ML111300570

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IR 05000397-11-002; 01/01/2011 - 03/26/2011; Columbia Generating Station, Integrated Resident and Regional Report; Postmaintenance Testing, Identification and Resolution of Problems
ML111300570
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 05/10/2011
From: Webb Patricia Walker
NRC/RGN-IV/DRP/RPB-A
To: Reddemann M
Energy Northwest
References
IR-11-002
Download: ML111300570 (33)


See also: IR 05000397/2011002

Text

May 10, 2011 Mr. M.E. Reddemann

Chief Executive Officer

Energy Northwest

P.O. Box 968, Mail Drop 1023

Richland, WA 99352

-0968 Subject: COLUMBIA GENERATING STATION

- NRC INTEGRATED INSPECTION REPORT NUMBER 05000 397/2011002 Dear Mr. Reddemann

On March 26, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Columbia Generating Station. The enclosed integrated inspection report documents the

inspection findings, which were discussed on March 31, 2011, with yourself, and other members of your staff.

The inspections examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, the

NRC has determined that

one Severity Level IV violation of NRC requirements occurred.

The NRC has also identified one NRC identified issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The NRC has determined that a violation is

associated with this issue

. However, because of the very low safety significance and because they were entered into your

corrective action program, the NRC is treating these findings as noncited violations , consistent with Section

2.3.2.a of the NRC Enforcement Policy.

If you contest the violation or the significance of the noncited violation, you should provide a response within 30

days of the date of this inspection report, with the basis for your denial, t

o the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555-0001, with copies to the Regional Administrator, U.S.

Nuclear Regulatory Commission, Region IV, 612 E. Lamar Blvd, Suite

400, Arlington, Texas, 76011

-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555

-0001; and the NRC Resident Inspector at the

facility. In addition, if you disagree with the cross

-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at the facility

. U N I T E D S T A T E S N U C L E A R R E G U L A T O R Y C O M M I S S I O N R E G I O N I V 6 12 EAST LAMAR BLVD

, S U I T E 4 0 0 A R L I N G T O N , T E X A S 7 6 0 1 1-4125

Energy Northwest

- 2 - In accordance with 10 CFR 2.390 of the NRC's "Rules of

Practice," a copy of this letter, its enclosure, and your response, if you choose to provide one for cases where a response is not required, will be made available electronically for public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading

-rm/adams.html

. To the extent possible, your response should not include any personal, privacy or proprietary information so that it can be made available to the Public without redaction.

Sincerely, /RA/ Wayne C. Walker, Chief Project Branch

A Division of Reactor Projects

Docket:

50-397 License: NPF-21 Enclosure:

NRC Inspection Report 05000 397/2011002 w/Attachment: Supplemental Information

cc: Distribution via ListServ for Columbia Generating Station

- 1 - Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION IV Docket: 05000 397 License: NPF-21 Report: 05000 397/2011002 Licensee: Energy Northwest

Facility: Columbia Generating Station

Location: Richland, WA

Dates: January 1, 2011

through March 26, 2011

Inspectors:

R. Cohen, Senior Resident Inspector

M. Hayes, Resident Inspector

B. Larson, Senior Operations Engineer

D. Strickland, Operations Engineer

Approved By:

W. Walker, Chief, Project Branch

A Division of Reactor Projects

- 2 - Enclosure SUMMARY OF FINDINGS

IR 05000 397/2011002; 01/01/2011

- 03/26/2011

Columbia Generating Station, Integrated Resident and Regional Report
Postmaintenance Testing, Identification and Resolution of Problems The report covered a 3

-month period of inspection by resident inspectors and announced baseline inspection

s by region-based inspector s. One Green noncited violation

of significance and one Severity Level IV violation were

identified.

The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance

Determination Process." The cross-cutting aspect is determined using Inspection Manual Chapter 0310, "Components Within the Cross

-Cutting Areas." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG

-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A. NRC-Identified Findings and Self

-Revealing Findings

Cornerstone: Mitigating Systems

Green. The inspectors identified a noncited violation of 10 CFR Part 50 Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the

licensee's failure to consider the impact of preconditioning on the emergency core cooling systems during maintenance. Specifically, licensee personnel failed to consider the impact of scheduling keep fill pump maintenance prior to technical specification required surveillance testing. Licensee personnel reviewed three years worth of data on the emergency core cooling systems to ensure there was no degrading performance trend. This issue was placed in the licensee's corrective action program as Action Request/Condition Report 23 6880. The performance deficiency was more than minor because it affected the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the reliability of systems that respond to initiating events. Using

Inspection Manual Chapter 0609.04, Phase 1

- "Initial Screening and Characterization of Findings," the inspectors determined that this performance

deficiency was of very low safety significance because this finding was confirmed to not result in a loss of operability

for the emergency core cooling systems.

Th e inspectors identified a cross

-cutting issue in the area of human performance, work practices, because the licensee failed to effectively communicate expectations regarding procedural compliance

H.4.b] (Section 1R19). Cornerstone: Miscellaneous

Severity Level IV. The inspectors identified a Severity Level IV violation of 10 CFR 50.72(b)(3)(v)(D) for the failure of the licensee to make a non

-emergency

- 3 - Enclosure event notification to the NRC. Specifically, on December

20, 2010 , the licensee failed to report the low pressure core spray minimum flow valve failing to open on pump start, rendering the low pressure core spray system incapable of performing

its specified safety function during testing. The licensee made Event Notification 46604 on February 8, 2011, to report the identified condition. As a corrective action the licensee has informed all current shift managers, and plans to train future senior reactor operators, of the expectation to evaluate low pressure core spray system failures as a failure of a single train system to complete a safety function. This violation has been placed in the licensee's corrective action program as Action Request/Condition Report

23 6879. The performance deficiency was more than minor because the NRC relies on licensees to identify

and report conditions or events meeting the criteria specified in the regulations in order to perform its regulatory function. The inspectors determined that this finding was not appropriate to evaluate using the Significance Determination Process due to the finding only affecting the NRC's ability to perform its regulatory oversight function. As a result, this finding was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This finding was determined to be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated September 30, 2010. The inspectors determined that assigning a cross

-cutting aspect was not applicable to this finding due to the finding being screened

exclusively using the traditional enforcement process (Section 4OA2).

