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Design Basis Assurance Inspection (Team) Inspection Report 05000397/2022010
	ML22175A050
Person / Time
Site:	Columbia
Issue date:	06/30/2022
From:	Vincent Gaddy; NRC Region 4
To:	Scheutz R; Energy Northwest
References
	IR 2022010
	Download: ML22175A050 (15)
	v • d • e

SUBJECT:

COLUMBIA GENERATING STATION - DESIGN BASIS ASSURANCE INSPECTION (TEAM) INSPECTION REPORT 05000397/2022010

Dear Mr. Scheutz:

On May 26, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station and discussed the results of this inspection with Mr. W.G. Hettel, Chief Nuclear Officer/VP Nuclear Generation and other members of your staff. The results of this inspection are documented in the enclosed report.

One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or the significance or severity of the violation 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.

June 30, 2022 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, Vincent G. Gaddy, Chief Engineering Branch 1 Division of Operating Reactor Safety Docket No. 05000397 License No. NPF-21

Enclosure:

As stated

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2022010

Enterprise Identifier:

I-2022-010-0011

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, WA

Inspection Dates:

May 09, 2022, to May 27, 2022

Inspectors:

J. Braisted, Reactor Inspector

M. Chisolm, Reactor Inspector

R. Deese, Senior Reactor Analyst

G. George, Senior Reactor Inspector

C. Smith, Senior Reactor Inspector

F. Thomas, Reactor Inspector

C. Young, Senior Reactor Analyst

Approved By:

Vincent G. Gaddy, Chief

Engineering Branch 1

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a design basis assurance inspection (team) 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 Identify and Correct Adverse HVAC Airflows in the Division II Electrical Safety Bus Vital Island Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2022010-01 Open/Closed

[H.6] - Design Margins 71111.21M The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for Energy Northwests failure to promptly identify and correct a condition adverse to quality. Specifically, from June 5, 2019, to May 26, 2022, the licensee failed to assure that degraded Division II critical switchgear area heating, ventilation, and air conditioning (HVAC) system airflows were promptly identified and corrected.

Additional Tracking Items

None.

INSPECTION SCOPES

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

REACTOR SAFETY

===71111.21M - Design Bases Assurance Inspection (Team) The inspectors evaluated the following components and listed applicable attributes, permanent modifications, and operating experience:

Design Review - Risk-Significant/Low Design Margin Components (IP Section 02.02) (6 Samples)

From May 9, 2022, to May 26, 2022, the team inspected the following components and listed applicable attributes.

(1) High-Pressure Core Spray Minimum Control Valve HPCS-V-12

Thrust and set-point calculation

Weak-link calculation to determine the maximum allowable thrust

Evaluation of pressure-locking and thermal binding

Calculation for setpoint range and allowable value determination for high pressure core spray flow indicating switch instrument loop

Preventive maintenance for inspection and lubrication

Surveillance and Inservice testing procedures and results

Corrective action documents to ensure that degraded or nonconforming conditions are identified and corrected

(2) Division II Battery Chargers E-C1-2A

Vendor technical documentation

Corrective actions associated with the E-C1-2A charger

Surveillance test results to verify charger supplies the required loads

Preventative maintenance and calibration records to ensure setpoints were within established acceptance criteria

Maintenance work orders to ensure appropriate component replacements and relay settings

(3) High Pressure Core Spray Emergency Diesel Generator DG-ENG-1C

Vendor documents on the operation and maintenance recommendations

Corrective action documents and system health reports

Calculations for fuel oil consumption rates

Suitability of elastomer materials with ultra-low-sulfur-diesel fuel Preventative maintenance and surveillance test records

(4) High Pressure Core Spray Room Cooler RRA-FN-4

Engineering calculations associated with replacement coils for cooler

Room cooler fan performance data and calculations to verify adequate room cooling

Preventative maintenance results for the fan and coils

Corrective action documents to ensure degraded or nonconforming conditions are identified and corrected

(5) Division II Direct Current (DC) Bus S1/2

System health report

Heating, ventilation, and air conditioning system calculations and flow balance test results for electrical rooms

Maintenance, inspection, and testing procedures

Vendor operating and maintenance requirements

Short circuit calculations, coordination studies, voltage drop calculations, and maintenance activities to ensure they were appropriate for the design of the Class 1E S1/2 DC Bus

Operating voltage characteristics to verify the Class 1E S1/2 DC Bus and downstream components can perform their design function through input voltage ranges

Corrective action documents to ensure degraded or nonconforming conditions are identified and corrected

(6) Circuit Breaker 7-73

System health report

Maintenance, inspection, and testing procedures

Vendor operating and maintenance requirements

Short circuit calculations, coordination studies, voltage drop calculations, and maintenance activities to ensure they were appropriate for the design 7-73 Circuit Breaker Design Review - Large Early Release Frequency (LERFs) (IP Section 02.02)===

Main article: IP 71111.21

From May 9, 2022, to May 26, 2022, the team inspected the following component and listed applicable attributes.

(1) Wetwell to Drywell Vacuum Breaker Valves

Vendor installation, operation, and maintenance manual to compare vendor recommendations with licensee practices.

Design specification to understand requirements for the engineering, design, fabrication, testing, and delivery of the valves.

Preventive maintenance documentation for a limited disassembly, inspection, and reassembly of the valves.

Calculation of leakage rate test acceptance criterion to compare with test procedure and design values to support the primary containment pressure suppression function.

Testing documentation for demonstration of operability per technical specifications and the inservice testing program.

Corrective action documents to ensure that degraded or nonconforming conditions are identified and corrected.

