IR 05000397/2018002: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(StriderTol Bot change)
 
(4 intermediate revisions by the same user not shown)
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:July 24, 2018 Mr. Brad Sawatzke, Chief Executive Officer Energy Northwest MD 1023 P.O. Box 968 Richland, WA 99352 SUBJECT: COLUMBIA GENERATING STATION  
{{#Wiki_filter:July 24, 2018
- NRC INTEGRATED INSPECTION REPORT 05000397/2018002 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200035/201800 1 Dear Mr. Sawatzke
 
: On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Columbia Generating Statio On July 12, 2018, the NRC inspectors discussed the results of this inspection with Mr. G. Hettel, 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 repor This finding involved a violation of NRC requirements
==SUBJECT:==
. The NRC is treating this violation as a non-cited violation (NCV)
COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018002 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200035/2018001
consistent with Section 2.3.2.a of the Enforcement Polic If you contest the violation or significance of the 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 20 555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and th e NRC R esident Inspector at the Columbia Generating Station
 
. If you disagree with a cross-cutting aspect assignment in this report, you should provi de 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 t he NRC Resident Inspector at the Columbia Generating Station
==Dear Mr. Sawatzke:==
.
On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Columbia Generating Station. On July 12, 2018, the NRC inspectors discussed the results of this inspection with Mr. G. Hettel, and other members of your staff. The results of this inspection are documented in the enclosed report.
B. Sawatzke 2 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, "Public Inspections, Exemptions, Requests for Withholding."
 
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 the 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,
Sincerely,
/RA/ Mark S. Haire, Chief Project Branch A Division of Reactor Projects Docket Nos. 50-397; 72-035 License No. NPF-21  
/RA/  
 
Mark S. Haire, Chief Project Branch A Division of Reactor Projects  
 
Docket Nos. 50-397; 72-035 License No. NPF-21  


===Enclosure:===
===Enclosure:===
Line 34: Line 45:


==Inspection Report==
==Inspection Report==
Docket Numbers: 05000397; 07200035 License Number s: NPF-21 Report Number s: 05000397/2018002; 07200035/2018001 Enterprise Identifier:
Docket Numbers:
I-2018-002-0020; 1-2018-001-0091 Licensee: Energy Northwest Facility: Columbia Generating Station and Independent Spent Fuel Storage Installation Location: Richland, Washington Inspection Dates:
05000397; 07200035  
April 1, 2018 to June 30, 2018 Inspectors:
G. Kolcum, Senior Resident Inspector L. Brandt, Resident Inspector L. Brookhart, Senior Inspector L. Carson II, Senior Health Physicist J. O'Donnell, CHP, Health Physicist Approved By:
M. Haire, Branch Chief Project Branch A Division of Reactor Projects


2
License Numbers:
NPF-21
 
Report Numbers:
05000397/2018002; 07200035/2018001
 
Enterprise Identifier: I-2018-002-0020; 1-2018-001-0091
 
Licensee:
Energy Northwest
 
Facility:
Columbia Generating Station and Independent Spent Fuel Storage
 
Installation
 
Location:
Richland, Washington
 
Inspection Dates:
April 1, 2018 to June 30, 2018
 
Inspectors:
G. Kolcum, Senior Resident Inspector
 
L. Brandt, Resident Inspector
 
L. Brookhart, Senior Inspector
 
L. Carson II, Senior Health Physicist
 
J. ODonnell, CHP, Health Physicist
 
Approved By:
M. Haire, Branch Chief
 
Project Branch A
 
Division of Reactor Projects


=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 Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2018002
===List of Findings and Violations===
-01 Closed H.12 - Avoid Complacency 71111.15 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 written procedures appropriate to the circumstances. Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW
Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2018002-01 Closed H.12 - Avoid Complacency 71111.15 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 written procedures appropriate to the circumstances. Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW-V-14B2, as part of work activities under Work Request (WR) 29127677, and rendered diesel generator 2 inoperable and unavailable.
-V-8B2, while operating a nearby demineralized water valve, DW
-V-14B2, as part of work activities under Work Request (WR) 29127677
, and rendered diesel generator 2 inoperable and unavailable
.
3


=PLANT STATUS=
=PLANT STATUS=


===The plant began the inspection period at 100 percent rated thermal power.
The plant began the inspection period at 100 percent rated thermal power. On April 19, 2018, the reactor unit was down powered to 98 percent due to feedwater heater 2C level control failure. On April 20, 2018, the unit was down powered further to 85 percent for troubleshooting.


On April 19, 2018, the reactor unit was down powered to 98 percent due to feedwater heater 2C level control failure. On April 20, 2018, the unit was down powered further to 85 percent for troubleshooting. The unit returned to rated thermal power on April 21, 2018.
The unit returned to rated thermal power on April 21, 2018.


On April 27, 2018, the reactor unit was down powered to 85 percent for economic dispatch from Bonneville Power Administration. The unit returned to rated thermal power on April 30, 2018.
On April 27, 2018, the reactor unit was down powered to 85 percent for economic dispatch from Bonneville Power Administration. The unit returned to rated thermal power on April 30, 2018.


On May 18, 2018, the reactor unit automatically scrammed due to a load reject from a grid disturbance
On May 18, 2018, the reactor unit automatically scrammed due to a load reject from a grid disturbance. The unit was restarted and synched to the grid on May 24, 2018. Reactor power was raised to 65 percent on May 25, 2018, and remained at 65 percent for economic dispatch from Bonneville Power Administration. The unit returned to rated thermal power on June 11, 2018.
. The unit was restarted and synched to the grid on May 24, 2018.
 
Reactor power was raised to 65 percent on May 25, 2018, and remained at 65 percent for economic dispatch from Bonneville Power Administration. The unit returned to rated thermal power on June 11, 2018.


On June 12, 2018, the unit was down powered to 98 percent due to trip of the 2C feedwater heater. On June 14, 2018, the unit was down powered to 85 percent to repair the 2C feedwater level controller. On June 15, 2018, the unit was down powered to 78 percent due to subsequent trip s of the 3C and 4C feedwater heaters. After maintenance, the reactor returned to rated thermal power on June 15, 2018.
On June 12, 2018, the unit was down powered to 98 percent due to trip of the 2C feedwater heater. On June 14, 2018, the unit was down powered to 85 percent to repair the 2C feedwater level controller. On June 15, 2018, the unit was down powered to 78 percent due to subsequent trips of the 3C and 4C feedwater heaters. After maintenance, the reactor returned to rated thermal power on June 15,


==INSPECTION SCOPES==
==INSPECTION SCOPES==
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.
-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.
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==
===71111.01Adverse Weather Protection Summer Readiness===
{{IP sample|IP=IP 71111.01|count=1}}


==71111.01 - Adverse Weather Protection==
===Summer Readiness===
{{IP sample|IP=IP 71111.01|count=1}}
The inspectors evaluated summer readiness of offsite and alternate alternating current power systems.
The inspectors evaluated summer readiness of offsite and alternate alternating current power systems.


==71111.04 - Equipment Alignment==
===71111.04Equipment Alignment Partial Walkdown===
{{IP sample|IP=IP 71111.04|count=4}}


===Partial Walkdown===
{{IP sample|IP=IP 71111.04|count=4}}
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
: (1) diesel generator 1 jacket water system on April 9, 2018
: (1) diesel generator 1 jacket water system on April 9, 2018
: (2) diesel generator 2 jacket water system on April 9, 2018
: (2) diesel generator 2 jacket water system on April 9, 2018
: (3) diesel generator 3 jacket water system on April 9, 2018
: (3) diesel generator 3 jacket water system on April 9, 2018
: (4) low pressure core spray system on June 1, 2018
: (4) low pressure core spray system on June 1, 2018  


==71111.05AQ - Fire Protection Annual/Quarterly==
===71111.05AQFire Protection Annual/Quarterly Quarterly Inspection===
{{IP sample|IP=IP 71111.05|count=4}}


===Quarterly Inspection===
{{IP sample|IP=IP 71111.05AQ|count=4}}
The inspectors evaluated fire protection program implementation in the following selected areas:
The inspectors evaluated fire protection program implementation in the following selected areas:
: (1) Fire Areas RC-14/1, RC-8/2, RC-5/1, and RC
: (1) Fire Areas RC-14/1, RC-8/2, RC-5/1, and RC-6/2; Divisions 1 and 2 switchgear and battery rooms; on April 6, 2018
-6/2; Divisions 1 and 2 switchgear and battery rooms
: (2) Fire Areas RC-4/1, RC-7/2, RC-9/2, and RC-19/2; Divisions 1 and 2 electrical equipment and reactor protection system rooms, remote shutdown room, and vital island corridor; on April 6, 2018
; on April 6, 2018
: (3) Fire Area TG1/2, reactor feed pump rooms, on April 18, 2018
: (2) Fire Areas RC
: (4) Fire Area RC-2/1, cable spreading room, on May 10, 2018  
-4/1, RC-7/2, RC-9/2 , and RC-19/2; Divisions 1 and 2 electrical equipment and reactor protection system rooms, remote shutdown room, and vital island corridor
; on April 6, 2018
: (3) Fire Area TG1/2, reactor feed pump rooms
, on April 18, 2018
: (4) Fire Area RC
-2/1, cable spreading room, on May 10, 2018
 
==71111.06 - Flood Protection Measures==


===Internal Flooding===
===71111.06Flood Protection Measures Internal Flooding===
{{IP sample|IP=IP 71111.06|count=1}}
{{IP sample|IP=IP 71111.06|count=1}}
The inspectors evaluated internal flooding mitigation protections in the reactor building 471 ft. level on June 22, 2018
.


==71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance==
The inspectors evaluated internal flooding mitigation protections in the reactor building 471 ft. level on June 22, 2018.


===Operator Requalification===
===71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification===
{{IP sample|IP=IP 71111.11|count=1}}
{{IP sample|IP=IP 71111.11|count=1}}
The inspectors observed and evaluated a licensed operator requalification evaluated scenario on April 16, 2018.
The inspectors observed and evaluated a licensed operator requalification evaluated scenario on April 16, 2018.


Operator Performance (1 Sample) The inspectors observed and evaluated
===Operator Performance (1 Sample)===
:
The inspectors observed and evaluated:
: (1) down power to 85 percent due to failure of feedwater heater 2C
: (1) down power to 85 percent due to failure of feedwater heater 2C, on April 20, 2018
, on April 20, 2018
: (2) startup to power increase, on May 24, 2018  
: (2) startup to power increase
, on May 24, 2018


==71111.12 - Maintenance Effectiveness==
===71111.12Maintenance Effectiveness Routine Maintenance Effectiveness===
{{IP sample|IP=IP 71111.12|count=3}}


===Routine Maintenance Effectiveness (3 Sample s)  The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:
: (1) HT-TE-SW71/2, high pressure core spray heat tracing replacement, on April 23, 2018
: (1) HT-TE-SW71/2, high pressure core spray heat tracing replacement, on April 23, 2018
: (2) E-RLY-86TM, main generator lockout relay, on May 22, 2018
: (2) E-RLY-86TM, main generator lockout relay, on May 22, 2018
: (3) RPS-RLY-K10F for EOC-RPT, maintenance to disable end of cycle recirculation pump trip relay, on May 30, 2018
: (3) RPS-RLY-K10F for EOC-RPT, maintenance to disable end of cycle recirculation pump trip relay, on May 30, 2018  


==71111.13 - Maintenance Risk Assessments and Emergent Work Control==
===71111.13Maintenance Risk Assessments and Emergent Work Control===
{{IP sample|IP=IP 71111.13|count=2}}


(2 Sample s)  The inspectors evaluated the risk assessments for the following planned and emergent work activities:
The inspectors evaluated the risk assessments for the following planned and emergent work activities:
: (1) yellow risk for heavy lifts at circulating water pump house on April 26, 2018
: (1) yellow risk for heavy lifts at circulating water pump house on April 26, 2018
: (2) yellow risk for standby gas treatment train A maintenance, week of May 14, 2018
: (2) yellow risk for standby gas treatment train A maintenance, week of May 14, 2018  


==71111.15 - Operability Determinations and Functionality Assessments==
===71111.15Operability Determinations and Functionality Assessments===
{{IP sample|IP=IP 71111.15|count=8}}
{{IP sample|IP=IP 71111.15|count=8}}
The inspectors evaluated the following operability determinations and functionality assessments:
The inspectors evaluated the following operability determinations and functionality assessments:
: (1) diesel generator 1 fuel oil pump 1B on April 1, 2018
: (1) diesel generator 1 fuel oil pump 1B on April 1, 2018
: (2) diesel generator 2 unplanned inoperability and unavailability for drain of jacket water on April 9, 2018
: (2) diesel generator 2 unplanned inoperability and unavailability for drain of jacket water on April 9, 2018
: (3) standby service water
: (3) standby service water 'B' pump house door gearbox on April 17, 2018
'B' pump house door gearbox on April 17, 2018
: (4) high pressure core spray power panel 4A voltage near minimum 120VAC on April 17, 2018
: (4) high pressure core spray power panel 4A voltage near minimum 120VAC on April 17, 2018
: (5) residual heat removal pump 1B relief valve on May 4, 2018
: (5) residual heat removal pump 1B relief valve on May 4, 2018
: (6) main steam relief valve 1B dual indication on May 18, 2018
: (6) main steam relief valve 1B dual indication on May 18, 2018
: (7) standby service water  
: (7) standby service water A spray ring header on May 24, 2018
'A' spray ring header on May 24, 2018
: (8) condensate pump 2C elevated water in oil, on May 24, 2018  
: (8) condensat e pump 2C elevated water in oil, on May 24, 2018


==71111.18 - Plant Modifications==
===71111.18Plant Modifications===
{{IP sample|IP=IP 71111.18|count=2}}
{{IP sample|IP=IP 71111.18|count=2}}
The inspectors evaluated the following temporary or permanent modifications:
The inspectors evaluated the following temporary or permanent modifications:
: (1) EC 17224, main transformer 1, 2, 3 alarm and trip function, on May 22, 2018
: (1) EC 17224, main transformer 1, 2, 3 alarm and trip function, on May 22, 2018
: (2) EC 17227, main transformer horizontal links bolting
: (2) EC 17227, main transformer horizontal links bolting, on May 22, 2018  
, on May 22, 2018


==71111.19 - Post Maintenance Testing==
===71111.19Post Maintenance Testing===
{{IP sample|IP=IP 71111.19|count=8}}


(8 Sample s)  The inspectors evaluated the following post maintenance tests:
The inspectors evaluated the following post maintenance tests:
: (1) diesel generator 1 fuel oil pump 1B
: (1) diesel generator 1 fuel oil pump 1B, on April 1, 2018
, on April 1, 2018
: (2) residual heat removal loop B operability test on April 1, 2018
: (2) residual heat removal loop B operability test on April 1, 2018
: (3) reactor building ventilation system operation on April 3, 2018
: (3) reactor building ventilation system operation on April 3, 2018
Line 177: Line 196:
: (6) power panel 4A transformer replacement on May 4, 2018
: (6) power panel 4A transformer replacement on May 4, 2018
: (7) main transformer 1, 2, 3 relay testing on May 22, 2018
: (7) main transformer 1, 2, 3 relay testing on May 22, 2018
: (8) main transformer 1 Buchholz relay testing on May 22, 2018
: (8) main transformer 1 Buchholz relay testing on May 22, 2018  


==71111.20 - Refueling and Other Outage Activities==
===71111.20Refueling and Other Outage Activities===
{{IP sample|IP=IP 71111.20|count=1}}
{{IP sample|IP=IP 71111.20|count=1}}
The inspectors evaluated forced outage activities following the load reject grid disturbance from May 18, 2018 to May 25, 2018.
The inspectors evaluated forced outage activities following the load reject grid disturbance from May 18, 2018 to May 25, 2018.


