Text

IR 05000397/2015003, July 1, 2015 Through September 30, 2015, Columbia Generating Station Exercise of Enforcement Discretion
	ML15316A834
Person / Time
Site:	Columbia
Issue date:	11/12/2015
From:	Pruett T W; NRC/RGN-IV/DRP
To:	Reddemann M E; Energy Northwest
	Ryan Alexander
References
	EA-15-202 IR 2015003
	Download: ML15316A834 (62)
	v • d • e

November 12, 2015

EA-15-202 Mr. Chief Executive Officer Energy Northwest P.O. Box 968, Mail Drop 1023 Richland, WA 99352-0968

SUBJECT: COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2015003 AND EXERCISE OF ENFORCEMENT DISCRETION

Dear Mr. Reddemann,

On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Columbia Generating Station. On October 1, 2015, the NRC inspectors discussed the results of this inspection with Mr. W.G. Hettel, Chief Operating Officer and Chief Nuclear Officer, and other members of your staff. The inspectors documented the results of this inspection in the enclosed inspection report. NRC inspectors documented five findings of very low safety significance (Green) in this report. Four of these findings involved violations of NRC requirements. The NRC is treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2.a of the NRC Enforcement Policy. Additionally, a violation involving the failure to maintain the operability of secondary containment during Operations with a Potential to Drain the Reactor Vessel (OPDRV) was identified. Specifically, from May 13, 2015, through June 13, 2015, Columbia Generating Station performed five OPDRV activities with secondary containment inoperable in violation of Technical Specification (TS) 3.6.4.1, "Secondary Containment." The NRC issued EGM 11-003, "Enforcement Guidance Memorandum on Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements During Operations with a Potential for Draining the Reactor Vessel," Revision 2, on December 13, 2013, allowing for the exercise of enforcement discretion for OPDRV-related TS violations, when certain criteria are met. The NRC concluded that Columbia Generating Station met these criteria. Because the violation was identified during the discretion period described in EGM 11-003, the NRC is exercising enforcement discretion in accordance with Section 3.5, "Violations Involving Special Circumstances," of the NRC Enforcement Policy and, therefore, will not issue enforcement action for this violation, subject to a timely license amendment request being submitted. If you contest the violations or significance of these NCVs, 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC resident inspector at the Columbia Generating Station. If you disagree with a cross-cutting aspect assignment or a finding not associated with a regulatory requirement 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 Columbia Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/ Troy W. Pruett Director Division of Reactor Projects Docket Nos. 50-397 License Nos. NPF-21

Enclosure:

Inspection Report 05000397/2015003 w/

Attachment:

Supplemental Information cc w/ encl: Electronic Distribution

SUMMARY

IR 05000397/2015003; 07/01/2015 - 09/30/2015; Columbia Generating Station; Equipment Alignment, Licensed Operator Performance, Radioactive Solid Waste Processing. The inspection activities described in this report were performed between July 1 and September 30, 2015, by the resident inspectors at Columbia Generating Station and inspectors from the NRC's Region IV office. Five findings of very low safety significance (Green) are documented in this report. Four of these findings involved violations of NRC requirements. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process." Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Aspects within the Cross-Cutting Areas." Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process."

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding associated with the licensee's failure to maintain seismic instrumentation functional as required by Licensee Controlled Specification 1.3.7.2, "Seismic Monitoring Instrumentation." Specifically, because of inadequate calibration procedures, several as-left setpoints for the seismic response spectrum recorders indicating lights were non-conservative relative to their function to alert operators of ground motion exceeding the operating basis earthquake (OBE). Following discovery of this issue, the licensee recalibrated the seismic response spectrum recorders using OBE ground motions as the upper tolerance. The licensee entered this issue into their corrective action program as Action Request 333996. The performance deficiency was more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone objective 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, the performance deficiency resulted in seismic instruments calibrations that were non-conservative relative to their function to alert plant operators that a shutdown is required. NRC regulations require a plant shutdown since systems necessary for continued operation without undue risk to the health and safety of the public are not designed to remain functional, in all cases, following an OBE. The inspector performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2,

"Mitigating Systems Screening Questions." The inspectors determined that the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Additionally, the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. The finding does not have a cross-cutting aspect since the configuration control error is associated with an instrument setpoint change request from 1990 and therefore not reflective of current licensee performance. (Section 1R04)

Green.

The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the failure to maintain an adequate abnormal procedure for earthquakes. Specifically, the licensee failed to establish appropriate shutdown criteria for earthquakes that exhibit ground motion exceeding the operating basis earthquake (OBE). The licensee's shutdown criteria would allow for continued operations if ground motion at a single frequency exceeded the design response spectrum. In response to this issue, the licensee initiated corrective actions to change the station's earthquake abnormal procedure to provide shutdown criteria consistent with the original licensing basis of the facility. The licensee entered this issue into their corrective action program as Action Request 336875. The performance deficiency was more than minor because it affected the procedural adequacy attribute of the Mitigating Systems Cornerstone objective 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, the performance deficiency resulted in shutdown criteria that would allow for continued operations following events where ground motion at a single frequency exceeded the design response spectra. NRC regulations require a plant shutdown since systems necessary for continued operation without undue risk to the health and safety of the public are not designed to remain functional, in all cases, following an OBE. The inspector performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions." The inspectors determined that the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Additionally, the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. The finding does not have a cross-cutting aspect since the procedure error is associated with a 1996 change to the licensing basis and therefore not reflective of current licensee performance. (Section 1R04)

Green.

The inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to verify the adequacy of the design of the control room HVAC system. Specifically, the licensee failed to demonstrate the ability of control room HVAC design to maintain the temperatures in the main control room below habitability and environmental qualification limits, for the duration of all accident scenarios. The licensee initiated Action Request 332565 to document the concern, issued night order 1662 to communicate the issue, aligned both control room air handling units to their respective chillers, created a quick card procedure to perform the chiller reset actions, and validated the quick card actions could be accomplished within 10 minutes. Additionally, the licensee determined that operators could restore the chillers during accident conditions within 90 minutes to prevent temperatures from exceeding equipment operability limits. The performance deficiency was more than minor because it adversely affected the design control attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This finding had a cross-cutting aspect in the area of problem identification and resolution, evaluation, in that the licensee did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee did not thoroughly evaluate the extent of condition from NRC-identified NCV 05000397/2013002-04, "Failure to Obtain NRC Approval for Changes to Control Room HVAC Requirements," for the effect of this change on other station calculations [P.2]. (Section 1R04)

Green.

The inspectors identified a non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the licensee's failure to ensure operators could perform time-critical steps for fire events. Specifically, on July 4, 2015, the licensee failed to implement written procedures to ensure that an equipment operator can complete certain post-fire safe-shutdown actions within 10 minutes. In response to this conclusion, the licensee initiated Action Request 332747 to document the inability to meet the post-fire safe-shutdown actions in accordance with procedure PPM 1.3.1, "Operating Policy, Programs, and Practices," Revision 119. Additionally, the licensee issued Night Order 1655, reminding all operating crews of the requirements of procedure PPM 1.3.1 for leaving the protected area.

This performance deficiency was more than minor because it was associated with the protection against external factors attribute of the Mitigating System Cornerstone and affected the cornerstone's objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. A senior reactor analyst performed a detailed significance determination process review using NRC Inspection Manual Chapter 0609, Appendix F, "Fire Protection Significance Determination," dated September 20, 2013 and NRC Inspection Manual 0308, Attachment 3, Appendix F, "Technical Basis Fire Protection Significance Determination Process (Supplemental Guidance for Implementing IMC 0609, Appendix F) At Power Operations," dated February 28, 2005. The senior reactor analyst determined that the failure of the equipment operator to perform the certain post-fire safe-shutdown actions within 10 minutes would not adversely affect a quantitative risk assessment, and therefore this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Teamwork, because the licensee failed to communicate and to coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the equipment operator spoke with the shift technical advisor about the need to exit the protected area at the morning turnover meeting but neither individual spoke with the control room supervisor. Communication was ineffective in that the Equipment Operator believed permission was granted and proceeded to exit the protected area [H.4]. (Section 1R11)

Cornerstone: Public Radiation Safety

Green.

The inspectors reviewed a self-revealing, non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the licensee's failure to follow their Process Control Program as implemented by their solid radioactive waste system procedures. Specifically, the licensee failed to reduce the free standing liquid in a condensate filter demineralizer resin disposal package (Liner 14-033-L) to less than the required 0.5 percent of the total waste volume. Corrective actions included retrieving the packages from waste shipment 14-32, testing each liner for free standing liquid content, and removing additional water as necessary. The licensee documented this issue in their corrective action program as Action Requests 00316555 and 00316676. The failure to follow the Process Control Program, resulting in the inadequate dewatering of radioactive waste liner contents, was a performance deficiency. The inspectors determined that the performance deficiency was more than minor, because it adversely affected the Public Radiation Safety cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released in the public domain.

Specifically, the failure to ensure that the free standing liquid in the radioactive waste liner shipped to US Ecology did not exceed 0.5 percent of the total waste volume subjected the disposal facility to the possibility of improper handling of the waste. Using Inspection Manual Chapter 0609, Appendix D, "Public Radiation Safety Significance Determination Process," dated February 12, 2008, the inspectors determined the violation was of very low safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was no breach of the package during transit, (3) there were no Certificate of Compliance issues, and (4) the low level burial ground nonconformance did not involve a 10 CFR 61.55 waste under-classification. The inspectors determined that the finding has a design margin cross-cutting aspect in the area of human performance, because the licensee failed to operate and maintain the radioactive waste dewatering system within the vendor design margins when changes were made to the operating procedures [H.6]. (Section 2RS8)

PLANT STATUS

The plant began the inspection period at approximately 65 percent power while troubleshooting a non-safety feedwater valve. On July 23, 2015, the plant returned to 100 percent power. On July 24, 2015, the plant experienced a loss of the 'B' recirculation pump and power was reduced to approximately 34 percent. Following repair to a non-safety cooling system supporting the recirculation pump, the plant returned to 100 percent power on July 26, 2015. The plant remained at 100 percent power for the remainder of the inspection period.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

On July 22, 2015, the inspectors completed an inspection of the station's readiness for seasonal extreme weather conditions. The inspectors reviewed the licensee's adverse weather procedures for seasonal high temperatures and evaluated the licensee's implementation of these procedures. The inspectors verified that prior to the onset of hot weather, the licensee had corrected weather-related equipment deficiencies identified during the previous season. The inspectors selected three risk-significant systems that were required to be protected from seasonal high temperatures: emergency diesel generators including support ventilation systems standby service water system high pressure core spray system The inspectors reviewed the licensee's procedures and design information to ensure the systems would remain functional when challenged by adverse weather. The inspectors verified that operator actions described in the licensee's procedures were adequate to maintain readiness of these systems. The inspectors walked down portions of these systems to verify the physical condition of the adverse weather protection features. These activities constituted one sample of readiness for seasonal adverse weather, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

On August 20, 2015, the inspectors completed an inspection of the station's readiness for impending adverse weather conditions involving high winds. The inspectors reviewed plant design features, the licensee's procedures to respond to tornadoes and high winds, and the licensee's potential implementation of these procedures. The inspectors evaluated operator staffing and accessibility of controls and indications for those systems required to control the plant.

