ML110390591
| ML110390591 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/08/2011 |
| From: | Webb Patricia Walker NRC/RGN-IV/DRP/RPB-A |
| To: | Reddemann M Energy Northwest |
| References | |
| IR-10-005 | |
| Download: ML110390591 (35) | |
See also: IR 05000397/2010005
Text
February 8, 2011
Mr. M.E. Reddemann
Chief Executive Officer
Energy Northwest
P.O. Box 968, Mail Drop 1023
Richland, WA 99352-0968
Subject: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT
Dear Mr. Reddemann:
On December 31, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Columbia Generating Station. The enclosed integrated inspection report
documents the inspection findings, which were discussed on January 6, 2011, with you 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, four NRC identified findings were evaluated under the
risk significance determination process as having very low safety significance (Green). The
NRC has determined that violations are associated with these issues. However, because of the
very low safety significance and because they were entered into your corrective action program,
the NRC is treating these findings as noncited violations, consistent with Section 2.3.2.a of the
If you contest the violations or the significance of the noncited violations, 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, D.C.
20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission,
Region IV, 612 E. Lamar Blvd, Suite 400, Arlington, Texas, 76011-4125; the Director, Office of
Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the
NRC Resident Inspector at the facility. In addition, if you disagree with the cross-cutting aspect
assigned to any finding 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 Regional Administrator,
Region IV, and the NRC Resident Inspector at the facility.
UNITED STATES
NUCLEAR REGULATORY COMMISSION
R E GI ON I V
612 EAST LAMAR BLVD, SUITE 400
ARLINGTON, TEXAS 76011-4125
Energy Northwest
- 2 -
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response, if you choose to provide one for cases where a response is not
required, will be made available electronically for public inspection in the NRC Public Document
Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not
include any personal, privacy, or proprietary information so that it can be made available to the
public without redaction.
Sincerely,
/RA/
Wayne Walker, Chief
Project Branch A
Division of Reactor Projects
Docket: 50-397
License: NPF-21
Enclosure:
NRC Inspection Report 05000397/2010005
w/ Attachment: Supplemental Information
cc w/Enclosure:
Chairman
Energy Facility Site Evaluation Council
P.O. Box 43172
Olympia, WA 98504-3172
Don Gregoire
Acting Manager, Regulatory Programs
Energy Northwest
P.O. Box 968, Mail Drop PE20
Richland, WA 99352-0968
Chairman
Benton County Board of Commissioners
P.O. Box 190
Prosser, WA 99350-0190
Energy Northwest
- 3 -
Richard Cowley
Washington State Department of Health
111 Israel Road, SE
Tumwater, WA 98504-7827
William A. Horin, Esq
Winston and Strawn
1700 K Street, NW
Washington, DC 20006-3817
Lynn Albin
Washington State Department of Health
P.O. Box 7827
Olympia, WA 98504-7827
Ken Niles
Assistant Director
Nuclear Safety and Energy Siting Division
Oregon Department of Energy
625 Marion Street NE
Salem, OR 97301-3737
Special Hazards Program Manager
Washington Emergency Management Division
127 W. Clark Street
Pasco, WA 99301
Chief, Technological Hazards Branch
FEMA Region X
Federal Regional Center
130 228th Street, SW
Bothell, WA 98021-9796
Energy Northwest
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Electronic distribution by RIV:
Regional Administrator (Elmo.Collins@nrc.gov)
Deputy Regional Administrator (Art.Howell@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
DRP Deputy Director (Troy.Pruett@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Vacant)
Senior Resident Inspector (Ronald.Cohen@nrc.gov)
Resident Inspector (Mahdi.Hayes@nrc.gov)
Branch Chief, DRP/A (Wayne.Walker@nrc.gov)
Senior Project Engineer, DRP/A (David.Proulx@nrc.gov)
Project Engineer, DRP/A (Laura.Micewski@nrc.gov)
Administrative Assistant (Crystal.Myers@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Balwant.Singal@nrc.gov)
Branch Chief, DRS/TSB (Michael.Hay@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
OEMail Resource
ROPreports
OEDO RIV Coordinator (John.Trapp@nrc.gov)
DRS/TSB STA (Dale.Powers@nrc.gov)
File located: R:\\_REACTORS/COL/CGS IR2010005 RP-RBC.docx
SUNSI Rev Compl.
- Yes No
- Yes No
Reviewer Initials
WW
Publicly Avail
- Yes No
Sensitive
Yes : No
RI:DRP/A
SRI:DRP/A
SPE:DRP/A
C:DRS/EB1
C:DRS/EB2
MOHayes
RBCohen
DProulx
TRFarnholtz
NFOKeefe
/RA/E-WWalker
/RA/E-WWalker
/RA/
/RA/
/RA/
2/8/11
2/8/11
2/7/11
1/31/11
1/31/11
C:DRS/OB
C:DRS/PSB1
C:DRS/PSB2
C:DRS/TSB
C:DRP/A
MSHaire
MPShannon
GEWerner
MCHay
WCWalker
/RA/
/RA/
/RA/
/RA/
/RA/
1/28/11
2/7/11
1/18/11
2/7/11
2/8/11
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
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Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
05000397
License:
Report:
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
Richland, WA
Dates:
September 26, 2010 through December 31, 2010
Inspectors:
R. Cohen, Senior Resident Inspector
M. Hayes, Resident Inspector
Approved By:
W. Walker, Chief, Project Branch A
Division of Reactor Projects
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Enclosure
SUMMARY OF FINDINGS
IR 05000397/2010005; 09/26/2010 - 12/31/2010; Columbia Generating Station, Integrated
Resident and Regional Report; Maintenance Risk Assessment and Emergent Work Control,
Postmaintenance Testing, Identification and Resolution of Problems.
The report covered a 3-month period of inspection by resident inspectors. Four Green noncited
violations of significance were identified. The significance of most findings is indicated by their
color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, Significance
Determination Process. The cross-cutting aspect is determined using Inspection Manual
Chapter 0310, Components within the Cross-Cutting Areas. Findings for which the
significance determination process does not apply may be Green or be assigned a severity level
after NRC management review. The NRC's program for overseeing the safe operation of
commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
A.
NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Initiating Events
Green. The inspectors identified a noncited violation of 10 CFR 50.65(a)(4) for
the licensees failure to perform a risk assessment during lifting activities in the
circulating water pump house. Specifically, licensee personnel failed to assess
the increase in risk during movement of a circulating water pump motor over
operating equipment. Licensee personnel performed a risk assessment and
determined the correct risk profile for the movement of the circulating water pump
motor. This issue was placed in the licensees corrective action program as
Action Request/Condition Report 228710.
