IR 05000397/2021001

CGS2021001-IR-NH, Columbia Generating Station - Integrated Inspection Report 05000397/2021001

ML21113A195
Person / Time
Site:	Columbia
Issue date:	05/07/2021
From:	Jeffrey Josey NRC/RGN-IV/DRP
To:	Sawatzke B Energy Northwest
References
IR 2021001
Download: ML21113A195 (28)

Text

May 7, 2021

SUBJECT:

COLUMBIA GENERATING STATION - INTEGRATED INSPECTION REPORT 05000397/2021001

Dear Mr. Sawatzke:

On March 31, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On April 15, 2021, the NRC inspectors discussed the results of this inspection with Mr. A. Javorik, Site Vice President, Engineering Projects, and other members of your staff. The results of this inspection are documented in the enclosed report.

Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:

Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspectors at Columbia Generating Station.

If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspectors at 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 Title 10 of the Code of Federal Regulations (10CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Jeffrey E. Josey, Chief Reactor Projects Branch A Division of Reactor Projects

Docket No. 05000397 License No. NPF-21

Enclosure:

As stated

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2021001

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, Washington

Inspection Dates:

January 1, 2021 to March 31, 2021

Inspectors:

N. Hernandez, Senior Resident Inspector

L. Merker, Senior Resident Inspector

W. Cullum, Reactor Inspector

L. Flores, Reactor Inspector

J. Melfi, Project Engineer

W. Sifre, Senior Reactor Inspector

Approved By:

Jeffrey E. Josey, Chief

Reactor Projects 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 (ROP). The ROP is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

Inadequate Operability Evaluations for American Society of Mechanical Engineers (ASME)

Code Pipe Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000397/2021001-01 Open/Closed

[H.1] -

Resources 71111.15 The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to establish adequate procedural guidance for operability determinations. Specifically, Plant Procedures Manual (PPM) 1.3.66, Operability Determination, Revisions 35 and 36, failed to include guidance identifying the need to also evaluate structural integrity in accordance with the ASME Code for code class piping systems when flaws are identified. This resulted in an incomplete operability determination on September 18, 2020, and loss of the presumption of operability of the reactor core isolation cooling (RCIC) system on December 11, 2020.

Failure to Perform Preservice Testing as Required by American Society of Mechanical Engineers (ASME) Code Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity Green NCV 05000397/2021001-02 Open/Closed

[H.1] -

Resources 71152 The team identified a Green, non-cited violation (NCV) of 10 CFR 50.55a(f), Preservice and inservice testing requirements, subsection (4), Inservice testing standards requirement for operating plants, because the licensee did not implement the Inservice Test (IST) Program in accordance with the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM) of Record for the control room chilled water system 1A and 1B pumps. Specifically, the licensee did not perform preservice testing of the 1A and 1B control room chilled water (CCH)pumps as required by ASME OM Code, Paragraph ISTB-3100 Preservice Testing, before scoping the pumps into their IST program. This resulted in CCH operability surveillance procedures with inaccurate IST information that could not be used to determine the pumps met technical specification requirements.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000397/2020004-02 Reactor Core Isolation Cooling Drainpipe Steam Leak 71111.15 Closed

PLANT STATUS

Columbia Generating Station began the inspection period at 100 percent power. On January 16, 2021, reactor power was reduced to 80 percent to perform a control rod sequence exchange before returning to rated thermal power. On February 20, 2021, reactor power was reduced to 65 percent to perform a control rod pattern adjustment and repair a leak on condensate booster pump 2C before returning to 100 percent power. On February 27, 2021, reactor power was reduced to 80 percent to perform a control rod pattern adjustment and turbine bypass valve testing before returning to 100 percent power. On March 23, 2021, the plant began power coastdown for refueling outage R25 and ended the inspection period at approximately 96 percent power.

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 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.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease 2019 (COVID-19),resident inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week; conducted plant status activities as described in IMC 2515, Appendix D, Plant Status; observed risk-significant activities; and completed on-site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on-site. The inspections documented below met the objectives and requirements for completion of the IP.

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather Sample (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated readiness for seasonal extreme weather conditions prior to the onset of seasonal extreme cold temperatures for standby service water system A, standby service water system B, diesel generator 1, and diesel generator 2 on February 3, 2021.

Impending Severe Weather Sample (IP Section 03.02) (1 Sample)

(1) The inspectors verified the adequacy of the overall preparations to protect risk-significant systems from impending severe weather during sustained high wind conditions on January 13, 2021.

External Flooding Sample (IP Section 03.03) (1 Sample)

(1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on March 3, 2021.

71111.04 - Equipment Alignment

Partial Walkdown Sample (IP Section 03.01) (3 Samples)

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

(1)control room emergency chilled water system B during planned maintenance on January 12, 2021 (2)control room emergency chilled water system A during planned maintenance on January 25, 2021 (3)diesel generator 3 during planned maintenance, week of January 25, 2021

Complete Walkdown Sample (IP Section 03.02) (1 Sample)

(1) The inspectors performed a complete system alignment of diesel generator 2 on March 26, 2021.

