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| number = ML18116A407
| number = ML18116A407
| issue date = 04/25/2018
| issue date = 04/25/2018
| title = Columbia - NRC Integrated Inspection Report 05000397/2018001
| title = NRC Integrated Inspection Report 05000397/2018001
| author name = Haire M S
| author name = Haire M
| author affiliation = NRC/RGN-IV/DRP
| author affiliation = NRC/RGN-IV/DRP
| addressee name = Sawatzke B J
| addressee name = Sawatzke B
| addressee affiliation = Energy Northwest
| addressee affiliation = Energy Northwest
| docket = 05000397
| docket = 05000397
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:ril 25, 2018
[[Issue date::April 25, 2018]]


Mr. Brad Sawatzke Interim Chief Executive Officer Energy Northwest MD 1023 P.O. Box 968 Richland, WA 99352
==SUBJECT:==
COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018001


SUBJECT: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018001 D ear Mr. Sawatzke: O n March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Columbia Generating Statio On April 19, 2018, the NRC inspectors discussed the results of this inspection with Mr. G. Hettel, Vice President for Operations, and other members of your staf The results of this inspection are documented in the enclosed repor NRC inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of NRC requirement The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Polic If you contest the violation or significance of this NCV , you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555
==Dear Mr. Sawatzke:==
-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and th e NRC resident inspector at the Columbia Generating Station. If you disagree with a cross
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Columbia Generating Station. On April 19, 2018, the NRC inspectors discussed the results of this inspection with Mr. G. Hettel, Vice President for Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.
-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 Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555
-0001; with copies to the Regional Administrator, Region IV; and th e NRC resident inspector at the Columbia Generating Station. UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD ARLINGTON, TX 76011
-4511 B.Sawatzke2 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.ht ml and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."


Sincerely,/RA/ Mark Haire, Chief Project Branch A Division of Reactor Projects Docket N License No. NPF-21
NRC inspectors documented one finding of very low safety significance (Green) in this report.


===Enclosure:===
This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
Inspection Report 05000397/2018001 w/


===Attachment:===
If you contest the violation or significance of this NCV, 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 inspector at the Columbia Generating Station.
Documents Reviewed


B.Sawatzke3 COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018001 - APRIL 25, 2018 DISTRIBUTION KKennedy, RA SMorris, DRA TPruett, DRP AVegel, DRS RLantz, DRP JClark, DRS SKirkwood, RC MHaire, DRP RAlexander, DRP LNewman, DRP DLackey, DRP GKolcum, DRP LBrandt, DRP MBennett, DRP JBowen, RIV/OEDO VDricks, ORA JWeil, OCA JKlos, NRR AMoreno, RIV/CAO BMaier, RSLO GGeorge, IPAT EUribe, IPAT MHerrera, DRMA R4Enforcement ROP Reports SUNSI Review:ADAMS: Non-Publicly AvailableNon-SensitiveKeyword: By: MSH2/dllYes NoPublicly AvailableSensitive NRC-002 OFFICE SRI:DRP/A RI:DRP/A DRS/EB1 DRS/EB2 DRS/OB DRS/PSB2 NAME GKolcum LBrandt TFarnholtz JDrake VGaddy HGepford SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 04/24/18 04/25/2018 04/24/2018 04/24/2018 4/25/18 04/24/18 OFFICE DRS/IPAT SPE:DRP/A BC:DRP/A NAME GGeorge RAlexander MHaire SIGNATURE /RA/ /RA/ /RA/ DATE 4/25/201 8 04/24/18 4/25/18 OFFICIAL RECORD COPY
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 inspector at the Columbia Generating Station. 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.


1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
Sincerely,
05000397 License Number:
/RA/
NPF-21 Report Number:
Mark Haire, Chief Project Branch A Division of Reactor Projects Docket No. 50-397 License No. NPF-21 Enclosure:
05000397/2018001 Enterprise Identifier:
Inspection Report 05000397/2018001 w/ Attachment: Documents Reviewed
I-2018-001-0010 Licensee: Energy Northwest Facility: Columbia Generating Station Location: Richland, Washington Inspection Dates:
January 1, 2018 to March 31, 2018 Inspectors:
G. Kolcum, Senior Resident Inspector L. Brandt, Resident Inspector P. Elkmann, Senior Emergency Preparedness Inspector J. Braisted, Reactor Inspector S. Hedger, Emergency Preparedness Inspector E. Ruesch, Senior Reactor Inspector Approved By:
M. Haire, Chief Project Branch A Division of Reactor Projects
 
2


=SUMMARY=
=SUMMARY=
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensee's performance by conducting an integrated inspection at Columbia Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRC's program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRC's assessment are summarized in the table below.
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. Findings and violations being considered in the NRCs assessment are summarized in the table below.


List of Findings and Violations Failure to Follow Procedure Leads to Loss of Secondary Containment Cornerstone Significance Cross-cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2018001
List of Findings and Violations Failure to Follow Procedure Leads to Loss of Secondary Containment Cornerstone           Significance                               Cross-cutting       Report Aspect               Section Barrier Integrity     Green                                     H.5 - Work          71153 -
-01 Closed H.5 - Work Management 71153 - Follow-up of Events and Notices of Enforcement Discretion The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a for the licensee's failure to perform maintenance in accordance with documented instructions appropriate to the circumstances. Specifically, on September 12, 2017 , the failure to verify power sources per Work Order 020 72924 caused a n electrical transient that caused the reactor building exhaust valve and supply valve to lo se power and close, resulting in a loss of secondary containment.
NCV 05000397/2018001-01                   Management       Follow-up of Closed                                                      Events and Notices of Enforcement Discretion The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to perform maintenance in accordance with documented instructions appropriate to the circumstances. Specifically, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.


Additional Tracking Items Type Issue Number Title Report Section Status LER 05000397/2017003
Additional Tracking Items Type     Issue Number                 Title                             Report         Status Section LER     05000397/2017003-00         Momentary Loss of                 71153          Closed Secondary Containment Due to Weather LER     05000397/2017005-00         Valve Closure Results in         71153          Closed Momentary Increase in Secondary Containment Pressure LER     05000397/2017006-00         Condition Prohibited by           71153          Closed Technical Specifications Due to Incomplete Action Statement
-00 Momentary Loss of Secondary Containment Due to Weather 71153 Closed LER 05000397/2017005
-00 Valve Closure Results in Momentary Increase in Secondary Containment Pressure 71153 Closed LER 05000397/2017006
-00 Condition Prohibited by Technical Specifications Due to Incomplete Action Statem ent 71153 Closed 3


=PLANT STATUS=
=PLANT STATUS=
The plant began the inspection period at 100 percent rated thermal power. On January 6, 2018, the unit was down-powered to 7 2 percent for turbine valve testing and a control rod sequence exchange. The unit was returned to 100 percent rated thermal power on January 6 , 2018. On March 31, 2018, the unit was down-powered to 7 0 percent for turbine valve testing and a control rod sequence exchange. The unit was returned to 100 percent rated thermal power on March 31, 2018.


INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection period unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading
The plant began the inspection period at 100 percent rated thermal power. On January 6, 2018, the unit was down-powered to 72 percent for turbine valve testing and a control rod sequence exchange. The unit was returned to 100 percent rated thermal power on January 6, 2018. On March 31, 2018, the unit was down-powered to 70 percent for turbine valve testing and a control rod sequence exchange. The unit was returned to 100 percent rated thermal power on March 31,
-rm/doc-collections/insp
 
-manual/inspection
==INSPECTION SCOPES==
-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
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection period 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.
-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.
 
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==
==REACTOR SAFETY==
71111.01 - Adverse Weather Protection Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions associated with high winds on February 17, 2018
. External Flooding (1 Sample)  The inspectors evaluated readiness to cope with external flooding on January 12, 2018. 71111.04 - Equipment Alignment Partial Walkdown (5 Sample s)  The inspectors evaluated system configurations during partial systems/trains walkdowns:
  (1) diesel generator 1 starting air on February 6, 2018 (2) diesel generator 2 starting air on February 22, 2018 (3) diesel generator 3 starting air on February 26, 2018 (4) diesel generator 3 governor on March 12, 2018 (5) diesel generator 2 governor on March 29, 2018 Complete Walkdown (1 Sample)
The inspectors evaluated standby service water loop A system configurations during a complete walkdown on January 12, 2018 71111.05AQ
- Fire Protection Annual/Quarterly Quarterly Inspection (6 Samples)  The inspectors evaluated fire protection program implementation in the following selected areas:  (1) Fire Area R
-6/2:  RCIC Pump Room on January 8, 2018 (2) Fire Area R
-7/1:  RHR-C Pump Room on January 9, 2018 (3) Fire Area R
-8/1:  LPCS Pump Room on January 10, 2018 (4) Fire Area RC
-13/2:  Chiller, Communications, I & C Area on January 26, 2018 (5) Fire Area RC
-11/1:  HVAC Equipment Room "A" Division 1 on January 26, 2018 (6) Fire Area RC
-12/2:  HVAC Equipment Room "B" Division 2 on January 26, 2018  71111.06 - Flood Protection Measures Internal Flooding (1 Sample)  The inspectors evaluated internal flooding mitigation protections
:  (1) Reactor Building 422' level on February 14, 2018 Cables (1 Sample)  The inspectors evaluated cable submergence protection:  (1) Manhole E-MH-E8 on February 22, 2018 (2) Manhole E-MH-01B, 10, 11, 13, 15 on February 28, 2018  71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification (1 Sample)  The inspectors observed and evaluated a crew during a simulator evaluated scenario for licensed operator requalification training on January 22, 2018.


