IR 05000397/2023010
| ML23310A103 | |
| Person / Time | |
|---|---|
| Site: | Columbia  (NPF-021) |
| Issue date: | 11/09/2023 |
| From: | Ami Agrawal NRC/RGN-IV/DORS |
| To: | Schuetz R Energy Northwest |
| Azua R | |
| References | |
| IR 2023010 | |
| Download: ML23310A103 (25) | |
Text
November 09, 2023
SUBJECT:
COLUMBIA GENERATING STATION - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000397/2023010
Dear Robert Schuetz:
On September 28, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Columbia Generating Station and discussed the results of this inspection with Randy Pruett, Plant Manager and other members of your staff.
The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations problem identification and resolution program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for problem identification and resolution programs.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. The team concluded that recent senior management actions has caused a Chilled Work Environment in the Operations Department because of a perception that operators are not free to raise safety concerns using all available avenues without fear of retaliation. We have not identified any serious safety violations or instances involving significant plant safety issues, but the information gathered has led to concerns about the impact the work environment is having on plant operations and raises questions about your commitment to emphasize safety over competing goals to ensure protection of people and the environment. The team brought these concerns to your attention and to the attention of Senior members of your staff. Following conversations between Region IV management, yourself, and Senior members of your staff, regarding the concerns raised by the team, your staff submitted to the NRC a list of actions that you have taken and actions that you have proposed to take to address the concerns raised by the team during the inspection. These actions are described in the body of this report. Due to the seriousness of the concerns raised by the PI&R team, Region IV management has determined that it is appropriate that we perform Inspection Procedure 93100, "Safety-Conscious Work Environment Issue of Concern Follow-up," at a future time, to be determined, to evaluate the effectiveness of your proposed actions. The Regional Administrator has approved the use of this inspection procedure.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Ami N. Agrawal, Team Lead Inspection Programs & Assessment Team 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-2023-010-0005
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, WA
Inspection Dates:
September 11, 2023 to September 28, 2023
Inspectors:
R. Azua, Senior Reactor Inspector
C. Cauffman, Reactor Operations Engineer
A. Donley, Resident Inspector
W. Tejada, Physical Security Inspector
D. Willis, Team Leader
Approved By:
Ami N. Agrawal, Team Lead
Inspection Programs & Assessment Team
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Columbia Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program, use of operating experience, self-assessments and audits, and safety conscious work environment.
- Corrective Action Program Effectiveness: The inspectors assessed the corrective action programs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Reactor Recirculation Pump Adjustable Speed Drive system.
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Assessment Effectiveness of Problem Identification: Based on the samples reviewed, the team determined that the licensee's performance in this area adequately supported nuclear safety. Overall, the team found that the licensee was identifying and documenting problems at an appropriately low threshold that supported nuclear safety.
Effectiveness of Prioritization and Evaluation of Issues: Overall, the team found that the licensee was appropriately prioritizing and evaluating issues to support nuclear safety. Of the samples reviewed, the team found that the licensee, in general, correctly characterized condition reports as to whether they represented conditions adverse to quality, and then prioritized the evaluation and corrective actions in accordance with program guidance.
Effectiveness of Corrective Actions: Overall, the team concluded that the licensee's corrective actions supported nuclear safety. The licensee generally developed effective corrective actions for the problems evaluated in the corrective action program. They generally implemented these corrective actions in a timely manner, commensurate with their safety significance. Finally, it was determined that the licensee reviewed the effectiveness of these corrective actions appropriately.
- As part of this inspection, the team selected the Reactor Recirculation Pump Adjustable Speed Drive system for a focused review within the corrective action program. For this system, the team performed sample selections of Condition Reports, looking at the adequacy of the licensee's evaluation process for determining which items are placed in the corrective actions process, and the corrective actions taken. The team also reviewed the licensee's use of operational experience and the Part 21 process with respect to this system.