The performance deficiency was more than minor because it involved a failure to
assess risk during a maintenance activity. The performance deficiency affected
the equipment performance attribute of the Initiating Events Cornerstone
objective to limit the likelihood of events that upset plant stability. The inspectors
evaluated the performance deficiency using Inspection Manual Chapter 0609,
Appendix K, Maintenance Risk Assessment and Risk Management Significance
Determination Process, and determined the performance deficiency to be of
very low safety significance because the risk deficit during the time the motor
was being moved was less than 1.0E-6. The inspectors determined the violation
had a cross-cutting aspect in the area of human performance, resources
component, for the failure to provide up to date procedures in the work order
planning process that would incorporate risk insights during lifting operations
around operating plant equipment H.2.c] (Section 1R13).
Cornerstone: Mitigating Systems
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure
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Enclosure
to follow Procedure PPM 10.2.53, "Seismic Requirements for Scaffolding,
Ladders, Man-Lifts, Tool Gang Boxes, Hoists, Metal Storage Cabinets, and
Temporary Shielding Racks," Revision 26. Specifically, the position of equipment
was required to meet specific criteria to prevent damage to safety-related
equipment during a seismic event. Contrary to this procedure, the inspectors
identified that equipment was positioned adjacent to safety-related equipment
without a supporting engineering evaluation. The inspectors notified the main
control room personnel, who directed an equipment operator to immediately
position the 55 gallon drum away from the standby liquid control system. This
issue has been placed in the licensees corrective action program as Action
Request/Condition Report 230872.
This finding was more than minor because it was a human performance error
which affected the Mitigating Systems Cornerstone objective to ensure the
availability and reliability of systems that respond to initiating events to prevent
undesirable consequences. The finding was determined to be of very low safety
significance because it was not a design or qualification deficiency; it did not
result in the loss of a system safety function; it did not represent the loss of a
single train for greater than technical specification allowed outage time; it did not
represent a loss of one or more non-technical specification risk-significant
equipment for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and it did not screen as potentially risk
significant due to seismic, flooding, or severe weather. A cross-cutting aspect in
the human performance area with a work control component was identified in
that Energy Northwest failed to appropriately plan work, resulting in job site
conditions which may have impacted plant components H.3.a] (Section 4OA2).
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the
licensees failure to include acceptance criteria appropriate to the circumstance in
surveillance testing procedures for the 125Vdc battery system. Specifically,
licensee personnel listed a non-conservative inter-tier resistance value as
acceptance criteria which led to a degraded condition being unanalyzed for 3
years. The licensee has revised the procedure to include the appropriate
acceptance criteria for the 125Vdc battery system. This issue has been placed in
the licensees corrective action program as Action Request/Condition Report
231971.
The performance deficiency is more than minor because it affects the equipment
performance attribute of the mitigating systems cornerstone for ensuring the
reliability of systems that respond to initiating events. Using Inspection Manual
Chapter 0609.04, Phase 1 - Initial Screening and Characterization of Findings,
the inspectors determined that this performance deficiency was of very low safety
significance because the finding was confirmed to not result in a loss of
operability for the 125Vdc batteries. The inspectors determined a cross cutting
aspect was not applicable to the finding due to the procedure change which
implemented the new acceptance criteria occurring in 2007, and determined this
not to be representative of current licensee performance (Section 1R19).
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Enclosure
Green. The inspectors identified a noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, "Corrective Action," for the failure to promptly identify
and correct a condition adverse to quality involving both trains of control room
emergency chillers. The hot gas bypass valves for each train of chillers were
installed incorrectly. The inspectors identified that actions to correct the deficient
condition were not timely. Procedure SWP-MAI-01, "Work Maintenance Process
Overview," Revision 20, Paragraph 8.0 stated in part that tests are conducted to
verify that maintenance is effective and is correctly implemented, the equipment
will function as required and desired improvements were achieved. Contrary to
this, the inspectors identified that post maintenance testing conducted on the
chiller was not adequate in that adjustments were allowed to be made by
procedure throughout the post maintenance testing process which could have
masked problems with the chillers, specifically, that the hot gas bypass valves
were installed incorrectly. The hot gas bypass valves were installed correctly in
both A and B trains of the control room emergency chiller systems and a
satisfactory operability test was performed on chiller CCH-CR-1A on October 13,
2010.
The finding was greater than minor because it was associated with the
configuration control attribute of the Mitigating Systems Cornerstone, and it
affected the cornerstone objective to ensure the availability, reliability, and
capability of systems that respond to initiating events to prevent undesirable
consequences. The inspectors conducted a Phase 1 screening of the finding in
accordance with IMC 0609, Attachment 0609.04, Initial Screening and
Characterization of Findings, and determined the finding to be of very low safety
significance because it was not a design or qualification deficiency; it did not
result in the loss of a system safety function; it did not represent the loss of a
single train for greater than technical specification allowed outage time; it did not
represent a loss of one or more non-technical specification risk-significant
equipment for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and it did not screen as potentially risk-
significant due to seismic, flooding, or severe weather. The cause of this finding
was determined to have no cross-cutting aspect due to the fact that the hot gas
bypass valves were installed backwards more than three years ago and did not
represent a current station performance issue (Section 1R19).
B.
Licensee-Identified Violations
None
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Enclosure
REPORT DETAILS
Summary of Plant Status
The plant began the inspection period at 100 percent power. The plant remained at 100 percent
power for the remainder of the inspection period except for planned power reductions to support
maintenance and testing.
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and
1R01 Adverse Weather Protection (71111.01)
.1
Readiness for Seasonal Extreme Weather Conditions
a.
Inspection Scope
The inspectors performed a review of the adverse weather procedures for seasonal
extremes (e.g., extreme high temperatures, extreme low temperatures, or hurricane
season preparations). The inspectors verified that weather-related equipment
deficiencies identified during the previous year were corrected prior to the onset of
seasonal extremes, and evaluated the implementation of the adverse weather
preparation procedures and compensatory measures for the affected conditions before
the onset of, and during, the adverse weather conditions.
During the inspection, the inspectors focused on plant-specific design features and the
procedures used by plant personnel to mitigate or respond to adverse weather
conditions. Additionally, the inspectors reviewed the FSAR and performance
requirements for systems selected for inspection, and verified that operator actions were
appropriate as specified by plant-specific procedures. Specific documents reviewed
during this inspection are listed in the attachment. The inspectors also reviewed
corrective action program items to verify that plant personnel were identifying adverse
weather issues at an appropriate threshold and entering them into their corrective action
program in accordance with station corrective action procedures. The inspectors
reviews focused specifically on the following plant systems:
November 18-19, 2010, diesel generator rooms and service water pump houses
for cold weather preparations
These activities constitute completion of one readiness for seasonal adverse weather
sample as defined in Inspection Procedure 71111.01-05.
b.
