IR 05000397/2021002
| ML21209A537 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/02/2021 |
| From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
| To: | Hettel G Energy Northwest |
| References | |
| IR 2021002 | |
| Download: ML21209A537 (36) | |
Text
August 2, 2021
SUBJECT:
COLUMBIA GENERATING STATION - INTEGRATED INSPECTION REPORT 05000397/2021002
Dear Mr. Hettel:
On June 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On July 14, 2021, NRC inspectors discussed the results of this inspection with you, and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Both findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
A licensee-identified violation, which was determined to be of very low safety significance, is documented in this report. We are treating this violation as an NCV consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Columbia Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Columbia Generating Station. 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-2021-002-0104
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, Washington
Inspection Dates:
April 01, 2021, to June 30, 2021
Inspectors:
N. Hernandez, Acting Senior Resident Inspector
L. Merker, Acting Senior Resident Inspector
P. Niebaum, Senior Resident Inspector
A. Donley, Resident Inspector
D. Antonangeli, Health Physicist
B. Baca, Health Physicist
S. Makor, Reactor Inspector
J. Melfi, Project Engineer
E. Simpson, Health Physicist
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. A licensee-identified NCV is documented in the Inspection Results Section under IP 71111.1
List of Findings and Violations
Failure to Install an Adequate Pressure Hose in Support of the Reactor Pressure Vessel Leak Test Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000397/2021002-01 Open/Closed
[H.12] - Avoid Complacency 71111.20 A Green, self-revealed violation of 10 CFR 50 Appendix B, Criterion V, Instructions,
Procedures and Drawings, was identified on June 11, 2021, when the licensee failed to follow licensee procedure OSP-RPV-R801, Reactor Pressure Vessel Leakage Test, Revision 33 and Work Order (WO) 02144095 task 18. Specifically, a mechanical jumper (hose) used to support the reactor pressure vessel (RPV) leak test was installed, but it was not the correct pressure rating listed in the WO instructions. As a result, the hose ruptured at approximately 760 psi, RPV pressure, which led to an uncontrolled drop in RPV pressure until the ruptured hose was isolated.
Inadequate Scaffold Procedure Results in Scaffold Installed Without Adequate Engineering Evaluation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2021002-02 Open/Closed
[H.11] -
Challenge the Unknown 71152 The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B,
Criterion V, Instructions, Procedures, and Drawings, because Energy Northwest did not ensure procedures were in place to adequately direct the conduct of evaluations of temporary scaffolding constructed in the vicinity of safety-related components. Specifically, NRC inspectors identified that scaffolds erected with clearances of less than two inches to safety-related equipment were not consistently receiving engineering evaluations, engineering evaluations that were conducted were inadequate in scope, and records were not maintained to demonstrate the engineering basis of those evaluations. As a result, the site had an inconsistent process that either failed to perform engineering evaluations or performed inadequate engineering evaluations that were not documented.
Additional Tracking Items
None.
PLANT STATUS
Columbia Generating Station began the report period at 96 percent rated thermal power (RTP),coasting down for a planned refueling outage (RFO). Columbia reached 84 percent RTP before shutting down on May 8, 2021, for the RFO. Columbia started up the reactor on June 16, 2021, synchronized and tied the main generator to the electrical grid on June 20, 2021, ending the outage. The station achieved 100 percent RTP on June 20, 2021, and remained at that power level through the end of the report 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 Disease 2019 (COVID-19),resident 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; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site 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
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal high temperatures for the following systems on June 2, 2021:
- standby service water system A
- standby service water system B
- transformer yard
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)high pressure core spray system on May 3, 2021 (2)residual heat removal system B while aligned for shutdown cooling on May 26, 2021 (3)standby service water system A following maintenance on May 26, 2021
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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 R-5, division 2 motor control center room, on April 8, 2021 (2)fire area R-5/1, residual heat removal system A pump room, on May 10, 2021 (3)fire area R-2/U, containment (drywell), on May 10, 2021 (4)fire area R-2, reactor building, on May 20, 2021 (5)fire area R-7/1, residual heat removal pump room C, on June 23, 2021
71111.08G - Inservice Inspection Activities (BWR)
BWR Inservice Inspection Activities Sample - Nondestructive Examination and Welding
Activities (IP Section 03.01)
- (1) The inspectors verified that the reactor coolant system boundary, reactor vessel internals, risk-significant piping system boundaries, and containment boundary are appropriately monitored for degradation, and that repairs and replacements were appropriately fabricated, examined and accepted by reviewing the following activities from May 18-21, 2021:
03.01.a - Nondestructive Examination and Welding Activities.
The inspectors evaluated nondestructive examination activities by observing the following activities:
a) Ultrasonic Examinations i) reactor recirculation control, nozzle 1B, nozzle to vessel and inner radius welds, (Report R-R25-034)ii) reactor recirculation control nozzle 2A, AAFE end to nozzle, (Report APR-R23-01)iii) reactor recirculation control nozzle 2A, nozzle to vessel, (Report AVR-R24-02)iv) reactor coolant isolation cooling, 10-RCIC (12)-2 pipe to elbow, (Report R-R25-029)v) reactor coolant isolation cooling, 10-RCIC (12)-3 elbow to pipe, (Report R-R25-028)vi) reactor coolant isolation cooling, 10-RCIC (12)-10A pipe to pipe, (Report R-R25-031)vii) reactor coolant isolation cooling, 10-RCIC (12)-13 pipe to elbow, (Report R-R25-030)
b) Radiographic Examinations i) reactor water cleanup spool piece welds for MD valve 71/72
c) Visual Examinations i) main steam head vent piping bolting, MS-RPV-3 (Report 5-21-8-1)ii) reactor in-vessel visual examination of jet pump 17/18 riser iii) reactor core isolation cooling strut RCIC-1C-13, (Report 4HV-197)iv) reactor core isolation cooling strut RCIC-1C-2, (Report 4HV-198)v) reactor core isolation cooling spring can RCIC-61, (Report 4HV-199)vi) reactor core isolation cooling spring can RCIC-66, (Report 4HV-200)
The inspector reviewed and evaluated the following welding activities:
a) Gas Tungsten Arc Welding i) main steam lines startup drain isolation motor operated valve MD-V-71 and MD-V-72 replacement, weld records 2-14279 and 2-14264
b) Shielded Metal Arc Welding i) pipe to RWCU-HX-1C weld per EC 16475, weld record 2-14158
Problem Identification and Resolution review of Inservice items
The inspector evaluated a sample of 25 condition reports associated with inservice inspection activities. No findings or violations of more than minor significance were identified.
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 the refueling outage for reactor cavity drain down, reactor pressure vessel leak test, the associated pre-job briefs, and performance of control rod drive scram testing June 8 - 12, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated the licensed operator requalification program evaluated simulator scenario (Crew F) on April 13, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated the effectiveness of Division 1 4kV bus (SM-7) outage maintenance to ensure the structures, systems, and components remained capable of performing their intended function on June 3, 2021.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (4 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)residual heat removal system A out-of-service, on April 26, 2021 (2)planned switchyard maintenance with standby diesel generator 3 out-of-service on April 28, 2021 (3)yellow risk for planned switchyard maintenance on April 30, 2021 (4)yellow risk for loss of reactor building ventilation on May 16, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)residual heat removal system A following inservice inspection identification of four indications in one-of-four seismic restraints on April 12, 2021 (2)residual heat removal system A gas intrusion on April 12, 2021 (3)damage to reactor core isolation cooling system pipe support RCIC-976S on May 18, 2021 (4)standby service water pumps A and B following temporary scaffolding placement error on June 2, 2021 (5)evaluation of reactor coolant system pressure boundary integrity following a heatup transient on June 16, 2021
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
(1)reactor protection systems trip system B following logic board replacement on May 7, 2021 (2)18.1.7, SW-P-1A baseline test, following replacement of the 1A standby service water pump motor on May 24, 2021
- (3) TSP-RCS-R802, Division 2 high-low pressure interface valve leak test, following corrective maintenance for residual heat removal valve RHR-V-8 on June 10, 2021
- (4) TSP-CEP/X67-R802; LLRT of CEP-V-3A, CEP-V-3B, CEP-V-4A, CEP-V-4B; following maintenance of containment exhaust purge valves CEP-V-3A and CEP-V-4A on June 22, 2021
71111.20 - Refueling and Other Outage Activities
Refueling/Other Outage Sample (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated refueling outage R25 activities from May 8, 2021, to June 19, 2021.
