IR 05000397/2021003
ML21300A182 | |
Person / Time | |
---|---|
Site: | Columbia |
Issue date: | 11/02/2021 |
From: | Jeffrey Josey NRC/RGN-IV/DRP/RPB-A |
To: | David Brown Energy Northwest |
References | |
IR 2021003 | |
Download: ML21300A182 (30) | |
Text
November 2, 2021
SUBJECT:
COLUMBIA GENERATING STATION - INTEGRATED INSPECTION REPORT 05000397/2021003
Dear Mr. Brown:
On September 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Generating Station. On October 7, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
Two findings of very low safety significance (Green) are documented in this report. Both of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the NRC Resident Inspector at Columbia Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the NRC Resident Inspector at Columbia Generating Station. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Josey, Jeffrey on 11/02/21 Jeffrey E. Josey, Chief Reactor Projects Branch A Docket No. 05000397 License No. NPF-21
Enclosure:
As stated
Inspection Report
Docket Number: 05000397 License Number: NPF-21 Report Number: 05000397/2021003 Enterprise Identifier: I-2021-003-0105 Licensee: Energy Northwest Facility: Columbia Generating Station Location: Richland, Washington Inspection Dates: June 28, 2021 to September 30, 2021 Inspectors: P. Niebaum, Senior Resident Inspector A. Donley, Resident Inspector D. Antonangeli, Health Physicist B. Baca, Health Physicist J. Melfi, Project Engineer J. O'Donnell, Senior Health Physicist E. Simpson, Health Physicist Approved By: Jeffrey E. Josey, Chief Reactor Projects Branch A Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Columbia Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Follow Procedure Resulted in an Inadequate Operability Determination due to a Breach of Secondary Containment Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.5] - Work 71111.15 NCV 05000397/2021003-01 Management Open/Closed The NRC inspectors identified a Green, non-cited violation (NCV) of Technical Specifications 5.4.1, Procedures, when the licensee failed to follow licensee procedure SOP-DOOR/HATCH-OPS, Reactor Building, Turbine Building, Radwaste Building and Containment Personnel, Equipment Access Area Doors, and Hatches, Revision 18, when the reactor building 606 foot roof access hatch was opened for maintenance on July 28, 2021. As a result, secondary containment was not declared inoperable while the access hatch was open.
Inadequate Maintenance Instructions when Performing Valve Diagnostic Testing Leads to Degraded Pipe Support Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71152 Systems NCV 05000397/2021003-02 Identification Open/Closed The NRC inspectors identified a Green, non-cited violation (NCV) of Technical Specification 5.4.1, Procedures, for failure to have adequate licensee procedural guidance and practices when performing diagnostic testing on reactor core isolation cooling (RCIC) valve RCIC-MO-76, which resulted in damage to pipe support RCIC-976S. The damage to the support occurred during diagnostic testing in a prior outage on the valve per work order 02110811-08 and maintenance procedure PPM 10.25.132, Thrust Adjustment and Diagnostic Analysis of Motor Operated Valves for valve RCIC-MO-76. Specifically, licensee personnel manually rotated and bent portions of pipe support RCIC-976S to enable access of a torque thrust cell onto valve RCIC-MO-76. This manual rotation bent tie rods on this support and caused the support to be out of alignment.
Additional Tracking Items
Type Issue Number Title Report Section Status LER 05000397/2021-001-00 LER 2021-001-00 for 71153 Closed Columbia, Breach of Secondary Containment
PLANT STATUS
Columbia Generating Station began the inspection period at 100 percent rated thermal power (RTP). On September 18, 2021, the unit was down powered to approximately 65 percent RTP for a control rod sequence exchange, a steam tunnel entry, and repairs to an adjustable speed drive channel. Columbia returned to RTP on September 20, 2021, and remained at or near RTP for the rest of the inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the coronavirus (COVID-19), resident and regional inspectors were directed to begin telework and to remotely access licensee information using available technology. During this time, the resident inspectors performed periodic site visits each week, increasing the amount of time on site as local COVID-19 conditions permitted.