==71111.22 - Surveillance Testing==
===71111.22Surveillance Testing  


The inspectors evaluated the following surveillance tests:
The inspectors evaluated the following surveillance tests:
Routine===
Routine===
{{IP sample|IP=IP 71111.12|count=3}}
{{IP sample|IP=IP 71111.22|count=3}}
: (1) ISP-SEIS-M201, Seismic System Channel Check, Revision 6, on April 23, 2018
: (1) ISP-SEIS-M201, Seismic System Channel Check, Revision 6, on April 23, 2018
: (2) OSP-ELEC-M703, HPCS Diesel Generator Monthly Operability Test, Revision 66, on April 25, 2018
: (2) OSP-ELEC-M703, HPCS Diesel Generator Monthly Operability Test, Revision 66, on April 25, 2018
: (3) ISP-RPS-S901, RPS (Channel A1) and EOC Recirc Pump Trip  
: (3) ISP-RPS-S901, RPS (Channel A1) and EOC Recirc Pump Trip - TGV Fast Closure RPS-PS-5A - CFT/CC, Revision 0, on May 7, 2018; and ISP RPS-S902, RPS (Channel A2) and EOC Recirc Pump Trip - TGV Fast Closure RPS-PS-5C - CFT/CC, Revision 0, on May 9, 2018  
- TGV Fast Closure RPS-PS-5A - CFT/CC, Revision 0, on May 7, 2018
; and ISP RPS-S902, RPS (Channel A2) and EOC Recirc Pump Trip  
- TGV Fast Closure RPS
-PS-5C - CFT/CC, Revision 0, on May 9, 2018 In-service (1 Sample)
: (1) OSP-HPCS/IST-Q701, HPCS System Operability Test, Revision 53, on April 23, 2018 Reactor Coolant System Leak Detection (1 Sample)
: (1) daily reactor coolant system leak checks , shift and daily instrument checks (Modes 1, 2, 3) on June 25, 2018


==71114.06 - Drill Evaluation==
===In-service (1 Sample)===
: (1) OSP-HPCS/IST-Q701, HPCS System Operability Test, Revision 53, on April 23, 2018


===Drill/Training Evolution===
===Reactor Coolant System Leak Detection (1 Sample)===
: (1) daily reactor coolant system leak checks, shift and daily instrument checks (Modes 1, 2, 3) on June 25, 2018
 
===71114.06Drill Evaluation
 
Drill/Training Evolution===
{{IP sample|IP=IP 71114.06|count=1}}
{{IP sample|IP=IP 71114.06|count=1}}
The inspectors evaluated the emergency preparedness training drill on May 15, 2018
 
The inspectors evaluated the emergency preparedness training drill on May 15,


==RADIATION SAFETY==
==RADIATION SAFETY==
 
===71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Radiological Work Planning===
==71124.02 - Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls==
 
===Radiological Work Planning===
{{IP sample|IP=IP 71124.02|count=1}}
{{IP sample|IP=IP 71124.02|count=1}}


The inspectors evaluated the licensee's radiological work planning by reviewing the following activities:
The inspectors evaluated the licensees radiological work planning by reviewing the following activities:
: (1) RWP 30004209, EDR Tank
: (1) RWP 30004209, EDR Tank-5 Desludge
-5 Desludge
: (2) RWP 30004210, EDR Tank-5 Desludge High Risk
: (2) RWP 30004210
: (3) RWP 30003882, Main Steam Relief Valves
, EDR Tank-5 Desludge High Risk
: (4) RWP 30003098, Wetwell Cleanup and Inspection
: (3) RWP 30003882
: (5) RWP 30003873, Drywell Shielding  
, Main Steam Relief Valves
: (4) RWP 30003098
, Wetwell Cleanup and Inspection
: (5) RWP 30003873
, Drywell Shielding Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)===
The inspectors


===evaluated dose estimates and exposure tracking.
===Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)===
The inspectors evaluated dose estimates and exposure tracking.


==71124.04 - Occupational Dose Assessment==
===71124.04Occupational Dose Assessment Source Term Characterization===
{{IP sample|IP=IP 71124.04|count=1}}


===Source Term Characterization===
The inspectors evaluated the licensees source term characterization.
{{IP sample|IP=IP 71124.04|count=1}}


The inspectors evaluated the licensee's source term characterization
===External Dosimetry (1 Sample)===
. External Dosimetry (1 Sample)===
The inspectors evaluated the licensees external dosimetry program.
The inspectors


===evaluated the licensee's external dosimetry program
===Internal Dosimetry (1 Sample)===
. Internal Dosimetry (1 Sample)===
The inspectors evaluated the licensees internal dosimetry program.
The inspectors


===evaluated the licensee's internal dosimetry program
===Special Dosimetric Situations (1 Sample)===
.
The inspectors evaluated the licensees performance for special dosimetry situations.
Special Dosimetric Situations (1 Sample)===
The inspectors evaluated the licensee's performance for special dosimetr y situations


==OTHER ACTIVITIES  
==OTHER ACTIVITIES - BASELINE==
- BASELINE==
===71151Performance Indicator Verification===
71151-Performance Indicator Verification (5 Samples)  The inspectors verified licensee performance indicators submittals listed below:
{{IP sample|IP=IP 71151|count=5}}
: (1) MS06:  Emergency AC Power Systems (07/01/2017
-06/30/2018)
: (2) MS07:  High Pressure Injection System s (07/01/2017
-06/30/2018)
: (3) MS08:  Heat Removal Systems (07/01/2017
-06/30/2018)
: (4) MS09:  Residual Heat Removal Systems (07/01/2017
-06/30/2018)
: (5) MS10:  Cooling Water Support Systems (07/01/2017
-06/30/2018)


==71152 - Problem Identification and Resolution==
The inspectors verified licensee performance indicators submittals listed below:
: (1) MS06: Emergency AC Power Systems (07/01/2017-06/30/2018)
: (2) MS07: High Pressure Injection Systems (07/01/2017-06/30/2018)
: (3) MS08: Heat Removal Systems (07/01/2017-06/30/2018)
: (4) MS09: Residual Heat Removal Systems (07/01/2017-06/30/2018)
: (5) MS10: Cooling Water Support Systems (07/01/2017-06/30/2018)


===Semiannual Trend Review===
===71152Problem Identification and Resolution Semiannual Trend Review===
{{IP sample|IP=IP 71152|count=1}}
{{IP sample|IP=IP 71152|count=1}}


The inspectors reviewed the licensee's corrective action program for trends that might be indicative of a more significant safety issue.
The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue. The inspectors reviewed a negative trend in human performance and documented one observation.
 
===Annual Follow-up of Selected Issues (1 Sample)===
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
: (1) Independent Spent Fuel Storage Installation cask stuck in reactor building, on April 7, 2018


The inspectors reviewed a negative trend in human performance and documented one observation.
===71153Follow-up of Events and Notices of Enforcement Discretion Events===
{{IP sample|IP=IP 71153|count=1}}


Annual Follow
The inspectors evaluated the plant scram from a load reject due to a grid disturbance and the licensees response on May 18,
-up of Selected Issues (1 Sample)  The inspectors reviewed the licensee's implementation of its corrective action program related to the following issues:
: (1) Independent Spent Fuel Storage Installation cask stuck in reactor building
, on April 7, 2018  71153-Follow-up of Events and Notices of Enforcement Discretion Events (1 Sample)  The inspectors evaluated the plant scram f rom a load reject due to a grid disturbance and the licensee's response on May 18, 2018
.


==OTHER ACTIVITIES==
==OTHER ACTIVITIES==
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants The inspectors evaluated the licensee's operation of the Independent Spent Fuel Storage Installation (ISFSI) from April 2 through April 5, 2018
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL  
, on-site at Columbia Generating Station (CGS). The CGS ISFSI was licensed as a general Part 72 license and utilized the Holtec HI-STORM 100 System, approved under Certificate of Compliance 1014, License Amendment 9, Revision 1
 
, and Final Safety Analysis Report (FSAR), Revision 13. The CGS had been loading HI
60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants  
-STORM 100S Version 243 overpacks containing the Multi
 
-Purpose Canister, MPC
The inspectors evaluated the licensees operation of the Independent Spent Fuel Storage Installation (ISFSI) from April 2 through April 5, 2018, on-site at Columbia Generating Station (CGS).
-68, and more recently the MPC
 
-68M. CGS's ISFSI contained a total of 39 HI-STORM overpacks at the time of the routine inspection. CGS was in the middle of its 2018 loading campaign. Inspectors were onsite to observe loading activities associated with cask Number 40. The CGS planned to complete an additional 5 canisters by the end of the campaign, increasing the total number of casks to 45 at the ISFSI.
The CGS ISFSI was licensed as a general Part 72 license and utilized the Holtec HI-STORM 100 System, approved under Certificate of Compliance 1014, License Amendment 9, Revision 1, and Final Safety Analysis Report (FSAR), Revision 13. The CGS had been loading HI-STORM 100S Version 243 overpacks containing the Multi-Purpose Canister, MPC-68, and more recently the MPC-68M. CGSs ISFSI contained a total of 39 HI-STORM overpacks at the time of the routine inspection. CGS was in the middle of its 2018 loading campaign. Inspectors were onsite to observe loading activities associated with cask Number 40. The CGS planned to complete an additional 5 canisters by the end of the campaign, increasing the total number of casks to 45 at the ISFSI.


The ISFSI activities specifically reviewed during the on
The ISFSI activities specifically reviewed during the on-site inspection and the subsequent in-office review included:
-site inspection and the subsequent in-office review included:
: (1) Evaluated and observed cask transportation operations.
: (1) Evaluated and observed cask transportation operations.
: (2) Reviewed the licensee's loading, processing, and heavy load procedures associated with their current dry fuel storage campaign.
: (2) Reviewed the licensee's loading, processing, and heavy load procedures associated with their current dry fuel storage campaign.
: (3) Reviewed the licensee's corrective action program implementation for ISFSI operations since the last routine ISFSI inspection
: (3) Reviewed the licensees corrective action program implementation for ISFSI operations since the last routine ISFSI inspection, which was completed in July 2016.
, which was completed in July 201 6.
: (4) Reviewed quality assurance (QA) program implementation, including recent QA audits, surveillances, receipt inspection, and quality control activities.
: (4) Reviewed quality assurance (QA) program implementation, including recent QA audits, surveillances, receipt inspection, and quality control activities.
: (5) Reviewed documentation related to Technical Specification (TS) required operational surveillance activities and FSAR required annual maintenance activities.
: (5) Reviewed documentation related to Technical Specification (TS) required operational surveillance activities and FSAR required annual maintenance activities.
: (6) Reviewed the licensee's radiological monitoring data for the calendar years 2016 and 20 17.
: (6) Reviewed the licensees radiological monitoring data for the calendar years 2016 and 2017.
: (7) Reviewed spent fuel documentation for the canisters loaded since the last routine ISFSI inspection (Canisters 37
: (7) Reviewed spent fuel documentation for the canisters loaded since the last routine ISFSI inspection (Canisters 37-40) to confirm the fuel met all TS requirements for storage at the ISFSI.
-40) to confirm the fuel met all TS requirements for storage at the ISFSI.
: (8) Reviewed annual maintenance activities for heavy lifting components which included special lifting devices, the vertical cask transporter, and the sites single-failure proof cask handling crane.
: (8) Reviewed annual maintenance activities for heavy lifting components which included special lifting devices, the vertical cask transporter, and the site's single-failure proof cask handling crane.
: (9) Reviewed all 72.48 safety evaluations/screenings for changes made to the licensees ISFSI operations in accordance with Inspection Procedure 60857 since the last routine ISFSI inspection.
: (9) Reviewed all 72.48 safety evaluations/screenings for changes made to the licensee' s ISFSI operations in accordance with Inspection Procedure 60857 since the last routine ISFSI inspection.
: (10) Reviewed all changes made to the licensees 72.212 Report from Revision 9 to Revision 10 under the licensees 72.48 program in accordance with Inspection Procedure 60857.
: (10) Reviewed all changes made to the licensee's 72.212 Report from Revision 9 to Revision 10 under the licensee's 72.48 program in accordance with Inspection Procedure 60857.


The inspectors did not identify any issues of concerns requiring documentation.
The inspectors did not identify any issues of concerns requiring documentation.


==INSPECTION RESULTS==
==INSPECTION RESULTS==
Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems   Green NCV 05000397/2018002
Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems  
-01 Closed H.12 - Avoid Complacency 71111.15 The inspectors reviewed a self
 
-revealed, Green, non
Green NCV 05000397/2018002-01 Closed H.12 - Avoid Complacency 71111.15 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 written procedures appropriate to the circumstances. Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW-V-14B2, as part of work activities under Work Request (WR) 29127677, and rendered diesel generator 2 inoperable and unavailable.
-cited violation of Technical Specification 5.4.1.a for the licensee's failure to perform maintenance in accordance with written procedures appropriate to the circumstances. Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW
-V-14B2, as part of work activities under Work Request (WR) 29127677
, and rendered diesel generator 2 inoperable and unavailable
. Description
:  On April 9, 2018, while operating demineralized water valve DW
-V-14B2, maintenance personnel inadvertently bumped and partially opened diesel cooling water valve DCW-V-8B2. The maintenance personnel completed their work activities, cleaned up the work area, and returned to the shop
, unaware that their actions resulted in the partial opening of DCW-V-8B2. Meanwhile, the accidental opening of this diesel cooling water valve caused the diesel generator 2 diesel cooling water expansion tank to drain into a nearby floor drain. Approximately 40 minutes later, the main control room received a diesel generator 2 local panel trouble alarm. Operations personnel responded to the alarm, found the diesel cooling water valve out of position (partially open), and closed the valve. During this event, the tank level reached
-4.5 inches, which is outside the normal standby lineup band of +2 to +6 inches. This rendered diesel generator 2 inoperable and caused an unplanned entry into Technical Specification 3.8.1 for one required diesel generator inoperable. The licensee restored the required water level within 40 minutes of declaring the diesel inoperable. The licensee then verified the diesel was in the proper standby lineup and restored the diesel to operable status approximately 2 hours later. Subsequently, the licensee initiated an investigation of the event that stated the diesel generator was rendered unavailable because it would not have been able to complete its 24
-hour mission time with the open diesel cooling water valve. The diesel generator would have started, loaded, and overheated in approximately 10 minutes without a credited cooling water makeup source. Total unavailability time accrued was 86 minutes. Procedure 1.3.81, "Maintaining Plant Component Status Control," Revision 12, ensures plant component status control is maintained. Step 5.5.2 states that personnel performing work in the plant that are given permission to manipulate the plant are required to accept responsibility for, and are accountable for
, maintaining plant component status control. Step 6.6.2.d states, in part, that electrical, mechanical, and instrumentation and control maintenance personnel manipulate components only as specified in approved procedures and work packages that have been authorized by the shift manager or designee.


