IR 05000397/2018004

NRC Integrated Inspection Report 05000397/2018004

ML19028A318
Person / Time
Site:	Columbia
Issue date:	01/28/2019
From:	Mark Haire NRC/RGN-IV/DRP/RPB-A
To:	Sawatzke B Energy Northwest
References
IR 2018004
Download: ML19028A318 (25)

Text

ary 28, 2019

SUBJECT:

COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018004

Dear Mr. Sawatzke:

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Columbia Generating Station. On January 10, 2019, the NRC inspectors discussed the results of this inspection with Mr. W. Grover Hettel, Chief Nuclear Officer/Vice President Nuclear Generation, and other members of your staff. The results of this inspection are documented in the enclosed report.

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

One of these findings involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 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 or a finding 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, Branch Chief Project Branch A Division of Reactor Projects Docket No. 50-397 License No. NPR-21 Enclosure:

Inspection Report 05000397/2018004 w/attachment: Documents Reviewed

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s): 05000397 License Number(s): NPF-21 Report Number(s): 05000397/2018004 Enterprise Identifier: I-2018-004-0040 Licensee: Energy Northwest Facility: Columbia Generating Station Location: Richland, Washington Inspection Dates: October 1, 2018 to December 31, 2018 Inspectors: G. Kolcum, Senior Resident Inspector L. Merker, Resident Inspector J. Braisted, Reactor Inspector M. Hayes, Operations Engineer N. Hernandez, Operations Engineer C. Smith, Reactor Inspector Approved By: M. Haire, Branch Chief Project Branch A Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Columbia Generating Station in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified and self-revealed findings, violations, and additional items are summarized in the tables below.

List of Findings and Violations Licensed Operator Failure Rate Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green H.1 - 71111.11 Systems FIN 05000397/2018004-01 Resources Closed The inspectors reviewed a self-revealed, Green finding associated with licensed operator performance on the biennial requalification exam. Specifically, 15 of 51 operators failed at least one portion of the biennial requalification examinations and 2 of 8 crews failed the simulator scenarios. Based on the licensee's successful remediation and subsequent retesting of individuals who failed a portion of the biennial requalification examination prior to returning to shift, no violation of regulatory requirements occurred.

Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program Cornerstone Significance Cross-cutting Inspection Aspect Procedure Mitigating Green H.4 - 71152 Systems NCV 05000397/2018004-02 Teamwork Closed The inspectors identified a Green, non-cited violation of Columbia Generating Station Operating License Condition 2.C(14), Fire Protection Program (Generic Letter 86-10),

because the licensee failed to perform hourly compensatory fire tours as required by the Licensee Controlled Specifications (LCS). Specifically, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct an hourly fire tour of the residual heat removal 2B pump room area.

Additional Tracking Items Type Issue number Title Inspection Status Procedure URI 05000397/2014002-02 Unresolved Discrepancies in 71152 Closed the Licensing Basis of the Tower Makeup System

PLANT STATUS

The plant began the inspection period at 100 percent rated thermal power.

On December 6, 2018, condensate booster pump 2A tripped due to low section pressure.

Reactor feedwater pump 1B tripped due to the condensate booster pump 2A trip and caused a recirculation pump runback to 69 percent power. On December 7, 2018, operators returned reactor feedwater pump 1B and condensate booster pump 2A to service and restored power to 74 percent. On December 11, 2018, power ascension to 85 percent power was halted at 77 percent power due to a lockup of the rod drive control system. On December 12, 2018, the licensee increased reactor power to 92 percent by increasing recirculation flow. The unit was returned to rated thermal power on December 13, 2018.

On December 15, 2018, the unit was down powered to 62 percent to perform control rod sequence exchanges, turbine valve testing, and planned repairs to condensate booster pump 2B. The unit was returned to rated thermal power on December 16, 2018.

On December 23, 2018, the unit was down powered to 98 percent to perform main steam bypass valve testing. The unit was returned to rated thermal power on December 23, 2018, and remained at or near rated thermal power for the remainder of the inspection period.

INSPECTION SCOPES

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

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

REACTOR SAFETY

71111.01Adverse Weather Protection Impending Severe Weather

The inspectors evaluated readiness for impending adverse weather conditions for high winds on October 2 - 3, 2018.

