IR 05000397/2022001
| ML22110A125 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/29/2022 |
| From: | Jason Kozal NRC/RGN-IV/DORS |
| To: | Schuetz R Energy Northwest |
| References | |
| IR 2022001 | |
| Download: ML22110A125 (25) | |
Text
April 29, 2022
SUBJECT:
COLUMBIA GENERATING STATION - INTEGRATED INSPECTION REPORT 05000397/2022001
Dear Mr. Schuetz:
On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On April 7, 2022, 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.
Three findings of very low safety significance (Green) are documented in this report. Two 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 or a finding not associated with a regulatory requirement 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, Jason W. Kozal, Chief Projects Branch A Division of Operating Reactor Safety Docket No. 05000397 License No. NPF-21
Enclosure:
As stated
Inspection Report
Docket Number:
05000397
License Number:
Report Number:
Enterprise Identifier:
I-2022-001-0012
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, Washington
Inspection Dates:
January 01, 2022, to March 31, 2022
Inspectors:
P. Niebaum, Senior Resident Inspector
A. Donley, Resident Inspector
N. Hernandez, Operations Engineer
Approved By:
Jason W. Kozal, Chief
Projects Branch A
Division of Operating Reactor Safety
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 Take Appropriate Maintenance Rule Corrective Actions for RHR-V-27B Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2022001-01 Open/Closed
[H.12] - Avoid Complacency 71111.12 The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(1) for failure to take appropriate action when containment isolation valve RHR-V-27B did not meet the performance criteria outlined the (a)(1) Performance Improvement Plan for the primary containment integrity and isolation (PCINT-PCISO) maintenance rule function. Specifically, not establishing corrective actions in 2019 for RHR-V-27B led to an additional primary containment integrity failure in 2021 and impacted overall containment performance when measured against the allowable leakage criteria.
Failure to Correct a Condition Adverse to Quality Associated with RFW-V-65A Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2022001-02 Open/Closed
[H.12] - Avoid Complacency 71111.12 A self-revealed Green, non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to promptly correct a condition adverse to quality with feedwater isolation valve RFW-V-65A. As a result, RFW-V-65A experienced a packing leak that began on June 24, 2021, contributing to the as-found local leak rate test valve failure on December 8, 2021.
Failure to Perform Functional Assessment for Degraded Leaking Plant Service Water Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000397/2022001-03 Open/Closed
[P.3] -
Resolution 71152A The inspectors identified a Green finding for failure to follow licensee procedure 1.3.66,
Operability and Functionality Evaluation, Revision 33, because the licensee failed to perform functionality assessments for degraded or non-conforming leaking plant service water (TSW)
Seismic II/1M class piping. Specifically, in 2017, the licensee identified through-wall leaks in TSW supply piping located in the overhead near the control room emergency chillers. In August of 2021, NRC inspectors identified that a functionality assessment addressing the potential impact to the control room chiller performance during a design-basis event had not been performed on the through-wall leaks in the TSW piping.
Additional Tracking Items
None.
PLANT STATUS
Columbia began the inspection period at 100 percent of rated thermal power (RTP). On February 5, 2022, the unit reduced power to 95 percent for maintenance on the adjustable speed drive system. During the maintenance, the 1A recirculation pump tripped and plant operators stabilized power at 65 percent. Following maintenance, the unit reduced power to 25 percent to restart the 1A recirculation pump. Plant operators raised reactor power following restoration of the 1A recirculation pump. On February 6, 2022, the unit achieved 100 percent RTP. On February 7, 2022, the unit reduced power to 85 percent to support control rod set activities. The unit returned to 100 percent on February 8, 2022. On February 21, 2022, the unit reduced power to 65 percent due to an oil leak on the 2B condensate booster pump. Following an investigation and corrective actions, the unit returned to 100 percent on February 23, 2022. On March 12, 2022, the unit reduced power to 82 percent for a control rod sequence exchange and returned to 100 percent later that day. The unit remained at 100 percent RTP for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, conducted routine reviews using IP 71152, Problem Identification and Resolution, observed risk-significant activities, and completed on site portions of IPs. 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
71111.01 - Adverse Weather Protection
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe weather during sustained high wind conditions on February 28, 2022.
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on March 16, 2022.