71111.05 - Fire Protection

Fire Area Walkdown and Inspection Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:

(1) Fire Area RC-13/2; chiller, communications, instrumentation and control area; on January 11, 2021

(2) Fire Areas RC-11/1 and RC-12/2; heating, ventilation, and air conditioning equipment rooms A and B; on January 22, 2021

(3) Fire Areas DG-1/4, DG-6/#, and DG-7/#; high-pressure core spray diesel generator room, storage tank access area, and day tank room; on January 25, 2021

(4) Fire Area R-3, high-pressure core spray pump room, on March 11, 2021

(5) Fire Areas DG-3, DG-5, and DG-9; diesel generator 2, diesel oil tank pump room, and diesel day tank room; on March 16, 2021

71111.06 - Flood Protection Measures

Cable Degradation (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated manholes E-MH-E11, E-MH-E13, and E-MH-E15 for cable submergence protection in the protected area on March 31, 2021.

===71111.07T - Heat Sink Performance

Triennial Review (IP Section 03.02)===

(1) RHR-HX-1A, Residual Heat Removal Train A

(2) RHR-HX-2A, RHR-P-2A Seal Injection Water Cooler

(3) DCW-HX-1C, Cooling Water to Division 3 Diesel

(4) RRA-CC-12, Division I Motor Control Center Room Cooler

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance

Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the control room during a reactor downpower to perform maintenance on condensate pump C on February 20, 2021.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated the licensed operator requalification training drill (Crew B) on February 1, 2021.

71111.12 - Maintenance Effectiveness

Maintenance Effectiveness (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the effectiveness of diesel generator 2 maintenance on March 25, 2021 to ensure structures, systems, and components remained capable of performing their intended function.

Quality Control (IP Section 03.02) (1 Sample)

(1) The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the commercial dedication of the control room emergency chiller 1A rupture disk remained capable of performing its intended function on January 15, 2021.

71111.13 - Maintenance Risk Assessments and Emergent Work Control

Risk Assessment and Management Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:

(1)high risk for transformer E-TR-8A/2 replacement on January 19, 2021 (2)yellow risk for diesel generator 3 maintenance, week of January 25, 2021 (3)yellow risk for standby service water system A, circuit breaker S/1, and turbine oil vapor extractors 1A and 1B maintenance, week of February 1, 2021 (4)yellow risk for RCIC system surveillance testing, week of March 8, 2021 (5)yellow risk for diesel generator 2 planned maintenance outage, week of March 15, 2021

71111.15 - Operability Determinations and Functionality Assessments

Operability Determination or Functionality Assessment (IP Section 03.01) (4 Samples)

The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:

(1)control room emergency chilled water pump 1B differential pressure beyond action range on February 12, 2021 (2)aging effects on electrical contactors on February 24, 2021 (3)diesel generator 3 high jacket water temperature shutdown switch out of calibration on March 9, 2021 (4)standby service water pump 1B oil sample found elevated water level in the upper bearing oil reservoir on March 12, 2021

71111.18 - Plant Modifications

Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)

The inspectors evaluated the following temporary or permanent modifications:

(1)control room emergency chilled water system A check valve replacement on January 27, 2021 (2)electrical bus SM-1 undervoltage relay E-RLY-27/1 removal on March 9, 2021

71111.19 - Post-Maintenance Testing

Post-Maintenance Test Sample (IP Section 03.01) (5 Samples)

The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:

(1)control room emergency chiller system A on January 22, 2021 (2)control room emergency chiller system B on January 29, 2021 (3)diesel generator 3 maintenance on January 29, 2021 (4)standby service water system A on February 8, 2021 (5)diesel generator 2 on March 26, 2021

71111.22 - Surveillance Testing

The inspectors evaluated the following surveillance tests:

Surveillance Tests (other) (IP Section 03.01)

(1) ISP-SGT-B101, standby gas treatment system A flow and filter pressure drop test (once per 24 months), on January 7, 2021

(2) OSP-CRD-C703, control rod settle time test, on February 20, 2021

Inservice Testing (IP Section 03.01) (1 Sample)

(1) OST-SLC/IST-Q701, standby liquid control pump 1A quarterly, on March 4, 2021

FLEX Testing (IP Section 03.02) (1 Sample)

(1) FLEX diesel quarterly testing on February 23, 2021

71114.06 - Drill Evaluation

Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01) (1 Sample)

(1) The inspectors evaluated the emergency planning drill (Emergency Response Organization Team C) on March 9,

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

IE01: Unplanned Scrams per 7000 Critical Hours Sample (IP Section 03.01)===

(1) January 1, 2020, through December 31, 2020

IE03: Unplanned Power Changes per 7000 Critical Hours Sample (IP Section 03.02) (1 Sample)

(1) January 1, 2020, through December 31, 2020

IE04: Unplanned Scrams with Complications Sample (IP Section 03.03) (1 Sample)

(1) January 1, 2020, through December 31, 2020

71152 - Problem Identification and Resolution

Annual Follow-up of Selected Issues (IP Section 02.03) (2 Samples)