As part of their onsite activities, resident inspectors conducted plant status activities as described in IMC 2515, Appendix D; observed risk significant activities; and completed on site portions of IPs. In addition, resident and regional baseline inspections were evaluated to determine if all or a portion of the objectives and requirements stated in the IP could be performed remotely. If the inspections could be performed remotely, they were conducted per the applicable IP. In some cases, portions of an IP were completed remotely and on site. The inspections documented below met the objectives and requirements for completion of the IP.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) reactor core isolation cooling system during the annual maintenance outage for the high pressure core spray system on July 27, 2021
- (2) emergency diesel generator 1 while emergency diesel generator 2 was inoperable on August 20, 2021
- (3) high pressure core spray during annual maintenance of the reactor core isolation cooling system on September 14, 2021
- (4) standby service water system B following maintenance on September 24, 2021
Complete Walkdown Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated system configurations during a complete walkdown of standby gas treatment system B following annual maintenance on September 30, 2021.
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Areas DG-2/1, DG-1 diesel generator room; DG-8/1, DG-1 day tank room; and DG-4/1, DG-1 diesel oil storage tank access room; on August 10, 2021
- (2) Fire Area RC-7, electrical equipment room number 2, on August 13, 2021
- (3) Fire Area SW-2, standby service water pumphouse 1B, on August 30, 2021
- (4) Fire Area RC-6/2, reactor core isolation cooling system pump room, on September 20, 2021
- (5) Fire Area R-8, low pressure core spray pump room, on September 20, 2021
- (6) Fire Area R1/1, standby gas treatment area, on September 29, 2021
Fire Brigade Drill Performance Sample (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated fire brigade performance during a fire drill on September 22, 2021.
71111.06 - Flood Protection Measures
Inspection Activities - Internal Flooding (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated internal flooding mitigation protections in the residual heat removal pump C room on August 20, 2021
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during the start of emergency diesel generator 1 on August 19, 2021, and during the load reduction from 100 percent power to 65 percent power on September 18, 2021.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated a licensed operator requalification evaluated scenario on July 20, 2021.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (2 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
- (1) staging and use of the FLEX C-3 air compressor during refueling outage 2R25
- (2) leaking residual heat removal check valve RHR-V-122A
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (6 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) evaluation of station risk for extreme hot weather on July 1, 2021
- (2) yellow risk for high pressure core spray system annual maintenance on July 29, 2021
- (3) yellow risk for increased probability of a plant transient associated with maintenance on the turbine oil reservoir vapor extractors on August 4, 2021
- (4) elevated plant risk for breach of secondary containment for steam tunnel entry on August 11, 2021
- (5) evaluation of station risk during unavailability of emergency diesel generator 4, week of August 16, 2021
- (6) yellow risk for reactor core isolation cooling equipment outage on September 14, 2021
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) emergency diesel generators 1, 2, and 3 elevated intake air temperatures on July 14, 2021
- (2) condition report (CR) 423467, emergency diesel generator 1 mixed air fan controller DMA-TIC-12/2 indicating low on July 23, 2021
- (3) CR 423611, maintenance craft opened the reactor building roof access hatch on July 28, 2021
- (4) CR 422728, RFW-V-65A packing leak could not be isolated after electric backseat on August 10, 2021
- (5) failure of TSP-RCS-R803, division 3 high-low pressure interface valve leak test, for reactor core isolation cooling valve 66 on September 16, 2021
- (6) degraded reactor core isolation cooling valve 1 latching mechanism components on September 28, 2021
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(1 Sample)
- (1) The inspectors evaluated the temporary modification of RFW-V-65A when the licensee electrically back seated the valve to reduce a packing leak on July 1, 2021.