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)standby liquid control system B during the maintenance window for standby liquid control system A on January 5, 2022 (2)reactor core isolation cooling during the maintenance window for high pressure core spray diesel generator on January 27, 2022 (3)standby service water system A while standby service water system B was out-ofservice for maintenance on February 1, 2022 (4)emergency diesel generator 1 while emergency diesel generator 2 was inoperable on March 24, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 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-6, reactor core isolation cooling pump room, on January 25, 2022
- (2) Fire Area RC-2, cable spreading room, on January 28, 2022
- (3) Fire Areas RC-14 and RC-8, division 1 and division 2 switchgear rooms, on February 14, 2022
- (4) Fire Areas DG-2/1 and DG-8/1, diesel generator 1 room and associated day tank room, on March 23, 2022
71111.07A - Heat Exchanger/Sink Performance
Annual Review (IP Section 03.01) (1 Sample)
The inspectors evaluated readiness and performance of:
- (1) the 1A residual heat removal (RHR) heat exchanger on March 31, 2022
71111.11A - Licensed Operator Requalification Program and Licensed Operator Performance
Requalification Exam Results (IP Section 03.03)
(1)
(Partial)
Inspection Report 05000397/2021004 documented partial completion of the inspectors review of the calendar year 2021 requalification exam results. Due to maintenance outage MO-02, two crews were not administered the 2021 annual operating test until January 2022. The inspectors reviewed and evaluated the licensed operator examination failure rates for the requalification annual operating exam administered January 10 - January 20, 2022. This review completes inspection sample 71111.11A for calendar year 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 power maneuvering for the restoration of recirculation pump 1A following an unexpected trip on February 7, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification evaluated scenario on January 12, 2022.
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)local leak rate testing failures for RHR-V-27B on June 4, 2021 (2)local leak rate testing failure of containment isolation valve RFW-V-65A on December 8, 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)yellow risk for emergency diesel generator system A planned maintenance on January 10, 2022 (2)yellow risk for a system outage on the high pressure core spray (HPCS) diesel generator, week of January 24, 2022 (3)heavy load lift of multi-purpose canister (MPC) and transfer cask from reactor building 606' to the 441', stack up of HI-TRAC to HI-STORM, and transfer of MPC into HI-STORM on March 10, 2022 (4)yellow risk for the diesel generator 2 system outage on March 22, 2022
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) CR 428650, high pressure core spray service water pump surveillance test in the action range, on January 13, 2022
- (2) CR 429109, standby service water system B pin hole leak evaluation, on January 21, 2022
- (3) CR 428398, opening in the suction path of the HPCS diesel generator room standby air handling unit, on January 24, 2022
- (4) CR 427927, past operability review of ground alarm associated with low pressure cooling system valve LPCS-V-5, on February 9, 2022
- (5) CR 430029, diesel starting air check valve 16B not working properly, on March 12, 2022
- (6) CR 430430, control room water chiller CCH-CR-1B, non-operational purge unit, on March 18, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (1 Sample)
The inspectors evaluated the following temporary or permanent modifications:
(1)nonintrusive compensatory measure for pinhole leak on standby service water system B piping, on January 27, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) OSP-ELEC-S701, Diesel Generator 1 Semi-Annual Operability Test, following corrective maintenance on January 10, 2022 (2)work order 02151271 for standby liquid control relief valve 29A on January 11, 2022
- (3) TSP-DG3-B502, HPCS Diesel Generator DG3 Load Testing, following a planned system outage on January 28, 2022 (4)work order 02190692 for service water B elbow piping replacement VT-2 system pressure testing on February 10, 2022 (5)work order 02191306 for replacement of diesel generator 3 ammeter (HPCS-AMR607) on February 17, 2022
- (6) OSP-SLC/IST-Q701, Standby Liquid Control Pumps Operability Test, following a planned system B outage on March 3, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (4 Samples)
- (1) OSP-ELEC-M701, Diesel Generator 1 - Monthly Operability Test, on January 12, 2022
- (2) ESP-ADS-Q901, automatic depressurization system (ADS) Trip System A on ADS Timer - CFT/CC, on March 10, 2022
- (3) OSP-MS-Q702, Bypass Valves Test, on March 14, 2022
- (4) OSP-RCIC/IST-Q701, Reactor Core Isolation Cooling (RCIC) Operability Test, on March 15, 2022
Inservice Testing (IP Section 03.01) (2 Samples)
- (1) OSP-SW/IST-Q703, HPCS Service Water Operability, on January 1, 2022
- (2) OSP-RHR/IST-Q702, RHR Loop A Operability Test, on February 10, 2022
FLEX Testing (IP Section 03.02) (1 Sample)
(1)work order 02176771, monthly test drive of the B5B fire truck, on January 21, 2022
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 February 22,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicator submittals listed below:
IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 02.01)===
- (1) January 1, 2021, through December 31, 2021 IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 02.02) (1 Sample)
- (1) January 1, 2021, through December 31, 2021
IE04: Unplanned Scrams with Complications (USwC) Sample (IP Section 02.03) (1 Sample)
- (1) January 1, 2021, through December 31, 2021
71152A - Annual Followup Problem Identification and Resolution Annual Followup of Selected Issues (Section 03.03)
- (1) The inspectors reviewed the licensees implementation of its corrective action program related to CR 00424814, evaluation not performed on leaking plant service water seismic II/1M piping value, on February 16, 2022.