Findings
No findings were identified.
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Enclosure
.2
Readiness for Impending Adverse Weather Conditions
a.
Inspection Scope
Since extreme cold conditions were forecast in the vicinity of the facility for November
24, 2010, the inspectors reviewed overall preparations/protection for the expected
weather conditions. The inspectors inspected the transformer yard, diesel generators,
and service water systems because their safety-related functions could be affected or
required as a result of the extreme cold conditions forecast for the facility. The
inspectors observed insulation, heat trace circuits, space heater operation, and
weatherized enclosures to ensure operability of affected systems. The inspectors
reviewed licensee procedures and discussed potential compensatory measures with
control room personnel. The inspectors focused on plant managements actions for
implementing the stations procedures for ensuring adequate personnel for safe plant
operation and emergency response would be available. Specific documents reviewed
during this inspection are listed in the attachment.
These activities constitute completion of one readiness for impending adverse weather
condition sample as defined in Inspection Procedure 71111.01-05.
b.
Findings
No findings were identified.
1R04 Equipment Alignments (71111.04)
.1
Partial Walkdown
a.
Inspection Scope
The inspectors performed partial system walkdowns of the following risk-significant
systems:
October 6, 2010, after fill verification of high pressure core spray system
November 1, 2010, circulating water system during lifting activities
December 20, 2010, containment instrument air system
The inspectors selected these systems based on their risk significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors attempted
to identify any discrepancies that could affect the function of the system, and, therefore,
potentially increase risk. The inspectors reviewed applicable operating procedures,
system diagrams, FSAR, technical specification requirements, administrative technical
specifications, outstanding work orders, condition reports, and the impact of ongoing
work activities on redundant trains of equipment in order to identify conditions that could
have rendered the systems incapable of performing their intended functions. The
inspectors also inspected accessible portions of the systems to verify system
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Enclosure
components and support equipment were aligned correctly and operable. The
inspectors examined the material condition of the components and observed operating
parameters of equipment to verify that there were no obvious deficiencies. The
inspectors also verified that the licensee had properly identified and resolved equipment
alignment problems that could cause initiating events or impact the capability of
mitigating systems or barriers and entered them into the corrective action program with
the appropriate significance characterization. Specific documents reviewed during this
inspection are listed in the attachment.
These activities constitute completion of three partial system walkdown samples as
defined in Inspection Procedure 71111.04-05.
b.
Findings
No findings were identified.
1R05 Fire Protection (71111.05)
.1
Quarterly Fire Inspection Tours
a.
Inspection Scope
The inspectors conducted fire protection walkdowns that were focused on availability,
accessibility, and the condition of firefighting equipment in the following risk-significant
plant areas:
September 29, 2010, fire area RC-2, cable spreading room
September 30, 2010, Technical Support Center heating, ventilation and air
conditioning room
October 15, 2010, TG-1, Turbine Building 471 foot elevation, digital electro-
hydraulic pump area
November 22, 2010, fire area RC-6, division 2 battery room
The inspectors reviewed areas to assess if licensee personnel had implemented a fire
protection program that adequately controlled combustibles and ignition sources within
the plant; effectively maintained fire detection and suppression capability; maintained
passive fire protection features in good material condition; and had implemented
adequate compensatory measures for out of service, degraded or inoperable fire
protection equipment, systems, or features, in accordance with the licensees fire plan.
The inspectors selected fire areas based on their overall contribution to internal fire risk
as documented in the plants Individual Plant Examination of External Events with later
additional insights, their potential to affect equipment that could initiate or mitigate a
plant transient, or their impact on the plants ability to respond to a security event. Using
the documents listed in the attachment, the inspectors verified that fire hoses and
extinguishers were in their designated locations and available for immediate use; that
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Enclosure
fire detectors and sprinklers were unobstructed; that transient material loading was
within the analyzed limits; and fire doors, dampers, and penetration seals appeared to
be in satisfactory condition. The inspectors also verified that minor issues identified
during the inspection were entered into the licensees corrective action program.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four quarterly fire-protection inspection samples
as defined in Inspection Procedure 71111.05-05.
b.
Findings
No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11)
a.
Inspection Scope
On November 2, 2010, the inspectors observed a crew of licensed operators in the
plants simulator to verify that operator performance was adequate, evaluators were
identifying and documenting crew performance problems, and training was being
conducted in accordance with licensee procedures. The inspectors evaluated the
following areas:
Licensed operator performance
Crews clarity and formality of communications
Crews ability to take timely actions in the conservative direction
Crews prioritization, interpretation, and verification of annunciator alarms
Crews correct use and implementation of abnormal and emergency procedures
Control board manipulations
Oversight and direction from supervisors
Crews ability to identify and implement appropriate technical specification
actions and emergency plan actions and notifications
The inspectors compared the crews performance in these areas to preestablished
operator action expectations and successful critical task completion requirements.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one quarterly licensed-operator requalification
program sample as defined in Inspection Procedure 71111.11.
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Enclosure
b.
Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12)
a.
Inspection Scope
The inspectors evaluated degraded performance issues involving the following risk
significant systems:
October 19, 2010, Action Request/Condition Report 218546, Control Room
Emergency Chiller CCh-CR-1A Unreliable
The inspectors reviewed events such as where ineffective equipment maintenance has
resulted in valid or invalid automatic actuations of engineered safeguards systems and
independently verified the licensee's actions to address system performance or condition
problems in terms of the following:
Implementing appropriate work practices
Identifying and addressing common cause failures
Scoping of systems in accordance with 10 CFR 50.65(b)
Characterizing system reliability issues for performance
Charging unavailability for performance
Trending key parameters for condition monitoring
Ensuring proper classification in accordance with 10 CFR 50.65(a)(1) or -(a)(2)
Verifying appropriate performance criteria for structures, systems, and
components classified as having an adequate demonstration of performance
through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as
requiring the establishment of appropriate and adequate goals and corrective
actions for systems classified as not having adequate performance, as described
The inspectors assessed performance issues with respect to the reliability, availability,
and condition monitoring of the system. In addition, the inspectors verified maintenance
effectiveness issues were entered into the corrective action program with the appropriate
significance characterization. Specific documents reviewed during this inspection are
listed in the attachment.
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Enclosure
These activities constitute completion of one quarterly maintenance effectiveness
sample as defined in Inspection Procedure 71111.12-05.
b.
Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)
a.