71111.04Equipment Alignment Partial Walkdown

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

(1) fuel pool cooling component check, system A, on November 21, 2018

(2) fuel pool cooling component check, system B, on November 21, 2018

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

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

(1) Fire Area DG-2/1, diesel generator 1, on October 15, 2018

(2) Fire Area R-18/2, motor control center room, Division 2, on October 17, 2018

(3) Fire Area RE-3/1, cable chase, on October 17, 2018

(4) Fire Area DG-3/2, diesel generator 2, on October 22, 2018

(5) Fire Area DG-1/1, diesel generator 3, on October 29, 2018

(6) Fire Area R-1/1, general floor area, reactor building, on October 29, 2018

71111.07Heat Sink Performance Heat Sink (Triennial)

The inspectors evaluated exchanger/sink performance on the following components from December 10, 2018, to December 13, 2018:

(1) control room chiller condenser CCH-CU-1B, Section 02.02b

(2) diesel cooling water heat exchanger DCW-HX-1A1, Section 02.02b

(3) residual heat removal pump seal cooler RHR-HX-2A, Section 02.02b

(4) residual heat removal pump room cooling Coil RRA-CC-3, Section 02.02b

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated a licensed operator requalification evaluated scenario on October 9, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated licensed operator performance associated with the following:

(1) standby liquid control, system A and B testing, on October 18, 2018

(2) tower makeup pump 1C trip, on November 25, 2018

Operator Exams (1 Sample)

The inspectors reviewed and evaluated requalification examination results on December 28, 2018, with the exception of three outstanding exams which will be administered the first week of January 2019.

Operator Requalification Program (1 Sample)

The inspectors evaluated the operator requalification program from October 15, 2018 to December 28, 2018.

71111.13Maintenance Risk Assessments and Emergent Work Control

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

(1) yellow risk for diesel generator 1 maintenance, week of October 1-5, 2018

(2) yellow risk for reactor core isolation cooling surveillances, on October 10-12, 2018

(3) orange risk during high pressure core spray battery charger C1-1 maintenance, on October 12, 2018

(4) yellow risk for residual heat removal system B maintenance, on October 15-16, 2018

(5) yellow risk for residual heat removal system A maintenance, on December 13, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) high pressure core spray battery charger low voltage, on October 11, 2018

(2) reactor building stack monitor fault, PRM-SR-1, on November 14, 2018

(3) reactor core isolation cooling system surveillance results, on December 13, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post-maintenance tests:

(1) standby diesel generator 1 load testing, on October 3, 2018

(2) high pressure core spray battery charger testing, on October 12, 2018

(3) fuel pool cooling tank 1B high level control indication switch replacement, FPC-LIS-2B, on October 31, 2018

(4) fuel pool cooling system A maintenance, on November 9, 2018

(5) fuel pool cooling system B maintenance, on November 28, 2018

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

(1) ISP-RCIC-Q903, reactor core isolation cooling surveillances, on October 10, 2018

(2) ISP-RCIC-Q901, reactor core isolation cooling surveillances, on October 11, 2018

In-service (1 Sample)

(1) OSP-CCH/IST-M702, control room emergency chiller system B, on October 18, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) SOP-FDR-OPS, floor drain system operation, on November 9, 2018

Containment Isolation Valve (1 Sample)

(1) OSP-RCIC/IST-Q701, reactor core isolation cooling valve V-19, on December 13,

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) BI01: Reactor Coolant System (RCS) Specific Activity Sample (10/01/2017-09/30/2018)

(2) BI02: RCS Leak Rate Sample (10/01/2017-09/30/2018)

71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue. The inspectors reviewed a potential trend of missed fire tours and documented one observation and an NRC-identified violation (NCV 05000397/2018004-02, Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program) on December 13, 2018.

Annual Follow-up of Selected Issues (3 Samples)

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

(1) hourly fire tours of residual heat removal pump 2B, pump room, on October 26, 2018

(2) low standby service water flow alarms, on December 18, 2018

(3) discrepancies in the licensing basis of the tower makeup system, on December 14, 2018

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

(1) The inspectors evaluated the functionality assessment of reactor building stack monitor, PRM-SR-1, and the licensees response on November 14, 2018.

(2) The inspectors evaluated the recirculation pump runback to 69 percent reactor power and the licensees response on December 6,

INSPECTION RESULTS

Observation 71152 The inspectors performed an in-depth review of the licensees evaluation and corrective actions related to a potential trend in missed fire tours. Since July 1, 2018, the licensee initiated four Action Requests documenting missed fire tours: Action Requests 382646, 383676, 384338, and 385266. Three of the missed fire tours were of minor significance; however, one fire tour was of more than minor significance and is documented in this report as NCV 05000397/2018004-02, Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program.

The inspectors assessed the licensees problem identification threshold, evaluations, and corrective actions and noted that the licensee appropriately considered extent of condition and extent of cause for the planned corrective action assignments. The inspectors determined the cause of each missed fire tour was unique and not indicative of a negative trend.

