IR 05000397/2024003
| ML24310A300 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/12/2024 |
| From: | Patricia Vossmar NRC/RGN-IV/DORS/PBA |
| To: | Schuetz R Energy Northwest |
| References | |
| IR 2024003 | |
| Download: ML24310A300 (1) | |
Text
November 12, 2024
SUBJECT:
COLUMBIA GENERATING STATION - INTEGRATED INSPECTION REPORT 05000397/2024003
Dear Robert Schuetz:
On September 30, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On October 28, 2024, the NRC inspectors discussed the results of this inspection with Dave Brown, Site Vice President, and other members of your staff. The results of this inspection are documented in the enclosed report.
Three findings of very low safety significance (Green) are documented in this report. All 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.
A licensee-identified violation which was determined to be Severity Level IV is also documented in this report. 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 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, Patricia J. Vossmar, Chief Reactor Projects Branch A Division of Operating Reactor Safety Docket No. 05000397 License No. NPF-21
Enclosure:
As stated
Inspection Report
Docket No:
05000397
License Nor:
Report No:
Enterprise Identifier:
I-2024-003-0007
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, WA
Inspection Dates:
July 1, 2024, to September 30, 2024
Inspectors:
B. Baca, Health Physicist
J. Brodlowicz, Resident Inspector
N. Greene, Senior Health Physicist
N. Hernandez, Senior Operations Engineer
C. Highley, Senior Resident Inspector
R. Kopriva, Senior Project Engineer
J. Melfi, Project Engineer
Approved By:
Patricia J. Vossmar, Chief
Reactor 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. A licensee-identified non-cited violation is documented in report section: 71111.1
List of Findings and Violations
Failure to Recognize Entry into an Orange 10 CFR 50.65(a)(4) Risk Window Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2024003-01 Open/Closed
[H.8] -
Procedure Adherence 71111.13 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of 10 CFR 50.65(a)(4) when Energy Northwest failed to identify an Orange risk window that occurred during a planned Yellow risk window, and a planned high-pressure core spray maintenance window outage, due to a failure of the service air dryer.
Failure of the Diesel Generator Cooling Coil due to Inadequate Maintenance Instruction and Post-Maintenance Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2024003-02 Open/Closed
[H.5] - Work Management 71111.15 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to establish and perform maintenance procedures appropriate to the circumstances. Specifically, the licensees Work Order 02144751 did not establish sufficient detail for the installation or post-maintenance testing of diesel generator room air handling unit damper motors. As a result, damper motor switches were set incorrectly and an air handling unit cooling coil failed during cold weather resulting in an inoperable condition for diesel generator 2 and service water train B, with diesel generator 2 being inoperable for greater than the technical specification allowed outage time.
Failure to Follow ALARA Planning Procedures Resulting in Unplanned Dose for a Work Activity Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/2024003-03 Open/Closed
[H.5] - Work Management 71124.01 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1 because the licensee failed to follow their as low as reasonably achievable planning procedure resulting in unplanned dose while performing work associated with Radiation Work Permit (RWP) 30004994, Refueling Outage 26 (R26) Steam Tunnel
RFW-V-65 A & B - High Risk, as related to RFW-V-65A valve work. Specifically, the procedure instructed the licensee to estimate the effective dose rate related to the current work area conditions, body position, and deviations from historical data and assumptions. The licensee initially planned the RFW-V-65A valve work for approximately 3.604 person-Rem, whereas the actual dose accrued to complete the work activity was 27.233 person-Rem.
Additional Tracking Items
None.
PLANT STATUS
The unit began the inspection period at or near rated thermal power. On July 17, 2024, the unit was down powered to 44 percent for reactor recirculation pump variable frequency drive maintenance. The unit was returned to rated thermal power on July 17, 2024. On September 20, 2024, the unit was down powered to 45 percent power for plant testing on bypass valves, variable speed drives for reactor recirculation system, and rod sequence exchange. The unit was returned to rated thermal power on September 22, 2024, and remained at or near rated thermal power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, 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
Impending Severe Weather Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the adequacy of the overall preparations to protect risk-significant systems from impending severe high temperature weather on August 2, 2024.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
(1)reactor protection system B following restoration of normal power supply on July 15, 2024 (2)diesel generator electric lineup following bus transfer per SOP-ELEC-4160V-OPS on September 3, 2024 (3)transverse incore probes including tubing and indexing mechanisms on September 11, 2024
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 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 zone 17 partial area, fire impairment camera for the high radiation area, on July 1, 2024
- (2) RHR-2B pump room, fire area R-4/2, on July 23, 2024 (3)motor control cabinets on reactor building 522 level, fire area R-18, on August 1, 2024 (4)turbine generator building on 441, fire area TG-1 and 2, on August 12, 2024 (5)reactor recirculation pump adjustable speed drive building No. 8, fire area ASD, and transformers on September 10, 2024
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 the down-power evolution in preparation for ASD work on July 17, 2024.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated operators during the licensed operator requalification annual exam (LE000044, revision 1) on September 4, 2024.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (3 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components remain capable of performing their intended function:
(1)review of work practices during reactor protection system B coil replacement on July 2, 2024 (2)review of damper DMA-M-AD-31/1 "A" failure on August 1, 2024 (3)review of Procedure 1.3.64, plant clearance orders for the past year on September 9, 2024
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following structure, system, or component remains capable of performing its intended function:
(1)fill material for buried service water pipe, 18 inch (21)-2 segment 492.7-502.7, on September 30, 2024.