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

(1)evaluation of the control room chilled water system addition to the IST program on March 9, 2021 (2)evaluation of the electrical power panel E-PP-8AF low voltage on March 22,

INSPECTION RESULTS

Inadequate Procedural Guidance for Operability Determinations for American Society of Mechanical Engineers (ASME) Code Pipe Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems

Green NCV 05000397/2021001-01 Open

[H.1] -

Resources 71111.15 The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, associated with the licensees failure to establish adequate procedural guidance for operability determinations. Specifically, Plant Procedures Manual (PPM) 1.3.66, Operability Determination, Revisions 35 and 36, failed to include guidance identifying the need to also evaluate structural integrity in accordance with the ASME Code for code class piping systems when flaws are identified. This resulted in an incomplete operability determination on September 18, 2020, and loss of the presumption of operability of the RCIC system on December 11, 2020.

Description:

On September 18, 2020, the licensee discovered a steam leak on the RCIC system turbine steam inlet valve drain line during recovery from planned RCIC maintenance. This issue was entered into the corrective action program under Action Request (AR) 410929. The licensee performed an operability determination that stated the RCIC system was operable with the steam leak because the leak would not impact the required steam flow to the RCIC turbine. The licensee restored the RCIC system to the normal standby lineup (which isolated the steam leak) on September 18, 2020. On December 9, 2020, engineering entered a concern into the corrective action program (AR 414023414023 that the operability determination from AR 410929410929failed to evaluate the steam leak against ASME Code requirements as the drain line was an ASME Section III, Class 2, high-energy pipe. Operations requested additional operability information from engineering to further evaluate operability of the RCIC system. Engineering provided the requested additional operability information on December 11, 2020. The inspectors identified weaknesses in the additional operability information and determined the licensee needed to perform an ASME Code repair on the pipe and submit an ASME Code relief request to the NRC. On December 17, 2020, the licensee declared the RCIC system inoperable. On December 19, 2020, the licensee declared the RCIC system unavailable in order to perform the ASME Code repair. The licensee restored the RCIC system to operable status on December 20, 2020.

The licensee completed an event investigation and entered AR 414343414343into the corrective action program to evaluate past operability of the RCIC system. The inspectors independently reviewed the licensees past operability analyses, evaluated the licensee's event investigation, and determined the licensee had demonstrated reasonable assurance of past operability of the RCIC system.

On April 30, 2020, the licensee updated PPM 1.3.66 to Revision 35 to reflect updated industry guidance on operability determinations. ASME Code requirements and their relationship to operability of structures, systems, and components were unknown by licensee personnel throughout the organization and were not included in the operability determination process update. This omission was carried through in the August 18, 2020, update to Revision 36. The licensee updated PPM 1.3.66 to Revision 37 to include guidance identifying the need to also evaluate structural integrity in accordance with the ASME Code for code class piping systems when flaws are identified on March 4, 2021.

Corrective Actions: The licensee performed an ASME Code repair on the turbine steam inlet valve drain line, entered the condition into the corrective action program, performed a failure analysis of the drain line, conducted an event investigation, performed extensive past operability analyses, and updated the operability procedure to include guidance identifying the need to also evaluate structural integrity in accordance with the ASME Code for code class piping systems when flaws are identified.

Corrective Action References: ARs 410929, 414023, and 414343

Performance Assessment:

Performance Deficiency: The failure to establish adequate procedural guidance for operability determinations was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Equipment Performance 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. Specifically, Plant Procedures Manual (PPM) 1.3.66, Operability Determination, Revisions 35 and 36, failed to include guidance identifying to evaluate structural integrity in accordance with the ASME Code for code class piping system when flaws are identified. This resulted in an incomplete operability determination on September 18, 2020, and the loss of the presumption of operability of the RCIC system on December 11, 2020.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined this finding is of very low safety significance (Green) because all of the screening questions were answered in the negative.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. The finding has a cross-cutting aspect in the area of human performance, resources, in that the licensee did not ensure that personnel, equipment, procedures, and other resources were available and adequate to support nuclear safety. Specifically, ASME Code requirements and their relationship to operability of structures, systems, and components were unknown by licensee personnel throughout the organization and were not included in the operability determination process update on April 30, 2020.

Enforcement:

Violation: Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances. The licensee established PPM 1.3.66, Operability Determination, as the implementing procedure for conducting operability determinations.

Contrary to the above, from April 30, 2020, through March 4, 2021, the licensee failed to ensure that operability determinations, activities affecting quality, were prescribed by a documented procedure of a type appropriate to the circumstances. Specifically, PPM 1.3.66, Operability Determination, Revisions 35 and 36, failed to include guidance to evaluate structural integrity in accordance with the ASME Code for code class piping systems when flaws are identified. This resulted in an incomplete operability determination on September 18, 2020, and the loss of the presumption of operability of the RCIC system on December 11, 2020, due to a steam leak on the turbine steam inlet valve drain line.

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

The disposition of this finding and associated violation closes URI: 05000397/2020004-02.

