ML15316A834

IR 05000397/2015003, July 1, 2015 Through September 30, 2015, Columbia Generating Station Exercise of Enforcement Discretion

ML15316A834
Person / Time
Site:	Columbia
Issue date:	11/12/2015
From:	Troy Pruett NRC/RGN-IV/DRP
To:	Reddemann M Energy Northwest
Ryan Alexander
References
EA-15-202 IR 2015003
Download: ML15316A834 (62)

See also: IR 05000397/2015003

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION IV

1600 E. LAMAR BLVD.

ARLINGTON, TX 76011-4511

November 12, 2015

EA-15-202

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 05000397/2015003 AND EXERCISE OF ENFORCEMENT

DISCRETION

Dear Mr. Reddemann,

On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Columbia Generating Station. On October 1, 2015, the NRC inspectors

discussed the results of this inspection with Mr. W.G. Hettel, Chief Operating Officer and Chief

Nuclear Officer, and other members of your staff. The inspectors documented the results of this

inspection in the enclosed inspection report.

NRC inspectors documented five findings of very low safety significance (Green) in this report.

Four of these findings involved violations of NRC requirements. The NRC is treating these

violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC

Enforcement Policy.

Additionally, a violation involving the failure to maintain the operability of secondary containment

during Operations with a Potential to Drain the Reactor Vessel (OPDRV) was identified.

Specifically, from May 13, 2015, through June 13, 2015, Columbia Generating Station

performed five OPDRV activities with secondary containment inoperable in violation of

Technical Specification (TS) 3.6.4.1, Secondary Containment. The NRC issued EGM 11-003,

Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee

Noncompliance with Technical Specification Containment Requirements During Operations with

a Potential for Draining the Reactor Vessel, Revision 2, on December 13, 2013, allowing for the

exercise of enforcement discretion for OPDRV-related TS violations, when certain criteria are

met. The NRC concluded that Columbia Generating Station met these criteria. Because the

violation was identified during the discretion period described in EGM 11-003, the NRC is

exercising enforcement discretion in accordance with Section 3.5, Violations Involving Special

Circumstances, of the NRC Enforcement Policy and, therefore, will not issue enforcement

action for this violation, subject to a timely license amendment request being submitted.

If you contest the violations or significance of these NCVs, you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

M. Reddemann -2-

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement,

U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident

inspector at the Columbia Generating Station.

If you disagree with a cross-cutting aspect assignment or a finding not associated with a

regulatory requirement 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 Columbia Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, a copy of this letter, its enclosure, and your

response (if any) will be available electronically for public inspection in the NRCs Public

Document Room or from the Publicly Available Records (PARS) component of the NRC's

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic

Reading Room).

Sincerely,

/RA/

Troy W. Pruett

Director

Division of Reactor Projects

Docket Nos. 50-397

License Nos. NPF-21

Enclosure: Inspection Report 05000397/2015003

w/ Attachment: Supplemental

Information

cc w/ encl: Electronic Distribution

ML15316A834

SUNSI Review Non-Sensitive Publicly Available Keyword:

By: JRG Sensitive Non-Publicly Available

OFFICE RIV/DRP RIV/DRP RIV/DRP RIV/DRS RIV/DRS RIV/DRS RIV/DRS

NAME DBradley JGroom RAlexander TFarnholtz VGaddy MHaire HGepford

SIGNATURE /RA/ via E /RA/ via E /RA/ /RA/ /RA/ /RA/ /RA/

KClayton for

DATE 11/3/15 11/3/15 11/5/15 11/4/15 11/5/15 11/5/15 11/2/15

OFFICE RIV/DRS RIV/TSS RIV/ACES RIV/DRP RIV/DRP

NAME GWerner ERuesch JKramer RSmith TPruett

SIGNATURE /RA/ /RA/ /RA/ via E /RA/ /RA/

ERuesch for

DATE 11/6/15 11/6/15 11/3/15 11/6/15 11/12/15

M. Reddemann -3-

Letter to M.E. Reddemann from T. Pruett dated November 12, 2015

SUBJECT: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT 05000397/2015003 AND EXERCISE OF ENFORCEMENT

DISCRETION

DISTRIBUTION:

Regional Administrator (Marc.Dapas@nrc.gov)

Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director (Ryan.Lantz@nrc.gov)

DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov)

Senior Resident Inspector (Jeremy.Groom@nrc.gov)

Resident Inspector (Dan.Bradley@nrc.gov)

Site Administrative Assistant (Vacant)

Incoming Branch Chief, DRP/A (Jeremy.Groom@nrc.gov)

Acting Branch Chief, DRP/A (Rich.Smith@nrc.gov)

Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Project Engineer (Thomas.Sullivan@nrc.gov)

Project Engineer (Mathew.Kirk@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov)

Acting Team Leader, DRS/TSS (Eric.Ruesch@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)

RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)

ROP Reports (ROPreports.Resource@nrc.gov)

ROP Assessment Resource (ROPassessment.Resource@nrc.gov)

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 05000397

License: NPF-21

Report: 05000397/2015003

Licensee: Energy Northwest

Facility: Columbia Generating Station

Location: North Power Plant Loop

Richland, WA 99354

Dates: July 1, 2015 through September 30, 2015

Inspectors: D. Bradley, Resident Inspector

L. Carson, Senior Health Physicist

N. Greene, PhD, Health Physicist

J. Groom, Senior Resident Inspector

J. ODonnell, CHP, Health Physicist

M. Phalen, Senior Health Physicist

C. Stott, Project Engineer

Approved Richard Smith

By: Acting Chief, Projects Branch A

Division of Reactor Projects

-1- Enclosure

SUMMARY

IR 05000397/2015003; 07/01/2015 - 09/30/2015; Columbia Generating Station; Equipment

Alignment, Licensed Operator Performance, Radioactive Solid Waste Processing.

The inspection activities described in this report were performed between July 1 and September

30, 2015, by the resident inspectors at Columbia Generating Station and inspectors from the

NRCs Region IV office. Five findings of very low safety significance (Green) are documented in

this report. Four of these findings involved violations of NRC requirements. The significance of

inspection findings is indicated by their color (Green, White, Yellow, or Red), which is

determined using Inspection Manual Chapter 0609, Significance Determination Process. Their

cross-cutting aspects are determined using Inspection Manual Chapter 0310, Aspects within

the Cross-Cutting Areas. Violations of NRC requirements are dispositioned in accordance with

the NRC Enforcement Policy. The NRCs program for overseeing the safe operation of

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

Cornerstone: Mitigating Systems

• Green. The inspectors identified a finding associated with the licensees failure to maintain

seismic instrumentation functional as required by Licensee Controlled Specification 1.3.7.2,

Seismic Monitoring Instrumentation. Specifically, because of inadequate calibration

procedures, several as-left setpoints for the seismic response spectrum recorders indicating

lights were non-conservative relative to their function to alert operators of ground motion

exceeding the operating basis earthquake (OBE). Following discovery of this issue, the

licensee recalibrated the seismic response spectrum recorders using OBE ground motions

as the upper tolerance. The licensee entered this issue into their corrective action program

as Action Request 333996.

The performance deficiency was more than minor because it affected the configuration

control attribute of the Mitigating Systems Cornerstone objective and adversely affected the

cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences. Specifically, the

performance deficiency resulted in seismic instruments calibrations that were non-

conservative relative to their function to alert plant operators that a shutdown is required.

NRC regulations require a plant shutdown since systems necessary for continued operation

without undue risk to the health and safety of the public are not designed to remain

functional, in all cases, following an OBE. The inspector performed the initial significance

determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2,

Mitigating Systems Screening Questions. The inspectors determined that the finding was

of very low safety significance because (1) the finding was not a deficiency affecting the

design or qualification of a mitigating system; (2) the finding did not represent a loss of

system and/or function; (3) the finding did not represent an actual loss of function of a single

train for greater than its technical specification allowed outage time; and (4) the finding does

not represent an actual loss of function of one or more non-technical specification trains of

equipment designated as high safety-significant in accordance with the licensees

maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Additionally, the finding did not involve

the loss or degradation of equipment or function specifically designed to mitigate a seismic,

flooding, or severe weather initiating event. The finding does not have a cross-cutting

aspect since the configuration control error is associated with an instrument setpoint change

request from 1990 and therefore not reflective of current licensee performance.

(Section 1R04)

-2-

• Green. The inspectors identified a non-cited violation of Technical Specification 5.4.1.a,

Procedures, for the failure to maintain an adequate abnormal procedure for earthquakes.

Specifically, the licensee failed to establish appropriate shutdown criteria for earthquakes

that exhibit ground motion exceeding the operating basis earthquake (OBE). The licensees

shutdown criteria would allow for continued operations if ground motion at a single

frequency exceeded the design response spectrum. In response to this issue, the licensee

initiated corrective actions to change the stations earthquake abnormal procedure to

provide shutdown criteria consistent with the original licensing basis of the facility. The

licensee entered this issue into their corrective action program as Action Request 336875.

The performance deficiency was more than minor because it affected the procedural

adequacy attribute of the Mitigating Systems Cornerstone objective and adversely affected

the cornerstone objective to ensure the availability, reliability, and capability of systems that

respond to initiating events to prevent undesirable consequences. Specifically, the

performance deficiency resulted in shutdown criteria that would allow for continued

operations following events where ground motion at a single frequency exceeded the design

response spectra. NRC regulations require a plant shutdown since systems necessary for

continued operation without undue risk to the health and safety of the public are not

designed to remain functional, in all cases, following an OBE. The inspector performed the

initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A,

Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that the

finding was of very low safety significance because (1) the finding was not a deficiency

affecting the design or qualification of a mitigating system; (2) the finding did not represent a

loss of system and/or function; (3) the finding did not represent an actual loss of function of

a single train for greater than its technical specification allowed outage time; and (4) the

finding does not represent an actual loss of function of one or more non-technical

specification trains of equipment designated as high safety-significant in accordance with

the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Additionally, the finding

did not involve the loss or degradation of equipment or function specifically designed to

mitigate a seismic, flooding, or severe weather initiating event. The finding does not have a

cross-cutting aspect since the procedure error is associated with a 1996 change to the

licensing basis and therefore not reflective of current licensee performance. (Section 1R04)

• Green. The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion

III, Design Control, for the licensees failure to verify the adequacy of the design of the

control room HVAC system. Specifically, the licensee failed to demonstrate the ability of

control room HVAC design to maintain the temperatures in the main control room below

habitability and environmental qualification limits, for the duration of all accident scenarios.

The licensee initiated Action Request 332565 to document the concern, issued night order

1662 to communicate the issue, aligned both control room air handling units to their

respective chillers, created a quick card procedure to perform the chiller reset actions, and

validated the quick card actions could be accomplished within 10 minutes. Additionally, the

licensee determined that operators could restore the chillers during accident conditions

within 90 minutes to prevent temperatures from exceeding equipment operability limits.

The performance deficiency was more than minor because it adversely affected the design

control attribute of the Mitigating Systems Cornerstone objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent undesirable

consequences. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2,

Mitigating Systems Screening Questions, the inspectors determined the finding was of

-3-

very low safety significance because (1) the finding was not a deficiency affecting the design

or qualification of a mitigating system; (2) the finding did not represent a loss of system

and/or function; (3) the finding did not represent an actual loss of function of a single train for

greater than its technical specification allowed outage time; and (4) the finding does not

represent an actual loss of function of one or more non-technical specification trains of

equipment designated as high safety-significant in accordance with the licensees

maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding had a cross-cutting aspect

in the area of problem identification and resolution, evaluation, in that the licensee did not

thoroughly evaluate issues to ensure that resolutions address causes and extent of

conditions commensurate with their safety significance. Specifically, the licensee did not

thoroughly evaluate the extent of condition from NRC-identified NCV 05000397/2013002-04,

Failure to Obtain NRC Approval for Changes to Control Room HVAC Requirements, for

the effect of this change on other station calculations [P.2]. (Section 1R04)

• Green. The inspectors identified a non-cited violation of Technical Specification 5.4.1.a,

Procedures, for the licensees failure to ensure operators could perform time-critical steps

for fire events. Specifically, on July 4, 2015, the licensee failed to implement written

procedures to ensure that an equipment operator can complete certain post-fire safe-

shutdown actions within 10 minutes. In response to this conclusion, the licensee initiated

Action Request 332747 to document the inability to meet the post-fire safe-shutdown actions

in accordance with procedure PPM 1.3.1, Operating Policy, Programs, and Practices,

Revision 119. Additionally, the licensee issued Night Order 1655, reminding all operating

crews of the requirements of procedure PPM 1.3.1 for leaving the protected area.