Inspection Scope
The inspectors reviewed licensee personnel's evaluation and management of plant risk
for the maintenance and emergent work activities affecting risk-significant and safety-
related equipment listed below to verify that the appropriate risk assessments were
performed prior to removing equipment for work:
November 2, 2010, circulating water system motor and pump lifting activities
The inspectors selected these activities based on potential risk significance relative to
the reactor safety cornerstones. As applicable for each activity, the inspectors verified
that licensee personnel performed risk assessments as required by 10 CFR 50.65(a)(4)
and that the assessments were accurate and complete. When licensee personnel
performed emergent work, the inspectors verified that the licensee personnel promptly
assessed and managed plant risk. The inspectors reviewed the scope of maintenance
work, discussed the results of the assessment with the licensee's probabilistic risk
analyst or shift technical advisor, and verified plant conditions were consistent with the
risk assessment. The inspectors also reviewed the technical specification requirements
and inspected portions of redundant safety systems, when applicable, to verify risk
analysis assumptions were valid and applicable requirements were met. Specific
documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of one maintenance risk assessments and
emergent work control inspection sample as defined in Inspection Procedure
71111.13-05.
b.
Findings
Introduction: The inspectors identified a Green noncited violation of 10 CFR 50.65(a)(4)
for the licensees failure to perform a risk assessment during lifting activities in the
circulating water pump house on November 2, 2010.
Description: On November 2, 2010 the inspectors observed lifting and rigging activities
in the circulating water pump house. The licensee was preparing to lift one circulating
water motor from its pedestal to a truck, so the motor could be sent off for maintenance.
The inspectors determined a risk assessment had not been performed for the movement
of the motor. The inspectors questioned the licensee staff as to what the risk was during
the movement of the motor based on the plant configuration. Licensee staff performed a
risk assessment and determined the risk category to be one level higher than what was
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Enclosure
reported during the lifting activities. The licensee's investigation determined that the
work order planning process did not adequately evaluate the risk of lifting loads above
operating equipment.
Analysis: The failure to perform a risk assessment was a performance deficiency. The
performance deficiency was more than minor because it involved a failure to assess risk
during a maintenance activity. The performance deficiency affected the equipment
performance attribute of the Initiating Events Cornerstone objective to limit the likelihood
of events that upset plant stability. The inspectors evaluated the performance deficiency
using Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and
Risk Management Significance Determination Process, and determined the
performance deficiency to be of very low safety significance (Green) because the risk
deficit during the time the motor was being moved was less than 1.0E-6. The inspectors
determined the violation had a cross-cutting aspect in the area of human performance,
resources component, for the failure to provide up to date procedures in the work order
planning process that would incorporate risk insights during lifting operations around
operating plant equipment H.2.c].
Enforcement: Title 10 CFR 50.65(a)(4), states, in part, that the licensee shall assess
and manage the increase in risk that may result from proposed maintenance activities.
Contrary to the above, on November 2, 2010, the licensee failed to assess the increase
in risk during lifting and rigging activities inside the circulating water pump house.
Because this violation was of very low safety significance and has been entered into the
licensees corrective action program as Action Request 228710, this violation is being
treated as a noncited violation, consistent with Section 2.3.2.a of the NRC Enforcement
Policy: NCV 05000397/2010005-01, "Inadequate Risk Assessment During Lifting
Activities."
1R15 Operability Evaluations (71111.15)
a.
Inspection Scope
The inspectors reviewed the following issues:
October 19, 2010, Action Request/Condition Report 227524, Unexpected Trip of
SGT-FN-1A1 during containment inerting
October 28, 2010, Action Request/Condition Report 228094, Service Water
System Piping 18 SW(22)-2-2 corrosion
November 4, 2010, Action Request/Condition Report 228614, DMA-TIC-22/2
Indicating Off Scale High
November 9, 2010, Work Order 01185837, CRD-LIS-601C is reading
erroneously high
The inspectors selected these potential operability issues based on the risk significance
of the associated components and systems. The inspectors evaluated the technical
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Enclosure
adequacy of the evaluations to ensure that technical specification operability was
properly justified and the subject component or system remained available such that no
unrecognized increase in risk occurred. The inspectors compared the operability and
design criteria in the appropriate sections of the technical specifications and FSAR to the
licensee personnels evaluations to determine whether the components or systems were
operable. Where compensatory measures were required to maintain operability, the
inspectors determined whether the measures in place would function as intended and
were properly controlled. The inspectors determined, where appropriate, compliance
with bounding limitations associated with the evaluations. Additionally, the inspectors
also reviewed a sampling of corrective action documents to verify that the licensee was
identifying and correcting any deficiencies associated with operability evaluations.
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four operability evaluations inspection samples
as defined in Inspection Procedure 71111.15-04
b.
Findings
No findings were identified.
1R18 Plant Modifications (71111.18)
a.
Inspection Scope
To verify that the safety functions of important safety systems were not degraded, the
inspectors reviewed temporary modification TMR 10-007.
The inspectors reviewed the temporary modification and the associated safety-
evaluation screening against the system design bases documentation, including the
FSAR and the technical specifications, and verified that the modification did not
adversely affect the system operability/availability. The inspectors also verified that the
installation and restoration were consistent with the modification documents and that
configuration control was adequate. Additionally, the inspectors verified that the
temporary modification was identified on control room drawings, appropriate tags were
placed on the affected equipment, and licensee personnel evaluated the combined
effects on mitigating systems and the integrity of radiological barriers.
These activities constitute completion of one sample for temporary plant modifications as
defined in Inspection Procedure 71111.18-05.
b.
Findings
No findings were identified.
- 13 -
Enclosure
1R19 Postmaintenance Testing (71111.19)
a.
Inspection Scope
The inspectors reviewed the following postmaintenance activities to verify that
procedures and test activities were adequate to ensure system operability and functional
capability:
October 1, 2010, Work Order 01189118, Perform leak Check on Cylinders, 25
hours after Diesel Generator 1 Run
October 14, 2010, control room emergency chiller system A operability test
October 18, 2010, Work Order 001196398, CMS-SR-20 Testing of Newly
Installed Fan
October 21, 2010, Work Order 01190544, replace standby liquid control relief
valve 29B
October 28, 2010, Work Order 01183582, PMT Leakage Inspection RHR-M-
P/2A
November 16, 2010, Work Order 01173045, RHR-MO-3A, Baseline Diagnostic
Test
November 22, 2010, Work Order 01184470, Repair Inter-Tier Cable Between
Cells 185 and 186 for 250Vdc Safety Related Battery
November 23, 2010, Work Order 01184469, Repair Inter-Tier Cable Between
Cells 28 and 29 of 125Vdc Division I Safety Related Battery
The inspectors selected these activities based upon the structure, system, or
component's ability to affect risk. The inspectors evaluated these activities for the
following (as applicable):
The effect of testing on the plant had been adequately addressed; testing was
adequate for the maintenance performed
Acceptance criteria were clear and demonstrated operational readiness; test
instrumentation was appropriate
The inspectors evaluated the activities against the technical specifications, the FSAR, 10
CFR Part 50 requirements, licensee procedures, and various NRC generic
communications to ensure that the test results adequately ensured that the equipment
met the licensing basis and design requirements. In addition, the inspectors reviewed
corrective action documents associated with postmaintenance tests to determine
whether the licensee was identifying problems and entering them in the corrective action
program and that the problems were being corrected commensurate with their
- 14 -
Enclosure
importance to safety. Specific documents reviewed during this inspection are listed in
the attachment.