The inspectors noted that step 6.1 of Procedure MI-1.8, "Conduct of Maintenance," Revision 70, directs all maintenance personnel to use and adhere to the station error prevention tools as described in Procedure STANDARD
=====Description:=====
-01. Procedure STANDARD
On April 9, 2018, while operating demineralized water valve DW-V-14B2, maintenance personnel inadvertently bumped and partially opened diesel cooling water valve DCW-V-8B2. The maintenance personnel completed their work activities, cleaned up the work area, and returned to the shop, unaware that their actions resulted in the partial opening of DCW-V-8B2. Meanwhile, the accidental opening of this diesel cooling water valve caused the diesel generator 2 diesel cooling water expansion tank to drain into a nearby floor drain.
-01, "Worker Error Prevention Tools," Revision 10, step 3.3 states, in part, that station personnel are responsible for performing work activities using the error prevention tools in accordance with this standard. Section 4.0 details the fundamental human performance tools workers apply during work activities to help them maintain positive control, regardless of their perception of the risk. For example, Section 4.2 describes the Take 2 error prevention tool. Step 4.2.1 states, in part, that Take 2 is a jobsite review done when first arriving at the jobsite.


The worker develops an accurate understanding of- the work environment-by taking time to become acquainted with the immediate work area. Step 4.2.4.a instructs the worker to review the Take 2 lanyard or job aid. The Take 2 job aid lists several questions to engage the worker. Question 7 asks, "Is there a component misposition or bump hazard in the work area (2 ft zone)? If yes, engage Operations."  The licensee's event investigation indicated that the maintenance personnel conducted a Take 2 upon arriving at the jobsite but did not refer to their Take 2 job aid.
Approximately 40 minutes later, the main control room received a diesel generator 2 local panel trouble alarm. Operations personnel responded to the alarm, found the diesel cooling water valve out of position (partially open), and closed the valve. During this event, the tank level reached -4.5 inches, which is outside the normal standby lineup band of +2 to +6 inches.


Notwithstanding the plant procedure for preventing inadvertent operation of equipment, the inspectors noted that WR 29127677 did not contain the necessary controls to ensure that safety-related equipment was not adversely affected during maintenance.
This rendered diesel generator 2 inoperable and caused an unplanned entry into Technical Specification 3.8.1 for one required diesel generator inoperable. The licensee restored the required water level within 40 minutes of declaring the diesel inoperable. The licensee then verified the diesel was in the proper standby lineup and restored the diesel to operable status approximately 2 hours later. Subsequently, the licensee initiated an investigation of the event that stated the diesel generator was rendered unavailable because it would not have been able to complete its 24-hour mission time with the open diesel cooling water valve. The diesel generator would have started, loaded, and overheated in approximately 10 minutes without a credited cooling water makeup source. Total unavailability time accrued was 86 minutes.
 
Procedure 1.3.81, Maintaining Plant Component Status Control, Revision 12, ensures plant component status control is maintained. Step 5.5.2 states that personnel performing work in the plant that are given permission to manipulate the plant are required to accept responsibility for, and are accountable for, maintaining plant component status control. Step 6.6.2.d states, in part, that electrical, mechanical, and instrumentation and control maintenance personnel manipulate components only as specified in approved procedures and work packages that have been authorized by the shift manager or designee.
 
The inspectors noted that step 6.1 of Procedure MI-1.8, Conduct of Maintenance, Revision 70, directs all maintenance personnel to use and adhere to the station error prevention tools as described in Procedure STANDARD-01. Procedure STANDARD-01, Worker Error Prevention Tools, Revision 10, step 3.3 states, in part, that station personnel are responsible for performing work activities using the error prevention tools in accordance with this standard. Section 4.0 details the fundamental human performance tools workers apply during work activities to help them maintain positive control, regardless of their perception of the risk. For example, Section 4.2 describes the Take 2 error prevention tool.
 
Step 4.2.1 states, in part, that Take 2 is a jobsite review done when first arriving at the jobsite.


Corrective Actions:  The licensee's corrective actions included immediately closing the diesel cooling water valve, replenishing the diesel cooling water level, restoring diesel generator 2 to operable status, and completing an event investigation.
The worker develops an accurate understanding of the work environment by taking time to become acquainted with the immediate work area. Step 4.2.4.a instructs the worker to review the Take 2 lanyard or job aid. The Take 2 job aid lists several questions to engage the worker. Question 7 asks, Is there a component misposition or bump hazard in the work area (2 ft zone)? If yes, engage Operations. The licensees event investigation indicated that the maintenance personnel conducted a Take 2 upon arriving at the jobsite but did not refer to their Take 2 job aid.


Corrective Action Reference(s):  Action Request 378835 Performance Assessment
Notwithstanding the plant procedure for preventing inadvertent operation of equipment, the inspectors noted that WR 29127677 did not contain the necessary controls to ensure that safety-related equipment was not adversely affected during maintenance.
:  Performance Deficiency:  The failure to perform maintenance in accordance with documented instructions appropriate to the circumstances was a performance deficiency.


Screeni ng: The performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW
Corrective Actions: The licensees corrective actions included immediately closing the diesel cooling water valve, replenishing the diesel cooling water level, restoring diesel generator 2 to operable status, and completing an event investigation.
-V-8B2, while operating a nearby demineralized water valve, DW
-V-14B2, as part of work activities under WR 29127677 , and rendered diesel generator 2 inoperable and unavailable.


Significance:
Corrective Action Reference(s): Action Request 378835
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 2, "Mitigating Systems Screening Questions," dated June 19, 2012. The inspectors determined the finding was of very low safety significance (Green) because all of the screening questions were answered in the negative.


Cross-cutting Aspect: This finding has a cross
=====Performance Assessment:=====
-cutting aspect in the area of human performance, avoid complacency, in that the licensee failed to implement appropriate error reduction tools and recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes.
Performance Deficiency: The failure to perform maintenance in accordance with documented instructions appropriate to the circumstances was a performance deficiency.


Specifically, licensee staff failed to implement the guidance found in the Take 2 card which demonstrated complacency in the perceived lack of intrusiveness of the work [H.12].
Screening: The performance deficiency was more than minor, and therefore a finding, because it was associated with the configuration control attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW-V-14B2, as part of work activities under WR 29127677, and rendered diesel generator 2 inoperable and unavailable.
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 Procedure 1.3.81, "Maintaining Plant Component Status Control," Revision 12, to meet the Regulatory Guide 1.33 requirement.


Step 6.6.2.d states, in part, that electrical, mechanical, and instrumentation and control maintenance personnel manipulate components only as specified in approved procedures and work packages that have been authorized by the shift manager or designee.
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 2, Mitigating Systems Screening Questions, dated June 19, 2012. The inspectors determined the finding was of very low safety significance (Green) because all of the screening questions were answered in the negative.


Contrary to the above, on April 9, 2018, the licensee did not manipulate components only as specified in approved procedures and work packages that had been authorized by the shift manager or designee. Specifically, the licensee inadvertently bumped and partially opened diesel cooling water valve DCW
Cross-cutting Aspect: This finding has a cross-cutting aspect in the area of human performance, avoid complacency, in that the licensee failed to implement appropriate error reduction tools and recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, licensee staff failed to implement the guidance found in the Take 2 card which demonstrated complacency in the perceived lack of intrusiveness of the work [H.12].  
-V-8B2 as part of work activities under WR 29127677
, and rendered diesel generator 2 inoperable and unavailable
. Disposition:  This violation is being treated as a non
-cited violation
, consistent with Section 2.3.2.a of the NRC Enforcement Policy
.


Observation
=====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 Procedure 1.3.81, Maintaining Plant Component Status Control, Revision 12, to meet the Regulatory Guide 1.33 requirement. Step 6.6.2.d states, in part, that electrical, mechanical, and instrumentation and control maintenance personnel manipulate components only as specified in approved procedures and work packages that have been authorized by the shift manager or designee.


==71152 - Semiannual Trend Review The inspectors performed an in==
Contrary to the above, on April 9, 2018, the licensee did not manipulate components only as specified in approved procedures and work packages that had been authorized by the shift manager or designee. Specifically, the licensee inadvertently bumped and partially opened diesel cooling water valve DCW-V-8B2 as part of work activities under WR 29127677, and rendered diesel generator 2 inoperable and unavailable.


-depth review of the licensee's evaluation and corrective actions related to human performance issues. Since the end of refueling outage RF23 in June 2017 , the licensee has initiated multiple condition reports documenting human performance errors.
Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.


The licensee had also identified an adverse trend as documented in Action Request s 377654, 377416, and 378892
Observation
.


This review focused on condition reports that documented plant component status control errors and failures to follow procedures. While many of the human performance issues were of minor significance, several resulted in NRC documented findings:  FIN 05000397/2017004
==71152 - Semiannual Trend==
-02, "Failure to Follow Procedure Results in Isolation of Reactor Feedwater Minimum Flow Lines."  (ADAMS Accession Number ML18036B104)
Review The inspectors performed an in-depth review of the licensees evaluation and corrective actions related to human performance issues. Since the end of refueling outage RF23 in June 2017, the licensee has initiated multiple condition reports documenting human performance errors. The licensee had also identified an adverse trend as documented in Action Requests 377654, 377416, and 378892.
NCV 05000397/201 8001-01 , "Failure to Follow Procedure Leads to Loss of Secondary Containment." (ADAMS Accession Number ML18116A407)  NCV 05000397/2018002
-01, "Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System."  (Section 71111.15 of this report)
The inspectors noted that the licensee appropriately considered extent of condition and cause when scheduling corrective action assignments. These actions included a site-wide initiative to identify and eliminat e any potential plant component status control hazards and a supervisor observation "blitz" that focused on human performance behaviors such as pre
-job briefs, use of the Take 2 card, procedure use and adherence, and supervisory oversig ht. The inspectors assessed the licensee's problem identification threshold, cause analyses, and compensatory actions.


The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.
This review focused on condition reports that documented plant component status control errors and failures to follow procedures. While many of the human performance issues were of minor significance, several resulted in NRC documented findings:
* FIN 05000397/2017004-02, Failure to Follow Procedure Results in Isolation of Reactor Feedwater Minimum Flow Lines. (ADAMS Accession Number ML18036B104)
* NCV 05000397/2018001-01, Failure to Follow Procedure Leads to Loss of Secondary Containment. (ADAMS Accession Number ML18116A407)
* NCV 05000397/2018002-01, Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System. (Section 71111.15 of this report)
The inspectors noted that the licensee appropriately considered extent of condition and cause when scheduling corrective action assignments. These actions included a site-wide initiative to identify and eliminate any potential plant component status control hazards and a supervisor observation blitz that focused on human performance behaviors such as pre-job briefs, use of the Take 2 card, procedure use and adherence, and supervisory oversight. The inspectors assessed the licensees problem identification threshold, cause analyses, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.


EXIT MEETIN GS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
==EXIT MEETINGS AND DEBRIEFS==
The inspectors verified no proprietary information was retained or documented in this report.


The inspectors confirmed that proprietary information was controlled to protect from public disclosure.
The inspectors confirmed that proprietary information was controlled to protect from public disclosure.


On April 5, 2018, the inspector s presented the results from the routine ISFSI inspection to Mr. G. Hettel, Vice President of Operations (title at the time of the ISFSI inspection, but subsequently assumed the title of Senior Vice President and Chief Nuclear Officer
On April 5, 2018, the inspectors presented the results from the routine ISFSI inspection to Mr. G. Hettel, Vice President of Operations (title at the time of the ISFSI inspection, but subsequently assumed the title of Senior Vice President and Chief Nuclear Officer), and other members of the licensee staff.
), and other members of the licensee staff.
 
On May 24, 2018, the inspectors presented the baseline radiation protection inspection results to Mr. G. Hettel, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.


On May 24, 2018, the inspector s presented the baseline radiation protection inspection results to Mr. G. Hettel, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff. On July 12, 2018, the inspector s presented the quarterly resident inspector inspection results to Mr. G. Hettel , Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.
On July 12, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. G. Hettel, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.


=DOCUMENTS REVIEWED=
=DOCUMENTS REVIEWED=
Line 383: Line 369:
71111.01 - Adverse Weather Protection
71111.01 - Adverse Weather Protection
Action Requests
Action Requests
379022 381176   Procedures
379022
(Number) Title Revision 13.1.1 Classifying the Emergency
381176  
4 9 13.1.1A Classifying the Emergency  
 
- Technical Bases
Procedures  
33 ABN-ELEC-GRID Degraded Off Site Power Grid
(Number)
10 SOP-HOTWEATHER
Title
-OPS Hot Weather Operations
Revision
6 SOP-WARMWEATHER
13.1.1
-OPS Warm Weather Operations
Classifying the Emergency
15  71111.04 - Equipment Alignment
049
Procedures
13.1.1A
(Number) Title Revision 5.5.1 Overriding ECCS Valve Logic to Allow
Classifying the Emergency - Technical Bases
Throttling RPV Injection
033
006 OSP-LPCS-M102 LPCS Valve Lineup
ABN-ELEC-GRID
2 S OP-LPCS-LU LPCS Valve and Breaker Lineup
Degraded Off Site Power Grid
003 SOP-LPCS-STBY Placing LPCS in Standby Status
010
2 SOP-DG-DCW Emergency Diesel Generator Jacket Water Cooling
SOP-HOTWEATHER-OPS
014 SOP-DG1-LU Emergency Diesel
Hot Weather Operations
Generator (Div 1) Valve and Power Supply Lineup
006
006 SOP-DG2-LU Emergency Diesel Generator (Div 2) Valve and Power Supply Lineup
SOP-WARMWEATHER-
006 SOP-DG3-LU High Pressure Core Spray Diesel Generator Valve and Power Supply Lineup
OPS
007 Miscellaneous Documents  
Warm Weather Operations
(Number) Title Revision Final Safety Analysis Report
015
064   71111.05AQ  
 
- Fire Protection Annual/Quarterly
71111.04 - Equipment Alignment
Procedures  
(Number)
Title
Revision
5.5.1
Overriding ECCS Valve Logic to Allow Throttling
RPV Injection
006
OSP-LPCS-M102
LPCS Valve Lineup
2
SOP-LPCS-LU
LPCS Valve and Breaker Lineup
003
SOP-LPCS-STBY
Placing LPCS in Standby Status
2
SOP-DG-DCW
Emergency Diesel Generator Jacket Water Cooling
014
SOP-DG1-LU
Emergency Diesel Generator (Div 1) Valve and
Power Supply Lineup
006
SOP-DG2-LU
Emergency Diesel Generator (Div 2) Valve and
Power Supply Lineup
006
SOP-DG3-LU
High Pressure Core Spray Diesel Generator Valve
and Power Supply Lineup
007
Miscellaneous Documents  
(Number)
Title
Revision
Final Safety Analysis Report
064  
 
71111.05AQ - Fire Protection Annual/Quarterly
Action Requests
Action Requests
378829 379167 379972
378829
Procedures
379167
(Number) Title Revision 1.3.10C Control of Transient Combustibles
379972  
20 PFP-RW-467 Radwaste 467
 