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (5 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)misclassification of an Orange plant risk condition in accordance with 10 CFR 50.65(a)(4), associated with a high-pressure core spray planned outage and unexpected loss of service air compressor on July 22, 2024 (2)risk informed completion times (RICT) for the service water A outage due to RHR-MOV-68A stem issue on August 7, 2024 (3)observed risk mitigation actions for planned diesel generator 2 outage window on August 19, 2024
- (4) Yellow risk window for low-pressure core spray short maintenance window on September 3, 2024
- (5) RICT, Yellow risk condition for the service water B and diesel generator 2 outage on September 16, 2024
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (10 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)operability assessment following mitigating actions of securing zone 17 fire detection on July 1, 2024 (2)past operability assessment following RPS-EPA-3B failure on July 15, 2024 (3)operability assessment following isolating and flushing FDR-FT-38 on July 15, 2024
- (4) DMA-AD-12/2 temperature controller for diesel generator 1 room recirculation damper on July 18, 2024 (5)high-pressure core spray (HPCS) restoration after maintenance outage on July 24, 2024 (6)operability assessment following the replacement of CRD-SPV-9 on August 6, 2024 (7)operability assessment following bypass IRM-H from CR 456582 on August 15, 2024 (8)past operability assessment of RHR-P-2A on September 17, 2024 (9)diesel generator 2 engine room temperature heat up calculation and cooling coil failure on September 30, 2024
- (10) PP-8AE sola transformer capacitor on September 30, 2024
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (3 Samples)
The inspectors evaluated the following temporary or permanent modifications:
(1)permanent modification - battery switch in control room with a commercial dedication on September 30, 2024 (2)permanent modification - CMS 20, division 1 containment radiation monitor modification on September 30, 2024 (3)temporary modification - MS-TCV-115B temporary modification on September 30, 2024
71111.24 - Testing and Maintenance of Equipment Important to Risk
The inspectors evaluated the following testing and maintenance activities to verify system operability and/or functionality:
Post-Maintenance Testing (PMT) (IP Section 03.01) (10 Samples)
(1)post-maintenance testing following the replacement of electric panel breaker in the reactor protection system bus B system on July 2, 2024 (2)post-maintenance testing following LPCS-P-2 replacement using Work Order 2222781 on July 22, 2024 (3)post-maintenance testing following ISP-HPCS-S902 on July 24, 2024
- (4) OSP-CRD/IST-Q701 following replacement of CRD-SPV-9 on August 6, 2024 (5)post-maintenance testing following replacement of transverse incore probe V-10 squib charge on September 10, 2024 (6)transverse incore probe explosive squib test for TIP-V-9, 10, 11 (WO 2205644) on September 12, 2024 (7)repair/tighten glycol leak on ASD channel 1B1 (GY-P-10B1) on September 21, 2024 (8)reactor protection system motor generator (RPS-MG) set 1 voltage regulator failure to replace (WO 02216680-11) on September 30, 2024 (9)diesel generator 3 maintenance window (WO 02212341-01) on September 30, 2024 (10)fuel pool cooling (FPC) valve (FPC-AO-1) air operator diaphragm replacement (WO 02209378-01 and 08) on September 30, 2024
Surveillance Testing (IP Section 03.01) (6 Samples)
- (1) ISP-RHR-S906, RHR B and C discharge pressure ADS SYS B permissive on August 19, 2024
- (2) OSP-ELEC-S702 the DG-2 semi-annual operability test on August 21, 2024
- (3) ISP-OPRM-B608, oscillation power range monitor (OPRM) response time testing on B trip system on August 22, 2024
- (4) ISP-MS-Q919 residual heat removal B and C actuation and reactor core isolation cooling isolation functional test on August 22, 2024
- (5) ISP-MS-S902, ECCS-LPCI B/C valve permissive on low reactor pressure, channels B and C on August 26, 2024
- (6) OSP-ELEC-M701 diesel generator number 1 on September 4, 2024
Inservice Testing (IST) (IP Section 03.01) (1 Sample)
- (1) SR-OSP-CVB/IST-M701 vacuum breaker operability on September 9, 2024
71114.06 - Drill Evaluation
Required Emergency Preparedness Drill (1 Sample)
- (1) Emergency Response Organization drill that showed the stations response to escalation of plant failure that ultimately results in a release of radioactivity from the plant. The station showed how they can determine emergency action level requirements and escalation criteria, and how to communicate to the many local, State, and Federal agencies on August 13,
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) (3 Samples)
The inspectors observed/evaluated the following licensee processes for monitoring and controlling contamination and radioactive material:
(1)licensee surveys of potentially contaminated material leaving the radiologically controlled area (RCA)
(2)workers exiting the RCA at the Unit 1 access point (3)workers deconning a contaminated condensate resin pump in the decon shop on the 467-foot elevation of the radwaste building
Radiological Hazards Control and Work Coverage (IP Section 03.04) (5 Samples)
The inspectors evaluated the licensee's control of radiological hazards for the following radiological work:
- (1) RWP 30005241, 2024 Radwaste 467 Operate Decon Facility, deconning and repairing a condensate pump that leaked resin, July 30, 2024
- (2) RWP 30005245, 2024 Radwaste 437 Behind Shield Wall - locked high radiation area (LHRA), conducting a calibration of area radiation monitor (ARM-RIS-29) within a locked high radiation area and a high contamination area, July 31, 2024
- (3) RWP 30005268, 2024 Valve/Pump/Sump Work in High Radiation Area, working on a fuel pool cooling valve (FPC-V-108) within a high radiation area and a high contamination area, July 31, 2024 (4)workers inside of a contamination area to install new switches in the black boxes of the spent fuel pool area, on the 606-foot elevation of the reactor building, August 1, 2024 (5)storage of radioactive materials inside of the radwaste building High Radiation Area and Very High Radiation Area Controls (IP Section 03.05) (5 Samples)
The inspectors evaluated licensee controls of the following high radiation areas (HRAs) and very high radiation areas (VHRAs):
(1)reactor water clean-up (RWCU) heat exchanger room on the 548-foot elevation of the reactor building (locked high radiation area (LHRA))
(2)resin liner cage on the 437-foot elevation of the radwaste building (LHRA)
(3)south pipe space ladder lock area on the 548-foot elevation of the reactor building (LHRA)
(4)calibration source storage area on the 487-foot elevation of the radwaste building (LHRA)
(5)personnel hatch and equipment hatch on the 501-foot elevation of the reactor building (VHRAs)
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) (1 Sample)
The inspectors evaluated the following internal dose assessments:
- (1) personnel exposure investigation #2422
Special Dosimetric Situations (IP Section 03.04) (2 Samples)
The inspectors evaluated the following special dosimetric situations:
(1)two declared pregnant worker packages (2)nine external multibadge dose tracking and dose assignments associated with RWP 30004941 wetwell diving and RWP 30004968 drywell and steam tunnel maintenance activities
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) July 1, 2023, through June 30, 2024
MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)
- (1) July 1, 2023, through June 30, 2024
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) July 1, 2023, through June 30, 2024
OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)
- (1) April 1, 2023, through June 30, 2024 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, 2023, through June 30, 2024
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees corrective action program to identify potential trends in housekeeping and cleanliness of plant to support emergent work to minimize entry of foreign material that might be indicative of a more significant safety issue. The review identified a potential adverse trend in this area, which was shared with the licensee for action.