These activities constitute completion of eight postmaintenance testing inspection
samples as defined in Inspection Procedure 71111.19-05.
b.
Findings
.1
Introduction: The inspectors identified a Green noncited violation of 10 CFR Part 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings for the licensees
failure to include acceptance criteria appropriate to the circumstance in Surveillance
Testing Procedure ESP-B11-A101 12 Month Battery Inspection of 125Vdc E-B1-1,
Revision 5. Specifically, licensee personnel listed a non conservative inter-tier
resistance value as acceptance criteria which led to a degraded condition being
unanalyzed for three years.
Description: On January 18, 2010, while performing Procedure ESP-B11-A101, licensee
staff noted the inter-tier battery cable resistance between two battery cells had increased
greater than 20 percent from the original installed value in 2006. This was found during
review of the completed procedure by a licensee staff member who was familiar with the
original installation value. The licensee documented the inter-tier resistance to be 106
micro-ohms in Action Request/Condition Report 211313. An operability review was
performed and the batteries were determined to be operable due to total battery
resistance being less than the design limit. In the same condition report the licensee
documented the connection values in 2006 as 84 micro ohms, in 2007 as 103 micro
ohms, in 2008 as 102 micro ohms, and in 2009 as 105 micro ohms. The condition report
did not document that the values during these years did not meet the acceptance criteria
for the battery. Due to the inspector's questioning, the licensee initiated Action
Request/Condition Report 224744 to document that the inter-tier battery cable had not
met its acceptance criteria since 2007. The licensee did not perform an operability
review for each year the battery did not meet its acceptance criteria. After the inspectors
questioned the licensee's review, the licensee documented a basis for operability for
each year the inter-tier battery cable was above its acceptance criteria. The final basis
for operability was documented in Action Request/Condition Report 230667.
Licensee Controlled Specification Surveillance Requirement 1.8.6.2.15 states that the
acceptance criteria of inter-tier connection resistance shall be less than or equal to 20
percent above the original installed value. In 2006, when Columbia Generating Station
installed new 125Vdc batteries, the measured installed resistance value for the inter-tier
cable connection between cell 28 and cell 29 was 84 micro-ohms. The acceptance
criteria for the inter-tier cable resistance should have been set at 101 micro-ohms. The
surveillance procedure was revised in August of 2007 and the chart used to document
cell resistance values listed the acceptance criteria of the inter-tier battery cable
resistance as 120 micro-ohms. This nonconservative value caused workers who were
performing the surveillance test to believe the acceptance criteria was met when it was
not.
- 15 -
Enclosure
Analysis: The failure to include appropriate acceptance criteria in surveillance
procedures is a performance deficiency. The performance deficiency is more than minor
because it affects the equipment performance attribute of the Mitigating Systems
Cornerstone for ensuring the reliability of systems that respond to initiating events.
Using Inspection Manual Chapter 0609.04, Phase 1 - Initial Screening and
Characterization of Findings, the inspectors determined that this performance deficiency
was of very low safety significance because the finding was confirmed to not result in a
loss of operability for the 125Vdc batteries. The inspectors determined a cross-cutting
aspect was not applicable to the finding because the procedure change which
implemented the new acceptance criteria occurred in 2007, and thus, was not
representative of current licensee performance.
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures,
and Drawings, requires in part that activities affecting quality shall be prescribed by
documented instructions, procedures, or drawings, of a type appropriate to the
circumstances and shall include appropriate quantitative or qualitative acceptance
criteria for determining that important activities have been satisfactorily accomplished.
Contrary to this, on August 31, 2007, the licensee failed to include appropriate
acceptance criteria for inter-tier battery cable resistance in Procedure ESP-B11-A101.
This caused the licensee to not document higher than acceptable resistance readings on
the 125Vdc battery system from 2007 through 2009. This surveillance procedure has
been revised to include the appropriate acceptance criteria. Because this finding was
determined to be of very low safety significance and was entered into the licensees
corrective action as Action Request/Condition Report 231971, this violation is being
treated as a noncited violation consistent with Section 2.3.2.a of the NRC Enforcement
Policy: NCV 05000397/2010005-02, Failure to Include Appropriate Acceptance
Criteria.
.2
Introduction: An NRC-identified Green noncited violation of 10 CFR 50, Appendix B,
Criterion XVI, Corrective Action, was identified for Energy Northwests failure to
promptly identify and correct a condition adverse to quality involving both trains of
control room emergency chillers.
Description: The control room emergency chillers have tripped on numerous occasions
in the past, but recently the CCH-CR-1A had tripped five times in the past six months
due to low refrigerant pressure as documented in the licensees control room logs and
Action Request/Condition Reports:
June 13, 2010, CCH-CR-1A tripped due to refrigerant low pressure
June 15, 2010, CCH-CR-1A tripped due to refrigerant low pressure
July 3, 2010, Action Request/Condition Report 221003, CCH-CR-1A tripped due
to refrigerant low pressure
August 1, 2010, Action Request/Condition Report 222650, CCH-CR-1A tripped
due to refrigerant low pressure
- 16 -
Enclosure
September 27, 2010, CCH-CR-1A and the chiller tripped due to refrigerant Low
Pressure (7R) light locked in and which comes from CCH-PS-2A. The hot gas
bypass valve is not opening
On August 13, 2010, the inspectors questioned the licensee's maintenance of the
control room emergency chiller systems. The inspectors questioned the material
condition, post maintenance testing procedural inadequacies, and operability of the
system. As required per FSAR Paragraph 9.4.1.2, Amendment 54, the chillers are
designed to be available to supply cooling water to the respective control room heating,
ventilation and control system emergency coil in support of comfort cooling, provided the
credited standby service water system allows temperatures to become uncomfortable for
the control room staff. The main control room habitability systems are designed to
ensure habitability inside the main control room during all normal and abnormal
operating conditions, including 30 days of habitability following a Loss-of-Coolant
Accident.
