ML15316A834
| ML15316A834 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/12/2015 |
| From: | Troy Pruett NRC/RGN-IV/DRP |
| To: | Reddemann M Energy Northwest |
| Ryan Alexander | |
| References | |
| EA-15-202 IR 2015003 | |
| Download: ML15316A834 (62) | |
See also: IR 05000397/2015003
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
November 12, 2015
Mr. M.E. Reddemann
Chief Executive Officer
Energy Northwest
P.O. Box 968, Mail Drop 1023
Richland, WA 99352-0968
SUBJECT:
COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION
REPORT 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
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
M. Reddemann
- 2 -
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 NRCs 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
SUNSI Review
By: JRG
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
Keyword:
OFFICE
RIV/DRP
RIV/DRP
RIV/DRP
RIV/DRS
RIV/DRS
RIV/DRS
RIV/DRS
NAME
DBradley
JGroom
RAlexander
TFarnholtz
VGaddy
MHaire
HGepford
SIGNATURE
/RA/ via E
/RA/ via E
/RA/
/RA/
/RA/
KClayton for
/RA/
/RA/
DATE
11/3/15
11/3/15
11/5/15
11/4/15
11/5/15
11/5/15
11/2/15
OFFICE
RIV/DRS
RIV/TSS
RIV/ACES
RIV/DRP
RIV/DRP
NAME
GWerner
ERuesch
JKramer
RSmith
TPruett
SIGNATURE
/RA/
ERuesch for
/RA/
/RA/ via E
/RA/
/RA/
DATE
11/6/15
11/6/15
11/3/15
11/6/15
11/12/15
M. Reddemann
- 3 -
Letter to M.E. Reddemann from T. Pruett dated November 12, 2015
SUBJECT:
COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION
REPORT 05000397/2015003 AND EXERCISE OF ENFORCEMENT
DISCRETION
DISTRIBUTION:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)
DRP Director (Troy.Pruett@nrc.gov)
DRP Deputy Director (Ryan.Lantz@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Jeremy.Groom@nrc.gov)
Resident Inspector (Dan.Bradley@nrc.gov)
Site Administrative Assistant (Vacant)
Incoming Branch Chief, DRP/A (Jeremy.Groom@nrc.gov)
Acting Branch Chief, DRP/A (Rich.Smith@nrc.gov)
Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)
Project Engineer (Thomas.Sullivan@nrc.gov)
Project Engineer (Mathew.Kirk@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Project Manager (Balwant.Singal@nrc.gov)
Acting Team Leader, DRS/TSS (Eric.Ruesch@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)
RIV/ETA: OEDO (Cindy.Rosales-Cooper@nrc.gov)
ROP Reports (ROPreports.Resource@nrc.gov)
ROP Assessment Resource (ROPassessment.Resource@nrc.gov)
- 1 -
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
05000397
License:
Report:
Licensee:
Energy Northwest
Facility:
Columbia Generating Station
Location:
North Power Plant Loop
Richland, WA 99354
Dates:
July 1, 2015 through September 30, 2015
Inspectors: D. Bradley, Resident Inspector
L. Carson, Senior Health Physicist
N. Greene, PhD, Health Physicist
J. Groom, Senior Resident Inspector
J. ODonnell, CHP, Health Physicist
M. Phalen, Senior Health Physicist
C. Stott, Project Engineer
Approved
By:
Richard Smith
Acting Chief, Projects Branch A
Division of Reactor Projects
- 2 -
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
NRCs 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 NRCs 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 licensees 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 licensees
maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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)
- 3 -
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 licensees
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 stations 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 licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 licensees 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
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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 licensees
maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 licensees 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 cornerstones 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 licensees 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
- 5 -
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)
- 6 -
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
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01)
.1
Readiness for Seasonal Extreme Weather Conditions
a.
Inspection Scope
On July 22, 2015, the inspectors completed an inspection of the stations readiness for
seasonal extreme weather conditions. The inspectors reviewed the licensees adverse
weather procedures for seasonal high temperatures and evaluated the licensees
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 licensees 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 licensees 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.