These activities constituted one sample of readiness for impending adverse weather conditions, as defined in Inspection Procedure 71111.01.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Main article: IP 71111.04

.1 Partial Walkdown

a. Inspection Scope

The inspectors performed partial system walk-downs of the following risk-significant systems: July 2, 2015, control room emergency chillers July 20, 2015, seismic instrumentation July 28, 2015, standby liquid control system September 14, 2015, standby gas treatment system The inspectors reviewed the licensee's procedures and system design information to determine the correct lineup for the systems. They visually verified that critical portions of the systems were correctly aligned for the existing plant configuration. These activities constituted four partial system walk-down samples as defined in Inspection Procedure 71111.04.

b. Findings

===.1 Failure to Maintain Seismic Instrumentation Functional to Alert Plant Operators of Ground Motions Exceeding the Operating Basis Earthquake

Introduction.

=

The inspectors identified a Green finding associated with the licensee's failure to maintain seismic instrumentation functional as required by Licensee Controlled Specification (LCS) 1.3.7.2, "Seismic Monitoring Instrumentation." Specifically, because of inadequate calibration procedures, several as-left setpoints for the seismic response spectrum recorders indicating lights were non-conservative relative to their function to alert operators of ground motion exceeding the operating basis earthquake.

Description.

On July 20, 2015, the inspectors reviewed the design and calibration settings for the Columbia Generating Station seismic triaxial response spectrum recorders, designated SEIS-RSRT-1/1, 1/2 and 1/3. The seismic RSRTs consist of three units, two horizontal and one vertical, each containing twelve frequency sensitive reeds used to passively record earthquake ground motions. The RSRTs have a secondary function to provide visual warnings to operators of exceedances of pre-determined ground acceleration limits. The RSRTs include red lights to indicate that operating basis earthquake (OBE) ground motions have been exceeded at certain frequencies. Licensee Control Specification 1.3.7.2 requires that the seismic instrumentation, including the triaxial response spectra recorders, remain functional to ensure the capability to promptly determine the magnitude of a seismic event and initiate evaluation of the seismic response features important to safety. In particular, the RSRTs red indicating lights are described in Columbia Generating Station FSAR, Section 3.7.4.4, as equipment used to alert plant operators that a shutdown is required. Title 10 CFR Part 100, Appendix A, "Seismic and Geologic Siting Criteria for Nuclear Power Plants," requires a plant shutdown if vibratory ground motion exceeding the OBE occurs. The OBE is defined as the earthquake which produces the vibratory ground motion where features of the nuclear power plant necessary for continued operation without undue risk to the health and safety of the public are designed to remain functional. The inspectors reviewed calculation CE-02-90-21, "Setpoints for Response Spectrum Indicating Lights," Revision 0, used to establish the ground acceleration levels where the RSRT red indicating lights illuminate. The calculation determined target acceleration values for the RSRT red indicating lights based on the most conservative OBE seismic response spectra for the reactor building base mat. This setpoint methodology was consistent with Regulatory Guide 1.12, "Nuclear Power Plant Instrumentation for Earthquakes," Revision 1, and American Nuclear Society ANS Standard 2.2, "Earthquake Instrumentation Criteria for Nuclear Power Plants," 1978. This regulatory guidance provided acceptable methods for meeting the seismic instrumentation requirements in 10 CFR Part 100, Appendix A and recommended a response spectrum recorder with setpoints established at OBE ground motions. The inspectors compared the setpoints established in calculation CE-02-90-21 to the setpoints found in calibration implementing procedure ISP-SEIS-X304, "Seismic System Reactor Building Foundation Triaxial Response - Spectrum Recorder - CC," Revision 1. Instrument Setpoint Change Request 979, dated April 30, 1990, established allowable setpoints and included an upper and lower tolerance of approximately 5-10 percent from the nominal setpoints established in calculation CE-02-90-21. The inspectors compared the setpoints against the design basis earthquake and concluded that since the nominal setpoint exactly matched the OBE ground motion values, the upper tolerance would, in all cases, result in setpoints that exceed the OBE seismic ground motion response spectra at the reactor building base mat.

The inspector reviewed the as-left setpoints for SEIS-RSRT-1/1, 1/2 and 1/3 and identified 12 of 36 setpoints that exceeded the nominal target accelerations established in calculation CE-02-90-21, resulting in red indicating lights that would not illuminate until after OBE seismic ground motions were exceeded. The inspectors concluded that these as-left setpoints were non-conservative relative to their LCS required function to alert plant operators of the need for a plant shutdown as required by 10 CFR 100 and the Columbia Generating Station FSAR. On August 3, 2015, plant operators declared SEIS-RSRT-1/1, 1/2 and 1/3 non-functional due to non-conservative setpoints for the system's red indicating lights and entered LCS 1.3.7.2, Condition A. During the period that SEIS-RSRT-1/1, 1/2 and 1/3 were non-functional, the passive features of the seismic monitoring system were still available for earthquake evaluation. On August 10, 2015, the licensee established new setpoints for SEIS-RSRT-1/1, 1/2 and 1/3 using OBE ground motions as the upper tolerance. On August 18, 2015, the licensee completed a calibration using the revised setpoints and exited LCS 1.3.7.2, Condition A. The licensee entered this issue into their corrective action program as Action Request 333996.

Analysis.

The failure to maintain seismic instruments functional to provide indications of exceeding the OBE seismic ground motion response spectra was a performance deficiency. The performance deficiency was more than minor because it affected the configuration control attribute of the Mitigating Systems Cornerstone objective 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, the performance deficiency resulted in seismic instrument calibrations that were non-conservative relative to their function to alert plant operators that a shutdown is required. NRC regulations require a plant shutdown since systems necessary for continued operation without undue risk to the health and safety of the public are not designed to remain functional, in all cases, following an OBE. The inspector performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions." The inspectors determined that the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Additionally, the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event. The finding does not have a cross-cutting aspect since the configuration control error is associated with an instrument setpoint change request from 1990 and therefore not reflective of current licensee performance.

Enforcement.

Enforcement action does not apply because the performance deficiency did not involve a violation of regulatory requirements. The finding is of very low safety significance and the issue was entered into the licensee's corrective action program as Action Request 333996. (FIN 05000397/2015003-01, Failure to Maintain Seismic Instrumentation Functional to Alert Plant Operators of Ground Motions Exceeding the Operating Basis Earthquake)

===.2 Non-Conservative Shutdown Criteria in Earthquake Abnormal Procedure

Introduction.

=

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the failure to maintain an adequate abnormal procedure for earthquakes. Specifically, the licensee failed to establish appropriate shutdown criteria for earthquakes that exhibit ground motion exceeding the OBE.

Description.

On July 20, 2015, the inspectors performed a review of the Columbia Generating Station seismic instrumentation and monitoring (SEIS) system. The SEIS system, described in the Final Safety Analysis Report, Section 3.7.4, "Seismic Instrumentation," consists of multiple passive and active subsystems used to record earthquake ground motion and to alert plant operators that design response spectra have been exceeded. One of those subsystems are the triaxial response-spectrum recorders used for comparison of measured and predicted earthquake responses. Final Safety Analysis Report, Section 3.7.4.4 provides guidance that if an earthquake is felt in the control room and the spectra experienced at the foundation of the reactor building exceeds the OBE acceleration levels as indicated on two or more response spectra indicating lights, the plant will be shut down pending permission to resume operations.

The shutdown criteria in abnormal procedure "ABN-Earthquake," Revisions 0-13, reflected the shutdown criteria found in FSAR Section 3.7.4.4. The inspectors questioned the need for two or more response spectra indicating lights to indicate that operating basis earthquake acceleration levels were exceeded prior to initiating a plant shutdown. The inspectors reviewed 10 CFR Part 100, Appendix A, which states, in part, that if vibratory ground motion exceeding that of the OBE occurs, shutdown of the nuclear power plant will be required. The inspectors determined that the licensee's shutdown criteria in Final Safety Analysis Report, Section 3.7.4.4 and incorporated into abnormal procedure "ABN-Earthquake" was contrary to 10 CFR Part 100, Appendix A. Specifically, the licensee's shutdown criteria would allow for continued operations if ground motion at a single frequency exceeded the design response spectrum. The inspectors reviewed historical licensing basis for Columbia Generating Station and found that FSAR Amendment 33, in effect when the full power operating license was issued for the station, provided the following: If the Instrumentation shows that the peak acceleration or the response spectra experienced at the foundation of the reactor building exceeds the operating basis earthquake acceleration levels or response spectra, the plant will be shut down pending permission to resume operations. The inspector discovered that the licensee changed FSAR Section 3.7.4.4 under licensing document change notice LDCN 96-079, dated December 12, 1996. This LDCN's purpose was to "strike a balance between ensuring that actions are not taken on a spurious signal and taking conservative actions following an earthquake." The inspectors agreed that shutdown of the plant due to a spurious signal was not desirable but that in the case of a single, valid indication that the OBE design response spectra was exceeded, shutdown of the nuclear power plant was required. The inspectors determined that the change implemented in LDCN 96-079 resulted in a non-conservative shutdown criteria compared to the regulatory requirements in 10 CFR Part 100, Appendix A. In response to this issue, the licensee initiated corrective actions to change abnormal procedure ABN-Earthquake to provide a shutdown criteria consistent with the original licensing basis of the facility. The licensee entered this issue into their corrective action program as AR 336875.

Analysis.

The failure to establish appropriate shutdown criteria in abnormal procedures for earthquakes was a performance deficiency. The performance deficiency was more than minor because it affected the procedural adequacy attribute of the Mitigating Systems Cornerstone objective 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, the performance deficiency resulted in shutdown criteria that would allow for continued operations following events where ground motion at a single frequency exceeded the design response spectra. NRC regulations require a plant shutdown since systems necessary for continued operation without undue risk to the health and safety of the public are not designed to remain functional, in all cases, following an OBE. The inspector performed the initial significance determination using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions." The inspectors determined that the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Additionally, the finding did not involve the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding, or severe weather initiating event.

The finding does not have a cross-cutting aspect since the procedure error is associated with a 1996 change to the licensing basis and therefore not reflective of current licensee performance.

Enforcement.

Technical Specification 5.4.1.a, "Procedures," requires, in part, that written procedures be established, implemented, and maintained as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, dated February 1978. Paragraph 6.w. of Regulatory Guide 1.33, Appendix A, requires specific procedures for acts of Nature (e.g., tornado, flood, dam failure, earthquakes). Licensee Procedure ABN-Earthquake, "Earthquake", Revision 0-13, is a procedure, required by Paragraph 6.w. of Regulatory Guide 1.33, Appendix A for earthquakes. Contrary to the above, from August 8, 2005 to the present, the licensee failed to maintain an adequate procedure as recommended in Regulatory Guide 1.33, Revision 2, Appendix A, Paragraph 6.w. Specifically, the shutdown criteria specified in Step 4.4 of procedure ABN-Earthquake, Revisions 0-13 was non-conservative relative to the shutdown criteria in 10 CFR 100, Appendix A because it would allow for continued operations if ground motion at a single frequency exceeded the design response spectrum. The licensee initiated corrective actions to change abnormal procedure ABN-Earthquake to provide a shutdown criteria consistent with the original licensing basis of the facility. Because this finding is of very low safety significance and entered into the licensee's corrective action program as Action Request 336875, the violation is being treated as a non-cited violation consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000397/2015003-02, Non-Conservative Shutdown Criteria in Earthquake Abnormal Procedure)

===.3 Failure to Provide Design Control Measures for Control Room Emergency Chillers

Introduction.