Unresolved Item Unresolved Discrepancies in the Licensing Basis of the 71152 (Closed) Tower Makeup System 05000397/2014002-02

Description:

This item was opened to review the adequacy of several changes the licensee made to the Columbia Generating Station Final Safety Analysis Report that redefined the role of the tower makeup (TMU) system as the ultimate heat sink following a design-basis tornado and changed the system description from safety-related to nonsafety-related. Additional inspection was required to determine whether the licensee made the subject changes in full compliance with 10 CFR 50.59. By memorandum, dated November 10, 2014 (ADAMS Accession No. ML14316A634), the U.S. Nuclear Regulatory Commission Region IV, Division of Reactor Projects, requested assistance from the NRC Office of Nuclear Reactor Regulation (NRR) to conduct a technical assessment of the Columbia Generating Station design and licensing bases for the TMU system.

Corrective Action Reference(s): Action Requests 302227, 304186, 308224, 312331, 346049 Closure Basis: The inspectors did not identify any findings during the follow-up inspection of this Unresolved Item. In a letter, dated October 17, 2018 (ADAMS Accession No. ML15191A2891), the NRR staff concluded that the TMU system is not part of the ultimate heat sink complex and that the requirement of Technical Specification 3.7.1, Standby Service Water (SW) System and Ultimate Heat Sink (UHS), is not applicable to the TMU system.

The NRR staff also concluded that the TMU system piping and components were not designated as Safety Class components and are not subject to the quality assurance requirements pursuant to Appendix B to Part 50 of Title 10 of the Code of Federal Regulations. This Unresolved Item is closed.

Licensed Operator Failure Rate Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.1 - 71111.11 Systems FIN 05000397/2018004-01 Resources Closed The inspectors reviewed a self-revealed, Green finding associated with licensed operator performance on the biennial requalification exam. Specifically, 15 of 51 operators failed at least one portion of the biennial requalification examinations, and 2 of 8 crews failed the simulator scenarios. Based on the licensee's successful remediation and subsequent retesting of individuals who failed a portion of the biennial requalification examination prior to returning to shift, no violation of regulatory requirements occurred.

Description:

During the facility-administered biennial requalification examination of licensed operators, the licensee training staff evaluated crew performance during dynamic simulator scenarios and individual operator performance during job performance measures and on the biennial written examination. Facility results of the biennial requalification examination showed that 15 of 51 licensed operators (29.4 percent) failed at least one portion of the biennial requalification examination and 2 of 8 crews (25 percent) failed the simulator scenarios, exceeding the threshold failure rate of 20 percent.

Corrective Actions: All individual and crew failures will be remediated and retested prior to performing licensed operator activities; and the licensee will perform an organizational and programmatic investigation (similar to a root cause investigation).

Corrective Action Reference: Action Request 387428

Performance Assessment:

Performance Deficiency: The inspectors determined that the high rate of licensed operator examination failures constituted a performance deficiency because licensed operators are expected to operate the plant within acceptable standards of knowledge and abilities demonstrated through periodic testing as required by 10 CFR 55.59(a)(2).

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the human performance attribute of Mitigating Systems cornerstone. Specifically, 15 of 51 licensed operators and 2 of 8 crews, failed to demonstrate a satisfactory understanding of the required knowledge and abilities required to safely operate the facility under normal, abnormal, and emergency conditions.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix I, "Licensed Operator Requalification Human Performance Significance Determination Process," dated December 6, 2011. This finding was of very low safety significance (Green) because the finding was related to the requalification exam results with a failure rate greater than 20 percent, but less than 40 percent.

Cross-cutting Aspect: This finding has a cross-cutting aspect in the area of human performance associated with resources, because the licensee failed to ensure that personnel were adequately trained to assure nuclear safety. Specifically, the licensee failed to use sufficiently challenging training evolutions during the training cycle to train and assess licensed operator knowledge [H.1].

Enforcement:

This finding does not involve enforcement action because no violation of regulatory requirements was identified.

Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program Cornerstone Significance Cross-cutting Report Aspect Section Mitigating Green H.4 - 71152 Systems NCV 05000397/2018004-02 Teamwork Closed The inspectors identified a Green, non-cited violation of Columbia Generating Station Operating License Condition 2.C(14), Fire Protection Program (Generic Letter 86-10),because the licensee failed to perform hourly compensatory fire tours as required by the LCS.

Specifically, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct an hourly fire tour of the residual heat removal 2B pump room area.

Description:

The Columbia Fire Protection Plan is the combination of Final Safety Analysis Report, Appendix F, and Procedure SWP-FPP-01, Nuclear Fire Protection Program, Revision 8.

Step 3.6.5 of Procedure SWP-FPP-01 states, in part, that an hourly fire tour is a common compensatory measure for impaired fire systems and identifies fire hazards and incipient fire/smokeand that a fire tour is performed in accordance with LCS 1.10, Plant Procedure Manual PPM 1.3.10B, PPM 1.3.57, and Fire Protection Program Procedure Manual FPP 1.7.

