ML18304A362
| ML18304A362 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/31/2018 |
| From: | Mark Haire NRC/RGN-IV/DRP |
| To: | Sawatzke B Energy Northwest |
| References | |
| IR 2018003 | |
| Download: ML18304A362 (36) | |
See also: IR 05000397/2018003
Text
.
October 31, 2018
Mr. Brad Sawatzke, Chief Executive Officer
Energy Northwest
MD 1023
P.O. Box 968
Richland, WA 99352
SUBJECT: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION
REPORT 05000397/2018003
Dear Mr. Sawatzke:
On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Columbia Generating Station. On October 15, 2018, the NRC inspectors
discussed the results of this inspection with Mr. Alex Javorik, Vice President, Engineering, and
other members of your staff. The results of this inspection are documented in the enclosed
report.
NRC inspectors documented three findings of very low safety significance (Green) in this report.
These findings involved violations of NRC requirements. The NRC is treating these violations
as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
Further, inspectors documented a licensee-identified violation which was determined to be of
very low safety significance in this report. The NRC is also treating this violation as an NCV
consistent with Section 2.3.2 of the Enforcement Policy.
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
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the
NRC resident inspectors at the Columbia Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC resident inspectors at the Columbia Generating Station.
B. Sawatzke 2
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 Haire, Branch Chief
Project Branch A
Division of Reactor Projects
Docket No. 50-397
License No. NPF-21
Enclosures:
1. Inspection Report 05000397/2018003
2. Request for Information: Occupational
Radiation Safety Inspection
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Number: 05000397
License Number: NPF-21
Report Number: 05000397/2018003
Enterprise Identifier: I-2018-003-0030
Licensee: Energy Northwest
Facility: Columbia Generating Station
Location: Richland, Washington
Inspection Dates: July 1, 2018 to September 30, 2018
Inspectors: G. Kolcum, Senior Resident Inspector
L. Brandt, Resident Inspector
R. Alexander, Senior Project Engineer
N. Hernandez, DRS Operations Engineer
J. ODonnell, DRS Health Physicist
Approved By: M. Haire, Branch Chief
Project Branch A
Division of Reactor Projects
Enclosure 1
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Columbia Generating Station in
accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs
program for overseeing the safe operation of commercial nuclear power reactors. Refer to
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified
findings are summarized in the table below. A licensee-identified non-cited violation is
documented in the Inspection Results at the end of this report.
List of Findings and Violations
Failure to Follow Radiologically Controlled Area Procedures
Cornerstone Significance Cross-cutting Inspection
Aspect Procedure
Occupational Green H.12 - Avoid 71124.01 -
Radiation NCV 05000397/2018003-01 Complacency Radiological
Safety Opened and Closed Hazard
Assessment
and
Exposure
Controls
The inspectors reviewed a self-revealed Green, non-cited violation of Technical
Specification 5.4.1(a) when the licensee failed to implement radiation control procedures.
Failure to Control Workers in a High Radiation Area (>1.0 rem per hour)
Cornerstone Significance Cross-cutting Inspection
Aspect Procedure
Occupational Green H.4 - 71124.01 -
Radiation NCV 05000397/2018003-02 Teamwork Radiological
Safety Opened and Closed Hazard
Assessment
and
Exposure
Controls
The inspectors reviewed a self-revealed Green, non-cited violation of Technical
Specification 5.7.2(b) and (e) when the licensee failed to control worker activities in a locked
high radiation area in accordance with the requirements of the radiation work permit and failed
to determine radiological conditions in the work area prior to the start of work.
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Failure to Adequately Control Work Hours for Covered Personnel
Cornerstone Significance Cross-cutting Inspection
Aspect Procedure
Emergency Green H.5 - Work 71152 -
Preparedness NCV 05000397/2018003-03 Management Problem
Opened and Closed Identification
and
Resolution
The inspectors identified a Green, non-cited violation of 10 CFR 26.205 associated with the
licensees failure to adequately schedule and control work hours for personnel subject to work
hour controls. Specifically, the licensee failed to appropriately schedule and control work
hours for at least three Chemistry Technicians who were providing covered work as the
designated Emergency Response Organization Duty Chemistry Technician as defined by the
Columbia Generating Station Emergency Plan.
3
PLANT STATUS
The plant began the inspection period at 100 percent rated thermal power. On August 4, 2018,
the reactor unit was down powered to 93 percent to remove the adjustable speed drive from
service for maintenance. On August 5, 2018, the unit was down powered to 74 percent to
recover the adjustable speed drive channel, and the unit was returned to rated thermal power
later that same day. On September 22, 2018, the unit was down powered to 83 percent to
perform control rod sequence exchange and turbine bypass valve testing. The unit was
returned to rated thermal power on September 22, 2018, and remained at or near rated thermal
power for the remainder of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/
reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were
declared complete when the IP requirements most appropriate to the inspection activity were
met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
Seasonal Extreme Weather (1 Sample)
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the
onset of seasonal hot temperatures on July 13 - 17, 2018.
71111.04 - Equipment Alignment
Partial Walkdown (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) low pressure core spray system on July 10, 2018
(2) high pressure core spray system on July 27, 2018
(3) control room emergency filter unit, WMA-FN-54A, on August 6, 2018
(4) reactor core isolation cooling system on August 21, 2018
(5) standby service water room coolers on September 20, 2018
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the fuel pool
cooling system on September 28, 2018.
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71111.05AQFire Protection Annual/Quarterly
Quarterly Inspection (5 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Fire Zones 47-64, transformer yard, on July 9, 2018
(2) Fire Area RC-1/2, radwaste building 437 feet elevation, on August 6, 2018
(3) Fire Area R-3/#, high pressure core spray pump room, on August 16, 2018
(4) Fire Area R-6/2, reactor core isolation cooling pump room, on August 16, 2018
(5) Fire Area R-4/2, residual heat removal system B pump room, on September 6, 2018
Annual Inspection (1 Sample)
The inspectors evaluated fire brigade performance on September 26, 2018.
71111.07Heat Sink Performance
Heat Sink (1 Sample)
The inspectors evaluated high pressure core spray diesel generator 3 diesel cooling water
heat exchanger, DCW-HX-1C, performance on August 29, 2018, and diesel generator 2
diesel cooling water heat exchangers, DCW-HX-1A1 and DCW-HX1A2, on
September 6, 2018.
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
Operator Requalification (1 Sample)
The inspectors observed and evaluated a licensed operator requalification evaluated scenario
on August 6, 2018.
Operator Performance (1 Sample)
The inspectors observed and evaluated operator performance during residual heat removal
heat exchanger 1A testing on September 11, 2018.
