IR 05000397/2011007

Columbia Generating Station - NRC Temporary Instruction 2515/183 Inspection Report 05000397/2011007

ML11133A202
Person / Time
Site:	Columbia
Issue date:	05/13/2011
From:	Walker W C NRC/RGN-IV/DRP/RPB-A
To:	Reddeman M E Energy Northwest
References
IR-11-007
Download: ML11133A202 (20)

Text

May 13, 2011

Mr. Chief Executive Officer Energy Northwest P.O. Box 968, Mail Drop 1023 Richland, WA 99352-0968

SUBJECT: COLUMBIA GENERATING STATION NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000397/2011007

Dear Mr. Reddemann:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Follow-up to the documents the inspection results which were discussed on May 2, 2011, with Mr. and other members of your staff. The objective of this inspection was to assess the adequacy of actions taken at Columbia Generating Station in response to the Fukushima Daiichi Nuclear Station fuel damage event. The results from this inspection, along with the results from similar inspections at other operating commercial nuclear plants in the United States, will be used to evaluate the United States the NRC to determine if additional regulatory actions are warranted. All of the potential issues and observations identified by this inspection are contained in this they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter. In its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Energy Northwest - 2 -

Sincerely,/RA/ By David L. Proulx Wayne Walker, Chief Project Branch A Division of Reactor Projects Docket: 50-397 License: NPF-21

Enclosure:

NRC Inspection Report 05000397/2011007

w/Attachment:

Supplemental Information cc w/Encl: Distribution via ListServ Energy Northwest - 3 - Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Art.Howell@nrc.gov) DRP Director (Kriss.Kennedy@nrc.gov) DRP Deputy Director (Troy.Pruett@nrc.gov) DRS Director (Anton.Vegel@nrc.gov) DRS Deputy Director (Vacant) Senior Resident Inspector (Ronald.Cohen@nrc.gov) Resident Inspector (Mahdi.Hayes@nrc.gov) Branch Chief, DRP/A (Wayne.Walker@nrc.gov) Senior Project Engineer, DRP/A (David.Proulx@nrc.gov) Site Administrative Assistant (Crystal.Myers@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov) Project Manager (Balwant.Singal@nrc.gov) Branch Chief, DRS/TSB (Michael.Hay@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov) Regional Counsel (Karla.Fuller@nrc.gov) NRR/DIRS/IRIB (Timothy.Kobetz@nrc.gov) Congressional Affairs Officer (Jenny.Weil@nrc.gov) OEMail Resource ROPreports RIV/ETA:OEDO (Stephanie.Bush-Goddard@nrc.gov) DRS/TSB STA (Dale.Powers@nrc.gov) R:/_REACTORS/TI-183/CGS 2011-007TI WCW.DOCX ADAMS ML SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials DP Publicly Avail Yes No Sensitive Yes No Sens. Type Initials DP SRI:DRP/A RI:DRP/A RI:TSB D:DRP/A RCohen MHayes ERuesch WWalker DP for-E DP for E /RA/ DP for 05/12/2011 05/12/2011 05/11/2011 05/11/2011 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax Enclosure U. S. NUCLEAR REGULATORY COMMISSION REGION IV Docket 05000397 License NPF-21 Report 05000397/2011007 Licensee Energy Northwest Facility Columbia Generating Station Location Richland, WA Dates March 23, 2011 through April 29, 2011 Inspectors R. Cohen, Senior Resident Inspector M. Hayes, Resident Inspector Approved by Wayne Walker, Chief, Project Branch A Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000397/2011007, 03/23/2011 04/29/2011; Columbia Generating Station; Temporary Instruction 2515/183 - Follow-up to the Fukushima Daiichi Nuclear Station Fuel Damage Event. This report covers an announced temporary instruction inspection. The inspection was commercial nuclear power reactors is described in NUREG-Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the temporary instruction is to be a high-for events that may exceed the design basis for a plant. The focus of the temporary instruction capabilimitigate internal and external flooding events required by station design; and

(4) assessing the uipment needed to during seismic events possible for the site. If necessary, a more specific follow-up inspection will be performed at a later date.

INSPECTION RESULTS

The following table documents the NRC inspection at Columbia Generating Station, performed in accordance with Temporary Instruction 2515/183. The numbering system in the table corresponds to the inspection items in the temporary instruction.

bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.54(hh). Procedure 71111.05T was recently performed at the facility, the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to: Licensee Action Describe what the licensee did to test or inspect equipment. a. Verify through test or inspection that equipment is available and functional. Active equipment shall be tested and passive equipment shall be walked down and inspected. It is not expected that permanently installed equipment that is tested under an existing regulatory testing program be retested. This review should be done for a reasonable sample of mitigating strategies/equipment. The licensee tested active equipment, and walked down and inspected passive equipment. The licensee performed these activities in accordance with existing station procedures and preventative maintenance work orders. Some items were verified to be complete, if performed within the last month, through a review of completion paperwork; activities not accomplished within the last month were re-performed. Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, reviewed test results, discussed actions, reviewed records, etc.).