INSPECTION RESULTS
Failure to Recognize Entry into an Orange 10 CFR 50.65(a)(4) Risk Window Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2024003-01 Open/Closed
[H.8] -
Procedure Adherence 71111.13 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of 10 CFR 50.65(a)(4) when Energy Northwest failed to identify an Orange risk window that occurred during a planned Yellow risk window, and a planned high-pressure core spray (HPCS) maintenance window outage, due to a failure of the service air dryer.
Description:
On Monday July 22, 2024, Columbia Generating Station was operating in a planned PARAGON Yellow condition for the HPCS maintenance window, where PARAGON was the licensees risk management tool. At 2:00 a.m. HPCS system one (HPCS-SYS-1),diesel generator system C (DG-SYS-C), and standby water system C (SW-SYS-C) were declared inoperable and unavailable. At 5:48 a.m. the main control room received a "Standby Compressor Start Alarm." Control air system compressor 1A (CAS-C-1A), had auto-started on low CAS header pressure, and an equipment operator was sent to investigate. Upon investigation of CASC-1A, the equipment operator discovered a small puddle forming beneath service air compressor 1 (SA-C-1) and reported it looked "blocked" or "frozen." The control room requested that the Fix It Now (FIN) work group investigate. A condition report (CR) and work request (WR) were initiated (00460350/29177838).
During the daily production meeting at 6:15 a.m. the shift manager (SM) reported the CAS alarm and the condition of service air and advised FIN was requested to investigate.
Throughout the day, instrument and control (l&C) technicians and mechanics investigated the service air system. It was determined that a significant condensate buildup on the service air dryer one (SA-DY-1) internals caused a trip, and it would need to be taken out of service. At this time, at approximately 1:00 p.m., a request was made to have a protection scheme generated and hung, and SA-C-1 was secured.
At 1:37 p.m., the SM obtained a copy of Procedure PPM 1.5.14, "Risk Assessment and Management for Maintenance/Surveillance Activities," and used it to enter SA-C-1 into PARAGON and calculated plant risk for existing conditions. He stated that his first attempt resulted in his computer freezing and aborting the calculation, so he attempted the calculations again. He believed the calculation was complete, verified the activity code and advised he had left the duration open-ended.
The SM stated that at that time everything "looked correct, and the color remained Yellow."
The SM then asked the shift technical advisor (STA) to perform a peer check and update the plant status page. He completed the plant status page update once the protection scheme was hung at approximately 2:34 p.m.
The SM notified the work week manager of the current plant status and PARAGON update during the 2:30 p.m. work management accountability meeting. The SM advised that PARAGON remained Yellow and that "[he] didn't see any upcoming CAS work that week that would conflict with the protection scheme." Operations dayshift personnel completed turnover with the oncoming nightshift. Their logs indicated that SA-DY-1 had malfunctioned and was entered into PARAGON. PARAGON was not verified by the nightshift, or the following dayshift; this is only done when new changes are made during their shift.
On Tuesday, July 23, 2024, 8:01 a.m. CR 460396 was created to document the "As found condition of SA-DY-1 investigation." The CR stated that, during the SA-DY-1 investigation, the hot gas bypass valve line was found to have a hole in it. It was rubbing/vibrating against the de-superheating expansion valve line. The CR is to document issues identified during the investigation and will be repaired under WR 29177849." At approximately 10:48 a.m.
clearance order D-SA-DY-1-003 was hung in the field by FIN.
On Wednesday July 24, 2024, at 7:49 a.m., the FIN senior reactor operator (SRO) requested that the work week manager (WWM) add reactor building exhaust air fan 1A (ROA-FN-1A)into PARAGON to allow for tag out for belt adjustment. Due to technical issues with the PARAGON program installation, the WWM could not add the new variable and asked a second WWM for help.
At approximately 8:24 a.m., the second WWM completed the plant risk calculation and noticed that the SA-DY-1 variable appeared to be pink, and PARAGON was now ORANGE.
This change was unexpected, so both WWMs requested a peer check from the probabilistic risk analyst (PRA) engineer. (The PARAGON program takes approximately 30 minutes to complete the calculations).
At approximately 8:30 a.m., the first WWM contacted FIN and advised them to stop work on ROA-FN-1A based on the PARAGON change to ORANGE. The WWM informed two SMs of the PARAGON change and requested verification/peer check. The planning, scheduling and outage manager was also notified. At 8:55 a.m. the SMs reported they had validated the station had entered PARAGON ORANGE risk. The PRA engineer also confirmed PARAGON ORANGE and informed the WWM that the change occurred with the loss of service air during the HPCS window on July 22, 2024.
At 2:18 p.m., HPCS was declared available, and Columbia exited PARAGON ORANGE.
Following the new PARAGON run, PARAGON risk was Green. The inspectors concluded the licensee did not follow Procedure PPM 1.5.14 for having designated personnel perform the assessment of plant risk, and personnel did not know how to properly work through unexpected problems during use of the PARAGON software when pop ups occur in the program.
Corrective Actions: On Wednesday July 24, 2024, at 2:18 p.m., Energy Northwest (ENW)restored HPCS and it was declared available, and Columbia exited PARAGON ORANGE plant risk. A PARAGON risk run was performed and indicated Green for plant risk. ENW updated the PARAGON program to prevent the allowance of skipping calculations.