=

The inspectors identified a Green, non-cited violation of 10 CFR 50, Appendix B, Criterion III, "Design Control," for the licensee's failure to verify the adequacy of the design of the control room HVAC system. Specifically, the licensee failed to demonstrate the ability of control room HVAC design to maintain the temperatures in the main control room below habitability and environmental qualification limits, for the duration of all accident scenarios.

Description.

On July 2, 2015, the inspectors performed a review of the control room HVAC system with a focus on the control room emergency chillers. The Final Safety Analysis Report, Section 9.4.1.1, "Design Basis" states, in part, that the design of the control room HVAC system is such that in an emergency condition, "the control room temperature will be maintained within the habitability limit (85°F) by the control room chilled water. Service water can maintain the control room temperature limit of 85°F during colder weather. Service water will maintain the control room within the environmental qualification temperature limit for control room equipment (104°F)."

The inspectors noted that the vendor manuals for the control room emergency chillers described an automatic trip feature that required local resetting. Specifically, the manufacturer states the following in the "Normal Operating Sequence" section of the manual: Shutdown where the unit cannot automatically restart-Shutdown on a power failure produces the same results as for a safety shutdown except relay 14R is de-energized-It is necessary to depress the "STOP-RESET" button to energize relay 14R when power is restored after interruption. The inspectors reviewed relevant electrical diagrams and confirmed that operation of the control room emergency chillers required a local reset of relay 14R following a loss of power. The alignment of the control room HVAC system is such that the division 1 air handling unit, WMA-AH-51A, is aligned to standby service water and the division 2 air handling unit, WMA-AH-51B, is aligned to chill water. Because of the design feature involving the relay 14R and the alignment of the air-handling units, the inspectors identified that: 1) Following any event that resulted in a loss of offsite power with a single-failure of the Division 1 emergency diesel generator, the control room would not receive cooling via WMA-AH-51B, the only operable air handling unit, until the local chiller reset pushbutton was depressed. The control room would remain without cooling until this manual reset was accomplished since relay 14R would be de-energized. 2) Following certain events involving a loss of offsite power with a single-failure of the Division 2 emergency diesel generator, the control room would experience reduced, and in some instances, no external cooling. In particular, when ambient conditions would not allow service water alone to maintain the control room below the 85°F habitability limit, operators would be prompted to secure standby service water cooling to WMA-AH-51A and realign cooling from the control room emergency chillers system. The inspectors noted that during the shift between standby service water and control room emergency chill water, there would be a brief period when the control room would receive no external cooling.

For each of the above scenarios, temperatures in the control room could exceed 85°F or 104°F due to times necessary for system realignment or local resetting manual actions. At the time of the inspection, procedure OI-69, "Time Critical Operator Actions," Revision 5, did not identify any required manual actions associated with local reset or realignment of the control room HVAC system. This procedure defines a time critical action as a manual action, or series of actions that must be completed within a specified time to meet the plant-licensing basis.

The inspectors reviewed calculation ME-02-92-43, "Room Temperature Calculation for DG Building, Reactor Building, Radwaste Building, and Service Water," Revision 10, and noted that this calculation covers the control room air-handling units but only considers steady-state conditions for heat exchanger performance. There is no discussion in ME-02-92-43 for transient scenarios where the control room would receive no external cooling, such as those involving local resetting of control room emergency chillers or during required shifts between standby service water and control room emergency chill water.

The inspectors requested a design analysis that demonstrated the ability of control room HVAC design to maintain the temperatures in the main control room below habitability and environmental qualification limits during these transient situations. The licensee was unable to locate a design verification that demonstrated the ability of the control room HVAC system during transient scenarios following a loss of power and could not determine the peak control room temperature nor the impact to habitability or equipment qualification in these scenarios. The inspectors reviewed previous inspection reports for the station and noted one related finding: NRC-identified NCV 05000397/2013002-04, "Failure to Obtain NRC Approval for Changes to Control Room HVAC Requirements." This NCV identified an incorrect value for the control room temperature limit and resulted in the current value as found in the licensee's design basis. The inspectors determined that the extent of condition review from this 2013 finding did not adequately consider the effects of lowering a design habitability temperature for the control room from 104°F to 85°F, necessitating the need for the control room emergency chillers. Specifically, when evaluating the correct habitability limit of 85°F, the licensee only considered the steady state cooling needs of the control room and not the transient effects experienced because of the chiller design. In response to the NRC's conclusions, the licensee initiated Action Request 332565 to document the concern, issued night order 1662 to communicate the issue, aligned both control room air handling units to their respective chillers, created a quick card procedure to perform the chiller reset actions, and validated the quick card actions could be accomplished within 10 minutes. Additionally, the licensee determined that operators could restore the chillers during accident conditions within 90 minutes to prevent temperatures from exceeding equipment operability limits.

Analysis.

The failure to provide design control measures to verify the adequacy of the design of the control room emergency chillers was a performance deficiency. The performance deficiency was more than minor because it adversely affected the design control attribute of the Mitigating Systems Cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to demonstrate the ability of control room HVAC design to maintain the temperatures in the main control room below habitability and environmental qualification limits, for the duration of all accident scenarios. Using NRC Inspection Manual Chapter 0609, Appendix A, Exhibit 2, "Mitigating Systems Screening Questions," the inspectors determined the finding was of very low safety significance because (1) the finding was not a deficiency affecting the design or qualification of a mitigating system; (2) the finding did not represent a loss of system and/or function; (3) the finding did not represent an actual loss of function of a single train for greater than its technical specification allowed outage time; and (4) the finding does not represent an actual loss of function of one or more non-technical specification trains of equipment designated as high safety-significant in accordance with the licensee's maintenance rule program for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This finding had a cross-cutting aspect in the area of problem identification and resolution, evaluation, in that the licensee did not thoroughly evaluate issues to ensure that resolutions address causes and extent of conditions commensurate with their safety significance. Specifically, the licensee did not thoroughly evaluate the extent of condition from NRC-identified NCV 05000397/2013002-04, "Failure to Obtain NRC Approval for Changes to Control Room HVAC Requirements," for the effect of this change on other station calculations [P.2].

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion III, "Design Control," requires, in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Final Safety Analysis Report, Section 9.4.1.1, "Design Basis," established the design of the control room HVAC system and specified, in part, that during emergency conditions, the control room temperature will be maintained within the habitability limit (85°F) by the control room chilled water. Service water can maintain the control room temperature limit of 85°F during colder weather. Service water will maintain the control room within the environmental qualification temperature limit for control room equipment (104°F). Contrary to the above, prior to July 2, 2015, the licensee failed to implement design control measures for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program. Specifically, the licensee failed to verify the adequacy of the design of the control room emergency chillers involving loss of offsite power scenarios that result in transient losses of control room cooling such that the design basis, established in Final Safety Analysis Report, Section 9.4.1.1 was ensured. The licensee initiated Action Request 332565 to document the concern, issued night order 1662 to communicate the issue, aligned both control room air handling units to their respective chillers, created a quick card procedure to perform the chiller reset actions, and validated the quick card actions could be accomplished within 10 minutes. Because the finding is of very low safety significance (Green) and has been entered into the licensee's corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. (NCV 05000397/2015003-03, Failure to Provide Design Control Measures for Control Room Emergency Chillers)

1R05 Fire Protection

Main article: IP 71111.05

.1 Quarterly Inspection

a. Inspection Scope

The inspectors evaluated the licensee's fire protection program for operational status and material condition. The inspectors focused their inspection on four plant areas important to safety: July 1, 2015, Fire Areas RC-4, 5, 6, 7, 8, and 9 and RC-14, radioactive waste building 467' elevation vital island July 14, 2015, Fire Area R-8, low pressure core spray pump room July 15, 2015, Fire Area RC-11, 12 and 13, radioactive waste building 525' elevation August 13, 2015, Fire Area R-5, residual heat removal train A pump room For each area, the inspectors evaluated the fire plan against defined hazards and defense-in-depth features in the licensee's fire protection program. The inspectors evaluated control of transient combustibles and ignition sources, fire detection and suppression systems, manual firefighting equipment and capability, passive fire protection features, and compensatory measures for degraded conditions. These activities constituted four quarterly inspection samples, as defined in Inspection Procedure 71111.05.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

a. Inspection Scope

On July 21, 2015, the inspectors completed an inspection of underground bunkers susceptible to flooding. The inspectors selected one underground vault, electrical manhole E-MH-08, that contained risk-significant or multiple-train cables whose failure could disable risk-significant equipment. The inspectors observed the material condition of the cables and splices contained in the bunkers vaults and looked for evidence of cable degradation due to water intrusion. The inspectors verified that the cables and vaults met design requirements. These activities constitute completion of one bunker/manhole sample, as defined in Inspection Procedure 71111.06.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

Main article: IP 71111.11

.1 Review of Licensed Operator Requalification

a. Inspection Scope

On July 29, 2015, the inspectors observed an evaluated simulator scenario performed by an operating crew. The inspectors assessed the performance of the operators and the evaluators' critique of their performance. The inspectors also assessed the modeling and performance of the simulator during the requalification activities.

These activities constitute completion of one quarterly licensed operator requalification program sample, as defined in Inspection Procedure 71111.11.

b. Findings

No findings were identified.

.2 Review of Licensed Operator Performance

a. Inspection Scope

On August 5, 2015, the inspectors observed the performance of on-shift licensed operators in the plant's main control room. At the time of the observations, the plant was in a period of heightened risk due to an unplanned orange risk window for Bonneville Power Administration's emergent work on the 230 kV switchyard. The inspectors observed the operators' performance of the following activities: Leak repair on the digital electro-hydraulic system under WO 02086051, including the pre-job brief In addition, the inspectors assessed the operators' adherence to plant procedures, including procedure PPM 1.3.1, "Operating Policy, Programs, and Practices," Revision 119 and other operations department policies.

These activities constitute completion of one quarterly licensed operator performance sample, as defined in Inspection Procedure 71111.11.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the licensee's failure to ensure operators could perform time-critical steps for fire events. Specifically, the licensee failed to implement written procedures to ensure that Category 2 personnel, needed for post-fire safe shutdown, can complete required actions within 10 minutes.

Description.

During a log review, the inspectors identified that an equipment operator (OPS3) left the protected area (PA) to compile equipment logs on July 4, 2015, at 8:57 AM and again at 4:37 PM. Licensee procedure PPM 1.3.1, "Operating Policy, Programs, and Practices," Revision 119, classifies watch positions as either Category 1 or Category 2. Category 1 personnel include the shift technical advisor (STA) and emergency action level notifier. Category 2 personnel include the shift manager (SM), all three reactor operators, the control room supervisor (CRS), and the OPS2 and OPS3 equipment operator positions. Procedure PPM 1.3.1 states that while Category 1 personnel may leave the PA with a risk evaluation and permission of the shift manager, Category 2 personnel "should not leave the protected area unless an emergent condition is jeopardizing the plant" and they "respond to an event that requires action within 10 minutes." The OPS3 equipment operator is a Category 2 watchstander because in the event of a control room fire, they must trip the condensate and condensate booster pumps within 10 minutes. These actions are proceduralized in ABN-CR-EVAC, "Control Room Evacuation and Remote Cooldown," Revision 33. The inspectors questioned the ability of OPS3 to move from outside the PA to their required station in a timely manner. The inspectors noted that the licensee performed a timed walkthrough of post-fire safe-shutdown actions for OPS3 for a similar issue in 2014. Specifically, the evaluation for NRC-identified NCV 05000397/2014003-02, "Failure to Implement Procedures That Ensure Operators Could Perform Time Critical Steps for Fire Events" concluded that OPS3 was not able to complete certain post-fire safe-shutdown actions within 10 minutes when initially located outside the PA. Instead, the equipment operator completed the required actions within 11 minutes and 33 seconds. The inspectors determined that this previous walkthrough from 2014 is representative of the issue identified on July 4, 2015 and no additional timed walkthrough was required. The inspectors concluded that by allowing Category 2 personnel to leave the PA, the licensee had not preserved the assumptions of available personnel in ABN-CR-EVAC to reach safe-shutdown conditions for a control room fire. Therefore, the licensee was not implementing written procedures for plant fires and responsibilities for safe operation as required by Technical Specification 5.4.1.a through Appendix A of Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation)," Revision 2.