71153 - Followup of Events and Notices of Enforcement Discretion Event Followup (IP Section 03.01)
- (1) The inspectors evaluated the trip of recirculation pump A and the licensees response on February 5,
INSPECTION RESULTS
Failure to Take Appropriate Maintenance Rule Corrective Actions for RHR-V-27B Leakage Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2022001-01 Open/Closed
[H.12] - Avoid Complacency 71111.12 The inspectors identified a Green, non-cited violation of 10 CFR 50.65(a)(1) for failure to take appropriate action when containment isolation valve RHR-V-27B did not meet the performance criteria outlined the (a)(1) Performance Improvement Plan for the primary containment integrity and isolation (PCINT-PCISO) maintenance rule function. Specifically, not establishing corrective actions in 2019 for RHR-V-27B led to an additional primary containment integrity failure in 2021 and impacted overall containment performance when measured against the allowable leakage criteria.
Description:
RHR-V-27B is a six-inch, motor-operated gate valve that is designed to maintain primary containment integrity while closed and establish containment spray cooling while open. RHR-V-27B is scoped into the Inservice Testing (IST) and Maintenance Rule program and is required to have local leak rate testing (LLRT) performed. On May 22, 2019, the as-found (A/F) LLRT for RHR-V-27B failed to achieve test pressure, as documented in work order (WO) 02112329, and was incorrectly documented in CR 393944. When the A/F LLRT failed to achieve test pressure, the leakage rate should have been assumed to be greater than La. La is the maximum allowable leakage rate at the calculated peak containment internal pressure related to the design-basis accident (121,536 standard cubic centimeters per minute (sccm)). The licensee did not identify that the incorrect A/F LLRT value was recorded on surveillance tests until November 3, 2021, in CR 426834. The licensee failed to evaluate RHR-V-27B A/F LLRT failure to achieve test pressure as a maintenance rule PCINT-PCISO functional impact on either date. The inspectors, after further review, determined this failure should have been evaluated as a condition monitoring failure.
The PCINT-PCISO function entered (a)(1) status in September 2019 due to six condition monitoring failures from various valves in a 24-month period, of which three failures were from valves unable to achieve test pressure during A/F LLRTs. This is the same failure that occurred for RHR-V-27B in May 2019. A Performance Improvement Plan (PIP) was created (CR 398779), but it did not include RHR-V-27B. This plan contained corrective actions specific to the valves which had exceeded the performance criteria for PCINT-PCISO and established a goal of less than or equal to four condition monitoring failures and zero functional failures during an increased monitoring period. The PIP was last revised in October 2020.
On June 4, 2021, the A/F LLRT for RHR-V-27B exceeded the administrative limits (70,000 sccm vs. 885 sccm) but was still able to achieve test pressure, as documented in CR 421357.
SYS-4-22, Maintenance Rule Program, Attachment 11.1, Guidance/Examples of FFs, MPFFs, and Repetitive MPFFs, states, in part, if an LLRT failure causes the total containment leakage summation to be greater than or equal to 0.45 La, then the failure is a functional failure. The A/F LLRT results for RHR-V-27B in June 2021 exceeded 0.45 La and should have been evaluated as a condition monitoring or functional failure impact to the PCINT-PCISO maintenance rule function. Instead, the screening for CR 421357 incorrectly referenced CR 393944, which had incorrect data and did not refer to SYS-4-22 criteria for failures of containment isolation valves.