71111.12Maintenance Effectiveness
Routine Maintenance Effectiveness (1 Sample)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) high pressure core spray system planned maintenance, week of July 23, 2018
5
71111.13Maintenance Risk Assessments and Emergent Work Control (8 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) yellow risk for reactor core isolation cooling surveillances, week of July 9, 2018
(2) orange risk due to high pressure core spray system maintenance, week of July 23, 2018
(3) green risk during control room envelope test, week of August 6, 2018
(4) yellow risk for reactor core isolation cooling maintenance, week of August 13, 2018
(5) yellow risk for reactor core isolation cooling surveillances on September 14, 2018
(6) yellow risk for standby service water system B maintenance, September 17-18, 2018
(7) green risk for reactor building crane roof operations, week of September 17, 2018
(8) yellow risk for standby gas treatment train B maintenance, week of September 24, 2018
71111.15Operability Determinations and Functionality Assessments (3 Samples)
The inspectors evaluated the following operability determinations and functionality
assessments:
(1) fire pump FP-P-110 failed to start on July 17, 2018
(2) reactor pressure vessel level transmitter MS-LT-61A, leaking fitting, on August 1, 2018
(3) Division 1 and Division 2, 120 Vac power supply inverter and inverter transfer switch, on
August 31, 2018
71111.19Post Maintenance Testing (6 Samples)
The inspectors evaluated the following post maintenance tests:
(1) low pressure core spray circuit breaker and mechanism operated cell (MOC) switch on
July 3, 2018
(2) high pressure core spray maintenance on July 25, 2018
(3) reactor pressure vessel level transmitter MS-LT-61A leak repair on August 1, 2018
(4) adjustable speed drive maintenance on August 4, 2018
(5) control room emergency filter unit WMA-FN-54A maintenance on August 8, 2018
(6) reactor core isolation cooling keepfill pump replacement on August 15, 2018
71111.22Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (4 Samples)
(1) OSP-MS-Q701, Turbine Valve Surveillance, Revision 1, on July 1, 2018
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(2) OSP-SLC/IST-Q701, Standby Liquid Control Pumps Operability Test, Revision 27, on
July 11, 2018
(3) OSP-HPCS/IST-Q701, High Pressure Core Spray Quarterly Surveillance Test,
Revision 54, on July 25, 2018
(4) OSP-SW/IST-Q702, Standby Service Water Loop B Operability, Revision 34,on
September 18, 2018
In-service (1 Sample)
(1) OSP-LPCS/IST-Q702, LPCS System Operability Test, Revision 42, on July 3, 2018
71114.06Drill Evaluation
Drill/Training Evolution (1 Sample)
The inspectors evaluated the Emergency Plan drill on September 25, 2018.
RADIATION SAFETY
71124.01Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (1 Sample)
The inspectors evaluated radiological hazards assessments and controls.
Instructions to Workers (1 Sample)
The inspectors evaluated worker instructions.
Contamination and Radioactive Material Control (1 Sample)
The inspectors evaluated contamination and radioactive material controls.
Radiological Hazards Control and Work Coverage (1 Sample)
The inspectors evaluated radiological hazards control and work coverage.
High Radiation Area and Very High Radiation Area Controls (1 Sample)
The inspectors evaluated risk-significant high radiation area and very high radiation area
controls.
Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
The inspectors evaluated radiation worker performance and radiation protection technician
proficiency.
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71124.03In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 Sample)
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices (1 Sample)
The inspectors evaluated respiratory protection.
Self-Contained Breathing Apparatus for Emergency Use (1 Sample)
The inspectors evaluated the licensees self-contained breathing apparatus program.
OTHER ACTIVITIES - BASELINE
71151Performance Indicator Verification (3 Samples)
The inspectors verified licensee performance indicators submittals listed below:
(1) MS05: Safety System Functional Failures (SSFFs) Sample (06/01/2017 -
06/30/2018)
(2) OR01: Occupational Exposure Control Effectiveness Sample (04/01/2017 -
06/30/2018)
(3) PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation
Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent
Occurrences Sample (04/01/2017 - 06/30/2018)
71152Problem Identification and Resolution
Annual Follow-up of Selected Issues (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1) management of personnel work hours per the Fatigue Rule (10 CFR 26, Subpart I) on
June 21 - July 31, 2018
(2) standby service water B pumphouse tornado missile door on August 20, 2018
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INSPECTION RESULTS
Licensee-Identified Non-Cited Violation 71124.01-
Radiological Hazard
Assessment and
Exposure Controls
This violation of very low safety significance was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a non-cited
violation, consistent with Section 2.3.2 of the Enforcement Policy.
Violation: Title 10 CFR 20.1902(a) requires the licensee to post each radiation area with a
conspicuous sign bearing the radiation symbol and the words "CAUTION, RADIATION
AREA."
Contrary to the above, from November 9, 2017 to November 13, 2017, the licensee failed to
post a radiation area with a conspicuous sign bearing the radiation symbol and the words
"CAUTION, RADIATION AREA."
The licensee moved two resin liners with high dose rates into the turbine building truck bay.
Once the resin liners were in the turbine building truck bay, a high radiation area boundary
was posted around them. However, the dose rates outside the truck bay doors were not
verified. On November 13, 2017, the licensee, while conducting routine area surveys,
identified an unposted radiation area outside the turbine building truck bay doors, which
resulted from the resin liners inside of the truck bay area. The licensee secured the radiation
area and adequately posted it, as required.
Significance/Severity Level: Green
Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety
Significance Determination Process, dated August 19, 2008, the inspectors determined the
finding was not related to ALARA planning, did not involve an overexposure or substantial
potential for overexposure, and the ability to assess dose was not compromised. For these
reasons, the inspectors concluded that the finding is of very low safety significance (Green).
Corrective Action Reference: AR 00373739
Failure to Follow Radiologically Controlled Area Procedures
Cornerstone Significance Cross-cutting Aspect Inspection Procedure
Occupational Green H.12 - Avoid IP 71124.01 -
Radiation NCV 05000397/2018003-01 Complacency Radiological Hazard
Safety Opened and Closed Assessment and
Exposure Controls
The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 5.4.1(a) when the licensee failed to implement radiation control procedures.
9
Description: On June 1, 2017, a supplemental health physics technician (HPT) entered a
posted locked high radiation area without a functioning electronic dosimeter (ED). Although
the area was posted as a locked high radiation area (LHRA), there were no measured dose
rates in excess of 1 rem per hour during this entry.
The HPT logged on to Radiation Work Permit (RWP) 30003852 and entered the radiologically
controlled area (RCA) to cover a job to add additional shielding in the travelling in-core probe
(TIP) Mezzanine room. The HPT entered the RCA through the HP swing gate near the RCA
exit point, in order to obtain survey instruments for the job coverage. The HPT proceeded to
the dress out area and then to the TIP Mezzanine room, where he entered with a survey
meter. After about 10 minutes in the room, the HPT looked at his ED and noticed that it was
in pause mode (i.e., not functioning). The HPT informed the worker he was covering, and
they both left the LHRA.
During the RWP logging process, there was an error when the HPTs ED was being
programmed that went unnoticed. As a result, the HPT was signed-on to the RWP, but the
ED was not programmed and active. Because the HPT used the HP swing gate at the RCA
exit rather than the normal access point with electronic turnstiles that verify ED function, this
errant condition was not identified. The swing gate used was intended for HPTs assigned to
assist workers with contamination alarms at the RCA exit, not as an RCA entry point to
perform work or cover a job.
Licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From Radiologically
Controlled Areas, Section 4.13 Dosimetry and Log-in, paragraph (e), requires workers to
ensure that electronic dosimetry is on immediately before entering the RCA. The HPT neither
used the electronic turnstiles nor checked to see if the ED was on prior to entering the RCA.
Additionally, licensee Procedure 11.2.7.3 High Radiation Area, Locked High Radiation Area,
and Very High Radiation Area Controls, Section 3.2.4 Coverage and Monitoring of Work,
paragraph (d), describes conducting a peer-check prior to LHRA entries, by the job coverage
HPT, to verify that workers are wearing an active ED (i.e., not in pause mode) in the
appropriate location on the body. The job coverage HPT checked to see that workers had an
ED appropriately placed, but did not check the ED setpoints or if the ED was active.