Licensee Controlled Specification 1.10.6, Essential Fire Detection, Revision 73, Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, lists the residual heat removal (RHR) 2B pump room as an area protected by essential fire detection that requires an hourly fire tour when the essential fire detection is inoperable.

On September 4, 2018, Fire Panel FP-CP-FCP1 was taken out of service for replacement per Work Order 02088112. The licensee activated fire protection system impairment (FPSI) 17-0367 and established an hourly fire tour of the affected areas in accordance with LCS 1.10.6, Essential Fire Detection, Revision 73, action statements A.1 and A.2, respectively. The work affected detection zone 13 which, per Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, Revision 73, included the residual heat removal 2A pump room, residual heat removal 2B pump room, residual heat removal 2C pump room, and the reactor core isolation cooling pump room, among others.

Security officers perform the hourly fire tours in accordance with Procedure SFI-26, Fire Tour, Revision 2. Step 4.3.7.b of Procedure SFI-26 states to complete and follow the Fire Tour Log as published, starting at the beginning of the first page. From September 4-6, 2018, the fire log listed [RB] 422 All Rooms and 441 Truck Bay, which included the residual heat removal 2B pump room. At the time of the required tours, the residual heat removal room 2B pump room was posted as a contaminated and high radiation area. Per plant procedures, entering a contaminated area and/or high radiation area during a fire tour is outside the scope for security personnel and as such, the security officers did not enter the residual heat removal 2B pump room as required. This was confirmed through interviews with plant personnel.

Multiple work groups are responsible for implementing the Columbia Fire Protection Plan when a fire protection system is impaired. Fire Protection personnel create the fire protection system impairments. Security personnel conduct the fire tours while Operations personnel provide oversight and ensure compliance with LCS 1.10.6. Meanwhile, radiation protection personnel maintain high radiation area, radiation area, and contamination area boundaries.

Communication between the work groups is essential to ensure that the fire tours are conducted in accordance with the fire protection system impairment while following radiation protection guidelines.

Corrective Actions: The licensees corrective actions included restoring functionality of the essential fire detection for the residual heat removal system 2B pump room by completing the maintenance on Fire Panel FP-CP-FCP1 and performing an apparent cause evaluation to identify the cause of the performance deficiency and implement further corrective actions.

Corrective Action Reference: Action Request 384338.

Performance Assessment:

Performance Deficiency: The failure to perform hourly compensatory fire tours in accordance with the LCS while a fire barrier component was out of service was a performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding, because it was associated with the protection against external factors (i.e. internal fire)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, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct a compensatory hourly fire tour of the residual heat removal 2B pump room area for a period of approximately 2 days. Not performing these tours led to a condition where a fire in the residual heat removal pump 2B room would go unrecognized for a longer than anticipated period of time leading to increased fire risk to safety related components and systems.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix F, Fire Protection Significance Determination Process, dated May 2, 2018. The inspectors assigned the finding to Fire Finding Category 1.4.2 using Inspection Manual Chapter 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018, because the finding involved a fire watch posted as a compensatory measure for a fixed fire protection system outage or degradation. The inspectors assigned the finding a high degradation rating using Inspection Manual Chapter 0609, Appendix F, 2, Degradation Rating Guidance, dated May 2, 2018, because the smoke detectors and fire panel annunciator for the affected room were nonfunctional during the panel replacement. Further, the inspectors determined a Phase 2 evaluation was required because the non-functional detection system adversely affected the ability of the system to protect equipment important to safe shutdown and the licensee did not have a fire PRA

[probabilistic risk assessment] capable of adequately evaluating the risk associated with the finding.

The senior reactor analyst performed a bounding risk evaluation for the performance deficiency and determined that the finding was of very low safety significance (Green). In the Washington Public Power Supply System Individual Plant Examination of External Events for the Washington Nuclear Plant 2, Revision 0, dated June 1995, Fire Zone R-4, RHR-B Room, was assigned a fire initiating event frequency of 5.0E-03/ year. The resulting baseline core damage frequency was calculated to be 2.57E-07. The performance deficiency existed for 2 days, from September 4 through 6, 2018. Applying the 2-day exposure period (5.48E-03), the resulting probability of a fire starting in the room over this period was calculated to be 2.74E-05. Because at least two trains of a multi-train injection system would be available following a postulated fire, the analyst assigned a bounding failure rate for a single multi-train system. Using Table 5, Mitigation Capability Credits for Installed Equipment, from Inspection Manual Chapter 0609, Appendix G, Attachment 3, Phase 2 Significance Determination Process Template for BWR during Shutdown, dated February 28, 2005, as best available information, the analyst assigned 1.0E-3 as the failure of the safe shutdown path failure probability. Therefore, the external events incremental conditional core damage probability from internal fire was 8.22E-08. The dominant sequence was a fire in the RHR-B Pump Room leading to a reactor trip followed by a failure of the following functions:

• main feedwater;

• high pressure core spray;

• reactor isolation core cooling;

• low pressure injection;

• condensate; and

• alternate low pressure injection.