This performance deficiency was more than minor because it was associated with the

protection against external factors attribute of the Mitigating System Cornerstone and

affected the cornerstones objective to ensure the availability, reliability, and capability of

systems that respond to initiating events to prevent undesirable consequences. A senior

reactor analyst performed a detailed significance determination process review using NRC

Inspection Manual Chapter 0609, Appendix F, Fire Protection Significance Determination,

dated September 20, 2013 and NRC Inspection Manual 0308, Attachment 3, Appendix F,

Technical Basis Fire Protection Significance Determination Process (Supplemental

Guidance for Implementing IMC 0609, Appendix F) At Power Operations, dated February

28, 2005. The senior reactor analyst determined that the failure of the equipment operator

to perform the certain post-fire safe-shutdown actions within 10 minutes would not adversely

affect a quantitative risk assessment, and therefore this finding was of very low safety

significance (Green). This finding has a cross-cutting aspect in the area of Human

Performance, Teamwork, because the licensee failed to communicate and to coordinate

their activities within and across organizational boundaries to ensure nuclear safety is

maintained. Specifically, the equipment operator spoke with the shift technical advisor

about the need to exit the protected area at the morning turnover meeting but neither

individual spoke with the control room supervisor. Communication was ineffective in that the

Equipment Operator believed permission was granted and proceeded to exit the protected

area [H.4]. (Section 1R11)

Cornerstone: Public Radiation Safety

• Green. The inspectors reviewed a self-revealing, non-cited violation of Technical

Specification 5.4.1.a, Procedures, for the licensees failure to follow their Process Control

Program as implemented by their solid radioactive waste system procedures. Specifically,

the licensee failed to reduce the free standing liquid in a condensate filter demineralizer

-4-

resin disposal package (Liner 14-033-L) to less than the required 0.5 percent of the total

waste volume. Corrective actions included retrieving the packages from waste shipment 14-

32, testing each liner for free standing liquid content, and removing additional water as

necessary. The licensee documented this issue in their corrective action program as Action

Requests 00316555 and 00316676.

The failure to follow the Process Control Program, resulting in the inadequate dewatering of

radioactive waste liner contents, was a performance deficiency. The inspectors determined

that the performance deficiency was more than minor, because it adversely affected the

Public Radiation Safety cornerstone objective to ensure adequate protection of public health

and safety from exposure to radioactive materials released in the public domain.

Specifically, the failure to ensure that the free standing liquid in the radioactive waste liner

shipped to US Ecology did not exceed 0.5 percent of the total waste volume subjected the

disposal facility to the possibility of improper handling of the waste. Using Inspection

Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination

Process, dated February 12, 2008, the inspectors determined the violation was of very low

safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was

no breach of the package during transit, (3) there were no Certificate of Compliance issues,

and (4) the low level burial ground nonconformance did not involve a 10 CFR 61.55 waste

under-classification. The inspectors determined that the finding has a design margin cross-

cutting aspect in the area of human performance, because the licensee failed to operate and

maintain the radioactive waste dewatering system within the vendor design margins when

changes were made to the operating procedures [H.6]. (Section 2RS8)

-5-

PLANT STATUS

The plant began the inspection period at approximately 65 percent power while troubleshooting

a non-safety feedwater valve. On July 23, 2015, the plant returned to 100 percent power. On

July 24, 2015, the plant experienced a loss of the B recirculation pump and power was reduced

to approximately 34 percent. Following repair to a non-safety cooling system supporting the

recirculation pump, the plant returned to 100 percent power on July 26, 2015. The plant

remained at 100 percent power for the remainder of the inspection period.

REPORT DETAILS

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection (71111.01)

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On July 22, 2015, the inspectors completed an inspection of the stations readiness for

seasonal extreme weather conditions. The inspectors reviewed the licensees adverse

weather procedures for seasonal high temperatures and evaluated the licensees

implementation of these procedures. The inspectors verified that prior to the onset of

hot weather, the licensee had corrected weather-related equipment deficiencies

identified during the previous season.

The inspectors selected three risk-significant systems that were required to be protected

from seasonal high temperatures:

• emergency diesel generators including support ventilation systems

• standby service water system

• high pressure core spray system

The inspectors reviewed the licensees procedures and design information to ensure the

systems would remain functional when challenged by adverse weather. The inspectors

verified that operator actions described in the licensees procedures were adequate to

maintain readiness of these systems. The inspectors walked down portions of these

systems to verify the physical condition of the adverse weather protection features.

These activities constituted one sample of readiness for seasonal adverse weather, as

defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

-6-

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On August 20, 2015, the inspectors completed an inspection of the stations readiness

for impending adverse weather conditions involving high winds. The inspectors

reviewed plant design features, the licensees procedures to respond to tornadoes and

high winds, and the licensees potential implementation of these procedures. The

inspectors evaluated operator staffing and accessibility of controls and indications for

those systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather

conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment (71111.04)

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant

systems:

• July 2, 2015, control room emergency chillers

• July 20, 2015, seismic instrumentation

• July 28, 2015, standby liquid control system

• September 14, 2015, standby gas treatment system

The inspectors reviewed the licensees procedures and system design information to

determine the correct lineup for the systems. They visually verified that critical portions

of the systems were correctly aligned for the existing plant configuration.

These activities constituted four partial system walk-down samples as defined in

Inspection Procedure 71111.04.

b. Findings

.1 Failure to Maintain Seismic Instrumentation Functional to Alert Plant Operators of

Ground Motions Exceeding the Operating Basis Earthquake

Introduction. The inspectors identified a Green finding associated with the licensees

failure to maintain seismic instrumentation functional as required by Licensee Controlled

Specification (LCS) 1.3.7.2, Seismic Monitoring Instrumentation. Specifically, because

of inadequate calibration procedures, several as-left setpoints for the seismic response

-7-

spectrum recorders indicating lights were non-conservative relative to their function to

alert operators of ground motion exceeding the operating basis earthquake.

Description. On July 20, 2015, the inspectors reviewed the design and calibration

settings for the Columbia Generating Station seismic triaxial response spectrum

recorders, designated SEIS-RSRT-1/1, 1/2 and 1/3. The seismic RSRTs consist of three

units, two horizontal and one vertical, each containing twelve frequency sensitive reeds

used to passively record earthquake ground motions. The RSRTs have a secondary

function to provide visual warnings to operators of exceedances of pre-determined

ground acceleration limits. The RSRTs include red lights to indicate that operating basis

earthquake (OBE) ground motions have been exceeded at certain frequencies.

Licensee Control Specification 1.3.7.2 requires that the seismic instrumentation,

including the triaxial response spectra recorders, remain functional to ensure the

capability to promptly determine the magnitude of a seismic event and initiate evaluation

of the seismic response features important to safety. In particular, the RSRTs red

indicating lights are described in Columbia Generating Station FSAR, Section 3.7.4.4, as

equipment used to alert plant operators that a shutdown is required. Title 10 CFR Part 100, Appendix A, Seismic and Geologic Siting Criteria for Nuclear Power Plants,

requires a plant shutdown if vibratory ground motion exceeding the OBE occurs. The

OBE is defined as the earthquake which produces the vibratory ground motion where

features of the nuclear power plant necessary for continued operation without undue risk

to the health and safety of the public are designed to remain functional.

The inspectors reviewed calculation CE-02-90-21, Setpoints for Response Spectrum

Indicating Lights, Revision 0, used to establish the ground acceleration levels where the

RSRT red indicating lights illuminate. The calculation determined target acceleration

values for the RSRT red indicating lights based on the most conservative OBE seismic

response spectra for the reactor building base mat. This setpoint methodology was

consistent with Regulatory Guide 1.12, Nuclear Power Plant Instrumentation for

Earthquakes, Revision 1, and American Nuclear Society ANS Standard 2.2,

Earthquake Instrumentation Criteria for Nuclear Power Plants, 1978. This regulatory

guidance provided acceptable methods for meeting the seismic instrumentation

requirements in 10 CFR Part 100, Appendix A and recommended a response spectrum

recorder with setpoints established at OBE ground motions.

The inspectors compared the setpoints established in calculation CE-02-90-21 to the

setpoints found in calibration implementing procedure ISP-SEIS-X304, Seismic System

Reactor Building Foundation Triaxial Response - Spectrum Recorder - CC, Revision 1.

Instrument Setpoint Change Request 979, dated April 30, 1990, established allowable

setpoints and included an upper and lower tolerance of approximately 5-10 percent from

the nominal setpoints established in calculation CE-02-90-21. The inspectors compared

the setpoints against the design basis earthquake and concluded that since the nominal

setpoint exactly matched the OBE ground motion values, the upper tolerance would, in

all cases, result in setpoints that exceed the OBE seismic ground motion response

spectra at the reactor building base mat.

The inspector reviewed the as-left setpoints for SEIS-RSRT-1/1, 1/2 and 1/3 and

identified 12 of 36 setpoints that exceeded the nominal target accelerations established

in calculation CE-02-90-21, resulting in red indicating lights that would not illuminate until

after OBE seismic ground motions were exceeded. The inspectors concluded that these

as-left setpoints were non-conservative relative to their LCS required function to alert

-8-

plant operators of the need for a plant shutdown as required by 10 CFR 100 and the

Columbia Generating Station FSAR.

On August 3, 2015, plant operators declared SEIS-RSRT-1/1, 1/2 and 1/3 non-functional

due to non-conservative setpoints for the systems red indicating lights and entered LCS

1.3.7.2, Condition A. During the period that SEIS-RSRT-1/1, 1/2 and 1/3 were non-

functional, the passive features of the seismic monitoring system were still available for

earthquake evaluation. On August 10, 2015, the licensee established new setpoints for

SEIS-RSRT-1/1, 1/2 and 1/3 using OBE ground motions as the upper tolerance. On

August 18, 2015, the licensee completed a calibration using the revised setpoints and

exited LCS 1.3.7.2, Condition A. The licensee entered this issue into their corrective

action program as Action Request 333996.

Analysis. The failure to maintain seismic instruments functional to provide indications of

exceeding the OBE seismic ground motion response spectra was a performance

deficiency. The performance deficiency was more than minor because it affected the

configuration control attribute of the Mitigating Systems Cornerstone objective and

adversely affected the cornerstone objective to ensure the availability, reliability, and

capability of systems that respond to initiating events to prevent undesirable

consequences. Specifically, the performance deficiency resulted in seismic instrument

calibrations that were non-conservative relative to their function to alert plant operators

that a shutdown is required. NRC regulations require a plant shutdown since systems

necessary for continued operation without undue risk to the health and safety of the

public are not designed to remain functional, in all cases, following an OBE. The

inspector performed the initial significance determination using NRC Inspection Manual

Chapter 0609, Appendix A, Exhibit 2, Mitigating Systems Screening Questions. The

inspectors determined that the finding was of very low safety significance because

(1) the finding was not a deficiency affecting the design or qualification of a mitigating

system; (2) the finding did not represent a loss of system and/or function; (3) the finding

did not represent an actual loss of function of a single train for greater than its technical

specification allowed outage time; and (4) the finding does not represent an actual loss

of function of one or more non-technical specification trains of equipment designated as

high safety-significant in accordance with the licensees maintenance rule program for

greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Additionally, the finding did not involve the loss or degradation of

equipment or function specifically designed to mitigate a seismic, flooding, or severe

weather initiating event. The finding does not have a cross-cutting aspect since the

configuration control error is associated with an instrument setpoint change request from

1990 and therefore not reflective of current licensee performance.

Enforcement. Enforcement action does not apply because the performance deficiency

did not involve a violation of regulatory requirements. The finding is of very low safety

significance and the issue was entered into the licensee's corrective action program as

Action Request 333996. (FIN 05000397/2015003-01, Failure to Maintain Seismic

Instrumentation Functional to Alert Plant Operators of Ground Motions Exceeding the

Operating Basis Earthquake)

.2 Non-Conservative Shutdown Criteria in Earthquake Abnormal Procedure

Introduction. The inspectors identified a Green, non-cited violation of Technical

Specification 5.4.1.a, Procedures, for the failure to maintain an adequate abnormal

procedure for earthquakes. Specifically, the licensee failed to establish appropriate

-9-

shutdown criteria for earthquakes that exhibit ground motion exceeding the OBE.

Description. On July 20, 2015, the inspectors performed a review of the Columbia

Generating Station seismic instrumentation and monitoring (SEIS) system. The SEIS

system, described in the Final Safety Analysis Report, Section 3.7.4, Seismic

Instrumentation, consists of multiple passive and active subsystems used to record

earthquake ground motion and to alert plant operators that design response spectra

have been exceeded. One of those subsystems are the triaxial response-spectrum

recorders used for comparison of measured and predicted earthquake responses. Final

Safety Analysis Report, Section 3.7.4.4 provides guidance that if an earthquake is felt in

the control room and the spectra experienced at the foundation of the reactor building

exceeds the OBE acceleration levels as indicated on two or more response spectra

indicating lights, the plant will be shut down pending permission to resume operations.

The shutdown criteria in abnormal procedure ABN-Earthquake, Revisions 0-13,

reflected the shutdown criteria found in FSAR Section 3.7.4.4.

The inspectors questioned the need for two or more response spectra indicating lights to

indicate that operating basis earthquake acceleration levels were exceeded prior to

initiating a plant shutdown. The inspectors reviewed 10 CFR Part 100, Appendix A,

which states, in part, that if vibratory ground motion exceeding that of the OBE occurs,

shutdown of the nuclear power plant will be required. The inspectors determined that

the licensees shutdown criteria in Final Safety Analysis Report, Section 3.7.4.4 and

incorporated into abnormal procedure ABN-Earthquake was contrary to 10 CFR Part 100, Appendix A. Specifically, the licensees shutdown criteria would allow for

continued operations if ground motion at a single frequency exceeded the design

response spectrum. The inspectors reviewed historical licensing basis for Columbia

Generating Station and found that FSAR Amendment 33, in effect when the full power

operating license was issued for the station, provided the following:

If the Instrumentation shows that the peak acceleration or the response spectra

experienced at the foundation of the reactor building exceeds the operating basis

earthquake acceleration levels or response spectra, the plant will be shut down

pending permission to resume operations.