Multiple barriers that could have prevented this situation from occurring were either ineffective
or not used. Had the error reduction/prevention measures been used, the ED programming
error during RWP log on would have been identified.
Corrective Action(s): An immediate corrective action, in addition to the HPT being restricted
from the RCA, was a stand down conducted with radiation protection personnel about this
incident and coaching on use of the procedures related to the verification of dosimetry and
peer-checking prior to entry into LHRAs.
Corrective Action Reference: AR 00366701
Performance Assessment:
Performance Deficiency: Failure to follow station procedures for entry into a radiologically
controlled area is a performance deficiency.
10
Screening: The inspectors determined the performance deficiency was more than minor
because it adversely affected the program and process attribute of the Occupational
Radiation Safety Cornerstone to ensure the adequate protection of the worker health and
safety from exposure to radiation from radioactive material during routine civilian nuclear
reactor operation, in that failure to comply with exposure monitoring and radiation protection
controls has the potential to increase dose. Specifically, licensee requirements to control
workers exposure were not implemented by the HPT.
Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety
Significance Determination Process, dated August 19, 2008, the inspectors determined
finding was not related to ALARA planning, did not involve an overexposure or substantial
potential for overexposure, and the ability to assess dose was not compromised. For these
reasons, the inspectors concluded that the finding is of very low safety significance (Green).
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated
with avoiding complacency, in that the individual did not implement appropriate error
reduction tools. Specifically, the individual failed to use the electronic turnstile and also failed
to check to see if the electronic dosimeter was on prior to entering the posted locked high
radiation area [H.12].
Enforcement:
Violation: Technical Specification 5.4.1(a) requires, in part, the implementation of written
procedures as outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978,
Section 7(e), Radiation Protection Procedures.
Contrary to the above, on June 1, 2017, the licensee failed to implement written procedures
for radiation protection. Specifically, the licensee failed to implement Sections 3.4 and
4.1.3(e) of licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From
Radiologically Controlled Areas.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Control Workers in a High Radiation Area (>1.0 rem per hour)
Cornerstone Significance Cross-cutting Inspection Procedure
Aspect
Occupational Green H.4 - Teamwork IP 71124.01 - Radiological
Radiation Safety NCV Hazard Assessment and
05000397/2018003-02 Exposure Controls
Opened and Closed
The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification (TS) 5.7.2(b) and (e) when the licensee failed to control worker activities in a locked high
radiation area in accordance with the requirements of the RWP and failed to determine
radiological conditions in the work area prior to the start of work.
Description: On June 20, 2017, the licensee failed to control the work activities of riggers
working in a locked high radiation area. The high risk activity involved moving an unshielded
TTDF-34 filter vessel that was used for the wet well cleanup from the 471 foot elevation of the
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reactor building (RX 471) to the 441 foot elevation of the reactor building (RX 441) truck bay
to place it in a disposable shield. The unshielded filter vessel radiation levels were 84.3 rem
per hour on contact and 52.8 rem per hour at 30 centimeters. The truck bay was closed and
guarded as a locked high radiation area (LHRA) during the filter vessel movement.
At 1:30 pm, a high risk brief was conducted for the filter vessel movement followed by a
briefing for the LHRA conditions and restrictions of the radiation work permit (RWP). The
brief included discussion of information on the RWP including the expected (i.e., calculated)
radiological conditions at various distances from the filter vessel, the use of continuous
radiation protection coverage for fields greater than 0.8 rem per hour, the electronic dosimeter
(ED) setpoints of 200 millirem for dose and 1.2 rem per hour for dose rate. The brief also
addressed the use of pre-staged shielding and long handled tools by the riggers. The HPT
conducting the brief (the job-coverage HPT) stated that an HPT must be present to approach
the filter vessel and informed the riggers not to be closer than thirty feet from the unshielded
filter vessel. The riggers asked if the setpoints were high enough and the HPT confirmed that
they were. At about 2:30 p.m., the two riggers logged on to RWP 3001279.
At 2:52 p.m., prior to the movement of the filter vessel from RX 471 to the truck bay on
RX 441, the two riggers entered the truck bay to prepare their work area. Once the filter
vessel was in motion from RX 471, the HPT covering the filter vessel movement proceeded to
the truck bay to provide radiation protection coverage for the two riggers as the filter vessel
was being lowered. The HPT arrived at the guarded truck bay door expecting to find the
riggers outside, but the riggers were already inside the truck bay. At 5:38 p.m., the HPT
entered the truck bay and found the riggers standing about 10 feet away from the shielded
cask with the unshielded filter vessel suspended about 15 feet overhead. At that point, one of
the riggers ED was alarming, with a dose rate of 1.52 rem per hour. Both riggers were
informed by the HPT to immediately leave the area. In order to leave the work in a safe
condition, the master rigger signaled the crane operator to stop movement and proceeded to
exit.
Subsequent to the event, the master rigger who received the ED alarm stated that he was
required to be in the truck bay when a load is being lifted out of or lowered into it. He stated
that he believed he was about 15 feet away from the filter vessel and that the position was as
far from the filter vessel as he could be to safely see the load being lowered.
The inspectors noted that the LHRA technical specification (TS 5.7.2) requires that activities
in LHRAs shall be controlled by means of an RWP that includes specification of dose rates in
the immediate work area and other appropriate radiation protection measures. Additionally,
entry into LHRAs shall be made only after dose rates in the area have been determined and
entry personnel made knowledgeable of them.
The inspectors also noted that licensee Procedure 11.2.7.3 High Radiation Area, Locked
High Radiation Area, and Very High Radiation Area Controls, Section 6.3, Controls to
Prevent Unplanned or Excessive Personnel Exposures, states in paragraph 6.3.6 that work
areas with dose rates greater than 1.5 rem per hour require continuous RP coverage as
either by line-of-sight or by remote means, and that continuous coverage means that the HPT
is capable of intervening to control a workers actions through direct or remote means.
Paragraph 6.3.6 continues by stating that continuous monitoring without the means to control
or constrain worker actions should not be used in place of continuous coverage.
12
Discussions with the licensee revealed that the estimated dose rates specified in the RWP
were calculated based on the contact readings of the unshielded filter vessel. However, no
confirmatory measurements were made of the RX 441 truck bay to determine the actual dose
rates prior to allowing worker entry. As such, the riggers entered the truck bay without the
required coverage HPT present and without the benefit of a survey of current radiological
conditions. The unanticipated ED alarm was an indication that riggers were unaware of the
current dose rates in the truck bay and that they were higher than what was calculated given
the indicated distance and the ED response.
Effective communication and coordination of this activity could have prevented this situation
from occurring. The licensees investigation of the ED alarm revealed that rigger workers
were used to conducting this work activity in a certain manner (i.e., positioning themselves to
see the load being safely lowered). From the riggers perspective, to ensure safety during the
lift, they needed to approach the vessel in order to direct the crane operator to land the load
safely. The riggers questioned the dose rate setpoint during the LHRA brief, but were told by
the HPT that it was sufficient without understanding the riggers safety perspective. As a
result, the riggers failed to understand the radiological restrictions and instructions conveyed
during the RWP and high risk briefings.
The inspectors concluded that two of the conditions for LHRA entry were not met. The
riggers failed to understand the radiological control requirements, and entered the truck bay
(impending LHRA) without continuous RP coverage, contrary to the RWP requirement.