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance test activities to verify system operability and functionality:
- (1) OSP-HPCS/IST-Q701, HPCS system operability test, following a planned system outage on July 30, 2021
- (2) OSP-CONT-M102, secondary containment integrity verification, with work order (WO) 02182918-23 on August 11, 2021
- (3) OSP-FLEX-Q704, diesel generator 4 quarterly surveillance, following maintenance to restore operability on August 19, 2021
- (4) OSP-ELEC-S702, diesel generator 2 semi-annual operability test, following corrective maintenance on August 21, 2021
- (5) Procedure 10.7.5, RCIC turbine uncoupled overspeed test run, following maintenance to restore operability on September 16, 2021
- (6) OSP-RCIC/IST-Q701, RCIC operability test, following a reactor core isolation cooling system equipment outage on September 17, 2021
- (7) OSP-SW/IST-Q702, standby service water loop B operability, following preventive maintenance on September 20, 2021
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance tests:
Surveillance Tests (other) (IP Section 03.01)
- (1) OSP-ELEC-S703, HPCS Diesel Generator Semi-Annual Operability Test, on July 30, 2021
- (3) OSP-ELEC-M702, diesel generator 2 - monthly operability test, on
September 27, 2021 Inservice Testing (IP Section 03.01) (1 Sample)
- (1) OSP-RHR/IST-Q702, RHR loop A operability test, on August 4, 2021
71114.06 - Drill Evaluation
Select Emergency Preparedness Drills and/or Training for Observation (IP Section 03.01)
(1 Sample)
- (1) The inspectors evaluated the emergency planning drill on August 31,
RADIATION SAFETY
71124.05 - Radiation Monitoring Instrumentation
Walkdowns and Observations (IP Section 03.01) (9 Samples)
The inspectors evaluated the following radiation detection instrumentation during plant walkdowns:
- (1) area radiation monitors and continuous air monitors in the reactor building, turbine building and radwaste buildings
- (2) high purity germanium detectors, HIDEX 300 SL liquid scintillation counter, iSOLO alpha counters in the chemistry count room
- (3) GEM-5 and Argos contamination monitors at the chemistry break room, control room, and the radiologically controlled area exits
- (4) SAM-12 tool monitors at the control room, radwaste building, and radiological controlled area exits
- (5) AMP-100 used as a compensatory monitoring device for offgas pre-treatment monitor OG-RE-612
- (6) friskers staged for use in the reactor, turbine, and radwaste buildings
- (7) telepoles and portable ion chambers used during survey observations
- (8) transmitting electronic alarming dosimeters used for dose rate tracking and trending at selected locations in the reactor building
- (9) portable air samplers used for monitoring working zones and perform grab samples
Calibration and Testing Program (IP Section 03.02) (15 Samples)
The inspectors evaluated the current calibration and testing of the following radiation detection instruments:
- (1) Canberra ARGOS 5 A/Bs: HP-EQ-42782 dated June 24, 2021, HP-EQ-42783 dated June 24, 2021, HP-EQ-42820 dated May 3, 2021, HP-EQ-42879 dated May 3, 2021
- (2) Canberra GEM 5s: HP-EQ-42733 dated May 3, 2021, HP-EQ-42734 dated May 3, 2021, HP-EQ-42737 dated August 3, 2020, and HP-EQ-42738 dated June 18, 2020
- (3) Canberra iSolos: serial number (SN) 64111 dated July 2, 2020, SN 64112 dated July 2, 2020; iSolo-2: SN 3085836 dated January 25, 2021
- (4) Eberline AMS-3 continuous air monitor: HP-EQ-34116 dated January 14, 2019; AMS-4 continuous air monitors: HP-EQ-42796 dated October 2, 2020, HP-EQ-42797 dated October 2, 2020, HP-EQ-42807 dated April 16, 2021, HP-EQ-42868 dated September 15, 2020
- (5) Eberline ion chamber RO-2s: RO126 dated March 1, 2021, RO137 dated March 1, 2021, RO172 dated June 7, 2021, RO223 dated March 1, 2021; Ludlum Model 14C: RO264 dated February 24, 2021
- (6) Eberline model ASP-1 RemBall: NO25 dated March 1, 2021
- (7) Eberline RAS-1 air samplers: HP-EQ-32364, HP-EQ-42582, HP-EQ-42775, HP-EQ-42869 batch calibration dated April 19 - 22, 2021
- (8) Fastscan whole body count system: WBC#2 dated July 23,2020;
- (9) General Atomics high range area radiation monitors: ARM-RIS-32 dated July 1, 2021, ARM-RIS-34 dated April 6, 2020
- (10) General Electric area radiation monitors: ARM-RIS-2 dated March 5, 2021, ARM-RIS-8 dated February 3, 2021, ARM-RIS-11 dated March 30, 2020, ARM-RIS-14 dated January 7, 2021, ARM-RIS-22 dated March 16, 2020
- (11) high purity germanium gamma spectroscopy units: Ortec-5, Ortec-6, and Ortec-7 annual calibration verification under WO package 02123220-01 dated January 12, 2021