The inspector discovered that the licensee changed FSAR Section 3.7.4.4 under

licensing document change notice LDCN 96-079, dated December 12, 1996. This

LDCNs purpose was to strike a balance between ensuring that actions are not taken on

a spurious signal and taking conservative actions following an earthquake. The

inspectors agreed that shutdown of the plant due to a spurious signal was not desirable

but that in the case of a single, valid indication that the OBE design response spectra

was exceeded, shutdown of the nuclear power plant was required. The inspectors

determined that the change implemented in LDCN 96-079 resulted in a non-conservative

shutdown criteria compared to the regulatory requirements in 10 CFR Part 100,

Appendix A.

In response to this issue, the licensee initiated corrective actions to change abnormal

procedure ABN-Earthquake to provide a shutdown criteria consistent with the original

licensing basis of the facility. The licensee entered this issue into their corrective action

program as AR 336875.

- 10 -

Analysis. The failure to establish appropriate shutdown criteria in abnormal procedures

for earthquakes was a performance deficiency. The performance deficiency was more

than minor because it affected the procedural adequacy attribute of the Mitigating

Systems Cornerstone objective and adversely affected the cornerstone objective to

ensure the availability, reliability, and capability of systems that respond to initiating

events to prevent undesirable consequences. Specifically, the performance deficiency

resulted in shutdown criteria that would allow for continued operations following events

where ground motion at a single frequency exceeded the design response spectra.

NRC regulations require a plant shutdown since systems necessary for continued

operation without undue risk to the health and safety of the public are not designed to

remain functional, in all cases, following an OBE. The inspector performed the initial

significance determination using NRC Inspection Manual Chapter 0609, Appendix A,

Exhibit 2, Mitigating Systems Screening Questions. The inspectors determined that

the finding was of very low safety significance because (1) the finding was not a

deficiency affecting the design or qualification of a mitigating system; (2) the finding did

not represent a loss of system and/or function; (3) the finding did not represent an actual

loss of function of a single train for greater than its technical specification allowed outage

time; and (4) the finding does not represent an actual loss of function of one or more

non-technical specification trains of equipment designated as high safety-significant in

accordance with the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Additionally, the finding did not involve the loss or degradation of equipment or function

specifically designed to mitigate a seismic, flooding, or severe weather initiating event.

The finding does not have a cross-cutting aspect since the procedure error is associated

with a 1996 change to the licensing basis and therefore not reflective of current licensee

performance.

Enforcement. Technical Specification 5.4.1.a, Procedures, requires, in part, that written

procedures be established, implemented, and maintained as recommended in

Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Paragraph 6.w.

of Regulatory Guide 1.33, Appendix A, requires specific procedures for acts of Nature

(e.g., tornado, flood, dam failure, earthquakes). Licensee Procedure ABN-Earthquake,

Earthquake, Revision 0-13, is a procedure, required by Paragraph 6.w. of Regulatory

Guide 1.33, Appendix A for earthquakes. Contrary to the above, from August 8, 2005 to

the present, the licensee failed to maintain an adequate procedure as recommended in

Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 6.w. Specifically, the

shutdown criteria specified in Step 4.4 of procedure ABN-Earthquake, Revisions 0-13

was non-conservative relative to the shutdown criteria in 10 CFR 100, Appendix A

because it would allow for continued operations if ground motion at a single frequency

exceeded the design response spectrum. The licensee initiated corrective actions to

change abnormal procedure ABN-Earthquake to provide a shutdown criteria consistent

with the original licensing basis of the facility. Because this finding is of very low safety

significance and entered into the licensees corrective action program as Action Request

336875, the violation is being treated as a non-cited violation consistent with Section

2.3.2.a of the NRC Enforcement Policy. (NCV 05000397/2015003-02,

Non-Conservative Shutdown Criteria in Earthquake Abnormal Procedure)

.3 Failure to Provide Design Control Measures for Control Room Emergency Chillers

Introduction. The inspectors identified a Green, non-cited violation of 10 CFR 50,

Appendix B, Criterion III, Design Control, for the licensees failure to verify the

adequacy of the design of the control room HVAC system. Specifically, the licensee

- 11 -

failed to demonstrate the ability of control room HVAC design to maintain the

temperatures in the main control room below habitability and environmental qualification

limits, for the duration of all accident scenarios.

Description. On July 2, 2015, the inspectors performed a review of the control room

HVAC system with a focus on the control room emergency chillers. The Final Safety

Analysis Report, Section 9.4.1.1, Design Basis states, in part, that the design of the

control room HVAC system is such that in an emergency condition, the control room

temperature will be maintained within the habitability limit (85°F) by the control room

chilled water. Service water can maintain the control room temperature limit of 85°F

during colder weather. Service water will maintain the control room within the

environmental qualification temperature limit for control room equipment (104°F).

The inspectors noted that the vendor manuals for the control room emergency chillers

described an automatic trip feature that required local resetting. Specifically, the

manufacturer states the following in the Normal Operating Sequence section of the

manual:

Shutdown where the unit cannot automatically restartShutdown on a power

failure produces the same results as for a safety shutdown except relay 14R is

de-energizedIt is necessary to depress the STOP-RESET button to energize

relay 14R when power is restored after interruption.

The inspectors reviewed relevant electrical diagrams and confirmed that operation of the

control room emergency chillers required a local reset of relay 14R following a loss of

power. The alignment of the control room HVAC system is such that the division 1 air

handling unit, WMA-AH-51A, is aligned to standby service water and the division 2 air

handling unit, WMA-AH-51B, is aligned to chill water. Because of the design feature

involving the relay 14R and the alignment of the air-handling units, the inspectors

identified that:

1) Following any event that resulted in a loss of offsite power with a single-failure of the

Division 1 emergency diesel generator, the control room would not receive cooling

via WMA-AH-51B, the only operable air handling unit, until the local chiller reset

pushbutton was depressed. The control room would remain without cooling until this

manual reset was accomplished since relay 14R would be de-energized.

2) Following certain events involving a loss of offsite power with a single-failure of the

Division 2 emergency diesel generator, the control room would experience reduced,

and in some instances, no external cooling. In particular, when ambient conditions

would not allow service water alone to maintain the control room below the 85°F

habitability limit, operators would be prompted to secure standby service water

cooling to WMA-AH-51A and realign cooling from the control room emergency

chillers system. The inspectors noted that during the shift between standby service

water and control room emergency chill water, there would be a brief period when

the control room would receive no external cooling.

For each of the above scenarios, temperatures in the control room could exceed 85°F or

104°F due to times necessary for system realignment or local resetting manual actions.

At the time of the inspection, procedure OI-69, Time Critical Operator Actions,

Revision 5, did not identify any required manual actions associated with local reset or

- 12 -

realignment of the control room HVAC system. This procedure defines a time critical

action as a manual action, or series of actions that must be completed within a specified

time to meet the plant-licensing basis.

The inspectors reviewed calculation ME-02-92-43, Room Temperature Calculation for

DG Building, Reactor Building, Radwaste Building, and Service Water, Revision 10, and

noted that this calculation covers the control room air-handling units but only considers

steady-state conditions for heat exchanger performance. There is no discussion in

ME-02-92-43 for transient scenarios where the control room would receive no external

cooling, such as those involving local resetting of control room emergency chillers or

during required shifts between standby service water and control room emergency chill

water.

The inspectors requested a design analysis that demonstrated the ability of control room

HVAC design to maintain the temperatures in the main control room below habitability

and environmental qualification limits during these transient situations. The licensee

was unable to locate a design verification that demonstrated the ability of the control

room HVAC system during transient scenarios following a loss of power and could not

determine the peak control room temperature nor the impact to habitability or equipment

qualification in these scenarios.

The inspectors reviewed previous inspection reports for the station and noted one

related finding: NRC-identified NCV 05000397/2013002-04, Failure to Obtain NRC

Approval for Changes to Control Room HVAC Requirements. This NCV identified an

incorrect value for the control room temperature limit and resulted in the current value as

found in the licensees design basis. The inspectors determined that the extent of

condition review from this 2013 finding did not adequately consider the effects of

lowering a design habitability temperature for the control room from 104°F to 85°F,

necessitating the need for the control room emergency chillers. Specifically, when

evaluating the correct habitability limit of 85°F, the licensee only considered the steady

state cooling needs of the control room and not the transient effects experienced

because of the chiller design.

In response to the NRCs conclusions, the licensee initiated Action Request 332565 to

document the concern, issued night order 1662 to communicate the issue, aligned both

control room air handling units to their respective chillers, created a quick card

procedure to perform the chiller reset actions, and validated the quick card actions could

be accomplished within 10 minutes. Additionally, the licensee determined that operators

could restore the chillers during accident conditions within 90 minutes to prevent

temperatures from exceeding equipment operability limits.

Analysis. The failure to provide design control measures to verify the adequacy of the

design of the control room emergency chillers was a performance deficiency. The

performance deficiency was more than minor because it adversely affected the design

control attribute of the Mitigating Systems Cornerstone objective to ensure the

availability, reliability, and capability of systems that respond to initiating events to

prevent undesirable consequences. Specifically, the licensee failed to demonstrate the

ability of control room HVAC design to maintain the temperatures in the main control

room below habitability and environmental qualification limits, for the duration of all

accident scenarios. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2,

Mitigating Systems Screening Questions, the inspectors determined the finding was of

- 13 -

very low safety significance because (1) the finding was not a deficiency affecting the

design or qualification of a mitigating system; (2) the finding did not represent a loss of

system and/or function; (3) the finding did not represent an actual loss of function of a

single train for greater than its technical specification allowed outage time; and (4) the

finding does not represent an actual loss of function of one or more non-technical

specification trains of equipment designated as high safety-significant in accordance with

the licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This finding had a

cross-cutting aspect in the area of problem identification and resolution, evaluation, in

that the licensee did not thoroughly evaluate issues to ensure that resolutions address

causes and extent of conditions commensurate with their safety significance.

Specifically, the licensee did not thoroughly evaluate the extent of condition from

NRC-identified NCV 05000397/2013002-04, Failure to Obtain NRC Approval for

Changes to Control Room HVAC Requirements, for the effect of this change on other

station calculations [P.2].

Enforcement. Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, requires,

in part, that design control measures shall provide for verifying or checking the adequacy

of design, such as by the performance of design reviews, by the use of alternate or

simplified calculational methods, or by the performance of a suitable testing program.

Final Safety Analysis Report, Section 9.4.1.1, Design Basis, established the design of

the control room HVAC system and specified, in part, that during emergency conditions,

the control room temperature will be maintained within the habitability limit (85°F) by the

control room chilled water. Service water can maintain the control room temperature

limit of 85°F during colder weather. Service water will maintain the control room within

the environmental qualification temperature limit for control room equipment (104°F).

Contrary to the above, prior to July 2, 2015, the licensee failed to implement design

control measures for verifying or checking the adequacy of design, such as by the

performance of design reviews, by the use of alternate or simplified calculational

methods, or by the performance of a suitable testing program. Specifically, the licensee

failed to verify the adequacy of the design of the control room emergency chillers

involving loss of offsite power scenarios that result in transient losses of control room

cooling such that the design basis, established in Final Safety Analysis Report, Section

9.4.1.1 was ensured.

The licensee initiated Action Request 332565 to document the concern, issued night

order 1662 to communicate the issue, aligned both control room air handling units to

their respective chillers, created a quick card procedure to perform the chiller reset

actions, and validated the quick card actions could be accomplished within 10 minutes.

Because the finding is of very low safety significance (Green) and has been entered into

the licensees corrective action program, this violation is being treated as a non-cited

violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000397/2015003-03, Failure to Provide Design Control Measures for Control Room

Emergency Chillers)

- 14 -

1R05 Fire Protection (71111.05)

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensees fire protection program for operational status

and material condition. The inspectors focused their inspection on four plant areas

important to safety:

• July 1, 2015, Fire Areas RC-4, 5, 6, 7, 8, and 9 and RC-14, radioactive waste

building 467 elevation vital island

• July 14, 2015, Fire Area R-8, low pressure core spray pump room

• July 15, 2015, Fire Area RC-11, 12 and 13, radioactive waste building 525

elevation

• August 13, 2015, Fire Area R-5, residual heat removal train A pump room

For each area, the inspectors evaluated the fire plan against defined hazards and

defense-in-depth features in the licensees fire protection program. The inspectors

evaluated control of transient combustibles and ignition sources, fire detection and

suppression systems, manual firefighting equipment and capability, passive fire

protection features, and compensatory measures for degraded conditions.

These activities constituted four quarterly inspection samples, as defined in Inspection

Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures (71111.06)

a. Inspection Scope

On July 21, 2015, the inspectors completed an inspection of underground bunkers

susceptible to flooding. The inspectors selected one underground vault, electrical

manhole E-MH-08, that contained risk-significant or multiple-train cables whose failure

could disable risk-significant equipment.

The inspectors observed the material condition of the cables and splices contained in

the bunkers vaults and looked for evidence of cable degradation due to water intrusion.

The inspectors verified that the cables and vaults met design requirements.

These activities constitute completion of one bunker/manhole sample, as defined in

Inspection Procedure 71111.06.

- 15 -

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

(71111.11)

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On July 29, 2015, the inspectors observed an evaluated simulator scenario performed

by an operating crew. The inspectors assessed the performance of the operators and

the evaluators critique of their performance. The inspectors also assessed the modeling

and performance of the simulator during the requalification activities.