005 PFP-RW-484-487 Radwaste 484
Procedures  
-487 005 1.3.10A Control of Ignition Sources
(Number)
17 FPP-1.6 Combustible Loading Calculation Control
Title
2 FPP-2.2.12 Annual Fire Door Operability Test 00 5 FPP-2.2.7 Fire Protection Water System Inspections
Revision
6 PFP-TG-441-456 Turbine Generator 441
1.3.10C
-456 008 Miscellaneous Documents  
Control of Transient Combustibles
(Number) Title Revision FSAR Fire Hazards Analysis
20
BIP 17-0613 Barrier Impairment Permit
PFP-RW-467
BIP 17-0614 Barrier Impairment Permit
Radwaste 467
BIP 17-0615 Barrier Impairment Permit
005
BIP 17-0616 Barrier Impairment Permit
PFP-RW-484-487
BIP 17-0643 Barrier Impairment Permit
Radwaste 484-487
BIP 17-0662 Barrier Impairment Permit
005
BIP 18-0096 Barrier Impairment Permit
1.3.10A
BIP 18-0097 Barrier Impairment Permit
Control of Ignition Sources
BIP 18-0111 Barrier Impairment Permit
017
BIP 18-0017 Barrier Impairment Permit
FPP-1.6
BIP 18-0018 Barrier Impairment Permit
Combustible Loading Calculation Control
BIP 18-0019 Barrier Impairment Permit
2
BIP 18-0029 Barrier Impairment Permit
FPP-2.2.12
BIP 18-0031 Barrier Impairment Permit
Annual Fire Door Operability Test
BIP 18-0037 Barrier Impairment Permit BIP 18-0041 Barrier Impairment Permit
005
BIP 18-0050 Barrier Impairment Permit
FPP-2.2.7
CALC FP-02-85-03 Combustible Loading Calculation
Fire Protection Water System Inspections
010   71111.06 - Flood Protection Measures
006
PFP-TG-441-456
Turbine Generator 441-456
008
Miscellaneous Documents  
(Number)
Title
Revision
FSAR Fire Hazards Analysis
BIP 17-0613
Barrier Impairment Permit
BIP 17-0614
Barrier Impairment Permit
BIP 17-0615
Barrier Impairment Permit
BIP 17-0616
Barrier Impairment Permit
BIP 17-0643
Barrier Impairment Permit
BIP 17-0662
Barrier Impairment Permit
BIP 18-0096
Barrier Impairment Permit
BIP 18-0097
Barrier Impairment Permit
BIP 18-0111
Barrier Impairment Permit
BIP 18-0017
Barrier Impairment Permit
BIP 18-0018
Barrier Impairment Permit
BIP 18-0019
Barrier Impairment Permit
BIP 18-0029
Barrier Impairment Permit
BIP 18-0031
Barrier Impairment Permit
BIP 18-0037
Barrier Impairment Permit
BIP 18-0041
Barrier Impairment Permit
BIP 18-0050
Barrier Impairment Permit
CALC FP-02-85-03
Combustible Loading Calculation
010  
 
71111.06 - Flood Protection Measures
Action Requests
Action Requests
378764     Procedures
378764  
(Number) Title Revision ABN-FLOODING Flooding 0 20 ME-02-02-02 Calculation for Reactor Building Flooding Analysis
 
4 PFP-RB-572 Reactor 572
Procedures  
4  71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
(Number)
Title
Revision
ABN-FLOODING
Flooding
20
ME-02-02-02
Calculation for Reactor Building Flooding Analysis
004
PFP-RB-572
Reactor 572
004
 
71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance
Action Requests
Action Requests
379240
379240  
Procedures
 
(Number) Title Revision 13.1.1 Classifying the Emergency
Procedures  
048 OI-0 9 Operations Standards and Expectation
(Number)
s 0 64 1.3.1 Operating Policy, Programs, and Practices
Title
26 5.1.1 RPV Control
Revision
21 5.2.1 Primary Containment Control
13.1.1
2 7 5.3.1 Secondary Containment Control 0 20 Miscellaneous Documents  
Classifying the Emergency
(Number) Title Revision LR002398 Cycle 18-2 Evaluated Scenario
048
001 Crew F Evaluated Scenario Cycle 18
OI-09
-2 4.0 Critique Summary
Operations Standards and Expectations
000   71111.12 - Maintenance Effectiveness
064
1.3.1
Operating Policy, Programs, and Practices
26
5.1.1
RPV Control
21
5.2.1
Primary Containment Control
27
5.3.1
Secondary Containment Control
20
Miscellaneous Documents  
(Number)
Title
Revision
LR002398
Cycle 18-2 Evaluated Scenario
001
Crew F Evaluated Scenario Cycle 18-2
4.0 Critique Summary
000  
 
71111.12 - Maintenance Effectiveness  
 
Action Requests
Action Requests
380427     Work Orders
380427  
2094222 02128788 29142758   Procedures
 
(Number) Title Revision 1.5.11 Maintenance Rule Program
Work Orders
1 5 OI-53 Offsite Power
2094222
1 4 SOP-RPS-OPS Reactor Protection System Operation
2128788
15 SOP-RPS-START Reactor Protection System Startup
29142758  
7  71111.13 - Maintenance Risk Assessments and Emergent Work Control
 
Procedures  
(Number)
Title
Revision
1.5.11
Maintenance Rule Program
015
OI-53
Offsite Power
014
SOP-RPS-OPS
Reactor Protection System Operation
015
SOP-RPS-START
Reactor Protection System Startup
007
 
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Work Orders
Work Orders
2085935     Procedures
2085935  
(Number) Title Revision 1.3.83 Protected Equipment Program
 
26 1.5.14 Risk Assessment and Management for Maintenance/Surveillance Activities
Procedures  
040 1.5.11 Maintenance Rule Program
(Number)
15 WCI-4 Online Work Control Process
Title
48 1.3.76 Integrated Risk Management
Revision
50
1.3.83
Protected Equipment Program
26
1.5.14
Risk Assessment and Management for
Maintenance/Surveillance Activities
040
1.5.11
Maintenance Rule Program
015
WCI-4
Online Work Control Process
048
1.3.76
Integrated Risk Management
050
 
Miscellaneous Documents  
Miscellaneous Documents  
(Number) Title Date High Risk Work Plan for Underwater Diving in Support of CW
(Number)
-P-1C 01/16/2018
Title
Date
High Risk Work Plan for Underwater Diving in
Support of CW-P-1C
01/16/2018  
 
71111.15 - Operability Determinations and Functionality Assessments
71111.15 - Operability Determinations and Functionality Assessments
Action Requests
Action Requests
306206 371516 378475 378835 378990 379120 379244 379504 380257 380307   Work Orders
306206
2123413 02126245    Procedures
371516
(Number) Title Revision 1.3.66 Operability and Functionality Evaluation
378475
34 10.25.53 Inspection of Lighting Panels and Power Panels
378835
13 OI-0 9 Operations Standards and Expectation
378990
6 9 OI-14 Columbia Generating Station Operational Challenges and Risk Program
379120
1 6 OSP-ELEC-W102 Electrical Distribution Subsystem Breaker Alignment and Power Availability Verification
379244
31 OSP-ELEC-W10 1 Offsite Station Power Alignment Check
379504
31  Miscellaneous Documents  
380257
(Number) Title Date EC 17110 EVAL DO-P-1B Failed to Start when Selected
380307  
06/13/2018   71111.18 - Plant Modifications
 
Work Orders
2123413
2126245
 
Procedures  
(Number)
Title
Revision
1.3.66
Operability and Functionality Evaluation
034
10.25.53
Inspection of Lighting Panels and Power Panels
013
OI-09
Operations Standards and Expectation
069
OI-14
Columbia Generating Station Operational
Challenges and Risk Program
016
OSP-ELEC-W102
Electrical Distribution Subsystem Breaker
Alignment and Power Availability Verification
031
OSP-ELEC-W101
Offsite Station Power Alignment Check
031
Miscellaneous Documents  
(Number)
Title
Date
EC 17110 EVAL
DO-P-1B Failed to Start when Selected
06/13/2018  
 
71111.18 - Plant Modifications
Action Requests
Action Requests
380372 380404   Procedures
380372
(Number) Title Revision ENG-DES-02 Columbia Generating Station Plant Modification Process 0 19 SWP-DES-01 Plant Modification and Configuration Control
380404  
17  71111.19 - Post Maintenance Testing
 
Procedures  
(Number)
Title
Revision
ENG-DES-02
Columbia Generating Station Plant Modification
Process
019
SWP-DES-01
Plant Modification and Configuration Control
017
 
71111.19 - Post Maintenance Testing
Action Requests
Action Requests
378475 378488 378990 379191 379244
378475
378488
378990
379191
379244  
 
Work Orders
Work Orders
2118434 02126245 02126307 0 2126372 02126372 02128700 02326309 29142042 Procedures
2118434
(Number) Title Revision OI-41 Operations Work Control Expectations
2126245
63 SWP-TST-01 Post Maintenance Testing Program
2126307
17  71111.2 0 - Refueling and Other Outage Activities
2126372
Procedures
2126372
(Number) Title Revision 9.3.6 Estimated Critical Position Calculation
2128700
5  9.3.7 Reactor Shutdown and Startup Calculations
2326309
2 OCC-01 Outage Control Center Norms
29142042
6 OI-09 Operator Standards and Expectations
Procedures  
69 1.3.84 Reactivity Management Control
(Number)
4 3.1.1 Master Startup Checklist
Title
58 3.1.2 Reactor Plant Startup
Revision
84 3.2.1 Normal Plant Shutdown
OI-41
88 3.3.1 Reactor Scram
Operations Work Control Expectations
65 SOP-RHR-SDC RHR Shutdown Cooling
063
28   71111.22 - Surveillance Testing
SWP-TST-01
Post Maintenance Testing Program
017
 
71111.20 - Refueling and Other Outage Activities
Procedures  
(Number)
Title
Revision
9.3.6
Estimated Critical Position Calculation
005
9.3.7
Reactor Shutdown and Startup Calculations
2
OCC-01
Outage Control Center Norms
006
OI-09
Operator Standards and Expectations
069
1.3.84
Reactivity Management Control
004
3.1.1
Master Startup Checklist
058
3.1.2
Reactor Plant Startup
084
3.2.1
Normal Plant Shutdown
088
3.3.1
Reactor Scram
065
SOP-RHR-SDC
RHR Shutdown Cooling
28  
 
71111.22 - Surveillance Testing
Work Orders
Work Orders
2114669 02118974 02118950 02122396 02122397    Procedures
2114669
(Number) Title Revision RPS-PS-5A Instrument Master Data Sheet
2118974
013 OSP-INST-H101 Shift and Daily Instrument Checks (Modes 1,2,3)
2118950
89  Miscellaneous Documents  
2122396
(Number) Title Revision CALC E/I-02-94-1334 Setting Range Determination for Instrument Loop
2122397
MS-LIS-24B 001 LDCN 373682, LDCN-17-028 (LCS) License Document Change Notice SR 1.3.7.6.2 Frequency Change per SFCP
 
STI-AR 365016 Surveillance Test Interval Change Form, Turbine Valve Surveillance
Procedures  
(Number)
Title
Revision
RPS-PS-5A
Instrument Master Data Sheet
013
OSP-INST-H101
Shift and Daily Instrument Checks (Modes 1,2,3)
089
Miscellaneous Documents  
(Number)
Title
Revision
CALC E/I-02-94-1334
Setting Range Determination for Instrument Loop
MS-LIS-24B
001
LDCN 373682,
LDCN-17-028 (LCS)
License Document Change Notice SR 1.3.7.6.2
Frequency Change per SFCP
STI-AR 365016
Surveillance Test Interval Change Form, Turbine
Valve Surveillance  


71114.06 - Drill Evaluation
71114.06 - Drill Evaluation
Procedures
Procedures  
(Number) Title Revision 13.10.1 Control Room Operation and Shift Manager Duties
(Number)
35 13.10.2 TSC Manager Duties
Title
35 13.2.1 Emergency Exposure Levels, Protective Action Guides 0 22 13.2.2 Determining Protective Actions
Revision
20 13.4.1 Emergency Notifications
13.10.1
43 13.5.1 Local, Protected Area, or Site Evacuation
Control Room Operation and Shift Manager Duties
29 13.9.1 Environmental Field Monitoring Operations
035
45 13.10.9 Operations Support Center Manager and Staff Duties 0 49 13.11.1 EOF Manager Duties
13.10.2
44 13.13.1 Reentry Operations
TSC Manager Duties
10 13.13.3 Intermediate Phase MUDAC Operations
035
18 13.13.4 After Action Reporting
13.2.1
10 13.14.9 Drill and Exercise Program
Emergency Exposure Levels, Protective Action
18  71124.02-Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Guides
2
13.2.2
Determining Protective Actions
20
13.4.1
Emergency Notifications
043
13.5.1
Local, Protected Area, or Site Evacuation
29
13.9.1
Environmental Field Monitoring Operations
045
13.10.9
Operations Support Center Manager and Staff
Duties
049
13.11.1
EOF Manager Duties
044
13.13.1
Reentry Operations
010
13.13.3
Intermediate Phase MUDAC Operations
018
13.13.4
After Action Reporting
010
13.14.9
Drill and Exercise Program
018
 
71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls
Action Requests
Action Requests
370540 377573 377743 377911 379078 354266 354320 375379 376734 365777   Procedures  
370540
(Number) Title Revision 11.2.13.8 Airborne Radioactivity Surveys
377573
19 11.2.7.1 Area Posting
377743
43 HPI-0.19 Radiation Protection Standards and Expectations
377911
17 HPI-6.4 Administering an Occupational Radiation Exposure History File
379078
25 SWP-RPP-01 Radiation Protection Program
354266
16 GEN-RPP-01 ALARA Program Description
354320
9 GEN-RPP-02 Radiological Planning and Control Process
375379
34 GEN-RPP-13 Senior Site ALARA Committee
376734
13 GEN-RPP-14 Control of Temporary Shielding
365777  
14 PPM 11.2.2.7
 
Procedures  
(Number)
Title
Revision
11.2.13.8
Airborne Radioactivity Surveys
019
11.2.7.1
Area Posting
043
HPI-0.19
Radiation Protection Standards and
Expectations
017
HPI-6.4
Administering an Occupational Radiation
Exposure History File
25
SWP-RPP-01
Radiation Protection Program
016
GEN-RPP-01
ALARA Program Description
009
GEN-RPP-02
Radiological Planning and Control Process
034
GEN-RPP-13
Senior Site ALARA Committee
013
GEN-RPP-14
Control of Temporary Shielding
014
PPM 11.2.2.7
ALARA Procedure Analysis
ALARA Procedure Analysis
12 PPM 11.2.2.8
2
PPM 11.2.2.8
ALARA Engineering Analysis
ALARA Engineering Analysis
7
007
 
Procedures  
Procedures  
(Number) Title Revision PPM 11.2.2.11
(Number)
Exposure Evaluations for Maintaining TEDE ALARA 00 8 PPM 11.2.2.12
Title
Radiological Risk Assessment and Management
Revision
8 PPM 11.2.2.13
PPM 11.2.2.11
Exposure Evaluations for Maintaining TEDE
ALARA
008
PPM 11.2.2.12
Radiological Risk Assessment and
Management
008
PPM 11.2.2.13
Flushing and Shielding Evaluations
Flushing and Shielding Evaluations
2 PPM 11.2.2.14
2
PPM 11.2.2.14
Radiological Planning and Reviews
Radiological Planning and Reviews
4 PPM 11.2.8.2
004
PPM 11.2.8.2
Radiation Work Permit Preparation and Use
Radiation Work Permit Preparation and Use
1  Audits and Self
001
-Assessments
Audits and Self-
(Number) Title Date AR-SA No. 375350
Assessments (Number)
Title
Date
AR-SA No. 375350
Annual Radiation Protection Program Review
Annual Radiation Protection Program Review
03/30/2018 SR-18-01 Continuous Monitoring Report
03/30/2018
03/07/2018 SR-17-04 Continuous Monitoring Report
SR-18-01
11/02/2017 374279 Self-Assessment: 71124.02 ALARA
Continuous Monitoring Report
2/15/2018 Radiation Work Permits  
03/07/2018
(Number) Title Revision RWP 30004209
SR-17-04
Continuous Monitoring Report
11/02/2017
374279
Self-Assessment: 71124.02 ALARA
2/15/2018
Radiation Work Permits  
(Number)
Title
Revision
RWP 30004209
RWP 30004210
RWP 30004210
RWP 30003882
RWP 30003882
RWP 30003098
RWP 30003098
RWP 30003873
RWP 30003873
2018 EDR Tank
2018 EDR Tank-5 Desludge
-5 Desludge
2018 EDR Tank-5 Desludge High Risk
2018 EDR Tank
-5 Desludge High Risk
Main Steam Relief Valves
Main Steam Relief Valves
Wetwell Cleanup and Inspection
Wetwell Cleanup and Inspection
Drywell Shielding
Drywell Shielding
1 00 2 00 1 00 1 00 1  ALARA Planning, In-Progress Reviews, and Post-Job Reviews  
001
(Number) Title Date WO 2117848
2
001
001
001
ALARA Planning,
In-Progress Reviews, and
Post-Job Reviews  
(Number)
Title
Date
WO 2117848
WO 2088288
WO 2088288
WO 2088287
WO 2088287
WO 2077319
WO 2077319
Clean EDR Tank
Clean EDR Tank-5
-5 Suppression Pool Cleanup
Suppression Pool Cleanup
Chemical Decon
Chemical Decon Cleanup
Cleanup Drywell Shielding
Drywell Shielding
2/11/2018   Miscellaneous Documents
2/11/2018  
Senior Site ALARA Committee EDR Tank
 