Corrective Action References: CR 00460431 was written and documented the direct cause and contributing factors.
Performance Assessment:
Performance Deficiency: The licensees failure to assess and manage risk associated with the failure of the service air dryer in the instrument air system in accordance with 10 CFR 50.65(a)(4) was a performance deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Human 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, the human error resulted in the licensee not being aware of the Orange condition and not taking required risk mitigating actions to assure availability of redundant equipment.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management SDP. Because the performance deficiency was associated with 10 CFR 50.65(a)(4) performance (Flow Chart 1),the incremental core damage probability deficit was <1E-6, and the incremental large early release probability deficit was <1E-7, the finding screened to Green.
Cross-Cutting Aspect: H.8 - Procedure Adherence: Individuals follow processes, procedures, and work instructions. Specifically, the failure of the station personnel to follow the risk assessment/evaluation Procedure PPM 1.5.14, prevented the station from identifying the appropriate plant risk associated with the changing plant conditions.
Enforcement:
Violation: Title 10 CFR 50.65(a)(4) requires that Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety. Contrary to the above, on July 22, 2024, after failure of the service air system dryer, the licensee failed to assess and manage the increase in risk that resulted from the failure of the service air system dryer.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Failure of the Diesel Generator Cooling Coil due to Inadequate Maintenance Instruction and Post-Maintenance Testing Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2024003-02 Open/Closed
[H.5] - Work Management 71111.15 The inspectors reviewed a self-revealed Green finding and associated non-cited violation of Technical Specification 5.4.1.a, Procedures, for the licensees failure to establish and perform maintenance procedures appropriate to the circumstances. Specifically, the licensees Work Order 02144751 did not establish sufficient detail for the installation or post-maintenance testing of diesel generator room air handling unit damper motors. As a result, damper motor switches were set incorrectly and an air handling unit cooling coil failed during cold weather resulting in an inoperable condition for diesel generator 2 and service water train B, with diesel generator 2 being inoperable for greater than the technical specification allowed outage time.
Description:
On the night of January 17-18, 2024, the licensee performed a monthly surveillance test of diesel generator (DG) 2. When DG 2 was shut down at the end of the surveillance test, the licensee discovered a large service water (SW) leak coming from cooling coil DMA-CC-21, located inside DG air handling unit DMA-AH-21. The licensee attempted to isolate the SW leak by closing the SW isolation valves to the cooling coil; however, the valves leaked by and did not isolate the cooling coil leak. The licensee then secured SW pump 1B, which stopped SW flow to all train B components and the leak stopped. The licensee declared DG2 and SW pump 1B inoperable at 1:35 a.m. on January 18, 2024. Upon further discussion with engineering, the licensee concluded the amount of SW leakage with SW pump 1B in operation could exceed the leakage limits for ultimate heat sink (UHS) operability. Therefore, the licensee declared the UHS inoperable and entered Technical Specification (TS) 3.7.1, condition D, at 12:04 p.m. The licensee then removed the control power fuses for SW pump 1B so that it would not be capable of auto-starting. Then, the licensee exited TS 3.7.1 at 12:38 p.m. for the inoperable UHS. The licensee completed surveillance testing of DG 1 and DG 3 on January 19, 2024, to check for common cause failure. These tests were completed satisfactorily.
Cooling coil DMA-CC-21 consists of two sets of cooling coils, a lower and an upper coil located inside air handling unit DMA-AH-21, in parallel operation for SW flow. The lower coil was found to have 19 tube elbows that had split, apparently caused by freezing SW inside the tubing. (The low temperature recorded at the Pasco Tri-Cities Airport weather station on the night of January 17-18, 2024, was 8°F). A winter weather system had entered the region 6 days prior to the service water pipe failure in which outside air temperature was nearly always below 20°F and less than 10°F at night.
According to the UFSAR (section 9.4.7.2), the HVAC system for the DG 2 room is serviced by two air handling units. The smaller unit, DMA-AH-22 is normally operating continuously to maintain proper temperatures in the DG room both with heating and cooling capability.
Ambient temperature control is provided by temperature regulated proportional dampers on the air handling unit intake which mix outside air and recirculated room air. Temperature sensors are in the exhaust ducts and DG rooms and will alarm in the event of abnormally high or low temperatures.
For DG surveillance testing, the service water system is started about an hour before the DG is started. The SW system flow is through the DG cooling water heat exchanger, the cooling coils for both air handling units (DMA-CC-21 and DMA-CC-22), all in parallel operation. When a DG is started, the larger air handling unit, DMA-AH-21, and the main exhaust fan, DEA-FN-21, automatically start and SW is supplied to the cooling coil units on both air handling units.
Like the small air handling unit, the large air handling unit has dampers on the air handling unit intake which mix outside air and recirculated room air. Both air handling units also have a motor-operated face and bypass (also known as mixed air) damper on the air handling unit cooling coil which is controlled by a temperature switch located in the fresh air intake. The larger unit only has cooling capability. This temperature switch causes the outside air/recirc dampers to align in the recirc damper open and outside damper closed configuration at a temperature range of 70°F to 100°F of room temperature.
During the investigation of the cause of the SW leak, the licensee determined the motor modules for DMA-AD-21/2, the outside air/recirculation dampers for the large air handling unit DMA-AH-21, were configured incorrectly. The as-found configuration caused the air dampers to operate in the reverse direction. This caused the outside air damper component of DMA-AD-21/2 to be open when it should have been closed and the recirculation air damper component of DMA-AD-21/2 to be closed when it should have been open.
For the normal HVAC lineup with the DG in standby mode, the Face/Bypass dampers (DMA-AD-21/1) are face open and bypass closed and the outside air/recirc dampers are outside air closed and recirc open. For the outside air/recirc dampers this is accomplished by springs in the damper motors. When the DG starts, the HVAC fan starts and allows the temperature elements (TE) to modulate the dampers. The face/bypass dampers are controlled by the TE that monitors outside air temperature in the intake and the outside/recirc dampers are controlled by the TE monitoring the large air handling unit DMA-AH-21 outlet temperature.