In response to this conclusion, the licensee initiated AR 332747 to document the inability to meet the post-fire safe-shutdown actions in accordance with procedure PPM 1.3.1. Additionally, the licensee issued Night Order 1655, reminding all operating crews of the requirements of procedure PPM 1.3.1 for leaving the PA. Through interviews, the licensee determined that the equipment operator discussed the need to leave the PA with the STA. Neither individual, however, discussed the situation with CRS, SM, or reviewed the relevant PPM 1.3.1 procedure.

Analysis.

The failure to implement written procedures to ensure that Category 2 personnel can complete certain post-fire safe-shutdown actions within 10 minutes was a performance deficiency. This performance deficiency was more than minor because it was associated with the protection against external factors attribute of the Mitigating System Cornerstone and affected the cornerstone's objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by allowing Category 2 personnel to leave the protected area, the licensee had not preserved the assumptions of available personnel in ABN-CR-EVAC to reach safe-shutdown conditions for a control room fire. The inspectors screened the finding in accordance with NRC Manual Chapter IMC 0609, Attachment 4, "Initial Characterization of Findings." In table 3, the inspectors answered "yes" to question E.2 because the finding affects the ability to reach and maintain safe shutdown conditions in case of a fire. Therefore, to assess this finding, a senior reactor analyst used NRC IMC 0609, Appendix F, "Fire Protection Significance Determination," dated September 20, 2013. The analyst noted that the degradation rating examples in Attachment 2 of that appendix were not well suited for this finding. Therefore, the analyst used the generic guidance from NRC IMC 0308, Attachment 3, Appendix F, "Technical Basis Fire Protection Significance Determination Process (Supplemental Guidance for Implementing IMC 0609, Appendix F) At Power Operations," dated February 28, 2005. This guidance stated, in part: -the definition of "low degradation" implies that the performance and/or reliability of the fire protection feature is not substantially impacted by the noted degradation finding. Hence, the feature would be given essentially full credit in the PRA-based analysis. In this case, the risk change is essentially zero, and the finding should be screened to Green.

For this finding, procedure ABN-CR-EVAC directed operator OPS3 to trip the condensate and condensate booster pumps within 10 minutes, but due to this finding, that action could be delayed to the 11.5 minute point. The subject action was intended to prevent taking the plant to a "solid" (completely filled) condition. However, the analyst noted that the failure to take this action would not increase the core damage probability (overfilling events at boiling water reactors soon after shutdown should not drive core damage and are not included in the probabilistic risk assessment model). Instead, this action is a desired step that was intended to establish positive control over reactor vessel pressure and level. In addition, the exposure period for this finding was very short (less than one day). Since the failure to perform this action within 10 minutes would not adversely affect a quantitative assessment, this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Teamwork, because the licensee failed to communicate and to coordinate their activities within and across organizational boundaries to ensure nuclear safety is maintained. Specifically, the equipment operator spoke with the STA about the need to exit the PA at the morning turnover meeting but neither individual spoke with the CRS. Communication was ineffective in that the equipment operator believed permission was granted and proceeded to exit the PA [H.4].

Enforcement.

Technical Specification 5.4.1.a, "Procedures" requires, in part, that written procedures shall be established, implemented, and maintained for activities described in Appendix A of the Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A, Section 1.b requires administrative procedures for authorities and responsibilities for safe operation and shutdown. Licensee procedure PPM 1.3.1, "Operating Policy, Programs, and Practices," Revision 119, a procedure required by Section 1.b of Regulatory Guide 1.33, Appendix A, establishes authorities and responsibilities for safe operation and shutdown, and states that Category 2 personnel should not leave the protected area unless an emergent condition is jeopardizing the plant and they respond to an event that requires action within 10 minutes. Contrary to this requirement, on July 4, 2015, Category 2 personnel (i.e., an equipment operator) left the protected area when no emergent condition jeopardizing the plant existed and therefore was unable to respond to an event that requires action within 10 minutes.

Specifically, the operator would not be able to complete certain time-critical operator actions associated with fire events as required by procedure ABN-CR-EVAC, "Control Room Evacuation and Remote Cooldown," Revision 33.

The licensee initiated Action Request 332747 to document the non-compliance with PPM 1.3.1. Additionally, the licensee issued Night Order 1655 reminding all operating crews of the requirements of PPM 1.3.1 for leaving the Protected Area. Because this violation was of very low safety significance and was entered into the licensee's corrective action program, this violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000397/2015003-04, Failure to Implement Procedures to Ensure Availability of Safe Shutdown Personnel)

1R12 Maintenance Effectiveness

Main article: IP 71111.12

a. Inspection Scope

The inspectors reviewed two instances of degraded performance or condition of safety-related structures, systems, and components (SSCs): July 10, 2015, system review of control room emergency chillers including maintenance history of system rupture discs September 10, 2015, main steam level indicating switches including maintenance history involving internal binding failures documented in AR 332078 The inspectors reviewed the extent of condition of possible common cause SSC failures and evaluated the adequacy of the licensee's corrective actions. The inspectors reviewed the licensee's work practices to evaluate whether these may have played a role in the degradation of the SSCs. The inspectors assessed the licensee's characterization of the degradation in accordance with 10 CFR 50.65 (the Maintenance Rule), and verified that the licensee was appropriately tracking degraded performance and conditions in accordance with the Maintenance Rule.

These activities constituted completion of two maintenance effectiveness samples, as defined in Inspection Procedure 71111.12.

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

Main article: IP 71114.06

No findings were identified.

2RS7 Radiological Environmental Monitoring Program

Main article: IP 71124.07

a. Inspection Scope

The inspectors evaluated whether the licensee's radiological environmental monitoring program quantified the impact of radioactive effluent releases to the environment and sufficiently validated the integrity of the radioactive gaseous and liquid effluent release program. The inspectors verified that the radiological environmental monitoring program was implemented consistent with the licensee's technical specifications and offsite dose calculation manual, and that the radioactive effluent release program met the design objective in Appendix I to 10 CFR Part 50. The inspectors verified that the licensee's radiological environmental monitoring program monitored non-effluent exposure pathways, was based on sound principles and assumptions, and validated that doses to members of the public were within regulatory dose limits. The inspectors reviewed or observed the following items: Annual environmental monitoring reports and offsite dose calculation manual Selected air sampling and dosimeter monitoring stations Collection and preparation of environmental samples Operability, calibration, and maintenance of meteorological instruments Selected events documented in the annual environmental monitoring report which involved a missed sample, inoperable sampler, lost dosimeter, or anomalous measurement Selected structures, systems, or components that may contain licensed material and has a credible mechanism for licensed material to reach ground water Records required by 10 CFR 50.75(g)

Significant changes made by the licensee to the offsite dose calculation manual as the result of changes to the land census or sampler station modifications since the last inspection Calibration and maintenance records for selected air samplers, composite water samplers, and environmental sample radiation measurement instrumentation Inter-laboratory comparison program results Audits, self-assessments, reports, and corrective action documents related to the radiological environmental monitoring program since the last inspection These activities constitute completion of one sample of radiological environmental monitoring program as defined in Inspection Procedure 71124.07.

b. Findings

No findings were identified.

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation

Main article: IP 71124.08

a. Inspection Scope

The inspectors evaluated the effectiveness of the licensee's programs for processing, handling, storage, and transportation of radioactive material. The inspectors interviewed licensee personnel and reviewed the following items: The solid radioactive waste system description, process control program, and the scope of the licensee's audit program Control of radioactive waste storage areas including container labeling/marking and monitoring containers for deformation or signs of waste decomposition Changes to the liquid and solid waste processing system configuration including a review of waste processing equipment that is not operational or abandoned in place Radio-chemical sample analysis results for radioactive waste streams and use of scaling factors and calculations to account for difficult-to-measure radionuclides Processes for waste classification including use of scaling factors and 10 CFR Part 61 analysis Shipment packaging, surveying, labeling, marking, placarding, vehicle checking, driver instructing, and preparation of the disposal manifest Audits, self-assessments, reports, and corrective action reports radioactive solid waste processing, and radioactive material handling, storage, and transportation performed since the last inspection These activities constitute completion of one sample of radioactive solid waste processing, and radioactive material handling, storage, and transportation as defined in Inspection Procedure 71124.08.

b. Findings

Introduction.

The inspectors reviewed a Green, self-revealing, non-cited violation of Technical Specification 5.4.1.a, "Procedures," for the licensee's failure to follow their Process Control Program as implemented by their solid radioactive waste system procedures. The licensee shipped a radioactive shipment of condensate filter demineralizer resin waste for disposal to US Ecology of Washington with free standing liquid in excess of 0.5 percent of the total waste volume.

Description.

On August 11, 2014, the licensee completed dewatering and drying of resin for a condensate demineralizer filter waste liner (14-033-L). On October 9, 2014, radioactive waste liner 14-033-L was shipped to US Ecology for disposal at their low level radioactive waste burial site near Richland, Washington. The liner was part of radioactive waste shipment #14-32 and manifested as a Class A Unstable waste form. On October 23, 2014, liner 14-033-L was randomly selected by the burial site for inspection to ensure compliance with the disposal site's license conditions. US Ecology punctured the bottom of the liner and determined that the liner contained free standing liquid, as evidenced by a slurry mix (150 ml) that drained from the puncture hole. On October 27, 2014, US Ecology continued their inspection of liner 14-033-L by fully opening the liner lid and sampling for additional free standing liquid. The inspection results revealed that over 8.5 gallons of free standing liquid was contained within the liner. This represented approximately 0.75 percent of the total waste volume (1132 gallons) and was in excess of the 0.5 percent free standing liquid requirement for unstable waste form. US Ecology contacted the licensee and informed them of the burial site noncompliance.

The licensee retrieved the packages (i.e., liners) contained in shipment #14-32 from US Ecology. Each liner was then tested for free standing liquid content and additional water was removed as necessary. This issue was entered into the licensee's corrective action program as Action Request 00316676, and an apparent cause evaluation was performed. The inspectors reviewed selected licensee, vendor, and burial site information related to this issue and interviewed selected knowledgeable plant staff. The inspectors determined that the licensee failed to maintain the appropriate operating procedures and dewatering components for the resin drying and dewatering system used for the condensate filter demineralizer waste liners. Specifically, in 1999 and 2012, changes were made to the Process Control Program via modifications to the resin drying system process. These modifications were different from the approved operations and specifications under NRC-approved Topical Report, TP-02-P-A, "Covering Nuclear Packaging, Inc. Dewatering System," approved September 6, 1985. In 1999, the specific change made was to open the valve to the lowest set of filter laterals in order to allow the use of these filters throughout the dewatering process for the condensate filter demineralizers. In 2011, following a condenser change-out, the carbon steel components of the new condenser introduced iron oxide into the resin drying system.

