IR 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:
Report Number:
Enterprise Identifier: I-2021-001-0004
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.
REACTOR SAFETY
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
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-
Cold Weather Operations
034, 035
SOP-
HOTWEATHER-
Hot Weather Operations
007
SOP-
WARMWEATHER-
Warm Weather Operations
016
Work Orders
2135244
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
Calculations
FP-02-85-03
Combustible Loading Calculation
011
Fire Plans
PFP-DG-
BUILDING
Diesel Generator Building
004
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
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
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
Minimum Wall Thickness Requirement for RHR-HX-2A
2
Replace RHR-P-2A
007
Miscellaneous
Columbia Generating Station Service Water Reliability
Program
004
Design Specification for Division 15 Section 15F.2 Essential
2
Fan Coil Units
Design Basis Document Division 300 Section 309 - Standby
Service Water System
018
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
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
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
Control Rod Exercise (week 4)
000
SOP-CR-
MOVEMENT
Control Rod Movement
004, 005
Work Orders
2146078
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
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
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
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
Electrical Distribution Subsystem Breaker Alignment and
Power Availability Verification
2
SOP-ELEC-AC-
LU
AC Electrical Distribution System Breaker Lineup
077
SOP-HPCS-
INJECTION
007
Work Orders
2163349, 02160962, 02162477, 02171486, 02172898,
2169318, 02120074, 02157617, 02163796, 02164284,
2151273, 02168694, 02129026, 02107861, 02153181
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
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
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
Standby Service Water Loop A Valve Position Verification
043, 044
Standby Service Water Loop B Valve Position Verification
044, 045
Work Orders
2159687, 02139086, 02120123, 02134259
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
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
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
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
DO-P-2 Operability
001
DO-TK-3B Operability Test
005
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
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
Standby Gas Treatment - System A - Flow and Filter
Pressure Drop Test
007
Control Rod Settle Time Test
2
Diesel Generator 4 Quarterly Surveillance
000
OSP-SLC/IST-
Q701
Standby Liquid Control Pumps Operability Test
29
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
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
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