These activities constitute completion of one quarterly licensed operator requalification

program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On August 5, 2015, the inspectors observed the performance of on-shift licensed

operators in the plants main control room. At the time of the observations, the plant was

in a period of heightened risk due to an unplanned orange risk window for Bonneville

Power Administrations emergent work on the 230 kV switchyard. The inspectors

observed the operators performance of the following activities:

• Leak repair on the digital electro-hydraulic system under WO 02086051,

including the pre-job brief

In addition, the inspectors assessed the operators adherence to plant procedures,

including procedure PPM 1.3.1, Operating Policy, Programs, and Practices, Revision

119 and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance

sample, as defined in Inspection Procedure 71111.11.

b. Findings

Introduction. The inspectors identified a Green, non-cited violation of Technical

Specification 5.4.1.a, Procedures, for the licensees failure to ensure operators could

perform time-critical steps for fire events. Specifically, the licensee failed to implement

written procedures to ensure that Category 2 personnel, needed for post-fire safe

shutdown, can complete required actions within 10 minutes.

- 16 -

Description. During a log review, the inspectors identified that an equipment operator

(OPS3) left the protected area (PA) to compile equipment logs on July 4, 2015, at 8:57

AM and again at 4:37 PM. Licensee procedure PPM 1.3.1, Operating Policy, Programs,

and Practices, Revision 119, classifies watch positions as either Category 1 or

Category 2. Category 1 personnel include the shift technical advisor (STA) and

emergency action level notifier. Category 2 personnel include the shift manager (SM),

all three reactor operators, the control room supervisor (CRS), and the OPS2 and OPS3

equipment operator positions. Procedure PPM 1.3.1 states that while Category 1

personnel may leave the PA with a risk evaluation and permission of the shift manager,

Category 2 personnel should not leave the protected area unless an emergent condition

is jeopardizing the plant and they respond to an event that requires action within 10

minutes. The OPS3 equipment operator is a Category 2 watchstander because in the

event of a control room fire, they must trip the condensate and condensate booster

pumps within 10 minutes. These actions are proceduralized in ABN-CR-EVAC, Control

Room Evacuation and Remote Cooldown, Revision 33.

The inspectors questioned the ability of OPS3 to move from outside the PA to their

required station in a timely manner. The inspectors noted that the licensee performed a

timed walkthrough of post-fire safe-shutdown actions for OPS3 for a similar issue in

2014. Specifically, the evaluation for NRC-identified NCV 05000397/2014003-02,

Failure to Implement Procedures That Ensure Operators Could Perform Time Critical

Steps for Fire Events concluded that OPS3 was not able to complete certain post-fire

safe-shutdown actions within 10 minutes when initially located outside the PA. Instead,

the equipment operator completed the required actions within 11 minutes and 33

seconds. The inspectors determined that this previous walkthrough from 2014 is

representative of the issue identified on July 4, 2015 and no additional timed

walkthrough was required.

The inspectors concluded that by allowing Category 2 personnel to leave the PA, the

licensee had not preserved the assumptions of available personnel in ABN-CR-EVAC to

reach safe-shutdown conditions for a control room fire. Therefore, the licensee was not

implementing written procedures for plant fires and responsibilities for safe operation as

required by Technical Specification 5.4.1.a through Appendix A of Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2.

In response to this conclusion, the licensee initiated AR 332747 to document the inability

to meet the post-fire safe-shutdown actions in accordance with procedure PPM 1.3.1.

Additionally, the licensee issued Night Order 1655, reminding all operating crews of the

requirements of procedure PPM 1.3.1 for leaving the PA. Through interviews, the

licensee determined that the equipment operator discussed the need to leave the PA

with the STA. Neither individual, however, discussed the situation with CRS, SM, or

reviewed the relevant PPM 1.3.1 procedure.

Analysis. The failure to implement written procedures to ensure that Category 2

personnel can complete certain post-fire safe-shutdown actions within 10 minutes was a

performance deficiency. This performance deficiency was more than minor because it

was associated with the protection against external factors attribute of the Mitigating

System Cornerstone and affected the cornerstones objective to ensure the availability,

reliability, and capability of systems that respond to initiating events to prevent

undesirable consequences. Specifically, by allowing Category 2 personnel to leave the

protected area, the licensee had not preserved the assumptions of available personnel

- 17 -

in ABN-CR-EVAC to reach safe-shutdown conditions for a control room fire. The

inspectors screened the finding in accordance with NRC Manual Chapter IMC 0609,

Attachment 4, Initial Characterization of Findings. In table 3, the inspectors answered

yes to question E.2 because the finding affects the ability to reach and maintain safe

shutdown conditions in case of a fire. Therefore, to assess this finding, a senior reactor

analyst used NRC IMC 0609, Appendix F, Fire Protection Significance Determination,

dated September 20, 2013. The analyst noted that the degradation rating examples in

Attachment 2 of that appendix were not well suited for this finding. Therefore, the

analyst used the generic guidance from NRC IMC 0308, Attachment 3, Appendix F,

Technical Basis Fire Protection Significance Determination Process (Supplemental

Guidance for Implementing IMC 0609, Appendix F) At Power Operations, dated

February 28, 2005. This guidance stated, in part:

the definition of low degradation implies that the performance and/or reliability

of the fire protection feature is not substantially impacted by the noted

degradation finding. Hence, the feature would be given essentially full credit in

the PRA-based analysis. In this case, the risk change is essentially zero, and the

finding should be screened to Green.

For this finding, procedure ABN-CR-EVAC directed operator OPS3 to trip the

condensate and condensate booster pumps within 10 minutes, but due to this finding,

that action could be delayed to the 11.5 minute point. The subject action was intended

to prevent taking the plant to a solid (completely filled) condition. However, the analyst

noted that the failure to take this action would not increase the core damage probability

(overfilling events at boiling water reactors soon after shutdown should not drive core

damage and are not included in the probabilistic risk assessment model). Instead, this

action is a desired step that was intended to establish positive control over reactor

vessel pressure and level. In addition, the exposure period for this finding was very

short (less than one day). Since the failure to perform this action within 10 minutes

would not adversely affect a quantitative assessment, this finding was of very low safety

significance (Green). This finding has a cross-cutting aspect in the area of Human

Performance, Teamwork, because the licensee failed to communicate and to coordinate

their activities within and across organizational boundaries to ensure nuclear safety is

maintained. Specifically, the equipment operator spoke with the STA about the need to

exit the PA at the morning turnover meeting but neither individual spoke with the CRS.

Communication was ineffective in that the equipment operator believed permission was

granted and proceeded to exit the PA [H.4].

Enforcement. Technical Specification 5.4.1.a, Procedures requires, in part, that written

procedures shall be established, implemented, and maintained for activities described in

Appendix A of the Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 1.b requires administrative procedures for authorities and

responsibilities for safe operation and shutdown. Licensee procedure PPM 1.3.1,

Operating Policy, Programs, and Practices, Revision 119, a procedure required by

Section 1.b of Regulatory Guide 1.33, Appendix A, establishes authorities and

responsibilities for safe operation and shutdown, and states that Category 2 personnel

should not leave the protected area unless an emergent condition is jeopardizing the

plant and they respond to an event that requires action within 10 minutes. Contrary to

this requirement, on July 4, 2015, Category 2 personnel (i.e., an equipment operator) left

the protected area when no emergent condition jeopardizing the plant existed and

therefore was unable to respond to an event that requires action within 10 minutes.

- 18 -

Specifically, the operator would not be able to complete certain time-critical operator

actions associated with fire events as required by procedure ABN-CR-EVAC, Control

Room Evacuation and Remote Cooldown, Revision 33.

The licensee initiated Action Request 332747 to document the non-compliance with

PPM 1.3.1. Additionally, the licensee issued Night Order 1655 reminding all operating

crews of the requirements of PPM 1.3.1 for leaving the Protected Area. Because this

violation was of very low safety significance and was entered into the licensees

corrective action program, this violation is being treated as a non-cited violation,

consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000397/2015003-04,

Failure to Implement Procedures to Ensure Availability of Safe Shutdown Personnel)

1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-

related structures, systems, and components (SSCs):

• July 10, 2015, system review of control room emergency chillers including

maintenance history of system rupture discs

• September 10, 2015, main steam level indicating switches including maintenance

history involving internal binding failures documented in AR 332078

The inspectors reviewed the extent of condition of possible common cause SSC failures

and evaluated the adequacy of the licensees corrective actions. The inspectors

reviewed the licensees work practices to evaluate whether these may have played a

role in the degradation of the SSCs. The inspectors assessed the licensees

characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance

Rule), and verified that the licensee was appropriately tracking degraded performance

and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as

defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope

The inspectors reviewed two risk assessments performed by the licensee prior to

changes in plant configuration and the risk management actions taken by the licensee in

response to elevated risk:

• August 20, 2015, planned yellow risk for a diesel generator 2 monthly

surveillance under Work Order 02068579

- 19 -

• September 15, 2015, planned yellow risk for a reactor core isolation cooling

system work window under Work Order 02078715

The inspectors verified that these risk assessments were performed timely and in

accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant

procedures. The inspectors reviewed the accuracy and completeness of the licensees

risk assessments and verified that the licensee implemented appropriate risk

management actions based on the result of the assessments.

Additionally, on September 28, 2015, the inspectors observed the operators response to

emergent work activities that resulted in unplanned unavailability of emergency diesel

generator 2. The inspectors verified that the licensee took precautions to minimize the

impact of the work activities on unaffected SSCs.

These activities constitute completion of three maintenance risk assessments and

emergent work control inspection samples, as defined in Inspection Procedure 71111.13.

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments (71111.15)

a. Inspection Scope

The inspectors reviewed four operability determinations that the licensee performed for

degraded or nonconforming SSCs:

• July 1, 2015, AR 332078, documenting reactor vessel water level indicating

switches MS-LIS-24A and C indicating abnormally high

• July 1, 2015, AR 332326, documenting concerns related to residual heat removal

system operability during venting operations

• July 22, 2015, AR 333334, documenting a slow opening time for main steam

isolation valve MS-V-22D

• August 13, 2015, AR 334459, documenting concerns related to required manual

actions for the control room HVAC system emergency chillers

The inspectors reviewed the timeliness and technical adequacy of the licensees

evaluations. Where the licensee determined the degraded SSC to be operable, the

inspectors verified that the licensees compensatory measures were appropriate to

provide reasonable assurance of operability. The inspectors verified that the licensee

had considered the effect of other degraded conditions on the operability of the

degraded SSC.

These activities constitute completion of four operability and functionality review samples

as defined in Inspection Procedure 71111.15.

- 20 -

b. Findings

No findings were identified.

1R18 Plant Modifications (71111.18)

a. Inspection Scope

On July 1, 2015, the inspectors reviewed a temporary modification of reactor feedwater

valve RFW-V-102A under Engineering Change EC14111. The inspectors verified that

the licensee had installed this temporary modification in accordance with technically

adequate design documents. The inspectors verified that this modification did not

adversely impact the operability or availability of affected SSCs. The inspectors

reviewed design documentation and plant procedures affected by the modification to

verify the licensee maintained configuration control.

These activities constitute completion of one sample of temporary modifications, as

defined in Inspection Procedure 71111.18.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope

The inspectors reviewed four post-maintenance testing activities that affected risk-

significant SSCs:

• August 5, 2015, post-maintenance test for service water temperature control

valve SW-TCV-11A, following maintenance under WO 02075767

• August 26, 2015, post-maintenance test for the Division 3 diesel mixed air

system, following maintenance under WO 02066727

• September 16, 2015, post-maintenance test for reactor core isolation cooling

system, following maintenance under Work Order 02078715

• September 28, 2015, post-maintenance test for the Division 2 diesel generator,

following replacement of shutdown relays under Work Order 02002258

The inspectors reviewed licensing- and design-basis documents for the SSCs and the

maintenance and post-maintenance test procedures. The inspectors observed the

performance of the post-maintenance tests to verify that the licensee performed the tests

in accordance with approved procedures, satisfied the established acceptance criteria,

and restored the operability of the affected SSCs.

These activities constitute completion of four post-maintenance testing inspection

samples, as defined in Inspection Procedure 71111.19.

- 21 -

b. Findings

No findings were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors observed three risk-significant surveillance tests and reviewed test

results to verify that these tests adequately demonstrated that the SSCs were capable of

performing their safety functions:

Routine tests:

• August 6, 2015, procedure OSP-DO/IST-Q701, DO-P-1A Operability, Revision

14, including a surveillance for the diesel generator fuel oil transfer pump

In-service tests:

• September 8, 2015, procedure OSP-LPCS/IST-Q702, LPCS System Operability

Test, Revision 39

Reactor coolant system leak detection tests:

• September 16, 2015, procedure OSP-INST-H101, Shift and Daily Instrument

Checks Modes 1, 2, 3 Revision 85, including reactor coolant system leakage

calculation

The inspectors verified that these tests met technical specification requirements, that the

licensee performed the tests in accordance with their procedures, and that the results of

the test satisfied appropriate acceptance criteria. The inspectors verified that the

licensee restored the operability of the affected SSCs following testing.

These activities constitute completion of three surveillance testing inspection samples,

as defined in Inspection Procedure 71111.22.

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors observed an emergency preparedness drill on July 7, 2015, to verify the

adequacy and capability of the licensees assessment of drill performance. The

inspectors reviewed the drill scenario, observed the drill from the simulator, technical

support center, operations support center and emergency operations facility, and

attended the post-drill critique. The inspectors verified that the licensees emergency

classifications, off-site notifications, and protective action recommendations were

- 22 -

appropriate and timely. The inspectors verified that any emergency preparedness

weaknesses were appropriately identified by the licensee in the post-drill critique and

entered into the corrective action program for resolution.

These activities constitute completion of one emergency preparedness drill observation

sample, as defined in Inspection Procedure 71114.06.

b. Findings

No findings were identified.