This high iron oxide content coated the bottom filter laterals in the resin drying system and caused discoloration of the resin water. In 2012, additional changes to the Process Control Program instructed the resin drying system operators to declare the bottom filter laterals as damaged if they saw a discoloration in the resin drying system viewing window. These changes were not in accordance with vendor specifications.

The inspectors determined that the licensee performed an inadequate technical review for the resin drying and dewatering system when changes were made to the Process Control Program. Additionally, the inspectors reviewed the 10 CFR 50.59 screening, dated July 6, 2010, and determined that the licensee performed an inadequate technical review to assess potential adverse impacts of the condenser change-out on the plant's radioactive waste processing system. Consequently, the inspectors concluded that between 1999 and 2013, the licensee failed to maintain the vendor procedures and appropriate design margins for the resin drying system. This resulted in inadequate dewatering of the resin for condensate filter demineralizers in liner 14-033-L.

Analysis.

The failure to follow the Process Control Program, resulting in the inadequate dewatering of radioactive waste liner contents, was a performance deficiency. Inspectors determined that the performance deficiency was more than minor, because it adversely affected the Public Radiation Safety cornerstone objective to ensure adequate protection of public health and safety from exposure to radioactive materials released in the public domain. Specifically, the failure to ensure that the free standing liquid in the radioactive waste liner shipped to US Ecology did not exceed 0.5 percent of the total waste volume subjected the disposal facility to the possibility of improper handling of the waste. Using Inspection Manual Chapter 0609, Appendix D, "Public Radiation Safety Significance Determination Process," dated February 12, 2008, the inspectors determined the violation was of very low safety significance (Green) because: (1) radiation limits were not exceeded, (2) there was no breach of the package during transit, (3) there were no Certificate of Compliance issues, and (4) the low level burial ground nonconformance did not involve a 10 CFR 61.55 waste under classification. The inspectors determined that the finding has a design margin cross-cutting aspect in the area of human performance, because the licensee failed to operate and maintain the radioactive waste dewatering system within the vendor design margins when changes were made to the operating procedures [H.6].

Enforcement.

Technical Specification 5.4.1.a, "Procedures," requires, in part, that written procedures be established, implemented, and maintained for activities described in Regulatory Guide 1.33, "Quality Assurance Program Requirements," Revision 2, Appendix A, dated February 1978. Regulatory Guide 1.33, Section 7.b.(2) requires procedures for the Solid Waste System - Spent Resins and Filter Sludge Handling. The licensee's Process Control Program procedure, SWP-RMP-02, "The Radioactive Waste Process Control Program," implements this requirement. Section 2.2.1.a of Procedure SWP-RMP-02, Revision 5, states, in part, that "The [resin dewatering and drying]

process is designed to reduce the free water, by disposal package volume, to less than - 0.5 percent when waste is packaged in an unstable waste form." Contrary to the above, on August 11, 2014, the licensee's resin dewatering and drying process failed to reduce the free water, by disposal package volume, to less than 0.5 percent when waste was packaged in an unstable waste form. Specifically, condensate filter demineralizer resin liner 14-033-L contained approximately 0.75 percent free standing liquid when it was received by US Ecology for disposal. Corrective actions included retrieving the packages from waste shipment (#14-32), and testing each liner for free standing liquid content, removing additional water as necessary. Because this violation is of very low safety significance and has been entered into the licensee's corrective action program as Action Request 00316676, it is being treated as a NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000397/2015003-05, Failure to Reduce the Free Water in a Class A Unstable Resin Disposal Package to Less than 0.5 Percent of Waste Volume)

OTHER ACTIVITIES

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency Preparedness, Public Radiation Safety, Occupational Radiation Safety, and Security

4OA1 Performance Indicator Verification

.1 (Closed) Licensee Event Report 05000397/2015-002-00, "Inadequately Fused Non- Class 1E Circuit on Division 1 120/240 VAC Bus"

On April 29, 2015, the licensee determined that Division 1 120/240 VAC vital instrumentation bus was inadequately protected for all conditions. Specifically, the Class 1E electrical panel E-PP-7AA did not have adequate electrical separation for scenarios involving a loss of offsite power coincident with a short circuit in a Non-Class 1E cooling fan. This issue was dispositioned as a licensee identified violation in Section

4OA7 of NRC Integrated Inspection Report 05000397/2015002, dated August 7, 2015 (ML15219A143).

No additional performance deficiencies were identified. This licensee event report is closed.

.2 (Closed) Licensee Event Report 05000397/2015-003-00, "Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2" During Refueling Outage 22 in May - June 2015, Columbia Generating Station implemented the guidance of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2, "Dispositioning Boiling Water Reactor Licensee Noncompliance with Technical Specification Containment Requirements during Operations with a Potential for Draining the Reactor Vessel," dated December 13, 2013.

Consistent with EGM 11-003, Revision 2, secondary containment operability was not maintained during operations with a potential for draining the reactor vessel activities, and required action C.2 of Technical Specification 3.6.4.1 was not completed. The inspectors reviewed this licensee event report for potential performance deficiencies and violations of regulatory requirements. The inspectors reviewed the station's implementation of the EGM 11-003, Revision 2, during operations with a potential for draining the reactor vessel. Specific observations included:

1. The inspectors observed that the operations logged all potential for draining the reactor vessel activities in the control room narrative logs, and that the log entry

appropriately recorded the standby source of makeup designated for the evolutions. 2. The inspectors noted that the licensee maintained reactor vessel water level at least greater than 21 feet above the top of the reactor pressure vessel flange as required by Technical Specification 3.9.6. The inspectors also verified that at least one safety-related pump was the standby source of makeup designed in the control room narrative logs for the evolutions. The inspectors confirmed that the worst case estimated time to drain the reactor cavity to the reactor pressure vessel flange was greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 3. The inspectors verified that the operations with a potential for draining the reactor vessels were not conducted in Mode 4 and that the licensee did not move irradiated fuel during the operations with a potential for draining the reactor vessels. The inspectors verified that two independent means of measuring reactor pressure vessel water level were available for identifying the onset of loss of inventory events. Technical Specification 3.6.4.1, "Secondary Containment" requires, in part, that secondary containment shall be operable during operations with a potential for draining the reactor vessel. Technical Specification 3.6.4.1, Condition C, requires the licensee to initiate actions to suspend operations with a potential for draining the reactor vessel immediately when secondary containment is inoperable. Contrary to the above, from May 13 - June 13, 2015, Columbia Generating Station performed a total of five operations with a potential for draining the reactor vessel activities while in Mode 5 without an operable secondary containment. These conditions were reported as conditions prohibited by Technical Specifications. The licensee entered this issue into its corrective action program as Action Request 329328. Since this violation occurred during the discretion period described in EGM 11-003, Revision 2, the NRC is exercising enforcement discretion in accordance with Section 3.5, "Violations Involving Special Circumstances," of the NRC Enforcement Policy, and, therefore, will not issue enforcement action for this violation. In accordance with EGM 11-003, Revision 2, each licensee that receives discretion must submit a license amendment request (LAR) to resolve the issue for its plant which the NRC staff LAR acceptance review finds acceptable in accordance with LIC-109, "Acceptance Review Procedures." The generic solution will be a generic change to the Standard Technical Specifications, and the NRC will publish a notice of availability (NOA) for the TS solution in the Federal Register. Each licensee that receives discretion must submit its amendment request within 12 months of the NRC staff's issuance of the NOA.

Licensees may submit LARs to adopt the NRC-approved approach or to propose an alternative approach for their plants. This licensee event report is closed.

.3 (Closed) Licensee Event Report 05000397/2015-004-00, "Unplanned Loss of 4.16KV Bus 7 Switchgear" Revision 0

On May 22, 2015, the licensee momentarily lost the division 1 vital bus, SM-7, due to a human performance error during maintenance. Specifically, a licensee electrician connected a multi-meter test lead to the wrong port on the instrument which caused an electrical short on SM-7. The SM-7 bus automatically divorced from the startup transformer due to a sensed phase-to-phase short, the short was isolated by a blown fuse, and SM-7 was rapidly repowered by the backup transformer via automatic transfer. The division 1 emergency diesel generator also auto-started from the loss of SM-7 and was secured. At the time of this transient, the plant was in a refueling outage in Mode 5 and crediting division 2 components for safety functions. The inspectors reviewed the licensee event report associated with this event and determined that the report adequately documented the summary of the event including the cause of the event and potential safety consequences. Required components for electrical power, inventory control, and decay heat removal were available and not challenged during the transient. Since this human performance error occurred while the plant was shutdown with division 1 components inoperable for testing, the inspectors did not identify any more than minor performance deficiencies. This licensee event report is closed. These activities constitute completion of three event follow-up samples, as defined in Inspection Procedure 71153.

4OA6 Meetings, Including Exit Exit Meeting Summary On September 24, 2015, the inspectors presented the radiation safety inspection results to Mr. W.G. Hettel, Chief Operating Officer and Chief Nuclear Officer, and other members of the licensee staff.

The inspection results were re-exited telephonically on October 7, 2015, to update the licensee on enforcement specifics of the non-cited violation. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed. On October 1, 2015, the inspectors presented the inspection results to Mr. W.G. Hettel, Chief Operating Officer and Chief Nuclear Officer, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.

A-1 Attachment

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

S. Abney, Assistant Manager, Operations

P. Allen, System Engineer, System Engineering

D. Brown, Manager, System Engineering

S. Clizbe, Manager, Emergency Preparedness

M. Davis, Manager, Chemistry/Radiation Protection

E. Dumlao, Senior Engineer

D. Gregoire, Manager, Regulatory Affairs

J. Hauger, System Engineering

G. Hettel, Chief Nuclear Officer and Chief Operating Officer

G. Higgs, Manager, Maintenance

M. Hummer, Licensing Engineer

A. Javorik, Vice President, Engineering

M. Laudisio, Manager, Radiation Protection

C. Moon, Manager, Quality

R. Prewett, Plant General Manager

G. Pierce, Manager, Training

A. Rice, Manager, Chemistry

B. Schuetz, Vice President, Operations

D. Stevens, Operations Manager

G. Strong, Electrical Design Supervisor

D. Suarez, Regulatory Compliance Engineer

J. Tansy, Reactor Engineering Supervisor

J. Trautvetter, Compliance Supervisor, Regulatory Affairs

L. Williams, Licensing Supervisor

D. Wolfgramm, Compliance Engineering

NRC Personnel

G. Replogle, Senior Reactor Analyst

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000397/2015003-01 FIN Failure to Maintain Seismic Instrumentation Functional to Alert Plant Operators of Ground Motions Exceeding the Operating Basis Earthquake (Section 1R04)

05000397/2015003-02 NCV Non-Conservative Shutdown Criteria in Earthquake Abnormal Procedure (Section 1R04)

05000397/2015003-03 NCV Failure to Provide Design Control Measures for Control Room Emergency Chillers (Section 1R04)

05000397/2015003-04 NCV Failure to Implement Procedures to Ensure Availability of Safe Shutdown Personnel (Section 1R11)