- (12) Ludlum model 2 frisker: F175 dated April 27, 2021; Ludlum Model 177 friskers: F104 dated April 28, 2021, F119 dated April 28, 2021, F150 dated April 28, 2021, F160 dated April 29, 2021
- (13) MGP AMP-100: RM-82 dated March 1, 2021
- (14) Mirion telepole IIs: T093 dated March 1, 2021, T112 dated April 27, 2021; teletector model 6112M: T-070 dated March 1, 2021
- (15) SAM12 small article monitors: HP-EQ-42713 dated June 30, 2021, HP-EQ-42813 dated February 25, 2021, HP-EQ-42814 dated February 25, 2021 Effluent Monitoring Calibration and Testing Program Sample (IP Sample 03.03) (3 Samples)
The inspectors evaluated the calibration and maintenance of the following radioactive effluent monitoring and measurement instrumentation:
- (1) reactor building elevated release radiation monitor PRM-RIS-1 (PRM-RE-11 stack monitor low range, PRM-RE-12 stack monitor intermediate range, and PRM-RE-13 stack monitor high range) calibration dated May 5,2021, with associated corrective actions
- (2) liquid radwaste effluent radiation monitor FDR-RIS-606 calibrations dated September 27, 2019, and April 23, 2021, with associated corrective actions
- (3) turbine building noble gas monitors TEA-RIS-12 low range calibration dated December 5, 2019, and TEA-RIS-13 high range calibration dated November 21, 2020, with associated corrective actions
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) reactor building standby gas treatment system
- (2) turbine building effluent ventilation system
- (3) reactor building effluent ventilation system
- (4) radwaste building effluent ventilation system
Sampling and Analysis (IP Section 03.02) (3 Samples)
The inspectors evaluated effluent samples, sampling processes and compensatory samples, as available, for the following systems:
- (1) weekly effluent sampling of particulate and iodine for the radwaste, turbine, and reactor building ventilation systems using procedure PPM 16.11.16, Weekly Iodine, Particulate, and Tritium Analysis
- (2) compensatory weekly effluent sampling of the particulate and iodine for the radwaste ventilation systems using procedure PPM 12.5.37, WEA Temporary Cart Sampling and Flow Monitoring
- (3) compensatory continuous/weekly effluent sampling system setup for the turbine building effluent ventilation systems using procedure PPM 12.5.35B, TEA Temporary
Cart Sampling and Flow Monitoring Dose Calculations (IP Section 03.03) (2 Samples)
The inspectors evaluated the following dose calculations:
- (1) continuous gaseous release monthly dose assessment/analysis 2019 (November, April, May, June)
- (2) continuous gaseous release monthly dose assessment/analysis 2020 (January, February, March)
Abnormal Discharges (IP Section 03.04)
There were no abnormal discharges during the monitoring period.
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples.
Radiological Environmental Monitoring Program (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated the implementation of the licensees radiological environmental monitoring program.
GPI Implementation (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees implementation of the groundwater protection initiative (GPI) program to identify incomplete or discontinued program elements.
There were no incomplete or discontinued program elements identified.
71124.08 - Radioactive Solid Waste Processing & Radioactive Material Handling, Storage,
& Transportation
Radioactive Material Storage (IP Section 03.01)
Inspectors evaluated the licensees performance in controlling, labeling, and securing radioactive materials in the following areas:
- (1) low specific activity (LSA) pad
- (2) RW-167 container storage yard
- (3) high level storage area (NUPAC cage) on the 437 foot elevation of the radwaste building
Radioactive Waste System Walkdown (IP Section 03.02) (2 Samples)
Inspectors walked down accessible portions of these solid radioactive waste systems and evaluated the systems' configuration and functionality, to include:
- (1) reactor water clean up filter demineralizer
- (2) equipment drain / floor drain polisher
Waste Characterization and Classification (IP Section 03.03) (3 Samples)
The inspectors evaluated the licensees characterization and classification of radioactive waste from the following:
- (1) reactor water cleanup filter demineralizer powdered resin system
- (2) equipment drain / floor drain polishing bead resin system
- (3) dry active waste
Shipment Preparation (IP Section 03.04) (1 Sample)
- (1) The inspectors observed that shipments containing differing forms of radioactive material (waste streams) were prepared according to requirements. The shipments included an LSA shipment (21-68) of dry active waste for burial and an LSA shipment (21-66) of dry active waste for processing.