B. Licensee-Identified Violations

None

- 4 - Enclosure REPORT DETAILS

Summary of Plant Status

The plant began the inspection period at

100 percent power. The plant remained at 100 percent power for the remainder of the inspection period except for planned power reductions to support maintenance and testing.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, and Emergency Preparedness

1R01 Adverse Weather Protection (71111.01)

Readiness for Seasonal Extreme Weather Conditions

a. The inspectors performed a review of the adverse weather procedures for seasonal extremes (e.g., extreme high temperatures, extreme low temperatures, or hurricane season preparations). The inspectors verified that weather

-related equipment deficiencies identified during the previous year were corrected prior to the onset of

seasonal extremes

, and evaluated the implementation of the adverse weather preparation procedures and compensatory measures for the affected conditions before the onset of, and during, the adverse weather conditions.

Inspection Scope

During the inspection, the inspectors focused on plant

-specific design features and the procedures used by plant personnel to mitigate or respond to adverse weather conditions. Additionally, the inspectors reviewed the FSAR and performance requirements for systems selected for inspection, and verified that operator actions were appropriate as specified by plant

-specific procedures. Specific documents reviewed during this inspection are listed in the attachment. The inspectors also reviewed corrective action program items to verify that plant personnel

were identifying adverse weather issues at an appropriate threshold and entering them into their corrective action

program in accordance with station corrective action procedures. The inspectors' reviews focused specifically on the following plant systems:

February 25, 2011, diesel generator rooms, service water pump houses and circulating water pump houses

due to extreme low temperatures being forecasted for the day

These activities constitute completion of one readiness for seasonal adverse weather sample as defined in Inspection Procedure

71111.01-05. b. No findings were identified.

Findings

- 5 - Enclosure 1R04 Equipment Alignments (71111.04)

Partial Walkdown

a. The inspectors performed partial system walkdowns of the following risk

-significant systems: Inspection Scope

January 5, 2011, residual heat removal system C

February 14, 2011, diesel generator 1

The inspectors selected these systems based on their risk significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors attempted to identify any discrepancies that could affect the function of the system, and, therefore, potentially increase risk. The inspectors reviewed applicable operating procedures, system diagrams, FSAR, technical specification requirements, administrative technical specifications, outstanding work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have rendered the systems incapable of performing their intended functions. The inspectors also inspected accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The

inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no obvious deficiencies. The inspectors also verified that the licensee had properly identified and resolved equipment alignment problems that could cause initiating events or impact the capability of

mitigating systems or barriers and entered them into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of two partial system walkdown sample

s as defined in Inspection Procedure

71111.04-05. b. No findings were identified.

Findings 1R05 Fire Protection (71111.05)

Quarterly Fire Inspection Tours

a. The inspectors conducted fire protection walkdowns that were focused on availability, accessibility, and the condition of firefighting equipment in the following risk

-significant plant areas:

Inspection Scope

- 6 - Enclosure January 6, 2011, fire area

RC-4, division 1 switch

gear room January 10, 2011, fire area R

-8/1, low pressure core spray pump room

January 12, 2011, fire area R

-1/1, reactor building 522' elevation northwest quadrant February 14, 2011, fire area

DG-2, division 1 diesel generator room

February 16, 2011, fire area R-5, residual heat removal pump 2A room

The inspectors reviewed areas to assess if licensee personnel had implemented a fire protection program that adequately controlled combustibles and ignition sources within the plant; effectively maintained fire detection and suppression capability; maintained passive fire protection features in good material condition; and had implemented adequate compensatory measures for out of service, degraded or inoperable fire protection equipment, systems, or features, in accordance with the licensee's fire plan. The inspectors selected fire areas based on their overall contribution to internal fire risk as documented in the plant's Individual Plant Examination of External Events with later additional insights, their potential to affect equipment that could initiate or mitigate a plant transient, or their impact on the plant's ability to respond to a security event. Using the documents listed in the attachment, the inspectors verified that fire hoses and extinguishers were in their designated locations and available for immediate use; that fire detectors and sprinklers were unobstructed

that transient material loading was within the analyzed limits; and fire doors, dampers, and penetration seals appeared to be in satisfactory condition. The inspectors also verified that minor issues identified during the inspection were entered into the licensee's corrective action program. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five quarterly fire

-protection inspection sample

s as defined in Inspection Procedure

71111.05-05. b. No findings were identified.

Findings 1R11 Licensed Operator Requalification Program (71111.11)

.1 Quarterly Review

a. On February 14, 2011, the inspectors observed a crew of licensed operators in the plant's simulator to verify that operator performance was adequate, evaluators were identifying and documenting crew performance problems, and training was being conducted in accordance with licensee procedures. The inspectors evaluated the following areas:

Inspection Scope

- 7 - Enclosure Licensed operator performance

Crew's clarity and formality of communications

Crew's ability to take timely actions in the conservative direction

Crew's prioritization, interpretation, and verification of annunciator alarms

Crew's correct use and implementation of abnormal and emergency procedures

Control board manipulations

Oversight and direction from supervisors

Crew's ability to identify and implement appropriate technical specification actions and emergency plan actions and notifications

The inspectors compared the crew's performance in these areas to preestablished operator action expectations and successful critical task completion requirements. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of one quarterly licensed

-operator requalification program sample as defined in Inspection Procedure

71111.11. b. No findings were identified.

Findings .2 Biennial Inspection (71111.11B)

The licensed operator requalification program involves two training cycles that are

conducted over a 2

-year period. In the first cycle, the annual cycle, the operators are administered an operating test consisting of job performance measures and simulator scenarios. In the second part of the training cycle, the biennial cycle, operators are administered an operating test and a comprehensive written examination.

a. Inspection Scope

To assess the performance effectiveness of the licensed operator requalification

program, the inspectors conducted personnel interviews, reviewed both the operating tests and written examinations, and observed ongoing operating test activities.