Opened and Closed

05000397/2015003-05 NCV Failure to Reduce the Free Water in a Class A Unstable Resin Disposal Package to Less than 0.5 Percent of Waste Volume (Section 2RS8)

Closed

05000397/LER-2015-002-00 LER Inadequately Fused Non- Class 1E Circuit on Division 1 120/240 VAC Bus (Section 4OA3)

05000397/LER-2015-003-00 LER Implementation of Enforcement Guidance Memorandum (EGM) 11-003, Revision 2 (Section 4OA3)

05000397/LER-2015-004-00 LER Unplanned Loss of 4.16KV Bus 7 Switchgear (Section 4OA3)

LIST OF DOCUMENTS REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

Number Title Revision

ABN-WIND Tornado/High Winds 27

SOP-HOTWEATHER-OPS Hot Weather Operations 6

SOP-WARMWEATHER-OPS Warm Weather Operations 11

SOP-SW-LU Standby Service Water System Valve & Breaker Lineup 6

Action Requests

(ARs)

293549

293878

299646

300923

300999

304714

308167

312775

333418 334819

Section 1R04: Equipment Alignment

Procedures

Number Title Revision 1.3.66 Operability and Functionality Evaluation 32 5.0.12 Station Blackout and Extended Loss of AC Power Basis 0

Procedures

Number Title Revision

ABN-Earthquake Earthquake 13

ABN-HVAC HVAC Trouble 12

ISP-SEIS-S402 Triaxial Seismic Switch Model

SP-1/TS-3 - CFT 3

ISP-SEIS-S403 Seismic System Reactor Building Foundation Triaxial Response - Spectrum Recorders - CFT 1

ISP-SEIS-X304 Seismic System Reactor Building Foundation Triaxial Response - Spectrum Recorders - CC 2

OI-69 Time Critical Operator Actions 4

OSP-CCH/IST-M702 Control Room Emergency Chiller System B Operability 35

SOP-HVAC/CR-LU Control, Cable, and Critical Switchgear Rooms HVAC Lineup 1

SOP-HVAC/CR-START Control, Cable, and Critical Switchgear Rooms HVAC Start 10

SOP-HVAC/CR-OPS Control, Cable, and Critical Switchgear Rooms HVAC Operation 19

SOP-RCC-LU RCC System Valve and Breaker Line-Up 1

SOP-SW-LU Standby Service Water System Valve & Breaker Lineup 6

TSP-DG2/LOCA-B501 Standby Diesel Generator DG2 LOCA Test 26

SOP-SLC-LU SLC System Valve and Breaker Lineup 0

SOP-SGT-LU Standby Gas Treatment System Lineup 0

Calculations

Number Title Revision

CE-02-90-21 Calculation for Set Points Response Spectrum Indicating Lights 0

ME-02-92-43 Room Temperature Calculation for DG Building, Reactor Building, Radwaste Building and Service Water 10

Drawings

Number Title Revision

EWO-101E-008 Electrical Wiring Diagram Heat Trace SLC Pump Suction Piping 2 M522 Flow Diagram Standby Liquid Control System 39

Miscellaneous

Number Title Revision/ Date C92-0020 Component Classification Evaluation Record 0 E555-HT-HTP-8B/A Fuse Detail Report December 15, 2008 ISCR 979 Instrument Setpoint Change Request

SEIS-RSRT-1/1, 1/2, 1/3 April 30, 1990

LDCN-11-001,11-013 Columbia Generating Station Final Safety Analysis Report 61

Work Orders

02041736

02075766

Action Requests

(ARs)

046497

298184

302392

304002

304040

307688

307703

308892

311384

313567

313883

313960

318811

319542

323891

325520

330741 333996

Section 1R05: Fire Protection

Drawings

Number Title Revision E503-1 Motor Control Center General Notes, MCC and Starter Index 86 E535-49A Connection Wiring Diagram Motor Control Center E-MC-7F 23 E535-49B Connection Wiring Diagram Motor Control Center E-MC-7F 23 E753 Radwaste and Control Building Elevation 525'-0" Power Conduit and Tray Plans 41

PFSS-1 Appendix R Post Fire Safe Shutdown (PFSS) Division 1 Boundaries One Line Diagram 10

Procedures

Number Title Revision 1.3.10A Control of Ignition Sources 15

FPP-1.6 Combustible Loading Calculation Control 2

FPP-2.2.12 Annual Fire Door Operability Test 4

FPP-2.2.7 Fire Protection Water System Inspections 5

Fire Protection Pre-Plans Number Title Revision

PFP-RB-422 Reactor 422 5

PFP-RW-467 Radwaste 467 5

PFP-RW-484-487 Radwaste 484-487 5

PFP-RW-525 Radwaste 525 5

Section 1R11: Licensed Operator Requalification Program and Licensed Operator Performance

Procedures

Number Title Revision

OI-9 Operations Standards and Expectation 62

OI-45 Color Banding of Control Room Instrumentation 6

OI-53 Offsite Power 14 1.3.67 Operational Decision Making Process 14 1.3.84 Reactivity Management Control 2 13.1.1 Classifying the Emergency 47 5.1.1 RPV Control 20 5.2.1 Primary Containment Control 22 5.3.1 Secondary Containment Control 19

Action Requests

(ARs)

332747 333692

Section 1R12: Maintenance Effectiveness

Procedures

Number Title Revision 1.5.11 Maintenance Rule Program 13

MOT-CHILL-1-1 Chiller Maintenance Scope and Basis Document 7

MOT-PRV-1-1 Pressure Relief Valve Maintenance Scope and Basis Document 6

Miscellaneous

Number Title Revision/ Date

Maintenance Rule Evaluations CCH System June 30, 2015

CCH System Performance Improvement Plan 4 51182 Reactor Operating Events-Event Notification Report June 25, 2015

CVI 531-00,1,1 Differential Pressure Indicating Switches, Unit, Calibration and Parts List 3

GEP-6013 Preparation and Installation of the ULTRX Rupture Disc Assembly 2008 IMDS Instrument Master Data Sheets

DMA-TIS-32A/B 7

Action Requests

(ARs)

020602

020829

122680

132812

135119

195492

195876

226018

284341

298184

304040

307688

307703

307863

307897

308892

308950

311597

313567

313883

318811

319542

320707

332078

332096

332617

332889

334369 334438

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

Number Title Revision

ABN-CR-EVAC Control Room Evacuation and Remote Cooldown 33

Procedures

Number Title Revision

OI-14 Columbia Generating Station Operational Challenges and Risk Program 13

OI-69 Time Critical Operator Actions 4 1.3.1 Operating Policies, Programs, and Practices 119 1.3.76 Integrated Risk Management 44

Action Requests

(ARs)

302053

306204

309005

311964

314936

314983

319661

321848

322776

323263

323364

329491

333025

333041

333622

333731

334749

Work Orders

(WOs)

02082634

Miscellaneous

Number Title Date

Protected Equipment Tracking Sheet August 20, 2015

Protected Equipment Tracking Sheet

September 13, 2015

Protected Equipment Tracking Sheet

September 26, 2015

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

Number Title Revision 1.3.66 Operability and Functionality Evaluation 32 4.601.A2 601.A2 Annunciator Panel Alarms 27 5.0.12 Station Blackout and Extended Loss of AC Power Basis 0

ABN-HVAC HVAC Trouble 12

OI-69 Time Critical Operator Actions 4

OI-9 Operations Standards and Expectation 62

Procedures

Number Title Revision

OSP-CCH/IST-M702 Control Room Emergency Chiller System B Operability 35

SOP-HOTWEATHER-OPS Hot Weather Operations 6

SOP-HVAC/CR-LU Control, Cable, and Critical Switchgear Rooms HVAC Lineup 1

SOP-HVAC/CR-OPS Control, Cable, and Critical Switchgear Rooms HVAC Operation 19

SOP-HVAC/CR-START Control, Cable, and Critical Switchgear Rooms HVAC Start 10

Calculations

Number Title Revision

ME-02-89-49 Calculation for Main Steam Isolation Valve Actuator Force Balance 0

NE-02-85-19 Calculation Post-Fire Safe Shutdown (PFSS) Analysis 7

Miscellaneous

Number Title Revision/ Date 531-00,1,1 Barton Differential Pressure Indicating Switches, Unit, Calibration and Parts List 3 IMDS Instrument Master Data Sheets

MS-LIS-24A/C 16

NO 1419 Night Order October 27, 2012

NO 1653 Night Order July 8, 2015

TM-2150 Mission Time of Emergency Safety Features 0

Action Requests

(ARs)

273129

332823

332326

332330

332078

032562

332096

021535

028598

333334 334459

Section 1R18: Plant Modifications

Miscellaneous

Number Title Revision EC14111

RFW-V-102A Push Rod Assembly 0

Section 1R19: Post-Maintenance Testing

Procedures

Number Title Revision

OSP-CCH/IST-M701 Control Room Emergency Chiller System A Operability 38

OSP-RCIC/IST-Q701 RCIC Operability Test 56

OSP-ELEC-S702 Diesel Generator 2 Semi-Annual Operability Test 55

SOP-DG2-START Emergency Diesel Generator (DIV 2) Start 26

Work Orders

02059527

02066727

02069655

02066726

02070167

02075767

Miscellaneous

Number Title Revision IMDS Instrument Master Data Sheets

DMA-TIS-32A/B 7

Action Requests

(ARs)

298184

314814

319542

320386

321294

323891

324941

325599

331175

332159

335270

335441

336314

336431 336485

Section 1R22: Surveillance Testing

Procedures

Number Title Revision

OSP-INST-H101 Shift and Daily Instrument Checks Modes 1, 2, 3 85

OSP-DO/IST-Q701

DO-P-1A Operability 14

Procedures

Number Title Revision

OSP-LPCS/IST-Q702 LPCS System Operability Test 39

Action Requests

(ARs)

316238

326038

332078

332833

335006 335144

Section 1EP6: Drill Evaluation

Procedures

Number Title Revision 5.1.1 RPV Control 20 5.2.1 Primary Containment Control 22 5.3.1 Secondary Containment Control 19 13.1.1 Classifying the Emergency 47

Action Requests

(ARs)

332756

333042

Miscellaneous

Number Title Date

ERO Team A Drill Guide July 7, 2015

ERO Team A Drill Report - After Action Improvement Plan July 30, 2015

Section 2RS5: Radiation Monitoring Instrumentation

Procedures

Number Title Revision

CI-13.10 Canberra iSolo Alpha/Beta Counting System 04

CI-13.12 Global Value Gamma Ray Analyzer System 03

CI-13.6 ORTEC Gamma Ray Analyzer System 03

CI-13.9 Tri-Carb Liquid Scintillation Counting System 03

HPI-12.100 Calibration of the SAM12 Small Article Monitor 03

HPI-5.6 FastScan Whole Body Count System 07

Procedures

Number Title Revision

HPI-7.5 Eberline Model

RO-2 and

RO-2A Calibration 10

PPM 16.1.2 Stack Monitor Low Range Detector

14

PPM 16.2.1 TEA Low Range Noble Gas Monitor Channel 1 10

PPM 16.4.4 OFFGAS Post Treatment Radiation Monitor CH A

16

PPM 16.7.2

FDR-RIS-606, Liquid Radwaste Effluent Monitor 08

PPM 16.7.4 Liquid Radwaste Effluent Line Flow Rate 07

Action Requests

(ARs)