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) ISP-MS-X309, turbine trip valve closure and turbine governor valve fast closure trip bypass testing, on April 7, 2021
- (2) SOP-RWM-START, rod worth minimizer testing, on May 7, 2021
- (3) TSP-DG1/LOCA-B501, standby diesel generator 1 loss-of-coolant accident test, on May 10, 2021
- (4) OSP-RPV-R801, reactor pressure vessel leakage test, on June 12, 2021
- (5) TSP-CRD-C101, control rod drive scram timing with auto scram timer system, on June 21, 2021
Inservice Testing (IP Section 03.01) (1 Sample)
- (1) ESP-SW/IST-Q701, standby service water system temperature control valve 11A operability, on April 20, 2021
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) TSP-RHR/X-11B-C801, local leak rate test of residual heat removal valves 16B and 17B, on June 7, 2021
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the emergency planning drill (Emergency Response Organization Team B) on April 6,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated how the licensee-identified the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assessed radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
The inspectors evaluated instructions to workers including radiation work permits (RWPs)used to access high radiation areas.
- (1) The inspectors reviewed the following:
Radiation Work Packages
- RWP 30004739, Dryer Separator Pit Entry **Locked High Radiation Area (LHRA)**, Revision 0
- RWP 30004661, Dry Well/Steam Tunnel In-service Inspection/Non-destructive Examination/Flow Accelerated Corrosion Program and Support
- LHRA**, Revision 1
- RWP 30004704, Dry Well Reactor Recirculation System Motor Replacement/Work **LHRA**, Revision 2
Electronic Alarming Dosimeter Alarms
- Accumulated dose alarm - a worker received an alarm while working in the radiologically controlled area (RCA) and not properly monitoring exposure.
- Dose rate alarm - a carpenter received an unanticipated dose rate alarm of 52 mrem per hour on a RWP set-point of 50 mrem per hour while climbing a scaffold during an RCA entry. (AR-00418294)
- Accumulated dose alarm - a worker received an unexpected and unverified dose alarm. Dosimeter recorded dose rates were significantly higher than the area survey results and the dosimeters of two coworkers in the area. The dosimeter was taken out-of-service for calibration/repair. (AR-00417622)
Labeling of Containers
- two low specific activity individually tagged yellow bags of dry active Waste (DAW) on the rad waste building 437-foot elevation
- one 55-gallon drum of contaminated hoses on the reactor building 548-foot elevation
- one contaminated turbine bypass tool storage box on the reactor building dry well 501-foot elevation
- one low specific activity individually tagged yellow bag of DAW on the reactor building spent fuel pool area 606-foot elevation
Contamination and Radioactive Material Control (IP Section 03.03) (3 Samples)
The inspectors evaluated licensee processes for monitoring and controlling contamination and radioactive material. The inspectors performed the following:
(1)observed licensee conduct surveys of potentially contaminated equipment leaving the RCA and exiting high contamination areas in the dry well during the current refueling outage (2)evaluated the licensee's physical and programmatic controls for highly activated and contaminated materials stored within the spent fuel pool (3)walked down the storage locations for selected non-exempt radioactive sources listed in the licensee's Technical Specification Source Inventory:
- J.L. Shepherd Model 78-2M Calibrator (Cs-137)
- J.L. Shepherd Model 89 Mini Calibrator (Cs-137)
- J.L. Shepherd Portable Unit (Cs-137)
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated in-plant radiological conditions during facility walkdowns and observations of radiological work activities, to include areas with airborne or the potential for airborne radioactivity. The following activities and work packages were reviewed:
(1)decontamination of valve body and valve seat replacement of reactor feedwater-V-32B under RWP 30004706, Refueling Outage 25 (R25) Steam Tunnel Replace Seats on Reactor Feedwater Valve 32B **Hight Radiation Area**, Revision 0 (2)reactor recirculation pump maintenance activities under RWP 30004704, R25 drywell reactor recirculation motor replacement work **LHRA**, Revision 1 (3)reactor water cleanup (RWCU) heat removal heat exchanger maintenance activities under RWP-30004619, R25 Reactor Water Cleanup Pump Rooms and Mezzanine
- LHRA**, Revision 0
High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (4 Samples)
The inspectors evaluated licensee controls of the following High Radiation Areas and Very High Radiation Areas:
(1)rad waste building, 437-foot elevation, room C-111 shield wall door (2)rad waste building, 437-foot elevation, room C-113 shield wall door (3)rad waste building, 437-foot elevation, room C-115 shield wall door (4)rad waste building, 437-foot elevation, resin processing cage
Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 03.06) (1 Sample)
- (1) The inspectors evaluated radiation worker and radiation protection technician performance as it pertains to radiation protection requirements.
71124.02 - Occupational ALARA Planning and Controls
Implementation of ALARA and Radiological Work Controls (IP Section 03.03) (4 Samples)
The inspectors reviewed as low as reasonably achievable practices and radiological work controls.
- (1) RWP 30004639, R25 Dry Well/Valve Room/Steam Tunnel Health Physics Support,
- LHRA**, Revision 0
- (2) RWP 30004676, Wet Well/ Reactor Dive Inspection (Divers), **LHRA**, Revision 0
- (3) RWP 30004732, RWCU Heat Exchanger Room-Install New Heat Exchanger and Piping **LHRA**, Revision 0
- (4) RWP 30004706, R25 Steam Tunnel Replace Seals on RFW-V-32A & 32B **High Radiation Area**, Revision 0
Radiation Worker Performance (IP Section 03.04) (1 Sample)
The inspectors evaluated radiation worker and radiation protection technician performance during multiple activities.
- (1) These activities included:
- general worker activity within the dry well/wet well/steam tunnel on multiple tasks in lock high radiation areas
- pipe and hose removal for the RWCU heat exchanger replacement activity
- radiation protection coverage during multiple tasks within locked high radiation areas and when diving was occurring
- radiation worker practices within the dry well during the reactor recirculation system motor replacement activity
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (2 Samples)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
(1)control room emergency filtration system (2)technical support center filtration system
Temporary Ventilation Systems (IP Section 03.02) (2 Samples)
The inspectors evaluated the configuration of the following temporary ventilation systems:
(1)high efficiency particulate air ventilation for RFW-V-32A and RFW-V-32B valve seat replacement under RWP 30004706, R25 Steam Tunnel Replace Seals on RFW-V-32A & 32B **High Radiation Area**, Revision 0 (2)high efficiency particulate air ventilation for RWCU heat exchanger replacement piping removal under RWP 30004732, RWCU Heat Exchanger Room-Install New Heat Exchanger and Piping **LHRA**, Revision 0
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 03.04)===
- (1) June 1, 2020, through May 31, 2021
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 03.15) (1 Sample)
- (1) July 1, 2020 through March 31, 2021
PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 03.16) (1 Sample)
- (1) July 1, 2020, through March 31, 2021
71152 - Problem Identification and Resolution
Semiannual Trend Review (IP Section 02.02) (1 Sample)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends that might be indicative of a more significant safety issue. The inspectors performed an in-depth review of the licensees ability to identify issues regarding site scaffolding, evaluate each occurrence, and implement corrective actions; and documented one observation on May 19, 2021.