2. RADIATION SAFETY

Cornerstones: Occupational Radiation Safety and Public Radiation Safety

2RS5 Radiation Monitoring Instrumentation (71124.05)

a. Inspection Scope

The inspectors evaluated the accuracy and operability of the radiation monitoring

equipment used by the licensee (1) to monitor areas, materials, and workers to ensure a

radiologically safe work environment, and (2) to detect and quantify radioactive process

streams and effluent releases. The inspectors interviewed licensee personnel, walked

down various portions of the plant, and reviewed licensee performance in the following

areas:

• Selected plant configurations and alignments of process, post-accident, and

effluent monitors with descriptions in the Final Safety Analysis Report and the

offsite dose calculation manual

• Selected instrumentation, including effluent monitoring instrument, portable

survey instruments, area radiation monitors, continuous air monitors, personnel

contamination monitors, portal monitors, and small article monitors to examine

their configurations and source checks

• Calibration and testing of process and effluent monitors, laboratory

instrumentation, whole body counters, post-accident monitoring instrumentation,

portal monitors, personnel contamination monitors, small article monitors,

portable survey instruments, area radiation monitors, electronic dosimetry, air

samplers, and continuous air monitors

• Audits, self-assessments, and corrective action documents related to radiation

monitoring instrumentation since the last inspection

These activities constitute completion of one sample of radiation monitoring instrumentation

as defined in Inspection Procedure 71124.05.

b. Findings

No findings were identified.

- 23 -

2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

a. Inspection Scope

The inspectors evaluated whether the licensee maintained gaseous and liquid effluent

processing systems and properly mitigated, monitored, and evaluated radiological

discharges with respect to public exposure. The inspectors verified that abnormal

radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors

are out-of-service, were controlled in accordance with the applicable regulatory

requirements and licensee procedures. The inspectors verified that the licensees

quality control program ensured radioactive effluent sampling and analysis adequately

quantified and evaluated discharges of radioactive materials. The inspectors verified the

adequacy of public dose projections resulting from radioactive effluent discharges. The

inspectors interviewed licensee personnel and reviewed or observed the following items:

• Radiological effluent release reports since the previous inspection and reports

related to the effluent program issued since the previous inspection

• Effluent program implementing procedures, including sampling, monitor setpoint

determinations and dose calculations

• Equipment configuration and flow paths of selected gaseous and liquid discharge

system components, filtered ventilation system material condition, and significant

changes to their effluent release points, if any, and associated 10 CFR 50.59

reviews

• Selected portions of the routine processing and discharge of radioactive gaseous

and liquid effluents (including sample collection and analysis)

• Controls used to ensure representative sampling and appropriate compensatory

sampling

• Results of the inter-laboratory comparison program

• Effluent stack flow rates

• Surveillance test results of technical specification-required ventilation effluent

discharge systems since the previous inspection

• Significant changes in reported dose values

• A selection of radioactive liquid and gaseous waste discharge permits

• Part 61 analyses and methods used to determine which isotopes are included in

the source term

• Offsite dose calculation manual changes

• Meteorological dispersion and deposition factors

- 24 -

• Latest land use census

• Records of abnormal gaseous or liquid tank discharges

• Groundwater monitoring results

• Changes to the licensees written program for identifying and controlling

contaminated spills/leaks to groundwater

• Identified leakage or spill events and entries made into 10 CFR 50.75(g) records,

if any, and associated evaluations of the extent of the contamination and the

radiological source term

• Offsite notifications, and reports of events associated with spills, leaks, and

groundwater monitoring results

• Audits, self-assessments, reports, and corrective action documents related to

radioactive gaseous and liquid effluent treatment since the last inspection

These activities constitute completion of one sample of radioactive gaseous and liquid

effluent treatment, as defined in Inspection Procedure 71124.06.

b. Findings

No findings were identified.

2RS7 Radiological Environmental Monitoring Program (71124.07)

a. Inspection Scope

The inspectors evaluated whether the licensees radiological environmental monitoring

program quantified the impact of radioactive effluent releases to the environment and

sufficiently validated the integrity of the radioactive gaseous and liquid effluent release

program. The inspectors verified that the radiological environmental monitoring program

was implemented consistent with the licensees technical specifications and offsite dose

calculation manual, and that the radioactive effluent release program met the design

objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensees

radiological environmental monitoring program monitored non-effluent exposure

pathways, was based on sound principles and assumptions, and validated that doses to

members of the public were within regulatory dose limits. The inspectors reviewed or

observed the following items:

• Annual environmental monitoring reports and offsite dose calculation manual

• Selected air sampling and dosimeter monitoring stations

• Collection and preparation of environmental samples

• Operability, calibration, and maintenance of meteorological instruments

- 25 -

• Selected events documented in the annual environmental monitoring report

which involved a missed sample, inoperable sampler, lost dosimeter, or

anomalous measurement

• Selected structures, systems, or components that may contain licensed material

and has a credible mechanism for licensed material to reach ground water

• Records required by 10 CFR 50.75(g)

• Significant changes made by the licensee to the offsite dose calculation manual

as the result of changes to the land census or sampler station modifications since

the last inspection

• Calibration and maintenance records for selected air samplers, composite water

samplers, and environmental sample radiation measurement instrumentation

• Inter-laboratory comparison program results

• Audits, self-assessments, reports, and corrective action documents related to the

radiological environmental monitoring program since the last inspection

These activities constitute completion of one sample of radiological environmental

monitoring program as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage,

and Transportation (71124.08)

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensees programs for processing,

handling, storage, and transportation of radioactive material. The inspectors interviewed

licensee personnel and reviewed the following items:

• The solid radioactive waste system description, process control program, and the

scope of the licensees audit program

• Control of radioactive waste storage areas including container labeling/marking

and monitoring containers for deformation or signs of waste decomposition

• Changes to the liquid and solid waste processing system configuration including

a review of waste processing equipment that is not operational or abandoned in

place

• Radio-chemical sample analysis results for radioactive waste streams and use of

scaling factors and calculations to account for difficult-to-measure radionuclides

- 26 -

• Processes for waste classification including use of scaling factors and

10 CFR Part 61 analysis

• Shipment packaging, surveying, labeling, marking, placarding, vehicle checking,

driver instructing, and preparation of the disposal manifest

• Audits, self-assessments, reports, and corrective action reports radioactive solid

waste processing, and radioactive material handling, storage, and transportation

performed since the last inspection

These activities constitute completion of one sample of radioactive solid waste

processing, and radioactive material handling, storage, and transportation as defined in

Inspection Procedure 71124.08.

b. Findings

Introduction. The inspectors reviewed a Green, self-revealing, non-cited violation of

Technical Specification 5.4.1.a, Procedures, for the licensees failure to follow their

Process Control Program as implemented by their solid radioactive waste system

procedures. The licensee shipped a radioactive shipment of condensate filter

demineralizer resin waste for disposal to US Ecology of Washington with free standing

liquid in excess of 0.5 percent of the total waste volume.

Description. On August 11, 2014, the licensee completed dewatering and drying of resin

for a condensate demineralizer filter waste liner (14-033-L). On October 9, 2014,

radioactive waste liner 14-033-L was shipped to US Ecology for disposal at their low

level radioactive waste burial site near Richland, Washington. The liner was part of

radioactive waste shipment #14-32 and manifested as a Class A Unstable waste form.

On October 23, 2014, liner 14-033-L was randomly selected by the burial site for

inspection to ensure compliance with the disposal sites license conditions. US Ecology

punctured the bottom of the liner and determined that the liner contained free standing

liquid, as evidenced by a slurry mix (150 ml) that drained from the puncture hole. On

October 27, 2014, US Ecology continued their inspection of liner 14-033-L by fully

opening the liner lid and sampling for additional free standing liquid. The inspection

results revealed that over 8.5 gallons of free standing liquid was contained within the

liner. This represented approximately 0.75 percent of the total waste volume (1132

gallons) and was in excess of the 0.5 percent free standing liquid requirement for

unstable waste form. US Ecology contacted the licensee and informed them of the

burial site noncompliance.

The licensee retrieved the packages (i.e., liners) contained in shipment #14-32 from US

Ecology. Each liner was then tested for free standing liquid content and additional water

was removed as necessary. This issue was entered into the licensees corrective action

program as Action Request 00316676, and an apparent cause evaluation was

performed.

The inspectors reviewed selected licensee, vendor, and burial site information related to

this issue and interviewed selected knowledgeable plant staff. The inspectors

determined that the licensee failed to maintain the appropriate operating procedures and

dewatering components for the resin drying and dewatering system used for the

condensate filter demineralizer waste liners. Specifically, in 1999 and 2012, changes

- 27 -

were made to the Process Control Program via modifications to the resin drying system

process. These modifications were different from the approved operations and

specifications under NRC-approved Topical Report, TP-02-P-A, Covering Nuclear

Packaging, Inc. Dewatering System, approved September 6, 1985. In 1999, the

specific change made was to open the valve to the lowest set of filter laterals in order to

allow the use of these filters throughout the dewatering process for the condensate filter

demineralizers. In 2011, following a condenser change-out, the carbon steel

components of the new condenser introduced iron oxide into the resin drying system.

This high iron oxide content coated the bottom filter laterals in the resin drying system

and caused discoloration of the resin water. In 2012, additional changes to the Process

Control Program instructed the resin drying system operators to declare the bottom filter

laterals as damaged if they saw a discoloration in the resin drying system viewing

window. These changes were not in accordance with vendor specifications.

The inspectors determined that the licensee performed an inadequate technical review

for the resin drying and dewatering system when changes were made to the Process

Control Program. Additionally, the inspectors reviewed the 10 CFR 50.59 screening,

dated July 6, 2010, and determined that the licensee performed an inadequate technical

review to assess potential adverse impacts of the condenser change-out on the plants

radioactive waste processing system. Consequently, the inspectors concluded that

between 1999 and 2013, the licensee failed to maintain the vendor procedures and

appropriate design margins for the resin drying system. This resulted in inadequate

dewatering of the resin for condensate filter demineralizers in liner 14-033-L.

Analysis. The failure to follow the Process Control Program, resulting in the inadequate

dewatering of radioactive waste liner contents, was a performance deficiency.

Inspectors determined that the performance deficiency was more than minor, because it

adversely affected the Public Radiation Safety cornerstone objective to ensure adequate

protection of public health and safety from exposure to radioactive materials released in

the public domain. Specifically, the failure to ensure that the free standing liquid in the

radioactive waste liner shipped to US Ecology did not exceed 0.5 percent of the total

waste volume subjected the disposal facility to the possibility of improper handling of the

waste. Using Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety

Significance Determination Process, dated February 12, 2008, the inspectors

determined the violation was of very low safety significance (Green) because:

(1) radiation limits were not exceeded, (2) there was no breach of the package during

transit, (3) there were no Certificate of Compliance issues, and (4) the low level burial

ground nonconformance did not involve a 10 CFR 61.55 waste under classification. The

inspectors determined that the finding has a design margin cross-cutting aspect in the

area of human performance, because the licensee failed to operate and maintain the

radioactive waste dewatering system within the vendor design margins when changes

were made to the operating procedures [H.6].

Enforcement. Technical Specification 5.4.1.a, Procedures, requires, in part, that

written procedures be established, implemented, and maintained for activities described

in Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 2,

Appendix A, dated February 1978. Regulatory Guide 1.33, Section 7.b.(2) requires

procedures for the Solid Waste System - Spent Resins and Filter Sludge Handling. The

licensees Process Control Program procedure, SWP-RMP-02, The Radioactive Waste

Process Control Program, implements this requirement. Section 2.2.1.a of Procedure

SWP-RMP-02, Revision 5, states, in part, that The [resin dewatering and drying]

- 28 -

process is designed to reduce the free water, by disposal package volume, to less than

0.5 percent when waste is packaged in an unstable waste form. Contrary to the

above, on August 11, 2014, the licensees resin dewatering and drying process failed to

reduce the free water, by disposal package volume, to less than 0.5 percent when waste

was packaged in an unstable waste form. Specifically, condensate filter demineralizer

resin liner 14-033-L contained approximately 0.75 percent free standing liquid when it

was received by US Ecology for disposal. Corrective actions included retrieving the

packages from waste shipment (#14-32), and testing each liner for free standing liquid

content, removing additional water as necessary. Because this violation is of very low

safety significance and has been entered into the licensees corrective action program

as Action Request 00316676, it is being treated as a NCV, consistent with Section 2.3.2

of the NRC Enforcement Policy. (NCV 05000397/2015003-05, Failure to Reduce the

Free Water in a Class A Unstable Resin Disposal Package to Less than 0.5 Percent of

Waste Volume)

4. OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and

Security

4OA1 Performance Indicator Verification (71151)

.1 Mitigating Systems Performance Index: Emergency AC Power Systems (MS06), High

Pressure Injection Systems (MS07), Residual Heat Removal Systems (MS09),

a. Inspection Scope

The inspectors reviewed the licensees mitigating system performance index data for the

period of July 2014 through June 2015 to verify the accuracy and completeness of the

reported data. The inspectors used definitions and guidance contained in Nuclear

Energy Institute Document 99-02, Regulatory Assessment Performance Indicator

Guideline, Revision 7, to determine the accuracy of the reported data.