- 7 -
.2
Readiness for Impending Adverse Weather Conditions
a.
Inspection Scope
On August 20, 2015, the inspectors completed an inspection of the stations readiness
for impending adverse weather conditions involving high winds. The inspectors
reviewed plant design features, the licensees procedures to respond to tornadoes and
high winds, and the licensees 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 (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 licensees 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 licensees
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
- 8 -
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
- 9 -
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 systems 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 licensees maintenance rule program for
greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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
.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
- 10 -
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 licensees 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 licensees 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
LDCNs 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 336875336875
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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 licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 licensees 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 licensees failure to verify the
adequacy of the design of the control room HVAC system. Specifically, the licensee
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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 restartShutdown on a power
failure produces the same results as for a safety shutdown except relay 14R is
de-energizedIt 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
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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 licensees 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 NRCs 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
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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 licensees maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 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 licensees 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)
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1R05 Fire Protection (71111.05)
.1
Quarterly Inspection
a.
Inspection Scope
The inspectors evaluated the licensees 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 licensees 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 (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.
- 16 -
b.
Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(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 plants 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 Administrations 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 licensees 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.
- 17 -
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 332747332747to 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 cornerstones 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
- 18 -
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.
- 19 -
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 licensees
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 (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 332078332078
The inspectors reviewed the extent of condition of possible common cause SSC failures
and evaluated the adequacy of the licensees corrective actions. The inspectors
reviewed the licensees work practices to evaluate whether these may have played a
role in the degradation of the SSCs. The inspectors assessed the licensees
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 (71111.13)
a.
Inspection Scope
The inspectors reviewed two risk assessments performed by the licensee prior to
changes in plant configuration and the risk management actions taken by the licensee in
response to elevated risk:
August 20, 2015, planned yellow risk for a diesel generator 2 monthly
surveillance under Work Order 02068579
- 20 -
September 15, 2015, planned yellow risk for a reactor core isolation cooling
system work window under Work Order 02078715
The inspectors verified that these risk assessments were performed timely and in
accordance with the requirements of 10 CFR 50.65 (the Maintenance Rule) and plant
procedures. The inspectors reviewed the accuracy and completeness of the licensees
risk assessments and verified that the licensee implemented appropriate risk
management actions based on the result of the assessments.
Additionally, on September 28, 2015, the inspectors observed the operators response to
emergent work activities that resulted in unplanned unavailability of emergency diesel
generator 2. The inspectors verified that the licensee took precautions to minimize the
impact of the work activities on unaffected SSCs.
These activities constitute completion of three maintenance risk assessments and
emergent work control inspection samples, as defined in Inspection Procedure 71111.13.
b.
Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments (71111.15)
a.
Inspection Scope
The inspectors reviewed four operability determinations that the licensee performed for
degraded or nonconforming SSCs:
July 1, 2015, AR 332078332078 documenting reactor vessel water level indicating
switches MS-LIS-24A and C indicating abnormally high
July 1, 2015, AR 332326332326 documenting concerns related to residual heat removal
system operability during venting operations
July 22, 2015, AR 333334333334 documenting a slow opening time for main steam
isolation valve MS-V-22D
August 13, 2015, AR 334459334459 documenting concerns related to required manual
actions for the control room HVAC system emergency chillers
The inspectors reviewed the timeliness and technical adequacy of the licensees
evaluations. Where the licensee determined the degraded SSC to be operable, the
inspectors verified that the licensees compensatory measures were appropriate to
provide reasonable assurance of operability. The inspectors verified that the licensee
had considered the effect of other degraded conditions on the operability of the
degraded SSC.
These activities constitute completion of four operability and functionality review samples
as defined in Inspection Procedure 71111.15.
- 21 -
b.
Findings
No findings were identified.
1R18 Plant Modifications (71111.18)
a.
Inspection Scope
On July 1, 2015, the inspectors reviewed a temporary modification of reactor feedwater
valve RFW-V-102A under Engineering Change EC14111. The inspectors verified that
the licensee had installed this temporary modification in accordance with technically
adequate design documents. The inspectors verified that this modification did not
adversely impact the operability or availability of affected SSCs. The inspectors
reviewed design documentation and plant procedures affected by the modification to
verify the licensee maintained configuration control.