Annual Follow-up of Selected Issues (IP Section 02.03) (1 Sample)
- (1) The inspectors reviewed the licensees implementation of its corrective action program related evaluation of the standby liquid control level tank instrumentation design and corrective actions on June 10,
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.13 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: 10 CFR 50.65(a)(4), states in part, that before performing maintenance activities (including, but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. Contrary to the above, on March 30, 2021, before performing maintenance activities, operations and work control personnel failed to adequately assess and manage the increase in risk that resulted from the proposed maintenance activities. Specifically, during maintenance that transferred the power source of the backup transformer, E-TR-B, from the normal power source to a non-credited source (White Bluffs 115 kV line) the risk was classified as Paragon Green when it should have been Paragon Yellow. On March 30, 2021, at 0700 PST, operations declared the backup transformer inoperable but available and risk was Paragon Green.
Significance/Severity: Green. The inspectors evaluated the licensee-identified violation using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, dated October 16, 2020, Flowchart 1, Assessment of Risk Deficit, and determined the need to calculate the risk deficit to determine the significance of this issue. Upon request, the licensees probabilistic risk assessment group estimated the incremental core damage probability deficit to be approximately 8.5E-10. In accordance with Flowchart 1 in Appendix K, because the core damage probability deficit was less than 1E-6 and the incremental large early release probability deficit was less than 1E-7, the violation screened as having very low safety significance (Green).
Corrective Action References: 417786, 417799
Observation: Increase in Scaffolding Issues Identified 71111.15 The inspectors performed an in-depth review of the licensee's evaluation and corrective actions related to a potential trend increase of scaffolding issues. From January 1, 2021, to May 14, 2021, the licensee initiated 58 ARs related to scaffolding. The inspectors noted that 14 of the ARs documented clearance issues where scaffolding was built within two inches of site components, contrary to Plant Procedure Manual (PPM) 10.2.53, Scaffolding, Revision 49. The inspectors evaluated each clearance performance deficiency and determined the following:
- one AR documented a licensee-identified performance deficiency of minor safety significance
- two ARs documented NRC-identified performance deficiencies of minor safety significance
- one AR documented a licensee-identified finding of low safety significance (Green)that did not result in a violation any NRC requirements
- ten ARs documented NRC-identified performance deficiencies of low safety significance (Green) with four examples detailed in NCV 05000397/2021002-02
The inspectors assessed the licensee's problem identification threshold, evaluations, and corrective actions related to these ARs. In each instance, the licensee adequately followed site procedures to identify, evaluate, and correct the issue. The inspectors identified that the licensee was aware of the increasing trend of scaffolding issues and performed a site walkdown to identify any additional scaffolding issues but did not initiate an AR to document the results of the walkdown by the end of shift, contrary to PPM SWP-CAP-01, Corrective Action Program, Revision 44. The licensee initiated AR 416868416868to document this issue. The inspectors evaluated this performance deficiency and determined it was of minor safety significance.
Failure to Install an Adequate Pressure Hose in Support of the Reactor Pressure Vessel Leak Test Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events
Green NCV 05000397/2021002-01
[H.12] - Avoid Complacency 71111.20 Open/Closed
A Green, self-revealed violation of 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified on June 11, 2021, when the licensee failed to follow licensee procedure OSP-RPV-R801, Reactor Pressure Vessel Leakage Test, Revision 33 and WO 02144095 task 18. Specifically, a mechanical jumper (hose) used to support the reactor pressure vessel (RPV) leak test was installed, but it was not the correct pressure rating as listed in the WO instructions. As a result, the hose ruptured at approximately 760 psi RPV pressure, which led to an uncontrolled drop in RPV pressure until the ruptured hose was isolated.
Description:
On June 11, 2021, while the plant was in Mode 4, the licensee conducted the RPV leakage test in accordance with licensee procedure OSP-RPV-R801, Revision 33. At approximately 760 psi RPV pressure, the test was aborted when the control room received indications of lowering RPV pressure. The licensee determined that a mechanical jumper used to pressurize portions of the main feed system had ruptured in the main steam tunnel. The mechanical jumper was required to be installed per step 9.1.12 of licensee procedure OSP-PV-R801 and WO 02144095 task 18. According to the WO instructions, the licensee should have installed a 3000-psi rated hose between RFW-V-30A/31A and MS-V-25B/26B. The licensee determined the installed hose was rated for 300 psi. Before repeating the RPV leak test on June 12, 2021, the licensee updated the procedure to remove the need to install a mechanical jumper if the reactor water cleanup system (RWCU) was in service and returning to the reactor feed water piping. This method also exposes the feedwater piping to the RPV test pressure as the mechanical jumper was intended to do.
Corrective Actions: The licensee aborted the RPV leak test, then isolated and removed the ruptured pressure hose from the main steam tunnel. The licensee also revised licensee procedure OSP-RPV-R801 which removed the need to install a mechanical jumper if RWCU is in service and connected to the reactor feed water piping.
Corrective Action References: 421766
Performance Assessment:
Performance Deficiency: The failure to install an adequate hose per licensee procedure OSP-RPV-801 and WO 02144095 task 18 in support of the RPV leak test was a performance deficiency. As a result, on June 11, 2021, at approximately 760 psi RPV pressure, the hose ruptured (in the main steam tunnel) and the RPV leak test was aborted.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human Performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the ruptured hose resulted in an uncontrolled drop in RPV pressure (plant transient) during the RPV leak test and challenged the inventory control shutdown safety function.
Significance: The inspectors assessed the significance of the finding using Appendix G, Shutdown Safety SDP. The inspectors assessed this finding using IMC 0609, Appendix G, 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, dated March 1, 2020. The finding screened to Green, very low safety significance, when considering the Loss of Inventory (LOI) Initiator screening questions in Exhibit 2, Initiating Events Screening Questions. Specifically, this event would not result in a loss of the decay heat removal method in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less and was considered self-limiting leakage.
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools. The individual(s) involved with installing the hose failed to implement appropriate error reduction tools by not verifying the required pressure rating of the hose before it was installed.
Enforcement:
Violation: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, requires, in part, activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Licensee procedure OSP-RPV-R801, Reactor Pressure Vessel Leakage Test, Revision 33 and WO 02144095 task 18 prescribed the procedures for the RPV leak test performed on June 10, 2021. Section 9.1.12.a of the procedure required the installation of a mechanical jumper (hose) between RFW-V-30A/31A and MS-V025B/26B and WO 02144095 task 18 required installation of a 3000-psi rated hose between these valves.
Contrary to the above, from June 10, 2021 until June 11, 2021, the licensee did not accomplish the RPV pressure vessel leakage test, an activity affecting quality, in accordance with documented instructions and procedures. Specifically, the licensee installed a hose rated for 300-psi between RFW-V-30A/31A and MS-V-025B/26B in performance of the RPV pressure vessel leakage test. As a result, the hose ruptured at approximately 760 psi in the RPV and led to an uncontrolled drop in RPV pressure until the ruptured hose was isolated. The licensee captured this issue in their corrective action program as AR 421766421766and conducted the RPV leak test satisfactorily on June 12, 2021.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Scaffold Procedure Results in Scaffold Installed Without Adequate Engineering Evaluation Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems
Green NCV 05000397/2021002-02 Open/Closed
[H.11] -
Challenge the Unknown 71152 The inspectors identified a Green, non-cited violation of 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Energy Northwest did not ensure procedures were in place to adequately direct the conduct of evaluations of temporary scaffolding constructed in the vicinity of safety-related components. Specifically, NRC inspectors identified that scaffolds erected with clearances of less than two inches to safety-related equipment were not consistently receiving engineering evaluations, engineering evaluations that were conducted were inadequate in scope, and records were not maintained to demonstrate the engineering basis of those evaluations. As a result, the site had an inconsistent process that either failed to perform engineering evaluations or performed inadequate engineering evaluations that were not documented.
Description:
Temporary scaffolding installed in the plant must be controlled to ensure it is not installed too closely to safety-related equipment without an appropriate evaluation. During a seismic event, scaffolding installed too closely to safety-related structures, systems, and components (SSCs) can come into contact with that equipment, cause damage to it, and affect its safety function. Energy Northwest procedures control the installation and evaluation of temporary scaffolds at Columbia Generating Station. Licensee procedure SWP-DES-01, Plant Modification and Configuration Control, Revision 19, Section 3.5.8, states, in part, changes (e.g., setpoints, scaffolding, temporary shielding) should be procedurally controlled.