The inspectors interviewed four licensee personnel, consisting of instructors and training

management, to determine their understanding of the policies and practices for administering requalification examinations. The inspectors also reviewed operator performance on the written exams and operating tests. These reviews included observations of portions of the operating tests by the inspectors. The operating tests

- 8 - Enclosure observed included six job performance measures and three scenarios that were used in the current biennial requalification cycle. These observations allowed the inspectors to assess the licensee's effectiveness in conducting the operating test to ensure operator mastery of the training program content. The inspectors also reviewed medical records of six licensed operators for conformance to license conditions and the licensee's system for tracking qualifications and records of license reactivation for two operators.

The results of these examinations were reviewed to determine the effectiveness of the licensee's appraisal of operator performance and to determine if feedback of performance analyses into the requalification training program was being accomplished.

The inspectors interviewed members of the training department and reviewed six

Licensee Event Reports to assess the responsiveness of the licensed operator requalification program to incorporate the lessons learned from plant events. In addition,

the inspectors reviewed examination security measures, a sample of simulator performance test records (transient and steady

-state tests, malfunction tests, and scenario-based tests), simulator fidelity and existing logs of simulator deficiencies.

Examination results were assessed to determine if they were consistent with the guidance contained in NUREG

1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1, and NRC Manual Chapter 0609, Appendix I, "Operator Requalification Human Performance Significance Determination Process."

The inspectors completed one inspection sample of the biennial licensed operator requalification program.

b. Findings No findings were identified.

1R12 Maintenance Effectiveness (71111.12)

a. The inspectors evaluated degraded performance issues involving the following ris

k- significant systems:

Inspection Scope

February 22, 2011, TSP

-TURB-G001, "Turbine Overspeed Protection Valve Disassembly and Inspection" March 2, 2011, Action Request/Condition Report 234859, "CRD

-HCU-1843 scram outlet valve leaks by

" March 2, 2011, Review of 10 CFR 50.65(a)(3) evaluation

The inspectors reviewed events such as where ineffective equipment maintenance has resulted in valid or invalid automatic actuations of engineered safeguards systems and

- 9 - Enclosure independently verified the licensee's actions to address system performance or condition problems in terms of the following:

Implementing appropriate work practices

Identifying and addressing common cause failures

Scoping of systems in accordance with 10 CFR 50.65(b)

Characterizing

system reliability issues for performance

Charging unavailability for performance

Trending key parameters for condition monitoring

Ensuring proper classification in accordance with 10

CFR 50.65(a)(1) or

-(a)(2) Verifying appropriate performance criteria for structures, systems, and components classified as having an adequate demonstration of performance through preventive maintenance, as described in 10 CFR 50.65(a)(2), or as requiring the establishment of appropriate and adequate goals and corrective actions for systems classified as not having adequate performance, as described in 10 CFR 50.65(a)(1)

The inspectors assessed performance issues with respect to the reliability, availability, and condition monitoring of the system. In addition, the

inspectors verified maintenance effectiveness issues were entered into the corrective action program with the appropriate significance characterization. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three quarterly maintenance effectiveness sample s as defined in Inspection Procedure

71111.12-05. b. No findings were identified.

Findings

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. The inspectors reviewed licensee personnel's evaluation and management of plant risk for the maintenance and emergent work activities affecting risk

-significant and safety

-related equipment listed below to verify that the appropriate risk assessments were

performed prior to removing equipment for work:

Inspection Scope

- 10 - Enclosure February 3, 2011, Action Request 233580, "500 KV Relay Set 1 Spurious Trip Tone Signals" March 1, 2011, Yellow risk due to I&C testing and removal of the 500 KV north bus from service

March 7, 2011, Yellow

risk due to stator cooling water pump maintenance

The inspectors selected these activities based on potential risk significance relative to

the reactor safety cornerstones. As applicable for each activity, the inspectors verified that licensee personnel

performed risk assessments as required by 10

CFR 50.65(a)(4) and that the assessments were accurate and complete. When licensee personnel

performed emergent work, the inspectors verified that the licensee personnel promptly assessed and managed plant risk. The inspectors reviewed the scope of maintenance work, discussed the results of the assessment with the licensee's probabilistic risk analyst or shift technical advisor, and verified plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of three maintenance risk assessments and emergent work control inspection sample

s as defined in Inspection Procedure 71111.13-05.

b. No findings were identified.

Findings 1R15 Operability Evaluations (71111.15)

a. The inspectors reviewed the following issues:

Inspection Scope

January 5, 2011, Action Request/Condition Report 231738, "Diesel Generator 2

Breaker Closing Spring will not Discharge" January 25, 2011, Action Request/Condition Report 232917, "Post Seal Cracks discovered on HPCS

-B1-DG3" February 1, 2011, Action Request/Condition Report 233290, "Emergency Siren

D-2 is Not Communicating" February 24, 2011, Action Request/Condition Report 234537, "Circuit Breaker Case is Cracked"

- 11 - Enclosure February 28, 2011, Action Request/Condition Report 234766, "DMA

-FN-31 Electrical Phase Imbalance Noted at Motor Starter

The inspectors selected these potential operability issues based on the risk

significance of the associated components and systems. The inspectors evaluated the technical adequacy of the evaluations to ensure that technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred.

The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and FSAR to the licensee personnel's

evaluations to determine whether the components or systems were operable. Where compensatory measures were required to maintain operability, the

inspectors determined whether the measures in place would function as intended and were properly controlled. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations. Additionally, the inspectors also reviewed a sampling of corrective action documents to verify that the licensee was identifying and correcting any deficiencies associated with operability evaluations. Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of five operability evaluations inspection samples

as defined in Inspection Procedure

71111.15-04 b. No findings were identified.

Findings 1R18 Plant Modifications (71111.18)

a. Temporary Modifications

To verify that the safety functions of important safety systems were not degraded, the

inspectors reviewed the temporary modification identified as Temporary Modification TMR-11-008, "Crack in Weld Down Stream of BS

-V-52A" Inspection Scope

The inspectors reviewed the temporary modification

and the associated safety

-evaluation screening against the system design bases documentation, including the

FSAR and the technical specifications, and verified that the modification

did not adversely affect the system operability/availability. The inspectors also verified that the installation and restoration were consistent with the modification documents and that configuration control was adequate. Additionally, the inspectors verified that the temporary modification was identified on control room drawings, appropriate tags were placed on the affected equipment, and licensee personnel evaluated the combined effects on mitigating systems and the integrity of radiological barriers.