Additionally, there was no radiological survey of the truck bay with the filter vessel present to
validate the calculated estimate so that the riggers could be made knowledgeable of the
conditions. Further, as the filter vessel was lowered creating the LHRA conditions, the HPT
was not in position to determine the radiological conditions or to control (intervene) in the
activities of the workers.
Corrective Action(s): The individuals involved exited the area and a recovery plan was
implemented. The riggers were coached on the requirements to follow the RWP and all
briefing instructions.
Corrective Action References: ARs 00368063 and 00368480
Performance Assessment:
Performance Deficiency: The failure to control worker activities and to determine current
radiological conditions prior to entry into a locked high radiation area was a performance
deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it adversely affected the program and process attribute of the Occupational
Radiation Safety Cornerstone to ensure the adequate protection of the worker health and
safety from exposure to radiation from radioactive material during routine civilian nuclear
reactor operation. Specifically, the failure to comply with exposure control measures in a
locked high radiation area has the potential for increased dose.
Significance: Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation
Safety Significance Determination Process, dated August 19, 2008, the finding was not an
ALARA finding, there was no overexposure or substantial potential for overexposure, and the
13
licensees ability to assess dose was not compromised. Therefore the safety significance of
the finding would be very low (Green).
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated
with teamwork, in that individuals and work groups did not communicate and coordinate their
activities within and across organizational boundaries to ensure nuclear safety is maintained.
Specifically, the riggers and the health physics technician failed to effectively communicate
their perspectives and expectations on safety for this high risk evolution and also failed to
effectively coordinate their activities in the locked high radiation area during the evolution
[H.4].
Enforcement:
Violation: Technical Specification 5.7.2, High Radiation Areas with Dose Rates Greater
than 1.0 rem/hour (at 30 cm from the radiation source), paragraph (b) requires, in part, that
activities shall be controlled by means of a radiation work permit that includes specification of
appropriate radiation protection measures, and paragraph (e) requires, in part, that entry shall
be made only after dose rates in the area have been determined and entry personnel are
knowledgeable of them.
Contrary to the above, on June 20, 2017, during work in a high radiation area with dose rates
greater than 1.0 rem per hour, the licensee failed to control activities by means of a radiation
work permit that included specification of appropriate radiation protection measures, and
entry was made prior to dose rates in the area having been determined and entry personnel
knowledgeable of them. Specifically, two workers entered the reactor building truck bay (a
locked high radiation area) and were present as a filter vessel with a dose rate of 52.8 rem
per hour at 30 cm was being lowered into it. Prior to arrival of the health physics technician,
required by the radiation work permit for continuous radiation protection coverage for work in
whole body dose rates greater than 800 millirem per hour, one of the workers received a dose
rate alarm of 1.52 rem per hour. Because a health physics technician was not present to
determine the actual dose rates (in contrast to calculated dose rates that had been briefed) in
the area while the load was being lowered, the workers were uninformed of the radiological
conditions.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Failure to Adequately Control Work Hours for Covered Personnel
Cornerstone Significance Cross-cutting Report
Aspect Section
Emergency Green NCV H.5 - Work 71152
Preparedness NCV 05000397/2018003-03 Management
Opened and Closed
The inspectors identified a Green, non-cited violation of 10 CFR 26.205 associated with the
licensees failure to adequately schedule and control work hours for personnel subject to work
hour controls. Specifically, the licensee failed to appropriately schedule and control work
hours for at least three Chemistry Technicians who were providing covered work as the
designated Emergency Response Organization (ERO) Duty Chemistry Technician as defined
by the Columbia Generating Station Emergency Plan.
14
Description: In reviewing licensee documentation relative to work hour controls in accordance
with the requirements in 10 CFR 26, Subpart I (10 CFR 26.205), for various workgroups
across the station, the inspectors noted an example where a Chemistry staff member
appeared to have worked 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in a 7-day period on at least one occasion in
September 2017. The inspectors noted that this was in excess of the limits established in the
licensees Procedure SWP-FFD-004, Work Hour Controls, Revision 9, Section 3.4.4, which
states in part The following controls apply to covered workers (Definition 5.9) regardless of
unit status No more than 72 work hours in any 7 day period. The inspectors identified
this apparent issue to the licensee to determine if the Chemistry staff member was completing
covered work during the period, and whether a waiver had been processed to allow this staff
member to exceed the work hour requirement in accordance with Section 3.6 of
SWP-FFD-004.
In response to the inspectors questions, the licensee determined that a work hour controls
waiver had not been processed for the particular instance noted by the inspectors. Further,
the licensee noted that the one staff member exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period on three
separate occasions in late August through late September 2017. The same staff member did
not receive the 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> off in a 9-day period two times in that period, and also did not have
the required average days off over a 6-week cycle twice during the period. (These additional
controls are further requirements described in Section 3.4.4 of SWP-FFD-004.) As part of an
extent of condition review, the licensee identified a total of 11 examples where Chemistry staff
members worked hours in excess of the controls described in SWP-FFD-004, Section 3.4.4,
and no waiver was processed, in the period of review of July 2017 through April 2018. The
licensees review found the following contributed to the issues identified:
1. The supervisors lack of verification and validation of the data being input into the work
hours tracking software.
2. A breakdown in communication between the supervisor and technicians as to whether
or not a work hours waiver was necessary, and the actions required of the parties
involved to request the waivers.
3. General lack of familiarity by the Chemistry staff with Procedure SWP-FFD-04 and the
requirements associated with obtaining a waiver.
4. Inadequate validation of assumptions by the Chemistry staff members that a waiver
would cover them to exceed specific work hour/fatigue rules for an extended period of
time.
Also, the inspectors reviewed additional work hour records for other departments whose staff
were subject to work hour/fatigue rules and could involve staff transitioning between covered
and non-covered work activities. Specifically, records from Radiation Protection, Operations
(whose members support the Fire Brigade), and Security were reviewed for the same time
periods described above. The inspectors review of the work hour records for these additional
departments did not identify any additional discrepancies/violations of the work hour/fatigue
rules within or outside of the Chemistry Department. As such, the inspectors concluded that
the issues identified appear to have been isolated within the Chemistry Department.
15
Corrective Actions: The licensee entered the identified violations of the work hours rules into
the corrective action program, and initiated the following corrective actions:
1. Creation of a job aid to assist Chemistry staff/supervisors in implementing work hours
and overtime controls, in support of data entry into the station tracking software.
2. Additional training to supervisors and staff with job-related functions in the work hours
tracking software and the impacts of SWP-FFD-04.
3. Revision of Procedure CI-1.14, Chemistry Department FFD Fatigue Management, to
implement a process for an independent check of the Chemistry Department data
entered into the work hours tracking software in accordance with SWP-FFD-04.
Corrective Action References: AR 00379991, AR 00381017, and AR 00381551
Performance Assessment:
Performance Deficiency: The licensees failure to control work hours for Chemistry staff
covered by the requirements of 10 CFR 26.205, was determined to be a performance
deficiency.
Screening: The performance deficiency is more than minor because it is associated with the
ERO [emergency response organization] readiness attribute of the Emergency Preparedness
cornerstone and adversely affects the cornerstone objective that the licensee is capable of
implementing adequate measures to protect the health and safety of the public in the event of
a radiological emergency. Specifically, the Chemistry staff members in question were
providing covered work as the designated ERO Duty Chemistry Technician as defined by the
Columbia Generating Station Emergency Plan, and therefore were subject to the work hour
controls to manage worker fatigue as described in 10 CFR 26, Subpart I, as implemented by
licensee Procedure SWP-FFD-004. As such, the licensee emergency response personnel
(on-shift chemistry staff) may not have been capable of implementing adequate measures to
protect the health and safety of the pubic if they were excessively fatigued.