Because this core damage frequency is below the green/white threshold for large, early release frequency, no additional evaluation was necessary to determine that the finding was of very low safety significance with respect to containment failures.

Cross-cutting Aspect: This finding had a cross-cutting aspect in the area of human performance, teamwork, in that the licensee individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained. Specifically, there was a lack of communication between the operations, radiation protection, fire protection, and security work groups when implementing FPSI 17-0367 [H.4].

Enforcement:

Violation: Columbia Generating Station License Condition 2.C(14), Fire Protection Program (Generic Letter 86-10), requires, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in Section 9.5.1 and Appendix F of the Final Safety Analysis Report (FSAR) for the facility through Amendment

1. 39 and as described in subsequent letters to the staff referenced in the May 22, 1989, safety evaluation and as approved in the Safety Evaluation Report issued in March 1982, and subsequent supplements and safety evaluations. The Columbia Fire Protection Plan is the combination of Final Safety Analysis Report Appendix F and Procedure SWP-FPP-01, Nuclear Fire Protection Program, Revision 8. Step 3.6.5 of Procedure SWP-FPP-01 states, in part, that an hourly fire tour is a common compensatory measure for impaired fire systems and identifies fire hazards and incipient fire/smokeand that a fire tour is performed in accordance with LCS 1.10, Plant Procedure Manual PPM 1.3.10B, PPM 1.3.57, and Fire Protection Program Procedure Manual FPP 1.7. Licensee Controlled Specification 1.10.6, Essential Fire Detection, Revision 73, Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, lists the residual heat removal 2B pump room as an area protected by essential fire detection that requires an hourly fire tour when the essential fire detection is inoperable. FPSI 17-0367 established an hourly fire tour of the affected areas in accordance with LCS 1.10.6. The work affected detection zone 13 which, per Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, Revision 73, included the residual heat removal 2A pump room, residual heat removal 2B pump room, residual heat removal 2C pump room, and the reactor core isolation cooling pump room, among others. Security officers perform the hourly fire tours in accordance with Procedure SFI-26, Fire Tour, Revision 2. Step 4.3.7.b of Procedure SFI-26 states to complete and follow the Fire Tour Log as published, starting at the beginning of the first page. From September 4-6, 2018, the fire log listed [RB] 422 All Rooms and 441 Truck Bay which included the residual heat removal 2B pump room.

Contrary to the above, from September 4-6, 2018, the licensee failed to implement all provisions of the approved fire protection program as described in Section 9.5.1 and Appendix F of the Final Safety Analysis Report (FSAR) for the facility through Amendment

1. 39 and as described in subsequent letters to the staff referenced in the May 22, 1989, safety evaluation and as approved in the Safety Evaluation Report issued in March 1982, and subsequent supplements and safety evaluations. Specifically, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct an hourly fire tour of the residual heat removal 2B pump room area for a period of approximately 2 days.

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

EXIT MEETINGS AND DEBRIEFS

On December 13, 2018, the inspectors presented the triennial heat sink inspection results to Mr. B. Sawatzke, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

On December 28, 2018, the inspector presented the licensed operator requalification inspection results to Mr. G. Pierce, Acting Chief Nuclear Officer, and other members of the licensee staff.

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

On January 10, 2019, the inspectors presented the quarterly resident inspector inspection results to Mr. W. Grover Hettel, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

