IR 05000397/2018010

Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans - Inspection Report 05000397/2018010

ML18232A432
Person / Time
Site:	Columbia
Issue date:	08/20/2018
From:	Mark Haire NRC/RGN-IV/DRP/RPB-A
To:	Sawatzke B Energy Northwest
Haire M
References
IR 2018010
Download: ML18232A432 (12)

Text

August 20, 2018

SUBJECT:

COLUMBIA GENERATING STATION - INSPECTION OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY PREPAREDNESS COMMUNICATION/STAFFING/MULTI-UNIT DOSE ASSESSMENT PLANS -

INSPECTION REPORT 05000397/2018010

Dear Mr. Sawatzke:

On June 14, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed the onsite portion of this inspection at Columbia Generating Station, and continued in-office review and inspection through July 2018. On August 1, 2018, the NRC inspectors discussed the final results of this inspection with Mr. B. Schuetz, Vice President - Operations, and other members of your staff in a telephonic meeting. The results of this inspection are documented in the enclosed report.

The inspection examined activities conducted under your license as they relate to the implementation of mitigation strategies and spent fuel pool instrumentation orders (EA-12-049 and EA-12-051) and Emergency Preparedness Communication, Staffing, and Multi-Unit Dose Assessment Plans, your compliance with the Commissions rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and records, observation of activities, and interviews with station personnel.

The NRC inspectors did not identify any findings or violations of more than minor safety significance. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Mark S. Haire, Chief Project Branch A Division of Reactor Projects

Docket: 50-397 License: NPF-21

Enclosure:

Inspection Report 05000397/2018010 w/ Attachment

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2018010

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, Washington

Inspection Dates:

June 11, 2018 to July 31, 2018

Inspectors:

R. Alexander, Sr. Project Engineer (Team Leader)

G. Kolcum, Sr. Resident Inspector - Columbia

D. Bradley, Sr. Resident Inspector - Callaway

K. Roche, Project Manager/Inspector, NRR

Approved By:

Mark S. Haire

Chief, Project Branch A

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensees performance by conducting a Temporary Instruction 2515/191, Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/

Staffing/Multi-Unit Dose Assessment Plans at Columbia Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status TI 2515/191 Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans Other Activities Closed

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The team reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose Assessment Plans

The inspection verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation (ADAMS No. ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ADAMS No. ML12053A340) and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013, (ADAMS No.

ML12339A262).

(1) Based on samples selected for review, the team inspected to determine whether the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals [including the Final Integrated Plan (ADAMS No. ML17229B506)] and the associated safety evaluation (ADAMS No. ML17333A888), and to determine whether the licensee is in compliance with NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events. Specifically, the team inspected to determine whether the licensee satisfactorily:

a) developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events; b) integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures; c) protected FLEX equipment from site-specific hazards; d) developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability; e) trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and f) developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.

(2) Based on samples selected for review, the team inspected to determine whether the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals [including the Final Integrated Plan (ADAMS No. ML17229B506)] and the associated safety evaluation (ADAMS No. ML17333A888),and to determine whether the licensee is in compliance with NRC Order EA-12-051, Order Modifying Licenses With Regard to Reliable Spent Fuel Pool Instrumentation.

Specifically, the team inspected to determine whether the licensee satisfactorily:

a) installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation; b) installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals; c) trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and d) developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation.

(3) The team reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter (ADAMS No.

ML12053A340), and inspected to determine whether the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force Recommendation 9.3.

Specifically, the team inspected to determine whether:

a) the licensee satisfactorily implemented required staffing changes to support an extend loss of all AC power (ELAP)/loss of ultimate heat sink (LUHS) scenario; b) emergency preparedness communications equipment and facilities are sufficient for dealing with an ELAP/LUHS scenario; and c) the licensee implemented multi-unit/-source dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

The team verified that non-compliances with requirements and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On June 14, 2018, the inspectors presented the on-site inspection results in a management debrief to Mr. G. Hettel, Chief Nuclear Officer, and other members of the site staff.

