IR 05000397/2022002
| ML22201A046 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/28/2022 |
| From: | Jason Kozal NRC/RGN-IV/DORS/PBA |
| To: | Schuetz R Energy Northwest |
| Kozal J | |
| References | |
| IR 2022001, IR 2022002 | |
| Download: ML22201A046 (34) | |
Text
July 28, 2022
SUBJECT:
COLUMBIA GENERATING STATION AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION - INTEGRATED INSPECTION REPORT 05000397/2022002 AND 07200035/2022001
Dear Mr. Schuetz:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On July 7, 2022, the NRC inspectors discussed the results of this inspection with Mr. David Brown 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.
Licensee-identified violations which were determined to be of very low safety significance are documented in this report. We are treating these violations as 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, Jason W. Kozal, Chief Projects Branch A Division of Operating Reactor Safety Docket Nos. 05000397 and 07200035 License No. NPF-21
Enclosure:
As stated
Inspection Report
Docket Number:
05000397 and 07200035
License Number:
Report Number:
05000397/2022002 and 07200035/202201
Enterprise Identifier:
I-2022-002-0004 and I-2022-001-0000
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, Washington
Inspection Dates:
April 01, 2022, to June 30, 2022
Inspectors:
P. Niebaum, Senior Resident Inspector
A. Donley, Resident Inspector
L. Brookhart, Senior Spent Fuel Storage Inspector
J. O'Donnell, Senior Health Physicist
E. Simpson, Health Physicist
C. Smith, Senior Reactor Inspector
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. Licensee-identified non-cited violations are documented under inspection results.
List of Findings and Violations
Failure to Implement ALARA Plans and Controls Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/2022002-01 Open/Closed
[H.4] -
Teamwork 71124.01 The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1(a) for failure to follow procedures, resulting in the licensee not maintaining doses as low as reasonably achievable (ALARA) for two work activities (RCC-P-1 A and RFW-V-32B). For both work activities, the licensee failed to execute the timely implementation of ALARA plans and controls. Specifically, the installation of temporary shielding packages for these two work activities according to schedule in their respective ALARA plans resulted in additional and unplanned exposure for workers.
Failure to Follow Procedures with an Improper Entry into a Locked High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/2022002-02 Open/Closed
[H.11] -
Challenge the Unknown 71124.01 The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1(a)for a workers failure to follow procedures for worker behavior inside a locked high radiation area. Specifically, the worker received a dose rate alarm on a self-reading dosimeter after entering an area that the worker had not been briefed by radiation protection personnel to enter.
Additional Tracking Items
None.
PLANT STATUS
Columbia Generating Station began the inspection period at 100 percent rated thermal power (RTP). On May 29, 2022, a downpower to approximately 78 percent occurred due to a feedwater heater controller failure which resulted in the loss of three feedwater heaters. Following corrective maintenance and restoration of the feedwater heaters, the unit returned to 100 percent RTP on May 30, 2022. On June 11, 2022, the station began a load reduction to approximately 40 percent RTP as requested by the Bonneville Power Administration. Once at 40 percent, the station conducted repair activities on their adjustable speed drive system for the reactor recirculation pumps, which resulted in an unplanned entry into single loop operations and a load reduction to approximately 30 percent. Following this event, power was raised to approximately 40 percent and on June 12, 2022, the station restored two-loop operation and maintained approximately 40 percent RTP. On June 20, 2022, the station raised power to approximately 99 percent RTP. On June 21, 2022, power was reduced to 90 percent RTP. On June 22, 2022, power was lowered to 70 percent RTP for a rod pattern adjustment and then began raising power to 100 percent RTP. The station achieved 100 percent RTP on June 23, 2022, and remained at that power through the end 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, 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.
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:
onsite transformer yard on May 28, 2022
emergency diesel generators 1 and 2 on May 31, 2022
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (1 Sample)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)residual heat removal system C on May 2, 2022
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of control room air conditioning (AC) system A on May 19, 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 areas DG-1, 6, and 7; high pressure core spray diesel generator, day tank, and diesel fuel oil storage tank room; on April 22, 2022 (2)fire area RC-13, communications room, main control room emergency chillers, instrument shop, and heating, ventilation, and air conditioning chase, on May 16, 2022 (3)fire area R-7, residual heat removal pump room C, on June 22, 2022 (4)fire area RC-19, vital island corridor, while maintenance on the A-7 fire riser caused the two essential fire hose stations (RWB26 and RWB13) to be non-functional, on June 29, 2022
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the onsite fire brigade training and performance during an unannounced fire drill on June 14, 2022.
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 scram time testing and operator response following a trip of recirculation pump 1A on June 11, 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 June 13, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated the effectiveness of maintenance to ensure high-energy line break doors, including R-DOOR-R211, remain capable of performing their intended function on June 27, 2022.
Quality Control (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure DO-V-68C1, diesel fuel oil pump suction valve installed in diesel generator 3, remains capable of performing its intended function on June 30, 2022.
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 emergent startup transformer outage on April 30, 2022 (2)yellow risk for transmission work that removed the 500kV north bus from service on May 16, 2022 (3)yellow risk for planned maintenance on standby service water system A on June 6, 2022 (4)elevated risk for adjustable speed drive maintenance on June 11, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) CR 431218, E-RLY-4/DG2 as found normally closed contact gap out of tolerance, discovered on March 23, 2022
- (2) CR 431635, failure to evaluate flooding impacts for credited doors on radwaste building 467, discovered on April 4, 2022
- (3) CR 432145, high-energy line break and secondary containment door R-211 was not latched and closed, discovered on April 20, 2022
- (4) CR 432705, service water to cooling coil of the main control room AC system 1A due to failure of SW-822A, discovered on May 9, 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) EC 19254, battery E-B1-7 fed from spare battery charger E-C1-1
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
(1)work order 02192768 for battery charger 1-7 (E-C1-7) on April 6, 2022
- (2) OSP-LPCS/IST-Q702, Low Pressure Core Spray (LPCS) System Operability Test, following a low-pressure core spray system outage on May 3, 2022 (3)work order 02194505 for test valve 4 associated with reactor protection system (RPS)pressure switch PS-5-A on May 4, 2022
- (4) OSP-SW/IST-Q701, Standby Service Water Loop A Operability, following maintenance on standby service water system A on June 7, 2022 (5)work orders 02163734 and 02185789 for check valve SW-V-226A on June 23, 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) (3 Samples)
- (1) WO 02160995, biannual functional testing of 6.9kV circuit breaker over current protective relays and associated control circuits, on April 13, 2022
- (2) ISP-RCIC-Q901, Reactor Core Isolation Cooling (RCIC) Isolation on RCIC Steam Supply Flow High Div 1 - CFT/CC, on April 15, 2022
- (3) ISP-RPS-S901, RPS (Channel A1) and EOC Recirc Pump Trip - TGV Fast Closure RPS-PS-5A - CFT/CC, on May 4, 2022
RCS Leakage Detection Testing (IP Section 03.01) (1 Sample)
(1)manual determination of drywell unidentified leakage per SOP-FDR-OPS, Floor Drain System Operation, on May 20, 2022
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the emergency planning drill on April 26,
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 identifies the magnitude and extent of radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
Instructions to Workers (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee instructs workers on plant-related radiological hazards and the radiation protection requirements intended to protect workers from those hazards.
