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Integrated Inspection Report 05000397/2021003
	ML21300A182
Person / Time
Site:	Columbia
Issue date:	11/02/2021
From:	Jeffrey Josey; NRC/RGN-IV/DRP/RPB-A
To:	David Brown; Energy Northwest
References
	IR 2021003
	Download: ML21300A182 (30)
	v • d • e

November 2, 2021

SUBJECT:

COLUMBIA GENERATING STATION - INTEGRATED INSPECTION REPORT 05000397/2021003

Dear Mr. Brown:

On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On October 7, 2021, the 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 of these 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.

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 Docket No. 05000397 License No. NPF-21

Enclosure:

As stated

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2021003

Enterprise Identifier:

I-2021-003-0105

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, Washington

Inspection Dates:

June 28, 2021 to September 30, 2021

Inspectors:

P. Niebaum, Senior Resident Inspector

A. Donley, Resident Inspector

D. Antonangeli, Health Physicist

B. Baca, Health Physicist

J. Melfi, Project Engineer

J. O'Donnell, Senior Health Physicist

E. Simpson, Health Physicist

Approved By:

Jeffrey E. Josey, Chief

Reactor Projects Branch A

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 Follow Procedure Resulted in an Inadequate Operability Determination due to a Breach of Secondary Containment Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2021003-01 Open/Closed

[H.5] - Work Management 71111.15 The NRC inspectors identified a Green, non-cited violation (NCV) of Technical Specifications 5.4.1, Procedures, when the licensee failed to follow licensee procedure SOP-DOOR/HATCH-OPS, Reactor Building, Turbine Building, Radwaste Building and Containment Personnel, Equipment Access Area Doors, and Hatches, Revision 18, when the reactor building 606 foot roof access hatch was opened for maintenance on July 28, 2021. As a result, secondary containment was not declared inoperable while the access hatch was open.

Inadequate Maintenance Instructions when Performing Valve Diagnostic Testing Leads to Degraded Pipe Support Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2021003-02 Open/Closed

[P.1] -

Identification 71152 The NRC inspectors identified a Green, non-cited violation (NCV) of Technical Specification 5.4.1, Procedures, for failure to have adequate licensee procedural guidance and practices when performing diagnostic testing on reactor core isolation cooling (RCIC) valve RCIC-MO-76, which resulted in damage to pipe support RCIC-976S. The damage to the support occurred during diagnostic testing in a prior outage on the valve per work order 02110811-08 and maintenance procedure PPM 10.25.132, Thrust Adjustment and Diagnostic Analysis of Motor Operated Valves for valve RCIC-MO-76. Specifically, licensee personnel manually rotated and bent portions of pipe support RCIC-976S to enable access of a torque thrust cell onto valve RCIC-MO-76. This manual rotation bent tie rods on this support and caused the support to be out of alignment.

Additional Tracking Items

Type Issue Number Title Report Section Status LER 05000397/2021-001-00 LER 2021-001-00 for Columbia, Breach of Secondary Containment 71153 Closed

PLANT STATUS

Columbia Generating Station began the inspection period at 100 percent rated thermal power (RTP). On September 18, 2021, the unit was down powered to approximately 65 percent RTP for a control rod sequence exchange, a steam tunnel entry, and repairs to an adjustable speed drive channel. Columbia returned to RTP on September 20, 2021, and remained at or near RTP for the rest 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 on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion 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)reactor core isolation cooling system during the annual maintenance outage for the high pressure core spray system on July 27, 2021 (2)emergency diesel generator 1 while emergency diesel generator 2 was inoperable on August 20, 2021 (3)high pressure core spray during annual maintenance of the reactor core isolation cooling system on September 14, 2021 (4)standby service water system B following maintenance on September 24, 2021

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated system configurations during a complete walkdown of standby gas treatment system B following annual maintenance on September 30, 2021.