• On August 1, 2018, the inspectors presented the complete inspection results in a telephonic exit meeting to Mr. B. Schuetz, Vice President - Operations, and other members of the site staff

DOCUMENTS REVIEWED

TI 2515/191 - Inspection of the Implementation of Mitigation Strategies and Spent Fuel Pool

Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit Dose

Assessment Plans

Corrective Action Program Documents [Action Requests] (AR-xxxxx)

278368

356000

360409

365033

368303

369984

371116

371448

373245

373950

373969

375066

375565

375565

375565

375623

375625

375626

376594

376845

377079

377079

377202

377461

377461

378465

378465

378826

379420

379420

379421

379538

379643

379741

380220

381241*

381263*

381271*

381289*

381306*

381307*

381316*

381319*

381321*

381322*

381350*

381382*

381385*

381387*

381389*

381390*

381393*

381403*

381405*

381430*

381432*

381436*

381437*

381445*

381446*

381447*

381457*

• - Notes ARs written as a result of the inspection

Procedures

(Number)

Title

Revision

or Date

ABN-ADHR

Alternate Decay Heat Removal

ABN-ASH

Ash Fall

ABN-ELEC-DG3-

CROSSTIE/SM7

DG-3 Crosstie to SM-7

ABN-ELEC-DG3-

CROSSTIE/SM8

DG-3 Crosstie to SM-8

ABN-ELEC-DG4-

CROSSTIE/MC-7A

DG-4 Crosstie to MC-7A

ABN-ELEC-DG4-

CROSSTIE/MC-8A

DG-4 Crosstie to MC-8A

ABN-ELEC-LOOP

Loss Of All OffSite Power

ABN-FSG-001

Accessing Essential Instrumentation during

Extended Loss of AC Power with No DC Power

Available

ABN-FSG-002

Water Makeup Strategies for RPV, SFP, DW, WW

During an Extended Loss of AC Power or other

Beyond Design Basis Event

ABN-FSG-003

DG4 Crosstie to E-MC-7A and E-MC-8A

ABN-FSG-004

DG5 Crosstie to E-MC-7A and E-MC-8A

ABN-FSG-NSRC-001 NSRC 4160V DG Crosstie via DG1, DG2 OR SM-3

to SM-7 OR SM-8

ABN-FSG-NSRC-002 NSRC Portable SW Pump Alignment to SW Loop A

or SW Loop B

Procedures

(Number)

Title

Revision

or Date

ABN-FSG-NSRC-003 NSRC 480V DG Crosstie to E-MC-7A and E-MC-8A

ABN-RCIC-START

RCIC Start Without AC and DC Power

ABN-SITE-ACCESS

Loss/Restriction of Site Access Routes

FLEX-01

Flex Program

OMI-3.2

Shutdown Safety Plan Development and Approval

Process

PPM 1.20.3

Outage Risk Management

PPM 1.5.18

Managing B.5.b and FLEX Equipment Unavailability

PPM 10.20.15

E-GEN-DG4 Mechanical Maintenance

PPM 3.1.10

OPS-4 LOGS

PPM 5.2.1

Primary Containment Control

PPM 5.5.1

RPV Control

PPM 5.5.14

Emergency Wetwell Venting

PPM 5.6.1

Station Blackout (SBO/ELAP)

PPM 5.6.2

Station Blackout (SBO) and Extended Loss of AC

Power ELAP Attachments

SOP-

COLDWEATHER-

OPS

Cold Weather Operations

SOP-DG1-START

Emergency Diesel Generator DIV 1 Start

SOP-DG2-START

Emergency Diesel Generator DIV 2 Start

SOP-DG3-START

HPCS DG Start

SOP-DG4-PM

Diesel Generator 4 Monthly/Quarterly Surveillance

SOP-DG4-START

Diesel Generator 4 Start

SOP-DG4-START

Diesel Generator 4 Start

SOP-ELEC-4160V-

OPS

4160 Volt AC Electrical Distribution System

Operation

SOP-ELEC-

BACKFEED

500 KV Plant Backfeed

SOP-FLEX-

20V220V480VDG-

OPS

480V FLEX-GEN-9 Operations

SOP-FLEX-

Equipment Storage

FLEX Equipment Storage

SOP-FLEX-

EQUIPMENT-

REFUEL

FLEX Equipment Refueling

SOP-FLEX-FP-

TRUCK-OPS

B.5.B Pumper Truck Operation to Support FLEX and

ELAP Conditions

SOP-FLEX-FP-

TRUCK-PM

B.5.B Pumper Truck FLEX Functionality

SOP-FLEX-FULL-

CORE-OFFLOAD

FLEX Activities to Support a Full Core Offload

SOP-FLEX-GEN-

DG5 PM

FLEX GEN DG5 Preventative Maintenance

SOP-FLEX-GEN-

DG5-PM

FLEX GEN DG5 Preventative Maintenance

SOP-FLEX-GEN-

DG5-SHUTDOWN

FLEX GEN DG5 Shutdown

SOP-FLEX-GEN-

DG5-SHUTDOWN-

QC

FLEX GEN DG5 Shutdown Quick Card

SOP-FLEX-GEN-

DG5-START

FLEX GEN DG5 Start

SOP-FLEX-GEN-

DG5-START-QC

FLEX GEN DG5 Start Quick Card

SOP-FLEX-HITCH-

OPS-QC

FLEX Hitch Connections - Quick Card

SOP-FLEX-

TEMPPOWER

FLEX Temporary Power to Support Communications

SWP-LIC-02

Licensing Basis Impact Determinations

SWP-SEC-14

Safety/Security Interface Program

SYS-4-31

System and Equipment Performance Monitoring and

Trending Program

Work Orders

(Number)