Such procedures should have Engineering review/verification, approval, and oversight to ensure design basis is maintained. Plant Program Manual (PPM) 10.2.53, Scaffolds, Revision 48, is the procedure used by site personnel to construct scaffolds in the plant. PPM 10.2.53, Section 4.3.4, states, in part, On identification of scaffold configurations outside of the generic configuration (Section 7.4.3), an engineering assessment is to be performed. PPM 10.2.53 does not place requirements on the scope, conduct, or record-keeping of the engineering evaluation, and does not ensure that scaffolding constructed in the vicinity of SSCs is appropriately evaluated in accordance with the site wide procedure requirements to provide reasonable assurance that temporary scaffolding will not impact safety-related equipment during a seismic event. The procedure allows for engineering evaluations to be performed over the telephone, which has led to incomplete and inconsistent engineering evaluations. The procedure includes a clearance requirement of 2 inches or greater that is intended to ensure the as-built scaffold configuration remains bounded by the site design basis seismic event in accordance with calculation CE-02-87-29, Seismic Requirements for Scaffolding, Revision 1. In the following examples, NRC inspectors determined that craft personnel did not understand when to contact engineering for evaluations, however, the engineering department also did not understand engineering evaluation standards or record-keeping requirements.
Example 1. On February 22, 2021, during a routine walkdown of the standby service water pump houses, the NRC resident inspectors noted that temporary scaffolds were erected around both standby service water pumps and that both scaffolds had horizontal support poles within 2 inches of the pumps. The NRC inspectors located the associated scaffold tags and noted that the engineering evaluation signatures were blank. PPM 10.2.53, Section 7.4.4.q, states, in part, If the two-inch minimum clearance cannot be maintained to safety-related equipment, contact engineering for an evaluation. When asked, the engineering department was unable to provide an evaluation for the as found condition as the craft did not recognize the need for the evaluation due to vague guidance in PPM 10.2.53, and never contacted the engineering department. The engineering department was unable to provide reasonable assurance that the service water pumps would remain operable during a seismic event and performed a calculation to demonstrate operability during the design basis seismic event. Engineering personnel drafted engineering change (EC) 18684 that provided reasonable assurance that the service water pumps would remain operable during the design basis seismic event.
Example 2. On March 2, 2021, during a routine walkdown of the residual heat removal (RHR)
C pump room, the NRC resident inspectors noted that temporary scaffolding was in contact with a tie rod/support on the pump suction line. The engineering evaluation signature on the scaffold tag was blank. When asked, the engineering department was unable to provide an evaluation for the as found condition as the craft did not recognize the need for the evaluation due to vague guidance in PPM 10.2.53, and never contacted the engineering department. Engineering personnel walked down the scaffolding, performed a qualitative review, and determined that a design basis seismic event would not impact the operation of the pump. Engineering department personnel signed the scaffold tag that the engineering evaluation had been completed but did not generate a record of the evaluation as PPM 10.2.53 does not require a record of the engineering evaluation outside of the initials on the tag. When asked to show the engineering basis for why the as-built scaffolding was bounded by the existing site scaffolding calculation, CE-02-87-29, Seismic Requirements for Scaffolding, Revision 1, the licensee was unable to provide any documentation that an adequate evaluation as required by SWP-DES-01 and PPM 10.2.53 was performed since engineering judgment was used to approve the as-built scaffold configuration.
Example 3. On March 16, 2021, during a routine walkdown of the RHR A pump room, the NRC resident inspectors noted that temporary scaffolding was in contact in two places with RHR pump A. The inspectors noted that the scaffold tag indicated that the engineering evaluation was completed and signed for via Telecom. When asked to provide the engineering evaluation for review, the engineering department informed the resident office that the initials on the tag constitute that an engineering evaluation was performed, but there was not a record to review as PPM 10.2.53 does not require a record of the engineering evaluation to be generated outside of the initials on the tag. The engineering department also indicated that it is common practice to have a scaffold builder describe the as-built scaffold over the phone and have that scaffold builder sign the tag as having a completed engineering evaluation. When asked how many points of contact were evaluated, what the aspect ratio of the as-built scaffold was, the size of the bays, and the number of joints on the scaffold, the engineering department was unable to answer those questions. When asked to review the personal notes for engineering evaluation approval, the licensee informed the residents that no notes existed. Engineering performed a walkdown of the pump and identified a third scaffold clearance less than 2 inches, and also identified a loose buckle. Engineering performed a qualitative review and determined the temporary scaffold would not impact operation of the pump during a design basis seismic event, but again did not generate a record to demonstrate the engineering basis for how the as-built scaffold is bounded by calculation CE-02-87-29 since engineering judgment was used to approve the as-built scaffold configuration.
Example 4. On May 17, 2021, during a routine walkdown of the high pressure core spray pump room, the NRC resident inspectors noted that a temporary scaffold was in contact with the pump motor grounding wire and within 2 inches of the pumps discharge piping. The inspectors noted that the scaffold tag was annotated that the engineering evaluation was approved, signed via Telecom. When asked to provide the engineering evaluation for review, the engineering department informed the resident office that the initials on the tag constitute that an engineering evaluation was performed, but there was not a record to review as PPM 10.2.53 does not require a record of the engineering evaluation to be generated outside of the initials on the tag. The engineering department also indicated that it is common practice to have a scaffold builder describe the as-built scaffold over the phone and have that scaffold builder sign the tag as having a completed engineering evaluation. The engineering department performed a walkdown of the HPCS pump room, found several loose planks that were not in accordance with PPM 10.2.53, performed a calculation for the loose planks, concluded that the clearance issues and loose planks would not impact the operation of the pump during a design basis event, and documented the results of the evaluation on a draft new form that was part of the PPM 10.2.53 procedure revision.
The licensee stated on March 23, 2021, in AR 417526417526 that there were deficiencies with procedure PPM 10.2.53, which make understanding procedure requirements difficult and that the procedure uses outdated seismic calculations that hamper the installation of Excell brand scaffold configurations in Seismic Category 1 areas of the plant. The licensee is in the process of revising PPM 10.2.53 to address these deficiencies.
Corrective Actions: The licensee reconfigured the temporary scaffolding around the standby service water pumps, corrected the loose buckle, performed an investigation template, and had engineers walk down and evaluate all of the clearances that were less than 2 inches.
The licensee has placed more stringent requirements on engineers performing evaluations and generated condition reports to track these items.
Corrective Action References: 416419, 416420, 417361, 412522, 413873, 414095, 416883, 416770, 416821, 416868, 416887, 417386, 417567, 417535, 417575, 417526, 417554, 417570
Performance Assessment:
Performance Deficiency: The failure to provide an adequate scaffold procedure that provided clear guidance for engineering evaluations when temporary scaffold is erected in close proximity to safety-related SSCs was a performance deficiency. The inspectors identified four examples of scaffolding within 2 inches of safety-related equipment that did not have an adequate engineering evaluation.
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. The performance deficiency was sufficiently similar to Inspection Manual Chapter 0612, Appendix E, example 3.g. Absent NRC intervention, the licensee did not have the procedural controls in place to prevent scaffolding from interfering with safety-related seismic targets. Specifically, the licensees practices of not informing the engineering department of clearances less than 2 inches to safety-related equipment, not performing adequate engineering evaluations (e.g., the use of engineering judgment and/or approving temporary scaffolds by telephonic communication and review), and failing to document the engineering basis for why the as-built configuration was bounded by the existing calculation may eventually result in scaffolds interfering with the operation of safety-related equipment during a seismic event.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) since it did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic event.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, when faced with scaffold construction that may not have met PPM 10.2.53 requirements, craft personnel assumed the scaffolds were adequate and did not contact the engineering department for an evaluation. When contacted by craft personnel, engineering department personnel assumed a walkdown of the as-built scaffolds was not required, assumed engineering judgment was an adequate engineering evaluation, and assumed a signature on the scaffold tag was justification for continued reasonable assurance of operability during a design basis seismic event.