-5 Desludge
Miscellaneous Documents
Senior Site ALARA Committee EDR Tank-5 Desludge
2017 CGS Dose Report to the NRC
2017 CGS Dose Report to the NRC
05-2018 CGS 5 Year CRE Reduction Plan
05-2018 CGS 5 Year CRE Reduction Plan
R23 CRE Outage Report
R23 CRE Outage Report  


71124.04-Occupational Dose Assessment
71124.04Occupational Dose Assessment
Action Requests
Action Requests
357564 360494 361631 365110 365545 365692 366701 367779 369181 374380 375624 376342 376403 377080 378436   Procedures  
357564
(Number) Title Revision 11.2.13.8 Airborne Radioactivity Surveys
360494
19 11.2.4.5 Whole Body Counts and Daily Checks Using the Renaissance FastScan
361631
16 11.2.6.7 Special Dosimetry
365110
18 11.2.7.1 Area Posting
365545
43 GEN-RPP-06 Dosimetry Program Description
365692
13 HPI 4.30 Processing, Evaluation, and Reporting of DLR Exposure Data
366701
14 HPI-0.19 Radiation Protection Standards and Expectations
367779
17 HPI-5.9 Evaluation of In
369181
-Vivo Bioassay Results Following a Potential Intake
374380
14 HPI-6.4 Administering an Occupational Radiation Exposure History File
375624
25 SWP-RPP-01 Radiation Protection Program 0 16  Audits and Self
376342
-Assessments
376403
(Number) Title Date 374271 Self-Assessment: 71124.04 Occupational Dose Assessment
377080
2/15/2018 374020 Self-Assessment: Site Bioassay Program
378436  
11/15/2017 Miscellaneous Documents  
 
(Number) Title Date Data Verification (REIRS Submission)
Procedures (Number)
Title
Revision
11.2.13.8
Airborne Radioactivity Surveys
019
11.2.4.5
Whole Body Counts and Daily Checks Using
the Renaissance FastScan
016
11.2.6.7
Special Dosimetry
018
11.2.7.1
Area Posting
043
GEN-RPP-06
Dosimetry Program Description
013
HPI 4.30
Processing, Evaluation, and Reporting of DLR
Exposure Data
014
HPI-0.19
Radiation Protection Standards and
Expectations
017
HPI-5.9
Evaluation of In-Vivo Bioassay Results
Following a Potential Intake
014
HPI-6.4
Administering an Occupational Radiation
Exposure History File
25
SWP-RPP-01
Radiation Protection Program
016
Audits and Self-
Assessments (Number)
Title
Date
374271
Self-Assessment: 71124.04 Occupational Dose
Assessment
2/15/2018
374020
Self-Assessment: Site Bioassay Program
11/15/2017
Miscellaneous Documents  
(Number)
Title
Date
Data Verification (REIRS Submission)
03/12/2018
03/12/2018
100518-0 NVLAP Scope and ISO 17025 Certificate for
100518-0
Landauer 01/01/2018
NVLAP Scope and ISO 17025 Certificate for
15-02 Bases for Neutron Correction Factors for OSLN and Survey Instruments
Landauer
04/03/2015
01/01/2018
15-02
Bases for Neutron Correction Factors for
OSLN and Survey Instruments
04/03/2015  


Miscellaneous Documents  
Miscellaneous Documents  
(Number) Title Date DAC-0446 Scaling Factor Determination at Columbia Generating Station  
(Number)
- 2017 02/28/ 2018
Title
Date
DAC-0446
Scaling Factor Determination at Columbia
Generating Station - 2017
2/28/ 2018
VSDS_Pros-M-20171223-2 RW 487 Monthly Survey
VSDS_Pros-M-20171223-2 RW 487 Monthly Survey
2/23/2017
2/23/2017  
 
71151 - Performance Indicator Verification
71151 - Performance Indicator Verification
Action Requests
Action Requests
377435 378504 379269 379591 380459 380745   Procedures
377435
(Number) Title Revision 1.5.11 Maintenance Rule Program
378504
15 SYS-4-22 Maintenance Rule Program
379269
13 SYS-4-31 System and Equipment Performance Monitoring and Trending Program
379591
12  71152 - Problem Identification and Resolution
380459
380745  
 
Procedures  
(Number)
Title
Revision
1.5.11
Maintenance Rule Program
015
SYS-4-22
Maintenance Rule Program
013
SYS-4-31
System and Equipment Performance Monitoring
and Trending Program
2
 
71152 - Problem Identification and Resolution
Action Requests
Action Requests
378489 378892 377416 376891 376894 375755 377654 377144 175386 373903 373313 378956 376921 372667 372847 373141 Work Orders
378489
2108935     Procedures
378892
(Number) Title Revision 1.3.81 Maintaining Plant Component Status Control
377416
2 1.5.14 Risk Assessment and Management for Maintenance/Surveillance Activities
376891
040 6.6.5 Movement and Transfer Operations of HI
376894
-TRAC and HI-STORM in the Reactor Building
375755
017 SOP-DOOR/HATCH OPS
377654
377144
175386
373903
373313
378956
376921
2667
2847
373141
Work Orders
2108935  
 
Procedures  
(Number)
Title
Revision
1.3.81
Maintaining Plant Component Status Control
2
1.5.14
Risk Assessment and Management for
Maintenance/Surveillance Activities
040
6.6.5
Movement and Transfer Operations of HI-TRAC
and HI-STORM in the Reactor Building
017
SOP-DOOR/HATCH OPS
Reactor Building, Turbine Building, Radwaste
Reactor Building, Turbine Building, Radwaste
Building, and Containment Personnel, Equipment Access Doors, and Hatches
Building, and Containment Personnel, Equipment
013 SOP-FLOCCULATOR
Access Doors, and Hatches
-OPS Flocculator System Operation
013
006 SWP-CAP-01 Corrective Action Program
SOP-FLOCCULATOR-OPS
39 SWP-CAP-06 Corrective Action Review
Flocculator System Operation
24 GBP-CAP-04 Corrective Action Review Board 00 0 GBP-CAP-03 Trending Program
006
0
SWP-CAP-01
Corrective Action Program
039
SWP-CAP-06
Corrective Action Review
24
GBP-CAP-04
Corrective Action Review Board
000
GBP-CAP-03
Trending Program
000
 
Miscellaneous Documents  
Miscellaneous Documents  
(Number) Title Revision /Date Ops Excellence Plan Cycle 24
(Number)
Title
Revision  
/Date
Ops Excellence Plan Cycle 24  
 
60855.1-Operation of an Independent Spent Fuel Storage Installation
60855.1-Operation of an Independent Spent Fuel Storage Installation
Action Requests
Action Requests
00377488 00377489 00373321 00369032 00360032     Work Orders
00377488
2100824-01 02088436-01 02119266-01 02119264-01 02119263-01 02119261-01 02115652-01 02101322-01 Procedures
00377489
(Number) Title Revision PPM 6.6.4 HI-STORM System Site Transportation
00373321
015 PPM 6.6.5 Transfer Operations of
00369032
HI-Track/HI-STORM in the Reactor Building
00360032  
017 PPM 6.6.6 MPC Fuel Loading
 
015 PPM 6.6.7 MPC Processing
Work Orders
28 PPM 6.6.12
2100824-01
2088436-01
2119266-01
2119264-01
2119263-01
2119261-01
2115652-01
2101322-01
Procedures  
(Number)
Title
Revision
PPM 6.6.4
HI-STORM System Site Transportation
015
PPM 6.6.5
Transfer Operations of HI-Track/HI-STORM in the
Reactor Building
017
PPM 6.6.6
MPC Fuel Loading
015
PPM 6.6.7
MPC Processing
28
PPM 6.6.12
Vacuum Drying System Operations
Vacuum Drying System Operations
006 PPM 6.6.13
006
PPM 6.6.13
Helium Backfill System Operations
Helium Backfill System Operations
004 PPM 6.6.14
004
PPM 6.6.14
MPC Alternate Cooling Water System Operation
MPC Alternate Cooling Water System Operation
2 PPM 6.6.15
2
PPM 6.6.15
Spent Fuel Cask Loading Verification
Spent Fuel Cask Loading Verification
006 PPM 6.3.23
006
PPM 6.3.23
Handling Irradiated Fuel in the Spent Fuel Pool
Handling Irradiated Fuel in the Spent Fuel Pool
010 SWP-LIC-02 Licensing Basis Impact Determinations
010
014 OSP-SFS-D101 Storage Cask Heat Removal System Daily Checks
SWP-LIC-02
015 PPM 10.4.5 Reactor and Turbine Building Overhead Traveling Crane Inspection, Maintenance and Testing
Licensing Basis Impact Determinations
23 PPM 9.6.1 Spent Fuel Selection for Cask Storage
014
008 PPM 6.3.40
OSP-SFS-D101
Determination of Fuel Assembly Condition for ISFSI 006 Design Basis
Storage Cask Heat Removal System Daily Checks
Documents  
015
(Number) Title Revision 72.212 ISFSI 10 CFR 72.212 Evaluation 72
PPM 10.4.5
-35 0 10 ISFSI FSAR
Reactor and Turbine Building Overhead Traveling
Crane Inspection, Maintenance and Testing
23
PPM 9.6.1
Spent Fuel Selection for Cask Storage
008
PPM 6.3.40
Determination of Fuel Assembly Condition for
ISFSI
006
Design Basis Documents  
(Number)
Title
Revision
2.212
ISFSI 10 CFR 72.212 Evaluation 72-35
010
ISFSI FSAR
HI-STORM 100 ISFSI Final Safety Analysis Report
HI-STORM 100 ISFSI Final Safety Analysis Report
13 CoC 1014 CoC and Technical Specifications for HI
013
-STORM 100 , Amendment 9
CoC 1014
1  Miscellaneous Documents  
CoC and Technical Specifications for HI-STORM
(Number) Title Revision /Date VSDS DIC 1517
100, Amendment 9
001
Miscellaneous Documents  
(Number)
Title
Revision  
/Date
VSDS DIC 1517
Survey of ISFSI Pad and & Building 105 Quarterly
Survey of ISFSI Pad and & Building 105 Quarterly
01/23/2018
01/23/2018
AU-DC-16 ISFSI Program QA Audit Report
AU-DC-16
ISFSI Program QA Audit Report
04/20/2016
04/20/2016
17-VS-04 Source QA Surveillance Report  
17-VS-04
- Holtec International
Source QA Surveillance Report - Holtec International
09/14/2017
09/14/2017
16-VS-05 Source QA Surveillance Report  
16-VS-05
- Holtec International
Source QA Surveillance Report - Holtec International
11/08/2016
11/08/2016  


DIC 1814.5
DIC 1814.5
Cask Loading Plan for Canisters 37  
Cask Loading Plan for Canisters 37 - 40
- 40 March 2018 PLM 003N2471
March
2018
PLM 003N2471
CGS Vacuum Sipping Final Report Fall 2015
CGS Vacuum Sipping Final Report Fall 2015
2/07/2015 Cal NE-02-00-08 Calculation for Fuel History Data
2/07/2015
6 Cal CE-02-00-12 Analysis of the Reactor Building Railroad Bay 441 Ft Elevation Slab
Cal NE-02-00-08
2 Cal CE-02-01-08 HI-TRAC/HI-STORM Dolly Seismic Restraint @ EL 441'
Calculation for Fuel History Data
2 Cal SLENW-Calc-1 Cask Transport Road Design
006
04/06/2001 GO2-17-091 GGS 2016 Annual Radiological Environmental Operating Report 05/09/2017 72. 48 Screenings
Cal CE-02-00-12
16-009 17-001 17-002 17-003 17-004 17-005 17-006 17-007 17-008 17-009 17-010 17-011 17-012 17-013 18-001 18-004 LDCN-14-024 LDCN-18-13       Engineering Changes
Analysis of the Reactor Building Railroad Bay 441 Ft
Elevation Slab
2
Cal CE-02-01-08
HI-TRAC/HI-STORM Dolly Seismic Restraint @ EL 441
2
Cal SLENW-Calc-1
Cask Transport Road Design
04/06/2001
GO2-17-091
GGS 2016 Annual Radiological Environmental Operating
Report
05/09/2017
2. 48 Screenings
16-009
17-001
17-002
17-003
17-004
17-005
17-006
17-007
17-008
17-009
17-010
17-011
17-012
17-013
18-001
18-004
LDCN-14-024
LDCN-18-13  
 
Engineering Changes
EC PDC 15708
EC PDC 15708
EC EVAL 17126
EC EVAL 17126  


Attachment 2
The following items are requested for the
The following items are requested for the
Occupational Radiation Safety Inspection
Occupational Radiation Safety Inspection
Line 716: Line 1,301:
Inspection areas are listed in the attachments below.
Inspection areas are listed in the attachments below.
Please provide the requested information on or before May 11, 2018.
Please provide the requested information on or before May 11, 2018.
Please submit this information using the same lettering system as below. For example, all contacts and phone numbers for Inspection Procedure 71124.0
Please submit this information using the same lettering system as below. For example, all
should be in a file/folder titled  
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
"1- A," applicable organization charts in file/folder "
1-A, applicable organization charts in file/folder 1-B, etc.
1- B," etc. If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at
inspection dates, so the inspectors will have access to the information while writing the report.
least 30 days later than the onsite inspection dates, so the inspectors will have access to the
In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting. The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.
information while writing the report.
If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which file the information can be found.
In addition to the corrective action document lists provided for each inspection procedure listed
If you have any questions or comments, please contact Louis Carson at 817. 200.1221 or louis.carson@nrc.gov
below, please provide updated lists of corrective action documents at the entrance meeting.
and John O'Donnell at 817.200.1441 or John.O'Donnell@nrc.gov
The dates for these lists should range from the end dates of the original lists to the day of the
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
If you have any questions or comments, please contact Louis Carson at 817. 200.1221 or
louis.carson@nrc.gov and John ODonnell at 817.200.1441 or John.ODonnell@nrc.gov  
 
PAPERWORK REDUCTION ACT STATEMENT
PAPERWORK REDUCTION ACT STATEMENT
This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.
This letter does not contain new or amended information collection requirements subject
: [[contact::S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget]], control number 3150
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
-0011.
collection requirements were approved by the Office of Management and Budget,
2. Occupational ALARA Planning and Controls (71124.02)
control number 3150-0011.  
 