The inspectors reviewed the test results. The inspectors independently walked down the in accordance with station procedures. The inspectors discussed with plant and licensed operators how the active and passive equipment is tested, maintained, and stored, and training is conducted on its use. Additionally, the inspectors walked down several of the procedures with plant operators to ensure familiarity with the operation of the equipment, storage locations of portable equipment, and locations of permanently installed equipment.

Discuss general results including corrective actions by licensee. The licensee discovered several minor issues that did not affect the availability and function of equipment used to support B.5.b, the emergency plan, and severe accident management guidelines. These e action program. Licensee Action (e.g. walkdowns, demonstrations, tests, etc.). b. Verify through walkdowns or demonstration that procedures to implement the strategies associated with B.5.b and 10 CFR 50.54(hh) are in place and are executable. Licensees may choose not to connect or operate permanently installed equipment during this verification. This review should be done for a reasonable sample of mitigating strategies/equipment. The licensee performed a walkdown and reviewed the extreme damage mitigation guidelines and severe accident mitigation guidelines. The licensee concluded that the procedures were executable. Describe inspector actions and the sample strategies reviewed. Assess whether procedures were in place and could be used as intended. The inspector reviewed all the severe accident procedures and guidelines to ensure that the appropriate equipment, training, and staging were in place and those actions could be accomplished in accordance with the established timelines. The inspectors determined that cently trained on, and could be implemented as intended. The inspectors walked down several strategies with plant operators to ensure that the operators knew where the equipment was located, how to operate the equipment, and the ease of use of the equipment. Discuss general results including corrective actions by licensee. corrective action program.

Licensee Action operators and support staff. c. Verify the training and qualifications of operators and the support staff needed to implement the procedures and work instructions are current for activities related to Security Order Section B.5.b and severe accident management guidelines as required by 10 CFR 50.54 (hh). Plant operators receive initial training on these severe accident procedures through walkdowns with qualified operators, which are required prior to initial watch standing. Continuing training for plant operators, accomplished in accordance with the plant operator requalification program, includes classroom training and walkthroughs of procedures. Licensed operators receive initial training on these severe accident procedures along with all emergency and off-normal operating procedures as part of initial licensed operator qualification. Continuing training for licensed operators is accomplished in accordance with the licensed operator requalification program. The emergency response organization training requirements are proceduralized in the emergency preparedness training program. Personnel on the emergency response roster must complete requalification training. Security officers are trained and qualified in the requirements of B.5.b. Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff. The inspectors reviewed the training records of plant and licensed operators and of emergency response roster personnel to ensure that they were still within their training window. The inspectors walked down and discussed several strategies with plant and licensed operators to ensure that the operators knew where the equipment was located, how to operate the equipment, the ease of use of the equipment, and could complete the procedures as written.

Discuss general results including corrective actions by licensee. accomplished. The inspector identified no deficiencies during this review. Licensee Action regarding applicable agreements and contracts are in place. d. Verify that any applicable agreements and contracts are in place and are capable of meeting the conditions needed to mitigate the consequences of these events. This review should be done for a reasonable sample of mitigating strategies/equipment. The licensee reviewed its Letters of Agreement with state and local entities, required by Annually, in accordance licensee reviews the Letters of Agreement for each offsite organization and ensures that all letters are current. For a sample of mitigating strategies involving contracts or agreements with offsite entities, describe inspector actions to confirm agreements and contracts are in place and current (e.g., confirm that offsite fire assistance agreement is in place and current). be maintained current. Additionally, the inspectors reviewed a sample of Letters of Agreement for mutual aid and support and verified that they were current. Discuss general results including corrective actions by licensee. The licensee identified no deficiencies during this review. The inspectors verified that agreements and contracts are in place for mutual aid and support.

Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy. e. Review any open corrective action documents to assess problems with mitigating strategy implementation identified by the licensee. Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted. The licensee documented all items associated with the Fukushima event in Action Request 235848. The licensee identified the following discrepancies; procedure enhancements to provide more details related to equipment location and operation of equipment to enhance operator response time, evaluation of the storage of equipment that may be vulnerable to seismic activity, readability of fire main header gages, and the lack of spare parts for the B.5.b fire pump truck to address extended use. None of the identified gaps or deficiencies would be expected to impact the success of any severe accident mitigation capability. The inspectors reviewed these discrepancies and determined that the items identified in Action Request condition report 235848 would not impact the mitigating strategy implementation. -Plant Action Item A-Temporary Instruction 2515/120 be completely re-inspected. The inspection should include, but not be limited to, an assessment of any licensee actions to: Licensee Action Describe the station blackout event. a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained. The licensee performed inventories of Emergency Operating Procedure and Main Control Room Emergency supplies. Additionally, walkdowns were performed for procedures supporting response to a station blackout event. During these walkdowns, required equipment was verified to be functional and properly staged.