These activities constitute completion of

one sample for temporary plant modifications as defined in Inspection Procedure

71111.18-05.

- 12 - Enclosure b. No findings were identified.

Findings 1R19 Postmaintenance Testing (71111.19)

a. The inspectors reviewed the following postmaintenance activities to verify that procedures and test activities were adequate to ensure system operability and functional capability:

Inspection Scope

January 3, 2011, WO 01126278, E

-CB-8/3, "Detailed Inspecti

on of MOC Switch" February 3, 2011, Work Order 01192825, "LPCS

-P-2 - Replace Pump Power Frame" February 28, 2011, Work Order 01195224, " DG3 DMA-Fan-31 Post Maintenance Testing" March 3, 2011, Work Order 01169668, "Replace FPC

-M-P/1A" March 10, 2011, Work Request 02000086, "SCW-P-2 Postmaintenance Testing" March 21, 2011, Work Request 29086232, "SEIS

-RSA-1 Amber and Red Lights Will Not Reset" The inspectors selected these activities based upon the structure, system, or component's ability to affect risk. The inspectors evaluated these activities for the following:

The effect of testing on the plant had been adequately addressed; testing was adequate for the maintenance performed

Acceptance criteria were clear and demonstrated operational readiness; test instrumentation was appropriate

The inspectors evaluated the activities against the technical specifications, the FSAR, 10 CFR Part 50 requirements, licensee procedures, and various NRC generic

communications to ensure that the test results adequately ensured that the equipment met the licensing basis and design requirements. In addition, the inspectors reviewed corrective action documents associated with postmaintenance tests to determine whether the licensee was identifying problems and entering them in the corrective action program and that the problems were being corrected commensurate with their importance to safety. Specific documents reviewed during this inspection are listed in

the attachment.

- 13 - Enclosure These activities constitute completion of six postmaintenance testing inspection sample s as defined in Inspection Procedure

71111.19-05. b. Introduction

The inspectors identified a noncited violation of 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the failure to consider the

impact of preconditioning on the emergency core cooling systems during keep fill pump maintenance in the work management process.

Findings Description: On February 3, 2011, the inspectors identified that the work schedule for the keep fill pump maintenance performed on December 20, 2010, could have resulted in the unacceptable preconditioning of the low pressure core spray system. The licensee was scheduled to start the low pressure core spray pump to perform Surveillance Procedure SOP

-LPCS-SP, "LPCS Suppression Pool Mixing," to support keep fill pump maintenance on the low pressure core spray system. During low pressure core spray pump start, the minimum flow valve strokes open to protect the pump from damage. The low pressure core spray minimum flow valve is scoped into the licensee's inservice testing program; which requires the licensee to test the valve in an

as-found condition without preconditioning of the valve prior to inservice testing. Preconditioning, as defined in the licensee's inservice testing program, "is the manipulation of the physical condition of a component before technical specification

surveillance testing." Unacceptable preconditioning is further defined to be preconditioning that alters one or more attributes of components which results in acceptable test results. The licensee's definition of unacceptable preconditioning goes on to further state that "any activity performed prior to an inservice test which results in acceptable test results, but may have adversely affected the ability to monitor the component for degradation." Once the keep fill pump maintenance was completed, the

licensee was scheduled to complete the required technical specification surveillance test on the low pressure core spray system. This technical specification surveillance test is used to test the time the low pressure core spray minimum flow valve takes to stroke from fully closed to fully

open, among other attributes of the low pressure core spray system. This test is performed to ensure the low pressure core spray

system can meet its specified design function, and to detect a degrading performance trend before operability is challenged.

The inspectors reviewed the licensee's technical position

on preconditioning within its inservice testing program plan to determine what the licensee had defined to be unacceptable preconditioning. The inspectors identified that one of the examples of unacceptable preconditioning listed in the licensee's inservice testing program was the exercising of a motor

-operated valve other than for test configurations or normal system operation prior to a surveillance test on the valve. The inspectors also reviewed NRC

Inspection Manual Chapter 9900, "Maintenance

-Preconditioning of Structures, Systems, and Components Before Determining Operability

." The inspectors noted that preconditioning could mask the actual as

-found condition of components and possibly result in an inability to verify the operability of components. The inspectors also noted in the NRC technical guidance, that the scheduling of apparently unrelated activities could

- 14 - Enclosure result in unacceptable preconditioning. The inspectors determined that the scheduling of the keep fill pump maintenance, which requires the starting of the low pressure core spray system and the cycling of the minimum flow valve, prior to technical specification surveillance testing constituted unacceptable preconditioning by the licensee.

The inspectors reviewed keep fill pump maintenance scheduling records for the previous three years and noted the following additional occurrences of unacceptable preconditioning on emergency core cooling systems:

4/22/2008 high pressure core spray system started for keep fill pump maintenance.

4/25/2008 high pressure core spray system started for technical specification surveillance testing.

7/14/2008 high pressure core spray system started for keep fill pump maintenance.

7/18/2008 high pressure core spray system started for technical specification

surveillance testing.

10/7/2008 high pressure core spray system starte

d for keep fill pump maintenance.

10/8/2008 high pressure core spray system started for technical specification

surveillance testing.

11/23/2009 low pressure core spray system started for keep fill pump maintenance.

11/27/2009 low pressure core spray system started for technical specification

surveillance testing.

5/17/2010 high pressure core spray system started for keep fill pump maintenance.

5/19/2010 high pressure core spray system started for technical specification

surveillance testing.

8/11/2010 high

pressure core spray system started for keep fill pump maintenance.

8/14/2010 high pressure core spray system started for technical specification

surveillance testing.

9/8/2010 high pressure core spray system started for keep fill pump maintenance.

9/8/2010 high pressure core spray system started for technical specification

surveillance testing.

2/2/2011 residual heat removal system, train

C , started for keep fill pump maintenance.

2/3/2011 residual heat removal

system, train

C , started for technical specification surveillance testing.

The inspectors determined , through interviews with the licensee's staff , the licensee did not have clear guidance on how to avoid preconditioning of components during the scheduling of work or how to resolve issues of preconditioning when identified.

