ML040300619

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IR 05000397-03-007, on 10/05/03 Through 12/31/03, Columbia Generating Station
ML040300619
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 01/30/2004
From: William Jones
NRC/RGN-IV/DRP
To: Parrish J
Energy Northwest
References
IR-03-007
Download: ML040300619 (30)
v • d • e


See also: IR 05000397/2003007

Text

January 30, 2004

Mr. J. V. Parrish

Chief Executive Officer

Energy Northwest

P.O. Box 968; MD 1023

Richland, Washington 99352-0968

SUBJECT: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT 05000397/2003007

Dear Mr. Parrish:

On December 31, 2003, the NRC completed an inspection at your Columbia Generating

Station. The enclosed integrated inspection report documents the inspection findings, which

were discussed on December 22, 2003, with Mr. Oxenford and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel.

Based on the results of this inspection, the NRC has identified one issue that was evaluated

under the risk significance determination process as having very low safety significance

(Green). This finding was determined to be a violation of NRC requirements, however, because

it was of very low safety significance and because it was entered into your corrective action

program, the NRC is treating the issue as a noncited violation, in accordance with

Section V1.A.1 of the NRCs Enforcement Policy. If you contest this noncited violation, you

should provide a response with the basis for your denial, within 30 days of the date of this

inspection report, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,

Washington DC 20555-0001; with copies to the Regional Administrator, U.S. Nuclear

Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011-

4005; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington,

DC 20555-0001; and the NRC Resident inspector at the Columbia Generating Station.

During this period, the inspectors completed trial Inspection Procedure 71111.HS, Heat Sink

Performance - Pilot, dated May 6, 2003, at your facility. The results for this inspection can be

found in Section 71111.07 of the enclosed report. The trial inspection procedure was

performed to help the NRC assess the general effectiveness of the new procedure.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Energy Northwest -2-

Room or from the Publicly Available Records (PARS) component of NRCs document

system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.gov/reading-rm/ADAMS.html (the Public Electronic Reading Room).

Sincerely,

/RA/

William B. Jones, Chief

Project Branch E

Division of Reactor Projects

Docket: 50-397

License: NPF-21

Enclosure:

NRC Inspection Report 05000397/2003007

cc w/enclosure:

Rodney Webring (Mail Drop PE04)

Vice President, Nuclear Generation

Energy Northwest

P.O. Box 968

Richland, WA 99352-0968

Albert E. Mouncer (Mail Drop PE01)

Vice President, Corporate Services/

General Counsel/CFO

Energy Northwest

P.O. Box 968

Richland, WA 99352-0968

Chairman

Energy Facility Site Evaluation Council

P.O. Box 43172

Olympia, WA 98504-3172

Douglas W. Coleman (Mail Drop PE20)

Manager, Performance Assessment

and Regulatory Programs

Energy Northwest

P.O. Box 968

Richland, WA 99352-0968

Energy Northwest -3-

Christina L. Perino (Mail Drop PE20)

Manager, Licensing

Energy Northwest

P.O. Box 968

Richland, WA 99352-0968

Chairman

Benton County Board of Commissioners

P.O. Box 190

Prosser, WA 99350-0190

Dale K. Atkinson (Mail Drop PE08)

Vice President, Technical Services

Energy Northwest

P.O. Box 968

Richland, WA 99352-0968

Thomas C. Poindexter, Esq.

Winston & Strawn

1400 L Street, N.W.

Washington, DC 20005-3502

Bob Nichols

Executive Policy Division

Office of the Governor

P.O. Box 43113

Olympia, WA 98504-3113

Lynn Albin

Washington State Department of Health

P.O. Box 7827

Olympia, WA 98504-7827

Chief, Technological Hazards Branch

FEMA Region X

Federal Regional Center

130 228th Street, SW

Bothell, WA 98201-9796

Chief, Technical Services Branch

FEMA Region X

Federal Regional Center

130 228th Street, SW

Bothell, WA 98201-9796

Energy Northwest -4-

Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

Senior Resident Inspector (GDR)

Branch Chief, DRP/E (WBJ)

Senior Project Engineer, DRP/E (VGG)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

A. Boland, OEDO RIV Coordinator (ATB)

Columbia Site Secretary (LEF1)

W. A. Maier, RSLO (WAM)

Dale Thatcher (DFT)

ADAMS: Yes * No Initials: __

Publicly Available * Non-Publicly Available * Sensitive Non-Sensitive

R:\_COL\2003\COL2003-07RP-GDR.wpd

RIV:SRI:DRP/E RIV:RI:DRP/E TL:PSB C:DRP/E

GDReplogle for ZKDunham MPShannon WBJones

E to WBJones NA /RA/-E /RA/

1/28/04 1/ /04 1/12/04 1/30/04

OFFICIAL RECORD COPY D=Discussed T=Telephone E=E-mail F=Fax

ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-397

License: NPF-21

Report: 05000397/2003007

Licensee: Energy Northwest

Facility: Columbia Generating Station

Location: Richland, Washington

Dates: October 5 through December 31, 2003

Inspectors: G. D. Replogle, Senior Resident Inspector, Project Branch E, DRP

Z. K. Dunham, Resident Inspector, Project Branch E, DRP

B. W. Tindell, Reactor Inspector, DRS

P. J. Elkmann, Emergency Preparedness Inspector, DRS

Approved By: W. B. Jones, Chief, Project Branch E, Division of Reactor Projects

ATTACHMENT: Supplemental Information

Enclosure

SUMMARY OF FINDINGS

IR05000397/2003-007; 10/5/2003 - 12/31/2003; Columbia Generating Station; Other

The report covered a 3-month period of inspections by resident inspectors and announced

inspections by an emergency preparedness inspector. One Green noncited violation was

identified. The significance of most findings is indicated by their color (Green, White, Yellow, or