Operator Performance (1 Sample) The inspectors observed and evaluated operator performance during the following activities
==71111.01 - Adverse Weather Protection    Impending Severe Weather==
: (1) maintenance on main generator seal oil pressure regulator on January 9, 2018 (2) diesel generator 3 testing on January 24, 2018 71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness (5 Sample s)  The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
{{IP sample|IP=IP 71111.01|count=1}}
  (1) fire pump 110 starting issue on January 10, 2018 (2) standby service water loop B planned maintenance
 
, week of January 15, 2018 (3) diesel generator 3 annual preventive maintenance
The inspectors evaluated readiness for impending adverse weather conditions associated with high winds on February 17, 2018.
, week of January 22, 2018 (4) SM4 relay testing on February 27, 2018 (5) diesel generator 2 12
 
-year maintenance, March 19
===External Flooding (1 Sample)===
-30, 2018 Quality Control (1 Sample) The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:  
The inspectors evaluated readiness to cope with external flooding on January 12, 2018.
  (1) main control room emergency chiller B maintenance, week of February 19, 2018 71111.13 - Maintenance Risk Assessments and Emergent Work Control (8 Sample s)  The inspectors evaluated the risk assessments for the following planned and emergent work activities:
 
  (1) yellow risk due to standby service water system A maintenance
==71111.04 - Equipment Alignment    Partial Walkdown==
, w eek of January 1, 2018 (2) yellow risk due to maintenance on main generator seal oil pressure regulator on January 9, 2018 (3) yellow risk for d iesel generator 3 maintenance on January 22, 2018 (4) yellow risk for circuit breaker S/2 maintenance on January 24, 2018 (5) yellow risk for maintenance on backup transformer, February 16
{{IP sample|IP=IP 71111.04|count=5}}
-17, 2018 (6) yellow risk for standby gas treatment B and SM4 relay testing, February 26
 
-28, 2018 (7) yellow risk for diesel generator 3 24
The inspectors evaluated system configurations during partial systems/trains walkdowns:
-hour load test and loss of coolant accident test , March 1-3, 2018 (8) yellow risk for diesel generator 2 12
: (1) diesel generator 1 starting air on February 6, 2018
-year maintenance, March 19-30, 2018 71111.15 - Operability Determinations and Functionality Assessments (7 Sample s)  The inspectors evaluated the following operability determinations and functionality assessments:
: (2) diesel generator 2 starting air on February 22, 2018
  (1) diesel generator 3 diesel oil valve DO
: (3) diesel generator 3 starting air on February 26, 2018
-V-14 on January 22, 2018 (2) diesel generator 3 exhaust thermocouple on January 24, 2018 (3) diesel generator 3 temperature test switch on January 25, 2018 (4) main control room emergency chiller B unexpected start during tagout on February 18, 2018 (5) high pressure core spray motor oil on March 8, 2018 (6) diesel generator 2 engine governor on March 28, 2018 (7) diesel generator 2 fuel oil pump on March 29, 2018 71111.18 - Plant Modifications (5 Sample s)  The inspectors evaluated the following temporary or permanent modifications:
: (4) diesel generator 3 governor on March 12, 2018
  (1) Engineering Change (EC)14954, CCH Bypass Line, Emergency Chilled Water, on Januar y 24, 2018 (2) Temporary Modification (TM)16326 , adjust setpoint of containment instrument air pressure control valve on February 2, 2018 (3) E C 16860 setpoint change on DG air start reducing valve pressure on February 9, 2018 (4) T M 16170 main control room chille r B bearing high temp switch on February 16, 2018 (5) EC 16066 vital island fire protection installation on March 31, 2018 71111.19 - Post Maintenance Testing (9 Sample s)  The inspectors evaluated the following post maintenance tests: (1) fire pump 110 maintenance on January 10, 2018 (2) standby service water loop B maintenance on January 16, 2018 (3) diesel generator 3 maintenance on January 25, 2018   (4) TR-B backup transformer maintenance on February 17, 2018 (5) t ower make-up pump C maintenance on February 21, 2018 (6) f uel pool cooling pump B maintenance on February 23, 2018 (7) RHR-V-68B standby service water supply isolation to residual heat removal heat exchanger 1B maintenance on February 26, 2018 (8) RHR-V-116 cross tie connection from standby service water maintenance on March 1, 2018 (9) diesel generator 2 12-year outage on March 2 9, 2018 71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:
: (5) diesel generator 2 governor on March 29, 2018
Routine (5 Sample s)  (1) service water spray pond quarterly surveillance test per OSP-SW-Q101, on January 4, 2018 (2) main steam isolation valve SCRAM closure test per OSP-RPS-S402, on January 7, 2018 (3) diesel generator 3 load testing per TSP-DG3-B502, on March 2, 2018 (4) diesel generator 3 loss of coolant accident test per TSP-DG3/LOCA-B501, on March 3, 2018 (5) main turbine bypass valve testing per OSP-MS-Q702, on March 31, 2018 In-service (1 Sample) (1) residual heat removal loop A operability test per OSP-RHR/IST-Q702, on February 7, 2018 71114.01 - Exercise Evaluation (1 Sample)
 
The inspectors evaluated the licensee's biennial emergency plan exercise and subsequent identification of performance weaknesses. The exercise scenario simulated the following on March 27, 2018
===Complete Walkdown (1 Sample)===
: (1) a loss of feedwater heating causing a power excursion which required the reactor be shut down (2) a problem with the reactor protection system which failed to shut down the reactor (3) a failure of some control rods to insert into the reactor (4) an unisolable pipe break on the reactor water clean
The inspectors evaluated standby service water loop A system configurations during a    complete walkdown on January 12, 2018
-up system outside of containment (5) an unfiltered and monitored radioactive release from the radioactive waste building through the plant vent which increased in activity over time (6) emergency depressurization of the reactor 71114.04 - Emergency Action Level and Emergency Plan Changes (1 Sample)  The inspectors evaluated submitted Emergency Action Level changes in-office on January 30, 2018. This evaluation does not constitute NRC approval.
 
==71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection==
{{IP sample|IP=IP 71111.05AQ|count=6}}
 
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) Fire Area R-6/2: RCIC Pump Room on January 8, 2018
: (2) Fire Area R-7/1: RHR-C Pump Room on January 9, 2018
: (3) Fire Area R-8/1: LPCS Pump Room on January 10, 2018
: (4) Fire Area RC-13/2: Chiller, Communications, I & C Area on January 26, 2018
: (5) Fire Area RC-11/1: HVAC Equipment Room A Division 1 on January 26, 2018
: (6) Fire Area RC-12/2: HVAC Equipment Room B Division 2 on January 26, 2018
 
==71111.06 - Flood Protection Measures    Internal Flooding==
{{IP sample|IP=IP 71111.06|count=1}}
 
The inspectors evaluated internal flooding mitigation protections:
: (1) Reactor Building 422 level on February 14, 2018
 
===Cables (1 Sample)===
The inspectors evaluated cable submergence protection:
: (1) Manhole E-MH-E8 on February 22, 2018
: (2) Manhole E-MH-01B, 10, 11, 13, 15 on February 28, 2018
 
==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance    Operator Requalification==
{{IP sample|IP=IP 71111.11|count=1}}
 
The inspectors observed and evaluated a crew during a simulator evaluated scenario for licensed operator requalification training on January 22, 2018.
 
===Operator Performance (1 Sample)===
The inspectors observed and evaluated operator performance during the following activities:
: (1) maintenance on main generator seal oil pressure regulator on January 9, 2018
: (2) diesel generator 3 testing on January 24, 2018
 
==71111.12 - Maintenance Effectiveness   Routine Maintenance Effectiveness==
{{IP sample|IP=IP 71111.12|count=5}}
 
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
: (1) fire pump 110 starting issue on January 10, 2018
: (2) standby service water loop B planned maintenance, week of January 15, 2018
: (3) diesel generator 3 annual preventive maintenance, week of January 22, 2018
: (4) SM4 relay testing on February 27, 2018
: (5) diesel generator 2 12-year maintenance, March 19-30, 2018
 
===Quality Control (1 Sample)===
The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:
: (1) main control room emergency chiller B maintenance, week of February 19, 2018
 
==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
{{IP sample|IP=IP 71111.13|count=8}}
 
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) yellow risk due to standby service water system A maintenance, week of January 1, 2018
: (2) yellow risk due to maintenance on main generator seal oil pressure regulator on January 9, 2018
: (3) yellow risk for diesel generator 3 maintenance on January 22, 2018
: (4) yellow risk for circuit breaker S/2 maintenance on January 24, 2018
: (5) yellow risk for maintenance on backup transformer, February 16-17, 2018
: (6) yellow risk for standby gas treatment B and SM4 relay testing, February 26-28, 2018
: (7) yellow risk for diesel generator 3 24-hour load test and loss of coolant accident test, March 1-3, 2018
: (8) yellow risk for diesel generator 2 12-year maintenance, March 19-30, 2018
 
==71111.15 - Operability Determinations and Functionality Assessments==
{{IP sample|IP=IP 71111.15|count=7}}
 
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) diesel generator 3 diesel oil valve DO-V-14 on January 22, 2018
: (2) diesel generator 3 exhaust thermocouple on January 24, 2018
: (3) diesel generator 3 temperature test switch on January 25, 2018
: (4) main control room emergency chiller B unexpected start during tagout on February 18, 2018
: (5) high pressure core spray motor oil on March 8, 2018
: (6) diesel generator 2 engine governor on March 28, 2018
: (7) diesel generator 2 fuel oil pump on March 29, 2018
 
==71111.18 - Plant Modifications==
{{IP sample|IP=IP 71111.18|count=5}}
 
The inspectors evaluated the following temporary or permanent modifications:
: (1) Engineering Change (EC) 14954, CCH Bypass Line, Emergency Chilled Water, on January 24, 2018
: (2) Temporary Modification (TM) 16326, adjust setpoint of containment instrument air pressure control valve on February 2, 2018
: (3) EC 16860 setpoint change on DG air start reducing valve pressure on February 9, 2018
: (4) TM 16170 main control room chiller B bearing high temp switch on February 16, 2018
: (5) EC 16066 vital island fire protection installation on March 31, 2018
 
==71111.19 - Post Maintenance Testing==
{{IP sample|IP=IP 71111.19|count=9}}
 
The inspectors evaluated the following post maintenance tests:
: (1) fire pump 110 maintenance on January 10, 2018
: (2) standby service water loop B maintenance on January 16, 2018
: (3) diesel generator 3 maintenance on January 25, 2018
: (4) TR-B backup transformer maintenance on February 17, 2018
: (5) tower make-up pump C maintenance on February 21, 2018
: (6) fuel pool cooling pump B maintenance on February 23, 2018
: (7) RHR-V-68B standby service water supply isolation to residual heat removal heat exchanger 1B maintenance on February 26, 2018
: (8) RHR-V-116 cross tie connection from standby service water maintenance on March 1, 2018
: (9) diesel generator 2 12-year outage on March 29, 2018
 
==71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests:   Routine==
{{IP sample|IP=IP 71111.22|count=5}}
: (1) service water spray pond quarterly surveillance test per OSP-SW-Q101, on January 4, 2018
: (2) main steam isolation valve SCRAM closure test per OSP-RPS-S402, on January 7, 2018
: (3) diesel generator 3 load testing per TSP-DG3-B502, on March 2, 2018
: (4) diesel generator 3 loss of coolant accident test per TSP-DG3/LOCA-B501, on March 3, 2018
: (5) main turbine bypass valve testing per OSP-MS-Q702, on March 31, 2018
 
===In-service (1 Sample)===
: (1) residual heat removal loop A operability test per OSP-RHR/IST-Q702, on       February 7, 2018
 
==71114.01 - Exercise Evaluation==
{{IP sample|IP=IP 71114.01|count=1}}
 
The inspectors evaluated the licensees biennial emergency plan exercise and subsequent identification of performance weaknesses. The exercise scenario simulated the following on March 27, 2018:
: (1) a loss of feedwater heating causing a power excursion which required the reactor be shut down
: (2) a problem with the reactor protection system which failed to shut down the reactor
: (3) a failure of some control rods to insert into the reactor
: (4) an unisolable pipe break on the reactor water clean-up system outside of containment
: (5) an unfiltered and monitored radioactive release from the radioactive waste building through the plant vent which increased in activity over time
: (6) emergency depressurization of the reactor
 
==71114.04 - Emergency Action Level and Emergency Plan Changes==
{{IP sample|IP=IP 71114.04|count=1}}
 
The inspectors evaluated submitted Emergency Action Level changes in-office on January 30, 2018. This evaluation does not constitute NRC approval.