Modification Review - Permanent Mods (IP Section 02.03) (5 Samples)

From May 9, 2022, to May 26, 2022, the team inspected the following permanent plant modifications.

(1) EC 08076, Power Range Nuclear Monitor System Replacement

(2) EC 12954, Move Non-1E Loads from Safety Related Inverter E-PP-7AA (Division 1)

(3) EC 13629, Change RCIC-MO-8 Motor and Gear Ratio for Margin

(4) EC 14646, Replace SR 250V / 125V Motor Control Center DC Buckets ITE Gould Starters with NLI

(5) EC 17459, MAG Rotor Replacement - RHR-M-V/24A

Review of Operating Experience Issues (IP Section 02.06) (3 Samples)

From May 9, 2022, to May 26, 2022, the team inspected the following operating experience issues.

(1) NRC Information Notice 2021-03: Operating Experience Related to the Duane Arnold Energy Center Derecho Event on August 10, 2020

(2) NRC Inspection Manual Operating Experience Smart Sample (OpESS)2020/01: Flex Equipment Design Control, Maintenance, and Testing

(3) NRC Information Notice 2006-22: New Ultra-Low-Sulfur Diesel Fuel Oil Could Adversely Impact Diesel Engine Performance

INSPECTION RESULTS

Failure to Identify and Correct Adverse HVAC Airflows in the Division II Electrical Safety Bus Vital Island Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2022010-01 Open/Closed

[H.6] - Design Margins 71111.21M The inspectors identified a Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, for Energy Northwests failure to promptly identify and correct a condition adverse to quality. Specifically, from June 5, 2019, to May 26, 2022, the licensee failed to assure that degraded Division II critical switchgear area heating, ventilation, and air conditioning (HVAC) system airflows were promptly identified and corrected.

Description:

The critical switchgear area HVAC system is designed to maintain temperatures in the electrical rooms between 55 degrees Fahrenheit and 104 degrees Fahrenheit during normal operation and to limit the temperatures below equipment operability limits during all emergency modes of operation. The safety-related WMA-FN-53B ventilation system achieves this function by maintaining temperatures for safety-related Division II battery room, charger room, reactor protection system equipment room, HVAC equipment room, and critical switchgear room. The Division II critical switchgear area HVAC system was designed to supply airflow at 22,800 cubic feet per minute to the switchgear area. Calculation ME-02-92-43, Room Temperature Calculation for DG Building, Reactor Building, Radwaste Building and Service Water, Revision 14, conservatively assumes that the WMA-FN-53B ventilation system supply airflow is 90 percent of design flow or 20,520 cubic feet per minute.

The inspectors reviewed the June 5, 2019, airflow testing and balancing results of the Division II critical switchgear room area ventilation system, WMA-FN-53B. The as-found test results indicated that the total supply airflow from the ventilation system was 17,210 cubic feet per minute, which was below design calculation assumptions. Additionally, the supply airflow to the Division II critical switchgear room and charger room were both below minimum airflows assumed in room temperature design calculation. Following damper adjustments, the ventilation system supply airflow was left at 18,038 cubic feet per minute; leaving supply airflow to the Division II charger room, HVAC room, critical switchgear room, battery room, and reactor protection system room below minimum airflows assumed in the design calculation.

Upon discovery of the degraded airflow results, the inspectors requested the licensees condition report, the associated corrective actions, operability determination, and reportability evaluation that identified and corrected the condition adverse to quality. The licensee informed the inspectors that the condition adverse to quality was not entered into the corrective action program; therefore, no corrective actions, operability determination, or past operability evaluation were initiated.

In accordance with Energy Northwest Procedure SWP-CAP-01, Corrective Action Program, the licensee failed to initiate a condition report to identify the degraded airflows and initiate corrective actions to correct the condition adverse to quality.

Corrective Actions: Following prompting by the inspectors, the licensee initiated a condition report to identify the degraded airflow conditions. The licensee reperformed the room temperature calculations with the as-left airflow results. This calculation determined that the Division II WMA-FN-53B system would maintain its design function although with very little design margin.

Corrective Action References: Action Request Condition Report 00433066

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to identify and initiate corrective actions for degraded airflows in the corrective action program, in accordance with Energy Northwest Procedure SWP-CAP-01, Corrective Action Program," was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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, Energy Northwest failed to maintain Division II vital island HVAC airflows within the design assumptions, and in order to justify the as-found condition, Energy Northwest revised assumptions solely to obtain favorable results, similar to Example 3.h in Inspection Manual Chapter 0612, Appendix E, "Examples of Minor Issues."

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. Using Exhibit 2, Mitigating Systems Screening Questions, the inspectors determined the finding to be of very low safety significance (Green) because the finding affected the design or qualification of a mitigating SSC and did not affect its operability or PRA functionality.

Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. Specifically, since June 2019, the licensee failed to operate and maintain the Division II WM-FN-53B ventilation system well within their design requirements.

Enforcement:

Violation: Title 10 Code of Federal Regulations Part 50, Appendix B, Criterion XVI, "Corrective Action," states "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 the above, from June 5, 2019, to May 26, 2022, the licensee failed to assure that conditions adverse to quality were promptly identify and corrected. Specifically, the licensee failed to assure that degraded Division II critical switchgear area heating, ventilation, and air conditioning (HVAC) system airflows were promptly identified and corrected.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

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

On May 26, 2022, the inspectors presented the design basis assurance inspection (team) inspection results to Mr. W.G. Hettel, Chief Nuclear Officer/VP Nuclear Generation and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

v t e Inspection Report - Columbia - 2022010
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2022 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 10(0) Security 401(0) 402(0) 403(0) 404(0) 405(0) 406(0) Operator Exams Emergency Planning Other

IR 05000397/2022010