Analysis: The failure to consider preconditioning during the work scheduling process is a performance deficiency. This performance

deficiency is more than minor because it

- 15 - Enclosure affects the equipment performance attribute of the Mitigating Systems Cornerstone objective of ensuring the reliability of systems that respond to initiating events. Specifically, the improper scheduling of maintenance and surveillance activities could mask a degraded condition such that systems would be unable to perform their intended safety function when called upon. Using Inspection Manual Chapter 0609.04, "Pha se 1 - Initial Screening and Characterization of Findings," the inspectors determined this performance deficiency was of very low safety significance because the finding was confirmed to not result in a loss of operability for the emergency core cooling systems. During interviews with plant personnel t

he inspectors identified a cross

-cutting issue in the area of human performance, work practices, because the licensee failed to

effectively communicate expectations regarding procedural compliance. In that, the

licensee failed to give clear guidance to work week managers in preparing work schedules H.4.b].

Enforcement: 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 procedures of a type appropriate to the circumstance and shall be accomplished in accordance with those procedures. Contrary to this, from 2008 through 2010, the licensee failed to ensure aspects of preconditioning are considered during scheduling of work as specified in Procedure 1.3.68, "Work Management Process". This caused the licensee to fail to realize the scheduling of emergency core cooling systems

keep fill pump maintenance prior to quarterly scheduled surveillance testing constituted unacceptable preconditioning. This violation was identified on February 3, 2011. Because this finding was determined to be of very low safety significance and was entered into the licensee's corrective action program as Action Request/Condition

Report 23 6880, this violation is being treated as a noncited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy: NCV 05000397/2011002

-01, "Failure to Ensure Unacceptable Preconditioning is Considered During the Work Management

Process."

1R22 Surveillance Testing (71111.22)

a. Inspection Scope

The inspectors reviewed the FSAR , procedure requirements, and technical specifications to ensure that the surveillance activities listed below demonstrated that the systems, structures, and/or components tested were capable of performing their intended safety functions. The inspectors either witnessed or reviewed test data to verify that the significant surveillance test attributes were adequate to address the

following:

Preconditioning

Evaluation of testing impact on the plant

Acceptance criteria

- 16 - Enclosure Test equipment

Procedures

Jumper/lifted lead controls

Test data Testing frequency and method demonstrated technical specification operability

Test equipment removal

Restoration of plant systems

Fulfillment of ASME Code requirements

Updating of performance indicator data

Engineering

evaluations, root causes, and bases for returning tested systems, structures, and components not meeting the test acceptance criteria were correct

Reference setting data

Annunciators and alarms setpoints

The inspectors also verified that licensee personnel identified and implemented any needed corrective actions associated with the surveillance testing.

January 5, 2011, Work Order 01194716, OSP

-RHR/IST-Q704, "RHR Loop C Operability Test"

January 5, 2011, OSP

-RHR-M103, "Fill Verification RHR

-C System" January 24, 2011, Work Order 01194381, ISP

-RFW-Q401, "Feedwater/Turbine Trip Reactor Level 8 Channel Functional Test

" February 2, 2011, ISP

-MS-Q935, "Division 2 Channel D Isolation Actuation on Reactor Level 2

- CFT/CC" February 7, 2011, Work Order 01194835, ISP

-RCIC-Q903, "RCIC Isolation on RCIC Steam Supply Flow High DIV 2

- CFT/CC" February 8, 2011, Work Order 01194837, "RCIC Isolation on RCIC Steam Supply

Flow High Division 1

- Channel Functional Tests and Channel Calibration" February 22, 2011, Work Order 01193731, "Control Rod Settle Time Test"

- 17 - Enclosure Specific documents reviewed during this inspection are listed in the attachment.

These activities constitute completion of seven surveillance testing inspection sample s as defined in Inspection Procedure

71111.22-05. b. No findings were identified.

Findings Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation (71114.06)

Training Observations

a. The inspectors observed a simulator training evolution for licensed operators on January 11, 2011, which required emergency plan implementation by a licensee operations crew. This evolution was planned to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the postevolution critique for the scenario. The focus of the inspectors' activities was to note any weaknesses and deficiencies in the crew's performance and ensure that the licensee evaluators noted the same issues and entered them into the corrective action program. As part of the inspection, the inspectors reviewed the scenario package and other documents listed in the attachment.

Inspection Scope

These activities constitute completion of one sample as defined in Inspection Procedure 71114.06-05. b. No findings were identified.

Findings 4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151)

.1 Data Submission Issue

a. The inspectors performed

a review of the performance indicator data submitted by the licensee for the fourth Quarter 2010 performance indicators for any obvious inconsistencies prior to its public release in accordance with Inspection Manual Chapter 0608, "Performance Indicator Program." Inspection Scope

- 18 - Enclosure This review was performed as part of the inspectors' normal plant status activities and, as such, did not constitute a separate inspection sample.

b. No findings were identified.

Findings .2 Unplanned Scrams per 7000 Critical Hours (IE01)

a. The inspectors sampled licensee submittals for the unplanned scrams per 7000 critical hours performance indicator for the period from the first quarter 20 10 through the fourth quarter 20 10. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used

definitions and guidance contained in NEI Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision

6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports , and NRC integrated inspection reports for the period of January 2010

through December 2010

, to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

Inspection Scope

These activities constitute completion of

one unplanned scrams per 7000 critical hours sample as defined in Inspection Procedure

71151-05.

b. No findings were identified.

Findings .3 Unplanned Scrams with Complications (IE02)

a. The inspectors sampled licensee submittals for the unplanned scrams with complications

performance indicator for the period from the first quarter 2010 through the fourth quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, event reports

, and NRC integrated inspection reports for the period of January 2010 through December 2010, to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any

problems had been identified with the performance indicator data collected or transmitted for this indicator and none were identified. Specific documents reviewed are

described in the attachment to this report.

Inspection Scope

- 19 - Enclosure These activities constitute completion of

one unplanned scrams with complications sample as defined in Inspection Procedure

71151-05. b. No findings were identified.