00307356

00308226

00308390

00308468

00309073

00309410

00310348

00312551

00319190

00319873

00325863

00326107

00334647

Audits and Self-Assessments Number Title Date

301869 Snapshot Self-Assessment Report - Radiation Instruments July 25, 2015

AU-CH-14 Quality Services Audit Report - Chemistry/REMP/Non-Rad & Rad Effluents/ODCM Program October 23, 2014

Installed Radiation Instrument Calibration Records WO Number Title Date

01167050 TEA Low Range Noble Gas Monitor Channel 1 April 3, 2014

02043785 OFFGAS Post Treatment Radiation Monitor CH A May 23, 2015

02047822 CC/RC Secondary Containment Isolation Reactor Building Vent Radiation Channel D March 26, 2014

02051142 Liquid Radwaste Flow Instrument June 13, 2014

02051815 MSL High Radiation Channel A

June 27, 2014

02053216 Stack Monitor Low Range Noble Gas Monitor July 17, 2014

02062579 Liquid Radwaste Effluent Radiation Monitor March 3, 2015

02066745 Plant Blowdown Discharge Line Flow Rate July 3, 2015

Portable Radiation Instrument Calibration Records Number Title Date 3891 Victoreen Model 570 R-Chamber Set January 20, 2014 F112 Ludlum Model 177 Frisker April 1, 2015 NO17 Eberline

ASP-1 w/ NRD Neutron Detector April 8, 2015 RO196 Eberline

RO-2 April 24, 2015 RO237 Ludlum Model 14C July 23, 2015 RS26 Thermo/Bicron Micro-Rem Meter April 30, 2015 RV07 Victoreen 451B April 2, 2015 T070 Teletector Model 6112M May 20, 2015

Stationary Radiation Instrument Calibration Records Number Title Date 36797 iSolo Calibration September 23, 2015

HP-EQ-42712 SAM12 Small Article Monitor September 23, 2015

HP-EQ-42734

GEM-5 July 19, 2015

HP-EQ-42747

GEM-5 September 3, 2015

HP-EQ-42783

ARGOS-5 A/B July 14, 2015

HP-EQ-42813 SAM12 Small Article Monitor April 20, 2015

HP-EQ-C015122

IPM-8 May 8, 2015 Ortec #5 Efficiency Verification Worksheet Calibration of 47 mm Filter Shelf 1 September 23, 2015 Ortec #5 Efficiency Verification Worksheet Calibration of 250 ml Polybottle - Shelf 1 September 23, 2015 WBC#2 FastScan Calibration July 29, 2015

WO 02062192 Annual Tritium Quench Curve Calibration June 10, 2015

Miscellaneous Documents

Number Title Revision/Date

Offsite Dose Calculation Manual 53

Calibration Lab Irradiator Periodic Dose Rate Decay Adjustment July 7, 2015

Miscellaneous Documents

Number Title Revision/Date 15-02 Calculation of the Activity for K40 Daily Check Source Used with SAM 9/11/12 and

BM 285 Monitors (Revises Calculation No. 04-1) June 23, 2015

Section 2RS6: Radioactive Gaseous and Liquid Effluent Treatment

Procedures

Number Title Revision 1.11.12 Removal of Liquids from

RCA 11 11.2.15.7 Release of Material from Radiologically Controlled Area 21

TSP-BOP/ISOL-B501 Balance of Plant Isolation Logic System Functional Test 07

TSP-SGT-B501 Standby Gas Treatment System Functional Test 08 10.2.8 Carbon Filter In Place Testing 08 10.2.82 HEPA Filter In Place Testing

07 12.4.21 The Sampling and Determination of Tritium 25 12.5.8 Gaseous Effluent Discharge Sampling 23 12.5.28 Sampling and Analysis for Unrestricted Release 12 16.11.1 Monthly Grab Gas Samples 10 16.11.6 Weekly Iodine, Particulate, and Tritium Analysis Results 15

MSP-SGT-B102 Standby Gas Treatment System Unit B HEPA Filter Test 04

MSP-SGT-B103 Standby Gas Treatment Filtration System - Unit A Carbon Adsorber Test 10

MSP-SGT-B104 Standby Gas Treatment Filtration System - Unit B Carbon Adsorber Test 08 9.3.32 Fuel Integrity Monitoring 12

Action Requests

(ARs)

00297561

00301591

00310348

00315360

00315492

00320966

00321016

00321365

00323071

00323632

00326490

00331287

00331587

00331588

00331589

00334641

00291084

Audits, Self-Assessments, and Surveillances Number Title Date

AU-CH-14 Chemistry-REMP-Non-Rad and Rad Effluents-ODCM Program Audit October 16, 2014

AU-RP-RW-13 Radiation Protection and Process Control November 16, 2013 23748A NUPIC Audit NCS Corporation September 3, 2014 23748B NUPIC Audit AEP Audit No.

PA-14-12 November 25, 2014

Section 2RS7: Radiological Environmental Monitoring Program

Procedures

Number Title Revision

SWP-CHE-01 Groundwater Protection Program 03 PPM 1.11.1 REMP Implementation Procedure - REMP 5.11 Use and Maintenance of Automatic Composite Samplers 02 REMP 9.10 Environmental TLD Calculations 01 REMP 11.01 Milk Sampling 06 Air Cleaning System Surveillance Test Records Number Title Date

WO 2004423 Standby Gas Treatment Filtration System - Unit A Carbon Adsorber Test July 15, 2013

WO 2046928 Standby Gas Treatment System Unit B HEPA Filter Test April 28, 2014

WO 2046928 Standby Gas Treatment Filtration System - Unit B Carbon Adsorber Test April 28, 2014 Title Date 2013 Annual Radioactive Effluent Release Report April 2014 2014 Annual Radioactive Effluent Release Report April 2015 Cross-Check Program 2013 Summary Report February 2014 Cross-Check Program 2014 Summary Report February 2015

Procedures

Number Title Revision REMP 11.02 Soil and Sediment Sampling 03 REMP 11.06 Fish Collection and Preparation 01 REMP 11.07 REMP Water Sample Collection 06 REMP 11.09 REMP Air Sample Collection 05 REMP 12.06 Quality Assurance for the Radiological Laboratory 01 REMP 12.07 Radiological Laboratory Measurement Assurance Program 01

SOP 11.09r05 REMP Air Sample Collection 05

Audits, Self-Assessments, and Surveillances Number Title Date

AR 291084 Perform a Self-Assessment of

SWP-CHE-01, Groundwater Protection Program Against the Requirements of

NEI 07-07 January, 2014 15-A-08 Energy Northwest Audit Report 15-A-08 of Mission Support Alliance - Radiological Site Services March 9, 2015

AU-RP/RW-13 Quality Services Audit Report; Radiation Protection and Process Control program November 2013

AR-SA:305111 Focused Self-Assessment Report; Radioactive Gaseous and Liquid Effluents; Radiological Environmental Monitoring Program; and Radioactive Solid Waste Processing, Radioactive Material Handling, Storage, and Transportation June 19, 2015

Action Requests

(ARs)

00320966

00303414

00335039

00331779

00300634

00317136

00333542

00318632

00320309

00316091

00321365

00325192

00329806

00331590

0033106

00333286

00299745

00334171

00334146

00303414

Miscellaneous Documents

Section 2RS8: Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation

Procedures

Number Title Revision 1.10.1 Notifications and Reportable Events 37 11.2.23.1 Shipping Radioactive Materials and Waste 15 11.2.23.2 Computerized Radioactive Waste and Material Characterization 19 11.2.23.4 Packaging Radioactive Material and Waste 23 11.2.23.14 Sampling of Radioactive Waste Streams

12 11.2.23.19 Operation of The Pacific Nuclear Resin Drying System 07, 13, 14 11.2.23.29 LSA Contaminated Laundry Shipments 11 11.2.23.37 Use of the 14D-2.0 Type A Transportation Cask 05 RW000103 Waste Characterizing Computer Code 00 RW000115

WNP-2 Radwaste Procedure Training 00 RW000116 NRC Packaging and Shipping Regulations 00 RW000117 DOT Packaging and Shipping Regulations 00 RW000118 Burial Site Disposal Requirements 00

SWP-CHE-02 Chemical Process Management and Control 24 Title Revision/Date Plant Meteorological Tower Data Availability Records, 2013, 2015 and 2015 (Year to Date) September 2015 Plant Specific Logs for Licensee Compliance to Title 10

Part 50.75.g. (Year to Date) September 2015 2013 Annual Radiological Environmental Operating Report May 2014 2014 Annual Radiological Environmental Operating Report May 2015 Offsite Dose Calculation Manual June 1991 Offsite Dose Calculation Manual 53

Procedures

Number Title Revision

SWP-RMP-02 Radioactive Waste Process Control Program 05

Audits, Self-Assessments, and Surveillances Number Title Date

AU-RP/RW-13 Quality Services Audit Report: Radiation Protection and Process Control Program

December 3, 2013

AU-CH-14 Quality Service Audit Report: Chemistry/REMP/Non-Rad and Rad Effluents/ODCM Program October 23, 2014 30511 Focused Self-Assessment Report: Radioactive Gaseous and Liquid Effluents; Radiological Environmental Monitoring Program; Radioactive Solid Waste Processing, Radioactive Material Handling, Storage, and Transportation June 19, 2015 Action Requests (ARs)

00297650

00300182

00308527

00316555

00316676

00316835

00316913

00320373

00323678

00323841

00325137

00332690

00332758

00333434

00333463

00333590

Radioactive Material and Waste Shipments Number Title Date 13-07 RWCU Resin (Non-DOT) March 26, 2013 13-39 12 Boxes of Dry Active Waste (LSA II) June 11, 2013 13-46 12 Boxes of Dry Active Waste (LSA II) June 27, 2013 13-50 Resin Bead, 1 PDX, 8 Boxes of Dry Active Waste (LSA II) August 27, 2013 14-03

RHR-P-2B (Type A) January 16, 2014 14-10 4 Condensate F/D Resins, 2 Boxes Dry Active Waste (LSA II) May 20, 2014 14-16 EDDR/FDR F/D Resins (LSA II) June 11, 2014

Radioactive Material and Waste Shipments Number Title Date 14-32 Condensate F/D Resins - 5 liners (RETURNED) (LSA II) October 9, 2014 14-38 EDR/FDR Resin Condensate (LSA II) December 15, 2014 15-01 Condensate F/D Resins; 4 Boxes Dry Active Waste (LSA II) January 20, 2015 15-43 One 20' C-Van with Dry Active Waste (LSA II) June 4, 2015

Radiation Work Permits Number Title Revision

30003514 2015

RW 437' Waste Processing NUPAC Cage - LHRA 00

30003520 2015 RW NUPAC Cage Processing - LHRA High Risk 00

30003498 NRC Tours and Inspections -

HRA 00

Radiological Surveys Number Title Date 4435 ISFSI Building 105 July 27, 2015 4497 Building 167 & C-Vans August 3, 2015 4500 Warehouse 5 (Building 80) August 3, 2015 4710 Building 13 Laundry August 21, 2015 4874 LSA Pad September 8, 2015 5057 Radwaste 437' NUPAC Cage September 23, 2015

Section 4OA1: Performance Indicator Verification

Procedures

Number Title Revision

CI-10.17 Iodine 12

CSP-I131-W101 Reactor Coolant Isotopic Analysis for I-131 Dose Equivalent 9

Miscellaneous

Number Title Revision

MSPI-01-BD-001 MSPI Basis Document 17

286838

286894

332833

333421

Work Orders

02069131

Section 4OA2: Problem Identification and Resolution Procedures Number Title Revision

SWP-CAP-06 Condition Report Review 22

Miscellaneous Documents

Number Title Revision/Date ODCM LEP Columbia Generating Station Offsite Dose Calculation Manual 53

Columbia Generating Station Final Safety Analysis Report - Chapter 11.4, "Solid Waste Management System" 57

2013 Annual Radioactive Effluent Release Report April 30, 2014

DIC 1554.58 Columbia Generating Station Scaling Factor Determination Package March 24, 2015

2014 Annual Radioactive Effluent Release Report April 30, 2015

10

CFR 61 Scaling Factor Determination September 17, 2015

Action Requests

(ARs)

329576

333690 334108

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Procedures

Number Title Revision 3.4.1 Minimizing the Potential of Draining the Reactor Vessel 19

Action Requests

(ARs)

323625

326336

326573

328051

328312

328726

329328

The following items are requested for the Public Radiation Safety Inspection Columbia September 21-24, 2015 Integrated Report

2015003

Inspection areas are listed in the attachments below.