Enforcement:
Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented procedures appropriate to the circumstances and shall be accomplished in accordance with those procedures.
Contrary to the above, the licensee did not ensure that procedures prescribing the construction and evaluation of temporary scaffolding in the vicinity of safety-related SSCs, activities affecting quality, were appropriate to the circumstances and accomplished in accordance with those procedures. Specifically, NRC inspectors identified four examples of temporary scaffolding that were erected within 2 inches of safety-related equipment without an adequate engineering evaluation directed by the applicable procedure, PPM 10.2.53, Scaffolds, Revision 48.
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 May 20, 2021, the inspectors presented the occupational radiation safety inspection results to Mr. R. Schuetz, Site Vice President, and other members of the licensee staff.
- On May 20, 2021, the inspectors presented the inservice inspection debrief inspection results to Mr. R. Schuetz, Site Vice President and other members of the licensee staff.
- On July 14, 2021, the inspectors presented the integrated inspection results to Mr. G. Hettel, Interim Chief Executive Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
ABN-SW
Service Water Trouble
015
Procedures
ABN-
TRANSFORMER
Transformer Abnormal Operation
28
Procedures
SOP-
HOTWEATHER-
Hot Weather Operations
007
Procedures
SOP-
WARMWEATHER-
Warm Weather Operations
017
Work Orders
2141151
Drawings
M-521-2
System Flow Diagram Residual Heat Removal Loop B
117
Drawings
M520
HPCS and LPCS Systems Flow Diagram
105
Procedures
1.3.29
Locked Valve Checklist
088
Procedures
SOP-HPCS-LU
HPCS Valve and Breaker Lineup
004
Procedures
SOP-HPCS-STBY
Placing HPCS in Standby Status
004
Procedures
SOP-RHR-LU
RHR System Valve and Breaker Lineup
009
Procedures
SOP-RHR-SDC
034
Calculations
FP-02-85-03
Combustible Loading Calculation
011
Corrective Action
Documents
Action Requests
(ARs)
419293
Fire Plans
Reactor 422
006
Fire Plans
Reactor 501
003
Fire Plans
Reactor 572
004
Procedures
1.3.10
Plant Fire Protection Program Implementation
036
Procedures
1.3.10A
Control of Ignition Sources
017
Procedures
1.3.10C
Control of Combustibles
2
Procedures
SOP-ENTRY-DW
Personnel Entry into Drywell
27
Procedures
SWP-FPP-01
Nuclear Fire Protection Program
008
71111.08G Corrective Action
Documents
Action Requests
(ARs)
2872, 393624, 403227, 403454, 405654, 405968,
408368, 408850,409044, 409642, 409808, 409824,
409930, 410217, 410242, 410929, 411795, 411809,
2412, 413063, 413900, 414023, 414044, 414216,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
415536, 416085, 416689
71111.08G Corrective Action
Documents
Resulting from
Inspection
Action Requests
(ARs)
419968, 419969
71111.08G Drawings
4HV-200, Visual
Examination Data
Sheet -
Component
Supports
RCIC - 66
05/23/2021
71111.08G Miscellaneous
ADAMS document
Columbia Generating Station - Approval for Relief Request
4ISI-09, Regarding Alternate Examination of Feedwater
Nozzles (EPID L-2020-LLR-0068) Accession No.
04/14/2021
71111.08G Miscellaneous
ADAMS Document
RFI Request for Columbia Generating Station ISI Inspection
(May 2021) Accession No. ML21068A284
03/04/2021
71111.08G Miscellaneous
ADAMS Document
Columbia Generating Station - Request to use a Provision
of a later Edition of the American Society of Mechanical
Engineers Boiler and Pressure Vessel Code,Section XI
(EPID L-2021-LLR-0015) Accession No. ML21061A211
03/25/2021
71111.08G Miscellaneous
ADAMS Document
Columbia Generating Station - Request to use a Provision
of a Later Edition of the ASME Boiler and Pressure Vessel
Code,Section XI (EPID L-2021-LLR-0015) Accession No.
03/25/2021
71111.08G Miscellaneous
Certificates of
Qualification
Qualification Certificates for Level II and III personnel
Various
71111.08G Miscellaneous
Licensee letter to
NRC
Fourth Ten-Year Interval Inservice Inspection (ISI) Program
4ISI-10, Request to use a Provision of a Later Edition of the
ASME Boiler and Pressure Vessel Code,Section XI
03/01/2021
71111.08G Procedures
ISI-4
Inservice Inspection Program Plan - Interval 4
004
71111.08G Procedures
NDE Special
Process Control
Instructions SPS-
7-3
Visual Inspection - Component Supports
2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.08G Procedures
NDE Special
Process Control
Instructions, SPS-
3-3
Liquid Penetrant Examination - Columbia Generating
Station - ISI
2
71111.08G Procedures
NDE Special
Process Control
Instructions, SPS-
7-1
Visual Examination
004
71111.08G Procedures
NDE Special
Process Control
Instructions, SPS-
7-4
Visual Examination of Containment
2
71111.08G Procedures
NDE Special
Process Control
Instructions, SPS-
7-5
In-vessel Visual Inspection of the RPV Internals (IVVI)
009
71111.08G Procedures
NDE Special
Process
Instructions, SPS-
4-3
Magnetic Particle Examination Columbia Generating Station
IS
2
71111.08G Procedures
Plant Procedures
Manual (PPM)
10.2.18
Maintenance Welding Program
019
71111.08G Work Orders
2116563, 02116563-01, 02116563-02, 02145058-01,
2145058-02, 02145907-01, 02145907-02, 02145907-03,
2145907-04, 02145907-05, 02149774-01, 02152608,
2152608-01, 02154006, 02154006-01, 02110811-01
71111.11Q Miscellaneous
Crew F Cycle 21-2 Critique Summary
04/12/2021
71111.11Q Miscellaneous
LR002518
Cycle 21-2 Evaluated Scenario
000
71111.11Q Procedures
13.1.1
Classifying the Emergency
049
71111.11Q Procedures
13.1.1A
Classifying the Emergency - Technical Bases
034
71111.11Q Procedures
OI-09
Operations Standards and Expectation
079
71111.11Q Procedures
OI-15
033
71111.11Q Procedures
OI-35
Conduct of Event Critiques and Operator Fundamentals
010
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71111.11Q Procedures
TDI-08
Licensed Operator Requalification Program
018
Corrective Action
Documents
Action Requests
(ARs)
419753, 419808, 419758
Procedures
ABN-ELEC-INV
20 VAC Critical Distribution System Failures
017
Procedures
SOP-ELEC-IN1-
IN-1 and E-US-PP Operations
005
Procedures
SOP-ELEC-IN1-
START
IN-1 Start
005
Procedures
SOP-ELEC-SM7-
MAINT
Removing/Restoring E-SM-7, E-SL-71, E-SL-73, and E-SM-
From/To Service
20
Work Orders
2146020
Calculations
ME-02-08-15
Determination of Allowable Volumes of Air/Gas in the RCIC
and ECCS Discharge Piping
003
Corrective Action
Documents
Action Requests
(ARs)
417799, 417786, 400346, 418184, 418190, 420012,
419750, 419729
Miscellaneous
Paragon Risk Assessment
04/28/2021
Miscellaneous
Control Room Logs, May 15-17, 2021
Procedures
1.3.68
Work Management Process
036
Procedures
1.3.76
Integrated Risk Management
060
Procedures
1.5.14
Risk Assessment and Management for
Maintenance/Surveillance Activities
043
Procedures
OI-53
Offsite Power
015
Procedures
RHR A Fill Verification
2
Procedures
SOP-ELEC-DIV1-
TEMPPOWER
Div. 1 Outage Temporary Power Installation/Removal