- The material condition of this system appeared to be adequate. Having said that, the team observed that the system has had a number of equipment failures due in-part to the age of the system and the fact that the original vendor is no longer available. This has required the station to refurbish old parts or purchase replacement parts from other vendors, which in some cases has resulted in failures that caused plant perturbations including unplanned plant power reductions. The inspectors found that this has been an issue that has caused the operations staff much concern.
- The most recent repairs appear to have addressed some of these problems. Plus, it has been brought to the NRC's attention that the Columbia Generating Station is planning to replace this system in the near future.
Corrective Action Program Assessment: Based on the samples reviewed, the team determined the licensee's corrective action program complied with regulatory requirements and self-imposed standards. The licensee's implementation of the corrective action program adequately supported nuclear safety. The team found that management's oversight of the corrective action program process was effective.
Assessment 71152B Operating Experience, Self-Assessment and Audit Assessment Operating Experience: The team reviewed a variety of sources of operating experience including 10 CFR Part 21 notifications and other vendor correspondence, NRC generic communications, and publications from various industry groups including INPO and EPRI. The team determined that the Columbia Generating Station staff is adequately screening and addressing issues identified through operational experience that apply to the station and that this information is evaluated in a timely manner once it is received.
Self-Assessments and Audit Assessment: The team reviewed a sample of the licensee's departmental self-assessments and audits to assess whether they regularly identified performance trends and effectively addressed them. The team also reviewed audit reports to assess the effectiveness of assessments in specific areas. Overall, the team concluded that the licensee had an effective departmental self-assessment and audit process.
Assessment 71152B Safety-Conscious Work Environment (SCWE) Assessment The NRCs Final Safety Culture Policy Statement applies to all NRC licensees, applicants, and vendors. The NRCs expectation is that all licensees maintain a healthy safety culture. The policy statement discusses 9 traits of a healthy safety culture to include environment for raising safety concerns, leadership safety values and actions, and effective safety communications. The Safety Culture Policy Statement notes that these traits describe patterns of thinking, feeling, and behaving that emphasize safety, particularly in conflict situations (e.g., safety considerations given precedence over concerns about production, schedule, and the cost of the effort). The NUREG 2165 "Safety Culture Common Language,"
provides a list of 10 traits (one trait added) and corresponding attributes that further that define a healthy safety culture (i.e., leadership, environment for raising concerns, etc.).
In addition, the Commission's policy statement, "Freedom of Employees in the Nuclear Industry to Raise Safety Concerns Without Fear of Retaliation," (61 FR 24336; May 14, 1996)describes a safety conscious work environment (SCWE) as a work environment in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation.
As part of this inspection, the team interviewed approximately sixty individuals in twelve group interviews. The purpose of these interviews was
- (1) to evaluate your safety-conscious work environment (SCWE) and
- (2) to evaluate the perceived effectiveness of the corrective action program at resolving identified problems.
The focus group participants included personnel from Operations, Radiation Protection, Mechanical and Electrical Maintenance, and Instrumentation and Controls. For the personnel in the Radiation Protection, Mechanical & Electrical Maintenance, and Instrumentation and Controls departments, the team found no evidence of challenges to the safety-conscious work environment. Individuals in these groups expressed a willingness to raise nuclear safety concerns and other issues through several means available including their management and the corrective action process.
The corrective actions put in place to correct previously identified work environment issues in Radiation Protection organization appear to have been effective. The team heard concerns about future resources for personnel as personnel retire and concerns about increasing the time in between preventative maintenance (PM) activities. Therefore, continued monitoring of these areas should ensure that future needs for qualified staff and PMs are analyzed and addressed.
The team spent considerable time interviewing operations staff and observing operations in the control room. Based on the interviews, the team concluded that recent senior management actions have caused a chilled work environment in the Operations Department due to a perception that operators are not free to raise safety concerns using all available avenues without the fear of retaliation. The team did not identify any serious safety violations or instances involving significant plant safety issues. However, the information gathered has led to concerns about the impact the work environment is having on plant operations and raises questions about your commitment to emphasize safety over competing goals to ensure the health and safety of the public.