71111.01Adverse Weather Protection

Action Reports

376979 376980 379000 379022 376079

Procedures

Number Title Revision

ABN-WIND Tornado / High Winds 029

ABN-WIND Tornado / High Winds 030

ABN-WIND Tornado / High Winds 031

71111.04Equipment Alignment

Procedures

Number Title Revision

ABN-FPC-LOSS Loss of Fuel Pool Cooling 016

SOP-FPC-ASSIST Alternate Fuel Pool Cooling Assist 011

SOP-FPC-LU Fuel Pool Cooling and Cleanup System Valve and

Breaker Lineup 006

SOP-FPC-OPS Fuel Pool Cooling and Cleanup Operations 007

SOP-FPC- FPC-Shutdown

SHUTDOWN 003

SOP-FPC-SPC FPC Suppression Pool Operations 011

SOP-FPC-SST FPC Skimmer Surge Tank Operations 005

SOP-FPC-START Fuel Pool Cooling Start 006

Drawings

Number Title Revision

M526-1 Flow Diagram Fuel Pool Cooling and Clean-up System 103

M526-2 Flow Diagram Fuel Pool Cooling and Clean-up System 002

E519, Sheet 25 Motor Valve and Miscellaneous Control

E519, Sheet 25A Motor Valve and Miscellaneous Control

Miscellaneous

Documents Number Title

WNP-2 FSAR, Chapter 9

71111.05AQFire Protection Annual/Quarterly

Procedures

Number Title Revision

1.3.10 Plant Fire Protection Program Implementation 034

1.3.10A Control of Ignition Sources 017

1.3.10C Control of Transient Combustibles 020

FP-02-85-03 Combustible Loading Calculation 010

PFP-RW-467 Radwaste 467 005

PFP-RB-522 Reactor 522 005

71111.07Heat Sink Performance

Action Requests (Reviewed)

350866 354191 343378 352608 364408

384466 384628 384953 382614 387552

387548 310795 358871

Action Requests (Issued)

387786 387787 387825

Work Orders

2080963 02013391 02103028 02001311 02047406 02094831 02077068

Procedures

Number Title Revision

Service Water Reliability Program 003

ABN-HVAC HVAC Trouble 013

HXP-01 Heat Exchanger Program 001

OSP-CCH/IST- Control Room Emergency Chiller System B Operability 040

M702

OSP-SW-M101 Standby Service Water Loop A Valve Position Verification 039

TSP-SW-A101 Service Water Loop A Cooling Coil Heat Load Capacity 003

Test

Drawings Revision

Number Title or Date

2C302FD RHR Pump General Arrangement November 23,

1971

CVI-215-11 Seal Injection Water Coolers 005

M521-1 Flow Diagram Residual Heat Removal System Loop A 117

RHR-4719-1 Seal Cooler Piping for RHR 001

Miscellaneous Revision

Documents Number Title or Date

Control Room Envelope Habitability Program 000

Eddy Current Inspection Report, CCH-CR-1B March 3, 2014

180734-01 Report of Analysis, Service Water Pond A Sediment January 10,

2018

5059 SCREEN-16- 354191-02 Evaluate CM to isolate 000

0157 CCH-CR-1B AOP while in standby mode

AR-SA 332674 Focused Self-Assessment Report, GL 89-13 Service 000

Water Self-Assessment for Ultimate Heat Sink

Inspection

AR-SA 378472 Snapshot Self-Assessment Report June 28, 2018

C94-0319 Component CER Summary Sheet, 2-CCH-P-1A and 2- 003

CCH-P-1B

CCH-02 Function Basis Document, Control Room Chilled Water 000

DBD 309 Design Basis Document, Standby Service Water System 018

GI2-97-039 Issuance of Amendment for the Washington Public March 4, 1997

Power Supply System Nuclear Project No. 2

(TAC No. M94226)

LBD-IST-4 Inservice Testing Program Plan, Fourth Ten-Year 001

Inspection Interval

LDCN-17-014 Revise FSAR Habitability Temperature Discussion 000

SD000201 System Description, Control Room, Cable Room and 015

Critical Switchgear Rooms - HVAC (CR-HVAC)

Modifications

Number Title Revision

EC 12326 Approve the Use of CID 8741 for RRA-CC-3 002

Replacement and Eliminate the Cooling Coil Zinc Anodes

EC 14954 CCH Bypass Line AR 224656224656 002

Calculations

Number Title Revision

ME-02-85-70 Seal Coolers for RHR-P-2A,-2B, &-2C 000

ME-02-92-43 Room Temperature Calculation for DG Building, Reactor 012

Building, Radwaste Building, and Service Water

ME-02-96-03 RHR Seal Cooler Performance Evaluation 000

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Action Reports

385920 358660 358602 358766 358890

2587 362548 362587 363586 366392

Action Reports

359162 375090 383090 359162 385010

359064 362548

Work Orders

2103901 02115120

Procedures

Number Title Revision

4.603.A7 603.A7 Annunciator Panel Alarms 054

4.603.A8 603.A8 Annunciator Panel Alarms 039

OI-09 Operations Standards and Expectation 070

OSP-INST-H101 Shift and Daily Instrument Checks (modes 1, 2, 3)

OSP-SLC-B703 SLC Pump Suction Flow Verification 009

SOP-RCIC-INJEC RCIC RPV Injection - Quick Card 007

TION-QC

OI-69 Time Critical Operator Actions 010

TDI-06 Simulator Management 020

TDI-08 Licensed Operator Requalification Program 015

TDI-23 LORQ Annual Exam Development and Administration 009

TDI-24 Exam Security 006

1.3.1 Operating Policies, Programs and Practices 127

1.8.10 Administration of Medical Qualifications 011

1.8.11 Medical Examination Program for Licensed Operators 011

Drawings

Number Title Revision

EWD-10E-003 Electrical Wiring Diagram Standby Liquid Control System 018

Pump SLC-P-1A (C41-L001A) and Squib Valve SLC-V-4A

(C41A-F004A) (Explosive Injection Valve)