This allows the face damper to close and the bypass damper to open at outside air temperatures below 40°F. The outside air/recirc dampers can modulate between 70-100°F of DMA-AH-21 outlet temperature. The springs in the motors for the dampers ensure that when the DG is in the standby mode the dampers are aligned appropriately, despite the module switch being aligned incorrectly.
As part of the planned monthly operability run, the SW B pump was started and run for about an hour before the DG was started and HVAC realignment occurred. The DG ran for over 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> (time to 100 percent loading and general procedure control) and then was secured.
The HVAC fans ran for an additional 30 minutes, then shut down, at which point the HVAC system realigned to the standby deenergized positions. A SW low flow to the DMA-AH-21 cooling coils alarm (105 gpm) was received 15 minutes after the fan secured (normal flow is 110-120 gpm). Since the HVAC was aligned such that cold outside air was allowed to be in contact with the cooling coils, the inspectors assessed that the cooling coils final freezing occurred during the time the HVAC system was running on the DG start. The mechanism of the thawing by the flowing service water most likely occurred during the time the system had realigned to standby alignment after the DG shutdown and the cooling fan stopped. This is when the broken sections of the cooling coils were exposed to the service water flow.
Additionally, during the time that the dampers were improperly configured and did not meet the UFSAR requirements, the ENW site experienced a period of high outside air temperatures, such that the air handling unit would not have been able to maintain the DG room temperature below 130°F, the maximum temperature allowed for operability of the DG.
The inspectors reviewed the cause of the equipment issue. The licensee had installed the motor and interface modules for the DMA-AD-21/2 outside air/recirculation dampers in accordance with WO 02144751 on March 23, 2022. Step 4.29 stated, in part, perform modulating motor - damper setup per PPM 10.23.7 and reference the owners manual as needed. The relevant work instructions PPM 10.23.5 (PMT) and 10.23.7 (DMA damper linkage setup) did not contain any steps to adjust the motor interface module.
The inspectors concluded that the incorrect damper motor interface module switch configuration was the result of an inadequate engineering change, which translated to an inadequate maintenance instruction and post-maintenance test for replacement of the DMA-AD-21/2 damper motors on March 23, 2022. The motor interface module switches were set incorrectly, and the condition was not identified during post-maintenance testing. The condition resulted in the DG 2 HVAC system to be in an improper configuration adversely affecting equipment performance for 1 year and 10 months and was finally corrected on January 24, 2024, after the failed cooling coil was replaced and the damper motor interface module switches were properly configured.
Corrective Actions: The licensee replaced the damaged lower cooling coil in the HVAC unit and replaced the lower cooling coil and properly configured the damper motor interface module switches. The licensee completed repairs, performed post-maintenance testing, and returned SW train B and DG 2 to operable status on January 24, 2024. A root cause evaluation was performed to determine the root cause, direct cause, and causal factors that lead to the failure.
Corrective Action References: CR 00454585, WO 022173353
Performance Assessment:
Performance Deficiency: The failure to establish and perform procedures, appropriate to the circumstances, for maintenance that could affect the performance of safety-related equipment is a performance deficiency. Specifically, Work Order 02144751, which was used for replacement of the motors and interface modules for DG 2 HVAC dampers DMA-AD-21/2, did not establish sufficient detail to set the interface module switches correctly and did not include adequate post-maintenance testing, which resulted in DG 2 air handling unit cooling coil DMA-CC-21 failure during cold weather.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality 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, the performance deficiency resulted in the DG 2 HVAC system cooling coils freezing and rupturing, which led to DG 2 being inoperable and unavailable.
Significance: The inspectors assessed the significance of the finding using IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined that this finding required a detailed risk evaluation because the degraded condition resulted in the loss of PRA function of one train of a multiple train TS system for greater than the TS allowed outage time. A regional senior reactor analyst performed the detailed risk evaluation which characterized the issue as having very low safety significance (Green). For this evaluation, the analyst assumed a total exposure time of 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />, comprised of a conservatively estimated 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of unavailability time when the coils were not known to be frozen and breached, a 9-hour time period from when the service water leak revealed the failed condition and when no risk management actions were in place, a 14-hour time period where risk management actions had been taken to protect redundant train equipment, and a 91-hour time period when the additional fire protection risk management actions had been taken when train B of the service water system and diesel generator B were in maintenance. Crediting of the risk management actions involved removing cutsets which included test and maintenance basic events for protected equipment and lowering the probability of transient fires. Using the Columbia SPAR model, version 8.82, run on SAPHIRE, version 8.2.11, the analyst set basic event SSW-MDP-FR-1B, Standby Service Water Pump 1B Fails to Run, as a surrogate event for the first 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> of the exposure time and basic event SSW-MDP-TM-1B, SSW MDP 1B Unavailable Due to Test and Maintenance, for the last 105 hours0.00122 days <br />0.0292 hours <br />1.736111e-4 weeks <br />3.99525e-5 months <br /> of the exposure time to model the unavailability. In applying these time assumptions, the analyst used the Columbia SPAR model to estimate the increase in core damage frequency (CDF) from internal events to be 4.59E-8/year, used more accurate seismic hazard and component fragilities incorporated into the Columbia SPAR model by Idaho National Laboratory to estimate the increase in CDF from seismic events to be 1.15E-7/year, and used the Columbia plant fire model (which was constructed using standard NRC-approved methodologies) to estimate the increase in CDF from fire events to be 6.29E-7/year. Other external hazards were assumed to not be risk significant.
Combining these inputs yielded an estimate of the total increase in CDF from the performance deficiency to be 7.9E-7/year. Dominant core damage sequences were fire events in the main control room which would have been mitigated by the redundant train of service water. The analyst used Appendix H, Containment Integrity Significance Determination Process, to estimate the increase in large early release frequency (LERF) the analyst classified the finding to be a Type A finding since it affected CDF and LERF. The analyst applied the factors in Table 6.2, Phase 2 Assessment Factors - Type A Findings At Power, to the applicable sequences to estimate the increase in LERF to be 3.8E-8/year. The analyst used these estimates of the increase in CDF and LERF to characterize the finding as having very low safety significance.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the work package and post-maintenance testing for the installation of the damper motor module switch was inadequate to allow for the maintenance personnel to install the switch correctly and the post-maintenance testing was not adequate to identify that the damper motor module switches had incorrect settings and would not operate correctly when required.