These activities constituted verification of the mitigating system performance index for

emergency ac power systems, high pressure injection systems, and residual heat

removal systems as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

.2 Reactor Coolant System Specific Activity (BI01)

a. Inspection Scope

The inspectors reviewed the licensees reactor coolant system chemistry sample

analyses for the period of July 2014 through June 2015 to verify the accuracy and

completeness of the reported data. The inspectors observed a chemistry technician

obtain and analyze a reactor coolant system sample on September 1, 2015. The

inspectors used definitions and guidance contained in Nuclear Energy Institute

- 29 -

Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,

to determine the accuracy of the reported data.

These activities constituted verification of the reactor coolant system specific activity

performance indicator, as defined in Inspection Procedure 71151.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution (71152)

.1 Routine Review

a. Inspection Scope

Throughout the inspection period, the inspectors performed daily reviews of items

entered into the licensees corrective action program and periodically attended the

licensees condition report screening meetings. The inspectors verified that licensee

personnel were identifying problems at an appropriate threshold and entering these

problems into the corrective action program for resolution. The inspectors verified that

the licensee developed and implemented corrective actions commensurate with the

significance of the problems identified. The inspectors also reviewed the licensees

problem identification and resolution activities during the performance of the other

inspection activities documented in this report.

b. Findings

No findings were identified.

4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)

.1 (Closed) Licensee Event Report 05000397/2015-002-00, Inadequately Fused Non-

Class 1E Circuit on Division 1 120/240 VAC Bus

On April 29, 2015, the licensee determined that Division 1 120/240 VAC vital

instrumentation bus was inadequately protected for all conditions. Specifically, the Class

1E electrical panel E-PP-7AA did not have adequate electrical separation for scenarios

involving a loss of offsite power coincident with a short circuit in a Non-Class 1E cooling

fan. This issue was dispositioned as a licensee identified violation in Section 4OA7 of

NRC Integrated Inspection Report 05000397/2015002, dated August 7, 2015

(ML15219A143). No additional performance deficiencies were identified. This licensee

event report is closed.

.2 (Closed) Licensee Event Report 05000397/2015-003-00, Implementation of

Enforcement Guidance Memorandum (EGM) 11-003, Revision 2

During Refueling Outage 22 in May - June 2015, Columbia Generating Station

implemented the guidance of Enforcement Guidance Memorandum (EGM) 11-003,

Revision 2, Dispositioning Boiling Water Reactor Licensee Noncompliance with

Technical Specification Containment Requirements during Operations with a Potential

for Draining the Reactor Vessel, dated December 13, 2013. Consistent with

- 30 -

EGM 11-003, Revision 2, secondary containment operability was not maintained during

operations with a potential for draining the reactor vessel activities, and required

action C.2 of Technical Specification 3.6.4.1 was not completed.

The inspectors reviewed this licensee event report for potential performance deficiencies

and violations of regulatory requirements. The inspectors reviewed the stations

implementation of the EGM 11-003, Revision 2, during operations with a potential for

draining the reactor vessel. Specific observations included:

1. The inspectors observed that the operations logged all potential for draining the

reactor vessel activities in the control room narrative logs, and that the log entry

appropriately recorded the standby source of makeup designated for the evolutions.

2. The inspectors noted that the licensee maintained reactor vessel water level at least

greater than 21 feet above the top of the reactor pressure vessel flange as required

by Technical Specification 3.9.6. The inspectors also verified that at least one

safety-related pump was the standby source of makeup designed in the control

room narrative logs for the evolutions. The inspectors confirmed that the worst case

estimated time to drain the reactor cavity to the reactor pressure vessel flange was

greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3. The inspectors verified that the operations with a potential for draining the reactor

vessels were not conducted in Mode 4 and that the licensee did not move irradiated

fuel during the operations with a potential for draining the reactor vessels. The

inspectors verified that two independent means of measuring reactor pressure

vessel water level were available for identifying the onset of loss of inventory

events.

Technical Specification 3.6.4.1, Secondary Containment requires, in part, that

secondary containment shall be operable during operations with a potential for draining

the reactor vessel. Technical Specification 3.6.4.1, Condition C, requires the licensee to

initiate actions to suspend operations with a potential for draining the reactor vessel

immediately when secondary containment is inoperable. Contrary to the above, from

May 13 - June 13, 2015, Columbia Generating Station performed a total of five

operations with a potential for draining the reactor vessel activities while in Mode 5

without an operable secondary containment. These conditions were reported as

conditions prohibited by Technical Specifications. The licensee entered this issue into

its corrective action program as Action Request 329328.

Since this violation occurred during the discretion period described in EGM 11-003,

Revision 2, the NRC is exercising enforcement discretion in accordance with Section

3.5, Violations Involving Special Circumstances, of the NRC Enforcement Policy, and,

therefore, will not issue enforcement action for this violation. In accordance with

EGM 11-003, Revision 2, each licensee that receives discretion must submit a license

amendment request (LAR) to resolve the issue for its plant which the NRC staff LAR

acceptance review finds acceptable in accordance with LIC-109, Acceptance Review

Procedures. The generic solution will be a generic change to the Standard Technical

Specifications, and the NRC will publish a notice of availability (NOA) for the TS solution

in the Federal Register. Each licensee that receives discretion must submit its

amendment request within 12 months of the NRC staffs issuance of the NOA.

- 31 -

Licensees may submit LARs to adopt the NRC-approved approach or to propose an

alternative approach for their plants.

This licensee event report is closed.

.3 (Closed) Licensee Event Report 05000397/2015-004-00, Unplanned Loss of 4.16KV

Bus 7 Switchgear Revision 0

On May 22, 2015, the licensee momentarily lost the division 1 vital bus, SM-7, due to a

human performance error during maintenance. Specifically, a licensee electrician

connected a multi-meter test lead to the wrong port on the instrument which caused an

electrical short on SM-7. The SM-7 bus automatically divorced from the startup

transformer due to a sensed phase-to-phase short, the short was isolated by a blown

fuse, and SM-7 was rapidly repowered by the backup transformer via automatic transfer.

The division 1 emergency diesel generator also auto-started from the loss of SM-7 and

was secured. At the time of this transient, the plant was in a refueling outage in Mode 5

and crediting division 2 components for safety functions. The inspectors reviewed the

licensee event report associated with this event and determined that the report

adequately documented the summary of the event including the cause of the event and

potential safety consequences. Required components for electrical power, inventory

control, and decay heat removal were available and not challenged during the transient.

Since this human performance error occurred while the plant was shutdown with division

1 components inoperable for testing, the inspectors did not identify any more than minor

performance deficiencies. This licensee event report is closed.

These activities constitute completion of three event follow-up samples, as defined in Inspection

Procedure 71153.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On September 24, 2015, the inspectors presented the radiation safety inspection results to

Mr. W.G. Hettel, Chief Operating Officer and Chief Nuclear Officer, and other members of the

licensee staff. The inspection results were re-exited telephonically on October 7, 2015, to

update the licensee on enforcement specifics of the non-cited violation. The licensee

acknowledged the issues presented. The licensee confirmed that any proprietary information

reviewed by the inspectors had been returned or destroyed.

On October 1, 2015, the inspectors presented the inspection results to Mr. W.G. Hettel, Chief

Operating Officer and Chief Nuclear Officer, and other members of the licensee staff. The

licensee acknowledged the issues presented. The licensee confirmed that any proprietary

information reviewed by the inspectors had been returned or destroyed.

- 32 -

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Abney, Assistant Manager, Operations

P. Allen, System Engineer, System Engineering

D. Brown, Manager, System Engineering

S. Clizbe, Manager, Emergency Preparedness

M. Davis, Manager, Chemistry/Radiation Protection

E. Dumlao, Senior Engineer

D. Gregoire, Manager, Regulatory Affairs

J. Hauger, System Engineering

G. Hettel, Chief Nuclear Officer and Chief Operating Officer

G. Higgs, Manager, Maintenance

M. Hummer, Licensing Engineer

A. Javorik, Vice President, Engineering

M. Laudisio, Manager, Radiation Protection

C. Moon, Manager, Quality

R. Prewett, Plant General Manager

G. Pierce, Manager, Training

A. Rice, Manager, Chemistry

B. Schuetz, Vice President, Operations

D. Stevens, Operations Manager

G. Strong, Electrical Design Supervisor

D. Suarez, Regulatory Compliance Engineer

J. Tansy, Reactor Engineering Supervisor

J. Trautvetter, Compliance Supervisor, Regulatory Affairs

L. Williams, Licensing Supervisor

D. Wolfgramm, Compliance Engineering

NRC Personnel

G. Replogle, Senior Reactor Analyst

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000397/2015003-01 FIN Failure to Maintain Seismic Instrumentation Functional to Alert

Plant Operators of Ground Motions Exceeding the Operating

Basis Earthquake (Section 1R04)05000397/2015003-02 NCV Non-Conservative Shutdown Criteria in Earthquake Abnormal

Procedure (Section 1R04)05000397/2015003-03 NCV Failure to Provide Design Control Measures for Control Room

Emergency Chillers (Section 1R04)05000397/2015003-04 NCV Failure to Implement Procedures to Ensure Availability of Safe

Shutdown Personnel (Section 1R11)

A-1 Attachment

Opened and Closed

05000397/2015003-05 NCV Failure to Reduce the Free Water in a Class A Unstable Resin

Disposal Package to Less than 0.5 Percent of Waste Volume

(Section 2RS8)

Closed

05000397/2015-002- LER Inadequately Fused Non- Class 1E Circuit on Division 1 120/240

00 VAC Bus (Section 4OA3)

05000397/2015-003- LER Implementation of Enforcement Guidance Memorandum (EGM)

00 11-003, Revision 2 (Section 4OA3)

05000397/2015-004- LER Unplanned Loss of 4.16KV Bus 7 Switchgear (Section 4OA3)

00

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

ABN-WIND Tornado/High Winds 27

SOP- Hot Weather Operations 6

HOTWEATHER-

OPS

SOP- Warm Weather Operations 11

WARMWEATHER-

OPS

SOP-SW-LU Standby Service Water System Valve & Breaker Lineup 6

Action Requests (ARs)

293549 293878 299646 300923 300999

304714 308167 312775 333418 334819

Section 1R04: Equipment Alignment

Procedures

Number Title Revision

1.3.66 Operability and Functionality Evaluation 32

5.0.12 Station Blackout and Extended Loss of AC Power Basis 0

A-2

Procedures

Number Title Revision

ABN-Earthquake Earthquake 13

ABN-HVAC HVAC Trouble 12

ISP-SEIS-S402 Triaxial Seismic Switch Model SP-1/TS-3 - CFT 3

ISP-SEIS-S403 Seismic System Reactor Building Foundation Triaxial 1

Response - Spectrum Recorders - CFT

ISP-SEIS-X304 Seismic System Reactor Building Foundation Triaxial 2

Response - Spectrum Recorders - CC

OI-69 Time Critical Operator Actions 4

OSP-CCH/IST- Control Room Emergency Chiller System B Operability 35

M702

SOP-HVAC/CR- Control, Cable, and Critical Switchgear Rooms HVAC 1

LU Lineup

SOP-HVAC/CR- Control, Cable, and Critical Switchgear Rooms HVAC Start 10

START

SOP-HVAC/CR- Control, Cable, and Critical Switchgear Rooms HVAC 19

OPS Operation

SOP-RCC-LU RCC System Valve and Breaker Line-Up 1

SOP-SW-LU Standby Service Water System Valve & Breaker Lineup 6

TSP-DG2/LOCA- Standby Diesel Generator DG2 LOCA Test 26

B501

SOP-SLC-LU SLC System Valve and Breaker Lineup 0

SOP-SGT-LU Standby Gas Treatment System Lineup 0

Calculations

Number Title Revision

CE-02-90-21 Calculation for Set Points Response Spectrum Indicating 0

Lights

ME-02-92-43 Room Temperature Calculation for DG Building, Reactor 10

Building, Radwaste Building and Service Water

A-3

Drawings

Number Title Revision

EWO-101E-008 Electrical Wiring Diagram Heat Trace SLC Pump Suction 2

Piping

M522 Flow Diagram Standby Liquid Control System 39

Miscellaneous

Number Title Revision/

Date

C92-0020 Component Classification Evaluation Record 0

E555-HT-HTP- Fuse Detail Report December

8B/A 15, 2008

ISCR 979 Instrument Setpoint Change Request SEIS-RSRT-1/1, 1/2, April 30,

1/3 1990

LDCN-11-001, Columbia Generating Station Final Safety Analysis Report 61

11-013

Work Orders

02041736 02075766

Action Requests (ARs)

046497 298184 302392 304002 304040

307688 307703 308892 311384 313567

313883 313960 318811 319542 323891

325520 330741 333996

Section 1R05: Fire Protection

Drawings

Number Title Revision

E503-1 Motor Control Center General Notes, MCC and Starter 86

Index

E535-49A Connection Wiring Diagram Motor Control Center E-MC-7F 23

E535-49B Connection Wiring Diagram Motor Control Center E-MC-7F 23

E753 Radwaste and Control Building Elevation 525-0 Power 41

Conduit and Tray Plans

PFSS-1 Appendix R Post Fire Safe Shutdown (PFSS) Division 1 10

Boundaries One Line Diagram

A-4

Procedures

Number Title Revision

1.3.10A Control of Ignition Sources 15

FPP-1.6 Combustible Loading Calculation Control 2

FPP-2.2.12 Annual Fire Door Operability Test 4

FPP-2.2.7 Fire Protection Water System Inspections 5

Fire Protection Pre-Plans

Number Title Revision

PFP-RB-422 Reactor 422 5

PFP-RW-467 Radwaste 467 5

PFP-RW-484- Radwaste 484-487 5

487

PFP-RW-525 Radwaste 525 5

Section 1R11: Licensed Operator Requalification Program and Licensed Operator

Performance

Procedures

Number Title Revision

OI-9 Operations Standards and Expectation 62

OI-45 Color Banding of Control Room Instrumentation 6

OI-53 Offsite Power 14

1.3.67 Operational Decision Making Process 14

1.3.84 Reactivity Management Control 2

13.1.1 Classifying the Emergency 47

5.1.1 RPV Control 20

5.2.1 Primary Containment Control 22

5.3.1 Secondary Containment Control 19

Action Requests (ARs)