Findings .4 Unplanned Power Changes per 7000 Critical Hours (IE03)

a. The inspectors sampled licensee submittals for the unplanned power changes per 7000 critical hours performance indicator for the period from the first quarter 2010 through the fourth quarter 2010. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99

-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors reviewed the licensee's operator narrative logs, issue reports, maintenance rule records, event reports

, and NRC integrated inspection reports for the period of January 2010 through December 2010, to validate the accuracy of the submittals. The inspectors also reviewed the licensee's issue report database to determine if any problems had been identified with the performance indicator data

collected or transmitted for this indicator and none were identified. Specific documents reviewed are described in the attachment to this report.

Inspection Scope

These activities constitute completion of

one unplanned transients per 7000 critical hours sample as defined in Inspection Procedure

71151-05.

b. No findings were identified.

Findings 4OA2 Identification and Resolution of Problems (71152)

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency

Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Physical Protection

.1 Routine Review of Identification and Resolution of Problems

a. As part of the various baseline inspection procedures discussed in previous sections of this report, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that they were being entered into the licensee's corrective action program at an appropriate threshold, that adequate attention was being given to timely corrective actions, and that adverse trends were identified and addressed. The inspectors reviewed attributes that included the complete and accurate identification of the problem; the timely correction, commensurate with the safety Inspection Scope

- 20 - Enclosure significance; the evaluation and disposition of performance issues, generic implications, common causes, contributing factors, root causes, extent of condition reviews, and previous occurrences reviews; and the classification, prioritization, focus, and timeliness of corrective actions. Minor issues entered into the licensee's corrective action program because of the inspectors' observations are included in the attached list of documents reviewed. These routine reviews for the identification and resolution of problems did not constitute any additional inspection samples. Instead, by procedure, they were considered an integral part of the inspections performed during

the quarter and documented in Section 1 of this report.

b. No findings were identified.

Findings .2 Daily Corrective Action Program Reviews

a. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow

-up, the inspectors performed a daily screening of items entered into the licensee's corrective action program. The inspectors

accomplished this through review of the station's daily corrective action documents.

Inspection Scope

The inspectors performed these daily reviews as part of their daily plant status monitoring activities and, as such, did not constitute any separate inspection samples.

b. No findings were identified.

Findings .3 Selected Issue Follow

-up Inspection

a. During a review of items entered in the licensee's corrective action program, the inspectors recognized a corrective action item documenting the low pressure core spray system's minimum flow valve losing position indication during surveillance testing.

The inspectors were concerned that the issue was reportable to the NRC and that the licensee had failed to do so.

Inspection Sc

ope These activities constitute completion of one

in-depth selected issue follow

-up inspection

sample as defined in Inspection Procedure 7115

2-05.

- 21 - Enclosure b. Introduction: The inspectors identified a Severity Level IV violation of Title 10 CFR 50.72(b)(3)(v)(D) for the failure of the licensee to make a non

-emergency event notification to the NRC. Specifically, the licensee failed to report

the low pressure core spray minimum flow valve failing to open on December 20, 2010, rendering the low pressure core spray system incapable of performing its specified safety function, during testing. Findings Description: On December 20, 2010, while performing Surveillance Procedure SOP

-LPCS-SP, "LPCS Suppression Pool Mixing," in support of scheduled maintenance, the low pressure core spray minimum flow valve failed to open as expected. The low

pressure core spray minimum flow valve is a motor

-operated valve which is required to open when the low pressure core spray system is started. This is done to establish a

flow path from the suppression pool, back to the suppression pool until a flow path can be established to the reactor vessel to prevent overheating and

damage to the low pressure core spray pump and motor. The low pressure core spray system was

subsequently declared inoperable and an investigation team was assembled to determine the cause of the failure. The investigation team determined that two of th

e three fuses associated with the low pressure core spray motor starter showed internal melting and discoloration while the third fuse did not. The licensee replaced all three fuses and performed testing on the low pressure core spray motor starter and returned the low pressure core spray system to an operable status.

The inspectors questioned the licensee on whether the low pressure core spray system was capable of performing its specified safety function, at the time of discovery, when the minimum flow valve failed to open. The inspectors referred to NUREG

-1022, "Event Reporting Guidelines 10 CFR 50.72 and 73," Revision 2, and noted the following under Section 3.2.7, "Event or Condition That Could Have Prevented Fulfillment of a Safety Function":

The intent of these criteria is to capture those events when there would have been a failure of a safety system to properly complete a safety function.

These criteria cover an event or condition where structures, components, or trains of a safety system could have failed to perform their intended function because of: [-] equipment failures.

The event must be reported regardless of whether or not an alternate safety system could have been used to perform the safety function.

There are a limited number of single train systems that perform safety functions. For such systems, loss of the single train would prevent the fulfillment of the

safety function of that system and, therefore, is reportable.

The inspectors presented their questions to the licensee on December 29, 2010. The licensee prepared a position paper that summarized the low pressure core spray system was not a single train system for reporting purposes, but that it was a redundant system

- 22 - Enclosure to both the residual heat removal system and the high pressure core spray system. Therefore, the reporting requirement would not be met due to the previously mentioned systems being able to provide the appropriate safety function. The licensee position paper was presented to the inspectors on January 6, 2011. The inspectors reviewed the FSAR and consulted with NRC regional, headquarters, and training staff to determine the treatment of the low pressure core spray system for reporting purposes. After review, the inspectors determined the low pressure core spray system was a single train system and the failure of the minimum flow valve to open was a reportable condition. The licensee submitted Event Notification 46604 to the Headquarters Operations Officer on February 8, 2011.

Analysis: The failure to report a condition that could have prevented the fulfillment of a system's safety function is a performance deficiency. This finding is more than minor because the NRC relies on licensees to identify and report conditions or events meeting

the criteria specified in the regulations in order to perform its regulatory function. Using Inspection Manual Chapter 0612, the inspectors determined that this performance

deficiency was not appropriate to evaluate using the NRC's Significance Determination Process due to the finding only affecting the NRC's ability to perform its regulatory oversight function. As a result, this performance deficiency was evaluated for traditional enforcement in accordance with the NRC Enforcement Policy. This performance deficiency was determined to

be a Severity Level IV violation in accordance with Section 6.9.d.9 of the NRC Enforcement Policy, dated September 30, 2010. The inspectors determined that assigning a cross

-cutting aspect was not applicable to this performance deficiency due to the performance deficiency being screened exclusively using the traditional enforcement process.