Enforcement:
Violation: Technical Specification (TS) 5.4.1.a, requires, in part, written procedures shall be established, implemented, and maintained in accordance with Appendix A of Regulatory Guide 1.33, revision 2. Appendix A, section 9, Procedures for Performing Maintenance, states in part, maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate for the circumstances.
Technical Specification 3.8.1, Electrical Power Systems AC Sources-Operating requires, in part, two qualified circuits from off-site power to onsite class 1E electrical power distribution system; and three DGs shall be operable in modes 1, 2, and 3. TS 3.8.1 action statement B requires, in part, with one required DG inoperable, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> restore the DG to operable status, or apply risk informed completion times (RICT), or be in mode 3 in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Contrary to the above, from March 23, 2022, to January 24, 2024, Columbia Generating Station (CGS) failed to properly pre-plan and perform maintenance activities that could affect the performance of safety-related equipment in accordance with documented instructions appropriate to the circumstances. Specifically, ENW failed to provide adequate work instructions to install and test the DG 2 DMA-HA-21 air handling unit damper motor module switches, resulting in the dampers working backwards. As a result, the DG 2 was inoperable for greater than the TS allowed outage time permitted by TS 3.8.1, action B, for one DG inoperable, and the unit was not placed in mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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 71111.15 This Severity Level IV violation 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: Energy Northwest failed to meet the requirements of 10 CFR 50.72(b)(3)(xiii)8-hour reporting requirements, in part, for any event that results in a major loss of emergency assessment capability. Specifically, on June 4, 2024, ENW lost the B reactor protection system (RPS) motor generator (MG) which caused a containment isolation of the equipment and floor drains radioactive which prevented the ability to determine reactor coolant system (RCS) leak rates which is considered a major loss of emergency assessment capability.
Significance/Severity: Severity Level IV. The inspectors determined that traditional enforcement applies because the failure to make a timely 8-hour report in accordance with 10 CFR 50.72(b)(3)(xiii) impedes the regulatory process. The inspectors determined this violation was associated with a minor performance deficiency under the reactor oversight process (ROP) because there was no underlying technical issue that impacted the ROP cornerstones. Using the NRC Enforcement Policy, dated August 23, 2024, the violation was determined to be a Severity Level IV violation in accordance with NRC Enforcement Policy example 6.1.d.2, because immediate NRC follow-up action was not required.
Corrective Action References: ENW restored the power to B RPS via alternate power and then unisolated and restored the containment equipment and floor drains to service, which then restored the emergency assessment capability for determining the RCS leak rate.
CR 00458969 Failure to Follow ALARA Planning Procedures Resulting in Unplanned Dose for a Work Activity Cornerstone Significance Cross-Cutting Aspect Report Section Occupational Radiation Safety Green NCV 05000397/2024003-03 Open/Closed
[H.5] - Work Management 71124.01 The inspectors reviewed a self-revealed, Green finding and associated non-cited violation of Technical Specification 5.4.1 because the licensee failed to follow their as low as reasonably achievable planning procedure resulting in unplanned dose while performing work associated with Radiation Work Permit (RWP) 30004994, Refueling Outage 26 (R26) Steam Tunnel RFW-V-65 A & B - High Risk, as related to RFW-V-65A valve work. Specifically, the procedure instructed the licensee to estimate the effective dose rate related to the current work area conditions, body position, and deviations from historical data and assumptions.
The licensee initially planned the RFW-V-65A valve work for approximately 3.604 person-Rem, whereas the actual dose accrued to complete the work activity was 27.233 person-Rem.
Description:
During R26, May to June 2023, numerous jobs led the licensee to exceeding their overall dose estimate of 168.681 person-Rem and goal of 87.138 person-Rem. The dose accrued was 226.252 person-Rem. One primary work activity that led to this dose exceedance was performed under RWP 30004994, R26 Steam Tunnel RFW-V-65 A & B - High Risk, revision 0. This RWP involved the repair of RFW-V-65A and preventive maintenance involving RFW-MO-65B. This job commenced on May 11, 2023. The licensee identified they were having issues maintaining doses ALARA and in alignment with their planned dose estimate. In action request (AR) 00449319, the licensee investigated the dose overrun for the RWP. Further, in ARs 00445461, 00445492, 00445546, 00445555, 00445556, 00445643, 00445701, 00445752, and 00445926, the licensee documented emergent issues resulting in additional unplanned dose which consisted of foreign material found internal to the valve, degraded internal components, and issues with the valve itself.
Procedure PPM 11.2.2.14, Radiological Planning and Reviews, revision 12, section 4.1.11 stated, in part:
- Based on the following, determine and enter an effective dose rate for each craft on the H213 Panel (of the Passport Computer Program), after considering the following:
o current and historical radiological conditions in the work area o
estimated locations and body positions of the workers during the task o
review of historical dose information corrected for current scope and conditions o
information obtained in step 4.1.10 (obtain data on the actual or anticipated radiological conditions in the work area)
Procedure PPM 11.2.2.14, section 6.1, defined Effective Dose Rate as, An estimated dose rate based on the actual work area dose rates, worker position, worker movement within the work area, and planned dose reduction measures.
The inspectors determined that the licensee failed to implement the steps in section 4.1.11 during their planning and implementation process for RWP 30004994. Specifically, while the licensee determined that the current radiological conditions were higher than the historical radiological data and adjusted the effective dose rates and dose estimates for the current, higher radiological conditions, the licensee did not assess the work area challenges to properly determine an effective dose rate from such impacts as work area interferences (location and body position) and inefficiencies of a new valve crew prior to commencement of the work activities (difference from historical conditions - an experienced work crew versus an inexperienced work crew). The licensee adjusted the effective dose rates and dose estimate for any remaining and emergent work, after the current work scope and efficiency challenges were identified and addressed.