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 Areas DG-2/1, DG-1 diesel generator room; DG-8/1, DG-1 day tank room; and DG-4/1, DG-1 diesel oil storage tank access room; on August 10, 2021

(2) Fire Area RC-7, electrical equipment room number 2, on August 13, 2021

(3) Fire Area SW-2, standby service water pumphouse 1B, on August 30, 2021

(4) Fire Area RC-6/2, reactor core isolation cooling system pump room, on September 20, 2021

(5) Fire Area R-8, low pressure core spray pump room, on September 20, 2021

(6) Fire Area R1/1, standby gas treatment area, on September 29, 2021

Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated fire brigade performance during a fire drill on September 22, 2021.

71111.06 - Flood Protection Measures

Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated internal flooding mitigation protections in the residual heat removal pump C room on August 20, 2021

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 start of emergency diesel generator 1 on August 19, 2021, and during the load reduction from 100 percent power to 65 percent power on September 18, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated a licensed operator requalification evaluated scenario on July 20, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (2 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)staging and use of the FLEX C-3 air compressor during refueling outage 2R25 (2)leaking residual heat removal check valve RHR-V-122A

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)evaluation of station risk for extreme hot weather on July 1, 2021 (2)yellow risk for high pressure core spray system annual maintenance on July 29, 2021 (3)yellow risk for increased probability of a plant transient associated with maintenance on the turbine oil reservoir vapor extractors on August 4, 2021 (4)elevated plant risk for breach of secondary containment for steam tunnel entry on August 11, 2021 (5)evaluation of station risk during unavailability of emergency diesel generator 4, week of August 16, 2021 (6)yellow risk for reactor core isolation cooling equipment outage on September 14, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1)emergency diesel generators 1, 2, and 3 elevated intake air temperatures on July 14, 2021 (2)condition report (CR) 423467, emergency diesel generator 1 mixed air fan controller DMA-TIC-12/2 indicating low on July 23, 2021

(3) CR 423611, maintenance craft opened the reactor building roof access hatch on July 28, 2021

(4) CR 422728, RFW-V-65A packing leak could not be isolated after electric backseat on August 10, 2021 (5)failure of TSP-RCS-R803, division 3 high-low pressure interface valve leak test, for reactor core isolation cooling valve 66 on September 16, 2021 (6)degraded reactor core isolation cooling valve 1 latching mechanism components on September 28, 2021

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)

(1) The inspectors evaluated the temporary modification of RFW-V-65A when the licensee electrically back seated the valve to reduce a packing leak on July 1, 2021.

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1) OSP-HPCS/IST-Q701, HPCS system operability test, following a planned system outage on July 30, 2021

(2) OSP-CONT-M102, secondary containment integrity verification, with work order (WO) 02182918-23 on August 11, 2021

(3) OSP-FLEX-Q704, diesel generator 4 quarterly surveillance, following maintenance to restore operability on August 19, 2021

(4) OSP-ELEC-S702, diesel generator 2 semi-annual operability test, following corrective maintenance on August 21, 2021

(5) Procedure 10.7.5, RCIC turbine uncoupled overspeed test run, following maintenance to restore operability on September 16, 2021

(6) OSP-RCIC/IST-Q701, RCIC operability test, following a reactor core isolation cooling system equipment outage on September 17, 2021

(7) OSP-SW/IST-Q702, standby service water loop B operability, following preventive maintenance on September 20, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

Main article: IP 71111.22

(1) OSP-ELEC-S703, HPCS Diesel Generator Semi-Annual Operability Test, on July 30, 2021

(2) TSP-DG3/LOCA-B501, HPCS diesel generator DG3 LOCA test, on August 23, 2021

(3) OSP-ELEC-M702, diesel generator 2 - monthly operability test, on September 27, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) OSP-RHR/IST-Q702, RHR loop A operability test, on August 4, 2021

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 on August 31,

RADIATION SAFETY

71124.05 - Radiation Monitoring Instrumentation

Walkdowns and Observations (IP Section 03.01) (9 Samples)

The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:

(1)area radiation monitors and continuous air monitors in the reactor building, turbine building and radwaste buildings (2)high purity germanium detectors, HIDEX 300 SL liquid scintillation counter, iSOLO alpha counters in the chemistry count room

(3) GEM-5 and Argos contamination monitors at the chemistry break room, control room, and the radiologically controlled area exits

(4) SAM-12 tool monitors at the control room, radwaste building, and radiological controlled area exits

(5) AMP-100 used as a compensatory monitoring device for offgas pre-treatment monitor OG-RE-612 (6)friskers staged for use in the reactor, turbine, and radwaste buildings (7)telepoles and portable ion chambers used during survey observations (8)transmitting electronic alarming dosimeters used for dose rate tracking and trending at selected locations in the reactor building (9)portable air samplers used for monitoring working zones and perform grab samples

Calibration and Testing Program (IP Section 03.02) (15 Samples)

The inspectors evaluated the current calibration and testing of the following radiation detection instruments:

(1) Canberra ARGOS 5 A/Bs: HP-EQ-42782 dated June 24, 2021, HP-EQ-42783 dated June 24, 2021, HP-EQ-42820 dated May 3, 2021, HP-EQ-42879 dated May 3, 2021

(2) Canberra GEM 5s: HP-EQ-42733 dated May 3, 2021, HP-EQ-42734 dated May 3, 2021, HP-EQ-42737 dated August 3, 2020, and HP-EQ-42738 dated June 18, 2020

(3) Canberra iSolos: serial number (SN) 64111 dated July 2, 2020, SN 64112 dated July 2, 2020; iSolo-2: SN 3085836 dated January 25, 2021

(4) Eberline AMS-3 continuous air monitor: HP-EQ-34116 dated January 14, 2019; AMS-4 continuous air monitors: HP-EQ-42796 dated October 2, 2020, HP-EQ-42797 dated October 2, 2020, HP-EQ-42807 dated April 16, 2021, HP-EQ-42868 dated September 15, 2020

(5) Eberline ion chamber RO-2s: RO126 dated March 1, 2021, RO137 dated March 1, 2021, RO172 dated June 7, 2021, RO223 dated March 1, 2021; Ludlum Model 14C: RO264 dated February 24, 2021

(6) Eberline model ASP-1 RemBall: NO25 dated March 1, 2021

(7) Eberline RAS-1 air samplers: HP-EQ-32364, HP-EQ-42582, HP-EQ-42775, HP-EQ-42869 batch calibration dated April 19 - 22, 2021

(8) Fastscan whole body count system: WBC#2 dated July 23,2020;

(9) General Atomics high range area radiation monitors: ARM-RIS-32 dated July 1, 2021, ARM-RIS-34 dated April 6, 2020

(10) General Electric area radiation monitors: ARM-RIS-2 dated March 5, 2021, ARM-RIS-8 dated February 3, 2021, ARM-RIS-11 dated March 30, 2020, ARM-RIS-14 dated January 7, 2021, ARM-RIS-22 dated March 16, 2020 (11)high purity germanium gamma spectroscopy units: Ortec-5, Ortec-6, and Ortec-7 annual calibration verification under WO package 02123220-01 dated January 12, 2021

(12) Ludlum model 2 frisker: F175 dated April 27, 2021; Ludlum Model 177 friskers: F104 dated April 28, 2021, F119 dated April 28, 2021, F150 dated April 28, 2021, F160 dated April 29, 2021

(13) MGP AMP-100: RM-82 dated March 1, 2021

(14) Mirion telepole IIs: T093 dated March 1, 2021, T112 dated April 27, 2021; teletector model 6112M: T-070 dated March 1, 2021

(15) SAM12 small article monitors: HP-EQ-42713 dated June 30, 2021, HP-EQ-42813 dated February 25, 2021, HP-EQ-42814 dated February 25, 2021 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)

The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:

(1)reactor building elevated release radiation monitor PRM-RIS-1 (PRM-RE-11 stack monitor low range, PRM-RE-12 stack monitor intermediate range, and PRM-RE-13 stack monitor high range) calibration dated May 5,2021, with associated corrective actions (2)liquid radwaste effluent radiation monitor FDR-RIS-606 calibrations dated September 27, 2019, and April 23, 2021, with associated corrective actions (3)turbine building noble gas monitors TEA-RIS-12 low range calibration dated December 5, 2019, and TEA-RIS-13 high range calibration dated November 21, 2020, with associated corrective actions

71124.06 - Radioactive Gaseous and Liquid Effluent Treatment

Walkdowns and Observations (IP Section 03.01) (4 Samples)

The inspectors evaluated the following radioactive effluent systems during walkdowns:

(1)reactor building standby gas treatment system (2)turbine building effluent ventilation system (3)reactor building effluent ventilation system (4)radwaste building effluent ventilation system

Sampling and Analysis (IP Section 03.02) (3 Samples)

The inspectors evaluated effluent samples, sampling processes and compensatory samples, as available, for the following systems:

(1)weekly effluent sampling of particulate and iodine for the radwaste, turbine, and reactor building ventilation systems using procedure PPM 16.11.16, Weekly Iodine, Particulate, and Tritium Analysis (2)compensatory weekly effluent sampling of the particulate and iodine for the radwaste ventilation systems using procedure PPM 12.5.37, WEA Temporary Cart Sampling and Flow Monitoring (3)compensatory continuous/weekly effluent sampling system setup for the turbine building effluent ventilation systems using procedure PPM 12.5.35B, TEA Temporary Cart Sampling and Flow Monitoring

Dose Calculations (IP Section 03.03) (2 Samples)

The inspectors evaluated the following dose calculations:

(1)continuous gaseous release monthly dose assessment/analysis 2019 (November, April, May, June)

(2)continuous gaseous release monthly dose assessment/analysis 2020 (January, February, March)

Abnormal Discharges (IP Section 03.04)

There were no abnormal discharges during the monitoring period.

71124.07 - Radiological Environmental Monitoring Program

Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.

Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.

GPI Implementation (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated the licensees implementation of the groundwater protection initiative (GPI) program to identify incomplete or discontinued program elements.

There were no incomplete or discontinued program elements identified.

71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,

& Transportation

Radioactive Material Storage (IP Section 03.01)

Main article: IP 71124.08

Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials in the following areas:

(1)low specific activity (LSA) pad

(2) RW-167 container storage yard (3)high level storage area (NUPAC cage) on the 437 foot elevation of the radwaste building

Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)

Inspectors walked down accessible portions of these solid radioactive waste systems and evaluated the systems' configuration and functionality, to include:

(1)reactor water clean up filter demineralizer (2)equipment drain / floor drain polisher

Waste Characterization and Classification (IP Section 03.03) (3 Samples)

The inspectors evaluated the licensees characterization and classification of radioactive waste from the following:

(1)reactor water cleanup filter demineralizer powdered resin system (2)equipment drain / floor drain polishing bead resin system (3)dry active waste

Shipment Preparation (IP Section 03.04) (1 Sample)

(1) The inspectors observed that shipments containing differing forms of radioactive material (waste streams) were prepared according to requirements. The shipments included an LSA shipment (21-68) of dry active waste for burial and an LSA shipment (21-66) of dry active waste for processing.

Shipping Records (IP Section 03.05) (4 Samples)

The inspectors evaluated the following non-excepted radioactive material shipments through a record review:

(1)shipment # 19-114, LSA-II, condensate filter demineralizer (resin) liners 19-093-HP and 19-096-HP, dated December 18, 2019 (2)shipment # 20-01, type A LSA, equipment drain / floor drain filter demineralizer (tank 22 resin) liner 19-075-HP, category 2 quantity, dated January 16, 2020 (3)shipment # 20-29, type B, reactor water clean up (resin) liner 119-101-HP, category 2 quantity, dated August 13, 2020 (4)shipment # 21-68, LSA-II, consolidated dry active waste (trash) liner 19-107-OT, dated June 28,

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)===

Main article: IP 71151