Red) using Manual Chapter 0609, "Significance Determination Process. Findings for which the

Significance Determination Process does not apply may be Green or be assigned a severity

level after NRC management review. The NRCs program for overseeing the safe operation of

commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,

Revision 3, dated July 2000.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Barriers

  • Green. The inspectors identified a violation of Technical Specifications

Surveillance Requirement 3.6.1.3.11, in that Energy Northwest had performed

inadequate main steam isolation valve local leak rate testing since initial plant

startup. The testing was inadequate because Energy Northwest utilized

nonsafety related instrument air to help close and seat the valves during testing.

The instrument air system provided substantially more seating pressure than the

safety-related air accumulators.

The issue had more than minor safety significance because it impacted the

barrier cornerstone attribute for containment isolation through verification of

safety system components for containment isolation. The established safety

system component testing did not ensure the operational capability of the main

steam isolation valves to perform their accident mitigating function. The issue

was of very low safety significance because the finding did not represent an

actual open pathway in the physical integrity of the reactor containment

(Section 4OA5).

B. Licensee Identified Violations

Violations of very low safety significance which were identified by Energy Northwest

have been reviewed by the inspectors. Corrective actions taken or planned by Energy

Northwest have been entered into Energy Northwests corrective action program. These

violations and corrective actions are listed in Section 4OA7 of this report.

Enclosure

REPORT DETAILS

Summary of Plant Status

The inspection period began with Columbia Generating Station at 100 percent power.

Operators maintained the plant at essentially 100 percent power for the entire inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

a. Inspection Scope

The inspectors completed two occurrences of adverse weather protection this inspection

period. From November 3 through 13, 2003, the inspectors reviewed Energy

Northwests measures to ensure adequate adverse weather (extreme cold) protection

for two mitigating systems. Specifically, the inspectors reviewed design features

including heat tracing and ventilation heating, equipment, and Energy Northwest

preparations associated with standby service water and emergency diesel generator

heating and ventilation. Additionally, the inspectors reviewed operations cold weather

Procedure PPM 3.1.9, Cold Weather Operations, Revision 5, to ensure that the

referenced equipment had been placed in their respective cold weather alignments.

The following additional documents were reviewed during the inspection:

  • Problem Evaluation Request 2003-1006, SW-V-694B Yoke Bushing Broke and

is Stuck Open, March 27, 2003

  • Problem Evaluation Request 2003-3991, Broken Stem Nut on SW-V-694B

Affects the Ability to Perform SOP-SW-COLD Weather, November 5, 2003

  • Procedure SOP-SW-Cold Weather, Standby Service Water Cold Weather

Operations, Revision 1

  • Procedure PPM 2.10.4, Diesel Generator and Cable Cooling HVAC (heating

ventilation and air conditioning), Revision 23

Enclosure

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b. Findings

No findings of significance were identified.

1R04 Equipment Alignments (71111.04)

a. Inspection Scope

The inspectors performed one partial walkdown of the Division 2 125 VDC safety related

battery and associated DC distribution system on December 16, 2003, while the

Division I 125 VDC battery was inoperable during a battery cell replacement. The

inspectors utilized facility drawings, procedures, and alignment checklists to verify the

correct system alignment. The inspectors then compared the as-found condition of the

system to verify that it could perform its safety function.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

1. Quarterly Walkdowns

a. Inspection Scope

The inspectors performed walkdowns of eight fire protection areas (8 occurrences) to

verify operational status and material condition of fire detection and mitigation systems,

passive fire barriers and fire suppression equipment. The inspectors reviewed Energy

Northwests implementation of controls for combustible materials and ignition sources in

selected fire protection zones. The inspectors compared observed plant conditions

against descriptions and commitments described in the Final Safety Analysis Report,

Section 9.5.1, Fire Protection System, and Appendix F, Fire Protection Evaluation.

The fire areas inspected were:

  • Fire Area RC-11, Division I air conditioning room, October 28
  • Fire Area RC-12, Division II air conditioning room, October 28
  • Fire Area R-1, Control rod drive pump room, November 21
  • Fire Area M-27, Instrument Rack E-IR-H22/P021 room, November 21
  • Fire Area R1, 522 elevation reactor building, November 21
  • Fire Area M-73, Instrument Rack E-IR-73 room, November 21

Enclosure

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November 26

b. Findings

No findings of significance were identified.

2. Annual Drill

a. Inspection Scope

The inspectors observed and evaluated a fire protection drill on August 11, 2003. The

inspectors considered whether the drill scenario properly demonstrated the use of fire

fighting equipment and that the subsequent drill critique was self-critical. The inspectors

had reviewed the fire protection drill as part of the 50-397/0030006 inspection cycle.