The licensee acknowledged that the last completed work on valve RFW-V-65A was 30 years prior and constituted a gap in current maintenance knowledge. In R26 RFW-V-65A ALARA Post-Job Review, dated September 19, 2023, the Health Physics planner acknowledged that having the valve team present during ALARA planning process would have led to better and more accurate dose assessment and less effective dose rate and estimated dose revisions.
The deficiencies noted in the work planning process ultimately resulted in unplanned dose to the workers for the work.
For work under RWP 30004994, valve RFW-V-65A, the inspectors reviewed the dose estimates of 3.604 person-Rem for the job, as commenced, and credited an additional 9.202 person-Rem for credible elevated dose rates and emergent work, resulting in an NRC revised dose estimate of 12.806 person-Rem. The inspectors could not credit additional dose due to additional work spent addressing interferences in and around the RFW-V-65A valve area that could have been foreseen while planning. The NRC revised dose estimate aligned the licensees approved revised dose estimate, via their in-progress review dated May 19, 2023, of 12.806 person-Rem for the valve work. Thus, the actual dose accrued of 27.233 person-Rem exceeded the NRC revised dose estimate by 112.7 percent (112.7%).
Corrective Actions: The licensee documented issues associated with the RFW-V-65A job in their corrective action program in the following ARs: 00445461, 00445492, 00445546, 00445555, 00445556, 00445643, 00445701, 00445752, and 00445926. The licensee also evaluated the performance of this job in their R26 post-job review package and initiated AR 00449319 to investigate the dose overrun.
Corrective Action References: ARs 00445461, 00445492, 00445546, 00445555, 00445556, 00445643, 00445701, 00445752, 00445926, and 00449319
Performance Assessment:
Performance Deficiency: The licensees failure to follow their ALARA planning procedures and properly determine the effective dose rate prior to commencement of the RFW-V-65A valve job was 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. Additionally, the finding was similar to example 6(i) in Inspection Manual Chapter 0612, Appendix E, Power Reactor Inspection Reports - Examples of Minor Issues.
Significance: The inspectors assessed the significance of the finding using IMC 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 3-year rolling average collective dose was less than 240 person-Rem (i.e., 188.376 person-Rem).
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the licensee failed to execute the work with the appropriate ALARA planning and work crew communication commensurate with the radiological risk identified, while coordinating and managing all relative RFW-V-65A valve work activities.
Enforcement:
Violation: Technical Specification 5.4.1, Procedures, states, in part, 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.
Procedure PPM 11.2.2.14, revision 12, section 4.1.11, states, in part, the licensee is to determine and enter an effective dose rate for each craft on the H213 Panel (of the Passport Computer Program), based on the following:
- current and historical radiological conditions in the work area
- estimated locations and body positions of the workers during the task
- review of historical dose information corrected for current scope and conditions
- information obtained in step 4.1.10 (obtain data on the actual or anticipated radiological conditions in the work area)
Contrary to the above, from May to June 2023 during Refueling Outage 26, the licensee failed to determine an effective dose rate for each craft based on information obtained in procedure PPM 11.2.2.14, section 4.1.11, as related to estimated locations, body positions, and the historical data corrected for current scope and conditions. Specifically, the licensee did not adequately estimate the effective dose rate related to the current work area conditions, body position, and deviations from historical data and assumptions.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with section 2.3.2 of the Enforcement Policy.
Observation: Potential Adverse Trend for Housekeeping issues 71152S During walkdowns, the inspectors identified that housekeeping has not been maintained in accordance with station procedures in all areas. Specifically, high radiation and locked high radiation areas have shown repeated housekeeping issues. This leads to the potential for issues during emergent work that could lead to potential entry of foreign material into the systems. The station entered this issue into their corrective action program under CR
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On September 19, 2024, the inspectors presented the radiation safety inspection results to Reginald Wainwright, Plant General Manager, and other members of the licensee staff.
- On October 28, 2024, the inspectors presented the integrated inspection results to Dave Brown, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Corrective Action
Documents
Action Request
(AR)
458194
SOP-
HOTWEATHER-
Hot Weather Operations
Procedures
SOP-
WARMWEATHER-
Warm Weather Operations
ABN-RPS
Loss of RPS
ISP-TIP/IST-B102
Procedures
SOP-RWCU-LU
Reactor Water Cleanup System Valve and Breaker Lineup
205644
TIP-V-10 Replace Squib Charge Per ISP-TIP/IST-B102
Work Orders
Corrective Action
Documents
Action Request
(AR)
459787, 460382
Reactor 422
Fire Plans
Reactor 522
DIC 1725
Fire Tour Logs
07/01/2024
Miscellaneous
L19-FP-Zone-17-
001
LCS Tracking Sheet
FPF 3.16-1
Fire Protection Compensatory Measures
Fire Tour Implementation
Procedures
PPM 1.3.10B
Active Fire System Operability and Impairment Control
Work Orders
WO 2126631, 02126632
1.3.1
Operating Policies, Programs, and Practices
141
Procedures
OI-9
Operations Standards and Expectation
Corrective Action
Documents
Action Request
(AR)
454897, 455600, 458251, 458412
AS 455600-20
Common Cause Analysis
06/10/2024
System Vulnerability Evaluation Report
Miscellaneous
Email: Teaching
and Learning for
Clearance Order and Tagging Training Topics and Tools
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
1.3.76
Integrated Risk Management.
WCI-1
Unit Coordinator BPA Duties
Procedures
WCI-10
Safety System Outage Windows
Work Orders
WO 217407, 2217564, 2222285
Calculations
NAS-2308-01
Columbia Generating Station DG-2 Room Damper Past
Operability Evaluation
06/25/2024
Action Request
(AR)
450596, 454585, 458912, 459787, 459803, 459854, 459897,
460558, 460624, 460752
Corrective Action
Documents
Engineering
Evaluations
EC 9777 DES-2-
EC 9777 for DG 2 Heat Load with Outside Air Damper Shut
CVI Manual
number 67-00, 75
Vendor Technical Manual for the Damper Motors and the
Cooling Coils for DG's
ENE-43847
Constellation Power Labs Failure Analysis of Circuit Breaker
Miscellaneous
Schulz 900 HP
Motor Oil Levels
and Fluctuations //
E-NW/Columbia -
N-7368 - RHR
Email Chain Between Energy Northwest and Schulz.