The inspectors identified the incorrect maintenance rule screenings for CR 393944 and 421357 and the failure to complete maintenance rule evaluations in January 2022. The inspectors concluded that the licensee failed to initiate appropriate corrective actions for the PCINT-PCISO function after May 22, 2019, when performance did not meet established goals and valve RHR-V-27B was incorrectly excluded from the scope of the (a)(1) PIP. The inspectors determined that the licensee again failed to initiate appropriate corrective actions in June 2021, while the function was in (a)(1) status, and another failure of RHR-V-27B should have been classified as a functional failure, but instead went unrecognized with no corrective actions initiated under the (a)(1) plan. The licensee wrote CR 429466 to address the inspectors concerns.
Corrective Actions: The licensee evaluated CR 421357 as a PCINT-PCISO functional failure and created further corrective actions to document the maintenance rule evaluation (CR 429466), update the PIP (CR 428546), and update the PCINT-PCISO Performance Criteria (CR 426834).
Corrective Action References: 393944, 421357, 426834, 428546, 429466
Performance Assessment:
Performance Deficiency: Failure to take appropriate corrective actions under 10CFR50.65(a)(1) for maintenance rule A/F LLRT failures of valve RHR-V-27B in May 2019 and June 2021 was a performance deficiency. Specifically, CR 393944 did not document the failure to achieve test pressure during A/F LLRT and, therefore, the failure was not evaluated for impact to PCINT-PCISO maintenance rule function. Further, CR 421357 did not identify that the A/F LLRT results exceeding the 0.45 La threshold identified in licensee procedure SYS-4-22, Maintenance Rule Program needed to be screened as a functional failure. As a result, the licensee failed to take corrective actions for maintenance rule failures of RHR-V-27B and revise the primary containment function (a)(1) plan.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, not establishing corrective actions for RHR-V-27B led to an additional LLRT failure in refueling outage R25 and impacted overall containment performance when measured against the allowable leakage criteria.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors evaluated the significance of the finding using IMC 0609, Appendix A, Significance Determination Process for Findings At-Power, and screened it to Green using Exhibit 3, Section C because the finding was of very low safety significance (Green) since leakage past RHR-V-27B did not represent an actual open pathway in the physical integrity of reactor containment. The suppression pool spray line represents a closed system which takes suction from the suppression pool and discharges back to the suppression pool.
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. Specifically, when screening CR 421357 for maintenance rule impact, the licensee referenced the CR 393944 maintenance rule screening which did not contain the correct information, failing to recognize and plan for the possibility of mistakes or latent issues.
Enforcement:
Violation: 10 CFR 50.65 (a)(1), requires, in part, that the holders of an operating license shall monitor the performance or condition of SSCs within the scope of the rule as defined by 10 CFR 50.65 (b), against licensee-established goals, in a manner sufficient to provide reasonable assurance that SSCs can fulfill their intended functions. Such goals shall be established commensurate with safety. When the performance or condition of an SSC does not meet established goals, appropriate corrective action shall be taken.
Contrary to the above, from May 22, 2019, the licensee failed to take corrective actions when the performance of RHR-V-27B did not meet licensee-established goals for the primary containment integrity and isolation (PCINT-PCISO) equipment functions.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Correct a Condition Adverse to Quality Associated with RFW-V-65A Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2022001-02 Open/Closed
[H.12] - Avoid Complacency 71111.12 A self-revealed Green, non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified when the licensee failed to promptly correct a condition adverse to quality with feedwater isolation valve RFW-V-65A. As a result, RFW-V-65A experienced a packing leak that began on June 24, 2021, contributing to the as-found local leak rate test (LLRT) valve failure on December 8, 2021.
Description:
RFW-V-65A is a 24-inch motor-operated feedwater isolation valve located in the steam tunnel of the reactor building outside of primary containment. It is considered a primary containment isolation valve according to Table 6.2-16 of Columbias updated Final Safety Analysis Report. It does not automatically close on a containment isolation signal because the feedwater system can be a source of reactor vessel makeup after a design-basis event (e.g., loss-of-coolant accident). There are two feedwater check valves downstream of this valve that can provide an immediate leak isolation.