URI (Closed)

Reactor Core Isolation Cooling Drainpipe Steam Leak URI 05000397/2020004-02 71111.15

Description:

This unresolved item (URI) is closed. The basis for the URI closure is discussed in this report under NCV 05000397/2021001-01 in the above Inspection Results associated with Report Section 71111.15.

Failure to Perform Preservice Testing as Required by American Society of Mechanical Engineers (ASME) Code Cornerstone Significance Cross-Cutting Aspect Report Section Barrier Integrity

Green NCV 05000397/2021001-02 Open

[H.1] -

Resources 71152 The team identified a Green, non-cited violation (NCV) of 10 CFR 50.55a(f), Preservice and inservice testing requirements, subsection (4), Inservice testing standards requirement for operating plants, because the licensee did not implement the IST program in accordance with the ASME OM Code of Record for the control room chilled water system 1A and 1B pumps. Specifically, the licensee did not perform preservice testing of the 1A and 1B control room chilled water (CCH) pumps as required by ASME OM Code, Paragraph ISTB-3100 Preservice Testing, before scoping the pumps into their IST program. This resulted in CCH operability surveillance procedures with inaccurate IST information that could not be used to determine the pumps met technical specification requirements.

Description:

On February 6, 2020, Columbia Generating Station received approval from the NRC for a license amendment request (LAR) to allow the use of either the CCH system or the emergency service water system (SW) as acceptable cooling sources in support of the main control room (MCR) air conditioning (AC) system. The safety-related function of the MCR AC system is to maintain the MCR temperature less than or equal to the 104°F equipment qualification temperature limit during and following design basis events, and maintaining the long term, steady state MCR design condition temperature less than or equal to 85°F that supports 30 days continuous MCR occupancy. The change would utilize the CCH system as the preferred cooling source in support of the MCR AC system due to SW heat removal capability limitations. The LAR implementation included expanding the scope of the IST program to include applicable components in the CCH and SW systems utilized for CCH system operation not previously included in the program and updating all relevant documentation to reflect the change. On May 4, 2020, Columbia Generating Station received approval to extend the LAR implementation date to February 6, 2021, due to unforeseen circumstances associated with the COVID-19 pandemic. The licensee completed full implementation of the LAR on February 4, 2021.

The inspectors reviewed several ARs that documented issues with implementing the LAR and establishing required test conditions for the CCH pumps. On February 4, 2021, the licensee created AR 415919415919to document that the newly updated CCH operability surveillance procedures contained inaccurate IST information that could not to be used to determine the pumps met technical specification requirements; the inaccurate IST information would be corrected by March 12, 2021, after the licensee performed additional testing. The inspectors identified that this was not in compliance with the ASME OM Code.

Corrective Actions: The licensee entered the condition into the corrective action program, performed preservice testing of the 1A and 1B control room chilled water pumps and established initial sets of reference values in accordance with the ASME OM Code, and completed an investigation.

Corrective Action References: ARs 415619, 415919, and 417741

Performance Assessment:

Performance Deficiency: The failure to perform required testing set forth in the ASME OM Code for the control room chilled water system 1A and 1B pumps was a performance deficiency.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Procedure Quality attribute of the Barrier Integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Specifically, the licensee did not perform preservice testing of the 1A and 1B CCH pumps as required by ASME OM Code, Paragraph ISTB-3100 Preservice Testing, before scoping the pumps into their IST program. This resulted in CCH operability surveillance procedures with inaccurate IST information that could not be used to determine the pumps met technical specification requirements.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The inspectors determined this finding is of very low safety significance (Green) because the finding did not represent a degradation of the radiological barrier function provided for the control room, auxiliary building, spent fuel pool, SBGT system (BWR), or EGTS system (PWR ice condenser) and did not represent a degradation of the barrier function of the control room against smoke or a toxic atmosphere.

Cross-Cutting Aspect: H.1 - Resources: Leaders ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. This finding had a cross-cutting aspect in the area of human performance, resources, in that the licensee did not ensure that personnel, equipment, procedures, and other resources are available and adequate to support nuclear safety. Specifically, the licensee did not understand the full scope of testing requirements required by the ASME Code and did not have adequate testing procedures available to support preservice testing.

Enforcement:

Violation: Title 10 CFR 50.55a(f), Preservice and inservice testing requirements, states, in part, that systems and components of boiling and pressurized water-cooled nuclear power reactors must meet the requirements for preservice and inservice testing (referred to in this paragraph

(f) collectively as inservice testing) of the ASME BPV Code and ASME OM Code. Subsection (4), Inservice testing standards requirement for operating plants, further states, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements set forth in the ASME OM Code and addenda. Paragraph ISTB-3100 of ASME OM Code 2004, 2006 Addenda, states, in part, before implementing inservice testing, an initial set of reference values shall be established for each pump. These tests shall be conducted under conditions as near as practicable to those expected during subsequent inservice testing

Contrary to the above, the licensee did not meet the requirements for preservice and inservice testing of the ASME OM Code, in that they did not establish an initial set of reference values for each pump before implementing inservice testing, and did not conduct these tests under conditions as near as practicable to those expected during subsequent inservice testing. Specifically, the licensee did not perform preservice testing of the 1A and 1B control room chilled water (CCH) pumps as required by ASME OM Code, Paragraph ISTB-3100 Preservice Testing, before scoping the pumps into their IST program. This resulted in CCH operability surveillance procedures with inaccurate IST information that could not be used to determine the pumps met technical specification requirements.