08/30/2024
FPF 3.16-1
Fire Protection Compensatory Measures
Fire Tour Implementation
PPM 1.3.10B
Active Fire System Operability and Impairment Control
Procedures
SOP-FDR-OPS
Floor Drain System Operation
Work Orders
WO 2196448, 2217828-10, 29177566, 29177609
Procedures
ISP-TIP/IST-B102
Work Orders
WO 2147456, 2176427, 2197876, 2206346, 2222285, 221719901
Corrective Action
Documents
Action Request
(AR)
445265, 445268, 445381, 453886, 445480, 445744, 445938,
446155, 446166, 446311, 446788, 447186, 448883, 449319,
450442, 450443, 451534, 451640, 452015, 452163, 452413,
2547, 452689, 452737, 453576, 453598, 455603, 455746,
456280, 459226, 460739
Corrective Action
Documents
Resulting from
Action Request
(AR)
460750, 461770
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Inspection
23 CGS Refueling Outage CRE Report
2/11/2023
Columbia Generating Station (CGS) CRE/Source Term
Reduction - 5 Year Plan 2024
07/02/2024
Miscellaneous
DIC 1541.12
Energy Northwest Weekly LHRA and VHRA Door Checks
07/30/2024
1.11.15
Control of Radioactive Material
11.2.13.1
Radiation and Contamination Surveys
11.2.13.11
Characterization of Alpha Radioactivity
11.2.13.8
Airborne Radioactivity Surveys
11.2.2.14
Radiological Planning and Reviews
11.2.7.1
Area Posting
11.2.7.3
High Radiation Area, Locked High Radiation Area, and Very
High Radiation Area Controls
11.2.8.2
Radiation Work Permit Preparation and Use
GEN-RPP-01
ALARA Program Description
GEN-RPP-02
Radiological Planning and Control Process
GEN-RPP-04
Entry into, Conduct In, and Exit from Radiologically Controlled
Areas
HPI-0.19
Radiation Protection Standards and Expectations
Procedures
SWP-RPP-01
Radiation Protection Program
Air Sample
25146
Sandblasting (East Side)
05/18/2023
Air Sample
25504
Sandblasting inside tent (East Side)
05/21/2023
Air Sample
25575
Sandblasting inside tent (East Side)
05/22/2023
M-20230519-29
R26 ST 501 RFW-V-65A Breach
05/19/2023
M-20230618-3
R26 Drywell 1000# Leak Inspection Walkdown
06/18/2023
M-20240704-2
Reactor Building 548' Monthly Survey
07/04/2024
M-20240706-3
Radwaste 467' All Areas
07/06/2024
M-20240711-10
Reactor Building 606' Monthly Survey
07/11/2024
M-20240718-4
Radwaste 437' NUPAC Update
07/18/2024
Radiation Surveys
M-20240719-2
Radwaste 437' Behind Shield Wall with EDR FDR Pumps
07/19/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
M-20240731-6
Turbine Building 441' RFW-P-1A HRA Verification
07/31/2024
30004973
R26 Refueling Floor *HRA* Wet Work
30004978
R26 Drywell *LHRA* MSIV-V-22B/C Maintenance and Refurb
Tasks
30004994
R26 RFW-V-65 A & B **HR,HCA,ARA**
30005097
R26 Reactor Building 548 B RHR HX RM Maintenance Tasks
- LHRA**
30005105
High Pressure Turbine *HRA*
30005241
Decon on Condensate Resin Pump 467' Radwaste
07/30/2024
30005245
Calibration of ARM-RIS-29 LHRA/HCA
07/31/2024
Radiation Work
Permits (RWPs)
30005268
Work on FPC-V-108
07/31/2024
Self-Assessments
AR-SA 453112
Evaluate CGS Radiological Protection Program Against the
Inspection Criteria of NRC Inspection Procedure 71124,
01, "Radiological Hazard Assessment and
Exposure Controls"
04/30/2024
Corrective Action
Documents
Action Request
(AR)
433249, 433337, 436033, 437969, 440624, 445114, 445305,
445375, 445545, 446162, 446594, 447181, 447213, 447950,
448499, 451681, 451809, 453173, 454942, 456186, 456699,
457449, 457902, 458499, 458566, 459292
22 Part 61 Waste Stream Data
09/07/2023
Airborne Radioactivity Areas and Associated RWP Summary
06/05/2024
Miscellaneous
Log of Positive Whole Body Counts for 2023
2/14/2024
GEN-RPP-06
Dosimetry Program Description
HPI-2.2
Skin Dose Evaluation
HPI-4.30
Processing, Evaluation, and Reporting of DLR Exposure Data
PPM 11.2.15.13
Control of Personnel Skin and Clothing Contamination
PPM 11.2.4.5
Whole Body Counter and checks
PPM 11.2.6.1
Issuance and Retrieval of Personnel Dosimetry
PPM 11.2.6.4
Damaged, Lost, or Off-Scale Dosimetry Devices
Procedures
PPM 11.2.6.7
Special Dosimetry
Self-Assessments
AR-SA 453104
Columbia Generating Station (CGS) Internal and External
Dosimetry Program
04/02/2024
71151
Corrective Action
Action Request
440629, 443967, 444543, 444647, 444941, 444998, 445424,
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
(AR)
446585, 446841
AR-SA 453111
71151-OR01 PI Verification: Occupational Exposure
04/09/2024
Self-Assessments
AR-SA 453143
Performance Indicator (PI) Verification PR-01: Radiological
Effluent Technical Specifications/Offsite Dose Calculation
Manual Radiological Effluent Occurrences
01/30/2024
Corrective Action
Documents
Condition Report
459608