Shipping Records (IP Section 03.05) (4 Samples)
The inspectors evaluated the following non-excepted radioactive material shipments through a record review:
- (1) shipment # 19-114, LSA-II, condensate filter demineralizer (resin) liners 19-093-HP and 19-096-HP, dated December 18, 2019
- (2) shipment # 20-01, type A LSA, equipment drain / floor drain filter demineralizer (tank 22 resin) liner 19-075-HP, category 2 quantity, dated January 16, 2020
- (3) shipment # 20-29, type B, reactor water clean up (resin) liner 119-101-HP, category 2 quantity, dated August 13, 2020
- (4) shipment # 21- 68, LSA-II, consolidated dry active waste (trash) liner 19-107-OT, dated June 28,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS06: Emergency AC Power Systems (IP Section 02.05) ===
- (1) July 1, 2020, to June 30, 2021
MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)
- (1) July 1, 2020, to June 30, 2021
MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)
- (1) July 1, 2020, to June 30, 2021
MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)
- (1) July 1, 2020, to June 30, 2021
MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)
- (1) July 1, 2020, to June 30, 2021
71152 - Problem Identification and Resolution
Annual Follow Up of Selected Issues (IP Section 02.03) (2 Samples)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) CR 422006, reactor coolant system excessive heat-up rate during reactor startup, on June 16, 2021
- (2) CR 419968, reactor core isolation cooling system valve RCIC-V-76 degraded pipe support on May 18, 2021
71153 - Follow Up of Events and Notices of Enforcement Discretion Event Report (IP Section 03.02)
The inspectors evaluated the following licensee event report (LER):
- (1) LER 05000397/2021-001-00, Breach of Secondary Containment (ADAMS Accession No. ML21266A279). The inspection conclusions associated with this LER are documented in this report under Inspection Results Section
INSPECTION RESULTS
Failure to Follow Procedure Resulted in an Inadequate Operability Determination due to a Breach of Secondary Containment Cornerstone Significance Cross-Cutting Report Aspect Section Barrier Integrity Green [H.5] - Work 71111.15 NCV 05000397/2021003-01 Management Open/Closed NRC inspectors identified a Green, non-cited violation (NCV) of Technical Specifications 5.4.1, Procedures, when the licensee failed to follow licensee procedure SOP-DOOR/HATCH-OPS, Reactor Building, Turbine Building, Radwaste Building and Containment Personnel, Equipment Access Area Doors, and Hatches, Revision 18, when the reactor building 606 foot roof access hatch was opened for maintenance on July 28, 2021. As a result, secondary containment was not declared inoperable while the access hatch was open.
Description:
On July 28, 2021, while Columbia was operating in Mode 1 at 100 percent reactor power, maintenance personnel failed to contact the main control room before breaching secondary containment by opening an access hatch on the reactor building roof.
As a result, the main control room received the secondary containment high differential pressure alarm, which alarms when differential pressure is greater than or equal to -0.25 inches of water. The licensee wrote condition report (CR) 423611 and evaluated the operability of secondary containment. Operations staff concluded that secondary containment remained operable following an evaluation of licensee procedure OSP-INST-H101, Attachment 9.9, Secondary Containment Drawdown Time Determination -
The inspectors reviewed the CR 423611 and the operability evaluation and determined operations staff should have concluded secondary containment was inoperable when the reactor building roof access hatch was opened. This was because when the access hatch was open, it represented a breach size larger than allowable. Additionally, section 2.1 of WO 02155418 used to perform the work stated, in part, that access is gained to the reactor building roof access hatch via licensee procedure SOP-DOOR/HATCH-OPS, Reactor Building, Turbine Building, Radwaste Building and Containment Personnel, Equipment Access Area Doors, and Hatches, Revision 18. Section 5.15 of this procedure contains a caution note requiring entry into Technical Specifications limiting condition for operation (LCO) 3.6.4.1 - Secondary Containment in Modes 1, 2 and 3, and requires logging secondary containment as inoperable in the control room logs. Work order 02155418 did not list LCO 3.6.4.1, Secondary Containment on the work order impact statement as expected.
The inspectors discussed this with operations staff who initiated CRs 423690, 423693, and made an 8-hour non-emergency report in accordance with 10 CFR 50.72(b)(3)(v)(C) and (D)on July 29, 2021. Event notification EN 55385 and LER 05000397/2021-001-00 contain additional information.
Corrective Actions: The licensee revised the operability evaluation and made the required 8-hour, non-emergency report in accordance with 10 CFR 50.72.