2.
Occupational ALARA Planning and Controls (71124.02)
Date of Last Inspection:
Date of Last Inspection:
May 26, 2017
May 26, 2017
A. List of contacts and telephone numbers for ALARA program personnel
A.
B. Applicable organization charts
List of contacts and telephone numbers for ALARA program personnel
: [[contact::C. Copies of audits]], self
B.
-assessments, and LERs, written since date of last inspection
Applicable organization charts
, focusing on ALARA
C.
D. Procedure index for ALARA Program
Copies of audits, self-assessments, and LERs, written since date of last inspection,
E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures may be requested by number
focusing on ALARA
after the inspector reviews the procedure indexes.
D.
Procedure index for ALARA Program
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures may be requested by number after the inspector reviews
the procedure indexes.
1. ALARA Program
1. ALARA Program
2. ALARA Committee
2. ALARA Committee
3. Radiation Work Permit Preparation
3. Radiation Work Permit Preparation
F. A summary list of corrective action documents (including corporate and sub
F.
-tiered systems) written since date of last inspection, related to the ALARA program. In addition to ALARA, the summary should also address Radiation Work Permit violations, Electronic Dosimeter Alarms, and RWP Dose Estimates
A summary list of corrective action documents (including corporate and sub-tiered
NOTE: The lists should indicate the significance level
systems) written since date of last inspection, related to the ALARA program. In addition
of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches.
to ALARA, the summary should also address Radiation Work Permit violations,
: [[contact::G. List of work activities greater than 1 rem]], since date of last inspection, Include original dose estimate and actual dose.
Electronic Dosimeter Alarms, and RWP Dose Estimates
H. Site dose totals and 3
NOTE: The lists should indicate the significance level of each issue and the search
-year rolling averages for the past 3 years (based on dose of record) I. Outline of source term reduction strategy
criteria used. Please provide in document formats which are searchable so that
: [[contact::J. If available]], provide a copy of the ALARA outage report for the most recently completed outages for each unit
the inspector can perform word searches.
K. Please provide your most recent Annual ALARA Report.
G.
List of work activities greater than 1 rem, since date of last inspection,
Include original dose estimate and actual dose.
H.
Site dose totals and 3-year rolling averages for the past 3 years (based on dose of
record)
I.
Outline of source term reduction strategy
J.
If available, provide a copy of the ALARA outage report for the most recently completed
outages for each unit
K.
Please provide your most recent Annual ALARA Report.  


4. Occupational Dose Assessment (Inspection Procedure 71124.04)
4. Occupational Dose Assessment (Inspection Procedure 71124.04)
Date of Last Inspection:
Date of Last Inspection:
September 1, 2016
September 1, 2016
A. List of contacts and telephone numbers for the following areas:
A.
List of contacts and telephone numbers for the following areas:
1. Dose Assessment personnel
1. Dose Assessment personnel
B. Applicable organization charts
B.
: [[contact::C. Audits]], self
Applicable organization charts
-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to:
C.
Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs
written since date of last inspection, related to:
1. Occupational Dose Assessment
1. Occupational Dose Assessment
D. Procedure indexes for the following areas:
D.
Procedure indexes for the following areas:
1. Occupational Dose Assessment
1. Occupational Dose Assessment
E. Please provide specific procedures related to the following areas noted below. Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.
E.
Please provide specific procedures related to the following areas noted below.
Additional Specific Procedures will be requested by number after the inspector reviews
the procedure indexes.
1. Radiation Protection Program
1. Radiation Protection Program
2. Radiation Protection Conduct of Operations
2. Radiation Protection Conduct of Operations
Line 773: Line 1,392:
7. Declared Pregnant Worker
7. Declared Pregnant Worker
8. Bioassay Program
8. Bioassay Program
F. List of corrective action documents (including corporate and sub
F.
-tiered systems) written since date of last inspection, associated with:
List of corrective action documents (including corporate and sub-tiered systems) written
since date of last inspection, associated with:
1. National Voluntary Laboratory Accreditation Program (NVLAP)
1. National Voluntary Laboratory Accreditation Program (NVLAP)
2. Dosimetry (TLD/OSL, etc.) problems
2. Dosimetry (TLD/OSL, etc.) problems
3. Electronic alarming dosimeters
3. Electronic alarming dosimeters
4. Bioassays or internally deposited
4. Bioassays or internally deposited radionuclides or internal dose
radionuclides or internal dose
5. Neutron dose
5. Neutron dose
NOTE: The lists should indicate the significance level
NOTE: The lists should indicate the significance level of each issue and the search
of each issue and the search criteria used. Please provide in document formats which are "searchable" so that the inspector can perform word searches.
criteria used. Please provide in document formats which are searchable so that
: [[contact::G. List of positive whole body counts since date of last inspection]], names redacted if desired H. Part 61 analyses/scaling factors
the inspector can perform word searches.
: [[contact::I. The most recent National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report or]], if dosimetry is provided by a vendor, the vendor's most recent results
G.
ML18206A16
List of positive whole body counts since date of last inspection, names redacted if
desired
H.
Part 61 analyses/scaling factors
I.
The most recent National Voluntary Laboratory Accreditation Program (NVLAP)
accreditation report or, if dosimetry is provided by a vendor, the vendors most recent
results  
 
ML18206A167
SUNSI Review
SUNSI Review
By: MSH/RDR Non-Sensitive Sensitive Publicly Available
By: MSH/RDR
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
Non-Publicly Available
Keyword: NRC-002 OFFICE SRI:DRP/A RI:DRP/A DRS/EB1 DRS/EB2 DRS/PSB2 DRS/OB DNMS:FCDB NAME GKolcum LBrandt TFarnholtz
Keyword:
JD rake HGepford VGaddy JKatanic SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ /RA-RSB for/ DATE 07/24/18 07/23/2018
NRC-002
OFFICE
SRI:DRP/A
RI:DRP/A
DRS/EB1
DRS/EB2
DRS/PSB2
DRS/OB
DNMS:FCDB
NAME
GKolcum
LBrandt
TFarnholtz
JDrake
HGepford
VGaddy
JKatanic
SIGNATURE  
/RA/  
/RA/  
/RA/  
/RA/  
/RA/  
/RA/  
/RA-RSB for/
DATE
07/24/18
07/23/2018
07/19/2018
07/19/2018
07/19/2018
07/19/2018 07/19/18 07/22/18 07/24/18 OFFICE DRS/IPAT SPE:DRP/A BC:DRP/A     NAME GGeorge RAlexander
07/19/18
MHaire     SIGNATURE /RA/ /RA/ /RA/     DATE 07/20/2018
07/22/18
07/20/18 07/24/18
07/24/18
OFFICE
DRS/IPAT
SPE:DRP/A
BC:DRP/A  
 
NAME
GGeorge
RAlexander
MHaire  
 
SIGNATURE  
/RA/  
/RA/  
/RA/  
 
DATE
07/20/2018
07/20/18
07/24/18
}}
}}

Latest revision as of 17:03, 5 January 2025

NRC Integrated Inspection Report 05000397/2018002 and Independent Spent Fuel Storage Installation Inspection Report 07200035/2018001
ML18206A167
Person / Time
Site: Columbia  Energy Northwest icon.png
Issue date: 07/24/2018
From: Mark Haire
NRC/RGN-IV/DRP/RPB-A
To: Sawatzke B
Energy Northwest
Haire M
References
IR 2018001, IR 2018002
Download: ML18206A167 (30)
v • d • e


Text

July 24, 2018

SUBJECT:

COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018002 AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION REPORT 07200035/2018001

Dear Mr. Sawatzke:

On June 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Columbia Generating Station. On July 12, 2018, the NRC inspectors discussed the results of this inspection with Mr. G. Hettel, 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 the 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 S. Haire, Chief Project Branch A Division of Reactor Projects

Docket Nos. 50-397;72-035 License No. NPF-21

Enclosure:

Inspection Report 05000397/2018002 and 07200035/2018001 w/Attachments 1. Documents Reviewed 2. O

Inspection Report

Docket Numbers:

05000397; 07200035

License Numbers:

NPF-21

Report Numbers:

05000397/2018002; 07200035/2018001

Enterprise Identifier: I-2018-002-0020; 1-2018-001-0091

Licensee:

Energy Northwest

Facility:

Columbia Generating Station and Independent Spent Fuel Storage

Installation

Location:

Richland, Washington

Inspection Dates:

April 1, 2018 to June 30, 2018

Inspectors:

G. Kolcum, Senior Resident Inspector

L. Brandt, Resident Inspector

L. Brookhart, Senior Inspector

L. Carson II, Senior Health Physicist

J. ODonnell, CHP, Health Physicist

Approved By:

M. Haire, Branch Chief

Project Branch A

Division of Reactor Projects

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 Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2018002-01 Closed H.12 - Avoid Complacency 71111.15 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 written procedures appropriate to the circumstances. Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW-V-14B2, as part of work activities under Work Request (WR) 29127677, and rendered diesel generator 2 inoperable and unavailable.

PLANT STATUS

The plant began the inspection period at 100 percent rated thermal power. On April 19, 2018, the reactor unit was down powered to 98 percent due to feedwater heater 2C level control failure. On April 20, 2018, the unit was down powered further to 85 percent for troubleshooting.

The unit returned to rated thermal power on April 21, 2018.

On April 27, 2018, the reactor unit was down powered to 85 percent for economic dispatch from Bonneville Power Administration. The unit returned to rated thermal power on April 30, 2018.

On May 18, 2018, the reactor unit automatically scrammed due to a load reject from a grid disturbance. The unit was restarted and synched to the grid on May 24, 2018. Reactor power was raised to 65 percent on May 25, 2018, and remained at 65 percent for economic dispatch from Bonneville Power Administration. The unit returned to rated thermal power on June 11, 2018.

On June 12, 2018, the unit was down powered to 98 percent due to trip of the 2C feedwater heater. On June 14, 2018, the unit was down powered to 85 percent to repair the 2C feedwater level controller. On June 15, 2018, the unit was down powered to 78 percent due to subsequent trips of the 3C and 4C feedwater heaters. After maintenance, the reactor returned to rated thermal power on June 15,

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html.

Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

REACTOR SAFETY

71111.01Adverse Weather Protection Summer Readiness

Main article: IP 71111.01

The inspectors evaluated summer readiness of offsite and alternate alternating current power systems.

71111.04Equipment Alignment Partial Walkdown

Main article: IP 71111.04

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

(1) diesel generator 1 jacket water system on April 9, 2018
(2) diesel generator 2 jacket water system on April 9, 2018
(3) diesel generator 3 jacket water system on April 9, 2018
(4) low pressure core spray system on June 1, 2018

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

Main article: IP 71111.05

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

(1) Fire Areas RC-14/1, RC-8/2, RC-5/1, and RC-6/2; Divisions 1 and 2 switchgear and battery rooms; on April 6, 2018
(2) Fire Areas RC-4/1, RC-7/2, RC-9/2, and RC-19/2; Divisions 1 and 2 electrical equipment and reactor protection system rooms, remote shutdown room, and vital island corridor; on April 6, 2018
(3) Fire Area TG1/2, reactor feed pump rooms, on April 18, 2018
(4) Fire Area RC-2/1, cable spreading room, on May 10, 2018

71111.06Flood Protection Measures Internal Flooding

Main article: IP 71111.06

The inspectors evaluated internal flooding mitigation protections in the reactor building 471 ft. level on June 22, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

Main article: IP 71111.11

The inspectors observed and evaluated a licensed operator requalification evaluated scenario on April 16, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated:

(1) down power to 85 percent due to failure of feedwater heater 2C, on April 20, 2018
(2) startup to power increase, on May 24, 2018

71111.12Maintenance 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) HT-TE-SW71/2, high pressure core spray heat tracing replacement, on April 23, 2018
(2) E-RLY-86TM, main generator lockout relay, on May 22, 2018
(3) RPS-RLY-K10F for EOC-RPT, maintenance to disable end of cycle recirculation pump trip relay, on May 30, 2018

71111.13Maintenance 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 for heavy lifts at circulating water pump house on April 26, 2018
(2) yellow risk for standby gas treatment train A maintenance, week of May 14, 2018

71111.15Operability Determinations and Functionality Assessments

Main article: IP 71111.15

The inspectors evaluated the following operability determinations and functionality assessments:

(1) diesel generator 1 fuel oil pump 1B on April 1, 2018
(2) diesel generator 2 unplanned inoperability and unavailability for drain of jacket water on April 9, 2018
(3) standby service water 'B' pump house door gearbox on April 17, 2018
(4) high pressure core spray power panel 4A voltage near minimum 120VAC on April 17, 2018
(5) residual heat removal pump 1B relief valve on May 4, 2018
(6) main steam relief valve 1B dual indication on May 18, 2018
(7) standby service water A spray ring header on May 24, 2018
(8) condensate pump 2C elevated water in oil, on May 24, 2018

71111.18Plant Modifications

Main article: IP 71111.18

The inspectors evaluated the following temporary or permanent modifications:

(1) EC 17224, main transformer 1, 2, 3 alarm and trip function, on May 22, 2018
(2) EC 17227, main transformer horizontal links bolting, on May 22, 2018

71111.19Post Maintenance Testing

Main article: IP 71111.19

The inspectors evaluated the following post maintenance tests:

(1) diesel generator 1 fuel oil pump 1B, on April 1, 2018
(2) residual heat removal loop B operability test on April 1, 2018
(3) reactor building ventilation system operation on April 3, 2018
(4) high pressure core spray reactor coolant system interface valve leakage pressure monitor on April 5, 2018
(5) wetwell exhaust isolation valve 3A maintenance for post-accident monitoring position indication on April 13, 2018
(6) power panel 4A transformer replacement on May 4, 2018
(7) main transformer 1, 2, 3 relay testing on May 22, 2018
(8) main transformer 1 Buchholz relay testing on May 22, 2018

71111.20Refueling and Other Outage Activities

Main article: IP 71111.20

The inspectors evaluated forced outage activities following the load reject grid disturbance from May 18, 2018 to May 25, 2018.

===71111.22Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine===

Main article: IP 71111.22
(1) ISP-SEIS-M201, Seismic System Channel Check, Revision 6, on April 23, 2018
(2) OSP-ELEC-M703, HPCS Diesel Generator Monthly Operability Test, Revision 66, on April 25, 2018
(3) ISP-RPS-S901, RPS (Channel A1) and EOC Recirc Pump Trip - TGV Fast Closure RPS-PS-5A - CFT/CC, Revision 0, on May 7, 2018; and ISP RPS-S902, RPS (Channel A2) and EOC Recirc Pump Trip - TGV Fast Closure RPS-PS-5C - CFT/CC, Revision 0, on May 9, 2018

In-service (1 Sample)

(1) OSP-HPCS/IST-Q701, HPCS System Operability Test, Revision 53, on April 23, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) daily reactor coolant system leak checks, shift and daily instrument checks (Modes 1, 2, 3) on June 25, 2018

===71114.06Drill Evaluation

Drill/Training Evolution===

Main article: IP 71114.06

The inspectors evaluated the emergency preparedness training drill on May 15,

RADIATION SAFETY

71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls Radiological Work Planning

Main article: IP 71124.02

The inspectors evaluated the licensees radiological work planning by reviewing the following activities:

(1) RWP 30004209, EDR Tank-5 Desludge
(2) RWP 30004210, EDR Tank-5 Desludge High Risk
(3) RWP 30003882, Main Steam Relief Valves
(4) RWP 30003098, Wetwell Cleanup and Inspection
(5) RWP 30003873, Drywell Shielding

Verification of Dose Estimates and Exposure Tracking Systems (1 Sample)

The inspectors evaluated dose estimates and exposure tracking.