In general, at the time of the inspection, the team heard that over half of the employees in the operations department stated that they were aware of multiple events in which senior managements reactions to others raising concerns could be perceived as retaliation. These actions by senior management have caused Operations staff to state that they would raise safety issues because it is their job and their responsibility. However, Operations personnel indicated a concern that senior management may take negative actions against them if they dislike the message, the manner in which the message is delivered, or the venue chosen in which it is delivered. Because of this, the NRC is concerned that a fear of retaliation exists to the extent that it is impeding open communication within the Operations Department.
The following observations leads the team to have concerns that the current environment is impacting the normal processes designed to identify such issues. The team heard that some Operations personnel will not use the Employee Concerns Program (ECP) due to a perception that information shared may not remain confidential. Also, some operations personnel indicated that while they are willing to write CRs, they have an overall perception that they will not always receive adequate feedback on the resolution of those CRs. In addition, the team identified that the Nuclear Safety Culture Monitoring Panel determined that there was a steady increase of anonymous CRs.
In addition, the team heard that staffing in the operations organization, plus the resultant overtime, has caused tremendous strain on the organization and has negatively affected Operations staff morale. The team heard that this deficit has been communicated by the operations staff to senior management multiple times, but the responses have been inadequate, slow and dont fully appear to resolve the current concerns. The NRC team determined that this impacted the trait of Leadership Safety Values and Actions (LA) which states that leaders should ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety, which is attribute LA.1 within NUREG 2165 Safety Culture Common Language.
Lastly, the team also heard about perceptions that senior management failed to adequately communicate the basis for their decisions. This included communications regarding decisions for equipment issues and staffing. This lack of information made it difficult for operations staff to fully understand how senior management prioritized safety during the decision-making process. The NRC team determined that this impacted the trait of Communication which states that leaders ensure that the basis for operational and organizational decisions is communicated in a timely manner, which is attribute CO.2 within NUREG 2165.
The team's review found that information from the corrective action program, the ECP, and other sources (Ask Senior Management questions), have provided opportunities for senior management to identify changes in certain aspects of the safety culture and SCWE, but the information had not been fully acknowledged and acted upon at the time of the inspection.
Following conversations between Region IV management and licensee senior management regarding the concerns raised by the team, the licensee submitted actions that they have taken and actions that they have proposed to take to address the concerns raised by the team during the inspection. These actions are as follows:
1. An outside vendor will conduct an independent safety culture evaluation to determine what
caused the reluctance to raise concerns and fear of retribution within the Operations Department and how the station should have identified and corrected the issue (AR 00450673 initiated on 09/20/23). Due Date: 11/30/23
2. Operations SCWE actions to address the work environment issues (AR 00450484).
1) An Emergent Nuclear Safety Culture Monitoring Panel meeting to discuss the work environment in the operations department. Complete: 10/11/23 2) Operations management will communicate staffing plans to the Operations department. Due Date: 11/9/23 3) The ECP will conduct electronic SCWE pulse surveys that specifically asks if the individual feels comfortable raising concerns. Due Date:11/9/23 4) The ECP developed a rotational schedule with key department managers/supervisors at least quarterly and provide coaching. Complete 5) The ECP will schedule and implement rotational lunch meetings with key departments staff other than managers/supervisors and improve relationships, communications and understanding of the ECP program. Complete 6) The ECP will conduct benchmarking of industry best ECP practices. Due Date:
10/26/23 7) The ECP will conduct a cross functional review of 93-100 review and adjust SCWE survey questions to align with INPO and NRC (Due Date: 10/26/23)8) The ECP will develop a robust communication plan to improve awareness and understanding of the ECP program. Due Date: 10/26/23 9) A cross functional team will conduct an effectiveness review of all assignments. Due Date: 1/31/24 10) The ECP developed an ECP rotational D-15 schedule with all agency departments.