RFW-V-65A has a history of small packing leaks (1 to 200 drops per minute) dating back to the early 2000s due to a scored stem following internal valve maintenance conducted in 2001. To mitigate the packing leaks, the valve has been placed on its backseat after almost every refueling outage since then. During the refueling outage R25 (May/June 2021), the valve packing was replaced. CR 422430, written on June 24, 2021, documented a packing leak with valve RFW-V-65A that occurred following the R25 refueling outage. CR 422457, written on June 27, 2021, documented that the leak was getting worse, with visible streams of water estimated to be more than 0.5 gallons per minute. Following this, the licensee placed the valve on its backseat. Placing RFW-V-65A on its backseat did not stop the packing leak and it continued until the plant shut down and entered Mode 4 on December 6, 2021. On December 8, 2021, the licensee performed an as-found LLRT in accordance with work order 02184040, task 04. Since the test pressure of 38.5 psi could not be achieved, the test was deemed a failure and was documented in CR 427855. The licensees investigation concluded that the failure of the LLRT was due to inboard seat leakage on RFW-V-65A. The licensee also noted that the valve packing was compromised by the scored stem which was characterized as a historical issue. The licensees investigation acknowledged that the repeated deferral of repairs to RFW-V-65A point to the stations reluctance to handle longstanding equipment issues. Additionally, the inspectors were provided outage scope change request (OSCR) 408585. This document originated on July 9, 2020, and requested to remove the work order that would have replaced the degraded/scored stem of valve RFW-V-65A from refueling outage R25. The OSCR documented that the funding was not approved to replace the degraded valve stem during R25. The OSCR was approved on July 16, 2020, and instead of replacing the scored stem, the station chose to replace and/or consolidate the packing during R25.
Following repairs to RFW-V-65A during the maintenance outage in December 2021, the as-left LLRT was completed satisfactorily before the plant restarted. Corrective actions to replace the degraded/scored valve stem and repair the inboard valve seat leakage were pending at the time of this inspection. The licensee also continued to monitor the valve and the steam tunnel for indications of another packing leak from this valve.
Corrective Actions: The licensee repacked the valve, cleaned and lightly polished the valve stem, and conducted a satisfactory as-left local leak rate test during the maintenance outage in December 2021. The licensee initiated an action to perform additional valve corrective maintenance and scheduled the work to be performed during the next refueling outage.
Corrective Action References: CR 427855
Performance Assessment:
Performance Deficiency: The failure to promptly correct a condition adverse to quality associated with a degraded/scored stem on valve RFW-V-65A is a performance deficiency. As a result, the scored stem adversely impacted the valve packing and contributed to the packing leak that began on June 24, 2021, and failure of the as-found LLRT on December 8, 2021.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the SSC and Barrier Performance attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the failure to replace the degraded valve stem of RFW-V65A led to a valve packing leak that started on June 24, 2021, and contributed to the failure of the valves as-found LLRT on December 8, 2021.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Specifically, other valves (RFW-V-32A and RFW-V-10A) installed downstream of RFW-V65A would have limited the leakage from this pathway to an acceptable level if feedwater flow through the A feedwater line was secured during a design-basis event that pressurized containment.
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. Specifically, OSCR 408585 deferred replacement of the scored stem of RFW-V65A during R25 due to an apparent lack of funding and instead relied on replacing the valve packing and the past practice of placing the valve on its backseat to mitigate any packing leaks from this valve.
Enforcement:
Violation: 10 CFR 50 Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quality such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to this requirement, since July 16, 2020, the licensee has failed to correct a condition adverse to quality associated with feedwater isolation valve RFW-V-65A. Specifically, the scored stem on RFW-V-65A could have been replaced during refueling outage R25 in May/June 2021, but instead work was delayed to a later date and the licensee chose to replace the valve packing. As a result, the valve developed a packing leak soon after the R25 outage and failed its as-found local leak rate test on December 8, 2021.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Perform Functional Assessment for Degraded Leaking Plant Service Water Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green FIN 05000397/2022001-03 Open/Closed
[P.3] -
Resolution 71152A The inspectors identified a Green finding for failure to follow licensee procedure 1.3.66, Operability and Functionality Evaluation, Revision 33, because the licensee failed to perform functionality assessments for degraded or non-conforming leaking plant service water (TSW)
Seismic II/1M class piping. Specifically, in 2017, the licensee identified through-wall leaks in TSW supply piping located in the overhead near the control room emergency chillers. In August of 2021, NRC inspectors identified that a functionality assessment addressing the potential impact to the control room chillers performance during a design-basis event had not been performed on the through-wall leaks in the TSW piping.