Contamination and Radioactive Material Control (IP Section 03.03) (2 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
(1)surveys of potentially contaminated packages/equipment from the radiologically controlled area and workers exiting potentially contaminated areas (2)the physical and programmatic controls for highly activated and contaminated non-fuel materials stored within the spent fuel pool
Radiological Hazards Control and Work Coverage (IP Section 03.04) (3 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
(1)medium risk radiological work and job coverage for fuel pool cooling flow control valve 15A replacement (Radiation Work Permit (RWP) #30004870, ALARA task
- 020593680102)
(2)medium risk radiological work and job coverage for fuel pool cooling flow control valve 15B replacement (RWP #30004870, ALARA task #021730280101)
(3)low risk radiological work and job coverage for fuel pool cooling valve 179 replacement (RWP #30004860, ALARA task #021731110101)
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)reactor building, 501-foot elevation, room R307, personnel hatch (2)reactor building, 522-foot elevation, room R405, reactor water cleanup pump room A (3)turbine building, 501-foot elevation, room T206, hallway entrance heater bay (4)radioactive waste building, 437-foot elevation, room C115, north shield door 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.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) A potential intake that occurred on June 3, 2021. An evaluation as a potential ingestion was completed on June 7, 2021. (CR 421374)
- (2) A potential intake that occurred on December 10, 2021. An evaluation as a potential ingestion was completed on December 13, 2021. (CR 428088)
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
(1)three examples of declared pregnant worker's dose assessment (2)neutron dose tracking for work on the reactor building 606' elevation under RWP
=30004916 and radiation survey number 2022-0419-6==71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,
& Transportation
Shipment Preparation (IP Section 03.04)
- (1) The inspectors observed the preparation of radioactive condensate resins in liner number 22-027-HP for transport. This shipment (# 22-22) was transported as Class A, LSA-II radioactive waste on May 18, 2022, in type A cask.
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 02.04)===
- (1) April 1, 2021, through March 31, 2022
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) April 1, 2021, through March 31, 2022 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)
- (1) April 1, 2021, through March 31, 2022
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) CR 429738, adjustable speed drive (ASD) channel 1A2 tripped causing loss of reactor recirculation pump RRC-P-1A on February 5, 2022
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program for potential adverse trends associated with the barrier impairment process that might be indicative of a more significant safety issue. One observation was documented in the results section of this report.
71153 - Follow-up of Events and Notices of Enforcement Discretion Event Follow-up (IP Section 03.01)
- (1) The inspectors evaluated the impact of an undemanded restart signal for recirculation pump A due to an issue with the adjustable speed drive and the licensees response on June 11,
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
===60853 - On-Site Fabrication of Components and Construction on an ISFSI To determine whether Independent Spent Fuel Storage Installation (ISFSI) dry cask storage components were designed and fabricated in accordance with license requirements. This sample included site observations of concrete placement activities and a review of the Columbia Generating Station's ISFSI pad design.
On-Site Fabrication Of Components And Construction On An ISFSI===
- (1) On April 19-20, 2022, the inspectors conducted an inspection of Columbia Generating Station's planning and construction of their ISFSI expansion. The licensee had designed the original ISFSI to hold 54 HI-STORM storage casks. At the time of the inspection, the licensee was expanding the ISFSI to have four additional concrete pads that would increase the capacity of the ISFSI to eventually store 126 casks.
Inspectors observed rebar verification and concrete placement activities associated with the fourth pad constructed during the expansion effort. The licensee was constructing the ISFSI pads in accordance with the Holtec International HI-STORM 100 Certificate of Compliance 72-1014, License Amendment 9, Revision 1, and the HI-STORM Final Safety Analysis Report (FSAR), Revision 13.
During the inspection period, Columbia Generating Station constructed four ISFSI concrete pads, the pads were each 30' x 147' x 2' in dimension. Each pad was designed to hold 18 storage casks. By the end of the quarter (June 30th) the licensee had completed construction of the four pads associated with the expansion activities.
During the concrete pad placement, the inspectors reviewed the following samples:
Reviewed documentation and observed construction services to ensure the ISFSI pad was designed and fabricated to meet the Holtec HI-STORM 100 FSAR requirements and design procurement specifications.
Concrete was cured in accordance with American Concrete Institute (ACI) 318 "Building Code Requirements for Structural Concrete."
Batch plant and concrete delivery trucks met American Society for Testing and Materials (ASTM) C 94 "Standard Specification for Ready-Mixed Concrete," in respect to maximum mix time, maximum/minimum drum revolutions, addition of admixtures on the jobsite, and calibration of scales at the batch plant.
Concrete forms met ACI 318 in respect to wetting prior to concrete placement, removal of debris, controlling leaks, controlling form deflection, applying release agents, and removing of standing water.
Concrete mix design for all ingredients met the ACI code requirements and ASTM standards for water-reducing admixtures, retarding/accelerating admixtures, aggregates, cement, air-entrainment admixtures, and potable water.
Rebar placement and construction was consistent with ACI 318 requirements for rebar size, bend diameters, tensile strength test records, and minimum concrete cover requirements to protect the rebar from corrosion.
Concrete testing and sampling met the ACI and ASTM standards with respect to sampling locations, methods, number of samples, and methods for molding and curing strength test cylinders.