71114.06 - Drill Evaluation Emergency Planning Drill (1 Sample)  The inspectors evaluated
==71114.06 - Drill Evaluation   Emergency Planning Drill==
:  (1) a general emergency scenario drill on February 27, 2018 71114.08 - Exercise Evaluation
{{IP sample|IP=IP 71114.06|count=1}}
- Scenario Review (1 Sample)
The inspectors conducted an in
-office review of the proposed biennial emergency plan exercise scenario between January 16 and February 22, 2018
. The inspectors also discussed the proposed scenario with staff at FEMA Region X.


==OTHER ACTIVITIES==
The inspectors evaluated:
- BASELINE  71151 - Performance Indicator Verification (6 Samples)  The inspectors verified licensee performance indicators submittals listed below:  (1) IE01:  Unplanned Scrams per 7000 Critical Hours (01/01/2017
: (1) a general emergency scenario drill on February 27, 2018
- 12/31/2017)
(2) IE03:  Unplanned Power Changes per 7000 Critical Hours (01/01/2017
- 12/31/2017)
(3) IE04:  Unplanned Scrams with Complications (01/01/2017
- 12/31/2017)
(4) EP01: Drill/Exercise Performance (01/01/2017
- 12/31/2017)
(5) EP02:  Emergency Response Organization Drill Participation (01/01/2017
- 12/31/2017)
(6) EP03:  Alert and Notification System Reliability (01/01/2017
- 12/31/2017)71152 - Problem Identification and Resolution Annual Follow
-up of Selected Issues (2 Sample s)  The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
  (1) required test for Westinghouse 480v ac circuit breaker on February 20, 2018 (2) licensee's corrective action for abnormal procedure ABN-AS H on March 31, 2018 71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports (3 Samples)  The inspectors evaluated the following Licensee Event Reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx
:  (1) LER 05000397/2017 00, Momentary Loss of Secondary Containment Due to Weather on June 26, 2017 (2) LER 05000397/2017 00, Valve Closure Results in Momentary Increase in Secondary Containment Pressure on September 12, 2017  (3) LER 05000397/2017 00, Condition Prohibited by Technical Specifications Due to Incomplete Action Statement on September 21, 2017  INSPECTION RESULTS Minor Performance Deficiency 71153 Minor Performance Deficiency:  The inspectors reviewed LER 2017 00 and determined the failure to follow Procedure OSP
-ELEC-W101, "Offsite Station Power Alignment Check," Revision 30
, was a performance deficiency.


Screening:  The performance deficiency was minor because while it was associated with the configuration control attribute of the Mitigating Systems Cornerstone, it did not adversely affect the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, when operations personnel performed the offsite station power alignment check in its entirety, all breakers were correctly aligned, and power was available for each offsite circuit.
==71114.08 - Exercise Evaluation - Scenario Review==
{{IP sample|IP=IP 71114.08|count=1}}


Failure to Follow Procedure Leads to Loss of Secondary Containment Cornerstone Significance Cross-cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2018001
The inspectors conducted an in-office review of the proposed biennial emergency plan exercise scenario between January 16 and February 22, 2018. The inspectors also discussed the proposed scenario with staff at FEMA Region X.
-01 Closed H.5 - Work Management 71153 - Follow-up of Events and Notices of Enforcement Discreti on During their inspection of LER 2017 00, the inspectors reviewed a self
-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensee's failure to perform maintenance in accordance with documented instructions appropriate to the circumstances. Specifically, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.


Description
==OTHER ACTIVITIES - BASELINE==
:  On September 12, 2017, electricians performed planned maintenance per Work Order 02072924 to replace the reactor core isolation cooling (RCIC) system direct current (DC) motor control center (MCC) buckets. As part of the work, electricians conducted live
-dead-live checks of wiring in the cubicle to check for DC voltage. The workers found DC voltage as expected and lifted the terminals, per instructions. Another live
-dead-live test for DC power was conducted which showed no voltage. While lifting a control wire, a maintenance worker believed they saw faint evidence of arcing. Another live
-dead-live test was conducted which showed no evidence of DC voltage. However, when electricians lifted the wire, it shorted out against the bucket chassis and caused a reactor building exhaust inboard isolation valve to lose power and close, resulting in a loss of secondary containment. The wire shorted because alternating current (AC) voltage was present on the control wire and the DC voltage checks were not adequate to identify the presence of AC voltage. Operations personnel responded to the incident and restored secondary containment to operable status within approximately 1 minute.


The inspectors noted Work Order 02072924 Precaution and Limitations Step 2.5 states that "electrical energy may be present, follow the requirements of ISPM
===71151 - Performance Indicator Verification ===
-7 & ISPM-20."  Step 2.6 states, in part, to "as needed, check all control wiring terminals in the cubicle for voltage prior to working in the cubicle."
{{IP sample|IP=IP 71151|count=6}}
The inspectors verified licensee performance indicators submittals listed below:
: (1) IE01: Unplanned Scrams per 7000 Critical Hours (01/01/2017 - 12/31/2017)
: (2) IE03: Unplanned Power Changes per 7000 Critical Hours (01/01/2017 - 12/31/2017)
: (3) IE04: Unplanned Scrams with Complications (01/01/2017 - 12/31/2017)
: (4) EP01: Drill/Exercise Performance (01/01/2017 - 12/31/2017)
: (5) EP02: Emergency Response Organization Drill Participation (01/01/2017 - 12/31/2017)
: (6) EP03: Alert and Notification System Reliability (01/01/2017 - 12/31/2017)


ISPM-20, "Electrical Arc Protection Work Practices and PPE Requirements," Revision 14, Step 3.1.2 states that electrical equipment and lines shall be considered energized until verified de
==71152 - Problem Identification and Resolution    Annual Follow-up of Selected Issues==
-energized by a "live
{{IP sample|IP=IP 71152|count=2}}
-dead-live" check. ISPM
-7, "Electrical Safety," Revision 17, Step 3.1.10 states that all circuits shall be tested utilizing a live
-dead-live method to verify that it is de-energized prior to commencing work, unless the circuit is planned to be worked live. In both procedures, two notes precede these steps. The first note states,  "NOTE: Live
-Dead-Live Check
- Ensure test equipment is rated for and set to the correct voltage source (AC/DC) range prior to use. Test the meter on a known live source, perform necessary checks, then test the meter on a known live source. The live source must be the same voltage type as the circuit to be worked. (AC/DC)"
The second note states,  "NOTE: Pre and post voltage verification is required when performing determinations/re
-terminations on a known live circuit. A "Live Dead Live" does not apply in this situation. When working on known live voltage sources per approved work documents, voltage verification is not required. (e.g. Battery surveillances)"
Work Order 02072924 Step 4.6 states, in part,  "Disconnect all external wiring at the bucket, using the attached de
-term/re-term data sheet, [Motor Control Center] as
-found diagram and/or cable termination instruction (CTI) as appropriate."


A warning note immediately prior to this step states
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
, "Control circuits will be energized. Refer to drawing EWD
: (1) required test for Westinghouse 480v ac circuit breaker on February 20, 2018
-6E-007. Ensure all wire terminals are checked for voltage, prior to disconnecting. Note any discrepancies."
: (2) licensees corrective action for abnormal procedure ABN-ASH on March 31, 2018


Maintenance personnel only performed a live
===71153 - Follow-up of Events and Notices of Enforcement Discretion    Licensee Event Reports ===
-dead-live check for DC voltage because the workers erroneously believed only DC voltage was present in the cubicle. The inspectors noted that drawing EWD
{{IP sample|IP=IP 71153|count=3}}
-6E-007, "Reactor Core Isolation Cooling System Pump RCIC
The inspectors evaluated the following Licensee Event Reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:
-P-2 (E51-C002)" Revision 13, clearly shows AC voltage sources also located in the same cubicle.
: (1) LER 05000397/2017-003-00, Momentary Loss of Secondary Containment Due to Weather on June 26, 2017
: (2) LER 05000397/2017-005-00, Valve Closure Results in Momentary Increase in Secondary Containment Pressure on September 12, 2017
: (3) LER 05000397/2017-006-00, Condition Prohibited by Technical Specifications Due to Incomplete Action Statement on September 21,


The inspectors determined the maintenance personnel failed to conduct a proper live-dead-live check because the workers did not follow the warning note in Work Order 02072924 and refer to drawing EWD
==INSPECTION RESULTS==
-6E-007.
Minor Performance Deficiency                                  71153 Minor Performance Deficiency: The inspectors reviewed LER 2017-006-00 and determined the failure to follow Procedure OSP-ELEC-W101, Offsite Station Power Alignment Check, Revision 30, was a performance deficiency.


Corrective Actions: The licensee's corrective actions included immediately restoring secondary containment to operable status and conducting a work stand down with all electricians to review requirements of Procedures ISPM
Screening: The performance deficiency was minor because while it was associated with the configuration control attribute of the Mitigating Systems Cornerstone, it did not adversely affect the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, when operations personnel performed the offsite station power alignment check in its entirety, all breakers were correctly aligned, and power was available for each offsite circuit.
-20 and ISPM
-7 and reinforce the expectation that drawings will be posted at the job site at all times.


Corrective Action Reference:  Action Request 371264 Performance Assessment
Failure to Follow Procedure Leads to Loss of Secondary Containment Cornerstone          Significance                    Cross-cutting Aspect        Report Section Barrier Integrity    Green                            H.5 - Work                  71153 - Follow-NCV 05000397/2018001-01          Management                    up of Events Closed                                                        and Notices of Enforcement Discretion During their inspection of LER 2017-005-00, the inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to perform maintenance in accordance with documented instructions appropriate to the circumstances.
:  Performance Deficiency:  The failure to perform maintenance in accordance with documented instructions appropriate to the circumstances was a performance deficiency.


Screening:  The performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.
Specifically, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.