71124.04Occupational Dose Assessment Source Term Characterization

Main article: IP 71124.04

The inspectors evaluated the licensees source term characterization.

External Dosimetry (1 Sample)

The inspectors evaluated the licensees external dosimetry program.

Internal Dosimetry (1 Sample)

The inspectors evaluated the licensees internal dosimetry program.

Special Dosimetric Situations (1 Sample)

The inspectors evaluated the licensees performance for special dosimetry situations.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

Main article: IP 71151

The inspectors verified licensee performance indicators submittals listed below:

(1) MS06: Emergency AC Power Systems (07/01/2017-06/30/2018)
(2) MS07: High Pressure Injection Systems (07/01/2017-06/30/2018)
(3) MS08: Heat Removal Systems (07/01/2017-06/30/2018)
(4) MS09: Residual Heat Removal Systems (07/01/2017-06/30/2018)
(5) MS10: Cooling Water Support Systems (07/01/2017-06/30/2018)

71152Problem Identification and Resolution Semiannual Trend Review

Main article: IP 71152

The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue. The inspectors reviewed a negative trend in human performance and documented one observation.

Annual Follow-up of Selected Issues (1 Sample)

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

(1) Independent Spent Fuel Storage Installation cask stuck in reactor building, on April 7, 2018

71153Follow-up of Events and Notices of Enforcement Discretion Events

Main article: IP 71153

The inspectors evaluated the plant scram from a load reject due to a grid disturbance and the licensees response on May 18,

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

60855.1 - Operation of an Independent Spent Fuel Storage Installation at Operating Plants

The inspectors evaluated the licensees operation of the Independent Spent Fuel Storage Installation (ISFSI) from April 2 through April 5, 2018, on-site at Columbia Generating Station (CGS).

The CGS ISFSI was licensed as a general Part 72 license and utilized the Holtec HI-STORM 100 System, approved under Certificate of Compliance 1014, License Amendment 9, Revision 1, and Final Safety Analysis Report (FSAR), Revision 13. The CGS had been loading HI-STORM 100S Version 243 overpacks containing the Multi-Purpose Canister, MPC-68, and more recently the MPC-68M. CGSs ISFSI contained a total of 39 HI-STORM overpacks at the time of the routine inspection. CGS was in the middle of its 2018 loading campaign. Inspectors were onsite to observe loading activities associated with cask Number 40. The CGS planned to complete an additional 5 canisters by the end of the campaign, increasing the total number of casks to 45 at the ISFSI.

The ISFSI activities specifically reviewed during the on-site inspection and the subsequent in-office review included:

(1) Evaluated and observed cask transportation operations.
(2) Reviewed the licensee's loading, processing, and heavy load procedures associated with their current dry fuel storage campaign.
(3) Reviewed the licensees corrective action program implementation for ISFSI operations since the last routine ISFSI inspection, which was completed in July 2016.
(4) Reviewed quality assurance (QA) program implementation, including recent QA audits, surveillances, receipt inspection, and quality control activities.
(5) Reviewed documentation related to Technical Specification (TS) required operational surveillance activities and FSAR required annual maintenance activities.
(6) Reviewed the licensees radiological monitoring data for the calendar years 2016 and 2017.
(7) Reviewed spent fuel documentation for the canisters loaded since the last routine ISFSI inspection (Canisters 37-40) to confirm the fuel met all TS requirements for storage at the ISFSI.
(8) Reviewed annual maintenance activities for heavy lifting components which included special lifting devices, the vertical cask transporter, and the sites single-failure proof cask handling crane.
(9) Reviewed all 72.48 safety evaluations/screenings for changes made to the licensees ISFSI operations in accordance with Inspection Procedure 60857 since the last routine ISFSI inspection.
(10) Reviewed all changes made to the licensees 72.212 Report from Revision 9 to Revision 10 under the licensees 72.48 program in accordance with Inspection Procedure 60857.

The inspectors did not identify any issues of concerns requiring documentation.

INSPECTION RESULTS

Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems

Green NCV 05000397/2018002-01 Closed H.12 - Avoid Complacency 71111.15 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 written procedures appropriate to the circumstances. Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW-V-14B2, as part of work activities under Work Request (WR) 29127677, and rendered diesel generator 2 inoperable and unavailable.

Description:

On April 9, 2018, while operating demineralized water valve DW-V-14B2, maintenance personnel inadvertently bumped and partially opened diesel cooling water valve DCW-V-8B2. The maintenance personnel completed their work activities, cleaned up the work area, and returned to the shop, unaware that their actions resulted in the partial opening of DCW-V-8B2. Meanwhile, the accidental opening of this diesel cooling water valve caused the diesel generator 2 diesel cooling water expansion tank to drain into a nearby floor drain.

Approximately 40 minutes later, the main control room received a diesel generator 2 local panel trouble alarm. Operations personnel responded to the alarm, found the diesel cooling water valve out of position (partially open), and closed the valve. During this event, the tank level reached -4.5 inches, which is outside the normal standby lineup band of +2 to +6 inches.

This rendered diesel generator 2 inoperable and caused an unplanned entry into Technical Specification 3.8.1 for one required diesel generator inoperable. The licensee restored the required water level within 40 minutes of declaring the diesel inoperable. The licensee then verified the diesel was in the proper standby lineup and restored the diesel to operable status approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later. Subsequently, the licensee initiated an investigation of the event that stated the diesel generator was rendered unavailable because it would not have been able to complete its 24-hour mission time with the open diesel cooling water valve. The diesel generator would have started, loaded, and overheated in approximately 10 minutes without a credited cooling water makeup source. Total unavailability time accrued was 86 minutes.

Procedure 1.3.81, Maintaining Plant Component Status Control, Revision 12, ensures plant component status control is maintained. Step 5.5.2 states that personnel performing work in the plant that are given permission to manipulate the plant are required to accept responsibility for, and are accountable for, maintaining plant component status control. Step 6.6.2.d states, in part, that electrical, mechanical, and instrumentation and control maintenance personnel manipulate components only as specified in approved procedures and work packages that have been authorized by the shift manager or designee.

The inspectors noted that step 6.1 of Procedure MI-1.8, Conduct of Maintenance, Revision 70, directs all maintenance personnel to use and adhere to the station error prevention tools as described in Procedure STANDARD-01. Procedure STANDARD-01, Worker Error Prevention Tools, Revision 10, step 3.3 states, in part, that station personnel are responsible for performing work activities using the error prevention tools in accordance with this standard. Section 4.0 details the fundamental human performance tools workers apply during work activities to help them maintain positive control, regardless of their perception of the risk. For example, Section 4.2 describes the Take 2 error prevention tool.

Step 4.2.1 states, in part, that Take 2 is a jobsite review done when first arriving at the jobsite.

The worker develops an accurate understanding of the work environment by taking time to become acquainted with the immediate work area. Step 4.2.4.a instructs the worker to review the Take 2 lanyard or job aid. The Take 2 job aid lists several questions to engage the worker. Question 7 asks, Is there a component misposition or bump hazard in the work area (2 ft zone)? If yes, engage Operations. The licensees event investigation indicated that the maintenance personnel conducted a Take 2 upon arriving at the jobsite but did not refer to their Take 2 job aid.

Notwithstanding the plant procedure for preventing inadvertent operation of equipment, the inspectors noted that WR 29127677 did not contain the necessary controls to ensure that safety-related equipment was not adversely affected during maintenance.

Corrective Actions: The licensees corrective actions included immediately closing the diesel cooling water valve, replenishing the diesel cooling water level, restoring diesel generator 2 to operable status, and completing an event investigation.

Corrective Action Reference(s): Action Request 378835

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 Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, on April 9, 2018, the licensee inadvertently bumped and partially opened a diesel cooling water valve, DCW-V-8B2, while operating a nearby demineralized water valve, DW-V-14B2, as part of work activities under WR 29127677, and rendered diesel generator 2 inoperable and unavailable.

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 2, Mitigating Systems Screening Questions, dated June 19, 2012. The inspectors determined the finding was of very low safety significance (Green) because all of the screening questions were answered in the negative.

Cross-cutting Aspect: This finding has a cross-cutting aspect in the area of human performance, avoid complacency, in that the licensee failed to implement appropriate error reduction tools and recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Specifically, licensee staff failed to implement the guidance found in the Take 2 card which demonstrated complacency in the perceived lack of intrusiveness of the work [H.12].

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 Procedure 1.3.81, Maintaining Plant Component Status Control, Revision 12, to meet the Regulatory Guide 1.33 requirement. Step 6.6.2.d states, in part, that electrical, mechanical, and instrumentation and control maintenance personnel manipulate components only as specified in approved procedures and work packages that have been authorized by the shift manager or designee.

Contrary to the above, on April 9, 2018, the licensee did not manipulate components only as specified in approved procedures and work packages that had been authorized by the shift manager or designee. Specifically, the licensee inadvertently bumped and partially opened diesel cooling water valve DCW-V-8B2 as part of work activities under WR 29127677, and rendered diesel generator 2 inoperable and unavailable.

Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.

Observation

71152 - Semiannual Trend

Review The inspectors performed an in-depth review of the licensees evaluation and corrective actions related to human performance issues. Since the end of refueling outage RF23 in June 2017, the licensee has initiated multiple condition reports documenting human performance errors. The licensee had also identified an adverse trend as documented in Action Requests 377654, 377416, and 378892.

This review focused on condition reports that documented plant component status control errors and failures to follow procedures. While many of the human performance issues were of minor significance, several resulted in NRC documented findings:

  • NCV 05000397/2018002-01, Failure to Maintain Configuration Control in the Diesel Generator 2 Diesel Cooling Water System. (Section 71111.15 of this report)

The inspectors noted that the licensee appropriately considered extent of condition and cause when scheduling corrective action assignments. These actions included a site-wide initiative to identify and eliminate any potential plant component status control hazards and a supervisor observation blitz that focused on human performance behaviors such as pre-job briefs, use of the Take 2 card, procedure use and adherence, and supervisory oversight. The inspectors assessed the licensees problem identification threshold, cause analyses, and compensatory actions. The inspectors verified that the licensee appropriately prioritized the planned corrective actions and that these actions were adequate to correct the condition.

EXIT MEETINGS AND DEBRIEFS

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

The inspectors confirmed that proprietary information was controlled to protect from public disclosure.

On April 5, 2018, the inspectors presented the results from the routine ISFSI inspection to Mr. G. Hettel, Vice President of Operations (title at the time of the ISFSI inspection, but subsequently assumed the title of Senior Vice President and Chief Nuclear Officer), and other members of the licensee staff.

On May 24, 2018, the inspectors presented the baseline radiation protection inspection results to Mr. G. Hettel, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.

On July 12, 2018, the inspectors presented the quarterly resident inspector inspection results to Mr. G. Hettel, Senior Vice President and Chief Nuclear Officer, and other members of the licensee staff.

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Action Requests

379022

381176

Procedures

(Number)

Title

Revision

13.1.1

Classifying the Emergency

049

13.1.1A

Classifying the Emergency - Technical Bases

033

ABN-ELEC-GRID

Degraded Off Site Power Grid

010

SOP-HOTWEATHER-OPS

Hot Weather Operations

006

SOP-WARMWEATHER-

OPS

Warm Weather Operations

015

71111.04 - Equipment Alignment

Procedures

(Number)

Title

Revision

5.5.1

Overriding ECCS Valve Logic to Allow Throttling

RPV Injection

006

OSP-LPCS-M102

LPCS Valve Lineup

2

SOP-LPCS-LU

LPCS Valve and Breaker Lineup

003

SOP-LPCS-STBY

Placing LPCS in Standby Status

2

SOP-DG-DCW

Emergency Diesel Generator Jacket Water Cooling

014

SOP-DG1-LU

Emergency Diesel Generator (Div 1) Valve and

Power Supply Lineup

006

SOP-DG2-LU

Emergency Diesel Generator (Div 2) Valve and

Power Supply Lineup

006

SOP-DG3-LU

High Pressure Core Spray Diesel Generator Valve

and Power Supply Lineup

007

Miscellaneous Documents

(Number)

Title

Revision

Final Safety Analysis Report

064

71111.05AQ - Fire Protection Annual/Quarterly

Action Requests

378829

379167

379972

Procedures

(Number)

Title

Revision

1.3.10C

Control of Transient Combustibles

20

PFP-RW-467

Radwaste 467

005

PFP-RW-484-487

Radwaste 484-487

005

1.3.10A

Control of Ignition Sources

017

FPP-1.6

Combustible Loading Calculation Control

2

FPP-2.2.12

Annual Fire Door Operability Test

005

FPP-2.2.7

Fire Protection Water System Inspections

006

PFP-TG-441-456

Turbine Generator 441-456

008

Miscellaneous Documents

(Number)

Title

Revision

FSAR Fire Hazards Analysis

BIP 17-0613

Barrier Impairment Permit

BIP 17-0614

Barrier Impairment Permit

BIP 17-0615

Barrier Impairment Permit

BIP 17-0616

Barrier Impairment Permit

BIP 17-0643

Barrier Impairment Permit

BIP 17-0662

Barrier Impairment Permit

BIP 18-0096

Barrier Impairment Permit

BIP 18-0097

Barrier Impairment Permit

BIP 18-0111

Barrier Impairment Permit

BIP 18-0017

Barrier Impairment Permit

BIP 18-0018

Barrier Impairment Permit

BIP 18-0019

Barrier Impairment Permit

BIP 18-0029

Barrier Impairment Permit

BIP 18-0031

Barrier Impairment Permit

BIP 18-0037

Barrier Impairment Permit

BIP 18-0041

Barrier Impairment Permit

BIP 18-0050

Barrier Impairment Permit

CALC FP-02-85-03

Combustible Loading Calculation

010

71111.06 - Flood Protection Measures

Action Requests

378764

Procedures

(Number)

Title

Revision

ABN-FLOODING

Flooding

20

ME-02-02-02

Calculation for Reactor Building Flooding Analysis

004

PFP-RB-572

Reactor 572

004

71111.11 - Licensed Operator Requalification Program and Licensed Operator Performance

Action Requests

379240

Procedures

(Number)

Title

Revision

13.1.1

Classifying the Emergency

048

OI-09

Operations Standards and Expectations

064

1.3.1

Operating Policy, Programs, and Practices

26

5.1.1

RPV Control

21

5.2.1

Primary Containment Control

27

5.3.1

Secondary Containment Control

20

Miscellaneous Documents

(Number)

Title

Revision

LR002398

Cycle 18-2 Evaluated Scenario

001

Crew F Evaluated Scenario Cycle 18-2

4.0 Critique Summary

000

71111.12 - Maintenance Effectiveness

Action Requests

380427

Work Orders

2094222

2128788

29142758

Procedures

(Number)

Title

Revision

1.5.11

Maintenance Rule Program

015

OI-53

Offsite Power

014

SOP-RPS-OPS

Reactor Protection System Operation

015

SOP-RPS-START

Reactor Protection System Startup

007

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Work Orders

2085935

Procedures

(Number)

Title

Revision

1.3.83

Protected Equipment Program

26

1.5.14

Risk Assessment and Management for

Maintenance/Surveillance Activities

040

1.5.11

Maintenance Rule Program

015

WCI-4

Online Work Control Process

048

1.3.76

Integrated Risk Management

050

Miscellaneous Documents

(Number)

Title

Date

High Risk Work Plan for Underwater Diving in

Support of CW-P-1C

01/16/2018

71111.15 - Operability Determinations and Functionality Assessments

Action Requests

306206

371516

378475

378835

378990

379120

379244

379504

380257

380307

Work Orders

2123413

2126245

Procedures

(Number)