Concrete placement met design specifications for air entrainment, slump, and water/cement ratio.
Concrete placement met ACI 318 requirements for consolidation, setup (not dragging the concrete), finishing techniques.
Compressive strength samples reviewed met the design specifications and FSAR requirements.
Licensee design evaluations were reviewed to ensure the pads met static and dynamic loads, soil-structure liquefaction requirements, and subsoil modulus of elasticity requirements.
===60855 - Operation of an ISFSI The inspectors performed a review of the licensees independent spent fuel storage installation (ISFSI) activities to verify compliance with requirements of the Certificate of Compliance 72-1014, License Amendment 9, Revision 1, and the HI-STORM Final Safety Analysis Report (FSAR), Revision 13. The inspectors reviewed selected procedures, corrective action reports, and records to verify ISFSI operations were compliant with the Certificate's technical specifications, requirements in the FSAR, and NRC regulations.
Operation Of An ISFSI===
- (1) The inspectors evaluated the licensees dry cask storage operations from March 21 - 24, 2022, during an on-site inspection. The Columbia Generating Station's original ISFSI pad was designed to store 54 Holtec International HI-STORM 100 spent fuel storage casks using the MPC-68M canister (containing 68 boiling-water reactor spent fuel assemblies). At the time of the on-site inspection, the licensee was in the process of expanding the ISFSI to eventually house 126 storage cask and were performing spent fuel loading operations. At the time of the inspection, the ISFSI pad contained 47 storage casks loaded with spent fuel, and the licensee was in the process of loading and processing the 48th canister in the reactor spent fuel building. By the end of the inspection period the licensee had filled the original ISFSI's pads with 54 casks.
During the on-site inspection, the inspectors evaluated and observed the following activities:
loading and verification of spent fuel into canister 47
heavy load lifts using the cask handling crane to remove the transfer cask with the loaded canister from the spent fuel pool to the canister processing area
welding and nondestructive testing of the lid-to-shell weld
processing of the spent nuclear fuel for storage, including bulk water removal, vacuum drying, and helium backfill operations
final sealing of the canister, including welding of the vent and port cover plates, nondestructive testing, and helium leak-testing The inspectors reviewed and evaluated the following documentation during the inspection:
fuel selection evaluations for the canisters loaded since the last NRC ISFSI inspection (canisters 41 - 47)
radiation surveys for dose at the owner-controlled boundary to verify compliance with the requirements of 10 CFR 72.104 for years 2018 - 2021
selected ISFSI-related condition reports issued since the last NRC ISFSI inspection
quality assurance program implementation, including recent audits, surveillances, receipt inspection, and quality control activities related to ISFSI operations
compliance to technical specifications for operational surveillance activities and FSAR required annual maintenance activities
documentation of annual maintenance activities for the sites cask handling crane, vertical cask transporter, and special lifting devices
selected licensee design changes and program changes to the ISFSI performed under the site's 10 CFR 72.48 program
changes made by the licensee in the site's 10 CFR Part 72.212 evaluation report from revision 10 to revision
INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71111.12 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 Appendix B, Criterion VIII, Identification and Control of Materials, Parts, and Components, requires in part that measures shall be established for the identification and control of materials, parts, and components. These control measures shall be designed to prevent use of incorrect or defective material, parts, and components.
Contrary to this requirement, the licensees control measures were not effective to prevent the use of a non-safety-related valve in a safety-related application. Specifically, on January 25, 2022, the licensee inappropriately installed a commercial grade valve as DO-V-68C1, diesel fuel oil pump suction valve, in the safety-related diesel generator (DG) 3 diesel fuel oil system with work order (WO) 02173055. The licensee ordered a safety-related valve to replace this valve and that work is being tracked under WO 02192160.
Significance/Severity: Green. The inspectors determined the finding was very low safety significance, Green, when screened in accordance with NRCs Inspection Manual Chapter (IMC) 0609, Appendix A, The Significance Determination Process For Findings At-Power, issued on November 30, 2020. Specifically, the screening questions in Exhibit 2 - Mitigating Systems Screening Questions were all answered no and DG 3 remained operable with this non-conforming valve installed.
Corrective Action References: The issue was captured in the licensees corrective action program as CR 429555 and the licensee plans to replace this valve with a safety-related valve using WO 02192160.
Failure to Implement ALARA Plans and Controls Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/2022002-01 Open/Closed
[H.4] -
Teamwork 71124.01 The inspectors identified a Green finding and associated non-cited violation (NCV) of Technical Specification 5.4.1(a) for failure to follow procedures, resulting in the licensee not maintaining doses as low as reasonably achievable (ALARA) for two work activities (RCC-P-1 A and RFW-V-32B). For both work activities, the licensee failed to execute the timely implementation of ALARA plans and controls. Specifically, the installation of temporary shielding packages for these two work activities according to schedule in their respective ALARA plans resulted in additional and unplanned exposure for workers.
Description:
During refueling outage 25 between May 8, 2021, and June 19, 2021, the licensee failed to implement the ALARA plans for two work activities. These work activities involved
- (1) refueling water valve 32B (RFW-V-32B) and
- (2) reactor recirculation pump A (RCC-P-1 A).
The first job, RFW-V-32B, was the replacement of the seals in the refueling water valve using radiation work permit (RWP) 30004706. The ALARA plan for this job included the use of temporary shielding to reduce the occupational exposure to workers. In the ALARA plan for this job, the first line under engineering controls in the ALARA checklist was that temporary shielding was to be installed and initial flushing completed prior to this work commencing.
However, the temporary shielding plan had not been implemented for this job and the shielding was not installed prior to work on the valve as was planned and scheduled. The temporary shielding task had been marked as a contingency task not a required task. An in-progress review of RWP 30004706 described that shielding package #17 was intended to be installed along with a frame (scaffold) to hold the shielding, which was not installed. The shielding not being installed was highlighted when the workers exceeded the dose estimate for valve disassembly. Work was stopped and the shielding was then installed.
In addition to the shielding issue, the work platform (scaffold) was installed too high on one side of the valve such that the workgroup could not work at valve height and needed the platform modified. The valve workers and carpenters did not have the same understanding of the required work platforms. The scaffold supporting the work platforms had not been built as during prior outages.