Discussions with engineering personnel revealed that adjustments were allowed to be
made to the chillers during chiller operability testing. Procedure PPM OSP-CCH/IST-
M701, Control Room Emergency Chiller System A Operability, Revision 28,
Paragraphs 7.1.2, 7.1.22, 7.1.32 and 7.1.44, allows addition of oil and paragraphs 7.1.33
and 7.1.38 allows filling and venting certain points in the chiller system during operability
testing. Following inspectors questioning, the licensee investigated chiller CH-CR-1A
failures and determined that the hot gas bypass valves for the A and B trains of control
room emergency chillers had been set up incorrectly, as documented in Action
Request/Condition Report 226868. As a result, the hot gas bypass valves, which control
chiller load and suction pressure in the compressor, opened when they should have
been closed. In this configuration under low load conditions, suction pressure in the
compressor was abnormally low, contributing to chiller trips on low refrigerant pressure.
The hot gas bypass valves were installed correctly in both A and B trains of the control
room emergency chiller systems and a satisfactory operability test was performed on
chiller CCH-CR-1A on October 13, 2010.
Analysis: The failure to perform appropriate postmaintenance tests is a performance
deficiency. The performance deficiency was determined to be more than minor because
it was associated with the configuration control attribute of the Mitigating Systems
Cornerstone, and affected the associated cornerstone objective to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. Using Manual Chapter 0609.04, Phase 1 - Initial
Screening and Characterization of Findings, the finding was determined to have very
low safety significance because: (1) the finding was not a qualification deficiency that
resulted in a loss of functionality of control room chillers; (2) it did not lead to an actual
loss of safety function of the system or train; (3) it did not result in an actual loss of
safety function of a single train for greater than its technical specification allowed outage
time; (4) it did not represent an actual loss of safety function of one or more non-
technical specification trains of equipment designated as risk-significant per 10 CFR
50.65, for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (5) it did not screen as potentially risk-significant
due to a seismic, flooding, or severe weather initiating event. The cause of this finding
- 17 -
Enclosure
was determined to have no cross-cutting aspect due to the fact that the hot gas bypass
valves were installed backwards more than three years ago and did not represent a
current station performance issue
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Actions,
states, in part, that conditions adverse to quality, such as failures, malfunctions,
deficiencies, deviations, defective material and equipment, and non-conformances are
promptly identified and corrected. Contrary to the above, on numerous occasions as
described above, inadequate operability testing failed to identify and correct hot gas
bypass valves that were installed incorrectly on the A and B trains of control room
emergency chillers. Because this finding was of very low safety significance and was
entered into the licensees corrective action program as Action Request/Condition
Report 223485, this violation is being treated as a noncited violation, consistent with
Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000397/2010005-03; Failure to
Promptly Identify and Correct a Condition Adverse to Quality Associated with both Trains
of Control Room Emergency Chillers.
1R22 Surveillance Testing (71111.22)
a.
Inspection Scope
The inspectors reviewed the FSAR, procedure requirements, and technical
specifications to ensure that the surveillance activities listed below demonstrated that the
systems, structures, and/or components tested were capable of performing their
intended safety functions. The inspectors either witnessed or reviewed test data to
verify that the significant surveillance test attributes were adequate to address the
following:
Preconditioning
Evaluation of testing impact on the plant
Acceptance criteria
Test equipment
Procedures
Jumper/lifted lead controls
Test data
Testing frequency and method demonstrated technical specification operability
Test equipment removal
Restoration of plant systems
- 18 -
Enclosure
Fulfillment of ASME Code requirements
Updating of performance indicator data
Engineering evaluations, root causes, and bases for returning tested systems,
structures, and components not meeting the test acceptance criteria were correct
Reference setting data
Annunciators and alarms setpoints
The inspectors also verified that licensee personnel identified and implemented any
needed corrective actions associated with the surveillance testing.
October 6, 2010, SOP-TIP-OPS, TIP System Operation
November 15, 2010, OSP-RHR/IST-Q702, RHR Loop A Operability Test
December 9, 2010, TSP-RHRB/RHRC-B502, RHRB/RHRC Annunciator LSFT
December 20, 2010, Work Order 01192226, SOP-FDR-OPS, Floor Drain
System Operation
Specific documents reviewed during this inspection are listed in the attachment.
These activities constitute completion of four surveillance testing inspection samples as
defined in Inspection Procedure 71111.22-05.
b.
Findings
No findings were identified.
4.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.1
Data Submission Issue
a.
Inspection Scope
The inspectors performed a review of the performance indicator data submitted by the
licensee for the third Quarter 2010 performance indicators for any obvious
inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, Performance Indicator Program.
This review was performed as part of the inspectors normal plant status activities and,
as such, did not constitute a separate inspection sample.
- 19 -
Enclosure
b.
Findings
No findings were identified.
.2
Mitigating Systems Performance Index - Residual Heat Removal System (MS09)
a.
Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance
index - residual heat removal system performance indicator for the period from the third
quarter 2009 through the fourth quarter 2010. To determine the accuracy of the
performance indicator data reported during those periods, the inspectors used definitions
and guidance contained in NEI Document 99-02, Regulatory Assessment Performance
Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator
narrative logs, issue reports, mitigating systems performance index derivation reports,
event reports, and NRC integrated inspection reports for the period of July 2009 through
December 2010, to validate the accuracy of the submittals. The inspectors reviewed the
mitigating systems performance index component risk coefficient to determine if it had
changed by more than 25 percent in value since the previous inspection, and if so, that
the change was in accordance with applicable NEI guidance. The inspectors also
reviewed the licensees issue report database to determine if any problems had been
identified with the performance indicator data collected or transmitted for this indicator
and none were identified. Specific documents reviewed are described in the attachment
to this report.
These activities constitute completion of one mitigating systems performance index-
residual heat removal system sample as defined in Inspection Procedure 71151-05.
b.
Findings
No findings were identified.
.3
Mitigating Systems Performance Index - Cooling Water Systems (MS10)
a.
Inspection Scope
The inspectors sampled licensee submittals for the mitigating systems performance
index - cooling water systems performance indicator for the period from the third quarter
2009 through the fourth quarter 2010. To determine the accuracy of the performance
indicator data reported during those periods, the inspectors used definitions and
guidance contained in NEI Document 99-02, Regulatory Assessment Performance
Indicator Guideline, Revision 6. The inspectors reviewed the licensees operator
narrative logs, issue reports, mitigating systems performance index derivation reports,
event reports, and NRC integrated inspection reports for the period of July 2009 through
December 2010, to validate the accuracy of the submittals. The inspectors reviewed the
mitigating systems performance index component risk coefficient to determine if it had
changed by more than 25 percent in value since the previous inspection, and if so, that
- 20 -
Enclosure
the change was in accordance with applicable NEI guidance. The inspectors also
reviewed the licensees issue report database to determine if any problems had been
identified with the performance indicator data collected or transmitted for this indicator
and none were identified. Specific documents reviewed are described in the attachment
to this report.