The following documents were reviewed as part of this inspection:

  • Drill Scenario
  • Attribute Checklists

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

The inspectors selected one area, external flooding, for this inspection period. Per the

Columbia Generating Station Final Safety Analysis Report Section 2.4.2 and 3.4.1.5.1,

the plant has no external flood threat, either by ground water or from the nearby

Columbia River. The inspectors verified that no other external flood threats exist.

b. Findings

No findings of significance were identified.

1R07 Heat Sink Performance (71111.07A/71111.HS)

a. Inspection Scope

The inspectors reviewed four heat exchanger performance tests for this inspection.

Heat exchangers inspected included the Division I emergency diesel generator cooling

water heat exchangers (2) and the Division I and II standby service water pump house

room coolers (2). Because the procedure was a pilot, the inspectors performed both the

Biennial Testing and Inspection Performance Review, and the Biennial Programmatic

Enclosure

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and Functional Performance Review. The inspectors performed independent

calculations, conducted interviews and reviewed procedures and design documents to

verify the acceptability of test methods/conditions, acceptance criteria, use of instrument

uncertainties, frequency of testing, biofouling controls, compliance with design

parameters, and the extrapolation of test data to design conditions. The inspectors also

reviewed a sample of Energy Northwest identified problems to ensure that appropriate

corrective measures were taken and assessed the overall condition of the ultimate heat

sink (standby service water spray ponds). Documents reviewed and utilized during this

inspection included:

  • Final Safety Analysis Report
  • Technical Specifications
  • Technical Memorandum TM-2111, Thermal Performance Testing of the Air-to-

Water Heat Exchangers in the WNP-2 SW Systems

testing on December 4, 2002

  • Procedure TSP-SW-A101, Service Water Loop A Cooling Coil Heat Load

Capacity Testing, Revision 0, conducted on July 21, 2003

  • Procedure TSP-SW-A102, Service Water Loop B Cooling Coil Heat Load

Capacity Testing, Revision 0, conducted on July 21, 2003

  • Calculation 9.46.04, Peak Room Temperatures, Revision 0

House A, Revision 7

Related Equipment, dated July 18, 1989

  • Problem Evaluation Request 203-3323, Unexpected standby service water flow

changes, dated November 4, 2003

  • Problem Evaluation Request 203-3041, Unplanned equipment inoperability due

to low service water cooling flow to room cooler, dated August 14, 2003

  • Problem Evaluation Request 203-1774, Service water relief Valve SW-RV-001B

failed as found set point test, dated May 19, 2003

b. Findings

No findings of significance were identified.

Enclosure

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1R11 Licensed Operator Requalification (71111.11)

a. Inspection Scope

On November 24, 2003, the inspectors observed one licensed operator requalification

training exam as operators participated in a scenario on the plant simulator. The

inspectors evaluated crew performance in terms of formality of communication,

prioritization of actions, annunciator response and implementation of procedures. The

inspectors also evaluated simulator fidelity by comparing simulator configurations with

the plant control room.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors performed three in-office reviews (3 occurrences) of safety-related

systems to evaluate Energy Northwests assessment of availability and reliability of risk-

significant structures, systems and components.

  • On October 30, 2003, the inspectors selected the automatic depressurization

system for routine review of a safety-related system.

  • On December 9, 2003, the inspectors selected the 125 and 250 VDC safety

related batteries for routine review.

system for routine review of a safety-related system.

The inspectors utilized the following documents for these inspections:

Report, January - June, 2003

  • Columbia Generating Station Maintenance Rule Scoping Matrix,

October 30, 2003

  • NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants, Revision 2

Enclosure

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b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15)

a. Inspection Scope

The inspectors reviewed two operability evaluations (2 occurrences) to assess Energy

Northwests assessment of operability for degraded or non-conforming equipment. The

inspectors reviewed the Final Safety Analysis Report, Technical Specifications, plant

drawings, and associated problem evaluation requests as criteria for this inspection.

  • Problem Evaluation Request 203-3942, Plant entered Technical

Specification 3.0.3 due to both trains of control room emergency filtration

being inoperable, November 1, 2003

  • Problem Evaluation Request 203-3767, Containment atmosphere control system

performance testing showed degraded performance in some instances

b. Findings

No findings of significance were identified.

1R16 Operator Workarounds (71111.16)

a. Inspection Scope

The inspectors completed two occurrences of operator workarounds on November 21

and December 12. The inspectors evaluated the potential affects of the workarounds

on the operator's ability to implement abnormal or emergency operating procedures and

the cumulative effects of workarounds on the reliability and availability of plant systems.

b. Findings

No findings of significance were identified.

1R17 Permanent Plant Modifications (71111.17)

a. Inspection Scope

On November 7, 2003, the inspectors completed one permanent plant modification

inspection related to Instrument Setpoint Change Request 1378. The purpose of this

modification was to change a low flow setpoint associated with the control room

emergency filtration system pre-heaters to ensure system operability during design flow

conditions. The change was necessary because Energy Northwest had identified

inadequate flow settings. The inspectors considered whether the change could

Enclosure

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adversely affect the design and licensing basis of the facility. The inspectors also

verified that the setpoint change was implemented in accordance with Energy

Northwests applicable procedural requirements and that the new setpoints supported

continued system operability.

b. Findings

No findings of significance were identified.