Specifically, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.
=====Description:=====
On September 12, 2017, electricians performed planned maintenance per Work Order 02072924 to replace the reactor core isolation cooling (RCIC) system direct current (DC) motor control center (MCC) buckets. As part of the work, electricians conducted live-dead-live checks of wiring in the cubicle to check for DC voltage. The workers found DC voltage as expected and lifted the terminals, per instructions. Another live-dead-live test for DC power was conducted which showed no voltage. While lifting a control wire, a maintenance worker believed they saw faint evidence of arcing. Another live-dead-live test was conducted which showed no evidence of DC voltage. However, when electricians lifted the wire, it shorted out against the bucket chassis and caused a reactor building exhaust inboard isolation valve to lose power and close, resulting in a loss of secondary containment.
 
The wire shorted because alternating current (AC) voltage was present on the control wire and the DC voltage checks were not adequate to identify the presence of AC voltage.
 
Operations personnel responded to the incident and restored secondary containment to operable status within approximately 1 minute.
 
The inspectors noted Work Order 02072924 Precaution and Limitations Step 2.5 states that electrical energy may be present, follow the requirements of ISPM-7 & ISPM-20. Step 2.6 states, in part, to as needed, check all control wiring terminals in the cubicle for voltage prior to working in the cubicle.
 
ISPM-20, Electrical Arc Protection Work Practices and PPE Requirements, Revision 14, Step 3.1.2 states that electrical equipment and lines shall be considered energized until verified de-energized by a live-dead-live check. ISPM-7, Electrical Safety, Revision 17, Step 3.1.10 states that all circuits shall be tested utilizing a live-dead-live method to verify that it is de-energized prior to commencing work, unless the circuit is planned to be worked live.
 
In both procedures, two notes precede these steps. The first note states, NOTE: Live-Dead-Live Check - Ensure test equipment is rated for and set to the correct voltage source (AC/DC) range prior to use. Test the meter on a known live source, perform necessary checks, then test the meter on a known live source. The live source must be the same voltage type as the circuit to be worked. (AC/DC)
The second note states, NOTE: Pre and post voltage verification is required when performing determinations/re-terminations on a known live circuit. A Live Dead Live does not apply in this situation. When working on known live voltage sources per approved work documents, voltage verification is not required. (e.g. Battery surveillances)
Work Order 02072924 Step 4.6 states, in part, Disconnect all external wiring at the bucket, using the attached de-term/re-term data sheet, [Motor Control Center] as-found diagram and/or cable termination instruction (CTI) as appropriate.
 
A warning note immediately prior to this step states, Control circuits will be energized. Refer to drawing EWD-6E-007. Ensure all wire terminals are checked for voltage, prior to disconnecting. Note any discrepancies.
 
Maintenance personnel only performed a live-dead-live check for DC voltage because the workers erroneously believed only DC voltage was present in the cubicle. The inspectors noted that drawing EWD-6E-007, Reactor Core Isolation Cooling System Pump RCIC-P-2 (E51-C002) Revision 13, clearly shows AC voltage sources also located in the same cubicle.
 
The inspectors determined the maintenance personnel failed to conduct a proper live-dead-live check because the workers did not follow the warning note in Work Order 02072924 and refer to drawing EWD-6E-007.


Significance:
Corrective Actions: The licensees corrective actions included immediately restoring secondary containment to operable status and conducting a work stand down with all electricians to review requirements of Procedures ISPM-20 and ISPM-7 and reinforce the expectation that drawings will be posted at the job site at all times.
The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, "Initial Characterization of Findings," and Appendix A, "The Significance Determination Process (SDP) for Findings At
-Power," Exhibit 3, "Barrier Integrity Screening Questions," dated June 19, 2012. The inspectors determined the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, auxiliary building, spent fuel pool , or standby gas treatment system.


Cross-cutting Aspect: This finding had a cross
Corrective Action Reference: Action Request 371264
-cutting aspect in the area of human performance, work management, in that the licensee failed to plan and execute the work activity adequately. Specifically, electricians performed an inadequate live
-dead-live check for the presence of only DC voltage when 120V AC voltage was present as reflected in the drawing [H.5].
Enforcement
:  Violation:
Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A of Regulatory Guide 1.33, Revision 2, requires, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with documented instructions appropriate to the circumstances. The licensee established Work Order 02072924 to meet the Regulatory Guide 1.33 requirement. The warning note preceding Step 4.6 of Work Order 02072924 requires the electricians "Refer to drawing EWD
-6E-007. Ensure all wire terminals are checked for voltage, prior to disconnecting."


Contrary to the above, on September 12, 2017, the licensee did not refer to drawing E WD-6E-007 and ensure all wire terminals are checked for voltage, prior to disconnecting. Specifically, the licensee should have identified there was live AC voltage present in the cubicle per drawing EWD
=====Performance Assessment:=====
-6E-007 and properly checked for AC voltage prior to disconnecting the wires. As a result, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.
Performance Deficiency: The failure to perform maintenance in accordance with documented instructions appropriate to the circumstances was a performance deficiency.


Disposition: This violation is being treated as a Non
Screening: The performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.
-Cited Violation consistent with Section 2.3.2.a of the NRC Enforcement Policy.


EXIT MEETINGS AND DEBRIEFS Unless otherwise noted, the inspectors verified no proprietary information was retained or documented in this report.
Specifically, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.


On February 20, 2018, the inspectors discussed the proposed exercise scenario with Mr. W. Webb, Branch Chief, Technological Hazards, FEMA Region X.
Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions, dated June 19, 2012. The inspectors determined the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, auxiliary building, spent fuel pool, or standby gas treatment system.


On February 22, 2018, the inspectors discuss ed t he results of the in
Cross-cutting Aspect: This finding had a cross-cutting aspect in the area of human performance, work management, in that the licensee failed to plan and execute the work activity adequately. Specifically, electricians performed an inadequate live-dead-live check for the presence of only DC voltage when 120V AC voltage was present as reflected in the drawing [H.5].
-office review of the licensee's preliminary exercise scenario with Mr. S. Clizbe, Manager, Emergency Preparedness, and other members of the licensee staff.


On March 30, 2018, the inspectors presented the results of the on
=====Enforcement:=====
-site inspection of the licensee's biennial emergency preparedness exercise and subsequent determination of performance weaknesses to Mr. R. Schuetz, Plant General Manager, Acting Vice President, Operations, and other members of the licensee staff. The inspectors also discussed exercise performance with Mr. W. Webb, Branch Chief, Technological Hazards, FEMA Region X.
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A of Regulatory Guide 1.33, Revision 2, requires, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with documented instructions appropriate to the circumstances. The licensee established Work Order 02072924 to meet the Regulatory Guide 1.33 requirement. The warning note preceding Step 4.6 of Work Order 02072924 requires the electricians Refer to drawing EWD-6E-007. Ensure all wire terminals are checked for voltage, prior to disconnecting.


On April 19, 2018 , the inspector s presented the integrated inspection results for the quarter to Mr. G. Hettel , Vice President for Operations
Contrary to the above, on September 12, 2017, the licensee did not refer to drawing EWD-6E-007 and ensure all wire terminals are checked for voltage, prior to disconnecting.
, and other members of the licensee staff.


=DOCUMENTS REVIEWED=
Specifically, the licensee should have identified there was live AC voltage present in the cubicle per drawing EWD-6E-007 and properly checked for AC voltage prior to disconnecting the wires. As a result, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.
 
Disposition: This violation is being treated as a Non-Cited Violation consistent with Section 2.3.2.a of the NRC Enforcement Policy.