Significance: The finding was evaluated using Inspection Manual Chapter 0609, Appendix B,
Emergency Preparedness Significance Determination Process, dated September 22, 2015,
and was determined to be of very low safety significance (Green). The finding had a very low
safety significance because it was a failure to comply with NRC requirements, was not
associated with a risk significant planning standard function, and was not a loss of planning
standard function. The finding was not a loss of planning standard function because there
was not a loss of emergency response organization minimum staffing (on-shift Chemistry).
Specifically, this finding was determined to be associated with a degraded planning standard
function in that the process to ensure that the on-shift chemistry technician was staffed with a
non-fatigued individual was challenged on several occasions during the period of July through
October 2017.
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated
with work management, in that the organization did not implement a process of planning,
controlling, and executing work activities such that nuclear safety is the overriding priority,
including the identification and management of risk commensurate to the work. Specifically,
the licensee failed to establish a verification/validation process for the Chemistry supervisors
16
to provide reasonable assurance that the technician work hours were accurately entered and
tracked [H.5].
Enforcement: Title 10 CFR 26.4(a) states in part that "All persons who are granted
unescorted access to nuclear power reactor protected areas by the licensees in § 26.3(a) ...
and perform the following duties shall be subject to a [fitness for duty] program..." and lists
one function as "(2) Performing health physics or chemistry duties required as a member of
the onsite emergency response organization minimum shift complement." Further,
10 CFR 26.205 states, in part, that individuals who perform duties identified in § 26.4(a)(1)
through (a)(5) shall be subject to the requirements of 10 CFR 26, Subpart I, and that
licensees shall calculate, schedule, and control the work hours of individuals who are subject
to that section.
Contrary to the above, from July through October 2017, for at least three individuals
performing chemistry duties required as a member of the onsite emergency response
organization minimum shift complement (to which 10 CFR 26.205 applies), the licensee failed
to assure that work hours were scheduled and controlled. In response to this issue, the
licensee developed actions to ensure that work hours for chemistry technicians were
adequately controlled including development of a user aid, additional training, and
independent validation of information entered into the work hours tracking software. This
issue does not represent an immediate safety concern because at the time of discovery no
personnel were in excess of work hour requirements, and the licensee took actions to prevent
occurrence in the future.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
On September 19, 2018, the inspectors presented the radiation protection baseline inspection
results to Mr. R. Schuetz, Vice President, Operations, Mr. A. Javorik, Vice President,
Engineering, and other members of the licensee staff. The inspectors verified no proprietary
information was retained or documented in this report. On October 3, 2018, the inspectors held
a follow-up telephonic exit with Mr. R. Schuetz, Vice President, Operations, Mr. D. Brown,
General Manager, Plant Operations, and other members of the licensee staff to clarify the
significance of an additional radiation protection issue discussed during the inspection, but not
presented in the on-site exit meeting stated above. The additional issue was a minor violation,
so the call was administrative in nature to validate the licensee understood the issues
significance. On October 15, 2018, the inspectors held a follow-up telephonic exit with Mr. R.
Schuetz, Vice President, Operations, Mr. D. Brown, General Manager, Plant Operations, and
other members of the licensee staff to communicate a change in the characterization of the
inspection results.
On October 15, 2018, the inspectors presented the quarterly resident inspector inspection
results to Mr. A. Javorik, Vice President, Engineering, and other members of the licensee staff.
The inspectors verified no proprietary information was retained or documented in this report.
17
DOCUMENTS REVIEWED
71111.01 - Adverse Weather Protection
Action Requests
370257 379411 369975 370063
382228 380608 380616 380310
382752 382753 382754
Work Orders
29137990 29137991 02098735
Procedures
(Number) Title Revision
SOP-COLDWEATHER-OPS Cold Weather Operations 030
SOP-HOTWEATHER-OPS Hot Weather Operations 006
SOP-WARMWEATHER- Warm Weather Operations 015
SOP-SW-SPRAY Standby Service Water Spray Header Operations 000
Miscellaneous
Documents
(Number) Title Revision
ME-02-92-43 Calculation for Room Temperature for DG Building and 012
R and W and SW Pumphouse Under Design Basis
Accident Conditions
ME-02-92-41 Calculation for Ultimate Heat Sink Analysis 007
ME-02-85-79 Calculation for Spray Pond Temperature Transient 003
Without Sprays
71111.04 - Equipment Alignment
Procedures
(Number) Title Revision
1.3.29 Locked Valve Checklist 079
ABN-FPC-LOSS Loss of Fuel Pool Cooling 016
ABN-HPCS-DEPRESS HPCS Recovery Following Depressurization From 003
Keep Fill Failure
SOP-FPC-ASSIST-ALT Alternate Fuel Pool Cooling Assist 011
SOP-FPC-OPS Fuel Pool Cooling and Cleanup Operations 007
SOP-FPC-SHUTDOWN FPC Shutdown 003
SOP-FPC-SPC FPC Suppression Pool Operations 011
SOP-FPC-SST FPC Skimmer Surge Tank Operations 005
SOP-FPC-START Fuel Pool Cooling Start 006
SOP-HPCS-LV HPCS Valve and Breaker Lineup 004
SOP-HPCS-M102 HPCS Valve Lineup 004
SOP-HPCS-STBY Placing HPCS in Standby Status 003
18
Procedures
(Number) Title Revision
SOP-LPCS-STBY Placing LPCS in Standby Status 002
SOP-LPCS-LU LPCS Valve and Breaker Lineup 003
SOP-RCIC-LU RCIC Valve and Breaker Lineup 004
SOP-RCIC-STBY Placing RCIC in Standby Status 011
SOP-SW-M103 HPCS Service Water Valve Position Verification 024
Drawings
(Number) Title Revision
M519 Reactor Core Isolation Cooling System Flow Diagram 102
M520 HPCS and LPCS Systems Reactor Building Flow Diagram 104
M200-103 Low Pressure Core Spray System Isometric Diagram 017
RCIC-656-5.8 Suction from Suppression Pool to RCIC Pump RCIC-P-1 017
RCIC-659-1.2 RCIC Pump to RCIC Vessel 011