332747 333692

A-5

Section 1R12: Maintenance Effectiveness

Procedures

Number Title Revision

1.5.11 Maintenance Rule Program 13

MOT-CHILL-1-1 Chiller Maintenance Scope and Basis Document 7

MOT-PRV-1-1 Pressure Relief Valve Maintenance Scope and Basis 6

Document

Miscellaneous

Number Title Revision/

Date

Maintenance Rule Evaluations CCH System June 30,

2015

CCH System Performance Improvement Plan 4

51182 Reactor Operating Events-Event Notification Report June 25,

2015

CVI 531-00,1,1 Differential Pressure Indicating Switches, Unit, Calibration 3

and Parts List

GEP-6013 Preparation and Installation of the ULTRX Rupture Disc 2008

Assembly

IMDS Instrument Master Data Sheets DMA-TIS-32A/B 7

Action Requests (ARs)

020602 020829 122680 132812 135119

195492 195876 226018 284341 298184

304040 307688 307703 307863 307897

308892 308950 311597 313567 313883

318811 319542 320707 332078 332096

332617 332889 334369 334438

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

ABN-CR-EVAC Control Room Evacuation and Remote Cooldown 33

A-6

Procedures

Number Title Revision

OI-14 Columbia Generating Station Operational Challenges and 13

Risk Program

OI-69 Time Critical Operator Actions 4

1.3.1 Operating Policies, Programs, and Practices 119

1.3.76 Integrated Risk Management 44

Action Requests (ARs)

302053 306204 309005 311964 314936

314983 319661 321848 322776 323263

323364 329491 333025 333041 333041

333622 333731 334749

Work Orders (WOs)

02082634

Miscellaneous

Number Title Date

Protected Equipment Tracking Sheet August 20,

2015

Protected Equipment Tracking Sheet September

13, 2015

Protected Equipment Tracking Sheet September

26, 2015

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision

1.3.66 Operability and Functionality Evaluation 32

4.601.A2 601.A2 Annunciator Panel Alarms 27

5.0.12 Station Blackout and Extended Loss of AC Power Basis 0

ABN-HVAC HVAC Trouble 12

OI-69 Time Critical Operator Actions 4

OI-9 Operations Standards and Expectation 62

A-7

Procedures

Number Title Revision

OSP-CCH/IST- Control Room Emergency Chiller System B Operability 35

M702

SOP- Hot Weather Operations 6

HOTWEATHER-

OPS

SOP-HVAC/CR- Control, Cable, and Critical Switchgear Rooms HVAC 1

LU Lineup

SOP-HVAC/CR- Control, Cable, and Critical Switchgear Rooms HVAC 19

OPS Operation

SOP-HVAC/CR- Control, Cable, and Critical Switchgear Rooms HVAC Start 10

START

Calculations

Number Title Revision

ME-02-89-49 Calculation for Main Steam Isolation Valve Actuator Force 0

Balance

NE-02-85-19 Calculation Post-Fire Safe Shutdown (PFSS) Analysis 7

Miscellaneous

Number Title Revision/

Date

531-00,1,1 Barton Differential Pressure Indicating Switches, Unit, 3

Calibration and Parts List

IMDS Instrument Master Data Sheets MS-LIS-24A/C 16

NO 1419 Night Order October 27,

2012

NO 1653 Night Order July 8, 2015

TM-2150 Mission Time of Emergency Safety Features 0

Action Requests (ARs)

273129 332823 332326 332330 332078

032562 332096 021535 028598 333334

334459

A-8

Section 1R18: Plant Modifications

Miscellaneous

Number Title Revision

EC14111 RFW-V-102A Push Rod Assembly 0

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

OSP-CCH/IST- Control Room Emergency Chiller System A Operability 38

M701

OSP-RCIC/IST- RCIC Operability Test 56

Q701

OSP-ELEC-S702 Diesel Generator 2 Semi-Annual Operability Test 55

SOP-DG2- Emergency Diesel Generator (DIV 2) Start 26

START

Work Orders

02059527 02066727 02069655 02066726 02070167

02075767

Miscellaneous

Number Title Revision

IMDS Instrument Master Data Sheets DMA-TIS-32A/B 7

Action Requests (ARs)

298184 314814 319542 320386 321294

323891 324941 325599 331175 332159

335270 335441 336314 336431 336485

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

OSP-INST-H101 Shift and Daily Instrument Checks Modes 1, 2, 3 85

OSP-DO/IST- DO-P-1A Operability 14

Q701

A-9

Procedures

Number Title Revision

OSP-LPCS/IST- LPCS System Operability Test 39

Q702

Action Requests (ARs)

316238 326038 332078 332833 335006

335144

Section 1EP6: Drill Evaluation

Procedures

Number Title Revision

5.1.1 RPV Control 20

5.2.1 Primary Containment Control 22

5.3.1 Secondary Containment Control 19

13.1.1 Classifying the Emergency 47

Action Requests (ARs)

332756 333042

Miscellaneous

Number Title Date

ERO Team A Drill Guide July 7, 2015

ERO Team A Drill Report - After Action Improvement Plan July 30, 2015

Section 2RS5: Radiation Monitoring Instrumentation

Procedures

Number Title Revision

CI-13.10 Canberra iSolo Alpha/Beta Counting System 04

CI-13.12 Global Value Gamma Ray Analyzer System 03

CI-13.6 ORTEC Gamma Ray Analyzer System 03

CI-13.9 Tri-Carb Liquid Scintillation Counting System 03

HPI-12.100 Calibration of the SAM12 Small Article Monitor 03

HPI-5.6 FastScan Whole Body Count System 07

A-10

Procedures

Number Title Revision

HPI-7.5 Eberline Model RO-2 and RO-2A Calibration 10

PPM 16.1.2 Stack Monitor Low Range Detector 14

PPM 16.2.1 TEA Low Range Noble Gas Monitor Channel 1 10

PPM 16.4.4 OFFGAS Post Treatment Radiation Monitor CH A 16

PPM 16.7.2 FDR-RIS-606, Liquid Radwaste Effluent Monitor 08

PPM 16.7.4 Liquid Radwaste Effluent Line Flow Rate 07

Action Requests (ARs)

00307356 00308226 00308390 00308468 00309073

00309410 00310348 00312551 00319190 00319873

00325863 00326107 00334647

Audits and Self-Assessments

Number Title Date

301869 Snapshot Self-Assessment Report - Radiation July 25, 2015

Instruments

AU-CH-14 Quality Services Audit Report - Chemistry/REMP/Non- October 23, 2014

Rad & Rad Effluents/ODCM Program

Installed Radiation Instrument Calibration Records

WO Number Title Date

01167050 TEA Low Range Noble Gas Monitor Channel 1 April 3, 2014

02043785 OFFGAS Post Treatment Radiation Monitor CH A May 23, 2015

02047822 CC/RC Secondary Containment Isolation Reactor March 26, 2014

Building Vent Radiation Channel D

02051142 Liquid Radwaste Flow Instrument June 13, 2014

02051815 MSL High Radiation Channel A June 27, 2014

02053216 Stack Monitor Low Range Noble Gas Monitor July 17, 2014

02062579 Liquid Radwaste Effluent Radiation Monitor March 3, 2015

02066745 Plant Blowdown Discharge Line Flow Rate July 3, 2015

A-11

Portable Radiation Instrument Calibration Records

Number Title Date

3891 Victoreen Model 570 R-Chamber Set January 20, 2014

F112 Ludlum Model 177 Frisker April 1, 2015

NO17 Eberline ASP-1 w/ NRD Neutron Detector April 8, 2015

RO196 Eberline RO-2 April 24, 2015

RO237 Ludlum Model 14C July 23, 2015

RS26 Thermo/Bicron Micro-Rem Meter April 30, 2015

RV07 Victoreen 451B April 2, 2015

T070 Teletector Model 6112M May 20, 2015

Stationary Radiation Instrument Calibration Records

Number Title Date

36797 iSolo Calibration September 23,

2015

HP-EQ-42712 SAM12 Small Article Monitor September 23,

2015

HP-EQ-42734 GEM-5 July 19, 2015

HP-EQ-42747 GEM-5 September 3,

2015

HP-EQ-42783 ARGOS-5 A/B July 14, 2015

HP-EQ-42813 SAM12 Small Article Monitor April 20, 2015

HP-EQ-C015122 IPM-8 May 8, 2015

Ortec #5 Efficiency Verification Worksheet September 23,

Calibration of 47 mm Filter Shelf 1 2015

Ortec #5 Efficiency Verification Worksheet September 23,

Calibration of 250 ml Polybottle - Shelf 1 2015

WBC#2 FastScan Calibration July 29, 2015

WO 02062192 Annual Tritium Quench Curve Calibration June 10, 2015

Miscellaneous Documents

Number Title Revision/Date

Offsite Dose Calculation Manual 53

Calibration Lab Irradiator Periodic Dose Rate Decay July 7, 2015

Adjustment

A-12

Miscellaneous Documents

Number Title Revision/Date

15-02 Calculation of the Activity for K40 Daily Check Source June 23, 2015

Used with SAM 9/11/12 and BM 285 Monitors

(Revises Calculation No. 04-1)

Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment

Procedures

Number Title Revision

1.11.12 Removal of Liquids from RCA 11

11.2.15.7 Release of Material from Radiologically Controlled 21

Area

TSP-BOP/ISOL- Balance of Plant Isolation Logic System Functional 07

B501 Test

TSP-SGT-B501 Standby Gas Treatment System Functional Test 08

10.2.8 Carbon Filter In Place Testing 08

10.2.82 HEPA Filter In Place Testing 07

12.4.21 The Sampling and Determination of Tritium 25

12.5.8 Gaseous Effluent Discharge Sampling 23

12.5.28 Sampling and Analysis for Unrestricted Release 12

16.11.1 Monthly Grab Gas Samples 10

16.11.6 Weekly Iodine, Particulate, and Tritium Analysis Results 15

MSP-SGT-B102 Standby Gas Treatment System Unit B HEPA Filter Test 04

MSP-SGT-B103 Standby Gas Treatment Filtration System - Unit A 10

Carbon Adsorber Test

MSP-SGT-B104 Standby Gas Treatment Filtration System - Unit B 08

Carbon Adsorber Test

9.3.32 Fuel Integrity Monitoring 12

Action Requests (ARs)

00297561 00301591 00310348 00315360 00315492

00320966 00321016 00321365 00323071 00323632

00326490 00331287 00331587 00331588 00331589

00334641 00291084

A-13

Audits, Self-Assessments, and Surveillances

Number Title Date

AU-CH-14 Chemistry-REMP-Non-Rad and Rad Effluents-ODCM October 16, 2014

Program Audit

AU-RP-RW-13 Radiation Protection and Process Control November 16, 2013

23748A NUPIC Audit NCS Corporation September 3, 2014

23748B NUPIC Audit AEP Audit No. PA-14-12 November 25, 2014

Air Cleaning System Surveillance Test Records

Number Title Date

WO 2004423 Standby Gas Treatment Filtration System - Unit A Carbon July 15, 2013

Adsorber Test

WO 2046928 Standby Gas Treatment System Unit B HEPA Filter Test April 28, 2014

WO 2046928 Standby Gas Treatment Filtration System - Unit B Carbon April 28, 2014

Adsorber Test

Title Date

2013 Annual Radioactive Effluent Release Report April 2014

2014 Annual Radioactive Effluent Release Report April 2015

Cross-Check Program 2013 Summary Report February 2014

Cross-Check Program 2014 Summary Report February 2015

Section 2RS7: Radiological Environmental Monitoring Program

Procedures

Number Title Revision

SWP-CHE-01 Groundwater Protection Program 03

PPM 1.11.1 REMP Implementation Procedure -

REMP 5.11 Use and Maintenance of Automatic Composite 02

Samplers

REMP 9.10 Environmental TLD Calculations 01

REMP 11.01 Milk Sampling 06

A-14

Procedures

Number Title Revision

REMP 11.02 Soil and Sediment Sampling 03

REMP 11.06 Fish Collection and Preparation 01

REMP 11.07 REMP Water Sample Collection 06

REMP 11.09 REMP Air Sample Collection 05

REMP 12.06 Quality Assurance for the Radiological Laboratory 01

REMP 12.07 Radiological Laboratory Measurement Assurance 01

Program

SOP 11.09r05 REMP Air Sample Collection 05

Audits, Self-Assessments, and Surveillances

Number Title Date

AR 291084 Perform a Self-Assessment of SWP-CHE-01, Groundwater January, 2014

Protection Program Against the Requirements of NEI 07-07

15-A-08 Energy Northwest Audit Report 15-A-08 of Mission Support March 9, 2015

Alliance - Radiological Site Services

AU-RP/RW-13 Quality Services Audit Report; Radiation Protection and November 2013

Process Control program

AR-SA:305111 Focused Self-Assessment Report; Radioactive Gaseous June 19, 2015

and Liquid Effluents; Radiological Environmental Monitoring

Program; and Radioactive Solid Waste Processing,

Radioactive Material Handling, Storage, and Transportation

Action Requests (ARs)