Inspection Procedure Type Designation
==EXIT MEETINGS AND DEBRIEFS==
Description or Title
Unless otherwise noted, the inspectors verified no proprietary information was retained or documented in this report.
Revision/  Date 71111.01 Procedures
* On February 20, 2018, the inspectors discussed the proposed exercise scenario with Mr. W. Webb, Branch Chief, Technological Hazards, FEMA Region X.
ABN-FLOODING Flooding 019 1.3.76 Integrated Risk Management
* On February 22, 2018, the inspectors discussed the results of the in-office review of the licensees preliminary exercise scenario with Mr. S. Clizbe, Manager, Emergency Preparedness, and other members of the licensee staff.
49 ABN-WIND Tornado/High Winds
* On March 30, 2018, the inspectors presented the results of the on-site inspection of the licensees biennial emergency preparedness exercise and subsequent determination of performance weaknesses to Mr. R. Schuetz, Plant General Manager, Acting Vice President, Operations, and other members of the licensee staff. The inspectors also discussed exercise performance with Mr. W. Webb, Branch Chief, Technological Hazards, FEMA Region X.
29 71111.04 Procedures
* On April 19, 2018, the inspectors presented the integrated inspection results for the quarter to Mr. G. Hettel, Vice President for Operations, and other members of the licensee staff.
3.1.6J Instrument Rack Valve Line up Service BLDG, DG BLDG, SW PPHSE, CWPH, & TMU PPHSE 004 SOP-DG 1-LU Emergency Diesel Generator (Div 1) Valve and Power Supply  Lineup
005 SOP-DG2-LU Emergency Diesel Generator (Div 2) ) Valve and
Power Supply  Lineup
005 SOP-DG 3-LU High Pressure Core Spray Diesel Generator Valve and Power Supply Lineup
007 SOP-DG-DSA Diesel Starting Air Operations
14 OSP-SW-M101 Standby Service Water Loop A Valve Position Verification
037 71111.05 Procedures 1.3.10B Active Fire System Operability and Impairment Control
015 1.3.10C Control of Transient Combustibles
20 SOP-FP-DRAIN  Fire Protection System Drain
1 SOP-FP-FILL Fire Protection System Fill 00 3 SOP-FP-LU Fire Protection System Valve and Breaker Lineup
9 MWP-1 Maintenance Welding Operating Procedure
20 PFP-RW-525 Radwaste 525
005 10.2.222 Seismic Storage Requirements for Transient Equipment 001 Miscellaneous
ISP 17-0124 Ignition Source Permit:
CCH-CR-1A, Control Room Emergency Chiller
01/02/2018
Action Requests 375440 376161 377528 378082 377895 377052
Inspection Procedure Type Designation
Description or Title
Revision/  Date 71111.06 Procedures
1.3.57 Barrier Impairment
036 ME-02-02-02 Calculation for
Reactor Building Flooding Analysis
2 Work Orders
2100891 02116122  71111.11 Procedures
OI-09 Operations Standards and Expectation
068 13.1.1A Classify the Emergency
- Technical Bases
033 13.1.1 Classifying the Emergency
049 Miscellaneous
Energy Northwest 4.0 Critique Summary for Crew F Evaluated Scenario Cycle 18
-1 01/22/2018
71111.12 Procedure 1.5.11 Maintenance Rule Program
015 Work Orders
2046756 02061863 02080115 02100745 02110118 02113431 0 2123160  Action Requests 373929 3739 36 375680 375996 376135 376155  71111.13 Procedure s 1.3.76 Integrated Risk Management
049 26871 High Risk Work Plan
013 1.3.83 Protected Equipment Program
26 Miscellaneous
High Risk Work Plan for MCR Chiller 'A' Outlet Line
2/20/2017
71111.15 Procedure 1.3.66 Operability and Functionality Evaluation
034 Action Requests 375995 375997 375998 376135 376155 377 143 377670 378475 378407 37840 8  71111.18 Procedure EC 14954 CCH Bypass Line
000 - 004 Work Order
2085978  Action Reques t 376012      71111.19  Procedures
OSP-ELEC-S703 HPCS Diesel Generator Semi-Annual Operability Test
60 TSP-DG2-B502 Standby Diesel Generator DG2 Load Testing
24 OSP-ELEC-M702 Diesel Generator 2
- Monthly Operability Test
2 OSP-ELEC-W101 Offsite Station Power Alignment Check 031 15.1.4 FP-P-110 Operability Test
038 SOP-TMU-START  Tower Makeup Water System Start 013 SOP-TMU-OPS Tower Makeup Water Operation 011
Inspection Procedure Type Designation
Description or Title
Revision/  Date 71111.19 Procedures
OSP-FPC/IST-Q701 Fuel Pool Cooling System Operability Surveillance
037 OSP-SW/IST-Q702 Standby service Water Loop B Operability
2 8.3.447 Testing RHR
-V-89, RHR-V-115, and RHR-V-116 001 OSP-SW-M102 Standby Service Water Loop B Valve Position Verification
038 Work Order
s 02096335 02120536 0 2123160 02090131 Action Requests 373929 373936 375680      71111.22 Procedures
SYS-2-27 Sonar Inspection
- Service Water Spray Pond Sediment Measurements
000 Calculations
ME-0 2-83-21 Calculation for Spray Pond Water Level Change
2 ME-02-92-41 Calculation for Ultimate Heat Sink Analysis
007 Work Orders
2090434 02092445 02097247  71114.01 Procedures
and Documents EPIP 13.1.1
Classifying the Emergency
EPIP 13.1.1A Classifying the Emergency, Technical Bases , January 17, 2018 0 33 EPIP 13.2.1
Emergency Exposure Levels/Protective Action Guides, December 21, 2017
22 EPIP 13.2.2
Determining Protective Action Recommendations, December 21, 2017 0 20 EPIP 13.4.1
Emergency Notifications, August 29, 2017
43  EPIP 13.5.1
Local, Protected Area or Site Evacuation, March 8, 2017
29 EPIP 13.8.1
Emergency Dose Projection System Operations
38 EPIP 13.10.1
Control Room Operations and Shift Manager Duties, February 14, 2017 0 35 EPIP 13.10.2
TSC Manager Duties, February 14, 2017 0 35 EPIP 13.10.9
Operations Support Center Manager and Staff Duties, January 24, 2017
49 EPIP 13.11.1
EOF Manager Duties, October 4, 2017 0 44
Inspection Procedure Type Designation
Description or Title
Revision/  Date 71114.01 Procedures
and Documents EPIP 13.14.11 EP Equipment
13 EPIP 13.14.8
Drill and Exercise Program, June 29, 2016
18 EPI-13 Emergency Notification System, August 29, 2017
8 EPI-17 After Action Report, Improvement Plan, Formatting, Distribution, and Retention, December 9, 2013
8 EPI-21 Drill and Exercise Development and Implementation, June 22, 2017 0 18 5.2.1 Primary Containment Control
27 5.8.1 Post-LOCA Hydrogen/Oxygen Monitoring
2 12.5.3 3 Reactor Coolant Sampling
004.001 12.17.1 EOP Reactor Water Sampling
2/21/2017
DWG M528-2 Flow Diagram Control Rod Drive System
9 RWP 30004172 2018 Emergency Drill Response Activities
2/21/2017
Columbia Generating Station ERO Team "B" Drill Report, January 12, 2016, After Action Report/Improvement Plan
2/11/2016
Columbia Generating Station ERO Team "B" Dress Rehearsal Drill Report, February 23, 2016, After Action Report/Improvement Plan
04/23/2016
Columbia Generating Station ERO Team "B" Exercise Drill Report, March 29, 2016, After Action Report/Improvement Plan 04/29/2016


Inspection Procedure Type Designation
=DOCUMENTS REVIEWED=
Description or Title
Revision/  Date 71114.01 Documents  Columbia Generating Station ERO Team "B" Exercise Drill Report, March 29, 2016, After Action Report/Improvement Plan 04/29/2016
Columbia Generating Station ERO Team "D" Drill, Drill Report, May 3, 2016, After Action Report/Improvement Plan 06/03/2016
Columbia Generating Station ERO Team "A" Drill, Drill Report, August 30, 2016, After Action Report/Improvement Plan 09/22/2016
Columbia Generating Station ERO Team "C" Drill, Drill Report, October 25, 2016, After Action Report/Improvement Plan 11/22/2016
Columbia Generating Station ERO Team "B" Drill, Dril
l Report, January 10, 2017, After Action Report/Improvement Plan 02/07/2017
Columbia Generating Station ERO Team "D" Drill, Drill Report, March 14, 2017, After Action Report/Improvement Plan 04/24/2017
Columbia Generating Station ERO Team "A" Drill, Drill Report, July 18, 2017, After Action Report/Improvement Plan 08/15/2017
Columbia Generating Station ERO Team "C" Drill, Drill Report, October 31, 2017, After Action Report/Improvement Plan 11/31/2017
Fire Brigade/First Responder Drill 2016, Contaminated/Injured Man
11/03/2016
Fire Brigade/First Responder Drill 2017, Contaminated/Injured Man
11/28/2017


Inspection Procedure Type Designation
Inspection Type          Designation  Description or Title              Revision/
Description or Title
Procedure                                                                Date
Revision/  Date 71114.01 Documents Apparent Cause Evaluation, Violation of
71111.01  Procedures    ABN-        Flooding                            019
CFR 50.54(q)(2) for Failure to Conduct Medical Emergency Drill in 2015
FLOODING
04/11/2016
1.3.76      Integrated Risk Management          049
Action Requests 347032 347050 347265 347490 348108 350241 353342 354107 356181 356227 356618 356826 357471 360335 360547 361134 361195 363014 366567 366884 366958 368177 368192 369531 369776 371856 373325 373732 374110 374115 374117 372561 375641 377563 378325 378339 378341 378394 378441 378471 378644   71114.04 Procedures
ABN-WIND    Tornado/High Winds                  029
and Documents  Columbia Generating Station Emergency Plan
71111.04  Procedures    3.1.6J      Instrument Rack Valve Line up      004
65 EPIP 13.1.1A Classifying the Emergency, Technical Bases
Service BLDG, DG BLDG, SW
33 EPI-16 50.54(Q) Change Evaluation, July 19, 2017
PPHSE, CWPH, & TMU
15 71151 Procedures
PPHSE
EPI-18 Emergency Preparedness Performance Indicators, May 31, 2017 025 Action Requests 358298 360339 361467 366785 368711 369130 369725 372372 373237 373325   71152 Action Requests 346054 376191 377044      71153  Action Requests 371646 371777 376985
SOP-DG1-LU Emergency Diesel Generator            005
                                      (Div 1) Valve and Power
Supply Lineup
SOP-DG2-LU Emergency Diesel Generator            005
                                      (Div 2) ) Valve and Power
Supply Lineup
SOP-DG3-LU High Pressure Core Spray              007
Diesel Generator Valve and
Power Supply Lineup
SOP-DG-DSA Diesel Starting Air Operations        014
OSP-SW-      Standby Service Water Loop A        037
M101        Valve Position Verification
71111.05  Procedures    1.3.10B      Active Fire System Operability      015
and Impairment Control
1.3.10C      Control of Transient                020
Combustibles
SOP-FP-      Fire Protection System Drain        001
DRAIN
SOP-FP-FILL Fire Protection System Fill          003
SOP-FP-LU    Fire Protection System Valve        009
and Breaker Lineup
MWP-1        Maintenance Welding                020
Operating Procedure
PFP-RW-525 Radwaste 525                          005
10.2.222    Seismic Storage                    001
Requirements for Transient
Equipment
Miscellaneous ISP 17-0124  Ignition Source Permit:          01/02/2018
CCH-CR-1A, Control Room
Emergency Chiller
Action          375440        376161          377528        378082
Requests        377895        377052
Attachment
Inspection Type         Designation Description or Title              Revision/
Procedure                                                                Date
71111.06  Procedures    1.3.57      Barrier Impairment                  036
ME-02-02-02 Calculation for Reactor Building    002
Flooding Analysis
Work Orders    02100891    02116122
71111.11  Procedures    OI-09      Operations Standards and            068
Expectation
13.1.1A    Classify the Emergency -            033
Technical Bases
13.1.1      Classifying the Emergency            049
Miscellaneous            Energy Northwest 4.0 Critique    01/22/2018
Summary for Crew F Evaluated
Scenario Cycle 18-1
71111.12  Procedure    1.5.11      Maintenance Rule Program            015
Work Orders    02046756    02061863          02080115  02100745
2110118    02113431          02123160
Action          373929      373936            375680      375996
Requests        376135      376155
71111.13  Procedures    1.3.76      Integrated Risk Management          049
26871      High Risk Work Plan                  013
1.3.83      Protected Equipment Program          026
Miscellaneous            High Risk Work Plan for MCR      12/20/2017
Chiller A Outlet Line
71111.15  Procedure    1.3.66      Operability and Functionality        034
Evaluation
Action          375995      375997            375998      376135
Requests        376155      377143            377670      378475
378407      378408
71111.18  Procedure      EC 14954  CCH Bypass Line                  000 - 004
Work Order      02085978
Action          376012
Request
71111.19  Procedures    OSP-ELEC-  HPCS Diesel Generator                060
S703        Semi-Annual Operability Test
TSP-DG2-    Standby Diesel Generator DG2        024
B502        Load Testing
OSP-ELEC-  Diesel Generator 2 - Monthly        062
M702        Operability Test
OSP-ELEC-  Offsite Station Power Alignment      031
W101        Check
15.1.4      FP-P-110 Operability Test            038
SOP-TMU-    Tower Makeup Water System            013
START      Start
SOP-TMU-    Tower Makeup Water                  011
OPS        Operation
Inspection Type        Designation  Description or Title           Revision/
Procedure                                                            Date
71111.19  Procedures  OSP-        Fuel Pool Cooling System          037
FPC/IST-    Operability Surveillance
Q701
OSP-        Standby service Water Loop B      032
SW/IST-      Operability
Q702
8.3.447      Testing RHR-V-89, RHR-V-115,      001
and RHR-V-116
OSP-SW-      Standby Service Water Loop B      038
M102        Valve Position Verification
Work Orders    02096335    02120536          02123160  02090131
Action          373929        373936            375680
Requests
71111.22  Procedures  SYS-2-27    Sonar Inspection - Service        000
Water Spray Pond Sediment
Measurements
Calculations ME-02-83-21  Calculation for Spray Pond        002
Water Level Change
ME-02-92-41  Calculation for Ultimate Heat    007
Sink Analysis
Work Orders    02090434    02092445          02097247
71114.01  Procedures  EPIP 13.1.1  Classifying the Emergency
and          EPIP        Classifying the Emergency,        033
Documents    13.1.1A      Technical Bases,
January 17, 2018
EPIP 13.2.1  Emergency Exposure                022
Levels/Protective Action
Guides, December 21, 2017
EPIP 13.2.2  Determining Protective Action    020
Recommendations,
December 21, 2017
EPIP 13.4.1  Emergency Notifications,          043
August 29, 2017
EPIP 13.5.1  Local, Protected Area or Site    029
Evacuation, March 8, 2017
EPIP 13.8.1  Emergency Dose Projection        038
System Operations
EPIP 13.10.1 Control Room Operations and      035
Shift Manager Duties, February
14, 2017
EPIP 13.10.2 TSC Manager Duties, February      035
14, 2017
EPIP 13.10.9 Operations Support Center        049
Manager and Staff Duties,
January 24, 2017
EPIP 13.11.1 EOF Manager Duties,              044
October 4, 2017
Inspection Type      Designation  Description or Title            Revision/
Procedure                                                            Date
71114.01  Procedures EPIP        EP Equipment                      013
and        13.14.11
Documents EPIP 13.14.8 Drill and Exercise Program,        018
June 29, 2016
EPI-13      Emergency Notification System,    008
August 29, 2017
EPI-17      After Action Report,              008
Improvement Plan, Formatting,
Distribution, and Retention,
December 9, 2013
EPI-21      Drill and Exercise Development    018
and Implementation, June 22,
2017
5.2.1        Primary Containment Control        027
5.8.1        Post-LOCA Hydrogen/Oxygen          002
Monitoring
2.5.33      Reactor Coolant Sampling        004.001
2.17.1      EOP Reactor Water Sampling      12/21/2017
DWG M528-    Flow Diagram Control Rod          009
Drive System
RWP          2018 Emergency Drill            12/21/2017
30004172    Response Activities
Columbia Generating Station    02/11/2016
ERO Team B Drill Report,
January 12, 2016, After Action
Report/Improvement Plan
Columbia Generating Station    04/23/2016
ERO Team B Dress
Rehearsal Drill Report,
February 23, 2016, After Action
Report/Improvement Plan
Columbia Generating Station    04/29/2016
ERO Team B Exercise Drill
Report, March 29, 2016, After
Action Report/Improvement
Plan
Inspection Type      Designation Description or Title            Revision/
Procedure                                                          Date
71114.01  Documents            Columbia Generating Station    04/29/2016
ERO Team B Exercise Drill
Report, March 29, 2016, After
Action Report/Improvement
Plan
Columbia Generating Station    06/03/2016
ERO Team D Drill, Drill
Report, May 3, 2016, After
Action Report/Improvement
Plan
Columbia Generating Station    09/22/2016
ERO Team A Drill, Drill
Report, August 30, 2016, After
Action Report/Improvement
Plan
Columbia Generating Station    11/22/2016
ERO Team C Drill, Drill
Report, October 25, 2016, After
Action Report/Improvement
Plan
Columbia Generating Station    02/07/2017
ERO Team B Drill, Drill
Report, January 10, 2017, After
Action Report/Improvement
Plan
Columbia Generating Station    04/24/2017
ERO Team D Drill, Drill
Report, March 14, 2017, After
Action Report/Improvement
Plan
Columbia Generating Station    08/15/2017
ERO Team A Drill, Drill
Report, July 18, 2017, After
Action Report/Improvement
Plan
Columbia Generating Station    11/31/2017
ERO Team C Drill, Drill
Report, October 31, 2017, After
Action Report/Improvement
Plan
Fire Brigade/First Responder    11/03/2016
Drill 2016,
Contaminated/Injured Man
Fire Brigade/First Responder    11/28/2017
Drill 2017,
Contaminated/Injured Man
Inspection Type      Designation Description or Title            Revision/
Procedure                                                            Date
71114.01   Documents             Apparent Cause Evaluation,     04/11/2016
Violation of 10 CFR 50.54(q)(2)
for Failure to Conduct Medical
Emergency Drill in 2015
Action       347032       347050           347265     347490
Requests      348108       350241           353342     354107
356181       356227           356618     356826
357471       360335           360547     361134
361195       363014           366567     366884
366958       368177           368192     369531
369776       371856           373325     373732
374110       374115           374117     372561
375641       377563           378325     378339
378341       378394           378441     378471
378644
71114.04   Procedures             Columbia Generating Station       065
and                    Emergency Plan
Documents  EPIP       Classifying the Emergency,        033
13.1.1A     Technical Bases
EPI-16     50.54(Q) Change Evaluation,       015
July 19, 2017
71151     Procedures EPI-18     Emergency Preparedness             025
Performance Indicators,
May 31, 2017
Action       358298       360339           361467     366785
Requests      368711       369130           369725     372372
373237       373325
71152     Action       346054       376191           377044
Requests
71153     Action       371646       371777           376985
Requests
6
}}
}}