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

EXIT MEETINGS AND DEBRIEFS

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

• On February 18, 2021, the inspectors presented the triennial heat sink inspection results to R. Shultz, Site Vice President and other members of the licensee staff.

• On April 15, 2021, the inspectors presented the integrated inspection results to Mr. A.

Javorik, Site Vice President, Engineering Projects, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71111.01

Calculations

CE-02-13-18

Probable Maximum Flood Analysis for Columbia Generating

Station

000

CE-02-13-22

Effects of Local Intense Probable Maximum Precipitation

Analysis for Columbia Generating Station

000

ME-02-92-41

Calculation for Ultimate Heat Sink Analysis

008

ME-02-92-43

Room Temperature Calculation for DG Building, Reactor

Building, Radwaste Building and Service Water

013

Corrective Action

Documents

Action Requests

(ARs)

403246, 404534, 415728, 396990, 025319, 400176,

389796

Miscellaneous

G02-16-143,

Columbia

Generating

Station, Docket

No. 50-397

Flooding Hazard

Reevaluation

Report

Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the

Near-term Task Force Review of Insights from the

Fukushima Dai-ichi Accident

MOT-HT-1-1

Freeze Protection Heat Trace

004

Procedures

4.840.A5

840.A5 Annunciator Panel Alarms

29

ABN-FLOODING

Flooding

2

ABN-WIND

Tornado/High Winds

034

SOP-

COLDWEATHER-

OPS

Cold Weather Operations

034, 035

SOP-

HOTWEATHER-

OPS

Hot Weather Operations

007

SOP-

WARMWEATHER-

OPS

Warm Weather Operations

016

71111.01

Work Orders

2135244

71111.04

Corrective Action

Documents

Action Requests

(ARs)

0415611

Drawings

M512-1

Flow Diagram Diesel Oil and Miscellaneous Systems Diesel

Generator Building

048

M512-4

Flow Diagram Diesel Oil and Miscellaneous Systems Diesel

Generator Building

015

M775

Flow Diagram Emergency Chilled Water Piping System

Control Room

29

Procedures

1.3.29

Locked Valve Checklist

087

OSP-CCH/IST-

M701

Control Room Emergency Chiller System A Operability

049

OSP-CCH/IST-

M702

Control Room Emergency Chiller System B Operability

047, 048

SOP-DG2-LU

Emergency Diesel Generator (Div 2) Valve and Power

Supply Lineup

007

SOP-DG2-START

Emergency Diesel Generator (Div 2) Start

031

SOP-DG2-STBY

Emergency Diesel Generator (Div 2) Standby Lineup

23

SOP-DG3-LU

High Pressure Core Spray Diesel Generator Valve and

Power Supply Lineup

009

SOP-DG3-STBY

High Pressure Core Spray Diesel Generator Standby

Lineup

20

SOP-HVAC/CR-

LU

Control, Cable, and Critical Switchgear Rooms HVAC

Lineup

001

SOP-SW-LU

Standby Service Water System Valve and Breaker Lineup

014

Work Orders

2172385

71111.05

Calculations

FP-02-85-03

Combustible Loading Calculation

011

Fire Plans

PFP-DG-

BUILDING

Diesel Generator Building

004

PFP-RW-525

Radwaste 525

006

Procedures

1.3.10

Plant Fire Protection Program Implementation

036

1.3.10A

Control of Ignition Sources

017

1.3.10C

Control of Combustibles

2

71111.06

Corrective Action

Documents

Action Requests

(ARs)

417530, 417568, 417604, 417615, 417852

Drawings

E823

Manhole Print Underground Duct Banks Plans and Profiles

27

Sheet 1

Miscellaneous

Video of E-MH-E15 Inspection

03/31/2021

BIP 20-0559

Barrier Impairment Permit for E-MH-E11 30 east of bldg. 88

(north end)

03/25/2021

BIP 20-0560

Barrier Impairment Permit for E-MH-E13 60 east of bldg. 88

(north end)

03/25/2021

BIP 20-0561

Barrier Impairment Permit for E-MH-E15 east of bldg. 88

03/25/2021

BIP 21-0097

Barrier Impairment Permit for E-MH-E15 east of bldg. 88

03/31/2021

Procedures

1.3.57

Barrier Impairment

040

Work Orders

2139272

71111.07T

Calculations

ME-02-05-05

Calculation for Projecting RHR Heat Exchanger Thermal

Performance

000

ME-02-09-03

Test Data Evaluation and Uncertainty Analysis for the RHR

Heat Exchangers

04/21/2009

ME-02-85-70

Seal Coolers for RHR-P-2A, 2B, and 2C

000

ME-02-92-41

Calculation for Ultimate Heat Sink Analysis

007

ME-02-92-43

Room Temperature Calculation for DG Building, Reactor

Building, Radwaste Building and Service Water

013

ME-02-96-03

Potential Effect of SW Fouling on RHR Seal Cooler

Performance

000

Corrective Action

Documents

Action Requests

(ARs)