These activities constitute completion of one sample of temporary modifications, as
defined in Inspection Procedure 71111.18.
b.
Findings
No findings were identified.
1R19 Post-Maintenance Testing (71111.19)
a.
Inspection Scope
The inspectors reviewed four post-maintenance testing activities that affected risk-
significant SSCs:
August 5, 2015, post-maintenance test for service water temperature control
valve SW-TCV-11A, following maintenance under WO 02075767
August 26, 2015, post-maintenance test for the Division 3 diesel mixed air
system, following maintenance under WO 02066727
September 16, 2015, post-maintenance test for reactor core isolation cooling
system, following maintenance under Work Order 02078715
September 28, 2015, post-maintenance test for the Division 2 diesel generator,
following replacement of shutdown relays under Work Order 02002258
The inspectors reviewed licensing- and design-basis documents for the SSCs and the
maintenance and post-maintenance test procedures. The inspectors observed the
performance of the post-maintenance tests to verify that the licensee performed the tests
in accordance with approved procedures, satisfied the established acceptance criteria,
and restored the operability of the affected SSCs.
These activities constitute completion of four post-maintenance testing inspection
samples, as defined in Inspection Procedure 71111.19.
- 22 -
b.
Findings
No findings were identified.
1R22 Surveillance Testing (71111.22)
a.
Inspection Scope
The inspectors observed three risk-significant surveillance tests and reviewed test
results to verify that these tests adequately demonstrated that the SSCs were capable of
performing their safety functions:
Routine tests:
August 6, 2015, procedure OSP-DO/IST-Q701, DO-P-1A Operability, Revision
14, including a surveillance for the diesel generator fuel oil transfer pump
In-service tests:
September 8, 2015, procedure OSP-LPCS/IST-Q702, LPCS System Operability
Test, Revision 39
Reactor coolant system leak detection tests:
September 16, 2015, procedure OSP-INST-H101, Shift and Daily Instrument
Checks Modes 1, 2, 3 Revision 85, including reactor coolant system leakage
calculation
The inspectors verified that these tests met technical specification requirements, that the
licensee performed the tests in accordance with their procedures, and that the results of
the test satisfied appropriate acceptance criteria. The inspectors verified that the
licensee restored the operability of the affected SSCs following testing.
These activities constitute completion of three surveillance testing inspection samples,
as defined in Inspection Procedure 71111.22.
b.
Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation (71114.06)
.1
Emergency Preparedness Drill Observation
a.
Inspection Scope
The inspectors observed an emergency preparedness drill on July 7, 2015, to verify the
adequacy and capability of the licensees assessment of drill performance. The
inspectors reviewed the drill scenario, observed the drill from the simulator, technical
support center, operations support center and emergency operations facility, and
attended the post-drill critique. The inspectors verified that the licensees emergency
classifications, off-site notifications, and protective action recommendations were
- 23 -
appropriate and timely. The inspectors verified that any emergency preparedness
weaknesses were appropriately identified by the licensee in the post-drill critique and
entered into the corrective action program for resolution.
These activities constitute completion of one emergency preparedness drill observation
sample, as defined in Inspection Procedure 71114.06.
b.
Findings
No findings were identified.
2.
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety and Public Radiation Safety
2RS5 Radiation Monitoring Instrumentation (71124.05)
a.
Inspection Scope
The inspectors evaluated the accuracy and operability of the radiation monitoring
equipment used by the licensee (1) to monitor areas, materials, and workers to ensure a
radiologically safe work environment, and (2) to detect and quantify radioactive process
streams and effluent releases. The inspectors interviewed licensee personnel, walked
down various portions of the plant, and reviewed licensee performance in the following
areas:
Selected plant configurations and alignments of process, post-accident, and
effluent monitors with descriptions in the Final Safety Analysis Report and the
offsite dose calculation manual
Selected instrumentation, including effluent monitoring instrument, portable
survey instruments, area radiation monitors, continuous air monitors, personnel
contamination monitors, portal monitors, and small article monitors to examine
their configurations and source checks
Calibration and testing of process and effluent monitors, laboratory
instrumentation, whole body counters, post-accident monitoring instrumentation,
portal monitors, personnel contamination monitors, small article monitors,
portable survey instruments, area radiation monitors, electronic dosimetry, air
samplers, and continuous air monitors
Audits, self-assessments, and corrective action documents related to radiation
monitoring instrumentation since the last inspection
These activities constitute completion of one sample of radiation monitoring instrumentation
as defined in Inspection Procedure 71124.05.
b.