Description:
On February 18, 2017, the licensee identified a through-wall leak on TSW supply piping in the overhead of the radwaste building at the 525-foot elevation, documented under Condition Report (CR) 361567. Work Request (WR) 29133653 was created to investigate the leak and a possible second through-wall leak was identified as documented in CR 361788 on February 23, 2017. This CR documented a large amount of hard water deposits on the south end of the chiller in the overhead. The CR also documented that along the same TSW piping, two other catch containers were installed at the north end of the chiller.
In August 2021, NRC inspectors identified that the potential impacts on the control room emergency chillers from the degraded TSW piping had not been evaluated since 2017. The licensee documented the issue in CR 424814.
In February 2017, revision 33 of licensee procedure 1.3.66, Operability and Functionality Evaluation should have been used to evaluate the impact of through-wall leaks identified in CRs 361567 and 361788. Section 2.2 states, in part, The scope of systems, structures, or components (SSCs) required to be assessed for Functionality include: SSCs required to be capable of performing a function(s) as set forth in the current licensing basis (CLB). The scope of the CLB programs include: Licensee Controlled Specifications (LCS), While the TSW system is not safety-related or in the CLB, the through-wall leaks were located near SSCs in the CLB, namely the control room emergency chillers, which in 2017 were scoped into the LCS. In February of 2021, the licensee fully implemented a license amendment request to classify the control room emergency chillers as safety-related, and moved surveillance requirements from the LCS to the technical specifications. The inspectors identified that the lack of an evaluation of the through-wall leaks on TSW piping and the potential impact of an internal flood or water electrical hazard, on the now safety-related control room emergency chillers, cast reasonable doubt on the capability of these chillers to perform their safety function during a design basis event should the TSW piping fail.
Corrective Actions: The licensee initiated action to evaluate TSW piping integrity for the piping leaks identified in 2017 and for several additional through-wall leaks identified on the same TSW piping since 2017. Two additional work requests (29162402 and 29162541) were created to perform external piping preparation to allow for nondestructive examination (NDE).
Corrective Action References: 361567, 361788, 424814, 425179
Performance Assessment:
Performance Deficiency: The inspectors determined the failure to evaluate the through-wall leaks in the TSW piping and the impact of failure of those pipes on the function of the control room emergency chillers was a performance deficiency. Specifically, CRs 361567 and CR 361788 were not evaluated for impact on the CLB function of the control room emergency chillers. Licensee procedure 1.3.66, Operability and Functionality Evaluation, Revision 33, requires in part, SSCs required to be assessed for Functionality include: SSCs required to be capable of performing a function(s) as set forth in the CLB, which includes those SSCs contained within the LCS. Contrary to the requirement above, the licensee failed to perform a functional assessment which should have prompted an evaluation of TSW Seismic II/1M piping integrity and any potential impacts to the control room emergency chillers.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, failure to evaluate the operability/functionality of the control room emergency chillers upon identification of through-wall leaks in overhead TSW piping cast reasonable doubt on the capability of these chillers during a design basis event, which resulted in the licensee performing a detailed piping integrity evaluation and NDE to address any impacts to these chillers.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors answered no to all the questions in IMC 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. Therefore, the finding is of very low safety significance, Green.
Cross-Cutting Aspect: P.3 - Resolution: The organization takes effective corrective actions to address issues in a timely manner commensurate with their safety significance.
Specifically, the original TSW pipe leak documented in 2017 did not drive a timely evaluation of the operability/functionality of the control room emergency chillers as documented in the 2021 NRC identified condition report.