1R19 Postmaintenance Testing (71111.19)

a. Inspection Scope

The inspectors performed an in-office review of six postmaintenance tests. The

inspectors considered whether Energy Northwest properly implemented procedural

controls, as applicable, and that each test adequately demonstrated equipment

operability. The inspectors also considered whether Energy Northwest met Technical

Specification and licensing basis requirements. The inspection sample included:

emergency diesel generator loss of field excitation Relay DG-RLY-40/DG1,

in-office review on November 5, 2003

  • Work Orders 01070029 and 01070028, Testing following replacement of position

indication relays for vacuum Breakers CVB-RLY-V/1ST/R3 and R4, and CVB-

RLY-V/1NP/R1 and R2, in-office review on December 7, 2003

office review on December 17, 2003

generator soakback Pump DLO-P-11B2 replacement, in-office review on

November 18, 2003

Pump HPCS-P-3 bearing replacement, in-office review on December 15, 2003

replacement, in-office review on December 19, 2003

b. Findings

No findings of significance were identified.

Enclosure

-8-

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors evaluated the two surveillance tests listed below. The inspectors

reviewed Technical Specifications, Final Safety Analysis Report, and applicable Energy

Northwest procedures to determine if the surveillance tests demonstrated that the tested

components were capable of performing their intended design functions. Additionally,

the inspectors also evaluated significant test attributes such as potential preconditioning,

clear acceptance criteria, accuracy and range of test equipment, procedure adherence,

and completion and acceptability of test data.

  • Procedure ISP-MS-Q902, RPS and Isolation Reactor Vessel Level Low, Level 3,

RCIC [Reactor Core Isolation Cooling] Isolation, Level 8 - CFT/CC, Revision 4,

performed on November 13, 2003, direct observation

Test", Revision 20, performed on December 10, 2003 - direct observation

b. Findings

No findings of significance were identified.

Cornerstone: Emergency Preparedness

1EP2 Alert Notification System Testing (71114.02)

a. Inspection Scope

The inspector discussed with Energy Northwest staff the status and condition of offsite

siren and tone alert radio systems to determine the adequacy of their methods for

testing the alert and notification system in accordance with 10 CFR Part 50 Appendix E.

Energy Northwests alert and notification system testing program was compared with

criteria in NUREG-0654, Criteria for Preparation and Evaluation of Radiological

Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,

Revision 1, Federal Emergency Management Agency (FEMA) Report REP-10, Guide

for the Evaluation of Alert and Notification Systems for Nuclear Power Plants, and

Energy Northwests current FEMA-approved alert and notification system design report.

The inspector completed the required one sample during this inspection.

b. Findings

No findings of significance were identified.

Enclosure

-9-

1EP3 Emergency Response Organization Augmentation Testing (71114.03)

a. Inspection Scope

The inspector discussed with Energy Northwest staff the status and condition of the

primary and backup systems for staffing emergency response facilities. The inspector

reviewed the results of Energy Northwest verification tests for installation of a new

automated dialing system, and reviewed the results of 4 quarterly response drills

conducted in 2002 and 2003. The inspector reviewed the following documents related

to the emergency response organization augmentation system to determine Energy

Northwests ability to staff emergency response facilities in accordance with the

emergency plan and the requirements of 10 CFR Part 50 Appendix E. The inspector

completed the required one sample during this inspection.

  • EPI-13, Automated Notification System, Revision 3
  • Win2000 Autodialer Test Plan (General)
  • Win2000 Autodialer Test Plan, Scenario Acceptance Tests (17 scenarios)

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level and Emergency Plan Changes (71114.04)

a. Inspection Scope

The inspector performed in-office reviews of:

  • Editorial changes to Revision 31 of Emergency Plan Implementing Procedure

13.1.1, Classifying the Emergency, and Revision 11 of Emergency Plan

Implementing Procedure 13.1.1A, Classifying the Emergency - Technical

Bases. These changes lowered the threshold wind speeds and increased the

associated averaging times for emergency action levels 9.4.U.2 and 9.4.A.2 in

the Hazards/Natural Events emergency action level category.

  • Revisions 35 and 36 to the Emergency Plan. These changes added one position

and removed five positions from the emergency response organization, and

clarified requirements for evacuating personnel from the site during an

emergency.

These revisions were compared to their previous versions, to the criteria of NEI 99-01,

Methodology for Development of Emergency Action Levels, Revision 2, and to the

requirements of 10 CFR Part 50.47(b) and 50.54(q) to determine if they decreased the

effectiveness of the emergency plan. The inspector completed the required three

samples during this inspection.