387462, 404282, 372892, 387484, 240323, 385702,

399102, 398565, 392171, 413335, 412987

Drawings

CVI DWG 215-11

Seal Injection Water Coolers

006

M524-1

Flow Diagram Standby Service Water System Reactor,

Radwaste, D.G. Buildings and Yard

140

M587

General Arrangement Plan and Section Diesel Generator

Building

040

M777

Composite Piping Plans at EL.441'-0", 455'-0", 472'-9"

Diesel Generator Building

054

M778

Composite Piping Sections and Details Diesel Generator

Building

041

Engineering

Changes

EC 17500

Minimum Wall Thickness Requirement for RHR-HX-2A

2

EC14774

Replace RHR-P-2A

007

Miscellaneous

Columbia Generating Station Service Water Reliability

Program

004

AED SPC 15F.2

Design Specification for Division 15 Section 15F.2 Essential

2

Fan Coil Units

AED SPC 309

Design Basis Document Division 300 Section 309 - Standby

Service Water System

018

AED SPC 310

Design Basis Document Standby Power Systems

015

DCW-HX-1C

Plugged Tubes

List

DCW-HX-1C Plugged Tubes List

000

DCW-HX-1C

Plugged Tubes

Map

DCW-HX-1C Plugged Tubes Map

000

Procedures

1.5.11

Maintenance Rule Program

015

2.14.1

Chemical Treatment of Standby Service Water

20

4.820.B1

20.B1 Annunciator Panel Alarms

041

ABN-SW

Service Water Trouble

015

SOP-SW-DRAIN

Standby Service Water Drain

008

SOP-SW-FILL

Standby Service Water System Fill

007

SOP-SW-OPS

Standby Service Water Operations

009

SWP-CHE-02

Chemical Process Management and Control

030

SYS-4-23

Maintenance Rule Structural Baseline Inspections

001

Self-Assessments 404096

Self-assessment is to assess Columbias performance in

the area of Service Water Reliability and GL 89-13 in

preparation for the triennial NRC ultimate heat sink

inspection

10/01/2020

Work Orders

2100975, 02117561, 02134259, 02131491, 02131518,

2103774, 02077068, 02111141, 02076064, 29135328,

2041703, 02076064, 02134638, 02134639, 02134640,

2143199, 02143200, 02143201, 02163358, 02136601,

2085391, 02085671, 02114521, 02134951, 02145562,

2165498, 02100975, 02117561, 02095968, 02135019,

2147556, 02147572, 02111141, 02128173, 01178727,

29135328, 29151758

71111.11Q Corrective Action

Documents

Action Requests

(ARs)

0415789

Miscellaneous

LR002510

Columbia Generating Station Simulator Cycle 21-1

Evaluated Scenario

Procedures

13.1.1

Classifying the Emergency

049

3.2.6

Power Maneuvering

015

3.3.1

Reactor Scram

066

5.1.1

RPV Control

2

5.1.2

RPV Control - ATWS

26

5.5.11

Alternate Control Rod Insertions

010

9.3.12

Plant Power Maneuvering

037

9.3.9

Control Rod Withdrawal Sequence Development and

Control

030

ABN-CORE

Unplanned Core Operating Conditions

018

OI-09

Operations Standards and Expectations

079

OSP-CRD-M704

Control Rod Exercise (week 4)

000

SOP-CR-

MOVEMENT

Control Rod Movement

004, 005

Work Orders

2146078

71111.12

Corrective Action

Documents

Action Requests

(ARs)

404914, 415069, 415085, 415094, 415233, 415125,

417213, 417232, 417233, 417234, 417235, 417236,

417238, 417242, 417266, 417275, 417291, 417297,

417308, 417360, 417364, 417366, 417376, 417390,

417406, 417423, 417426, 417429, 417435, 417441,

417449, 417450, 417237, 417241

Miscellaneous

Commercial Grade Dedication Package for Continental

Rupture Discs

01/11/2021

ISP 20-0216

Ignition Source Permit for DG2 Room

03/17/2021

ISP 20-0217

Ignition Source Permit for DG2

01/20/2021

MOT-CHILL-1-1-

9.1

MOT for Chillers

010

Procedures

1.3.10A

Control of Ignition Sources

017

1.3.56

Conduct of Maintenance

2

1.3.64

Plant Clearance Order

044

1.5.11

Maintenance Rule Program

016

10.2.13

Approved Lubricants

077

10.20.19

Diesel Generator Alternative Refuel Cycle (2 Year & 4 Year)

Preventative Maintenance (Division 1 and 2)

010

ECP-DG2/INSP-

B101

Diesel Generator DG2 Electrical Inspection

20

OQAPD-01

Operational Quality Assurance Program Description

(EN-QA-004)