21
Procedures
SOP-ELEC-
PP7AA-MAINT
Removing/Restoring E-PP-7AA From/To Service
001
Work Orders
2137154, 29159087
Calculations
CE-02-87-29
Seismic Requirements for Scaffolding
001
Calculations
Scaffolding Closer than 2 Inches to SW-M-P1/A and SW-M-
P1/B
000
Calculations
ME-02-08-15
Determination of Allowable Volumes of Air/Gas in the RCIC
and ECCS Discharge Piping
003
Calculations
ME-02-92-43
Room Temperature Calculation for DG Building, Reactor
013
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Building, Radwaste Building and Service Water
Corrective Action
Documents
Action Requests
(ARs)
419968, 418105, 418184, 418190, 417140, 416419,
416420, 417361, 412522, 413873, 414095, 416883,
416887, 419968, 421579
Drawings
Containment Composite Plan at EL 545-6
G
Drawings
AED STL S777
Structural Reactor Building Radial Plans, Sheet 1
2
Drawings
AED STL S797
Structural Reactor Building Containment Vessel, Sheet 4
018
Drawings
AED STL S801
Structural Containment Vessel, Sheet 8
25
Drawings
RCIC-668-1-2
RHR Condensing Mode Steam Supply RHR-HX-1A & RHR-
HX-1B
014
Engineering
Changes
18679
ME-02-92-43, EC 16619 Chiller Analysis Revision
000
Engineering
Changes
18733
Engineering Evaluation for RHR-HX-1A Upper Restraint
Indication
000
Engineering
Changes
18736
Engineering Evaluation for Voids in RHR System A
000
Engineering
Evaluations
Evaluation of RCIC-976S Pipe Support and RCIC(12)-4 CL-
Piping
000
Engineering
Evaluations
Evaluate RCPB Integrity per ASME Code Requirements
Following a Heatup Transient in Mode 2, Cycle 26 Startup
from R25
000
Miscellaneous
Technical Issue Resolution - Excessive Voids in RHR-SYS-
A
04/11/2021
Miscellaneous
4-21-21-1
Ultrasonic Thickness Measurement Data Sheet
04/11/2021
Miscellaneous
CNF-ISI-001
Customer Notification Form - 4RHR-006
04/07/2021
Procedures
1.3.66
037
Procedures
10.2.53
049
Procedures
RPV Heatup Surveillance
013
Procedures
RHR A Fill Verification
2
Procedures
TSP-CR/HVAC-
B101
Control Room AC Heat Load Capacity Test - Div 1
009
Work Orders
2149770, 29159159, 29159087, 02147565, 02169565
Corrective Action
Documents
Action Requests
(ARs)
254077, 420412, 419581, 419773, 421649, 419710,
21804, 421875
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Drawings
EWD-15E-047
Electrical Wiring Diagram Reactor Protection System RPS-
PP-C72/P001 Circuit Breaker & Control Panel
011
Procedures
1.3.74
Repair Process
008
Procedures
10.2.235
Overhaul Procedure for Bettis NT520-SR2 and NT820-SR3
Spring Return Air Actuators
001
Procedures
10.24.241
Flow Makeup and Pressure Decay Leak Rate Testing
003
Procedures
10.24.242
High/Low Pressure Hydraulic Leak Rate Testing Water Cart
Operations
004
Procedures
ESP-EPA3B3D-
S901
Electrical Protection Assemblies RPS-EPA-3B and RPS-
EPA-3D-CFT/CC
014
Procedures
IST-4
Inservice Testing Program Plan, Fourth Ten-year Inspection
Interval
005
Procedures
TSP-CEP/X67-
R802
LLRT of CEP-V-3A, CEP-V-3B, CEP-V-4A, CEP-V-4B
2
Procedures
TSP-RCS-R802
Division 2 High-Low Pressure Interface Valve Leak Test
017, 018,
019
Work Orders
2136595, 02153579, 0215809844, 02107556, 02142984,
2081706, 02144009, 02180846
Calculations
NE-02-94-14
Calculation for Determination of Containment Integrated
Leak Rate from %day to SCCM
2
Corrective Action
Documents
Action Requests
(ARs)
419458, 419749, 419866, 420214, 420599, 420725,
20992, 420982, 420988, 421180, 421835, 422408,
395368, 398329
Drawings
Cycle 26 Core Map
Miscellaneous
R25 Outage Shutdown Safety Plan
000
Miscellaneous
Reactivity Control Plan May 2021 Cycle 25 EOC Shutdown
04/29/2021
Miscellaneous
0-RCIC-SYS/R25-
001
R25 RCIC Clearance
05/28/2021
Miscellaneous
POC 21-08
Plant Operations Committee (POC) Meeting Package 21-08 06/12/2021
Procedures
1.20.3
Outage Risk Management
013
Procedures
1.3.40
Outage Mode Change, Refueling Activity Readiness, and
ISFSI Activity Readiness Evaluation
28
Procedures
1.3.5
Reactor Trip Report
27
Procedures
1.3.64
Plant Clearance Order
2
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
1.3.76
Integrated Risk Management
060
Procedures
1.3.84
Reactivity Management Control
006, 007
Procedures
3.1.11
Final Feedwater Temperature Reduction
2
Procedures
3.1.2
Reactor Plant Startup
089
Procedures
3.2.1
Normal Plant Shutdown
096
Procedures
3.3.1
Reactor Scram
066
Procedures
6.3.2
Fuel Movement with the Refueling Bridge
27
Procedures
6.3.5
Full Core Verification
013
Procedures
9.3.12
Plant Power Maneuvering
037
Procedures
LLRT-01
Primary Containment Leakage Rate Testing Program
008
Procedures
OI-12
Clearance Order Instruction
057
Procedures
OMI-3.2
Shutdown Safety Plan Development and Approval Process
2
Procedures
Mode Switch Shutdown Position CFT
005
Procedures
SOP-CAVITY-
DRAIN
Reactor Cavity and Dryer Separator Pit Draining
011
Procedures
SOP-CR-
MOVEMENT
Control Rod Movement
005
Procedures
SOP-FPC-
ASSIST-ALT
Alternate Fuel Pool Cooling Assist
013
Procedures
SOP-MT-
SHUTDOWN
Main Turbine Shutdown
015
Procedures
SOP-MT-START
Main Turbine Start
030
Procedures
SOP-REFUEL-
Refueling Bridge Operations
2
Procedures
SWP-FFD-04
Work Hour Controls
009
Procedures
SWP-RXE-01
Reactivity Management Program
006
Procedures
TSP-CONT-R801
Containment Isolation Valve and Penetration Leak Test
Program
016
Work Orders
2143651, 02111609
Calculations
E/I-02-92-1070
Calculation for Setting Range Determination
001
Calculations
ME-02-17-02
Control Room Habitability During a LOCA with LOOP and
Emergency A/C Coils Aligned to Emergency Chillers (CCH)
000
Corrective Action
Action Requests
217444, 204656, 350866, 376348, 415425, 418083,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
(ARs)
395207, 326587, 328726
Drawings
EWD-15E-006
Reactor Protection System, Trip System A Sensor Relays
2
Drawings
M775
Emergency Chilled Water Piping System Control Room
Flow Diagram
030
Engineering
Changes
16840
ME-02-17-02 Rev. 0 Credit CCH for MCR Equipment
Operability (EC 16619)
000
Miscellaneous
Operator Logs: April 7 - 8, 2021
04/12/2021
Miscellaneous
Operator Logs: May 10, 2021
Miscellaneous
IST-4
Inservice Testing Program Plan Fourth Ten-year Inspection
Interval
005
Procedures
1.3.76
Integrated Risk Management
060
Procedures
10.24.241
Flow Makeup and Pressure Decay Leak Rate Testing
003
Procedures
ESP-SW/IST-
Q701
SW-TCV-11A Operability
011
Procedures
RPS and EOC Pump Trip - TTV Closure and TGV Fast
Closure Trip Bypass MS-PS-3C - CFT/CC
011
Procedures
Rod Worth Minimizer CFT Prior to Shutdown
007
Procedures
SOP-RWM-
START
Rod Worth Minimizer Start
007
Procedures
TSP-CRD-C101
CRD SCRAM Timing with Auto SCRAM Timer System
29
Procedures
TSP-DG1/LOCA-
B501
Standby Diesel Generator DG 1 LOCA Test
034
Work Orders
2159227, 02155656, 02155988, 02155989, 02148025,
2153566, 02144095, 02141951
Miscellaneous
Columbia Generating Station ERO Team B Drill Report
April 6, 2021 After Action Report / Improvement Plan
04/29/2021
Miscellaneous