71111.05AQFire Protection Annual/Quarterly
Action Requests
382268 382272 383100 385162
Procedures
(Number) Title Revision
1.3.10 Plant Fire Protection Program Implementation 034
1.3.10A Control of Ignition Sources 017
1.3.10B Active Fire System Operability and Impairment Control 015
1.3.10C Control of Transient Combustibles 020
1.9.13 Transformer Yard Access and Controls 019
FPP-1.7 Fire Tour Implementation 006
PFP-MN-XMR-YD-MISC PFP-MN-XMR-YD-MISC Bldgs 006
PFP-RB-422 Reactor 422 006
PFP-RW-437-452 RADWASTE 437-452 005
SFI-26 Fire Tour 002
SWP-FPP-01 Nuclear Fire Protection Program 008
Miscellaneous
Documents Revision or
(Number) Title Date
FP-02-85-03 Calculation for FSAR Update Including Fire Loading in 010
General Room and Floor Areas
Fire Brigade Training Drill Cycle 18-1 Crew E Critique January 18, 2018
Fire Brigade Training Drill Cycle 18-3 Crew F Critique May 31, 2018
Fire Brigade Training Drill Cycle 18-4 Crew F Critique August 23, 2018
Fire Brigade Unannounced Drill 18-001 Crew A Critique October 1, 2018
71111.07Heat Sink Performance
Action Requests
384028 384029
19
Work Orders
02100975 02123992 02126970 02126200
02126970 02100975 02080164 02105918
02023553 02106204 02084429 02106205
02084430
Procedures
(Number) Title Revision
1.5.13 Preventive Maintenance Optimization Living Program 040
8.4.54 Thermal Performance Monitoring for DCW-HX-1A1 and 010
DCW-HX-1A2
8.4.63 Thermal Performance Monitoring of DCW-HX-1C 010
Drawings
(Number) Title Revision
M512-2 Flow Diagram Diesel Oil & Miscellaneous Systems 037
M524-1 Flow Diagram Standby Service Water System Reactor, 138
Radwaste, D.G. Bldgs and Yard
Miscellaneous
Documents
(Number) Title Revision
02E22-07,54,3 HPCS Diesel Generator 012
ME-02-92-243 Calculation for DCW-HX-1C Design Performance 003
Requirements
MOT-HX-1-1 Heat Exchangers 012
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
Procedures
(Number) Title Revision
1.3.1 Operating Policies, Programs and Programs 127
5.1.1 RPV Control 021
5.2.1 Primary Containment Control 027
5.3.1 Secondary Containment Control 020
13.1.1 Classifying the Emergency 049
OI-09 Operations Standards and Expectation 070
OSP-RCIC/IST-Q701 RCIC Operability Test 061
Miscellaneous
Documents
(Number) Title Revision
Crew D Evaluated Scenario Cycle 18-4, 4.0 Critique 000
Summary
LR002425 Cycle 18-4 Evaluated Scenario 000
20
71111.12Maintenance Effectiveness
Action Requests
369836 372031 366178 366220
368573 369803 363774 334979
336819 324924 340031 343726
351952 362949 364950 366788
Procedures
(Number) Title Revision
1.5.11 Maintenance Rule Program 015
OSP-SW/IST-Q703 HPCS Service Water Operability 027
SOP-HPCS-CST/SP HPCS CST and Suppression Pool Operations 014
SYS-4-22 Maintenance Rule Program 014
71111.13Maintenance Risk Assessments and Emergent Work Control
Action Requests
337916 382706
Work Orders
02098551 02097647 02121918 02132528
02095968 02101599 02130842
Procedures
(Number) Title Revision
1.3.76 Integrated Risk Management 049
1.3.76 Integrated Risk Management 050
1.3.76 Integrated Risk Management 051
1.3.83 Protected Equipment Program 026
8.4.42 Thermal Performance Monitoring of RHR-HX-1A and 012
RHR-HX-1B
ESP-RCIC-X301 RCIC Turbine Speed Monitor - CC 004
ISP-RCIC-Q901 RCIC Isolation on RCIC Steam Supply Flow High 024
DIV 1-CFT/CC
ISP-RCIC-Q903 RCIC Isolation on RCIC Steam Supply Flow High 019
DIV 2-CFT/CC
OSP-RCIC/IST-Q701 RCIC Operability Test 061
OSP-RCIC/IST-Q702 RCIC Valve Operability Test 043
OSP-RCIC-M101 RCIC Fill, Flow Controllers, and Valve Lineup Verification 017
SOP-SW-DRAIN Standby Service Water Drain 008
WCI-1 Unit Coordinator BPA Duties 008
21
71111.15Operability Determinations and Functionality Assessments
Action Requests
382900 382882 383452 383440
383703 383698 366967 383232
383236 383054 383057
Work Orders
02130891 02131541 02131542 02131543
02131544 02131545 02131593
Procedures
(Number) Title Revision
1.10.11 Technical Assessments Supporting Reportability and 002
Reportability Evaluations
OPEX-01 Operating Experience Program Implementation Manual 009
SWP-OPX-01 Operating experience Program 000
Drawings
(Number) Title Revision
E-504-1 Vital One Line Diagram 006
71111.19Post Maintenance Testing
Action Requests
265493 382110 382674 382784
PER 205-0024 382426 374860
Work Orders
02093978 02116384 02089875 02089987
02089995 02095010 02096336 02130586
02128698 02108899 02122111 02122391
02129438
Procedures
(Number) Title Revision
10.2.3 Pump Packing Replacement and Adjustment 013
10.2.54 Pump Testing 009
10.24.248 Visual Examination of Electronic Components, Circuit 000
Boards, and Solder Joints
10.25.105 Motor Control Center and Switchgear Maintenance 035
10.25.13 Westinghouse Medium Voltage Circuit Breakers 034
ISP-MS-X312, DIV 1 Channel A Isolation Actuation on Level 1 and Reactor 006
Level 2 - Channel Calibration
OSP-ELEC-S703 HPCS Diesel Generator Semi-Annual Operability Test 062
22
Procedures
(Number) Title Revision
OSP-LPCS/IST-Z702 LPCS System Operability Test 042
OSP-WMA-B701 Control Room Ventilation System A Pressurization Flow 020
Test
SOP-RCIC-FILL RCIC Fill and Vent 017
Miscellaneous
Documents (Number) Title Revision
Channel A Isolation Actuation on Reactor Level 1 and 006
Reactor Level 2 - Channel Calibration
71111.22Surveillance Testing
Action Requests
353783 358013 359298 360016
360021 353864 382785
Work Orders
02090774 02094071 02098015 02114831
02122412 02117436 02114670 02130842
02103225 02101890
Procedures
(Number) Title Revision
4.601.A3 601.A3 Annunciator Panel Alarms 027
DBD 316 Design Specification for Low Pressure Core Spray 011
EWD-15E-014 Reactor Protection System Trip System B Sensor Relays 005
IST-4 Inservice Testing Program Plan Fourth Ten-Year 001
Inspection Interval
OSP-MS-S701 Turbine Valve Surveillance 001
OSP-RPS-Q401 Turbine Throttle Valve Closure CFT 002
OSP-RPS-S401 Turbine Throttle Valve Closure CFT 000
OSP-SLC/IST-Q701 Standby Liquid Control Pumps Operability Test 026
SD000192 System Description Low Pressure Core Spray (LPCS) 013
SWP-IST-01 ASME Inservice Testing 003
71114.06Drill Evaluation
Procedures
(Number) Title Revision
1.3.1 Operating Policy, Programs, and Practices 127
5.1.1 RPV Control 021
5.2.1 Primary Containment Control 027
5.3.1 Secondary Containment Control 020
13.1.1 Classifying the Emergency 049
23
Procedures
(Number) Title Revision
13.10.1 Control Room Operation and Shift Manager Duties 035
13.10.2 TSC Manager Duties 035
13.2.1 Emergency Exposure Levels, Protective Action Guides 022