Enforcement: Title 10 CFR 50.72(b)(3)(v)(D) requires, in part, that licensees shall notify the NRC within eight hours of the occurrence of an event or condition that

at the time of discovery could have prevented the fulfillment of the safety function of systems that are needed to mitigate the consequences of an accident. Contrary to this requirement, on December 20, 2010, the licensee failed to report to the NRC a condition that could have, at the time of discovery, prevented the low pressure core spray system from fulfilling its

safety function. This violation was identified on December 28, 2010. The licensee made Event Notification 46604 on February 8, 2011. As a corrective action the licensee has informed all current shift managers, and plans to train future senior reactor operators, of

the expectation to evaluate low pressure core spray system failures as a failure of a single train system to complete a safety function. There w as no actual or potential safety consequences

associated with this violation. Because this violation was placed into the licensee's corrective action program as Action Request/Condition Report 23 6879, compliance was restored within a reasonable amount of time, the violation was not repetitive, or willful, this Severity Level IV violation is being treated as a noncited violation, consistent with Section 2.3.2.a of the Enforcement Policy: NCV 05000397/2011002, "Failure to Make Required Event Notification"

.

- 23 - Enclosure .4 Assessment of Licensee Improvement Efforts

a. The inspectors reviewed the following issue:

Inspection Scope

March 2, 2011, Action Request/Condition Report 222076, Pride and

Performance Completion Sample

- Equipment Reliability , items 12 and 30

The inspectors determined that the licensee has effectively identified systems and

components necessary to control reactor power, reactor pressure and reactor level and have accurately assessed the reliability of such systems and component

s. These activities constitute completion of one

in-depth problem identification and resolution sample as defined in Inspection Procedure 71152

-05. b. No findings were identified.

Findings 4OA3 Event Follow

-up (71153)

.1 (Closed) Licensee Event Report (LER) 05000397/2010

-002-00: LPCS Minimum Flow Valve Failed to Open Due to Premature Fuse Failure at the Solder Joint

This LER documented a failure of the low pressure core spray minimum flow valve to open during surveillance testing, rendering the low pressure core spray system

inoperable and unable to perform its specified safety function. See Section 4OA5 of

NRC Inspection Report 05000397/2011002 for a discussion of an NRC identified violation associated with this event. The inspectors completed a review of this LER and did not identify any other violations of regulatory requirements or findings associated with this event. This LER is closed.

4OA5 Other Activities

.1 NRC TI 2515/177, "Managing Gas Accumulation in Emergency Core Cooling Decay Heat Removal and Containment Spray Systems (NRC Generic Letter 2008

-01)" As documented in Section 1R22 of Inspection Report 05000397/2010005 and 1R22 of Inspection

Report 05000397/2011002, the inspectors confirmed the acceptability of the described actions for the residual heat removal system and the high pressure core spray system. This inspection effort counts towards the completion of TI 2515/177 which will

be closed in a later inspection report.

- 24 - Enclosure 4OA6 Meetings Exit Meeting Summary

The inspectors debriefed Messrs. John Bekhazi, Plant General Manager, James Moon, Training Manager, and other members of the staff on December 2, 2010. A telephonic exit of the results of the licensed operator requalification program inspection was conducted on March 1, 2011, between Messrs. Brian Larson, Lead Inspector, and Kevin Smart, Operations Training Supervisor. The inspector asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was identified.

On March 31, 2011, the inspectors presented the inspection results to Mr. Mark Reddemann

, Chief Executive Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspector 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 B. Sawatzke, Chief Nuclear Officer

B. MacKissock, Plant General Manager

C. King, Assistant, Plant General Manager

D. Brown, Operations Manager

S. Wood, Organizational Effectiveness Manager

D. Swank, Engineering General Manager

D. Mand, Design Engineering Manager

J. Bekhazi, Maintenance Manager D. Gregoire, Acting Regulatory Affairs Manager

K. Christianson, Acting Licensing Supervisor

R. Garcia, Licensing Engineer

L. Williams, Licensing Engineer

P. Taylor, Operations Training Manager

K. Smart, Operations Training Supervisor

R. Hayden, Operations Training Specialist

NRC Personnel

R. Cohen, Resident Inspector

M. Hayes, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened None. Opened and Closed

05000 397/2011 002-01 NCV Failure to Ensure Unacceptable Preconditioning is Considered During the Work Management Process (Section 1R19)

05000397/2011 002-02 NCV Failure to Make Required Event Notification (Section 4OA2)

Closed 05000397/2010

-0 0 2-00 LER LPCS Minimum Flow Valve Failed to Open Due to Premature Fuse Failure at the Solder Joint

(Section 4OA3)

Discussed None.

A-2 Attachment

LIST OF DOCUMENTS REVIEWED

Section 1RO1: Adverse Weather Protection

PROCEDURES

NUMBER TITLE REVISION SOP-COLDWEATHER

-OPS Cold Weather Operations

16 Section 1RO4: Equipment Alignment

PROCEDURES

NUMBER TITLE REVISION SOP-DG1-STBY Emergency Diesel Generator (Div 1) Standby Lineup

14 Section 1RO5: Fire Protection

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION FSAR Columbia Generating Station Final Safety Analysis Report, Appendix F

60 Section 1R11: Licensed Operator Requalification Program

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION Licensed Operator Requalifications Training LR002021

0 TDI-08 Licensed Operator Requalification Program

7 TDI-12 Shift Technical Advisor/Incident Advisor Program

2 AR/CR 00230147 Licensee Medical Status Not Consistent with RIV Database

LICENSEE EVENT REPORTS

397-10001 Failure of a Secondary Containment Isolation Valve to Fully Close 397-09005 Manual Reactor Scram due to Main Turbine DEH

Control System Fluid Leak

397-09004 6.9 kV Non

-Segregated Electrical Bus Failure

397-09003-1 Manual Reactor Scram due to a Fire Stemming from a Turbine Lube Oil leak

A-3 Attachment

397-09002-1 Manual Reactor Scram due to Loss of Hydrogen Pressure in the Main Generator 397-09001-1 Reactor Scram due to Turbine Control System Trip Header Depressurization