056

SWP-ENV-01

Refrigerant Compliance Program

005

SWP-INS-01

Quality Control Inspection and Peer Verification

008

SYS-4-31

System and Equipment Performance Monitoring and

Trending Program

2

WCI-2

Standard Operating Cycle Schedule Development

006

Work Orders

2136926, 02155988, 02165100, 02159685, 02152933,

2155807, 02128138, 02129026, 02127872, 02127930,

2127931, 02121189

71111.13

Corrective Action

Documents

Action Requests

(ARs)

2066, 412131, 414328, 414384, 414642, 415479,

415528, 415781, 414350, 417009, 398152

Miscellaneous

Paragon Snapshot of week of March 8

03/09/2021

Paragon Snapshot of week of March 15

03/15/2021

BIP 20-0471

Barrier Impairment Permit: ISP-MS-Q923 (Calibrate MS-

LIS-38A)

03/08/2021

Procedures

1.3.76

Integrated Risk Management

060

1.3.83

Protected Equipment Program

031, 032,

033

1.5.14

Risk Assessment and Management for

Maintenance/Surveillance Activities

043

OSP-ELEC-W102

Electrical Distribution Subsystem Breaker Alignment and

Power Availability Verification

2

SOP-ELEC-AC-

LU

AC Electrical Distribution System Breaker Lineup

077

SOP-HPCS-

INJECTION

HPCS RPV Injection

007

Work Orders

2163349, 02160962, 02162477, 02171486, 02172898,

2169318, 02120074, 02157617, 02163796, 02164284,

2151273, 02168694, 02129026, 02107861, 02153181

71111.15

Calculations

9.32.02

HVAC Control Room Emergency Chiller System

2

E/I-02-91-1096

Setting Range Determination for Instrument Loop DCW-TS-

000

ME-02-92-43

Room Temperature Calculation for DG Building, Reactor

Building, Radwaste Building and Service Water

013

Corrective Action

Action Requests

415639, 415798, 415855, 415892, 415935, 416136,

Documents

(ARs)

415566, 413121, 414214, 396335

Drawings

EWD-7E-004C

High Pressure Core Spray System HPCS Diesel Engine

DG-ENG-1C Controls

004

EWD-7E-005C

High Pressure Core Spray System HPCS Diesel Engine

DG-ENG-1C Controls

005

M775

Flow Diagram: Emergency Chilled Water Piping System

Control Room

29, 030

Engineering

Changes

16619

Credit CCH for MCR Equipment Operability

2

Engineering

Evaluations

Failure Evaluation

Failure Evaluation of Aux contact from WMA-42-8F2C

Miscellaneous

AED SPC 309

Design Basis Document Division 300 Section 309 - Standby

Service Water System

018

Procedures

1.10.11

Technical Assessments Supporting Reportability and

Reportability Evaluations

2

1.3.66

Operability Determination

036, 037

OSP-CCH/IST-

M701

Control Room Emergency Chiller System A Operability

047, 048,

049, 050,

051, 052

OSP-CCH/IST-

M702

Control Room Emergency Chiller System B Operability

045, 046,

047, 048,

049

OSP-SW-M101

Standby Service Water Loop A Valve Position Verification

043, 044

OSP-SW-M102

Standby Service Water Loop B Valve Position Verification

044, 045

Work Orders

2159687, 02139086, 02120123, 02134259

71111.18

Calculations

8.42.0241

Pipe Stress Analysis CCH A Piping

003

Corrective Action

Documents

Action Requests

(ARs)

415249, 408430

Drawings

215-00,14008,1

Chilled Water Surge Pipe to CCH-P-1A

005

M775

Flow Diagram Emergency Chilled Water Piping System

Control Room

29

Engineering

Changes

16619

CCH-V-14A Replacement Check Valve

2A.FCR

16619

Credit CCH for MCR Equipment Operability

2

18415

TMOD Remove SM-1 UV Relay E-RLY-27/1

000

Miscellaneous

5059EVAL-18-

0002

EC 16619

000

696-00,4

Vendor Manual Y-type Check Valve with Soft Mainseat

2

SPC 1

Design Specification for Division 100, Section 1, ASME

Piping Systems

24

Procedures

1.3.30

Repair, Replacement, and Alteration of ASME Items

29

1.3.9

Temporary Modifications

057

10.2.28

Installation, Modification and Inspection of Piping Systems

23

10.25.23

Testing and Setting Time Voltage Relays

016

DES-2-15

Engineering Change Revisions

013

ENG-DES-50

Interface Procedure for IP-ENG-001 Standard Design

Process

2

IP-ENG-001

Standard Design Process

2

Work Orders

2173116, 02164829

71111.19

Corrective Action

Documents

Action Requests

(ARs)

415125, 415249, 415251, 415253, 415254, 415264,

415385, 415428, 415448, 415426, 415443, 415619,

415639, 415640, 415566, 415784, 417360, 417364

Procedures

1.3.16

Issue Management

2

10.20.19

Diesel Generator Alternative Refuel Cycle (2 Year & 4 Year)