The initial dose estimate for the job was 1.427 rem. This estimate was revised before work started to 2.383 rem. The actual dose accrued for this job was determined to be 5.660 rem, which exceeded the revised dose estimate by 137 percent.
The second job, RCC-P-1 A, was the replacement of the reactor recirculation pump A. Two ALARA plans were reviewed that were associated with this job: one for RWP 30004704 and one for RWPs 30004705 and 30004728. These ALARA plans also included the planned use of temporary shielding to reduce the occupational exposure to workers. In the ALARA plan for RWP 30004704, the engineering controls section stated that work required an initial shielding package be installed. Additional shielding packages to be installed (recirculation ring header and reactor water cleanup line) were also described. The ALARA plan for the other two RWPs had many more engineering controls than just shielding. But the same shielding requirements were included.
The ALARA post-job review described the reactor water cleanup line shielding installation required multiple entries. Also, the initial shielding package could have been completed sooner and could be improved. Two additional locations were identified where shielding was needed, and three unplanned scaffolds had to be built. Delayed installation of shielding resulted in extra dose.
Additional dose was also accrued when workers were pulled off other work to install mirror insulation on critical path activities only to have quality control personnel arrive and inform the insulators that the insulation had to be removed to perform an inspection. There was inadequate time for the radiation protection personnel to integrate with project planning and management to understand the full scope of this project. This resulted in a reactionary posture for radiation protection personnel, which contributed to schedule delays, unexpected challenges, and general frustration and confusion about the scope of work and radiological controls.
The initial dose estimate for this job was 41.502 rem. The actual dose accrued for this job was determined to be 65.701 rem, which exceeded the initial dose estimate by 58 percent.
For both work activities, the final accrued dose exceeded the initial or revised dose estimate by more than 50 percent, with an actual accrued dose of greater than five person-rem.
The licensee uses procedures to implement the ALARA program and ALARA plans. The sitewide procedure SWP-PRO-01, Procedure and Work Instruction Use and Adherence, revision 34, section 4.10 describes the requirements for procedure and work instruction use treating work instructions the same as procedures. The plant procedure GEN-RPP-02, Radiological Planning and Control Process, revision 34, sections 2.2 and 2.3 describe the work management process and ALARA planning and review and how they work together to incorporate ALARA into the work orders and work order task instructions. The implementation of ALARA plans as ALARA tasks and work instructions (work orders) is described in plant procedure 11.2.2.14, Radiological Planning and Reviews, revision 7, section 4.1.
Work orders were generated and scheduled for the shielding packages but were not implemented at the scheduled time in the ALARA plans resulting in additional/unplanned dose. Shielding was not solely responsible for all the unplanned dose on these two jobs, but it was a common aspect of both.
Corrective Actions: The licensee has revised GEN-RPP-14, Control of Temporary Shielding, to clarify and reinforce that temporary shielding tasks should not be considered contingency tasks.
Corrective Action References: CR 00419954, CR 00420746, and CR 00421857
Performance Assessment:
Performance Deficiency: The licensee failed to execute the timely implementation of ALARA plans and controls. Two examples of this performance deficiency were identified.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to implement the ALARA plans (i.e., shielding packages) for these work activities increased individual and collective radiation exposures beyond the planned, intended dose.
Significance: The inspectors assessed the significance of the finding using Manual Chapter 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding had very low safety significance (Green) because, although the finding involved ALARA planning and work controls, the licensees latest three-year rolling average collective dose was less than 240 person-rem.
Cross-Cutting Aspect: H.4 - Teamwork: Individuals and work groups communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the licensee failed to provide adequate time to integrate the various organizations to fully understand the work activities and their responsibilities resulting in a reactionary posture for the workgroups. This led to schedule delays, challenges, and confusion about the scope of work and radiological controls.
Enforcement:
Violation: Technical Specification 5.4.1, states, in part, that written procedures shall be established, implemented, and maintained covering the following activities:
- (a) the applicable procedures recommended in Regulatory Guide 1.33, revision 2, appendix A, February 1978.
Appendix A, section 7(e), recommends radiation protection procedures including the implementation of the ALARA program.
Several procedures implement the ALARA program, specifically ALARA plans, including:
- SWP-PRO-01, section 4.10, describes the requirement for adherence to procedures and work instructions
- GEN-RPP-02, sections 2.2 and 2.3, describes the integration of ALARA and work management, and
The work orders were used to implement the installation of temporary shielding described in the ALARA plans.
Contrary to the above, during the R25 refueling outage beginning May 8, 2021, and ending June 19, 2021, the licensee failed to implement the procedures established for the implementation of the ALARA program. Specifically, the licensee failed to install, in a timely manner (i.e., prior to the work commencing), temporary shielding packages required by the ALARA plans for two work activities (RCC-P-1 A and RFW-V-32B). The failure to install the shielding increased worker exposure.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Failure to Follow Procedures with an Improper Entry into a Locked High Radiation Area Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/2022002-02 Open/Closed
[H.11] -
Challenge the Unknown 71124.01 The inspectors reviewed a self-revealed, non-cited violation of Technical Specification 5.4.1(a) for a workers failure to follow procedures for worker behavior inside a locked high radiation area. Specifically, the worker received a dose rate alarm on a self-reading dosimeter after entering an area that the worker had not been briefed by radiation protection personnel to enter.
Description:
On May 12, 2021, a worker inside the drywell, which was controlled as a locked high radiation area (LHRA), was removing electrical grounds from the RRC-P-1 A motor on the 512-foot elevation. The worker dropped a bolt which fell to the 501-foot elevation. The worker traveled to that location to retrieve the bolt and received a dose rate alarm. The worker was authorized on radiation work permit (RWP) 300004704, which did not include areas in the 501-foot elevation. Therefore, the worker was not briefed for areas on the 501-foot elevation. The worker's RWP had a self-reading dosimeter dose rate alarm setpoint of 300 millirem (mrem) per hour. The worker received a dose rate alarm while retrieving the dropped bolt. The dose rate alarm showed the worker was exposed to 563 mrem per hour.
Upon receipt of the dose rate alarm, the worker left the area and reported to radiation protection. A follow-up survey showed 610 mrem per hour in the area where the alarm occurred.