Section 1R12: Maintenance Effectiveness

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE TSP-TURB-G001 Turbine Overspeed Protection Valve Disassembly and Inspection

April 19, 2007

Drawing M502

Flow Diagram Main & Exhaust Steam System

35 Drawing M959

Flow Diagram Electro

-Hydraulic Fluid System

15 ABN-DEH-LEAK DEH-System-Leak 2 Section 1R13: Maintenance Risk Assessment and Emergent Work Controls

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE AR 233580 500 KV Relay Set 1 Spurious Trip Tone Signals

February 3, 2011 Energy Northwest Impact Statement, BPA Communication Equipment February 3, 2011 WO 2000583

Investigate Spurious Tone 1 and Tone 2 Signals on 500 KV Relay Set 1

0 ABN-GENERATOR Main Generator Trouble

9 02000086-01 SCW-P-2 Replace power frame with rebuilt one

February 28, 2011 Section 1R15: Operability Evaluations

NUMBER TITLE REVISION / DATE ESP-B1DG3-A101 12 Month Battery Inspection of 125 VDC HPCS

-B1-DG3 6

A-4 Attachment

AR/CR 234537

Circuit breaker Case is Cracked

February 24, 2011 AR/CR 234766

DMA-FN-31 Electrical Phase Imbalance Noted at Motor Starter February 28, 2011 ACTION REQUEST/CONDITION REPORTS

232917 218082 228525 218980 Section 1R18: Plant Modifications

NUMBER TITLE REVISION / DATE TMR-11-008 Crack in Weld Down Stream of BS

-V-52A March 1, 2011 Section 1R19: Postmaintenance Testing

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE Action Request

234765 DMA-FN-31 Electrical

Phase Imbalance Noted at Motor Starter February 25, 2011 Action Request

234766 DMA-FN-31 Phase Imbalance

February 25, 2011 Work Order 01195224 DG3 Monthly Operability Testing

February 25, 2011 OSP-FPC/IST-Q701 Fuel Pool Cooling System Operability Surveillance

24 18.1.22 FPC-P-1A IST Preservice Test

1 Work Request 02000086 SCW-P-2 Postmaintenance Testing

March 10, 2011 Work Request 29086232 SEIS-RSA-1 Amber and Red Lights Will Not Reset

March 21, 2011 Work Order 0119282503

SP HP Support Replace Power Frame LPCS

-P-2 December 20, 2010 Work Order 0119266501

OSP-LPCS/IST-Q702 Operability Testing

December 20, 2010 SWP-PRO-01 Description and Use

of procedures and Instructions

16

A-5 Attachment

Section 1R18: Plant Modifications

NUMBER TITLE REVISION / DATE Inservice Testing Program Plan Third Ten

-Year Inspection Interval 2011 Action Request

234072 Energy Northwest Condition Evaluation

1.3.68 Work Management Process

22 Section 1R22: Surveillance Testing

PROCEDURES

NUMBER TITLE REVISION ISP-RFW-Q401 Feedwater/Turbine Trip reactor level 8 Channel Functional Test 11 ISP-MS-Q935 D ivision 2 Channel D Isolation Actuation on Reactor Level

2-CFT/CC 8 ISP-RCIC-Q903 RCIC Isolation on RCIC Steam Supply Flow High DIV 2

- CFT/CC 15 RCIC Isolation on RCIC Steam Supply Flow High Division 1

- Channel Functional Test and Channel Calibration

17 PPM 8.2.449

Control Rod Settle Time Test

3 ACTION REQUEST/CONDITION REPORT

S 01194620 01193731 Section 1EP6: Drill Evaluation

MISCELLANEOUS DOCUMENTS

NUMBER TITLE DATE Columbia Generating Station 2011 ERO Team D Training Drill January 11, 2011

A-6 Attachment

Section 4OA1: Performance Indicator Verification

MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE NEI 99-02 Regulatory Assessment Performance Indicator Guideline

6 Operator Logs

Energy Northwest and NRC Performance Indicator Data

Section 4OA2: Identification and Resolution of Problems

ACTION REQUEST/CONDITION REPORTS

00233155 00233160 00233181 00233182 00233184 00233209 00233210 00233227 00233228 00233260 00232626 00233275 00233276 00233278 00233266 00233267 00233290 00233452 00233457 00233456 00233462 00233463 00233368 00233580 00233588 00233642 00233644 00233646 00233647 00233648 00233668 00233670 00233679 00233682 00233691 00233692 00233913 00233915 00233883 00233887 00233913 00233915 00233580 00233588 00233589 00233592 00233594 00233609 00233614 00233634 00233637 00233642 00233644 00233646 00233647 00233648 00233649 00233650 00233652 00233653 00231848 00231907 00231905 00231908 00231661 00231662 00231665 00231677 00231680 00231684 00231738 00231778 00231798 00231805 00231810 00231813 00231848 00231852 00234219 00234221 00234265 00234268 00234269 00234271 00233986 00233989 00234167 00234169 00234187 00234190 00234191 00234051 00234052 00234072 00234077 00234081 00234082 00234101 00234102 00234103 00234119 00234120 00234122 00234123 00234134 00234135 00234136 00234137 00234140 00234141 00234146 00234765 00234535 00234537 00234538 00234580 00234380 00234381 00234383 00234384 00234407 00234409 00234443 00234444 00234445

A-7 Attachment

00234446 00235404 00235405 00235522 00235523 00235525 00235526 00236261 00236264 00236265 00236306 00236307 00236311 00235994 00235996 00235997 00236022 00236023 00236024 00235660 00235661 00235640 00235654 00236339 00236340 00236343 00236453 00236454 00236455 00236473 00236474 00236488 00236489 00236500 00236501 00236502 MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE AR/CR 222076 Pride and Performance Completion Sample

- Equipment Reliability, items 12, 30

March 2, 2011 Section 4OA3: Event Follow

-Up MISCELLANEOUS DOCUMENTS

NUMBER TITLE REVISION / DATE LER 2010-002-00 LPCS Minimum Flow Valve Failed to Open Due to Premature Fuse

Failure at the Solder Joint

February 18, 2011