Scenario Based

Testing Number Title

Week 2 Simulator Scenario 1

Week 2 Simulator Scenario 2

Week 2 Simulator Scenario 3

Week 2 Simulator Scenario 4

Miscellaneous

Documents Number Title

2018 Operational Exam Week 2

2017 Training Remediation Analysis

OE 2017 LORQ

Miscellaneous

Documents Number Title

OE 2018 LORQ

SRB 2017-4-17 Minutes

SRB 2017-9-05 Minutes

SRB 2018-2-08 Minutes

SRB 2018-6-27 Minutes

71111.13Maintenance Risk Assessments and Emergent Work Control

Action Reports

373410 373028 374072 378760 379507

2576 382706 385221 385048

Procedures

Number Title Revision

1.3.10 Plant Fire Protection Implementation 034

1.3.76 Integrated Risk Management 052

1.3.83 Protected Equipment Program 026

1.3.83 Protected Equipment Program 027

1.3.85 On-line Risk Management 005

ICP-RCIC-Q901 RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC 013

ISP-RCIC-Q901 RCIC Isolation on RCIC Steam Supply Flow High

DIV 1-CFT/CC 024

ISP-RCIC-Q903 RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC 019

71111.15Operability Determinations and Functionality Assessments

Action Reports

385634 385654 385674 386750 386861

387833 387990 386956 387479

Work Orders

29146086 29146159 29146182 29146189 02049828 02137070 02105341

Procedures

Number Title Revision

ESP-MOVTOL- MOV Thermal Overload Testing - CC 022

B301

OSP-RCIC/ RCIC Operability Test 062

IST-Q701

Procedures

Number Title Revision

SOP-HOT Hot Weather Operations 006

WEATHER-OPS

SOP-HPCS- HPCS CST and Suppression Pool Operations 014

CST/SP

SOP-HPCS- HPCS Drain 007

DRAIN

SOP-HPCS-FILL HPCS Fill and Vent 013

SOP-HPCS- HPCS RPV Injection 006

INJECTION

SOP-HPCS- HPCS-RPV Injection-Quick Cards 004

INJECTION-QC

SOP-HPCS-LU HPCS Valve and Breaker Lineup 004

SOP-HPCS-STBY Placing HPCS in Standby Status 003

Drawings

Number Title Revision

250-00.47.1 Valve Assembly, 2 inch. Y Type, Globe Valve, Motor

Operated, C.S 000

807EI72TC, G.E. Elementary Drawings

Sheets 1 - 8

M520 High-Pressure Core Spray

Miscellaneous

Documents Number Title Revision

Columbia Generating Station FSAR, Chapters 6, 7, and

776-00.1.1 Stack Monitoring System Equipment, Instrumentation, 002

Dual Sum, Amplifier, Power Supply, Modular System and

Coaxicon Vendor Manual

RCIC-MO-19 MOV Master Data Sheet 013

Calculations

Number Title Revision

NE-02-09-12 CGS Emergency Action Levels (EALs) Technical Bases 004

NE-02-13-10 Determination of Low Range Stack Monitor Xe-133 000

Equivalent Efficiency

NE-02-15-07 Setpoint Calculation for Reactor Building Elevated 000

Discharge Radiation Monitor (Stack Monitor)