Preventative Maintenance (Division 1 and 2)

010

10.25.207

Testing and Setting Agastat 7000 Series and Agastat ETR

Series Time Delay Relays

007

ECP-DG2/INSP-

B101

Diesel Generator DG2 Electrical Inspection

20

MI-1.22

Maintenance Planning Program

25

OSP-CCH/IST-

M701

Control Room Emergency Chiller System A Operability

048, 049

OSP-CCH/IST-

M702

Control Room Emergency Chiller System B Operability

046, 047,

048

OSP-DO-Q703

DO-P-2 Operability

001

OSP-ELEC-M102

DO-TK-3B Operability Test

005

OSP-ELEC-S703

HPCS Diesel Generator Semi-Annual Operability Test

064

OSP-LPCS/IST-

Q702

LPCS System Operability Test

045

OSP-SW/IST-

Q701

Standby Service Water Loop A Operability

2

QAP-ASU-07

Peer Verification Program Planning

006

SWP-TST-01

Post Maintenance Testing Program

017

TSP-DG2-B502

Standby Diesel Generator DG2 Load Testing

26

Work Orders

2163484, 02136926, 02159685, 02152933, 02159687,

2138414, 02160255, 02168523, 02153328, 02150242,

2152214, 02152211, 02139086, 02128619, 02143355,

2155806, 02157633, 02157844, 02153328, 02167414,

2153540, 02155511, 02165185, 02138671, 02129026,

2127872, 02121189, 02176181, 02168090

71111.22

Corrective Action

Documents

Action Requests

(ARs)

414973, 416341, 416689, 416475, 416474

Miscellaneous

Reactivity Control Plan, Rod Set

2/13/2021

Control Rod Withdrawal Deviation Sheet, pages 28, 29, 30

and 31

2/20/2021

NRC Information Notice 2020-02

FLEX Diesel Generator Operational Challenges

09/15/2020

Procedures

1.5.1

Surveillance Testing Program

045

ISP-SGT-B101

Standby Gas Treatment - System A - Flow and Filter

Pressure Drop Test

007

OSP-CRD-C703

Control Rod Settle Time Test

2

OSP-FLEX-Q704

Diesel Generator 4 Quarterly Surveillance

000

OSP-SLC/IST-

Q701

Standby Liquid Control Pumps Operability Test

29

71111.22

Procedures

SOP-DG4-

SHUTDOWN

Diesel Generator 4 Shutdown

003

SOP-DG4-START

Diesel Generator 4 Start

010

SOP-DG4-STBY

Diesel Generator 4 Standby

2

Work Orders

2136245, 02163210, 02163209, 02158719, 02126801,

2123201, 02168152

71114.06

Corrective Action

Documents

Action Requests

(ARs)

416984, 416986, 416996

Miscellaneous

Columbia Generating Station ERO Team C Drill Report:

March 9, 2021 After Action Report / Improvement Plan

000

Procedures

13.1.1

Classifying the Emergency

049

13.1.1A

Classifying the Emergency - Technical Bases

034

13.10.2

TSC Manager Duties

035

13.10.9

Operations Support Center Manager and Staff Duties

050

13.11.1

EOF Manager Duties

044

13.11.12

EOF Engineering Manager and Staff Duties

2

13.11.2

Assistant EOF Manager Duties

010

13.11.3

Site Support Manager and Staff Duties

033

71151

Corrective Action

Documents

Action Requests

(ARs)

403173, 404225, 404429, 407724, 412859, 416468

Miscellaneous

Operations Logs

01/01/2020 -

2/31/2020

Operational Decision Making Issue Evaluation

2, 003,

004, 005

Timeline and Discussion of Second Turbine Balance Shot in

June 2020 White Paper

03/08/2021

Procedures

1.10.10

Consolidated Data Entry Process Description

008

ABN-FWH-

HILEVEL/TRIP

Feedwater Heater High Level Trip

007

ABN-POWER

Unplanned Reactor Power Change

016

Work Orders

2147004, 02145898

71152

Corrective Action

Documents

Action Requests

(ARs)

415619, 415795, 415640, 415892, 415919, 415955,

419957, 419958, 415999, 409590, 409591, 409937,

2066, 412131, 412465, 414328, 414384, 414642,

415308, 415383, 415384, 415575, 417741

Drawings

EWD-46E-252

Electrical Wiring Diagram AC Electrical Distribution System

Power Panel E=PP-8AF

21

Engineering

Changes

16619

Credit CCH for MCR Equipment Operability

2

Miscellaneous

FA-PR20001875-1 Failure Analysis Report for Regulating Transformers SOLA

P/N 63-28-315-8

000

IST-4

Inservice Testing Program Plan Fourth Ten-Year Inspection

Interval

004, 005

Procedures

18.1.19

CCH-P-1A Pre-service Test

000, 001

18.1.21

CCH-P-1B Pre-service Test

000

SOP-ELEC-AC-LU AC Electrical Distribution System Breaker Lineup

077

Work Orders

2167660, 02171486, 02157840