Enclosure

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The inspector also performed an in-office review of Revision 32 to emergency plan

implementing procedure 13.1.1, Classifying the Emergency, and Revision 12 to

emergency plan implementing procedure 13.1.1A, Classifying the Emergency -

Technical Bases. The inspector performed an on-site review of calculation NE-02-03-6,

Determine EOF and SAG Action Levels..., Revision 0. These revisions changed the

reactor vessel water level threshold in emergency action levels 2.1.S.1, 2.1.G.2,

4.1.G.1, 6.1.G.1, Table 1, TCS Barrier Loss Indications, and Table 6, Fuel Clad

Potential Loss and RCS Loss Criteria, from -192 inches to -183 inches. These

revisions were compared to their previous revisions, to the criteria of NEI 99-01,

Methodology for Development of Emergency Action Levels, Revision 2, and to the

requirements of 10 CFR Part 50.47(b) and 50.54(q), to determine if the revisions

decreased the effectiveness of the emergency plan. The inspector completed 2

samples during this inspection.

b. Findings

No findings of significance were identified.

1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies (71114.05)

a. Inspection Scope

The inspector reviewed the following documents related to Energy Northwests

corrective action program to determine Energy Northwests ability to identify and correct

problems in accordance with 10 CFR Part 50.47(b)(14) and 10 CFR Part 50 Appendix E.

The inspector completed the required one sample during this inspection.

  • SWP-CAP-01, Problem Evaluation Requests, Revision 7
  • SWP-CAP-07, Department Trend Review Program, Revision 0
  • Integrated Performance Assessment Report, July through December 2002
  • Integrated Performance Assessment Report, January through June 2003
  • Team D Drill Report for January 14, 2003
  • Team B Drill Report for May 6, 2003
  • Team C Drill Report for October 28, 2003

Enclosure

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  • Team A Drill Report for November 4, 2003
  • Summaries of approximately 250 corrective actions assigned to the emergency

preparedness department during calendar years 2002 and 2003

  • Details of 26 selected corrective actions

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation (71114.06)

a. Inspection Scope

The inspectors inspected two drills this period. First, on November 24, 2003, the

inspectors observed a simulator drill in which the control room staff was required to

make and report emergency classifications in response to a simulated accident.

Second, the inspectors reviewed logs, after action reports and observed the

management drill critique for a site emergency preparedness drill that was conducted on

November 4, 2003. The inspectors reviewed the facility emergency plan implementing

procedures and the Emergency Plan to establish the criteria for the drills. Additionally,

the inspectors reviewed the completed emergency action level declaration and

notification forms to verify proper emergency action level declarations and protective

action recommendations. Lastly, the inspectors reviewed Energy Northwests evaluation

of the drills to ensure that any performance deficiency associated with classification,

notification, and protective action recommendation development was accurately

characterized.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator Verification (71151)

.1 Mitigating Systems Cornerstone

a. Inspection Scope

The inspectors assessed the accuracy of the following performance indicator. The

inspectors compared the data with operator logs, equipment out of service logs, and

corrective action documents for the last four quarters. The inspectors verified that

Energy Northwest calculated performance indicators in accordance with NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Revision 2.

  • Safety System Unavailability - BWR Heat Removal System (Reactor Core

Isolation System)

Enclosure

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b. Findings

No findings of significance were identified.

.2 Emergency Preparedness Cornerstone

a. Inspection Scope

The inspector sampled Energy Northwest submittals for the performance indicators

listed below for the period July 2002 through September 2003:

  • Drill and Exercise Performance
  • Emergency Response Organization Participation
  • Alert and Notification System Reliability

The definitions and guidance of NEI 99-02, Regulatory Assessment Indicator Guideline,

Revision 2, were used to verify Energy Northwests basis for reporting each data element

to ensure the accuracy of performance indicator data reported during the assessment

period. Energy Northwest performance indicator data was also reviewed against the

requirements of Procedure 1.10.10, Regulatory Assessment Performance Indicator

Reporting, Revision 3, and Emergency Planning Instruction EPI-18, Emergency

Preparedness NRC Performance Indicators, Revision 6. Drill and exercise performance

was compared to the requirements of EPIP 13.1.1, Classifying the Emergency,

Revision 32, EPIP 13.4.1, Emergency Notifications, Revision 28, and EPIP 13.8.1,

Emergency Dose Projection System Operations, Revision 23.

The inspector reviewed a 100 percent sample of drill and exercise scenarios and

licensed operator simulator training sessions, notification forms, and attendance and

critique records associated with training sessions, drills, and exercises conducted during

the verification period. The inspector reviewed selected emergency responder

qualification, training, and drill participation records. The inspector reviewed alert and

notification system testing procedures, maintenance records, and a 100 percent sample

of siren test records. The inspector also interviewed Energy Northwest personnel

responsible for collecting and evaluating performance indicator data. The inspector

completed the required three samples during this inspection.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

.1 Annual Sample Review

Enclosure

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a. Inspection Scope

The inspectors reviewed one plant issue to verify that equipment, human performance,

and programmatic issues were being identified by Energy Northwest at an appropriate

threshold and were being entered in the corrective action program. The following issue

was evaluated during this inspection period:

  • Nine occurrences of Division 1 and Division 2 125 and 250 VDC battery cells not

meeting Technical Specification category A and B limits since September 2002. Two

of the occurrences were associated with battery cell inoperability.

The following performance attributes were evaluated:

  • Complete and accurate identification of the problem
  • Evaluation of operability
  • Consideration of extent of condition and common cause
  • Classification and prioritization of the resolution
  • Identification and completion of corrective actions

b. Findings

No findings of significance were identified.