Modifications

Number Title Revision

EC 11288 Replace Stack Monitors 008

71111.19Post Maintenance Testing

Action Reports

386266 386407 383578 386511 386534

369412 375956 386788 387001 387128

387131 275278

Work Orders

2066474 02084370 02012402 02093087 02105297 02066473 02085665

2117254 02117272 02134934 02118420 02119131 02103360 02117248

2117266 02117733 02118376 02036318 02025412 02125833 02103028

2066474 02102737 02102767

Procedures

Number Title Revision

10.2.10 Fastener Torque and Tensioning 028

10.24.34 PM Calibration Test Barton Differential Indicating Switch 016

ESP-MOVTOL- MOV Thermal Overload Testing - CC 021

B301

OSP-FPC/IST- Fuel Pool Cooling System Operability Surveillance 037

Q701

TSP-DG1-B502 Standby Diesel Generator DG1 Load Testing 021

Drawings

Number Title Revision

EWD-69E-116 Condensate System Valve COND-SPV-42 010

Miscellaneous

Documents Number Title Revision

CVI 531-00, 1, 2 Barton Differential Pressure Indicating Switches, Unit,

Calibration, and Parts List Manual 003

71111.22Surveillance Testing

Action Reports

385817 386056 385829

Work Orders

2102754 02106212 02102737 02102767 02125833 02103028

Procedures

Number Title Revision

ABN-LEAKAGE Reactor Coolant Leakage 006

CVI 02E31-03,4 Leak Detection System Design Specification 003

CVI 02E31-04,2,1 Leak Detection System Design Specification 018

Procedures

Number Title Revision

CVI 02E31-04,2,2 Leak Detection System Design Specification 013

ICP-RCIC-Q901 RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC 013

ISP-RCIC-Q901 RCIC Isolation on RCIC Steam Supply Flow High

DIV 1-CFT/CC 024

ISP-RCIC-Q903 RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC 019

ISP-FDR/ Drywell Sump Flow Monitors - CC 011

EDR-X301

OSP-CCH/ Control Room Emergency Chiller System B Operability 040

IST-M702

OSP-INST-H101 Shift and Daily Instrument Checks (Modes 1, 2, 3) 091

SOP-FDR-OPS Floor Drain System Operation 003

SYS-2-19 Reactor Coolant System Leakage Best Practice 000

Drawings

Number Title Revision

M539 Floor Drain System Reactor Building Flow Diagram 088

M775 Flow Diagram Emergency Chilled Water Piping System 028

Control Room

Miscellaneous

Documents Number Title Revision

EDR-FRS-623 Instrument Master Data Sheet for EDR-FRS-623 013

FDR-FT-38 Instrument Master Data Sheet for EDR-FRS-623 009

FDR-SQRT-38 Instrument Master Data Sheet for FDR-SQRT-38 011

71151Performance Indicator Verification

Action Reports

2567

Work Orders

2100685 02092836

Procedures

Number Title Revision

CI-10.17 Iodine 012

CSP-I131-W101 Reactor Coolant Isotopic Analysis for I-131 Dose

Equivalent 009

OSP-INST-H101 Shift and Daily Instrument Checks (Modes 1, 2, 3) 091

71152Problem Identification and Resolution

Action Reports

383152 383417 385638 385266 384338

383676 382646 380257 384338

Procedures

Number Title Revision

1.3.10 Plant Fire Protection Program Implementation 034

1.3.10B Active Fire System Operability and Impairment Control 015

FPP-1.7 Fire Tour Implementation 006

PFP-RB-422 Reactor 422 006

SFI-26 Fire Tour 002

SWP-FPP-01 Nuclear Fire Protection Program 008

Modifications

Number Title

EC 17375

71153Follow-up of Events and Notices of Enforcement Discretion

Action Reports

386750 387596 387597 387594 388087

387651 387598 387621 387623 387611

386956

Work Orders

2136717

Procedures

Number Title Revision

ABN-CORE Unplanned Core Operating Conditions 017

ABN-FWH- Feedwater Header High Level Trip

HI/LEVEL-TRIP 007

ABN-HWC Hydrogen Water Chemistry System Trouble 004

ABN-POWER Unplanned Reactor Power Change 016

SOP-FWH- Extraction Steam and Heater Vents / Drains System

SHUTDOWN Shutdown 004

Drawings

Number Title Revision

M504-1 Flow Diagram Condensate and Feed Water Systems 111

Miscellaneous

Documents Number Title Revision

Operations Logs 12/5-12/7 000

358.00,1,5 O/M Manual for Type 701 Basic Controller 001

776-00.1.1 Stack Monitoring System Equipment, Instrumentation, 002

Dual Sum, Amplifier, Power Supply, Modular System

and Coaxicon Vendor Manual

Calculations

Number Title Revision

NE-02-09-12 CGS Emergency Action Levels (EALs) Technical Bases 004

NE-02-13-10 Determination of Low Range Stack Monitor Xe-133 000

Equivalent Efficiency

NE-02-15-07 Setpoint Calculation for Reactor Building Elevated 000

Discharge Radiation Monitor (Stack Monitor)

Modifications

Number Title Revision

EC 11288 Replace Stack Monitors 008

ML19028A318

SUNSI Review ADAMS: Non-Publicly Available Non-Sensitive Keyword:

By: Yes No Publicly Available Sensitive NRC-002

OFFICE SRI:DRP/A RI:DRP/A DRS/IPAT DRS/EB1 DRS/EB2 DRS/PSB2

NAME GKolcum LMerker RKellar VGaddy JDrake HGepford

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/

DATE 01/21/19 01/17/19 01/16/19 01/17/19 01/16/19 01/17/19

OFFICE DRS/OB SPE:DRP/A BC:DRP/A

NAME GWerner RAlexander MHaire

SIGNATURE /RA/ /RA/ /RA/

DATE 01/20/19 01/22/19 01/28/19