Corrective Action References: CRs 423611, 423690, and 423693
Performance Assessment:
Performance Deficiency: Failure to follow licensee procedure SOP-DOOR/HATCH-OPS, Reactor Building, Turbine Building, Radwaste Building and Containment Personnel, Equipment Access Area Doors, and Hatches, Revision 18, when the reactor building 606 foot roof access hatch was opened for maintenance on July 28, 2021, was a performance deficiency. Specifically, the licensee failed to declare secondary containment inoperable as required.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the configuration control attribute of the barrier integrity cornerstone and adversely affected the cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding screened to Green, very low safety significance, when considering the Control Room, Auxiliary, Reactor, or Spent Fuel Pool Building screening questions in Exhibit 3, Barrier Integrity Screening Questions.
Cross-Cutting Aspect: H.5 - Work Management: The organization implements a process of planning, controlling, and executing work activities such that nuclear safety is the overriding priority. The work process includes the identification and management of risk commensurate to the work and the need for coordination with different groups or job activities. Specifically, the impact statement associated with work order 02155418 did not recognize that secondary containment would be inoperable when the reactor building 606 foot hatch was opened for maintenance.
Enforcement:
Violation: Technical Specifications 5.4.1.a, Procedures, requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, revision 2, Appendix A, February 1978.
Section 9.a of Appendix A requires maintenance that can affect the performance of safety-related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
WO 02155418 was established and implemented to perform maintenance activities that can affect the performance of secondary containment. Section 2.1 stated in part that access is gained via the reactor building roof access hatch per SOP-DOOR/HATCH-OPS. Section 5.15 of this procedure cautions that opening the reactor building roof access hatch in Modes 1, 2, or 3 requires entry into Technical Specification limiting condition for operation 3.6.4.1.
Contrary to these requirements, on July 28, 2021, the licensee failed to follow licensee procedure SOP-DOOR/HATCH-OPS, Reactor Building, Turbine Building, Radwaste Building and Containment Personnel, Equipment Access Area Doors, and Hatches, Rev. 18 when the reactor building 606 foot roof access hatch was opened for maintenance. As a result, operations staff did not recognize that secondary containment was inoperable and did not enter the required actions statement associated with technical specifications limiting condition for operation 3.6.4.1.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Inadequate Maintenance Instructions when Performing Valve Diagnostic Testing Leads to Degraded Pipe Support Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [P.1] - 71152 Systems NCV 05000397/2021003-02 Identification Open/Closed NRC inspectors identified a Green, non-cited violation (NCV) of Technical Specification 5.4.1, Procedures, for failure to have adequate licensee procedural guidance and practices when performing diagnostic testing on valve RCIC-MO-76, which resulted in damage to pipe support RCIC-976S. The damage to the support occurred during diagnostic testing in a prior outage on the valve per work order 02110811-08 and maintenance procedure PPM 10.25.132, Thrust Adjustment and Diagnostic Analysis of Motor Operated Valves for valve RCIC-MO-76. Specifically, licensee personnel manually rotated and bent portions of pipe support RCIC-976S to enable access of a torque thrust cell onto valve RCIC-MO-76.
This manual rotation bent tie rods on this support and caused the support to be out of alignment.
Description:
On May 18, 2021, inspectors identified that pipe support RCIC-976S was damaged and not in the configuration noted on the pipe hanger drawing RCIC-976S. Pipe hanger drawing RCIC-976S shows a vertical spring can supporting a horizonal upper piece of angle iron, two vertical tie rods, and a lower horizontal piece of angle iron. The reactor core isolation cooling (RCIC) system pipe is connected to the lower horizonal piece of angle iron with a U-bolt clamp. The as-found condition of this support had the horizontal pieces of angle iron at about a 45-degree angle instead of horizontal, with the tie rods bent and almost in contact with the pipe.
The licensee repaired the pipe support under WO 02179663 on May 27, 2021. The licensee evaluated the effect of the damaged support on the RCIC system and determined that the pipe stresses were within design limits. The licensee concluded the damage to the pipe hanger damage likely occurred during the prior outage when the licensee performed diagnostic testing on valve RCIC-MO-76 per PPM 10.25.132, Thrust Adjustment and Diagnostic Analysis of Motor Operated Valves. This diagnostic testing was performed on May 31, 2019, under WO 02110811-08. To perform this maintenance activity and gain access, the workers would have had to rotate the valve to place a load cell.
Step 1.2.1 of Attachment 9.10, Thrust and Torque Instrumentation Setup and Removal Guidelines in procedure PPM 10.25.132 notes that a torque thrust cell can be installed between the actuator and the valve. Installation requires the actuator be rotating the actuator
[stet]. A careful inspection for interferences or other problems (such as insufficient motor lead length to allow rotation) is required.