Latest revision as of 23:29, 18 December 2019

NRC Integrated Inspection Report 05000397/2018001
ML18116A407
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 04/25/2018
From: Mark Haire
NRC/RGN-IV/DRP
To: Sawatzke B
Energy Northwest
Mark Haire
References
IR 2018001
Download: ML18116A407 (21)
v • d • e


Text

ril 25, 2018

SUBJECT:

COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018001

Dear Mr. Sawatzke:

On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Columbia Generating Station. On April 19, 2018, the NRC inspectors discussed the results of this inspection with Mr. G. Hettel, Vice President for Operations, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented one finding of very low safety significance (Green) in this report.

This finding involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.

If you contest the violation or significance of this NCV, 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 inspector 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 inspector at the Columbia Generating Station. 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, Chief Project Branch A Division of Reactor Projects Docket No. 50-397 License No. NPF-21 Enclosure:

Inspection Report 05000397/2018001 w/ Attachment: Documents Reviewed

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. Findings and violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations Failure to Follow Procedure Leads to Loss of Secondary Containment Cornerstone Significance Cross-cutting Report Aspect Section Barrier Integrity Green H.5 - Work 71153 -

NCV 05000397/2018001-01 Management Follow-up of Closed Events and Notices of Enforcement Discretion The inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a for the licensees failure to perform maintenance in accordance with documented instructions appropriate to the circumstances. Specifically, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.

Additional Tracking Items Type Issue Number Title Report Status Section LER 05000397/2017003-00 Momentary Loss of 71153 Closed Secondary Containment Due to Weather LER 05000397/2017005-00 Valve Closure Results in 71153 Closed Momentary Increase in Secondary Containment Pressure LER 05000397/2017006-00 Condition Prohibited by 71153 Closed Technical Specifications Due to Incomplete Action Statement

PLANT STATUS

The plant began the inspection period at 100 percent rated thermal power. On January 6, 2018, the unit was down-powered to 72 percent for turbine valve testing and a control rod sequence exchange. The unit was returned to 100 percent rated thermal power on January 6, 2018. On March 31, 2018, the unit was down-powered to 70 percent for turbine valve testing and a control rod sequence exchange. The unit was returned to 100 percent rated thermal power on March 31,

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection period 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 Impending Severe Weather

Main article: IP 71111.01

The inspectors evaluated readiness for impending adverse weather conditions associated with high winds on February 17, 2018.

External Flooding (1 Sample)

The inspectors evaluated readiness to cope with external flooding on January 12, 2018.

71111.04 - Equipment Alignment Partial Walkdown

Main article: IP 71111.04

The inspectors evaluated system configurations during partial systems/trains walkdowns:

(1) diesel generator 1 starting air on February 6, 2018
(2) diesel generator 2 starting air on February 22, 2018
(3) diesel generator 3 starting air on February 26, 2018
(4) diesel generator 3 governor on March 12, 2018
(5) diesel generator 2 governor on March 29, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated standby service water loop A system configurations during a complete walkdown on January 12, 2018

71111.05AQ - Fire Protection Annual/Quarterly Quarterly Inspection

Main article: IP 71111.05AQ

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Area R-6/2: RCIC Pump Room on January 8, 2018
(2) Fire Area R-7/1: RHR-C Pump Room on January 9, 2018
(3) Fire Area R-8/1: LPCS Pump Room on January 10, 2018
(4) Fire Area RC-13/2: Chiller, Communications, I & C Area on January 26, 2018
(5) Fire Area RC-11/1: HVAC Equipment Room A Division 1 on January 26, 2018
(6) Fire Area RC-12/2: HVAC Equipment Room B Division 2 on January 26, 2018

71111.06 - Flood Protection Measures Internal Flooding

Main article: IP 71111.06

The inspectors evaluated internal flooding mitigation protections:

(1) Reactor Building 422 level on February 14, 2018

Cables (1 Sample)

The inspectors evaluated cable submergence protection:

(1) Manhole E-MH-E8 on February 22, 2018
(2) Manhole E-MH-01B, 10, 11, 13, 15 on February 28, 2018

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

Main article: IP 71111.11

The inspectors observed and evaluated a crew during a simulator evaluated scenario for licensed operator requalification training on January 22, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during the following activities:

(1) maintenance on main generator seal oil pressure regulator on January 9, 2018
(2) diesel generator 3 testing on January 24, 2018

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness

Main article: IP 71111.12

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) fire pump 110 starting issue on January 10, 2018
(2) standby service water loop B planned maintenance, week of January 15, 2018
(3) diesel generator 3 annual preventive maintenance, week of January 22, 2018
(4) SM4 relay testing on February 27, 2018
(5) diesel generator 2 12-year maintenance, March 19-30, 2018

Quality Control (1 Sample)

The inspectors evaluated maintenance and quality control activities associated with the following equipment performance issues:

(1) main control room emergency chiller B maintenance, week of February 19, 2018

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) yellow risk due to standby service water system A maintenance, week of January 1, 2018
(2) yellow risk due to maintenance on main generator seal oil pressure regulator on January 9, 2018
(3) yellow risk for diesel generator 3 maintenance on January 22, 2018
(4) yellow risk for circuit breaker S/2 maintenance on January 24, 2018
(5) yellow risk for maintenance on backup transformer, February 16-17, 2018
(6) yellow risk for standby gas treatment B and SM4 relay testing, February 26-28, 2018
(7) yellow risk for diesel generator 3 24-hour load test and loss of coolant accident test, March 1-3, 2018
(8) yellow risk for diesel generator 2 12-year maintenance, March 19-30, 2018