00320966 00303414 00335039 00331779 00300634

00317136 00333542 00318632 00320309 00316091

00321365 00325192 00329806 00331590 0033106

00333286 00299745 00334171 00334146 00303414

A-15

Miscellaneous Documents

Title Revision/Date

Plant Meteorological Tower Data Availability Records, 2013, 2015 and 2015 September 2015

(Year to Date)

Plant Specific Logs for Licensee Compliance to Title 10 Part 50.75.g. (Year September 2015

to Date)

2013 Annual Radiological Environmental Operating Report May 2014

2014 Annual Radiological Environmental Operating Report May 2015

Offsite Dose Calculation Manual June 1991

Offsite Dose Calculation Manual 53

Section 2RS8: Radioactive Solid Waste Processing, and Radioactive Material Handling,

Storage, and Transportation

Procedures

Number Title Revision

1.10.1 Notifications and Reportable Events 37

11.2.23.1 Shipping Radioactive Materials and Waste 15

11.2.23.2 Computerized Radioactive Waste and Material 19

Characterization

11.2.23.4 Packaging Radioactive Material and Waste 23

11.2.23.14 Sampling of Radioactive Waste Streams 12

11.2.23.19 Operation of The Pacific Nuclear Resin Drying System 07, 13, 14

11.2.23.29 LSA Contaminated Laundry Shipments 11

11.2.23.37 Use of the 14D-2.0 Type A Transportation Cask 05

RW000103 Waste Characterizing Computer Code 00

RW000115 WNP-2 Radwaste Procedure Training 00

RW000116 NRC Packaging and Shipping Regulations 00

RW000117 DOT Packaging and Shipping Regulations 00

RW000118 Burial Site Disposal Requirements 00

SWP-CHE-02 Chemical Process Management and Control 24

A-16

Procedures

Number Title Revision

SWP-RMP-02 Radioactive Waste Process Control Program 05

Audits, Self-Assessments, and Surveillances

Number Title Date

AU-RP/RW-13 Quality Services Audit Report: Radiation Protection and December 3,

Process Control Program 2013

AU-CH-14 Quality Service Audit Report: Chemistry/REMP/Non-Rad and October 23, 2014

Rad Effluents/ODCM Program

30511 Focused Self-Assessment Report: Radioactive Gaseous and June 19, 2015

Liquid Effluents; Radiological Environmental Monitoring

Program; Radioactive Solid Waste Processing, Radioactive

Material Handling, Storage, and Transportation

Action Requests (ARs)

00297650 00300182 00308527 00316555 00316676

00316835 00316913 00320373 00323678 00323841

00325137 00332690 00332758 00333434 00333463

00333590

Radioactive Material and Waste Shipments

Number Title Date

13-07 RWCU Resin (Non-DOT) March 26, 2013

13-39 12 Boxes of Dry Active Waste (LSA II) June 11, 2013

13-46 12 Boxes of Dry Active Waste (LSA II) June 27, 2013

13-50 Resin Bead, 1 PDX, 8 Boxes of Dry Active Waste (LSA II) August 27, 2013

14-03 RHR-P-2B (Type A) January 16, 2014

14-10 4 Condensate F/D Resins, 2 Boxes Dry Active Waste May 20, 2014

(LSA II)

14-16 EDDR/FDR F/D Resins (LSA II) June 11, 2014

A-17

Radioactive Material and Waste Shipments

Number Title Date

14-32 Condensate F/D Resins - 5 liners (RETURNED) (LSA II) October 9, 2014

14-38 EDR/FDR Resin Condensate (LSA II) December 15,

2014

15-01 Condensate F/D Resins; 4 Boxes Dry Active Waste (LSA II) January 20, 2015

15-43 One 20 C-Van with Dry Active Waste (LSA II) June 4, 2015

Radiation Work Permits

Number Title Revision

30003514 2015 RW 437 Waste Processing NUPAC Cage - LHRA 00

30003520 2015 RW NUPAC Cage Processing - LHRA High Risk 00

30003498 NRC Tours and Inspections - HRA 00

Radiological Surveys

Number Title Date

4435 ISFSI Building 105 July 27, 2015

4497 Building 167 & C-Vans August 3, 2015

4500 Warehouse 5 (Building 80) August 3, 2015

4710 Building 13 Laundry August 21, 2015

4874 LSA Pad September 8,

2015

5057 Radwaste 437 NUPAC Cage September 23,

2015

A-18

Miscellaneous Documents

Number Title Revision/Date

ODCM LEP Columbia Generating Station Offsite Dose Calculation Manual 53

Columbia Generating Station Final Safety Analysis Report - 57

Chapter 11.4, Solid Waste Management System

2013 Annual Radioactive Effluent Release Report April 30, 2014

DIC 1554.58 Columbia Generating Station Scaling Factor Determination March 24, 2015

Package

2014 Annual Radioactive Effluent Release Report April 30, 2015

10 CFR 61 Scaling Factor Determination September 17,

2015

Section 4OA1: Performance Indicator Verification

Procedures

Number Title Revision

CI-10.17 Iodine 12

CSP-I131-W101 Reactor Coolant Isotopic Analysis for I-131 Dose 9

Equivalent

Miscellaneous

Number Title Revision

MSPI-01-BD-001 MSPI Basis Document 17

286838 286894 332833 333421

Work Orders

02069131

Section 4OA2: Problem Identification and Resolution

Procedures

Number Title Revision

SWP-CAP-06 Condition Report Review 22

A-19

Action Requests (ARs)

329576 333690 334108

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Procedures

Number Title Revision

3.4.1 Minimizing the Potential of Draining the Reactor Vessel 19

Action Requests (ARs)

323625 326336 326573 328051 328312

328726 329328

A-20

The following items are requested for the

Public Radiation Safety Inspection

Columbia

September 21-24, 2015

Integrated Report 2015003

Inspection areas are listed in the attachments below.

Please provide the requested information on or before August 31, 2015.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1- A, applicable organization charts in file/folder 1- B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Martin Phalen at (817) 200-1158 or

martin.phalen@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

A-21

1. Radiation Monitoring Instrumentation (71124.05)

Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas:

1. Effluent monitor calibration

2. Radiation protection instrument calibration

3. Installed instrument calibrations

4. Count room and Laboratory instrument calibrations

B. Applicable organization charts

C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support and

LERs, written since date of last inspection, related to:

1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey

instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,

or whole body counters

2. Installed radiation monitors

D. Procedure index for:

1. Calibration, use and operation of continuous air monitors, criticality monitors,

portable survey instruments, temporary area radiation monitors, electronic

dosimeters, teledosimetry, personnel contamination monitors, and whole body

counters.

2. Calibration of installed radiation monitors

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Calibration of portable radiation detection instruments (for portable ion chambers)

2. Whole body counter calibration

3. Laboratory instrumentation quality control

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the following programs:

1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey

instruments, electronic dosimeters, teledosimetry, personnel contamination monitors,

whole body counters,

2. Installed radiation monitors,

3. Effluent radiation monitors

4. Count room radiation instruments

NOTE: The lists should indicate the significance level of each issue and the search criteria

used. Please provide in document formats which are searchable so that the inspector can

perform word searches.

G. Offsite dose calculation manual, technical requirements manual, or licensee controlled

specifications which lists the effluent monitors and calibration requirements.

H. Current calibration data for the whole body counters.

I. Primary to secondary source calibration correlation for effluent monitors.

J. A list of the point of discharge effluent monitors with the two most recent calibration

dates and the work order numbers associated with the calibrations.

K. Radiation Monitoring System health report for the previous 12 months

A-22

2. Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas:

1. Radiological effluent control

2. Engineered safety feature air cleaning systems

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Radioactive effluents

2. Engineered Safety Feature Air cleaning systems

D. Procedure indexes for the following areas

1. Radioactive effluents

2. Engineered Safety Feature Air cleaning systems

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Sampling of radioactive effluents

2. Sample analysis

3. Generating radioactive effluent release permits

4. Laboratory instrumentation quality control

5. In-place testing of HEPA filters and charcoal adsorbers

6. New or applicable procedures for effluent programs (e.g., including ground water

monitoring programs)

F. List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. Radioactive effluents

2. Effluent radiation monitors

3. Engineered Safety Feature Air cleaning systems

NOTE: The lists should indicate the significance level of each issue and the search criteria

used. Please provide in document formats which are searchable so that the inspector can

perform word searches.

G. 2013 and 2014 Annual Radioactive Effluent Release Report or the two most recent

reports

H. Current Copy of the Offsite Dose Calculation Manual

I. Copy of the 2013 and 2014 interlaboratory comparison results for laboratory quality

control performance of effluent sample analysis, or the two most recent results.

J. Effluent sampling schedule for the week of the inspection

K. New entries into 10 CFR 50.75(g) files since date of last inspection

L. Operations department (or other responsible dept.) log records for effluent monitors

removed from service or out of service

M. Listing or log of liquid and gaseous release permits since date of last inspection

A-23

N. A list of the technical specification-required air cleaning systems with the two most

recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal

adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers

associated with the surveillances

O. System Health Report for radiation monitoring instrumentation. Also, please provide a

specific list of all effluent radiation monitors that were considered inoperable for 7 days

or more since November 2011. If applicable, please provide the relative Special Report

and condition report(s) moreover

P. A list of all radiation monitors that are considered §50.65/Maintenance Rule equipment.

Q. A list of all significant changes made to the Gaseous and Liquid Effluent Process

Monitoring System since the last inspection. If applicable, please provide the

corresponding UFSAR section in which this change was documented.

R. A list of any occurrences in which a non-radioactive system was contaminated by a

radioactive system. Please include any relative condition report(s).

3. Radiological Environmental Monitoring Program (71124.07)

Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas:

1. Radiological environmental monitoring

2. Meteorological monitoring

B. Applicable organization charts

C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Radiological environmental monitoring program (including contractor environmental

laboratory audits, if used to perform environmental program functions)

2. Environmental TLD processing facility

3. Meteorological monitoring program

D. Procedure index for the following areas:

1. Radiological environmental monitoring program

2. Meteorological monitoring program

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Environmental Program Description

2. Sampling, collection and preparation of environmental samples

3. Sample analysis (if applicable)

4. Laboratory instrumentation quality control

5. Procedures associated with the Offsite Dose Calculation Manual

6. Appropriate QA Audit and program procedures, and/or sections of the stations QA

manual (which pertain to the REMP)

F. A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the following programs:

1. Radiological environmental monitoring

A-24

2. Meteorological monitoring

NOTE: The lists should indicate the significance level of each issue and the search criteria

used. Please provide in document formats which are searchable so that the inspector can

perform word searches.

G. Wind Rose data and evaluations used for establishing environmental sampling locations

H. Copies of the 2 most recent calibration packages for the meteorological tower

instruments

I. Copy of the 2013 and 2014 Annual Radiological Environmental Operating Report and

Land Use Census, and current revision of the Offsite Dose Calculation Manual, or the

two most recent reports.

J. Copy of the environmental laboratorys interlaboratory comparison program results for

2013 and 2014, or the two most recent results, if not included in the annual radiological

environmental operating report

K. Data from the environmental laboratory documenting the analytical detection sensitivities

for the various environmental sample media (i.e., air, water, soil, vegetation, and milk)

L. Quality Assurance audits (e.g., NUPIC) for contracted services

M. Current NEI Groundwater Initiative Plan and status

N. Technical requirements manual or licensee controlled specifications which lists the

meteorological instruments calibration requirements

O. A list of Regulatory Guides and/or NUREGs that you are currently committed to relative

to the Radiological Environmental Monitoring Program. Please include the revision

and/or date for the committed item and where this can be located in your current

licensing basis/UFSAR.

P. If applicable, per NEI 07-07, provide any reports that document any spills/leaks to

groundwater since the last inspection

4. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage,

and Transportation (71124.08)

Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas:

1. Solid Radioactive waste processing

2. Transportation of radioactive material/waste

B. Applicable organization charts (and list of personnel involved in solid radwaste

processing, transferring, and transportation of radioactive waste/materials)

C. Copies of audits, department self-assessments, and LERs written since date of last

inspection related to:

1. Solid radioactive waste management

2. Radioactive material/waste transportation program

D. Procedure index for the following areas:

1. Solid radioactive waste management

2. Radioactive material/waste transportation

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E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Process control program

2. Solid and liquid radioactive waste processing

3. Radioactive material/waste shipping

4. Methodology used for waste concentration averaging, if applicable

5. Waste stream sampling and analysis

F. A summary list of corrective action documents (including corporate and subtiered

systems) written since date of last inspection related to:

1. Solid radioactive waste

2. Transportation of radioactive material/waste

NOTE: The lists should indicate the significance level of each issue and the search criteria

used. Please provide in document formats which are searchable so that the inspector can

perform word searches.

G. Copies of training lesson plans for 49CFR172 subpart H, for radwaste processing,

packaging, and shipping

H. A summary of radioactive material and radioactive waste shipments made from date of

last inspection to present

I. Waste stream sample analyses results and resulting scaling factors for 2013, 2014,

and 2915, or the two most recent results

J. Waste classification reports if performed by vendors (such as for irradiated hardware)

K. A listing of all onsite radwaste storage facilities. Please include a summary or listing of

the items stored in each facility, including the total amount of radioactivity and the

highest general area dose rate

Although it is not necessary to compile the following information, the inspector will also review:

L. Training, and qualifications records of personnel responsible for the conduct of

radioactive waste processing, package preparation, and shipping

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