24075
Columbia Generating Station Classification Notification
Form (CNF)
24
Miscellaneous
25665
Reactor Plant Event Notification Worksheet
004
Miscellaneous
25810
Energy Northwest Emergency Director Turnover Sheet
009
Miscellaneous
26045
Energy Northwest Emergency Classification or Other
Emergency Messages Form
036
Miscellaneous
26050
Energy Northwest Public Address Emergency Message for
Protected Area Evacuation Form
014
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
26051
Energy Northwest Public Address Emergency Message for
Site Evacuation Form
013
Miscellaneous
26501
Energy Northwest Shift Manager Checklist
007
Procedures
13.1.1
Classifying the Emergency
049
Procedures
13.1.1A
Classifying the Emergency - Technical Bases
034
Procedures
13.10.1
Control Room Operation and Shift Manager Duties
035
Procedures
5.1.1
RPV Control
2
Procedures
5.1.2
26
Corrective Action
Documents
Action Requests
(ARs)
00393990, 00393998, 00394064, 00394156, 00394272,
00394339, 00394432, 00394579, 00395067, 00395167,
00395232, 00395272, 00396413, 00396632, 00398991,
00400349, 00401039, 00401200, 00401615, 00403346,
00404722, 00406957, 00409248, 00409249, 00412778,
00414240, 00415055, 00415317, 00415351, 00415546,
00415859, 00416044, 00416339, 00416544. 00416546,
00417622, 00418272, 00418294, 00418921, 00418922
Corrective Action
Documents
Resulting from
Inspection
Action Requests
(ARs)
00419864, 00419865, 00419871, 00420075
Procedures
HPI-0.19
Radiation Protection Standards and Expectations
019
Procedures
HPI-4.30
Processing, Evaluation, and Reporting of Dosimetry of
Legal Record Exposure Data
017
Procedures
HPI-4.8A
Routine Exchange of Personnel Dosimetry of Legal Record
25
Procedures
HPI-6.4
Administering and Occupational Radiation Exposure History
File
26
Procedures
PPM 11.2.13.1
Radiation and Contamination Surveys
044
Procedures
PPM 11.2.13.8
Airborne Radioactivity Surveys
21
Procedures
PPM 11.2.6.1
Issuance and Retrieval of Personnel Dosimetry
28
Procedures
PPM 11.2.6.7
Special Dosimetry
20
Procedures
PPM 11.2.7.1
Area Posting
045
Procedures
PPM 11.2.7.3
High Radiation Area, Locked High Radiation Area, and Very
High Radiation Area Controls
044
Procedures
PPM 6.1.1
Spent Fuel Pool Inventory
010
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
PPM GEN-RPP-04 Entry Into, Conduct In, and Exit from Radiologically
Controlled Areas
035
Procedures
PPM GEN-RPP-06 Dosimetry Program Description
015
Procedures
SWP-RPP-01
Radiation Protection Program
016
Radiation
Surveys
M-20210518-26
Reactor Building 548' Elevation Reactor Water Clean Up
Heat Exchanger Room
05/18/2021
Radiation Work
Permits (RWPs)
30004650
Refueling Outage Number 25 Dry Well Minor
Maintenance/Setup/Surveillances **LHRA**
001
Radiation Work
Permits (RWPs)
30004661
Refueling Outage Number 25 In-service Inspection Locked
High Radiation Work - Nondestructive Examination/In-
service Inspection/Weld Cleaning Dry Well & Steam Tunnel
001
Radiation Work
Permits (RWPs)
30004704
Refueling Outage Number 25 Dry Well Reactor
Recirculation Pump Motor Replacement/Work **LHRA**
2
Self-Assessments AR-SA 413680-01
Energy Northwest Snapshot Self-Assessment Report
03/20/2021
Self-Assessments AR-SA 414739
Energy Northwest Snapshot Self-Assessment Report
04/04/2021
Self-Assessments AU-RP/RW-20
Quality Services Audit Report Radiation Protection and
2/16/2020
ALARA Plans
RWP 30004649
R25 Drywell Steam Tunnel Shielding ALARA Plan
001
ALARA Plans
RWP 30004661
R25 Drywell & Steam Tunnel ISI/Flow Accelerated
Corrosion and Support ALARA Plan
000
ALARA Plans
RWP 30004704
R25 Drywell Reactor Recirculating Motor
Replacement/Work **LHRA** ALARA Plan
000
ALARA Plans
RWP 30004706
R25 Steam Tunnel Replace Hard Seats on RFW-V-32A &
2B **High Radiation Area** ALARA Plan
000
ALARA Plans
RWP 30004732
R25 RWCU Heat Exchanger Replacement Project ALARA
Plan
000
Corrective Action
Documents
Action Requests
(ARs)
00402861, 00416924, 00413985, 00416972, 00405197,
00408948, 00405192, 00410826, 00405193, 00411143,
00405201, 00411316, 00405207, 00416546, 00405207,
00412778, 00404667, 00419954
Miscellaneous
Energy Northwest
ALARA In-
Progress Review
Job Description: R25 Steam Tunnel Replace Seals RFW-V-
2A/B **High Radiation Area**
05/24/2021
Miscellaneous
Energy Northwest
Job Description: Cut existing pipe. Install/Remove plugs &
05/15/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ALARA In-
Progress Review
hoses - Reactor Building 548' elevation - RWCU Heat
Exchanger
Miscellaneous
Energy Northwest
ALARA In-
Progress Review
Job Description: R25 Wet Work In-vessel, Spent Fuel Pool,
and Dryer Separator Pit **HRA**
05/27/2021
Miscellaneous
Evaluation
RWP 30004739-PAPR Use TEDE ALARA Evaluation
04/27/2021
Miscellaneous
Evaluation
RWP 30004690- PAPR Use TEDE ALARA Evaluation
05/05/2020
Procedures
PPM 11.2.2.11
Exposure Evaluations for Maintaining TEDE ALARA
009
Procedures
PPM 11.2.2.12
Radiological Risk Assessment and Management
008
Procedures
PPM 11.2.2.13
Flushing and Shielding Evaluations
2
Procedures
PPM 11.2.2.14
Radiological Planning and Reviews
007
Procedures
PPM 11.2.2.7
ALARA Procedure Analysis
2
Procedures
PPM 11.2.2.8
ALARA Engineering Analysis
007
Procedures
PPM 11.2.8.2
Radiation Worker Permit Preparation and Use
003
Procedures
PPM GEN-RPP-
ALARA Program Description
009
Procedures
PPM GEN-RPP-
Radiological Planning and Control Process
034
Procedures
PPM GEN-RPP-
Senior Site ALARA Committee
014
Procedures
PPM GEN-RPP-
Control of Temporary Shielding
016
Radiation
Surveys
M-20210518-26
Reactor Building 548' Elevation Reactor Water Clean Up
Heat Exchanger Room
05/18/2021
Radiation
Surveys
M-20210520-18
Reactor Building 548' Elevation High Radiation Area
Boundary Expansion
05/20/2021
Radiation Work
Permits (RWPs)
30004639
R25 Drywell/Valve Room/Steam Tunnel Health Physics
Support **LHRA**
000
Radiation Work
Permits (RWPs)
30004676
R25 Wetwell/Reactor Dive Inspection (Divers) **LHRA/High
Risk Activity**
000
Radiation Work
Permits (RWPs)
30004690
20 Reactor Building 548'/572' Elevation Pipe Cutout and
Flush of DSP Drain Line
001
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Radiation Work
Permits (RWPs)
30004704
R25 Drywell Reactor Recirculation Motor
Replacement/Work **LHRA**
2
Radiation Work
Permits (RWPs)
30004706
RF 25 Steam Tunnel Replace Hard Seats on RFW-V-32A &
2B
000
Radiation Work
Permits (RWPs)
30004732
RWCU Heat Exchanger Room-Install New Heat Exchanger
and Piping (LHRA)
000
Radiation Work
Permits (RWPs)
30004739
21 Reactor Building 606' Elevation Dryer Separator Pit
Entry **LHRA**
000
Self-Assessments Energy Northwest
Snapshot Self-
Assessment
Report
Pre-inspection (71124.02) ALARA Snapshot Self-
assessment
2/28/2020
Self-Assessments Energy Northwest
Snapshot Self-
Assessment
Report
Annual Review of Columbia Generating Station Radiation
Protection Program to meet 10 CFR 20.1101(c)
requirements.