Describe inspector actions to verify equipment is available and useable.

Final Safety Analysis Report to understand the implementation and required equipment for station blackout and alternate ac source plant criteria. The inspectors walked down each standby diesel generator looking for deficiencies that might call into question the operability of the diesel. The inspectors reviewed the most recent surveillance test data for each diesel generator and the emergency locker inventory checklist. Additionally, the inspectors searched through the corrective action program database for items that could impact the operability of the standby diesel generators. Discuss general results including corrective actions by licensee. The licensee discovered several minor issues with the adequacy of properly staging required materials that did not affect the ability to implement and execute the strategies corrective action program. Licensee Action blackout event. b. Demonstrate through walkdowns that procedures for response to a station blackout are executable. The licensee walked down the station blackout procedure to ensure that all sections of the procedure could be completed. The licensee verified that the equipment necessary to execute the station blackout procedure was staged and ready for operation. Describe inspector actions to assess whether procedures were in place and could be used as intended. The inspectors performed several plant walkdowns, both independently and in conjunction readiness to execute the station blackout procedures.

Discuss general results including corrective actions by licensee. The licensee discovered several minor issues with the adequacy of station blackout procedures and equipment that did not affect the ability to implement and execute the strategies associated with station blackout. These minor issues were entered into the o Inspection Procedure 71111.01, verify through walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional. Licensee Action verify the capability to mitigate existing design basis flooding events. a. Verify through walkdowns and inspection that all required materials are adequate and properly staged, tested, and maintained. The licensee reviewed the Final Safety Analysis Report related to external flooding. Columbia Generating Station is considered a dry site because of its elevation. The licensee also reviewed the internal flooding design calculations, reviewed instrumentation, sump pump capabilities, and alarms used for detection of flooding to ensure they were functional. The licensee walked down flood seals and penetrations to ensure they were properly sealed and in good material condition. The licensee generated the population of seals and penetrations to inspect by reviewing civil (construction and architectural), and as built drawings.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended. The inspectors performed independent reviews of seal penetration inspection results. The inspectors reviewed to identify current issues with flooding mitigation equipment or barriers. The inspectors reviewed the Final Safety Analysis Report, internal flooding design calculations, and flood seal and penetration design program to ensure installed flood mitigation equipment was properly maintained. The inspectors reviewed the corrective action program to ensure the licensee had taken corrective action on issues that were identified during the walkdowns and reviews. Discuss general results including corrective actions by licensee. During this review, the licensee confirmed no mitigating actions were necessary for an external flood because of the plants elevation. The licensee verified that the preventive maintenance records for the flood penetration seals were current, and did not re-inspect them for this review. The licensee identified several minor deficiencies with adequacy of flood mitigation 3.04 Assess the thoroughness of the y new mitigating strategies for identified vulnerabilities (e.g., entered it into the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary) such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that Licensee Action availability of equipment used in fire and flooding mitigation strategies.

Verify through walkdowns that all required materials are adequate and properly staged, tested, and maintained. The licensee identified equipment that would be used for mitigation of fire and flooding events. The licensee determined whether this equipment was seismically qualified or if it could be evaluated as meeting the general building codes as applicable for the function of the equipment. All of the fire suppression systems were walked down by a qualified fire protection engineer, all of the fire protection program procedures were reviewed for any potential impacts/vulnerabilities, and all portable firefighting equipment was examined for any potential impacts.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended. The inspectors reviewed the Final Safety Analysis Report to identify equipment important to mitigate flooding mitigation procedures, including natural and destructive phenomena procedures. The inspavailable and usable and to ensure that the procedures could be accomplished as written. These walk downs included contingency response equipment, the fire protection system pumps, and the fire main headetesting the Security Order Section B.5.b pump truck.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee because of their reviews.

The inspectors verified that equipment was available and useable, and procedures needed to mitigate fire and flood events were in place, and could be used as intended. The licensee discovered several minor issues related to the impact of seismic events on equipment used in fire and flooding mitigation strategies. These minor issues were entered The licensee determined that the Emergency Response Facilities, the Tower Makeup, system, and the fire protection systems, were not seismically qualified, but met the design requirements of the Uniform Building and National Fire Protection Association codes. Floor drain isolation valves and sump level switches (used to mitigate internal flooding) were not seismically qualified.