13.2.2 Determining Protective Actions 020
13.4.1 Emergency Notifications 043
13.5.1 Local, Protected Area, or Site Evacuation 029
13.9.1 Environmental Field Monitoring Operations 045
13.10.9 Operations Support Center Manager and Staff Duties 049
13.11.1 EOF Manager Duties 044
13.13.1 Reentry Operations 010
13.13.3 Intermediate Phase MUDAC Operations 018
13.13.4 After Action Reporting 010
13.14.9 Drill and Exercise Program 029
OI-09 Operations Standards and Expectations 070
71124.01Radiological Hazard Assessment and Exposure Controls
Procedures
(Number) Title Revision
GEN-RPP-04 Entry Into, Conduct In, and Exit From Radiologically 032
Controlled Areas
HPI-0.19 Radiation Protection Standards and Expectations 018
SWP-RPP-01 Radiation Protection Program 016
PPM 11.2.7.1 Area Posting 043
PPM 11.2.13.1 Radiation and Contamination Surveys 040
PPM 11.2.24.1 Radiation Protection Work Routines 035
PPM 11.2.7.3 High Radiation Area, Locked High Radiation Area, and Very 042
High Radiation Area Controls
PPM 11.2.14.4 Procurement, Receipt, Control and Leak Testing of 024
Radioactive Sealed Sources and Devices
PPM 11.2.13.8 Airborne Radioactivity Surveys 019
PPM 11.2.14.9 Control and Labeling of Radioactive Material 021
PPM 1.11.15 Control of Radioactive Material 013
PPM 6.1.1 Spent Fuel Pool Inventory 010
Audits and Self-
Assessments
(Number) Title Date
AR-SA 374280 Occupational Exposure Control Effectiveness May 25, 2018
AR-SA 374283 Performance Indicator Verification PR-01 June 7, 2018
AR-SA 375035-06 Radiological Hazard Assessment and Exposure July 9, 2018
Controls
AU-RP/RW-17 QA Audit: Radiation Protection and Process Control December 18,
Programs 2017
24
Action Requests
366701 367332 368222 368480
368651 369180 370737 373739
379010 379636 381763 381764
Radiation Surveys
M-20170601-11 M-20170620-11 M-20170620-12 M-20170624-1
M-20170813-3 M-20170830-4 M-20170906-5 M-20180717-3
M-20180721-4 M-20180807-3 M-20180807-5 M-20180830-1
M-20180830-4 M-20180905-4 M-20180910-1 M-20180910-1
M-20180912-5
Air Samples
875805 875816 895915 907092
Radiation Work
Permits Title Revision
30001279 R23 WW Packaging TTDF-34 Filter *LHRA* *High Risk* STK 001
30003852 R23 RX/WW , RP Surveys & Job Coverage **LHR** 000
30003986 2017 RW 487 WEA Fan Rem/Replace Pre-Filter *HR*High
001
Contam*
30004141 2018 RX 501 TIP Room/TIP Drive Room **HRA** 000
30004147 2018 TG 501 W. Labyrinth PMs & Surveillance ***LHRA*** 000
30004200 2018 RW 437 Waste Processing NUPAC Cage **LHRA** 001
Miscellaneous
Documents Revision
(Number) Title or Date
CGS Radioactive Source Inventory - Non-Exempt August 21,
2018
374337 Information for NSTS Annual Inventory Reconciliation January 15,
2018
W/O 2119710 HSP-SSC-0801 Sealed Source Leakage Verification April 9, 2018
30001279 High Risk Plan for R23 WW Packaging 003
TTDF-34 Filter
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Procedures
(Number) Title Revision
25
GEN-RPP-05 Respiratory Protection Program Description 015
GEN-RPP-10 Use of Respiratory Protection Equipment 012
HPI-15.1 Inspection and Storage of Respirators and Attachments 011
HPI-15.5 Set Up and Use of Bullard Air Line Filters 003
PPM 11.2.11.3 Issuance of Respiratory Protection Equipment 017
PPM 13.14.4 Emergency Equipment Maintenance and Testing 054
Audits and Self-
Assessments
(Number) Title Date
AR-SA 301868-03 Respiratory Protection Self-Assessment April 14, 2017
AR-SA 00357502 71124.03 Self-Assessment March 5,
2018
AU-RP/RW-17 QA Audit: Radiation Protection and Process Control December 18,
Programs 2017
Action Requests
371385 347601 347688 347689
377412
Radiation Work
Permits (Number) Title Revision
30004034 R23 TG 501 Sandblasting Tent Work 000
30004161 2018 RW 437 / 452 / 467 High Rad Work ***HR*** 002
30004152 2018 RW 487 Chemistry Lab High Radiation Areas *HR* 001
SCBA Records
(Number) Title Date
67833 Calibration Certificate August 13,
2018
67958 Calibration Certificate August 13,
2018
67993 Calibration Certificate August 15,
2018
W/O 2123630 Fire Brigade Station Inventory TG 501 and MCR July 26, 2018
In Place Filter
Testing Records
Work Order Title Date
02074192 MSP-WMA-B104 - WMA-FU-54B - Carbon Adsorber Test September 22,
2016
26
In Place Filter
Testing Records
Work Order Title Date
02074207 MSP-WMA-B102 - WMA-FU-54B - HEPA Filter Test September 22,
2016
02081424 MSP-WMA-B101 - WMA-FU-54A - HEPA Filter Test August 3,
2016
02083458 MSP-WMA-B103 - WMA-FU-54A - Carbon Adsorber Test August 3,
2016
02083554 AMA-CF-52 Replace Carbon, Inspect March 8, 2018
(FILTR-1-1-9.3)
Miscellaneous
Documents (Number) Title Date
OK 581518 Certificate of Analysis June 20, 2018
SA-V-99/35 Analysis of Air Samples for Breathing Air July 26, 2018
W/O 2123630 Fire Brigade Station Inventory TG 501 and MCR September 26,
2018
71151Performance Indicator Verification
Procedures
(Number) Title Revision
SWP-OPS-02 Safety Function Determination Program 007
71152Problem Identification and Resolution
Action Requests
379991 381017 381551 379120
379504 307821 009924 383966
383951 280168 383773
Work Orders
02128878 02128879 02059398
Procedures
(Number) Title Revision
1.5.13 Preventive Maintenance Optimization Living Program 039
EC 17325 Evaluation for Service Water (SW) Pumphouse Swinging 000
Door B-DOOR-G200 Supporting SW Operability with the
Designated Shear Pins Not Engaged
SWP-FFD-03 Fatigue Management 005
SWP-FFD-04 Work Hour Controls 009
27
Drawings
(Number) Title Revision
AED-ARC-A555 Door Schedule Sheet 3 030
CVI-DWG-210-23 Spec. Section 8L Exterior Missile Doors G100 & G200 003
Miscellaneous
Documents Revision
(Number) Title or Date
Schedule Report for Radiation Protection May 10, 2018
(8/2017 - 10/2017, 1/2018 - 2/2018)
Schedule Report for Chemistry June 20, 2018
(8/2017 - 10/2017, 1/2018 - 2/2018)
Schedule Report for Operations June 4, 2018
(8/2017 - 10/2017, 1/2018 - 2/2018)
Schedule Report for Security May 9, 2018
(8/2017 - 10/2017, 1/2018 - 2/2018)
Plant General Manager & Department Manager Work July 6, 2017
Hour Reviews per SWP-FFD-04 (January 1 to June
30, 2017)
Plant General Manager & Department Manager Work January 30,
Hour Reviews per SWP-FFD-04 (July 1 to December 2018
30, 2017)
AED-SPC-08L Design Specification for Division 8 Section 8L Exterior 002
Missile Doors G100 and G200
28
The following items are requested for the
Occupational Radiation Safety Inspection
at Columbia
Dates of Inspection: 09/10/2018 to 09/14/2018
Integrated Report 2018003
Inspection areas are listed in the attachments below.