04/04/2021
Calibration
Records
300300444
CL-8030 Clean and Calibrate Model 8030 PortaCount Pro
Respirator Fit Tester: Serial Number 8030123705
10/20/2020
Corrective Action
Documents
Action Requests
(ARs)
00400325, 00400333, 00400691, 00403946, 00404472,
00412409, 00404716, 00416544, 00416546, 00417403
Miscellaneous
Breathing Air Sample Analysis: SCBA Air Compressor
03/18/2020
Miscellaneous
Breathing Air Sample Analysis: Oxarc Specialty Gas
Division
2/05/2020
Procedures
GEN-RPP-05
Respiratory Protection Program Description
015
Procedures
GEN-RPP-10
Use of Respiratory Protection Equipment
2
Procedures
HPI-15.1
Inspection and Storage of Respirators and Attachments
2
Procedures
HPI-8.2
Quantitative Respirator Fit Testing Using PortaCount
System
29
Procedures
HPI-8.4
Respirator Facepiece Cleaning and Disinfection
004
Procedures
MSP-WMA-B101
Control Room DIV A Emergency Filtration System HEPA
Filter Test
010
Procedures
PPM 10.2.62
Breathing Air Compressor Operation
011
Procedures
PPM 10.2.82
HEPA Filter In-Place Testing
008
Procedures
PPM 10.2.83
Carbon Filter In-Place Testing
009
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
PPM 11.2.11.3
Issuance of Respiratory Protection Equipment
017
Procedures
PPM 12.5.36
Service Air Sampling
005
Procedures
SWP-RPP-01
Radiation Protection Program
016
Self-Assessments AR-SA 00402740
Snapshot Self-Assessment: Control of in-plant airborne
concentrations
2/06/2020
Self-Assessments AR-SA 00415897
Snapshot Self-Assessment: Control of in-plant airborne
concentrations
2/26/2021
Self-Assessments AR-SA 378162
Focused Self-Assessment Report: Respiratory Protection
Program
03/12/2020
Self-Assessments AU-RP/RW-19
Quality Services Audit Report: Radiation Protection and
2/12/2019
Self-Assessments AU-RP/RW-20
Quality Services Audit Report: Radiation Protection and
2/16/2020
Work Orders
MSP-WMA-B104-WMA-FU-54B (B Control Room
Emergency Filter Unit)-Carbon Adsorber Test
09/22/2016
Work Orders
MSP-WMA-B102-WMA-FU-54B (B Control Room
Emergency Filter Unit)-HEPA Filter Test
09/22/2016
Work Orders
AMA-CF-52 (Technical Support Center Filtered Ventilation):
Replace the Carbon Filter. Replace Pre-Filter and HEPA
Filter as required. Perform filter In-Place Testing.
03/08/2018
Work Orders
MSP-WMA-B103-WMA-FU-54A (A Control Room
Emergency Filter Unit)-Carbon Adsorber Test
09/06/2018
Work Orders
MSP-WMA-B101-WMA-FU-54A (A Control Room
Emergency Filter Unit)-HEPA Filter Test
08/09/2018
Work Orders
MSP-WMA-B102-WMA-FU-54B (B Control Room
Emergency Filter Unit)-HEPA Filter Test
03/21/2019
Work Orders
MSP-WMA-B104-WMA-FU-54B (B Control Room
Emergency Filter Unit)-Carbon Adsorber Test
03/12/2019
Work Orders
MSP-WMA-B101-WMA-FU-54A (A Control Room
Emergency Filter Unit)-HEPA Filter Test
10/21/2020
Work Orders
MSP-WMA-B103-WMA-FU-54A (A Control Room
Emergency Filter Unit)-Carbon Adsorber Test
10/21/2020
Work Orders
Breathing Air Sample Analysis: SA-V-99/35
03/23/2020
Work Orders
AMA-CF-52 (Technical Support Center Filtered Ventilation):
06/29/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Replace the Carbon Filter. Replace Pre-Filter and HEPA
Filter as required. Perform filter In-Place Testing.
Work Orders
Breathing Air Sample Analysis: SA-V-100/58
10/26/2020
Work Orders
Breathing Air Sample Analysis: SA-V-99/35
01/25/2021
Work Orders
SA-C-1 1000 Hour Maintenance (CDR-1-1-12)
05/03/2021
Work Orders
Work Order (WO)
Monthly Fire Brigade Station Inventories:
2168171-05, 02168171-06, 02169517-05, 02169517-06,
2169519-05, 02169519-06, 02169521-05, 02169521-06
71151
Corrective Action
Documents
Action Requests
(ARs)
00404722, 00416805
71151
Miscellaneous
20 Annual Radioactive Effluent Release Report
04/15/2021
71151
Miscellaneous
Limiting Conditions for Operations Logs June 1, 2020 -
May 31, 2021
71151
Procedures
PPM 16.12.1
Liquid Release Dose Assessments
007
71151
Procedures
PPM 16.12.2
Monthly Gaseous Release Dose Assessment
016
71151
Work Orders
Monthly Gaseous Release Dose Assessment: January 2021 03/01/2021
71151
Work Orders
Liquid Release Dose Assessment: January 2021
03/01/2021
71151
Work Orders
Liquid Release Dose Assessment: February 2021
03/17/2021
71151
Work Orders
Monthly Gaseous Release Dose Assessment: February
21
03/17/2021
71151
Work Orders
Liquid Release Dose Assessment: March 2021
04/20/2021
71151
Work Orders
Monthly Gaseous Release Dose Assessment: March 2021
04/20/2021
Corrective Action
Documents
Action Requests
(ARs)
415576, 416145, 416419, 416420, 417361, 056200,
2522, 413873, 414095, 416883, 416887, 417361,
416523, 416770, 416821, 416868, 416887, 417386,
417526, 417554, 417570, 417567, 417535, 417575,
403227, 405968, 409930, 410242, 414216, 416689
Miscellaneous
2-02C41-05
Standby Liquid Control System
2
Miscellaneous
2-431-00
Reissue of O/M Manual for ST3000 Smart Transmitter &
SFC Smart Field Communicator
2
Miscellaneous
93-01
Customer Service Bulletin
06/07/1993
Miscellaneous
999-00, 199
SLC Tank Flow Indicating Controller Replacement
000
Miscellaneous
CVI 02-01, 1, 2
Part Equivalency Evaluation Sheet
2
Miscellaneous
SLC-FIC-4
Inst. Air Supply for SLC-TK-1 Level
006
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
SLC-LI-1
SLC-TK-1 Level Local Indication
008
Miscellaneous
SLC-LI-601
SLC-TK-1 Level Control Room Indication
009
Miscellaneous
SLC-LT-1
Storage Tank (SLC-TK-1) Level SLC
2
Procedures
10.2.53
049
Procedures
Shift and Daily Instrument Checks
094