These activities constitute completion of one mitigating systems index-cooling water
system sample as defined in Inspection Procedure 71151-05.
b.
Findings
No findings were identified.
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical
Protection
4OA2 Identification and Resolution of Problems (71152)
.1
Routine Review of Identification and Resolution of Problems
a.
Inspection Scope
As part of the various baseline inspection procedures discussed in previous sections of
this report, the inspectors routinely reviewed issues during baseline inspection activities
and plant status reviews to verify that they were being entered into the licensees
corrective action program at an appropriate threshold, that adequate attention was being
given to timely corrective actions, and that adverse trends were identified and
addressed. The inspectors reviewed attributes that included the complete and accurate
identification of the problem; the timely correction, commensurate with the safety
significance; the evaluation and disposition of performance issues, generic implications,
common causes, contributing factors, root causes, extent of condition reviews, and
previous occurrences reviews; and the classification, prioritization, focus, and timeliness
of corrective actions. Minor issues entered into the licensees corrective action program
because of the inspectors observations are included in the attached list of documents
reviewed.
These routine reviews for the identification and resolution of problems did not constitute
any additional inspection samples. Instead, by procedure, they were considered an
integral part of the inspections performed during the quarter and documented in Section
1 of this report.
b.
Findings
No findings were identified.
- 21 -
Enclosure
.2
Daily Corrective Action Program Reviews
a.
Inspection Scope
In order to assist with the identification of repetitive equipment failures and specific
human performance issues for follow-up, the inspectors performed a daily screening of
items entered into the licensees corrective action program. The inspectors
accomplished this through review of the stations daily corrective action documents.
The inspectors performed these daily reviews as part of their daily plant status
monitoring activities and, as such, did not constitute any separate inspection samples.
b.
Findings
No findings were identified.
.3
Selected Issue Follow-up Inspection
a.
Inspection Scope
During a review of items entered in the licensees corrective action program, the
inspectors reviewed the following corrective action items:
February 1, 2010, Action Request/Condition Report 212058, NRC Questions
Regarding Improperly Installed Fuses
December 12, 2010, Action Request/Condition Report 203872, NRC Questions
the location of a barrel near Standby Liquid Control Equipment
The inspectors performed a review of the licensees corrective action program and
associated documents to identify trends that could indicate the existence of a more
significant safety issue. The inspectors review was focused on repetitive equipment and
corrective maintenance issues but also considered the results of daily inspector
corrective action program item screenings discussed in Section 4OA2.1. Corrective
actions associated with identified trends were reviewed for adequacy.
These activities constitute completion of two in-depth problem identification and
resolution samples as defined in Inspection Procedure 71152-05.
b.
Findings
Introduction: The inspectors identified a noncited violation of 10 CFR Part 50, Appendix
B, Criterion V, Instructions, Procedures, and Drawings," for Energy Northwests
repetitive failure to conduct engineering evaluations in accordance with the stations
seismic procedure as it relates to equipment positioned adjacent to safety-related
components.
- 22 -
Enclosure
Description: On December 15, 2010, during a walkdown of the standby liquid control
system, the inspectors noted that a 55 gallon drum was positioned adjacent to the
standby liquid control system. This barrel had been staged to support work associated
with the standby service water system per Work Order 01188898. The inspectors noted
that this container was positioned such that it could overturn during a seismic event and
impact the safety-related standby liquid control system. The inspectors notified the main
control room personnel, who directed an equipment operator to immediately position the
55 gallon drum away from the standby liquid control system. This was documented in
Action Request/Condition Report 230872.
The inspectors questioned the Energy Northwest staff if this met the requirements of
Procedure PPM 10.2.53, Seismic Requirements For Scaffolding, Ladders, Man-Lifts,
Tool Gang Boxes, Hoists, Metal Storage Cabinets, and Temporary Shielding Racks,
Revision 26 to properly secure or analyze equipment in close proximity to safety-related
equipment to prevent seismically-induced interactions. Step 7.2.2 of Procedure PPM
10.2.53 stated that transient equipment used in the reactor building is to be stored so it
does not overturn in a seismic event and impact safety-related equipment. Energy
Northwest staff concluded damage could result from an impact of the improperly staged
barrel next to the standby liquid control system during a seismic event.
Analysis: The licensee's failure to implement Procedure PPM 10.2.53 is a performance
deficiency. This finding was more than minor because it was a human performance
error which affected the Mitigating Systems Cornerstone objective to ensure the
availability and reliability of systems that respond to initiating events to prevent
undesirable consequences. Energy Northwests failure to evaluate this condition in
accordance with Procedure PPM 10.2.53 was not commensurate with ensuring the
reliability and availability of safety-related equipment in the plant. The finding was
determined to be of very low safety significance because it was not a design or
qualification deficiency; it did not result in the loss of a system safety function; it did not
represent the loss of a single train for greater than technical specification allowed outage
time; it did not represent a loss of one or more non-technical specification risk-significant
equipment for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and it did not screen as potentially risk significant
due to seismic, flooding, or severe weather. A cross-cutting aspect in the human
performance area with a work control component was identified in that Energy Northwest
failed to appropriately plan work, resulting in job site conditions which may have
impacted plant components H.3.a].
- 23 -
Enclosure
Enforcement: Title 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures,
and Drawings," states, in part, that activities affecting quality shall be accomplished in
accordance with documented instructions appropriate to the circumstances. Contrary to
this requirement, on December 15, 2010, Energy Northwest failed to implement
Procedure PPM 10.2.53 by failing to conduct an engineering evaluation to assess the
seismic interaction of equipment staged adjacent to safety related components.
Because this finding was of very low safety significance and was entered into the
licensee's corrective action program as Action Request/Condition Report 230872, this
violation is being treated as a noncited violation, consistent with Section 2.3.2.a of the
NRC Enforcement Policy: NCV 05000397/2010005-04; Failure to Perform Engineering
Evaluation to Determine Seismic Qualification of Safety-related Equipment.
4OA5 Other Activities
.1
(Closed) Licensee Event Report (LER) 05000397/2010-001-00: Secondary
Containment Isolation Valve Not Fully Seated
This LER documented a secondary containment isolation valve not being fully closed
since July 4, 1994. Technical Specification Section 3.6.4.2, requires that each
secondary containment isolation valve shall be operable. Contrary to this requirement,
on August 13, 1994, the air actuator for FDR-V-219 (a secondary containment isolation
valve) was replaced without ensuring that the valve was fully seated and thus was
considered inoperable. NRC Inspection Report 05000397/2010004 previously
documented one licensee identified finding associated with this issue. This LER is
closed.