Title

Revision

1.3.66

Operability and Functionality Evaluation

034

10.25.53

Inspection of Lighting Panels and Power Panels

013

OI-09

Operations Standards and Expectation

069

OI-14

Columbia Generating Station Operational

Challenges and Risk Program

016

OSP-ELEC-W102

Electrical Distribution Subsystem Breaker

Alignment and Power Availability Verification

031

OSP-ELEC-W101

Offsite Station Power Alignment Check

031

Miscellaneous Documents

(Number)

Title

Date

EC 17110 EVAL

DO-P-1B Failed to Start when Selected

06/13/2018

71111.18 - Plant Modifications

Action Requests

380372

380404

Procedures

(Number)

Title

Revision

ENG-DES-02

Columbia Generating Station Plant Modification

Process

019

SWP-DES-01

Plant Modification and Configuration Control

017

71111.19 - Post Maintenance Testing

Action Requests

378475

378488

378990

379191

379244

Work Orders

2118434

2126245

2126307

2126372

2126372

2128700

2326309

29142042

Procedures

(Number)

Title

Revision

OI-41

Operations Work Control Expectations

063

SWP-TST-01

Post Maintenance Testing Program

017

71111.20 - Refueling and Other Outage Activities

Procedures

(Number)

Title

Revision

9.3.6

Estimated Critical Position Calculation

005

9.3.7

Reactor Shutdown and Startup Calculations

2

OCC-01

Outage Control Center Norms

006

OI-09

Operator Standards and Expectations

069

1.3.84

Reactivity Management Control

004

3.1.1

Master Startup Checklist

058

3.1.2

Reactor Plant Startup

084

3.2.1

Normal Plant Shutdown

088

3.3.1

Reactor Scram

065

SOP-RHR-SDC

RHR Shutdown Cooling

28

71111.22 - Surveillance Testing

Work Orders

2114669

2118974

2118950

2122396

2122397

Procedures

(Number)

Title

Revision

RPS-PS-5A

Instrument Master Data Sheet

013

OSP-INST-H101

Shift and Daily Instrument Checks (Modes 1,2,3)

089

Miscellaneous Documents

(Number)

Title

Revision

CALC E/I-02-94-1334

Setting Range Determination for Instrument Loop

MS-LIS-24B

001

LDCN 373682,

LDCN-17-028 (LCS)

License Document Change Notice SR 1.3.7.6.2

Frequency Change per SFCP

STI-AR 365016

Surveillance Test Interval Change Form, Turbine

Valve Surveillance

71114.06 - Drill Evaluation

Procedures

(Number)

Title

Revision

13.10.1

Control Room Operation and Shift Manager Duties

035

13.10.2

TSC Manager Duties

035

13.2.1

Emergency Exposure Levels, Protective Action

Guides

2

13.2.2

Determining Protective Actions

20

13.4.1

Emergency Notifications

043

13.5.1

Local, Protected Area, or Site Evacuation

29

13.9.1

Environmental Field Monitoring Operations

045

13.10.9

Operations Support Center Manager and Staff

Duties

049

13.11.1

EOF Manager Duties

044

13.13.1

Reentry Operations

010

13.13.3

Intermediate Phase MUDAC Operations

018

13.13.4

After Action Reporting

010

13.14.9

Drill and Exercise Program

018

71124.02Occupational As Low As Reasonably Achievable (ALARA) Planning and Controls

Action Requests

370540

377573

377743

377911

379078

354266

354320

375379

376734

365777

Procedures

(Number)

Title

Revision

11.2.13.8

Airborne Radioactivity Surveys

019

11.2.7.1

Area Posting

043

HPI-0.19

Radiation Protection Standards and

Expectations

017

HPI-6.4

Administering an Occupational Radiation

Exposure History File

25

SWP-RPP-01

Radiation Protection Program

016

GEN-RPP-01

ALARA Program Description

009

GEN-RPP-02

Radiological Planning and Control Process

034

GEN-RPP-13

Senior Site ALARA Committee

013

GEN-RPP-14

Control of Temporary Shielding

014

PPM 11.2.2.7

ALARA Procedure Analysis

2

PPM 11.2.2.8

ALARA Engineering Analysis

007

Procedures

(Number)

Title

Revision

PPM 11.2.2.11

Exposure Evaluations for Maintaining TEDE

ALARA

008

PPM 11.2.2.12

Radiological Risk Assessment and

Management

008

PPM 11.2.2.13

Flushing and Shielding Evaluations

2

PPM 11.2.2.14

Radiological Planning and Reviews

004

PPM 11.2.8.2

Radiation Work Permit Preparation and Use

001

Audits and Self-

Assessments (Number)

Title

Date

AR-SA No. 375350

Annual Radiation Protection Program Review

03/30/2018

SR-18-01

Continuous Monitoring Report

03/07/2018

SR-17-04

Continuous Monitoring Report

11/02/2017

374279

Self-Assessment: 71124.02 ALARA

2/15/2018

Radiation Work Permits

(Number)

Title

Revision

RWP 30004209

RWP 30004210

RWP 30003882

RWP 30003098

RWP 30003873

2018 EDR Tank-5 Desludge

2018 EDR Tank-5 Desludge High Risk

Main Steam Relief Valves

Wetwell Cleanup and Inspection

Drywell Shielding

001

2

001

001

001

ALARA Planning,

In-Progress Reviews, and

Post-Job Reviews

(Number)

Title

Date

WO 2117848

WO 2088288

WO 2088287

WO 2077319

Clean EDR Tank-5

Suppression Pool Cleanup

Chemical Decon Cleanup

Drywell Shielding

2/11/2018

Miscellaneous Documents

Senior Site ALARA Committee EDR Tank-5 Desludge

2017 CGS Dose Report to the NRC

05-2018 CGS 5 Year CRE Reduction Plan

R23 CRE Outage Report

71124.04Occupational Dose Assessment

Action Requests

357564

360494

361631

365110

365545

365692

366701

367779

369181

374380

375624

376342

376403

377080

378436

Procedures (Number)

Title

Revision

11.2.13.8

Airborne Radioactivity Surveys

019

11.2.4.5

Whole Body Counts and Daily Checks Using

the Renaissance FastScan

016

11.2.6.7

Special Dosimetry

018

11.2.7.1

Area Posting

043

GEN-RPP-06

Dosimetry Program Description

013

HPI 4.30

Processing, Evaluation, and Reporting of DLR

Exposure Data

014

HPI-0.19

Radiation Protection Standards and

Expectations

017

HPI-5.9

Evaluation of In-Vivo Bioassay Results

Following a Potential Intake

014

HPI-6.4

Administering an Occupational Radiation

Exposure History File

25

SWP-RPP-01

Radiation Protection Program

016

Audits and Self-

Assessments (Number)

Title

Date

374271

Self-Assessment: 71124.04 Occupational Dose

Assessment

2/15/2018

374020

Self-Assessment: Site Bioassay Program

11/15/2017

Miscellaneous Documents

(Number)

Title

Date

Data Verification (REIRS Submission)

03/12/2018

100518-0

NVLAP Scope and ISO 17025 Certificate for

Landauer

01/01/2018

15-02

Bases for Neutron Correction Factors for

OSLN and Survey Instruments

04/03/2015

Miscellaneous Documents

(Number)

Title

Date

DAC-0446

Scaling Factor Determination at Columbia

Generating Station - 2017

2/28/ 2018

VSDS_Pros-M-20171223-2 RW 487 Monthly Survey

2/23/2017

71151 - Performance Indicator Verification

Action Requests

377435

378504

379269

379591

380459

380745

Procedures

(Number)

Title

Revision

1.5.11

Maintenance Rule Program

015

SYS-4-22

Maintenance Rule Program

013

SYS-4-31

System and Equipment Performance Monitoring

and Trending Program

2

71152 - Problem Identification and Resolution

Action Requests

378489

378892

377416

376891

376894

375755

377654

377144

175386

373903

373313

378956

376921

2667

2847

373141

Work Orders

2108935

Procedures

(Number)

Title

Revision

1.3.81

Maintaining Plant Component Status Control

2

1.5.14

Risk Assessment and Management for

Maintenance/Surveillance Activities

040

6.6.5

Movement and Transfer Operations of HI-TRAC

and HI-STORM in the Reactor Building

017

SOP-DOOR/HATCH OPS

Reactor Building, Turbine Building, Radwaste

Building, and Containment Personnel, Equipment

Access Doors, and Hatches

013

SOP-FLOCCULATOR-OPS

Flocculator System Operation

006

SWP-CAP-01

Corrective Action Program

039

SWP-CAP-06

Corrective Action Review

24

GBP-CAP-04

Corrective Action Review Board

000

GBP-CAP-03

Trending Program

000

Miscellaneous Documents

(Number)

Title

Revision

/Date

Ops Excellence Plan Cycle 24

60855.1-Operation of an Independent Spent Fuel Storage Installation

Action Requests

00377488

00377489

00373321

00369032

00360032

Work Orders

2100824-01

2088436-01

2119266-01

2119264-01

2119263-01

2119261-01

2115652-01

2101322-01

Procedures

(Number)

Title

Revision

PPM 6.6.4

HI-STORM System Site Transportation

015

PPM 6.6.5

Transfer Operations of HI-Track/HI-STORM in the

Reactor Building

017

PPM 6.6.6

MPC Fuel Loading

015

PPM 6.6.7

MPC Processing

28

PPM 6.6.12

Vacuum Drying System Operations

006

PPM 6.6.13

Helium Backfill System Operations

004

PPM 6.6.14

MPC Alternate Cooling Water System Operation

2

PPM 6.6.15

Spent Fuel Cask Loading Verification

006

PPM 6.3.23

Handling Irradiated Fuel in the Spent Fuel Pool

010

SWP-LIC-02

Licensing Basis Impact Determinations

014

OSP-SFS-D101

Storage Cask Heat Removal System Daily Checks

015

PPM 10.4.5

Reactor and Turbine Building Overhead Traveling

Crane Inspection, Maintenance and Testing

23

PPM 9.6.1

Spent Fuel Selection for Cask Storage

008

PPM 6.3.40

Determination of Fuel Assembly Condition for

ISFSI

006

Design Basis Documents

(Number)

Title

Revision

2.212

ISFSI 10 CFR 72.212 Evaluation 72-35

010

ISFSI FSAR

HI-STORM 100 ISFSI Final Safety Analysis Report

013

CoC 1014

CoC and Technical Specifications for HI-STORM

100, Amendment 9

001

Miscellaneous Documents

(Number)

Title

Revision

/Date

VSDS DIC 1517

Survey of ISFSI Pad and & Building 105 Quarterly

01/23/2018

AU-DC-16

ISFSI Program QA Audit Report

04/20/2016

17-VS-04

Source QA Surveillance Report - Holtec International

09/14/2017

16-VS-05

Source QA Surveillance Report - Holtec International

11/08/2016

DIC 1814.5

Cask Loading Plan for Canisters 37 - 40

March

2018

PLM 003N2471

CGS Vacuum Sipping Final Report Fall 2015

2/07/2015

Cal NE-02-00-08

Calculation for Fuel History Data

006

Cal CE-02-00-12

Analysis of the Reactor Building Railroad Bay 441 Ft

Elevation Slab

2

Cal CE-02-01-08

HI-TRAC/HI-STORM Dolly Seismic Restraint @ EL 441

2

Cal SLENW-Calc-1

Cask Transport Road Design

04/06/2001

GO2-17-091

GGS 2016 Annual Radiological Environmental Operating

Report

05/09/2017

2. 48 Screenings16-009

17-001

17-002

17-003

17-004

17-005

17-006

17-007

17-008

17-009

17-010

17-011

17-012

17-013

18-001

18-004

LDCN-14-024

LDCN-18-13

Engineering Changes

EC PDC 15708

EC EVAL 17126

The following items are requested for the

Occupational Radiation Safety Inspection

at Columbia Generating Station

May 21 thru 25, 2018

Integrated Report 2018002

Inspection areas are listed in the attachments below.

Please provide the requested information on or before May 11, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1-A, applicable organization charts in file/folder 1-B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspectors will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact Louis Carson at 817. 200.1221 or

louis.carson@nrc.gov and John ODonnell at 817.200.1441 or John.ODonnell@nrc.gov

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

2.

Occupational ALARA Planning and Controls (71124.02)

Date of Last Inspection:

May 26, 2017

A.

List of contacts and telephone numbers for ALARA program personnel

B.

Applicable organization charts

C.

Copies of audits, self-assessments, and LERs, written since date of last inspection,

focusing on ALARA

D.

Procedure index for ALARA Program

E.

Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. ALARA Program

2. ALARA Committee

3. Radiation Work Permit Preparation

F.

A summary list of corrective action documents (including corporate and sub-tiered

systems) written since date of last inspection, related to the ALARA program. In addition

to ALARA, the summary should also address Radiation Work Permit violations,

Electronic Dosimeter Alarms, and RWP Dose Estimates

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G.

List of work activities greater than 1 rem, since date of last inspection,

Include original dose estimate and actual dose.

H.

Site dose totals and 3-year rolling averages for the past 3 years (based on dose of

record)

I.

Outline of source term reduction strategy

J.

If available, provide a copy of the ALARA outage report for the most recently completed

outages for each unit

K.

Please provide your most recent Annual ALARA Report.

4. Occupational Dose Assessment (Inspection Procedure 71124.04)

Date of Last Inspection:

September 1, 2016

A.

List of contacts and telephone numbers for the following areas:

1. Dose Assessment personnel

B.

Applicable organization charts

C.

Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs

written since date of last inspection, related to:

1. Occupational Dose Assessment

D.

Procedure indexes for the following areas:

1. Occupational Dose Assessment

E.

Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews

the procedure indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations

3. Personnel Dosimetry Program

4. Radiological Posting and Warning Devices

5. Air Sample Analysis

6. Performance of High Exposure Work

7. Declared Pregnant Worker

8. Bioassay Program

F.

List of corrective action documents (including corporate and sub-tiered systems) written

since date of last inspection, associated with:

1. National Voluntary Laboratory Accreditation Program (NVLAP)

2. Dosimetry (TLD/OSL, etc.) problems

3. Electronic alarming dosimeters

4. Bioassays or internally deposited radionuclides or internal dose

5. Neutron dose

NOTE: The lists should indicate the significance level of each issue and the search

criteria used. Please provide in document formats which are searchable so that

the inspector can perform word searches.

G.

List of positive whole body counts since date of last inspection, names redacted if

desired

H.

Part 61 analyses/scaling factors

I.

The most recent National Voluntary Laboratory Accreditation Program (NVLAP)

accreditation report or, if dosimetry is provided by a vendor, the vendors most recent

results

ML18206A167

SUNSI Review

By: MSH/RDR

Non-Sensitive

Sensitive

Publicly Available

Non-Publicly Available

Keyword:

NRC-002

OFFICE

SRI:DRP/A

RI:DRP/A

DRS/EB1

DRS/EB2

DRS/PSB2

DRS/OB

DNMS:FCDB

NAME

GKolcum

LBrandt

TFarnholtz

JDrake

HGepford

VGaddy

JKatanic

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

/RA-RSB for/

DATE

07/24/18

07/23/2018

07/19/2018

07/19/2018

07/19/18

07/22/18

07/24/18

OFFICE

DRS/IPAT

SPE:DRP/A

BC:DRP/A

NAME

GGeorge

RAlexander

MHaire

SIGNATURE

/RA/

/RA/

/RA/

DATE

07/20/2018

07/20/18

07/24/18

Retrieved from "https://kanterella.com/w/index.php?title=IR_05000397/2018002&oldid=4976232"