Complete 11) The ECP will develop and implement a comprehensive communication plan to the entire station about comments from the Problem Identification & Resolution (PI&R)inspection and the stations plan to address issues. Due Date: 10/25/23 12) Performance Improvement will establish a SCWE trend code to be added to any susceptible Condition Reports to use for trending. This tag will be discussed with the Management Review Team. Complete 13) Training Request 23-0127 is submitted to establish annual SCWE training for Managers and Supervisors. Due Date: 1/10/24 14) An external assessment of the ECP program will be scheduled and completed. Due Date: 12/20/23 15) The station will conduct an external SCWE assessment. An independent external agency will be contracted to evaluate the agency work environment in approximately 4-months. Due Date: 4/17/24 16) The Chief Nuclear Officer began and will continue meeting with operations staff on shift and during their training week to improve trust. Due Date: 12/05/23 17) The ECP will benchmark industry best Nuclear Safety Culture Monitoring Panel practices. Due Date: 10/25/23 18) Operations will develop and implement a monthly roll up communication to include events, concerns received and resolutions, as well as top safety issues with updates.
Due Date: 10/25/23 19) The station will conduct Complements and Concerns 2Cs meetings in January of 2024. This will be a cross functional effort requiring departments to use a manager outside his/her department. This will evaluate trajectory of recovery. Due Date:
1/24/24 20) The Chief Nuclear Officer (CNO) will meet with management to discuss the removal of language, The Plant General Manager (PGM) will openly discuss the results with all crews. The discussion and communication will be developed by 10/5/2023. Complete 21) Develop a plan that ensures operators are involved in decisions and issues. This plan will be presented to the CNO and Continuous Improvement Manager for approval.
Due Date: 10/11/23 22) The Employee Concerns Program Manager (ECP) will develop talking points from AR00498656, (design concern). The PGM will present the results to all crews. Due Date: Complete 23) Site Vice President will communicate the basis for the decision around verification for clearance hang. Complete 24) Columbia Generating Station (CGS) will conduct a review of all Ask Senior Management questions relating to the Operations department. The PGM will rewrite and discuss the answers with each crew. Due Date: 10/11/23 25) PGM will discuss the board meeting discussions in questions. Due Date: Complete 26) The CNO will develop a process for feedback. Due Date: 10/31/2023 27) The CNO and CEO will author a company news article explaining the stations Zero tolerance for retaliation. Due Date: 10/19/2023 28) The SVP will send a letter to all operations personnel explaining the stations policy against Retaliation. Arrange face-to-face conversations with all Operations personnel.
Due Date: 10/26/2023 29) The Operations Manager will document singe person policy assessment results. Due Date 11/16/2023 The NRC will continue to monitor the safety culture at the Columbia Generating Station and expects that you enact swift corrective actions to effect change in the operations department.
The NRC will continue to follow its process as prescribed in the Allegations Manual Section 5.2.i.6 to determine any future actions associated with the NRC's oversight of the SCWE within the Columbia Generating Station. In addition, the licensee has been informed that the NRC plans to perform Inspection Procedure 93100, "Safety-Conscious Work Environment Issue of Concern Follow-up," at a future date, to evaluate the effectiveness of the licensee's actions in this matter.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 28, 2023, the inspectors presented the biennial problem identification and resolution inspection results to Randy Pruett, Plant Manager and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Action Requests