Prior to making the entry into the radiologically controlled area (RCA), the worker was informed of the radiological conditions for his work area. The dose rates briefed for the RWP ranged from 100 to 120 mrem per hour. He was not briefed for the area where the radiation dose rate alarm occurred. The inspectors concluded that the worker did not follow the instructions provided by radiation protection during the pre-job briefing or the requirements of site procedures when he improperly entered an area that was not briefed and received a dose rate alarm.
Plant procedure 11.2.7.3, High Radiation Area, Locked High Radiation Area, and Very High Radiation Area Controls, revision 45, states in section 6.2.2 that entry into LHRAs shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.
Corrective Actions: The licensee assessed this issue and implemented multiple immediate corrective actions. Some of the actions taken included:
- The workers access was restricted from radioactive material areas and the RCA.
- The worker was coached on proper radiation worker behavior and expectations.
Corrective Action References: CR 00419431
Performance Assessment:
Performance Deficiency: The failure to follow a radiological protection procedure for entry into a locked high radiation area is a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Program & Process attribute of the Occupational Radiation Safety cornerstone and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. Specifically, the failure to follow procedure requirements had the potential to increase the workers dose and making an improper entry into a controlled area resulted in exposure to unplanned elevated dose rates.
Significance: The inspectors assessed the significance of the finding using Manual Chapter 0609 Appendix C, Occupational Radiation Safety SDP. The inspectors determined the finding to be of very low safety significance (Green) because
- (1) it was not associated with as low as is reasonably achievable planning or work controls,
- (2) there was no overexposure,
- (3) there was no substantial potential for an overexposure, and
- (4) the ability to assess dose was not compromised.
Cross-Cutting Aspect: H.11 - Challenge the Unknown: Individuals stop when faced with uncertain conditions. Risks are evaluated and managed before proceeding. Specifically, the worker failed to contact radiation protection before preceding into unknown radiological conditions and was therefore unaware of the nature of the radiological hazard.
Enforcement:
Violation: Technical Specification 5.4.1(a) requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in NRC Regulatory Guide 1.33, revision 2, appendix A, February 1978. Appendix A, Section 7.e.(1)requires written radiation protection procedures to control access to radiation areas. The licensee established plant procedure 11.2.7.3, High Radiation Area, Locked High Radiation Area, and Very High Radiation Area Controls, revision 45, section 6.2.2, which states that entry into locked high radiation areas (LHRAs) shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them.
Contrary to the above, on May 12, 2021, the licensee failed to implement the procedures established for entry into LHRAs to ensure workers are knowledgeable of area dose rates.
Specifically, the worker entered an area for which he was not briefed by radiation protection staff, while unknowledgeable of the radiological conditions of the area.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Licensee-Identified Non-Cited Violation 71124.01 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: Licensee-identified violation of 10 CFR 20.1801 which requires licensees to secure from unauthorized removal or access licensed materials that are stored in controlled or unrestricted areas. Contrary to this requirement, on October 6, 2021, a radiation protection technician performing a routine surveillance of radiation posting requirements found that an intermodal container (ID RSC-237-019) containing licensed material (dry active waste) in a satellite radiologically controlled area was not locked or sealed, as required by site procedures. The container was found to be closed. However, one of the latching mechanisms was not in its secure position and an open lock was hanging from the latch hole. Survey results indicated radiation levels outside of the container of 82 mrem per hour on contact and 2.5 mrem per hour at one meter. The external radiation levels are indicative of higher radiation levels accessible on the inside of the storage container that was not secured as required by regulations.
Significance/Severity: Green. The inspectors determined the finding to be of very low safety significance (Green) because
- (1) it was not associated with as low as is reasonably achievable planning or work controls,
- (2) there was no overexposure,
- (3) there was no substantial potential for an overexposure, and
- (4) the ability to assess dose was not compromised.
Corrective Action References: CR 425945 Observation: Adverse Trend in Barrier Impairment Process 71152S The inspectors reviewed the licensee's corrective action program (CAP) for trends associated with implementation of the barrier impairment process during a six-month period ending on June 30, 2022. Condition report (CR) 433080 documented an adverse trend in operations performance regarding barrier impairments and fire protection system impairments. This CR cross-referenced nine additional CRs that make up the adverse trend. Two of these were NRC identified issues and one (CR 431649) was considered a minor violation of licensee procedure 1.3.57, "Barrier Impairment" for not conducting a concurrent flood watch with the hourly fire watch. The licensee restored compliance by establishing a flood watch and conducting an investigation to identify the cause(s), review extent of condition, and establish corrective actions. Final corrective actions to mitigate the adverse trend were in development at the end of this inspection period.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 7, 2022, the inspectors presented the integrated inspection results to Mr. David Brown, Operations Vice President, and other members of the licensee staff.
On May 5, 2022, the inspectors presented the ISFSI spent fuel loading and concrete placement inspection activities inspection results to Mr. Randy Prewett, Plant General Manager, and other members of the licensee staff.