71111.15 - Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) diesel generator 3 diesel oil valve DO-V-14 on January 22, 2018
(2) diesel generator 3 exhaust thermocouple on January 24, 2018
(3) diesel generator 3 temperature test switch on January 25, 2018
(4) main control room emergency chiller B unexpected start during tagout on February 18, 2018
(5) high pressure core spray motor oil on March 8, 2018
(6) diesel generator 2 engine governor on March 28, 2018
(7) diesel generator 2 fuel oil pump on March 29, 2018

71111.18 - Plant Modifications

Main article: IP 71111.18

The inspectors evaluated the following temporary or permanent modifications:

(1) Engineering Change (EC) 14954, CCH Bypass Line, Emergency Chilled Water, on January 24, 2018
(2) Temporary Modification (TM) 16326, adjust setpoint of containment instrument air pressure control valve on February 2, 2018
(3) EC 16860 setpoint change on DG air start reducing valve pressure on February 9, 2018
(4) TM 16170 main control room chiller B bearing high temp switch on February 16, 2018
(5) EC 16066 vital island fire protection installation on March 31, 2018

71111.19 - Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) fire pump 110 maintenance on January 10, 2018
(2) standby service water loop B maintenance on January 16, 2018
(3) diesel generator 3 maintenance on January 25, 2018
(4) TR-B backup transformer maintenance on February 17, 2018
(5) tower make-up pump C maintenance on February 21, 2018
(6) fuel pool cooling pump B maintenance on February 23, 2018
(7) RHR-V-68B standby service water supply isolation to residual heat removal heat exchanger 1B maintenance on February 26, 2018
(8) RHR-V-116 cross tie connection from standby service water maintenance on March 1, 2018
(9) diesel generator 2 12-year outage on March 29, 2018

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

Main article: IP 71111.22
(1) service water spray pond quarterly surveillance test per OSP-SW-Q101, on January 4, 2018
(2) main steam isolation valve SCRAM closure test per OSP-RPS-S402, on January 7, 2018
(3) diesel generator 3 load testing per TSP-DG3-B502, on March 2, 2018
(4) diesel generator 3 loss of coolant accident test per TSP-DG3/LOCA-B501, on March 3, 2018
(5) main turbine bypass valve testing per OSP-MS-Q702, on March 31, 2018

In-service (1 Sample)

(1) residual heat removal loop A operability test per OSP-RHR/IST-Q702, on February 7, 2018

71114.01 - Exercise Evaluation

Main article: IP 71114.01

The inspectors evaluated the licensees biennial emergency plan exercise and subsequent identification of performance weaknesses. The exercise scenario simulated the following on March 27, 2018:

(1) a loss of feedwater heating causing a power excursion which required the reactor be shut down
(2) a problem with the reactor protection system which failed to shut down the reactor
(3) a failure of some control rods to insert into the reactor
(4) an unisolable pipe break on the reactor water clean-up system outside of containment
(5) an unfiltered and monitored radioactive release from the radioactive waste building through the plant vent which increased in activity over time
(6) emergency depressurization of the reactor

71114.04 - Emergency Action Level and Emergency Plan Changes

Main article: IP 71114.04

The inspectors evaluated submitted Emergency Action Level changes in-office on January 30, 2018. This evaluation does not constitute NRC approval.

71114.06 - Drill Evaluation Emergency Planning Drill

Main article: IP 71114.06

The inspectors evaluated:

(1) a general emergency scenario drill on February 27, 2018

71114.08 - Exercise Evaluation - Scenario Review

Main article: IP 71114.08

The inspectors conducted an in-office review of the proposed biennial emergency plan exercise scenario between January 16 and February 22, 2018. The inspectors also discussed the proposed scenario with staff at FEMA Region X.

OTHER ACTIVITIES - BASELINE

71151 - Performance Indicator Verification

Main article: IP 71151

The inspectors verified licensee performance indicators submittals listed below:

(1) IE01: Unplanned Scrams per 7000 Critical Hours (01/01/2017 - 12/31/2017)
(2) IE03: Unplanned Power Changes per 7000 Critical Hours (01/01/2017 - 12/31/2017)
(3) IE04: Unplanned Scrams with Complications (01/01/2017 - 12/31/2017)
(4) EP01: Drill/Exercise Performance (01/01/2017 - 12/31/2017)
(5) EP02: Emergency Response Organization Drill Participation (01/01/2017 - 12/31/2017)
(6) EP03: Alert and Notification System Reliability (01/01/2017 - 12/31/2017)

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues

Main article: IP 71152

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) required test for Westinghouse 480v ac circuit breaker on February 20, 2018
(2) licensees corrective action for abnormal procedure ABN-ASH on March 31, 2018

71153 - Follow-up of Events and Notices of Enforcement Discretion Licensee Event Reports

Main article: IP 71153

The inspectors evaluated the following Licensee Event Reports (LERs) which can be accessed at https://lersearch.inl.gov/LERSearchCriteria.aspx:

(1) LER 05000397/2017-003-00, Momentary Loss of Secondary Containment Due to Weather on June 26, 2017
(2) LER 05000397/2017-005-00, Valve Closure Results in Momentary Increase in Secondary Containment Pressure on September 12, 2017
(3) LER 05000397/2017-006-00, Condition Prohibited by Technical Specifications Due to Incomplete Action Statement on September 21,

INSPECTION RESULTS

Minor Performance Deficiency 71153 Minor Performance Deficiency: The inspectors reviewed LER 2017-006-00 and determined the failure to follow Procedure OSP-ELEC-W101, Offsite Station Power Alignment Check, Revision 30, was a performance deficiency.

Screening: The performance deficiency was minor because while it was associated with the configuration control attribute of the Mitigating Systems Cornerstone, it did not adversely affect the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, when operations personnel performed the offsite station power alignment check in its entirety, all breakers were correctly aligned, and power was available for each offsite circuit.

Failure to Follow Procedure Leads to Loss of Secondary Containment Cornerstone Significance Cross-cutting Aspect Report Section Barrier Integrity Green H.5 - Work 71153 - Follow-NCV 05000397/2018001-01 Management up of Events Closed and Notices of Enforcement Discretion During their inspection of LER 2017-005-00, the inspectors reviewed a self-revealed, Green, non-cited violation of Technical Specification 5.4.1.a, for the licensees failure to perform maintenance in accordance with documented instructions appropriate to the circumstances.

Specifically, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.

Description:

On September 12, 2017, electricians performed planned maintenance per Work Order 02072924 to replace the reactor core isolation cooling (RCIC) system direct current (DC) motor control center (MCC) buckets. As part of the work, electricians conducted live-dead-live checks of wiring in the cubicle to check for DC voltage. The workers found DC voltage as expected and lifted the terminals, per instructions. Another live-dead-live test for DC power was conducted which showed no voltage. While lifting a control wire, a maintenance worker believed they saw faint evidence of arcing. Another live-dead-live test was conducted which showed no evidence of DC voltage. However, when electricians lifted the wire, it shorted out against the bucket chassis and caused a reactor building exhaust inboard isolation valve to lose power and close, resulting in a loss of secondary containment.

The wire shorted because alternating current (AC) voltage was present on the control wire and the DC voltage checks were not adequate to identify the presence of AC voltage.

Operations personnel responded to the incident and restored secondary containment to operable status within approximately 1 minute.

The inspectors noted Work Order 02072924 Precaution and Limitations Step 2.5 states that electrical energy may be present, follow the requirements of ISPM-7 & ISPM-20. Step 2.6 states, in part, to as needed, check all control wiring terminals in the cubicle for voltage prior to working in the cubicle.

ISPM-20, Electrical Arc Protection Work Practices and PPE Requirements, Revision 14, Step 3.1.2 states that electrical equipment and lines shall be considered energized until verified de-energized by a live-dead-live check. ISPM-7, Electrical Safety, Revision 17, Step 3.1.10 states that all circuits shall be tested utilizing a live-dead-live method to verify that it is de-energized prior to commencing work, unless the circuit is planned to be worked live.

In both procedures, two notes precede these steps. The first note states, NOTE: Live-Dead-Live Check - Ensure test equipment is rated for and set to the correct voltage source (AC/DC) range prior to use. Test the meter on a known live source, perform necessary checks, then test the meter on a known live source. The live source must be the same voltage type as the circuit to be worked. (AC/DC)

The second note states, NOTE: Pre and post voltage verification is required when performing determinations/re-terminations on a known live circuit. A Live Dead Live does not apply in this situation. When working on known live voltage sources per approved work documents, voltage verification is not required. (e.g. Battery surveillances)

Work Order 02072924 Step 4.6 states, in part, Disconnect all external wiring at the bucket, using the attached de-term/re-term data sheet, [Motor Control Center] as-found diagram and/or cable termination instruction (CTI) as appropriate.

A warning note immediately prior to this step states, Control circuits will be energized. Refer to drawing EWD-6E-007. Ensure all wire terminals are checked for voltage, prior to disconnecting. Note any discrepancies.

Maintenance personnel only performed a live-dead-live check for DC voltage because the workers erroneously believed only DC voltage was present in the cubicle. The inspectors noted that drawing EWD-6E-007, Reactor Core Isolation Cooling System Pump RCIC-P-2 (E51-C002) Revision 13, clearly shows AC voltage sources also located in the same cubicle.

The inspectors determined the maintenance personnel failed to conduct a proper live-dead-live check because the workers did not follow the warning note in Work Order 02072924 and refer to drawing EWD-6E-007.

Corrective Actions: The licensees corrective actions included immediately restoring secondary containment to operable status and conducting a work stand down with all electricians to review requirements of Procedures ISPM-20 and ISPM-7 and reinforce the expectation that drawings will be posted at the job site at all times.

Corrective Action Reference: Action Request 371264

Performance Assessment:

Performance Deficiency: The failure to perform maintenance in accordance with documented instructions appropriate to the circumstances was a performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute of the Barrier Integrity Cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers (fuel cladding, reactor coolant system, and containment) protect the public from radionuclide releases caused by accidents or events.

Specifically, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 3, Barrier Integrity Screening Questions, dated June 19, 2012. The inspectors determined the finding was of very low safety significance (Green) because the finding only represented a degradation of the radiological barrier function provided for the control room, auxiliary building, spent fuel pool, or standby gas treatment system.

Cross-cutting Aspect: This finding had a cross-cutting aspect in the area of human performance, work management, in that the licensee failed to plan and execute the work activity adequately. Specifically, electricians performed an inadequate live-dead-live check for the presence of only DC voltage when 120V AC voltage was present as reflected in the drawing [H.5].

Enforcement:

Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A of Regulatory Guide 1.33, Revision 2, requires, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with documented instructions appropriate to the circumstances. The licensee established Work Order 02072924 to meet the Regulatory Guide 1.33 requirement. The warning note preceding Step 4.6 of Work Order 02072924 requires the electricians Refer to drawing EWD-6E-007. Ensure all wire terminals are checked for voltage, prior to disconnecting.