Findings
No findings were identified.
- 24 -
2RS6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
a.
Inspection Scope
The inspectors evaluated whether the licensee maintained gaseous and liquid effluent
processing systems and properly mitigated, monitored, and evaluated radiological
discharges with respect to public exposure. The inspectors verified that abnormal
radioactive gaseous or liquid discharges and conditions, when effluent radiation monitors
are out-of-service, were controlled in accordance with the applicable regulatory
requirements and licensee procedures. The inspectors verified that the licensees
quality control program ensured radioactive effluent sampling and analysis adequately
quantified and evaluated discharges of radioactive materials. The inspectors verified the
adequacy of public dose projections resulting from radioactive effluent discharges. The
inspectors interviewed licensee personnel and reviewed or observed the following items:
Radiological effluent release reports since the previous inspection and reports
related to the effluent program issued since the previous inspection
Effluent program implementing procedures, including sampling, monitor setpoint
determinations and dose calculations
Equipment configuration and flow paths of selected gaseous and liquid discharge
system components, filtered ventilation system material condition, and significant
changes to their effluent release points, if any, and associated 10 CFR 50.59
reviews
Selected portions of the routine processing and discharge of radioactive gaseous
and liquid effluents (including sample collection and analysis)
Controls used to ensure representative sampling and appropriate compensatory
sampling
Results of the inter-laboratory comparison program
Effluent stack flow rates
Surveillance test results of technical specification-required ventilation effluent
discharge systems since the previous inspection
Significant changes in reported dose values
A selection of radioactive liquid and gaseous waste discharge permits
Part 61 analyses and methods used to determine which isotopes are included in
the source term
Offsite dose calculation manual changes
Meteorological dispersion and deposition factors
- 25 -
Latest land use census
Records of abnormal gaseous or liquid tank discharges
Groundwater monitoring results
Changes to the licensees written program for identifying and controlling
contaminated spills/leaks to groundwater
Identified leakage or spill events and entries made into 10 CFR 50.75(g) records,
if any, and associated evaluations of the extent of the contamination and the
radiological source term
Offsite notifications, and reports of events associated with spills, leaks, and
groundwater monitoring results
Audits, self-assessments, reports, and corrective action documents related to
radioactive gaseous and liquid effluent treatment since the last inspection
These activities constitute completion of one sample of radioactive gaseous and liquid
effluent treatment, as defined in Inspection Procedure 71124.06.
b.
Findings
No findings were identified.
2RS7 Radiological Environmental Monitoring Program (71124.07)
a.
Inspection Scope
The inspectors evaluated whether the licensees 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 licensees 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 licensees
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
- 26 -
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 (71124.08)
a.
Inspection Scope
The inspectors evaluated the effectiveness of the licensees 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 licensees 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
- 27 -
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 licensees 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 sites 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 licensees 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
- 28 -
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 plants
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
licensees 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]
- 29 -
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 licensees 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 licensees 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)
4.
OTHER ACTIVITIES
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity, Emergency
Preparedness, Public Radiation Safety, Occupational Radiation Safety, and
Security
4OA1 Performance Indicator Verification (71151)
.1
Mitigating Systems Performance Index: Emergency AC Power Systems (MS06), High
Pressure Injection Systems (MS07), Residual Heat Removal Systems (MS09),
a.
Inspection Scope
The inspectors reviewed the licensees mitigating system performance index data for the
period of July 2014 through June 2015 to verify the accuracy and completeness of the
reported data. The inspectors used definitions and guidance contained in Nuclear
Energy Institute Document 99-02, Regulatory Assessment Performance Indicator
Guideline, Revision 7, to determine the accuracy of the reported data.