On May 31, 2022, the inspectors presented the occupational radiation safety inspection results to Mr. W. G. Hettel, Chief Nuclear Officer, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
60853
Engineering
Evaluations
ISFSI Expansion
001
60853
Miscellaneous
Submittal
21-000298
Concrete Design Mix Submittal
10/11/2021
60855
Corrective Action
Documents
Resulting from
Inspection
03/24/2022
60855
Miscellaneous
CFR 72.212
Evaluation
Columbia 72.212 Evaluation Report
013
60855
Miscellaneous
CoC 72-1014
Certificate of Compliance Holtec HI-STORM 100
Amendment
9, Rev. 1
60855
Miscellaneous
Holtec HI-STORM 100 FSAR
013
60855
Miscellaneous
QA-AU-20
000
60855
Miscellaneous
QA-AU-DC-18
000
60855
Miscellaneous
R05-R09,
U01-U03
Cask Loading Plans
000
60855
Procedures
PPM 6.6.12
Vacuum Drying System Operation
007
60855
Procedures
PPM 6.6.13
Helium Backfill System Operation
005
60855
Procedures
PPM 6.6.15
Spent Fuel Cask Loading Verification
006
60855
Procedures
PPM 6.6.4
HI-STORM System Site Transportation
016
60855
Procedures
PPM 6.6.5
Movement and Transfer Operations of HI-TRAC and
HI-STORM in the Reactor
019
60855
Procedures
PPM 6.6.6
MPC Fuel Loading
017
60855
Procedures
PPM 6.6.7
MPC Processing
031
60855
Procedures
SWP-LIC-02
Licensing Basis Impact Determinations
015
60855
Work Orders
HI-STORM Inspection
000
Corrective Action
Documents
Resulting from
Inspection
Action Requests
433300, 433301, 433302, 433393, 433394, 433395,
433396
Procedures
ABN-ELEC-GRID
Degraded Off Site Power Grid
013
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Procedures
Offsite Station Power Alignment Check
037
Procedures
SOP-
HOTWEATHER-
Hot Weather Operations
007
Procedures
SOP-SW-SPRAY
Standby Service Water Spray Header Operations
000
Procedures
SOP-
WARMWEATHER-
Warm Weather Operations
018
Work Orders
2185699
Corrective Action
Documents
Action Requests
409552, 406685, 406639, 432705, 432670, 432669,
2666
Drawings
M521-3
Flow Diagram, Residual Heat Removal Loop "C"
013
Drawings
M524-1
Flow Diagram Standby Service Water System Reactor,
Radwaste, D.G. Bldgs and Yard
140
Drawings
M548-1
Flow Diagram HVAC for Control and Switchgear Rooms
Radwaste Building
103
Drawings
M775
Flow Diagram Emergency Chilled Water Piping System
Control Room
030
Procedures
OSP-
CCH/IST/M701
Control Room Emergency Chiller System A Operability
057
Procedures
SOP-HVAC/CR-
LU
Control, Cable, and Critical Switchgear Rooms HVAC
Lineup
003
Procedures
SOP-HVAC/CR-
STBY
Control, Cable, and Critical Switchgear Rooms HVAC in
Standby Status
2
Procedures
SOP-RHR-LU
RHR System Valve and Breaker Lineup
009
Procedures
SOP-SW-LU
Standby Service Water System Valve & Breaker Lineup
014
Work Orders
29156103, 29154868, 02162099, 29154848, 02161981,
2194701
Calculations
FP-02-85-03
Combustible Loading Calculation
011
Corrective Action
Documents
Action Requests
434082, 434282
Drawings
FM 892-3
Fire Area Boundary Plan - Operating Floors
011
Miscellaneous
Fire Protection System Impairment 22-0075
Miscellaneous
Form 26392
Fire Brigade Leader Response Checklist
000
Miscellaneous
L22-FP RISER A-
7-001
eSoms tracker
Miscellaneous
TG 441' - LOC
Fire Drill Scenario for Turbine Bldg 441' East
06/08/2022
Procedures
1.3.10B
Active Fire System Operability and Impairment Control
017
Procedures
15.2.16
Thermal Detector-Channel Function Test
009
Procedures
15.2.2
Function and Sensitivity Check of Ionization Detectors
21
Procedures
PFP-DG-
BUILDING
Diesel Generator Building
004
Procedures
Reactor 422
006
Procedures
Radwaste 467
006
Procedures
Radwaste 525
007
Procedures
TPD-22
Fire Brigade Training Program Description
008
Miscellaneous
LR0025558
Cycle 22-3 Evaluated Scenario
000
Procedures
3.2.6
Power Maneuvering
21
Procedures
ABN-CORE
Unplanned Core Operating Conditions
21
Procedures
ABN-POWER
Unplanned Reactor Power Change
018
Procedures
ABN-RRC-LOSS
Loss of Reactor Recirculation Flow
019
Procedures
OI-07
Training Expectations
015
Procedures
SOP-RRC-ASD
Reactor Recirculation ASD Operations
016
Procedures
TDI-08
Licensed Operator Requalification Program
019
Procedures
TSP-CRD-C101
CRD Scram Timing with Auto Scram Timer System
030
Corrective Action
Documents
Action Requests
29555, 432145, 432975, 433649, 433854, 434359,
434361
Miscellaneous
210-28,7
Specification Section 8K Interior Low Range Blast Doors
and Airtight Doors Elevation and Sections
013
Miscellaneous
A553
Door Schedule Sheet 1
045
Miscellaneous
FPF 1.6
Fire Protection Engineering Evaluation, Barrier Functions
List
008
Procedures
1.3.55
Requesting Material, Equipment, Parts and Supplies
000
Procedures
1.3.57
Barrier Impairment
043
Procedures
1.5.11
016
Procedures
10.2.17
Certified Consumable Material Control
011
Procedures
ENG-PRG-09
License Renewal Structures Monitoring Program
Inspections
000
Procedures
Secondary Containment Integrity Verification
2
Procedures
SWP-PUR-02
Procurement Technical Reviews
010
Procedures
SWP-PUR-04
Material, Equipment, Parts and Supplies Procurement
017
Procedures
SYS-4-22
015
Procedures
SYS-4-23
Maintenance Rule Structural Baseline Inspections
001
Work Orders
2194321, 02085605, 02171389
Work Orders
273, 16881, 16131, 19751
Corrective Action
Documents
Action Requests
2305, 433720, 433722, 433768
Corrective Action
Documents
Resulting from
Inspection
Action Requests
433583
Miscellaneous
Operator Logs
06/11/2022
Miscellaneous
P-RRC-IMD-
1A1/2-002
eSoms tracker
Miscellaneous
T22-E-TR-S-001
eSoms tracker
Procedures
1.3.76
Integrated Risk Management
061
Procedures
1.3.83
Protected Equipment Program
035
Procedures
OI-53
Offsite Power
018
Procedures
Offsite Station Power Alignment Check
036
Work Orders
2194327, 02194311, 02194506, 02191551
Corrective Action
Documents
Action Requests
431649, 432666, 432670, 381212, 388291, 388567,
24911
Drawings
EWD-47E-006
Electrical Wiring Diagram Standby AC Power System
Diesel Generator 2 Breaker E-CB-8/DG2
26
Drawings
EWD-47E-007
Electrical Wiring Diagram Standby AC Power System
Diesel Generator 2 Breaker E-CB-DG2/8
21
Drawings
EWD-47E-007A
Electrical Wiring Diagram Standby AC Power System
Diesel Generator 2 Breaker E-CB-DG2/8
005
Drawings
M524-1
Flow Diagram Standby Service Water System Reactor,
Radwaste, DG Bldgs and Yard
140
Drawings
M548-1
Flow Diagram HVAC for Control and Switchgear Rooms
Radwaste Building
103
Drawings
M775