Please provide the requested information on or before August 31, 2015.

Please submit this information using the same lettering system as below.

For example, all contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled "1- A," applicable organization charts in file/folder "1- B," etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at least 30 days later than the onsite inspection dates, so the inspectors will have access to the information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed below, please provide updated lists of corrective action documents at the entrance meeting.

The dates for these lists should range from the end dates of the original lists to the day of the entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear to be redundant, there is no need to provide duplicate copies.

Enter a note explaining in which file the information can be found.

If you have any questions or comments, please contact Martin Phalen at (817) 200-1158 or martin.phalen@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT This letter does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget, control number 3150-0011.

1.

Radiation Monitoring Instrumentation (71124.05) Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas: 1. Effluent monitor calibration 2. Radiation protection instrument calibration 3. Installed instrument calibrations 4. Count room and Laboratory instrument calibrations B. Applicable organization charts C. Copies of audits, self-assessments, vendor or NUPIC audits for contractor support and LERs, written since date of last inspection, related to:

1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, or whole body counters

2. Installed radiation monitors D. Procedure index for: 1. Calibration, use and operation of continuous air monitors, criticality monitors, portable survey instruments, temporary area radiation monitors, electronic dosimeters, teledosimetry, personnel contamination monitors, and whole body counters. 2. Calibration of installed radiation monitors E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.

1. Calibration of portable radiation detection instruments (for portable ion chambers) 2. Whole body counter calibration 3. Laboratory instrumentation quality control F. A summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection, related to the following programs: 1. Area radiation monitors, continuous air monitors, criticality monitors, portable survey instruments, electronic dosimeters, teledosimetry, personnel contamination monitors, whole body counters,

2. Installed radiation monitors,

3. Effluent radiation monitors 4. Count room radiation instruments NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Offsite dose calculation manual, technical requirements manual, or licensee controlled specifications which lists the effluent monitors and calibration requirements. H. Current calibration data for the whole body counter's. I. Primary to secondary source calibration correlation for effluent monitors. J.

A list of the point of discharge effluent monitors with the two most recent calibration dates and the work order numbers associated with the calibrations. K. Radiation Monitoring System health report for the previous 12 months

2. Radioactive Gaseous and Liquid Effluent Treatment (71124.06)

Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas: 1. Radiological effluent control 2. Engineered safety feature air cleaning systems B. Applicable organization charts C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1.

Radioactive effluents 2.

Engineered Safety Feature Air cleaning systems D. Procedure indexes for the following areas 1.

Radioactive effluents 2.

Engineered Safety Feature Air cleaning systems E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.

1. Sampling of radioactive effluents 2. Sample analysis 3. Generating radioactive effluent release permits 4. Laboratory instrumentation quality control 5. In-place testing of HEPA filters and charcoal adsorbers 6. New or applicable procedures for effluent programs (e.g., including ground water monitoring programs) F. List of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection, associated with: 1.

Radioactive effluents 2.

Effluent radiation monitors 3.

Engineered Safety Feature Air cleaning systems NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. 2013 and 2014 Annual Radioactive Effluent Release Report or the two most recent reports H. Current Copy of the Offsite Dose Calculation Manual I. Copy of the 2013 and 2014 interlaboratory comparison results for laboratory quality control performance of effluent sample analysis, or the two most recent results.

J. Effluent sampling schedule for the week of the inspection K. New entries into 10

CFR 50.75(g) files since date of last inspection L. Operations department (or other responsible dept.) log records for effluent monitors removed from service or out of service M. Listing or log of liquid and gaseous release permits since date of last inspection

N. A list of the technical specification-required air cleaning systems with the two most recent surveillance test dates of in-place filter testing (of HEPA filters and charcoal adsorbers) and laboratory testing (of charcoal efficiency) and the work order numbers associated with the surveillances

O. System Health Report for radiation monitoring instrumentation.

Also, please provide a specific list of all effluent radiation monitors that were considered inoperable for 7 days or more since November 2011.

If applicable, please provide the relative Special Report and condition report(s) moreover

P. A list of all radiation monitors that are considered §50.65/Maintenance Rule equipment.

Q. A list of all significant changes made to the Gaseous and Liquid Effluent Process Monitoring System since the last inspection.

If applicable, please provide the corresponding UFSAR section in which this change was documented.

R.

A list of any occurrences in which a non-radioactive system was contaminated by a radioactive system.

Please include any relative condition report(s).

3. Radiological Environmental Monitoring Program (71124.07)

Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas: 1. Radiological environmental monitoring 2. Meteorological monitoring B. Applicable organization charts C. Audits, self-assessments, vendor or NUPIC audits of contractor support, and LERs written since date of last inspection, related to: 1. Radiological environmental monitoring program (including contractor environmental laboratory audits, if used to perform environmental program functions) 2. Environmental TLD processing facility 3. Meteorological monitoring program D. Procedure index for the following areas: 1. Radiological environmental monitoring program 2. Meteorological monitoring program E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.

1. Environmental Program Description 2. Sampling, collection and preparation of environmental samples 3. Sample analysis (if applicable)

4. Laboratory instrumentation quality control 5. Procedures associated with the Offsite Dose Calculation Manual 6. Appropriate QA Audit and program procedures, and/or sections of the station's QA manual (which pertain to the REMP) F. A summary list of corrective action documents (including corporate and sub-tiered systems) written since date of last inspection, related to the following programs: 1. Radiological environmental monitoring

2. Meteorological monitoring

NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide in document formats which are "searchable" so that the inspector can perform word searches.

G. Wind Rose data and evaluations used for establishing environmental sampling locations H. Copies of the 2 most recent calibration packages for the meteorological tower instruments

I. Copy of the 2013 and 2014 Annual Radiological Environmental Operating Report and Land Use Census, and current revision of the Offsite Dose Calculation Manual, or the two most recent reports. J. Copy of the environmental laboratory's interlaboratory comparison program results for 2013 and 2014, or the two most recent results, if not included in the annual radiological environmental operating report K. Data from the environmental laboratory documenting the analytical detection sensitivities for the various environmental sample media (i.e., air, water, soil, vegetation, and milk) L. Quality Assurance audits (e.g., NUPIC) for contracted services

M. Current NEI Groundwater Initiative Plan and status

N.

Technical requirements manual or licensee controlled specifications which lists the meteorological instruments calibration requirements

O. A list of Regulatory Guides and/or NUREGs that you are currently committed to relative to the Radiological Environmental Monitoring Program.

Please include the revision and/or date for the committed item and where this can be located in your current licensing basis/UFSAR.

P. If applicable, per

NEI 07-07, provide any reports that document any spills/leaks to groundwater since the last inspection

4. Radioactive Solid Waste Processing, and Radioactive Material Handling, Storage, and Transportation (71124.08)

Date of Last Inspection: November 8, 2013

A. List of contacts and telephone numbers for the following areas: 1. Solid Radioactive waste processing 2. Transportation of radioactive material/waste B. Applicable organization charts (and list of personnel involved in solid radwaste processing, transferring, and transportation of radioactive waste/materials) C. Copies of audits, department self-assessments, and LERs written since date of last inspection related to: 1. Solid radioactive waste management 2. Radioactive material/waste transportation program D. Procedure index for the following areas: 1. Solid radioactive waste management 2. Radioactive material/waste transportation

E. Please provide specific procedures related to the following areas noted below.

Additional Specific Procedures will be requested by number after the inspector reviews the procedure indexes.

1. Process control program 2. Solid and liquid radioactive waste processing

3. Radioactive material/waste shipping

4. Methodology used for waste concentration averaging, if applicable 5. Waste stream sampling and analysis F. A summary list of corrective action documents (including corporate and subtiered systems) written since date of last inspection related to: 1. Solid radioactive waste 2. Transportation of radioactive material/waste NOTE: The lists should indicate the significance level of each issue and the search criteria used.

Please provide in document formats which are "searchable" so that the inspector can perform word searches. G. Copies of training lesson plans for 49CFR172 subpart H, for radwaste processing, packaging, and shipping

H. A summary of radioactive material and radioactive waste shipments made from date of last inspection to present

I. Waste stream sample analyses results and resulting scaling factors for 2013, 2014, and 2915, or the two most recent results

J. Waste classification reports if performed by vendors (such as for irradiated hardware)

K. A listing of all onsite radwaste storage facilities.

Please include a summary or listing of the items stored in each facility, including the total amount of radioactivity and the highest general area dose rate

Although it is not necessary to compile the following information, the inspector will also review:

L. Training, and qualifications records of personnel responsible for the conduct of radioactive waste processing, package preparation, and shipping

ML15316A834

Text

Dear Mr. Reddemann,

Enclosure:

Attachment:

SUMMARY

Cornerstone: Mitigating Systems

Cornerstone: Public Radiation Safety

PLANT STATUS

REPORT DETAILS

REACTOR SAFETY

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

b. Findings

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

b. Findings

1R04 Equipment Alignment

.1 Partial Walkdown

a. Inspection Scope

b. Findings

Introduction.

=

Description.

Analysis.

Enforcement.

Introduction.

=

Description.

Analysis.

Enforcement.

Introduction.

=

Description.

Analysis.

Enforcement.

1R05 Fire Protection

.1 Quarterly Inspection

a. Inspection Scope

b. Findings

1R06 Flood Protection Measures

a. Inspection Scope

b. Findings

1R11 Licensed Operator Requalification Program and Licensed Operator Performance

.1 Review of Licensed Operator Requalification

a. Inspection Scope

b. Findings

.2 Review of Licensed Operator Performance

a. Inspection Scope

b. Findings

Introduction.

Description.

Analysis.

Enforcement.

1R12 Maintenance Effectiveness

a. Inspection Scope

b. Findings

1R13 Maintenance Risk Assessments and Emergent Work Control

a. Inspection Scope

b. Findings

1R15 Operability Determinations and Functionality Assessments

a. Inspection Scope

b. Findings

1R18 Plant Modifications

a. Inspection Scope

b. Findings

1R19 Post-Maintenance Testing

a. Inspection Scope

b. Findings

1R22 Surveillance Testing

a. Inspection Scope

b. Findings

Cornerstone:

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

b. Findings

RADIATION SAFETY

2RS5 Radiation Monitoring Instrumentation