Title

Revision

or Date

2011514

E-GEN-DG4 Annual Maintenance

5/25/2012

2051051

B5B Fire Truck Discharge Flow Calibration

(model work order)

{No Date}

2095318

B5B Inventory

03/20/2017

2095318

B5B Cabinet Inventory RB

8/14/2017

2095543

E-GEN-DG4, 3 Year Inspection Alt AC Source (GEN)

7/4/2017

2097881

FLEX-DG-5, Quarterly Load Test of Generator

4/30/2018

2098385

FLEX-DG-5, Run Time Maintenance

10/20/2017

2099229

E-GEN-DG4 Quarterly

3/06/2018

2100913

FLEX-DG-5, Sampling of Lube Oil & Engine Coolant

5/02/2018

2100915

FLEX-DG-5, Trailer Inspections

4/23/2018

2102560

FLEX-DG-5 Full Load Test of Generator

1/19/2018

2103257

E-GEN-DG4 Annual Maintenance

11/12/2017

2103438

Perform Annual Inventory of Flex Equipment

10/28/2017

2109005

Field Team Portable Radio Functional Test

03/29/2018

2119718

CGS Communications Console Functional Test

05/16/2018

2124113

Perform SOP-FLEX-FP-TRUCK-PM

05/03/2018

Miscellaneous

Documents (Number)

Title

Revision

or Date

Snow Removal Presentation

2017

Building 600 HVAC Load Calc

11/04/2013

OI-FLEX-06

{No Date}

Caterpillar Vendor Technical Manual

{No Date]

Shutdown Safety Plan - R23

{No Date}

2.05.01

Maintenance of 125 and 250 VDC Bus Voltage

26918

Technical Assessment Supporting Reportability

AD-18-0273

Applicability Determination for License Basis

Changes: FLEX-01, Rev. 2

05/29/2018

CVI 1228-00

SAFER Response Plan for Columbia Generating

Station

EC 12959

Develop Design to Install Sat Phones in Main Control

Room and Technical Support Center

EP000222

Emergency Dose Projection System (URI)

EP000385

CGS Site-Specific FLEX Strategies Training

(10/15/2016)

FLEX-01

FLEX Program Document

GO2-14-174

Energy Northwests NEI 12-01 Phase 2 Staffing

Assessment

2/23/2014

LE-18-013

Licensing Basis Impact Evaluation: FLEX-01,

Revision 2

5/29/2018

LS-18-0273

LBIE Screening for License Basis Changes: FLEX-

01, Rev. 2

5/29/2018

ME-02-12-06

Evaluation of the Use of Portable Equipment During

an Extended Loss of AC Power (ELAP) during a

Beyond Design Basis External Event (BDBEE)

ME-02-13-22

Extended Loss of AC (ELAP) in Conjunction with a

Volcanic Ashfall Event - Combustion Air Filters

ME-02-92-37

SBO Loss of Control Room Ventilation

ME-02-92-41

Ultimate Heat Sink Analysis

NE-02-90-39

Removal of Computer Loads

R23 SDSP

Shutdown Safety Plan - R23

TM-2183

Implementation of FLEX Strategies Used to Cope

With a Beyond Design Basis External Event

(BDBEE)

TM-2185

Equipment refueling Strategy of Phase 1 and 2 FLEX

Components During the First 72 Hours Following an

ELAP

TM-2187

Actions, Limitations, and Notes Associated with an

Extended Loss of AC Power

Vendor Manual

CAT Operation and Maintenance Manual C15

Generator Set

October

2013

Drawings

(Number)

Title

Revision

or Date

21S001.002.101.5

01.502

Diesel Generator Building 82

ML18232A432

SUNSI Review

By: RDA/rdr

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

Keyword:

NRC-002

OFFICE

SPE:DRP/A

SRI:DRP/A

SRI:DRP/B

PM/RI:NRR/DLP

BC:DRP/A

NAME

RAlexander

GKolcum

DBradley

KRoche

MHaire

SIGNATURE

/RA/

/RA-E/

/RA-E/

/RA-E/

/RA/

DATE

07/31/18

8/8/18

8/6/18

8/14/18

8/20/18