Flow Diagram Emergency Chilled Water Piping System
Control Room
030
Miscellaneous
FPF 1.6-1
Barrier Function Data
008
Miscellaneous
FPF 1.6-1
1, Barrier Functions List - All Barriers
008
Miscellaneous
ME-02-02-23
Post Fire Safe Shutdown Flooding Analysis - Radwaste
Building
001
Miscellaneous
ME-02-03-04
Radwaste Building Flooding Analysis
001
Miscellaneous
TR-102067
Maintenance and Application Guide for Control Relays and
Timers
Procedures
1.3.57
Barrier Impairment
2, 043
Procedures
ABN-
Earthquake
016
Procedures
ABN-ELEC-LOOP
Loss of All Off-Site Electrical Power
019
Procedures
SOP-DG2-
SHUTDOWN
Emergency Diesel Generator (Div 2) Shutdown
018
Procedures
SOP-HVAC/CR-
Control, Cable, and Critical Switchgear Rooms HVAC
Operation
28
Work Orders
2192768, 02186433, 02187816, 02185431, 02169293
Procedures
1.3.9
057
Work Orders
2192768-06
Corrective Action
Documents
Action Requests
430780, 430800, 430869, 432588, 432670, 432705,
2707, 432666
Drawings
M520
Flow Diagram, HPCS and LPCS Systems, Reactor
Building
105
Drawings
M524-1
Flow Diagram Standby Service Water System, Reactor,
140
Radwaste, DG Bldg's and Yard
Drawings
M775
Flow Diagram Emergency Chilled Water Piping System
Control Room
030
Drawings
M959
Flow Diagram Electro-Hydraulic Fluid System Turbine
Generator Building
019
Procedures
10.25.5A
Monthly Battery Testing
016
Procedures
10.25.5B
Quarterly Battery Testing
011
Procedures
OSP-CCH/IST-
M701
Control Room Emergency Chiller System A Operability
057, 058, 059
Procedures
SWP-TST-01
Post Maintenance Testing Program
017
Work Orders
2165190, 02066079, 02161753, 02195412, 02172761,
2145888
Corrective Action
Documents
Action Requests
380387, 259406, 259433, 432986, 433013
Drawings
EWD-15E-006
Reactor Protection System Trip System A Sensor Relays
Sheet 5
006
Drawings
EWD-15E-060
Electrical Wiring Diagram Reactor Protection System Trip
System A Scram Relay
003
Drawings
M539
Flow Diagram Floor Drain System Reactor Building
090
Procedures
ABN-LEAKAGE
Reactor Coolant Leakage
007
Procedures
S Breaker System Functional Test S5
003
Procedures
SOP-ELEC-
6900V-OPS
6900 Volt AC Electrical Power Distribution System
Operation
006
Procedures
SOP-ELEC-BKR-
AC Electrical Breaker Racking
019
Work Orders
2188586, 02161753, 29165898
Corrective Action
Documents
Action Requests
2295, 432298, 432293, 432299, 432307
Miscellaneous
Team 'B' EP Drill Scenario
Miscellaneous
Classification Notification Forms associated with drill
Miscellaneous
ERO Team "B" ERO Drill April 26, 2022, After Action
Report/Improvement Plan
ALARA Plans
R25 RWCU Heat
Exchanger
Replacement
Project
ALARA Post-Job Review
09/14/2021
ALARA Plans
Replace RRC-P-
1A and RRC-MO-
P/1A
Projects 1470501
and 000525201
ALARA Post-Job Review
08/05/2021
ALARA Plans
RWP 30004706
ALARA In-Progress Review (Problem)
05/23/2021
ALARA Plans
RWP 30004706
ALARA In-Progress Review (Exceeded 125% of Estimate)
05/17/2021
ALARA Plans
RWP 30004706
ALARA Plan: R25 ST Replace Hard Seats on RFW-V-32A
& 32B *HI RAD*
Corrective Action
Documents
Action Requests
00419431, 00419954, 00420113, 00420343, 00420392,
00420557, 00420746, 00420932, 00420977, 00421174,
00421250, 00421262, 00421439, 00421857, 00422231,
00422720, 00422874, 00423352, 00423685, 00424199,
00424426, 00424890, 00425213, 00425213, 00425945,
00425945, 00426115, 00426158, 00426198, 00426421,
00426433, 00426695, 00426695, 00427890, 00428401,
00429198, 00429907
Procedures
GEN-RPP-01
ALARA Program Description
009
Procedures
GEN-RPP-02
Radiological Planning and Control Processes
034
Procedures
GEN-RPP-04
Entry Into, Conduct In, and Exit from Radiologically
Controlled Areas
036
Procedures
HPI-0.19
Radiation Protection Standards and Expectations
019
Procedures
HPI-0.41
Expectations for Radiological Job Coverage
001
Procedures
PPM 1.11.15
Control of Radioactive Material
016
Procedures
PPM 11.2.13.1
Radiation and Contamination Surveys
044
Procedures
PPM 11.2.13.8
Airborne Radioactivity Surveys
21
Procedures
PPM 11.2.15.7
Release of Material from Radiologically Controlled Areas
23
Procedures
PPM 11.2.2.14
Radiological Planning and Reviews
007, 008
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
045
Procedures
PPM 11.2.8.2
Radiation Work Permit Preparation and Use
005
Procedures
PPM 6.1.1
Spent Fuel Pool Inventory
010
Procedures
SWP-PRO-01
Procedure and Work Instruction Use and Adherence
034
Procedures
SWP-RPP-01
Radiation Protection Program
016
Radiation
M-20190614-1
RB 501 Steam Tunnel Valves
06/14/2019
Surveys
Radiation
Surveys
M-20210512-6
Drywell, 501-foot Elevation
05/12/2021
Radiation
Surveys
M-20210516-1
05/16/2021
Radiation
Surveys
M-20210516-33
05/16/2021
Radiation
Surveys
M-20210517-28
RB 501' Steam Tunnel with Walkway
05/17/2021
Radiation
Surveys
M-20211031-3
Radioactive Wrench Survey
10/31/2021
Radiation
Surveys
M-20220515-3
Reactor Waste Building 467-foot Elevation "B" Valve
Gallery
05/15/2022
Radiation
Surveys
M-20220517-6
Reactor Waste Building 467-foot Elevation "A" Valve
Gallery
05/17/2022
Radiation
Surveys
M-20220519-4
Reactor Building 471-foot Elevation, Valve 179 Location
05/19/2022
Radiation Work
Permits (RWPs)
30004860
Valve/Pump Work in a Non-High Radiation Area
000
Radiation Work
Permits (RWPs)
30004870
Reactor Waste Building High Radiation Area Work
000
Calibration
Records
WBC #2
FastScan Calibration
09/02/2021
Calibration
Records
WBC #2
FastScan Calibration
07/22/2020
Corrective Action
Documents
Action Requests
00410822, 00415351, 00416339, 00416924, 00416942,
00419654, 00421174, 00421374, 00426198, 00426199,
00428088, 00430536
Corrective Action
Documents
Resulting from
Inspection
Action Requests
00433061, 00433062
Miscellaneous
21 CGS Refueling Outage CRE Report
Miscellaneous
100518-0
Certificate of Accreditation to ISO/IEC 17025:2017
01/01/2022
Miscellaneous
20
Columbia Generating Station Scaling Factors
04/26/2021
Miscellaneous
AR 403244403244CRE/Source Term Reduction
Year Plan 2022
Miscellaneous
Body1.Lib
Primary Whole Body Counting Nuclide Library
08/03/2017
Miscellaneous
RTBD-06-15
Personnel Exposure Monitoring at Columbia Generating
Station
10/01/2019
Miscellaneous
RTBD-17-07
Electronic Dosimeter Geometry Correction Factor for the
iDC Dosimeter Calibrator
09/28/2021
Miscellaneous
RWP 30004916
Neutron Dose Tracking Sheet(s) for MPC #51 on the
Reactor Building 606' elevation.