.2 Review of Emergency Preparedness Related Problem Evaluation Requests

a. Inspection Scope

The inspector selected 26 Problem Evaluation Requests for detailed review, based on

their impact on the risk significant planning standards, emergency worker protection, and

the ability to staff and maintain emergency response facilities. The requests were

reviewed to ensure that the full extent of the issues were identified, an appropriate

evaluation was performed, appropriate corrective actions were identified and prioritized,

and effective corrective actions were completed. The inspector evaluated the Problem

Evaluation Requests against the requirements of SWP-CAP-01, Problem Evaluation

Requests, Revision 7.

b. Findings and Observations

No findings of significance were identified.

.3 Cross-References to PI&R Findings Documented Elsewhere

The inspectors documented an issue related to problem resolution, associated with

inadequate main steam isolation valve (MSIV) local leak rate testing (LLRT). While

Energy Northwest had originally questioned using the instrument air system to close the

main steam isolation valves, they inappropriately concluded that it was acceptable.

(Section 4OA5 ).

Enclosure

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4OA5 Other

(Closed) URI 50-397/2003005-04: Use of nonsafety related instrument air during MSIV

LLRT. Energy Northwest had initially questioned the use of instrument air to help close

and seat MSIVs during LLRT but determined that the practice was acceptable. This

unresolved item was opened to allow more time to evaluate Energy Northwests position.

Introduction:

The inspectors identified a violation of Technical Specification Surveillance

Requirement (TSSR) 3.6.1.3.11, to verify leakage rate through each MSIV is

  1. 11.5 standard cubic feet per hour (SCFH) when tested at $ 25.0 psig., in that Energy

Northwest had performed inadequate MSIV LLRT since initial plant startup. The testing

was inadequate because Energy Northwest utilized nonsafety related instrument air to

assist in closing and seating the valves during testing. The instrument air system

provides substantially more seating pressure than the safety-related air accumulators.

Since Energy Northwest had initially questioned the issue but came to an unacceptable

conclusion, this issue is also related to the cross-cutting area of problem identification

and resolution. The failure to properly evaluate a condition adverse to quality is a

performance deficiency.

Description.

The inspectors determined that Energy Northwests MSIV LLRT testing was inadequate,

in that the use of instrument air during the tests provided additional valve seating forces

that enhanced valve performance such that there was no longer a reasonable assurance

that postaccident valve leakage would be less than that specified in the Columbia

Generating Station Technical Specifications.

Columbia Generating Station is a 10 CFR Part 50, Appendix J, Option B plant and

Energy Northwest, in part, follows the guidance in NEI 94-01, Industry Guideline for

Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, Revision 0.

NEI 94-01 references industry Standard ANSI/ANS-56.8-1994, Containment System

Leakage Testing Requirements, Section 3.3.3 Containment Isolation Valve Closure

which states, Closure of primary containment isolation valves for Type C testing [the

applicable testing in this case] shall by accomplished by normal or equivalent means and

without adjustment (e.g., no hand tightening of remotely operated valves after closure).

Exercising valves for the purpose of improving leakage performance shall not be

permitted.

The inspectors determined that Energy Northwests testing of the MSIVs was not

consistent with 10 CFR Part 50, Appendix J, and that the testing as performed was

inconsistent with 10 CFR Part 50.36 (for TSSRs) and their submittal to the NRC

requesting approval of TSSR 3.6.1.3.11.

Enclosure

-15-

The inspectors considered the following points regarding design requirements,

regulations, the licensees amendment request for TSSR 3.6.1.3.11 and operating

experience:

  • Energy Northwest derived MSIV performance requirements from Calculation 5.45.07,

Post-LOCA MSIV Leakage Calculation, Revision 1. This calculation determined the

permissible postaccident MSIV leakage in order to demonstrate compliance with

10 CFR Part 50, Part 100 requirements during a design basis accident. The

calculation identified the leakage limit as #11.5 SCFH per valve. The design basis

accident assumed a loss of instrument air. The leakage limit identified in the

calculation was the foundation for the #11.5 SCFH limit, per valve, specified in TSSR 3.6.1.3.11.

to assure that (a) leakage through the primary reactor containment and systems and

components penetrating primary containment shall not exceed allowable leakage rate

values as specified in the technical specifications...

  • Energy Northwests submittal, dated December 8, 1995, included TS Bases Section 3.6.1.3.11, which states:, The analysis in Reference 1 [FSAR, Chapter 6.2] are

based on leakage that is less than the specified leakage rate [11.5 scfh]. Leakage

through each MSIV must be # 11.5 scfh when tested at Pt ($ 25 psig). This ensures

that MSIV leakage is properly accounted for in determining the overall primary

containment leakage rate... Energy Northwests testing with instrument air would not

ensure that MSIV leakage is properly accounted for in determining the overall primary

containment leakage rate.

the necessary quality of systems and components is maintained,... and that the

limiting conditions for operation will be met. The Limiting conditions for operation

are: the lowest functional capability or performance levels of equipment required for

safe operation of the facility. Energy Northwests testing methods are inconsistent

with the above because they would not ensure that the MSIVs are capable of their

lowest functional capability required for safe operation of the facility (# 11.5 scfh

under accident conditions).