4OA6 Meetings
Exit Meeting Summary
On January 6, 2011, the inspectors presented the inspection results to Mr. M. Reddemann,
Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged
the issues presented. The inspector asked the licensee whether any materials examined during
the inspection should be considered proprietary. No proprietary information was identified.
A-1
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
D. Brown, Operations Manager
K. Christianson, Acting Licensing Supervisor
D. Clymer, Supervisor, Quality Services
M. Davis, Radiological Services Manager
C. Forrester, Manager, Nuclear Security
S. Gambhir, Vice President, Engineering
D. Gregoire, Acting Manager, Regulatory Affairs
C. King, Assistant Plant General Manager
J. Latta, Supervisor, System Engineer
D. Montgomery, Maintenance Coach
C. Moon, Training Manager
R. Parmelee, Systems Engineering Manager
J. Roy, Acting Manager, Production Maintenance
C. Sanoda, Licensing Engineer
B. Sawatzke, Chief Nuclear Officer
L. Sawyer, Organization Effectiveness Manager
N. Stuart, Maintenance Manager
D. Swank, General Manager, Engineering
J. Tansy, PSA Supervisor
L. Williams, Licensing Engineer
NRC Personnel
R. Cohen, Senior Resident Inspector
M. Hayes, Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
None.
Opened and Closed 05000397/2010005-01 NCV Inadequate Risk Assessment During Lifting Activities
(Section 1R13)05000397/2010005-02 NCV Failure to Include Appropriate Acceptance Criteria (Section 1R19)05000397/2010005-03 NCV Failure to Promptly Identify and Correct a Condition Adverse to
Quality Associated with both Trains of Control Room Emergency
Chillers (Section 1R19)
A-2
Attachment 05000397/2010005-04 NCV Failure to Perform Engineering Evaluation to Determine Seismic
Qualification of Safety-related Equipment (Section 4OA2)
Closed
05000397-2010-01-00 LER Secondary Containment Isolation Valve Not Fully Seated
Discussed
None.
A-3
Attachment
LIST OF DOCUMENTS REVIEWED
Section 1RO1: Adverse Weather Protection
PROCEDURES
NUMBER
TITLE
REVISION
SOP-COLDWEATHER-OPS
Cold Weather Operations
15
Section 1RO4: Equipment Alignment
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
REVISION
Fill Verification High pressure Core Spray System
6
SOP-CIA-LU
Containment Instrument Air System Valve and
Breaker Lineup
1
SOP-CIA-OPS
Containment Instrument Air System Operation
0
Drawing M556
Containment Instrument air System
50
ACTION REQUEST/CONDITION REPORTS
01189275
Section 1RO5: Fire Protection
PROCEDURES
NUMBER
TITLE
REVISION
Section F 2.2.15
Amendment
54
Section 1R11: Licensed Operator Requalification Program
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
REVISION
LR002002
Columbia Generating Station Simulator Examination
September 3,
2010
A-4
Attachment
Section 1R12: Maintenance Effectiveness
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
REVISION /
DATE
AR/CR 223485
CCH-CR-1A/1B Control Room Emergency Chiller System
Concerns
September
12, 2010
AR/CR 212058
NRC Questions Regarding Improperly Installed Fuses
February 1,
2010
Section 1R13: Maintenance Risk Assessment and Emergent Work Controls
PROCEDURES
NUMBER
TITLE
REVISION /
DATE
12 Month Battery Inspection of 125 VDC E-B1-1
6
ACTION REQUEST/CONDITION REPORTS
230667
211372
47998
229807
224774
211313
211374
Section 1R15: Operability Evaluations
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
REVISION /
DATE
CRD-LIS-601C is reading erroneously high
November 9,
2010
Calculation CMR
96-0115
Correct Algebraic Expression
November 9,
2010
AR/CR 213131
CRD-LIS-601C indicating erroneously high
November 9,
2010
CER C92-0488
Component Classification Record
0
Section 1R18: Plant Modifications
NUMBER
TITLE
DATE
TMR 10-007
Jumper Input Due to Reactor Feedwater Governor Speed
Probe RFT-SE-99T/1B1 Providing an Erratic Signal
October 4,
2010
A-5
Attachment
Section 1R19: Postmaintenance Testing
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
REVISION /
DATE
OSP-CCH/IST-
M701
Control Room Emergency Chiller System A Operability Test
28
CMS-SR-20 Testing Of Newly Installed Fan
October 18,
2010
AR/CR 227450
Oxygen Levels Trending Up Again Flowing Maintenance on
CMS-SR-20
Perform Leak Check on Cylinders 25 Hours after Diesel
Generator 1 Run
October 1,
2010
Repair Inter-Tier Cable between Cells 185 and 186 for
250VDC Safety Related Battery
November
22, 2010
Repair Inter-Tier Cable Between Cells 28 and 29 of 125VDC
Division I Safety Related Battery
November
23, 2010
Section 1R22: Surveillance Testing
PROCEDURES
NUMBER
TITLE
REVISION
SOP-TIP-OPS
TIP System Operation
8
Manual Scram Functional Test
6
TSP-RHRB/RHRC-B502
RHRB/RHRC Annunciator LSFT
2
Residual Heat Removal System B Valve position
Verification
2
Residual Heat Removal System C Valve Position
Verification
1
SOP-FDR-OPS
Floor Drain System Operation
0
SOP-CIA-LU
Containment Instrument Air System Valve and
Breaker Lineup
1
SOP-CIA-OPS
Containment Instrument Air System Operation
0
WORK ORDERS
01191549
01192111
01192110
01192226
A-6
Attachment
Section 4OA1: Performance Indicator Verification
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
REVISION /
DATE
Regulatory Assessment Performance Indicator Guideline
6
Energy Northwest and NRC Performance indicator Data for
July 2009 through December 2010
N/A
Energy Northwest Operator Logs for July 2009 through
December 2010
N/A
Section 4OA2: Identification and Resolution of Problems
ACTION REQUEST/CONDITION REPORTS
00226033
00226038
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A-7
Attachment
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A-8
Attachment
MISCELLANEOUS DOCUMENTS
NUMBER
TITLE
DATE
AR/CR 230872
NRC Questioned the Location of a Barrel Near SLC Pumps
December
12, 2010
AR/CR 212058
NRC Questions Regarding Improperly Installed Fuses
February 1,
2010
Disassembled and Clean out Orifice Flange Ports for SW-FI-
44
December
12, 2010
PPM 10.2.53 Seismic Requirements for Scaffolding, Ladders, Man-Lifts, 26
Tool Gang Boxes, Hoists, Metal Storage Cabinets, and
Temporary Shielding Racks