04/19/2022
through
04/21/2022
Miscellaneous
RWP 30004918
Neutron Dose Tracking Sheet for MPC #51 in the Truck
Bay
04/21/2022
Miscellaneous
TBD 01-04
Updated Prospective Evaluation for Internal Monitoring
2/13/2001
Miscellaneous
TBD 02-05 R-1
Neutron Dosimetry and Survey Instruments for ISFSI
08/05/2002
Miscellaneous
TBD 12-05
Calibration Correction Factor for DMC 2000
2/22/2013
Miscellaneous
TBD 15-02
Bases for Neutron Correction Factors for OSLN and
Survey Instruments
04/08/2015
Miscellaneous
TBD 18-04
Basis for Scaling and Detecting Internal Dose
08/23/2018
Procedures
GEN-RPP-06
Dosimetry Program Description
015
Procedures
HPI-4.30
Processing, Evaluation, and Reporting of DLR Exposure
Data
017
Procedures
HPI-5.9
Evaluation of In-Vivo Bioassay Results Following a
Potential Intake
015
Procedures
HPI-6.4
Administering an Occupational Radiation Exposure History
File
27
Procedures
PPM 11.2.15.13
Control of Personnel Skin and Clothing Contamination
010
Procedures
PPM 11.2.4.5
Whole Body Counts and Daily Checks Using the
Renaissance Fastscan
019
Procedures
PPM 11.2.6.4
Damaged, Lost, or Off-Scale Dosimetry Devices
016
Procedures
PPM 11.2.6.7
Special Dosimetry
20
Procedures
SWP-RPP-01
Radiation Protection Program
016
Radiation
Surveys
M-20220419-6
04/19/2022
Self-
Snapshot Self-Assessment Report:
2/10/2022
Assessments
Internal and external Dosimetry Programs
Radiation
Surveys
M-20220406-6
RW 437 COND Liner Survey 22-2027-HP
04/06/2022
Radiation
Surveys
M-20220516-3
Outgoing Cask 14D-2.0 Cask w/ 22-Title: 027-HP to U.S.
Ecology
05/16/2022
Shipping Records 22-22
Shipment Summary
04/12/2022
Shipping Records 22-22
Radioactive Waste Manifest
05/18/2022
71151
Corrective Action
Documents
Action Requests
25605
71151
Miscellaneous
21 Annual Radioactive Effluent Release Report
04/15/2022
71151
Miscellaneous
LER 2021-001-00
Breach of Secondary Containment
71151
Miscellaneous
LER 2021-002-00
Integrated Leak Test
71151
Procedures
HPI-0.14
Assessing and Reporting NRC Occupational Exposure
Control Effectiveness Performance Indicator Data
006
71151
Self-
Assessments
Snapshot Self-Assessment Report:
Occupational Exposure Control Performance Indicator
(OR01)
2/17/2022
71151
Self-
Assessments
Snapshot Self-Assessment Report:
Performance Indicator (PI) Verification PR-01:
Radiological Effluent Technical Specification/Offsite Dose
Calculation Manual Radiological Effluent Occurrences
2/15/2021
Corrective Action
Documents
Action Requests
404225
Corrective Action
Documents
Resulting from
Inspection
Action Requests
433521, 434115
Drawings
E502-4
Main One Line Diagram
010
Procedures
1.3.76
Integrated Risk Management
061
Procedures
1.5.14
Risk Assessment and Management for
Maintenance/Surveillance Activities
043
Corrective Action
Documents
Action Requests
433079, 432260, 431980, 431804, 431250, 431110,
431123, 430356
Corrective Action
Documents
Resulting from
Inspection
Action Requests
431649, 432145
Procedures
SWP-CAP-01
Corrective Action Program
044
Corrective Action
Documents
Action Requests
433720, 433722, 433725
Drawings
E502-4
Main One Line Diagram
010
Drawings
E507-7A
Main Three Line Diagram, Loop A, Reactor Recirc Pump
006
Miscellaneous
Operator Logs
06/11-13/2022
Miscellaneous
Average power range monitor neutron flux, Recirc Pump
Motor Frequency and pump Flow, total core flow data
trending during the event on June 11, 2022
Procedures
Verification of Plant Operating Parameters for Single Loop
Operation
005
Procedures
RRC Pump Start Temperature and Loop Flow Verification
014
Procedures
SOP-RRC-ASD
Reactor Recirculation ASD Operations
016
Procedures
SOP-RRC-START
Reactor Recirculation System Start
21