Please provide the requested information on or before Wednesday, August 22, 2018.
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 inspector 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 John O'Donnell at 817-200-1441 or via
e-mail at John.ODonnell@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.
29 Enclosure 2
1. Radiological Hazard Assessment and Exposure Controls (71124.01) and
Performance Indicator Verification (71151)
Date of Last Inspection: May 26, 2017
A. List of contacts and telephone numbers for the Radiation Protection Organization Staff
and Technicians. Please include area code and prefix. If work cell numbers are
appropriate, then please include them as well.
B. Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C. Copies of audits, self-assessments, LARs, and LERs written since the last inspection
date, related to this inspection area
D. Procedure indexes for the radiation protection procedures and other related disciplines.
E. Please provide procedures related to the following areas noted below. Additional
procedures may be requested by number after the inspector reviews the procedure
indexes.
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations, if not included in #1.
3. Personnel Dosimetry
4. Posting of Radiological Areas
5. High Radiation Area Controls
6. RCA Access Controls and Radiation Worker Instructions
7. Conduct of Radiological Surveys
8. Radioactive Source Inventory and Control
9. Fuel Pool Inventory Access and Control
F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G. Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) since the last inspection date.
1. Initiated by the radiation protection organization
2. Assigned to the radiation protection organization
NOTE: These lists should include a description of the condition that provides sufficient
detail that the inspector can ascertain the regulatory impact, the significance level
assigned to the condition, the status of the action (e.g., open, working, closed,
etc.) and the search criteria used. Please provide in document formats which are
sortable and searchable so that inspector can quickly and efficiently determine
appropriate sampling and perform word searches, as needed. (Excel
spreadsheets are the preferred format.) If codes are used, please provide a
legend for each column where a code is used.
H. List of radiologically significant work activities scheduled to be conducted during the
inspection period. (If the inspection is scheduled during an outage, please also include a
list of work activities greater than 1 rem, scheduled during the outage with the dose
30
estimate for the work activity.) Please include the radiological risk assigned to each
activity.
I. Provide a summary of any changes to plant operation that have resulted or could result
in a significant new radiological hazard. For each change, please provide the
assessment conducted on the potential impact and any monitoring done to evaluate it.
J. List of active radiation work permits and those specifically planned for the on-site
inspection week.
K. Please provide a list of air samples taken to verify engineering controls and a separate
list for breathing air samples in airborne radiation areas or high contamination work
areas. Please include the RWP the breathing air sampling supports.
L. Please provide the current radioactive source inventory, listing all radioactive sources
that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,
Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and
current activity (w/assay date), and storage location for each applicable source.
M. The last two leak test results for the Category 1 or 2 radioactive sources and any other
radioactive source(s) that have failed its leak test within the last two years. Provide any
applicable condition reports.
N. A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate
dose rates (Contact / @ 30cm)
O. A list of radiological controlled area entries greater than 100 millirem, since the last
inspection date. The list should include the date of entry, some form of worker
identification, the radiation work permit used by the worker, dose accrued by the worker,
and the electronic dosimeter dose alarm set-point used during the entry (for
Occupational Radiation Safety Performance Indicator verification in accordance with
IP 71151).
P. A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.
Include their current status, locations, and control measures.
Q. Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally
closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay
doors). Include any CRs associated with this monitoring or instrumentation.
31
3. In-Plant Airborne Radioactivity Control and Mitigation (71124.03)
Date of Last Inspection: March 4, 2016
A. List of contacts and telephone numbers for the following areas. Please include area
code and prefix. If work cell numbers are appropriate, then please include them as well.
1. Respiratory Protection Program
2. Self-contained breathing apparatus
3. Ventilation Systems for breathing air (not effluents)
B. Applicable organization charts including position or job titles. Please include as
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Engineering, and Emergency Protection. (Recent pictures are appreciated.)
C. Copies of audits, self-assessments, vendor, or NUPIC audits for contractor support
(SCBA), LARs, and LERs, written since the date of last inspection related to:
1. Installed air filtration systems
2. Self-contained breathing apparatuses
D. Procedure index for Radiation Protection, Maintenance, I&C, and other related
disciplines.
1. Use, operation, and maintenance of installed and portable continuous air monitors
2. Use operation, and maintenance of installed air filtration units for breathing air (e.g.,
for airline respirators, emergency ventilation systems).
3. Use, operation, and maintenance of temporary air filtration units and vacuums
4. Respiratory protection and other related disciplines
E. Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. Respiratory protection program
2. Use and maintenance of self-contained breathing apparatuses
3. Air quality testing for SCBAs or other compressed or supplied air systems
4. Use and testing of installed plant air cleaning systems used for breathing air, such as
control room emergency ventilation, technical support center, operations support
center, and emergency operations facility (When containment purge is not used as
an effluent system, then it can be considered as a breathing air system used prior to
outages during RCS breach and flood up.)
F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
committed to relative to this program. Please include the revision and/or date for the
commitment and where this may be located in your current licensing basis documents.
G. Please provide a summary list of corrective action documents (including corporate and
sub-tiered systems) written since the date of last inspection, related to the Airborne
Monitoring program including:
1. In-plant continuous air monitors (installed or portable), not effluent monitors
2. Self-contained breathing apparatus
3. Air Cleaning systems (not effluent)
4. Respiratory protection program
NOTE: These lists should include a description of the condition that provides
32
sufficient detail that the inspector can ascertain the regulatory impact, the
significance level assigned to the condition, the status of the action (e.g., open,
working, closed, etc.) and the search criteria used. Please provide in document
formats which are sortable and searchable so that inspector can quickly and
efficiently determine appropriate sampling and perform word searches, as needed.
(Excel spreadsheets are the preferred format.) If codes are used, please provide a
legend for each column where a code is used.
H. List of SCBA qualified personnel - reactor operators and emergency response
personnel. For the control room individuals, please indicate their normally scheduled
shift and specific mask size, as well as note if they are permitted/fitted for eyewear.
I. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant
for use since the date of last inspection.
J. SCBA training and qualification records for control room operators, shift supervisors,
STAs, and OSC personnel for the last year.
A selection of personnel may be asked to demonstrate proficiency in donning, doffing,
and performance of functionality check for respiratory devices.
K. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,
model, quantity by size, and location. Be prepared to demonstrate that these respirators
are NIOSH certified.
Include in the list the specific quantities and sizes staged for emergency use.
L. Provide one-line drawings of the supplied air and air cleaning systems identified in E.3
and E.4 above.
M. List work activities requiring respiratory protection and the type of respirator used
(include PAPRs).
N. Please have available, on-site, the records demonstrating the compressed air for SCBAs
or supplied air for a breathing air system is at least Grade D.
33
SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: MSH Yes No Publicly Available Sensitive NRC-002
OFFICE SRI:DRP/A RI:DRP/A DRS/IPAT DRS/EB1 DRS/EB2 DRS/PSB2
NAME GKolcum LMerker GMiller TFarnholtz GWerner HGepford
SIGNATURE GJK LNM GBM TRF GEW HJG
DATE 10/29/18 10/29/18 10/29/18 10/29/2018 10/29/2018 10/29/2018
OFFICE DRS/OB SPE:DRP/A BC:DRP/A
NAME VGaddy RAlexander MHaire
SIGNATURE vgg RDA /MSH
DATE 10/29/18 10/29/2018 10/31/18