The inspectors concluded that the interferences caused by the hanger affecting the torque thrust cell installation were not adequately addressed or removed during this maintenance.
As a result, the pipe support/hanger was left degraded since May 13, 2019, until discovered by the inspectors on May 18, 2021, and repaired by the licensee on May 27, 2021.
Corrective Actions: The licensees corrective actions included fixing the pipe support and modifying procedure PPM 10.25.132 and work orders to ensure removal of the pipe supports before performing diagnostic testing in the future. The licensee also conducted an extent of condition review of similar pipe support configurations and did not identify any additional degraded pipe supports.
Corrective Action References: CR 419968 and WO 02179663
Performance Assessment:
Performance Deficiency: The failure to provide adequate work instructions during the installation of a torque thrust cell on valve RCIC-V-76 was a performance deficiency. As a result, licensee personnel manually rotated and bent portions of pipe support RCIC-976S.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the configuration control attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, on May 31, 2019, during the performance of diagnostic testing on motor-operated valve RCIC-MO-76, interferences were not removed or assessed when performing maintenance which led to the damage of the associated pipe support.
Additionally, the inspectors determined that this issue was sufficiently similar to example 3.k in NRCs inspection manual chapter (IMC) 0612, Appendix E, Examples of Minor Issues dated January 1, 2021, to conclude that the performance deficiency was more than minor because the licensee had to perform actions (an evaluation) to continue to demonstrate operability of RCIC.
Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green) under Exhibit 2, Mitigating Systems Screening Questions, because the performance deficiency did not impact the operability or PRA functionality of the affected structure, system or component. Specifically, the licensee was able to demonstrate that the RCIC system remained operable with the damaged pipe support by performing an evaluation.
Cross-Cutting Aspect: P.1 - Identification: The organization implements a corrective action program with a low threshold for identifying issues. Individuals identify issues completely, accurately, and in a timely manner in accordance with the program. Specifically, the licensee did not identify the need to have instructions to remove and reinstall the pipe support to prevent damage to the pipe support when performing a diagnostic test on valve RCIC-MO-76.
Enforcement:
Violation: Technical Specification 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. Section 9.a of Appendix A of Regulatory Guide 1.33, requires, in part, that maintenance that can affect the performance of safety-related equipment should be performed in accordance with documented instructions appropriate to the circumstances. The licensee implemented WO 02110811-08 using procedure PPM 10.25.132, Thrust Adjustment and Diagnostic Analysis of Motor Operated Valves, Revision 33, to perform diagnostic testing on motor-operated valve RCIC-MO-76.
Step 1.2.1 of the Thrust and Torque Instrumentation Setup and Removal Guidelines contained in procedure PPM 10.25.132 states that a torque thrust cell can be installed between the actuator and the valve. Installation requires the actuator be rotating the actuator
[stet]. A careful inspection for interferences or other problems (such as insufficient motor lead length to allow rotation) is required.
Contrary to the above, on May 31, 2019, maintenance occurred on RCIC-MO-76 using instructions that were not appropriate for the circumstances. Specifically, WO 02110811-08 failed to contain adequate instructions to address the interference problem which ultimately led to damage of the RCIC pipe hanger, RCIC-976S.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 1, 2021, the inspectors presented the public radiation safety inspection results to Mr. R. Schuetz, Site Vice President, and other members of the licensee staff.