Enforcement:
Inspectors did not identify a violation of regulatory requirements associated with this finding.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On April 7, 2022, the inspectors presented the integrated inspection results to Mr. R. Schuetz, Chief Executive Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CE-02-02-09
Calculation for ISFSI Tornado Effects Evaluation for Site
Specific Design Basis Tornado
000
CE-02-13-22
Effects of Local Intense Probable Maximum Precipitation
Analysis for Columbia Generating Station
000
CE-02-13-27
Local Drainage Basin Probable Maximum Flood (PMF)
Analysis for Columbia Generating Station
000
Calculations
CE-02-14-10
Site-Specific Local Intense Probable Determination for
Columbia Generating Station
000
ABN-FLOODING
Flooding
2
ABN-WIND
Tornado/High Winds
034
Procedures
SWP-MAI-02
Station Material Condition Inspection and Housekeeping
Program
23
Corrective Action
Documents
Action Requests
27719, 426911
M512-2
Flow Diagram Diesel Oil & Miscellaneous Systems Diesel
Generator Building
041
M512-4
Flow Diagram Diesel Oil and Miscellaneous Systems Diesel
Generator Building
015
M519
Flow Diagram Reactor Core Isolation Cooling System
103
M522
Flow Diagram Standby Liquid Control System Reactor
Building
040
M524-1
Flow Diagram Standby Service Water System Reactor,
Radwaste, DG Bldgs and Yard
140
Drawings
M524-2
Flow Diagram Standby Service Water System Reactor,
Radwaste, DG Bldgs and Yard
24
SOP-DG1-LU
Emergency Diesel Generator (DIV 1) Valve and Power
Supply Lineup
008
SOP-RCIC-LU
RCIC Valve and Breaker Lineup
004
SOP-SLC-LU
SLC System Valve and Breaker Lineup
000
SOP-SLC-STBY
Placing SLC in Standby Status
2
SOP-SW-LU
Standby Service Water System Valve & Breaker Lineup
014
Procedures
SOP-SW-STBY
Placing Standby Service Water in Standby Status
004
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Calculations
FP-02-85-03
Combustible Loading Calculation
011
Corrective Action
Documents
Action Requests
29060
Drawings
FM892-2
Fire Barrier and Fire Boundary Plan, Mezzanine Floors EL
467' and 471' and Misc. Floors
010
PFP-DG-
BUILDING
Diesel Generator Building
004
Reactor 422
006
Radwaste 467
006
Fire Plans
Radwaste 484-487
006
1.3.10
Plant Fire Protection Program Implementation
038
1.3.10C
Control of Combustibles
23
15.2.2
Function and Sensitivity Check of Ionization Detectors
21
Procedures
15.3.5
Fire Damper Operational Inspection
20
Corrective Action
Documents
430925
Miscellaneous
Response to Generic Letter 89-13, Service Water System
Problems Affecting Safety-Related Equipment
2/05/1990
Procedures
8.4.42
Thermal Performance Monitoring of RHR-HX-1A and
RHR-HX-1B
013
Work Orders
2155623
Miscellaneous
21 Annual Operating Test Results
000
Miscellaneous
LE000036
LORQ Annual Exam Scenario LE000036
000
3.2.6
Power Maneuvering
20
OI-09
Operations Standards and Expectations
080
SOP-COND-
SHUTDOWN
Main Condensate System Shutdown
26
SOP-MSR-OPS
Main Turbine Moisture Separate Reheater Operations
011
SOP-RFT-
SHUTDOWN
Reactor Feedwater Turbine Shutdown
016
SOP-RRC-
START
Reactor Recirculation System Start
21
Procedures
TDI-23
LORQ Annual Exam Development and Administration
016
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Action Requests
393944, 421357, 425456, 425605, 426834, 398779, 429466,
28546, 425900, 427855, 422728, 422430, 430891
Performance Criteria Form for PCINT-PCISO - Fluid
Leakage
004
Miscellaneous
PCINT-PCISO (a)(1) Performance Improvement Plan and
Goals
000, 001
1.5.11
016
IST-4
Inservice Testing Program Plan Fourth Ten-Year Inspection
Interval
005
LLRT-01
Primary Containment Leakage Rate Testing Program Plan
009
SYS-4-22
015
Procedures
TSP-RFW/X17A-
R802
LLRT of RFW-V-65A, RFW-V-65B, RWCU-V-40
008
Work Orders
2112329, 02154645, 02184040
Corrective Action
Documents
Action Requests
28921
Miscellaneous
T22-DG-SC-BA2-
001
eSoms tracker
1.3.83
Protected Equipment Program
034
1.3.85
On-Line Fire Risk Management
006
1.5.14
Risk Assessment for Management and
Maintenance/Surveillance Activities
043
10.4.12
Crane, Hoist, Lifting Device and Rigging Control Program
033