Contrary to the above, on September 12, 2017, the licensee did not refer to drawing EWD-6E-007 and ensure all wire terminals are checked for voltage, prior to disconnecting.

Specifically, the licensee should have identified there was live AC voltage present in the cubicle per drawing EWD-6E-007 and properly checked for AC voltage prior to disconnecting the wires. As a result, on September 12, 2017, the failure to verify power sources per Work Order 02072924 caused an electrical transient that caused the reactor building exhaust valve and supply valve to lose power and close, resulting in a loss of secondary containment.

Disposition: This violation is being treated as a Non-Cited Violation consistent with Section 2.3.2.a of the NRC Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

Unless otherwise noted, the inspectors verified no proprietary information was retained or documented in this report.

  • On February 20, 2018, the inspectors discussed the proposed exercise scenario with Mr. W. Webb, Branch Chief, Technological Hazards, FEMA Region X.
  • On February 22, 2018, the inspectors discussed the results of the in-office review of the licensees preliminary exercise scenario with Mr. S. Clizbe, Manager, Emergency Preparedness, and other members of the licensee staff.
  • On March 30, 2018, the inspectors presented the results of the on-site inspection of the licensees biennial emergency preparedness exercise and subsequent determination of performance weaknesses to Mr. R. Schuetz, Plant General Manager, Acting Vice President, Operations, and other members of the licensee staff. The inspectors also discussed exercise performance with Mr. W. Webb, Branch Chief, Technological Hazards, FEMA Region X.
  • On April 19, 2018, the inspectors presented the integrated inspection results for the quarter to Mr. G. Hettel, Vice President for Operations, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision/

Procedure Date

71111.01 Procedures ABN- Flooding 019

FLOODING

1.3.76 Integrated Risk Management 049

ABN-WIND Tornado/High Winds 029

71111.04 Procedures 3.1.6J Instrument Rack Valve Line up 004

Service BLDG, DG BLDG, SW

PPHSE, CWPH, & TMU

PPHSE

SOP-DG1-LU Emergency Diesel Generator 005

(Div 1) Valve and Power

Supply Lineup

SOP-DG2-LU Emergency Diesel Generator 005

(Div 2) ) Valve and Power

Supply Lineup

SOP-DG3-LU High Pressure Core Spray 007

Diesel Generator Valve and

Power Supply Lineup

SOP-DG-DSA Diesel Starting Air Operations 014

OSP-SW- Standby Service Water Loop A 037

M101 Valve Position Verification

71111.05 Procedures 1.3.10B Active Fire System Operability 015

and Impairment Control

1.3.10C Control of Transient 020

Combustibles

SOP-FP- Fire Protection System Drain 001

DRAIN

SOP-FP-FILL Fire Protection System Fill 003

SOP-FP-LU Fire Protection System Valve 009

and Breaker Lineup

MWP-1 Maintenance Welding 020

Operating Procedure

PFP-RW-525 Radwaste 525 005

10.2.222 Seismic Storage 001

Requirements for Transient

Equipment

Miscellaneous ISP 17-0124 Ignition Source Permit: 01/02/2018

CCH-CR-1A, Control Room

Emergency Chiller

Action 375440 376161 377528 378082

Requests 377895 377052

Attachment

Inspection Type Designation Description or Title Revision/

Procedure Date

71111.06 Procedures 1.3.57 Barrier Impairment 036

ME-02-02-02 Calculation for Reactor Building 002

Flooding Analysis

Work Orders 02100891 02116122

71111.11 Procedures OI-09 Operations Standards and 068

Expectation

13.1.1A Classify the Emergency - 033

Technical Bases

13.1.1 Classifying the Emergency 049

Miscellaneous Energy Northwest 4.0 Critique 01/22/2018

Summary for Crew F Evaluated

Scenario Cycle 18-1

71111.12 Procedure 1.5.11 Maintenance Rule Program 015

Work Orders 02046756 02061863 02080115 02100745

2110118 02113431 02123160

Action 373929 373936 375680 375996

Requests 376135 376155

71111.13 Procedures 1.3.76 Integrated Risk Management 049

26871 High Risk Work Plan 013

1.3.83 Protected Equipment Program 026

Miscellaneous High Risk Work Plan for MCR 12/20/2017

Chiller A Outlet Line

71111.15 Procedure 1.3.66 Operability and Functionality 034

Evaluation

Action 375995 375997 375998 376135

Requests 376155 377143 377670 378475

378407 378408

71111.18 Procedure EC 14954 CCH Bypass Line 000 - 004

Work Order 02085978

Action 376012

Request

71111.19 Procedures OSP-ELEC- HPCS Diesel Generator 060

S703 Semi-Annual Operability Test

TSP-DG2- Standby Diesel Generator DG2 024

B502 Load Testing

OSP-ELEC- Diesel Generator 2 - Monthly 062

M702 Operability Test

OSP-ELEC- Offsite Station Power Alignment 031

W101 Check

15.1.4 FP-P-110 Operability Test 038

SOP-TMU- Tower Makeup Water System 013

START Start

SOP-TMU- Tower Makeup Water 011

OPS Operation

Inspection Type Designation Description or Title Revision/

Procedure Date

71111.19 Procedures OSP- Fuel Pool Cooling System 037

FPC/IST- Operability Surveillance

Q701

OSP- Standby service Water Loop B 032

SW/IST- Operability

Q702

8.3.447 Testing RHR-V-89, RHR-V-115, 001

and RHR-V-116

OSP-SW- Standby Service Water Loop B 038

M102 Valve Position Verification

Work Orders 02096335 02120536 02123160 02090131

Action 373929 373936 375680

Requests

71111.22 Procedures SYS-2-27 Sonar Inspection - Service 000

Water Spray Pond Sediment

Measurements

Calculations ME-02-83-21 Calculation for Spray Pond 002

Water Level Change

ME-02-92-41 Calculation for Ultimate Heat 007

Sink Analysis

Work Orders 02090434 02092445 02097247

71114.01 Procedures EPIP 13.1.1 Classifying the Emergency

and EPIP Classifying the Emergency, 033

Documents 13.1.1A Technical Bases,

January 17, 2018

EPIP 13.2.1 Emergency Exposure 022

Levels/Protective Action

Guides, December 21, 2017

EPIP 13.2.2 Determining Protective Action 020

Recommendations,

December 21, 2017

EPIP 13.4.1 Emergency Notifications, 043

August 29, 2017

EPIP 13.5.1 Local, Protected Area or Site 029

Evacuation, March 8, 2017

EPIP 13.8.1 Emergency Dose Projection 038

System Operations

EPIP 13.10.1 Control Room Operations and 035

Shift Manager Duties, February

14, 2017

EPIP 13.10.2 TSC Manager Duties, February 035

14, 2017

EPIP 13.10.9 Operations Support Center 049

Manager and Staff Duties,

January 24, 2017

EPIP 13.11.1 EOF Manager Duties, 044

October 4, 2017

Inspection Type Designation Description or Title Revision/

Procedure Date

71114.01 Procedures EPIP EP Equipment 013

and 13.14.11

Documents EPIP 13.14.8 Drill and Exercise Program, 018

June 29, 2016

EPI-13 Emergency Notification System, 008

August 29, 2017

EPI-17 After Action Report, 008

Improvement Plan, Formatting,

Distribution, and Retention,

December 9, 2013

EPI-21 Drill and Exercise Development 018

and Implementation, June 22,

2017

5.2.1 Primary Containment Control 027

5.8.1 Post-LOCA Hydrogen/Oxygen 002

Monitoring

2.5.33 Reactor Coolant Sampling 004.001

2.17.1 EOP Reactor Water Sampling 12/21/2017

DWG M528- Flow Diagram Control Rod 009

Drive System

RWP 2018 Emergency Drill 12/21/2017

30004172 Response Activities

Columbia Generating Station 02/11/2016

ERO Team B Drill Report,

January 12, 2016, After Action

Report/Improvement Plan

Columbia Generating Station 04/23/2016

ERO Team B Dress

Rehearsal Drill Report,

February 23, 2016, After Action

Report/Improvement Plan

Columbia Generating Station 04/29/2016

ERO Team B Exercise Drill

Report, March 29, 2016, After

Action Report/Improvement

Plan

Inspection Type Designation Description or Title Revision/

Procedure Date

71114.01 Documents Columbia Generating Station 04/29/2016

ERO Team B Exercise Drill

Report, March 29, 2016, After

Action Report/Improvement

Plan

Columbia Generating Station 06/03/2016

ERO Team D Drill, Drill

Report, May 3, 2016, After

Action Report/Improvement

Plan

Columbia Generating Station 09/22/2016

ERO Team A Drill, Drill

Report, August 30, 2016, After

Action Report/Improvement

Plan

Columbia Generating Station 11/22/2016

ERO Team C Drill, Drill

Report, October 25, 2016, After

Action Report/Improvement

Plan

Columbia Generating Station 02/07/2017

ERO Team B Drill, Drill

Report, January 10, 2017, After

Action Report/Improvement

Plan

Columbia Generating Station 04/24/2017

ERO Team D Drill, Drill

Report, March 14, 2017, After

Action Report/Improvement

Plan

Columbia Generating Station 08/15/2017

ERO Team A Drill, Drill

Report, July 18, 2017, After

Action Report/Improvement

Plan

Columbia Generating Station 11/31/2017

ERO Team C Drill, Drill

Report, October 31, 2017, After

Action Report/Improvement

Plan

Fire Brigade/First Responder 11/03/2016

Drill 2016,

Contaminated/Injured Man

Fire Brigade/First Responder 11/28/2017

Drill 2017,

Contaminated/Injured Man

Inspection Type Designation Description or Title Revision/

Procedure Date

71114.01 Documents Apparent Cause Evaluation, 04/11/2016

Violation of 10 CFR 50.54(q)(2)

for Failure to Conduct Medical

Emergency Drill in 2015

Action 347032 347050 347265 347490

Requests 348108 350241 353342 354107

356181 356227 356618 356826

357471 360335 360547 361134

361195 363014 366567 366884

366958 368177 368192 369531

369776 371856 373325 373732

374110 374115 374117 372561

375641 377563 378325 378339

378341 378394 378441 378471

378644

71114.04 Procedures Columbia Generating Station 065

and Emergency Plan

Documents EPIP Classifying the Emergency, 033

13.1.1A Technical Bases

EPI-16 50.54(Q) Change Evaluation, 015

July 19, 2017

71151 Procedures EPI-18 Emergency Preparedness 025

Performance Indicators,

May 31, 2017

Action 358298 360339 361467 366785

Requests 368711 369130 369725 372372

373237 373325

71152 Action 346054 376191 377044

Requests

71153 Action 371646 371777 376985

Requests

6

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