These activities constituted verification of the mitigating system performance index for
emergency ac power systems, high pressure injection systems, and residual heat
removal systems as defined in Inspection Procedure 71151.
b.
Findings
No findings were identified.
.2
Reactor Coolant System Specific Activity (BI01)
a.
Inspection Scope
The inspectors reviewed the licensees reactor coolant system chemistry sample
analyses for the period of July 2014 through June 2015 to verify the accuracy and
completeness of the reported data. The inspectors observed a chemistry technician
obtain and analyze a reactor coolant system sample on September 1, 2015. The
inspectors used definitions and guidance contained in Nuclear Energy Institute
- 30 -
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7,
to determine the accuracy of the reported data.
These activities constituted verification of the reactor coolant system specific activity
performance indicator, as defined in Inspection Procedure 71151.
b.
Findings
No findings were identified.
4OA2 Problem Identification and Resolution (71152)
.1
Routine Review
a. Inspection Scope
Throughout the inspection period, the inspectors performed daily reviews of items
entered into the licensees corrective action program and periodically attended the
licensees condition report screening meetings. The inspectors verified that licensee
personnel were identifying problems at an appropriate threshold and entering these
problems into the corrective action program for resolution. The inspectors verified that
the licensee developed and implemented corrective actions commensurate with the
significance of the problems identified. The inspectors also reviewed the licensees
problem identification and resolution activities during the performance of the other
inspection activities documented in this report.
b. Findings
No findings were identified.
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153)
.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
- 31 -
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 stations
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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 staffs issuance of the NOA.
- 32 -
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)
A-2
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
05000397/2015-002-
00
LER
Inadequately Fused Non- Class 1E Circuit on Division 1 120/240
VAC Bus (Section 4OA3)
05000397/2015-003-
00
LER
Implementation of Enforcement Guidance Memorandum (EGM)11-003, Revision 2 (Section 4OA3)
05000397/2015-004-
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-
Hot Weather Operations
6
SOP-
WARMWEATHER-
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
A-3
Procedures
Number
Title
Revision
ABN-Earthquake Earthquake
13
ABN-HVAC
HVAC Trouble
12
Triaxial Seismic Switch Model SP-1/TS-3 - CFT
3
Seismic System Reactor Building Foundation Triaxial
Response - Spectrum Recorders - CFT
1
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-
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
A-4
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
A-5
Procedures
Number
Title
Revision
1.3.10A
Control of Ignition Sources
15
Combustible Loading Calculation Control
2
Annual Fire Door Operability Test
4
Fire Protection Water System Inspections
5
Fire Protection Pre-Plans
Number
Title
Revision
Reactor 422
5
Radwaste 467
5
PFP-RW-484-
487
Radwaste 484-487
5
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
A-6
Section 1R12: Maintenance Effectiveness
Procedures
Number
Title
Revision
1.5.11
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
A-7
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
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
A-8
Procedures
Number
Title
Revision
OSP-CCH/IST-
M702
Control Room Emergency Chiller System B Operability
35
SOP-
HOTWEATHER-
Hot Weather Operations
6
SOP-HVAC/CR-
LU
Control, Cable, and Critical Switchgear Rooms HVAC
Lineup
1
SOP-HVAC/CR-
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
A-9
Section 1R18: Plant Modifications
Miscellaneous
Number
Title
Revision
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
A-10
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
A-11
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
A-12
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
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
A-13
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
A-14
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
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
Standby Gas Treatment Filtration System - Unit A Carbon
Adsorber Test
July 15, 2013
Standby Gas Treatment System Unit B HEPA Filter Test
April 28, 2014
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
A-15
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 291084291084
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
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
A-16
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
A-17
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
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
A-18
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
A-19
Section 4OA1: Performance Indicator Verification
Procedures
Number
Title
Revision
CI-10.17
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
A-20
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
A-21
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.
A-22
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 counters.
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
A-23
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
A-24
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 stations 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
A-25
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 laboratorys 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
A-26
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.
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