Inadequate Inservice Testing of MSIVs. The information notice states, in part, the

practice of performing inservice testing of components, which are relied on to mitigate

the consequences of accidents, with sources of power not considered in the safety

analysis, is not in keeping with the objective of periodic testing. This objective is to

test equipment to verify operational readiness under conditions that reasonably

duplicate the design basis." In this case, Energy Northwest had utilized a nonsafety

related power source (instrument air) during the LLRT (a type of inservice testing).

The nonsafety related power source significantly impacted the test results such that

the testing did not reasonably duplicate the design basis conditions.

Enclosure

-16-

The inspectors determined the issue was not an immediate or existing safety concern.

Energy Northwest performed an assessment to verify that the MSIVs maintained

adequate performance margin so that, if the testing had been performed under

appropriate conditions, the valves would have passed.

Assessment:

The issue had more than minor safety significance because it impacted the barrier

cornerstone attribute for containment isolation through verification of safety system

components for containment isolation. The established safety system component testing

did not ensure the operational capability of the main steam isolation valves to perform

their accident mitigating function. The inspectors utilized the Significance Determination

Process, as described in NRC Manual Chapter 0609, to assess the safety significance of

the issue. Per the Phase 1 screening criteria, Attachment A, Containment Barriers

Section, Item 3, the inspectors determined that the issue was of very low safety

significance because the finding did not represent an actual open pathway in the physical

integrity of the reactor containment.

Enforcement:

The inspectors identified a violation of TSSR 3.6.1.3.11, to verify leakage rate through

each MSIV is # 11.5 scfh when tested at $ 25.0 psig. The leakage rate testing as

performed was inadequate because Energy Northwest utilized nonsafety related

instrument air to assist in closing and seating the valves during testing and therefore did

not verify the lowest functional capability or performance levels of equipment (MSIVs)

required for safe operation of the facility. Energy Northwest entered the issue into their

corrective action program as Problem Evaluation Request 203-2382. Because the

finding was of very low safety significance, and was entered into Energy Northwests

corrective action program, this issue is being treated as a noncited violation, consistent

with Section VI.A.1 of the NRC Enforcement Policy (NCV 50-397/03-07-01, Inadequate

Local Leak Rate Testing Due to Use of Nonsafety Related Instrument Air).

4OA6 Management Meetings

Meetings, Including Exit

Regional and resident inspectors conducted exit meetings with members of Energy

Northwests management during the inspection period. The meetings included:

of the inspection results to Mr. C. Moore, Supervisor, Emergency Planning, and other

members of the staff.

remaining emergency preparedness inspection results to Mr. V. Parrish and other

members of his staff.

Enclosure

-17-

  • On December 22, 2003, the Senior Resident Inspector provided the remaining

inspection results to Mr. S. Oxenford, Plant Manager and other members of Energy

Northwests staff.

Energy Northwest acknowledged the inspection results during each meeting. Following

the meetings, the inspectors asked Energy Northwest whether any materials examined

during the inspection should be considered proprietary. No proprietary information was

identified.

4OA7 Licensee-Identified Violations

The following violations of very low safety significance (Green) were identified by Energy

Northwest and are violations of NRC requirements which meet the criteria of Section VI

of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as NCVs.

  • Energy Northwest identified a violation of TS 5.4.1.a for an inadequate control room

emergency filtration testing procedure. TS 5.4.1.a requires that written procedures

be established for the applicable procedures recommended in Regulatory

Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33,

Appendix A, requires in part that instructions for changing the modes of operation

should be prepared for the Control Room Heating and Ventilation Systems. On

October 31, 2003, Energy Northwest was performing Procedure PPM 8.3.417,

Control Room Envelope for Unfiltered In-Leakage Tracer Gas Test, Revision 1,

which prescribed placing the control room emergency filtration system in different

operating configurations for testing of the control room envelope in-leakage. The

procedure was inadequate because it directed that both remote air intakes and the

normal air intake for the control room emergency filtration system be closed.

Consequently, the system was rendered inoperable for approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This

procedural step was contrary to Final Safety Analysis Report, Section 9.4, which

stated that both remote intakes are not isolated at the same time to ensure the

control room is pressurized. Energy Northwest documented the issue in their

corrective action program as Problem Evaluation Request 203-3975. This finding

affected the barrier integrity cornerstone but was of very low safety significance

because it only represented a degradation of the radiological barrier function for the

control room.

report of each change made to the emergency plan without prior NRC approval within

30 days after the change is made. Contrary to this, Emergency Plan Revision 33 was

submitted to the NRC 43 days after changes were made. This was identified in

Energy Northwests corrective action program as Problem Evaluation Request 2003-

0545. This finding is Severity Level IV because the failure was administrative in

nature, and the failure to submit required information to the NRC in a timely manner

affects the regulatory process.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Parrish, Chief Executive Officer