205427, 259975, 312978, 352835, 359748, 361567, 361788,
363946, 367515, 388849, 391991, 393944, 398399, 403173,
404225, 404832, 405604, 410057, 413112, 419431, 419487,
419954, 419968, 420162, 420746, 420829, 421303, 421357,
21568, 421857, 422006, 423611, 423658, 423690, 423693,
23940, 424193, 424236, 424250, 424311, 424436, 424457,
24487, 424814, 424925, 425179, 425316, 425456, 425605,
25713, 426199, 426212, 426249, 426299, 426743, 426803,
26834, 427090, 427172, 427768, 427776, 427801, 427855,
27871, 428031, 428079, 428413, 428421, 428546, 429166,
29255, 429466, 429738, 429926, 429989, 430211, 430495,
430537, 430766, 430818, 430924, 431209, 431649, 431889,
2093, 432106, 432171, 432260, 432740, 432856, 432856,
2930, 433050, 433061, 433062, 433067, 433281, 433328,
433380, 433637, 433720, 433852, 433989, 434115, 434198,
434488, 434489, 434563, 434743, 435049, 435163, 435206,
435752, 435836, 435960, 436016, 436041, 436053, 436570,
436712, 437348, 437360, 437377, 437460, 437461, 437462,
437463, 437979, 438046, 438331, 438525, 439645, 439653,
440346, 440523, 440724, 440735, 440858, 441373, 441418,
441573, 441609, 441704, 441751, 441760, 441984, 442009,
2197, 442428, 442932, 443014, 443065, 443098, 443159,
443546, 443731, 444188, 444241, 444391, 444441, 444579,
444730, 444803, 444809, 444812, 445012, 445162, 445163,
445210, 445213, 445257, 445323, 445373, 445381, 445396,
445979, 446032, 446093, 446166, 446644, 446993, 447070,
447115, 447278, 447533, 447712, 448454, 448533, 448863,
448888, 449006, 449389, 449541, 450310, 450378
Drawings
M521-2
Flow Diagram Residual Heat Removal Loop B"
117
Miscellaneous
Local Leak Rate Testing Scope Reduction for Columbia
Generating Station (CGS) RHR System Technical Specification 5.5.12, Primary Containment Leakage Rate
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Testing Program
Miscellaneous
Form 2500
Pre-Job Brief Checklist for Investigation Template, Governing
Document: SWP-CAP-01, Corrective Action Program
005
Miscellaneous
LDCN -23-005
Energy Northwest Licensing Document Change Notice
Procedures
1.10.11
Technical Assessments Supporting Reportability and
Reportability Evaluations
004
Procedures
1.3.66
038
Procedures
1.3.68
Work Management Process
037
Procedures
10.25.234
Equalize Charging 24 VDC, 125 VDC, and 250 VDC Station
Batteries
004
Procedures
GEN-RPP-02
Controls for Temporary Shielding
Rev. 18
Procedures
GEN-RPP-02
ALARA Planning and Radiation Work Permits
Rev. 34
Procedures
HPI 5.9
Evaluation of In-Vivo Bioassay Results Following a Potential
Intake
Rev. 17
Procedures
HPI-12.96
Health Physics Instruction Manual
Rev. 11
Procedures
PP 11.2.7.3
High Radiation Area, Locked High Radiation Area, and Very
High Radiation Page Area Controls
Rev. 46
Procedures
PPM 11.2.4.5
Whole body Counts and Daily Checks Using the
Renaissance Fastscan
Rev. 19
Procedures
SWP-CAP-01
Corrective Action Program
Procedures
SWP-PRO-03
Writer's Manual
Procedures
SWP-PRO-01
Procedure and Work Instruction Use and Adherence
Rev. 25
Procedures
TSP-RHR/X25B-
C801
LLRT of RHR-V-27B
Major 003
Minor 002
Self-Assessments
00423761
Part 37 Snapshot Self-Assessment Report
2/1/2021
Self-Assessments
00426212
Snapshot Self-Assessment Report - System Vulnerability
Evaluation (SVE) on the AC (Instruments) System
Self-Assessments
435882
Part 37 Snapshot Self-Assessment Report
11/14/2022
Work Orders
2199124, 02202521, 02192768, 02185920, 02189679,
2116068, 02094683, 02203670, 02196056, 02191528,
2194749, 02179663, 02181425
Work Orders
work requests
29163754, 29164993, 29170654, 29169653, 29167088,
29165898, 29164957, 29166010, 29164777, 29164778,
29163264, 29163071, 29161538, 29137056, 29129835,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
29165805, 29166388, 29171104