EXIT MEETING SUMMARY The inspectors presented the inspection results to Mr. M. Reddemann and other members of licensee management at the conclusion of the inspection on May 2, 2011. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Bekhazi, Maintenance Manager

D. Brown, Operations Manager

K. Christianson, Acting Licensing Supervisor

R. Garcia, Licensing Engineer

D. Gregoire, Acting Regulatory Affairs Manager

C. King, Assistant, Plant General Manager

B. MacKissock, Plant General Manager

D. Mand, Design Engineering Manager

B. Sawatzke, Chief Nuclear Officer

D. Swank, Engineering General Manager

P. Taylor, Operations Training Manager

S. Wood, Organizational Effectiveness Manager

LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report.

DOCUMENTS NUMBER DESCRIPTION OR TITLE REVISION/DATE

ABN-CONT-VENT 2

ABN-ASH FALL 15

ABN-FLOODING 10

ABN-AIRBORNE-ATTACK 7

ABN-TSG-007 3

KADLEC HOSPITAL AGREEMENT March 25, 2011

KENNEWICK GENERAL HOSPITAL AGREEMENT March 25, 2011

LOURDES MEDICAL CENTER AGREEMENT March 25, 2011

BENTON COUNTY AGREEMENT March 24, 2011

Attachment DOCUMENTS NUMBER DESCRIPTION OR TITLE REVISION/DATE

FRANKLIN COUNTY AGREEMENT March 22, 2011

WASHINGTON STATE AGREEMENT March 28, 2011

OREGON STATE AGREEMENT March 25, 2011

AREVA AGREEMENT March 25, 2011

DEPARTMENT OF ENERGY, RICHLAND SITE AGREEMENT March 25, 2011

HANFORD FIRE AGREEMENT March 29, 2011

FEMA AGREEMENT March 23, 2011

FSAR : 1.2.7 EOP/SAG PROGRAM MAINTENANCE 7 5.0.9 EOP/SAG REVISION 7

ABN-CR-EVAC CONTROL ROOM EVACUATION AND REMOTE COOLDOWN 18

ABN-FPC-LOSS LOSS OF FUEL POOL COOLING 5

OI-57 OPERATIONS DEPARTMENT ATTENDANCE STANDARDS AND EXPECTATIONS 2 PPM 5.5.3 FIREWATER TO CONDENSATE CROSSTIE 8

CONDITION REPORTS

235030

236006

236015

236015

236030

236035

236045

236047

236052

236054

236058

236064

236067

236071

236157

236202

236202

236204

ACTION REQUEST

235848

Attachment 03.02 design basis events

DOCUMENTS NUMBER DESCRIPTION OR TITLE REVISION

ABN-FLOODING 10

ABN-FIRE 21

SOP-CAS-OPS CONTROL AND SERVICE AIR OPERATION 10

ABN-ELEC-DG3-CROSSTIE/SM7 5

ABN-ELEC-DG3-CROSSTIE/SM8 5

ABN-ELEC-LOOP 11

FSAR

OSP-ELEC-C701 DIESEL GENERATOR 1

AC SOURCE OPERABILITY CHECK 12

OSP-ELEC-C702 DIESEL GENERATOR 2

AC SOURCE OPERABILITY CHECK 11

OSP-ELEC-C703 HPCS DIESEL GENERATOR AC SOURCE OPERABILITY CHECK 12 PPM 5.5.27 REACTOR BUILDING 422 MAX SAFE OPERATING WATER LEVEL MEASUREMENT 4 PPM 5.5.3 FIREWATER TO CONDENSATE CROSSTIE 8 PPM 5.6.1 STATION BLACKOUT 14

CONDITION REPORTS

236030

236035

236054

236064

236067

236157

236202

236204

236618

ACTION REQUEST

235848

Attachment 03.03 required by station design

MISCELLANEOUS

NUMBER DESCRIPTION OR TITLE REVISION

ABN-FLOODING FSAR 10

CONDITION REPORTS

236841

236936

236939

237009

237071

237077

237084

237142

237212

237217

237218

237290

ACTION REQUEST

235848

03.04 Assess important equipment needed to mitigate fire and flood events to identify the

MISCELLENAOUS NUMBER DESCRIPTION OR TITLE REVISION

ABN-EARTHQUAKE 5

ABN-FLOODING 10

ABN-FIRE 21

FSAR : 15.4.6 ESSENTIAL FIRE RATED PENETRATION SEAL AND ESSENTIAL FIRE AND FLOOD BARRIER OPERABILITY INSPECTION 8

ACTION REQUEST

235848