D. Atkinson, Vice President, Technical Services

P. Ankrum, Licensing Engineer

I. Boreland, Manager, Radiation Services

D. Coleman, Manager, Performance Assessment and Regulatory Programs

D. Feldman, Operations Manager

C. King, Manager, Chemistry

C. Moore, Supervisor, Emergency Planning

W. Oxenford, Plant General Manager

J. Parrish, Chief Executive Officer

C. Perino, Manager, Licensing

S. Scammon, Manager, Resource Protection

R. Webring, Vice President, Nuclear Generation

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Opened and Closed

05000397/200307-01 NCV Inadequate Local Leak Rate Testing

Due to Use of Nonsafety Related

Instrument Air (Section 4OA5)

Closed

05000397/200305-04 URI Technical Specification Surveillance

Requirement 3.6.1.3.11 Local Leak

Rate Test Implementation (Section

4OA5)

Discussed

None

A-1 Attachment

LIST OF DOCUMENTS REVIEWED

Problem Evaluation Requests

203-4001 203-1006 203-3991 203-0298 203-3942

203-3996 203-4256 203-4230 203-4173 203-3111

202-2761 203-0146 202-3234 202-2542 202-2428

203-3084 203-4333

Procedures

SOP-SW-Cold Weather, Standby Service Water Cold Weather Operations, Revision 1

PPM 3.1.9, Cold Weather Operations, Revision 5

PPM 10.25.35, Testing and Setting GE CEH Relays, Revision 10

OSP-CVB/IST-M701, Suppression Chamber-Drywell Vacuum Breaker Operability, Revision 2

ESP-B11-A101, 12 Month Battery Inspection of 125 VDC E-B1-1, Revision 3

ESP-B11-Q101, Quarterly Battery Testing 125 VDC E-B1-1, Revision 6

ISP-MS-Q902, RPS and Isolation Reactor Vessel Level Low, Level 3, RCIC Isolation, Level 8 -

CFT/CC, Revision 4

Procedure 2.7.8B, 125 VDC Division 2 Distribution System, Revision 8

Drawings

M548-1, Flow Diagram HVAC for Control and Switchgear Rooms Radwaste Building,

Revision 90

Other

CVI 02-216-13, Brasch Manufacturing Co. Instruction Manual for Electric Duct Heaters

GEK-27887G, GE Instructions Loss of Excitation Relay Type CEH51A

CVI 02-51A-00, Exide Instruction Manual for Stationary Batteries & Chargers

IEEE Std 450-1975, IEEE Recommended Practice for Maintenance, Testing, and Replacement

of Large Lead Storage Batteries for Generating Stations and Substations

A-2 Attachment

1EP2

TSI 6.2.3.2, Biweekly Emergency Response River Siren Polling Test, Revision 7

EBS Radio Acceptance Tests for Model 5220-FM-EAR

WNP2 Site Specific Offsite Radiological Emergency Preparedness Alert and Notification

System Quality Assurance Verification, Federal Emergency Management Agency, Region X,

May 1994.

Section 1EP4

Emergency Plan, Columbia Generating Station, Revision 36

Emergency Plan, Columbia Generating Station, Revision 37

1EP5

Problem Evaluation Requests:

  • 202-2567, On-Shift ERO Personnel changed without Notification to EP
  • 202-2639, Methodology used for Dose Projection Calculations during the Evaluated

Exercise was not in accordance with Procedure Guidance

  • 202-2698, HP Technician assigned ERO Duties prior to Receiving SCBA Training
  • 202-2749, Project HP Technicians assigned to Shift Work did not have all Requirements

of Qual Group EPAI Completed

  • 202-2832, Error concerning the Classification Notification Forms have been Ineffectively

Resolved

  • 202-2918, Potential Inadequacy exists in Requirements for Establishing TSC

Radiological Access Control during Emergency Response

  • 202-3049, EP Drill Critique Process Less than Adequate
  • 202-3110, TSC Manager had no Obvious Backup to Demonstrate 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Coverage of

the TSC

  • 202-3120, Emergency Response Field Team Vehicles are in Poor Condition with

Extremely High Milage (also 203-0103, 203-0135, 203-0155, 203-0576, and 203-0690)

  • 202-3204, Collateral Duties of On-Shift Support Personnel may affect Required ERO

Staffing Responsibilities

  • 202-3348, Discrepancy Identified in the Emergency Action Level Thresholds for the

WEA Radiation Monitors

A-3 Attachment

  • 203-0034, OER OE15218 - Lack of Adequate Backup Power Supply for Public Address

System

  • 203-0545, Emergency Plan Revision was not Submitted to the NRC within 30 days as

Required

  • 203-0850, The Remote Shutdown Room lacks Documentation which would be needed if

the Control Room must be Abandoned

  • 203-0889, Evaluate if enough Phones to Function Effectively are available in the Control

Room if TSC Staff are Evacuated to the Control Room

  • 203-0973, Adverse Trend - Continued Problems with ERDS
  • 203-1175, TSC Ability to maintain Habitability may be Compromised by As-Built

Configuration of the TSC Access

  • 203-1255, Since December 2000, 17 OSC Personnel have not been Provided with

Documented Formal Emergency Preparedness Overview Training

  • 203-1531, Errors and Inconsistencies were Identified in the Emergency Plan Evacuation

Time Estimate Study

  • 203-2456, POC Identified Shot on Goal EPlan issue during Review of EPlan Submittal
  • 203-2499, OSC Walkdown identifies less than Adequate Conditions and needed

Improvements

A-4 Attachment

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