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Biennial Problem Identification and Resolution Inspection Report 05000397/2021010
	ML21236A264
Person / Time
Site:	Columbia
Issue date:	08/29/2021
From:	Ami Agrawal; Division of Reactor Safety IV
To:	Schuetz R; Energy Northwest
References
	IR 2021010
	Download: ML21236A264 (17)
	v • d • e

SUBJECT:

COLUMBIA GENERATING STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000397/2021010

Dear Mr. Schuetz:

On July 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Columbia Generating Station. On August 2, 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.

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

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

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

Finally, the team reviewed the stations programs to establish and maintain a safety conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found that your organization appeared to have a safety conscious work environment where individuals felt free to raise concerns without fear of retaliation. Most expressed positive experiences after raising issues to their supervisors and documenting issues in condition reports, and all individuals indicated that they would not hesitate to raise safety concerns.

However, the team noted that several individuals brought up continuing morale concerns, consistent with the results of the previous problem identification and resolution inspection (NRC Problem Identification and Resolution Inspection Report 05000397/2019010). The team noted that if not addressed properly, these morale concerns could erode the individuals willingness to bring up safety concerns in the future.

No findings or violations of more than minor significance were identified during this inspection.

August 29, 2021 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, Ami N. Agrawal, Team Leader Inspection Programs & Assessment Team Division of Reactor Safety Docket No. 05000397 License No. NPF-21

Enclosure:

As stated

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2021010

Enterprise Identifier:

I-2021-010-0003

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, WA

Inspection Dates:

July 12, 2021 to July 30, 2021

Inspectors:

F. Ramirez Munoz, Senior Reactor Inspector (Team Lead)

H. Freeman, Senior Project Engineer

N. Greene, Senior Health Physicist

P. Niebaum, Senior Resident Inspector

R. Smith, Senior Resident Inspector

Approved By:

Ami N. Agrawal, Team Leader

Inspection Programs & Assessment Team

Division of or Reactor Safety

SUMMARY

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

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

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), inspectors were directed to begin tele-work. In addition, 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.

OTHER ACTIVITIES - BASELINE

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

Main article: IP 71152

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

Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors sampled over 220 condition reports and their associated cause evaluations, if applicable. The inspectors also conducted a five-year review of the high pressure core spray system and the emergency chilled water system, which included review of failures, maintenance issues, surveillances, corrective and preventive maintenance, reliability, and maintenance rule performance. In addition, the inspectors reviewed 16 findings and violations issued during the biennial period.

Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits, and self-assessments. The sample included industry operating experience communications like 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, publications from various industry groups, and site evaluations. The sample also included reviews of licensee self-assessments and internal audits.

Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety conscious work environment. The team interviewed 55 individuals, attended routine meetings, interviewed the Employee Concerns Program Manager, and reviewed employee concerns files.

INSPECTION RESULTS

Assessment 71152B Corrective Action Program Assessment

Based on the samples reviewed, the team determined that the licensees corrective action program complied with regulatory requirements and self-imposed standards. The licensees performance in each of the areas of Problem Identification, Problem Prioritization and Evaluation, and Corrective Actions adequately supported nuclear safety.

Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.

Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee correctly characterized each condition report as to whether it represented a condition adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.

In January 2021, the licensee began using the IBM Watson artificial intelligence system to pre-screen all condition reports instead of the departmental performance improvement specialists that had previously performed this task. The artificial intelligence system pre-screens the condition report to determine the priority (whether it represents a condition adverse to quality or not), category (A, B, C, D, etc.), and responsible department based upon program inputs. The inspectors noted that following the artificial intelligence pre-screen, 12 percent of condition reports needed to be corrected for priority and 14 percent of condition reports needed to be corrected for severity. However, the final determination review is still performed by the management review team and changes are incorporated back into the artificial intelligence algorithm. As such, the team did not identify any concerns with the licensees implementation of this pre-screening process.

Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. Specifically, the Columbia Generating Station developed effective corrective actions for the problems evaluated in the corrective action program and generally implemented these corrective actions in a timely manner commensurate with their safety significance. As part of this inspection, the team selected the plants high pressure core spray and emergency chilled water systems for a focused review within the corrective action program. For these systems, the team performed sample selections of condition reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective action process, and the corrective actions taken. The team did not identify any concerns with these systems that were not already being addressed by the station's monitoring and corrective action programs.

Assessment 71152B Use of Self-Assessment & Audits The team reviewed a sample of Columbia Generating Station's departmental self-assessments and audits to assess whether performance trends were regularly identified and effectively addressed. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an adequate departmental self-assessment and audit process.

Assessment 71152B Operating Experience The team reviewed a variety of sources of operating experience including NRC generic communications, and publications from various industry groups, such as the Nuclear Energy Institute (NEI) and Electric Power Research Institute (EPRI). The team determined that the Columbia Generating Station is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.

Assessment 71152B Safety Conscious Work Environment (SCWE)

The team conducted safety conscious work environment interviews with 55 employees from five different disciplines that included electrical maintenance, instrumentation and controls, mechanical maintenance, operations, and security. The purpose of these interviews was (1)to evaluate the willingness of the licensee staff to raise nuclear safety issues, either by initiating a condition report or by another method,

(2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems, and

(3) to evaluate the licensee's safety conscious work environment (SCWE). The team also observed interactions between employees during routine daily production meetings, operational focus meetings and management condition report review meetings. The team interviewed the Employee Concerns Program Manager and reviewed the results of the latest safety culture surveys and a sample of case files that may relate to safety conscious work environment.

The team found that the licensee had a safety conscious work environment where individuals felt free to raise concerns without fear of retaliation. Most expressed positive experiences after raising issues to their supervisors and after documenting issues in condition reports, and all individuals indicated that they would not hesitate to raise safety concerns, through at least one of the several means available at the station. Based on feedback from these interviews regarding anonymous condition reports, the station should consider enhancing communications with plant personnel so that it is better understood how anonymous condition reports are treated. Additionally, the team noted that several individuals brought up continuing morale concerns, particularly mechanical maintenance, electrical maintenance and instrument and controls. These morale concerns appear to be caused by union contract negotiations and arbitration and its impact on the relationship between the staff and senior management. The team noted that the morale concerns are consistent with the results of the previous problem identification and resolution inspection (NRC Problem Identification and Resolution Inspection Report 05000397/2019010) and if not addressed properly could erode the individuals willingness to bring up safety concerns in the future.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On August 2, 2021, the inspectors presented the biennial problem identification and resolution inspection results to Robert Schuetz and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - Columbia - 2021010
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \| 26 \|
2021 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) 11(0) 12(0) 13(0) 90(0) Security 401(0) 402(0) 420(0) 401(0) Operator Exams 301(0) Emergency Planning Other

IR 05000397/2021010