Procedures
6.6.5
Movement and Transfer Operations of HI-TRAC and HI-
STORM in the Reactor Building
019
Corrective Action
Documents
Action Requests
365054, 428490, 430430, 307798, 385839
M512-3
Flow Diagram Diesel Oil and Miscellaneous Systems Diesel
Generator Building
2
Drawings
M788-1
D HVAC Plans and Sections
031
Engineering
Evaluations
EC EVAL 19170
Service Water Piping Through-wall Leak Upstream of
SW-RO11B
000
Miscellaneous
CVI Manual
Number:
Vendor Manual - Borg-Werner Compressor Condensing Unit
003
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
339-00,3,2
ME-02-94-44
Diesel Starting Air System Capabilities to meet the Number
of Starts Requirement
003
Operability
Evaluations
AR 429109429109ODMI
Operational Decision-Making Issue Evaluation
01/18/2022
1.3.66
037
Procedures
SOP-HVAC/CR-
Control, Cable, and Switchgear Rooms HVAC Operation
28
Work Orders
29163902, 29163619, 02152866, 02189395, 02189031,
2158583, 02180824
Corrective Action
Documents
Action Requests
29126, 429109
1.3.76
Integrated Risk Management
061
1.5.14
Risk Assessment and Management for
Maintenance/Surveillance Activities
043
Procedures
SWP-CM-02
Temporary Configuration Changes
004
Work Orders
2190722, 02190692
Corrective Action
Documents
Action Requests
400213, 429109, 429406, 430118, 430408
Drawings
M522
Flow Diagram Standby Liquid Control System Reactor
Building
040
CVI 215-00-
13834
Loop B Return
2
Miscellaneous
SLC-RV-29A
Relief Valve Setpoint Data Sheet
005
10.2.8
Testing and Repair of Safety and Relief Valves
039
8.7.3A
ASME Code Required VT-2 Visual Examinations
010
ESP-ATDDG3-
X301
Ammeter and Transducer for HPCS Diesel Generator,
HPCS-AM-R607 and HPCS-ATD-K001
004
OSP-SLC/IST-
Q701
Standby Liquid Control Pumps Operability Test
030
SWP-TST-01
Post Maintenance Testing Program
017
Procedures
TSP-RV/IST-
R701
Testing of IST Program Safety/Relief Valves
015
Work Orders
2187559, 02145891, 02185341, 02176926, 02152923,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2176451, 02152219
Corrective Action
Documents
Action Requests
28650, 427719, 427704, 428812, 426911, 422875, 426042,
29081, 428163, 428227, 417513, 418486, 417427, 404062,
2622, 412661, 416045, 430879, 430881
Drawings
M524-1
Flow Diagram Standby Service Water System Reactor,
Radwaste, DG Buildings and Yard
140
Miscellaneous
2004
Code for Operation and Maintenance of Nuclear Power
Plants
15.1.29
B.5.B Pumper Truck and Monitor Nozzle Operability
017
FLEX-01
FLEX Program
004
IST-4
Inservice Testing Program Plan Fourth Ten-Year Inspection
Interval
5.001
HPCS Service Water Flow Limit
27
Procedures
SOP-FP-TRUCK-
B.5.B Pumper Truck Operation
008
Work Orders
2165839, 02178846, 02161468, 29164146, 29161535,
2168371, 02173271, 02183860, 29164201, 29158898,
29159311, 02158120, 02160737, 02177631, 02160108,
2168698, 02159799
Corrective Action
Documents
Action Requests
430259, 430247, 430276
Miscellaneous
Team "A" EP Drill Scenario
Corrective Action
Documents
Action Requests
26130, 426150
Monthly PI Summary Spreadsheet for 2021
December 2021 Station Performance Spreadsheet
71151
Miscellaneous
Operations Logs 01/01/2021-12/31/2021
Corrective Action
Documents
Action Requests
361567, 361788, 425179
Engineering
Changes
16619
Credit CCH for MCR Equipment Operability
003
Miscellaneous
SS2-PE-98-091
Interoffice Memorandum, Generic Structural Evaluation of
TSW Piping with Hypothetical Through-Wall Flaws
Procedures
1.3.66
Operability and Functionality Evaluation
033, 037
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
DES-4-16
Configuration Change Walkdowns
2
Work Orders
2186308, 02108066, 29133653, 29133739
Corrective Action
Documents
Action Requests
29738, 429741
Miscellaneous
Operator Logs
2/05/2022
ABN-CORE
Unplanned Core Operating Conditions
20
ABN-POWER
Unplanned Reactor Power Change
018
ABN-RRC-LOSS
Loss of Reactor Recirculation Flow
018
Verification of Plant Operating Parameters for Single Loop
Operation
005
RRC Pump Start Temperature and Loop Flow Verification
014
Jet Pump Operability Single Loop Operation
003
Procedures
SOP-RRC-START
Reactor Recirculation System Start
21