On October 7, 2021, the inspectors presented the integrated inspection results to Mr. D. Brown, Site Vice President, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.04 Corrective Action Action Requests 424457, 425221, 425508, 423666, 398768, 377422, 425576,
Documents (ARs) 725595
Drawings M512-2 Flow Diagram Diesel Oil & Miscellaneous Systems Diesel 041
Generator Building
M519 Flow Diagram Reactor Cores Isolation Cooling System 103
M520 Flow Diagram HPCS and LPCS Systems Reactor Building 105
M524-1 Flow Diagram Standby Service Water System, Reactor, 140
Radwaste, D.G. Bldgs and Yard
M524-2 Flow Diagram Standby Service Water System Reactor, 124
Radwaste, D.G. Bldg.s and Yard
M544 Flow Diagram HVAC-Standby Gas Treatment Reactor 076
Building
Procedures OSP-ELEC-C701 Diesel Generator 1 - AC Source Operability Check 014
OSP-SW-M102 Standby Service Water Loop B Valve Position Verification 047
SOP-DG1-LU Emergency Diesel Generator (DIV 1) Valve and Power 007
Supply Lineup
SOP-DG1-STBY Emergency Diesel Generator (DIV 1) Standby Lineup 022
SOP-HPCS-LU HPCS Valve and Breaker Lineup 004
SOP-HPCS- Placing HPCS in Standby Status 004
STBY
SOP-RCIC-STBY Placing RCIC in Standby Status 012
SOP-SGT-LU Standby Gas Treatment System Lineup 000
SOP-SGT-STBY Placing Standby Gas Treatment in Standby Status 002
SOP-SW-LU Standby Service Water System Valve and Breaker Lineup 014
Work Orders 02184042, 02184044, 02153758, 02117221, 02173335,
29161905, 29162728, 29141412, 29161954
71111.05 Calculations FP-02-85-03 Combustible Loading Calculation 011
NE-02-85-19 Post Fire Safe Shutdown (PFSS) Analysis 014
Corrective Action Action Requests 402774, 415524, 417503, 418461, 424939, 425369
Documents (ARs)
71111.05 Corrective Action Action Requests 424136, 424250
Documents (ARs)
Resulting from
Inspection
Fire Plans PFP-DG- Diesel Generator Building 004
BUILDING
PFP-MN-XFMR- MN XFMR YD Misc Bldgs 007
YD-MISC
PFP-RB-422 Reactor 422 006
PFP-RB-572 Reactor 572 005
Miscellaneous Fire Impairment Permit 21-0184
Drill Report for Scenario RX-E-TR-7-BB on 3/31/21 (Crew F) 000
Drill Report for Scenario 19-010 on 4/21/21 (Crew A) 000
Fire Safe Normal Shutdown Manual Action Feasibility Review 006
Shutdown
Program
Overview, FPF
4.1-2
Procedures 1.3.10 Plant Fire Protection Program Implementation 036
1.3.10C Control of Combustibles 022
ABN-FIRE Fire 043
TPD-22 Fire Brigade Training Program Description 006
Work Orders 02169521, 02171425
71111.06 Calculations ME-02-02-02 Reactor Building Flooding Analysis 004
Drawings M539 Flow Diagram Floor Drain System Reactor Building 090
M567 Reactor Building Plan El. 422'-3 and El. 441' General 028
Arrangement
Procedures 5.3.1 Secondary Containment Control 022
5.5.27 RB 422 max Safe Operating Level Measurement 005
ABN-ELEC- Loss of All Off-Site Electrical Power 018
ABN-FLOODING Flooding 022
71111.11Q Corrective Action Action Requests 422410
Documents (ARs)
Miscellaneous LR002530 Simulator Guide for Cycle 21-3 Evaluated Scenario 000
71111.11Q Procedures 3.2.6 Power Maneuvering 020
OI-09 Operations Standards and Expectations 079
OSP-ELEC-C701 Diesel Generator 1 - AC Source Operability Check 014
SWP-TQS-01 Training, Qualifications and Standards 020
SWP-TQS-02 Training Committees 018
TDI-02 Systematic Approach to Training 043
TDI-08 Licensed Operator Requalification Program 018
TDI-23 LORQ Annual Exam Development and Administration 016
71111.12 Corrective Action Action Requests 417982, 418184, 418190, 418473, 419032, 419736, 420790
Documents (ARs)
Drawings M521-1 Flow Diagram Residual Heat Removal System Loop A 108
Miscellaneous IST-4 Inservice Testing Program Plan, Fourth Inspection Interval 5.001
Procedures 1.5.11 Maintenance Rule Program 016
1.5.18 Managing B.5.b and FLEX Equipment Unavailability 009
ABN-CAS Control Air System Failure 012
71111.13 Corrective Action Action Requests 424224
Documents (ARs)
Resulting from
Inspection
Miscellaneous L21-E-GEN-DG4- eSOMs Tracker
001
P-HPCS-SYS-1- Clearance Order
001
Procedures 1.3.83 Protected Equipment Program 034
1.5.11 Maintenance Rule Program 016
1.5.14 Risk Assessment and Management for 043
Maintenance/Surveillance Activities
1.5.18 Managing B.5.b and FLEX Equipment Unavailability 009
FLEX-01 FLEX Program 003
Work Orders 02157618
71111.15 Calculations E/I-02-91-02 Calculation for Division 1 and 2 and 3 Diesel Generator 021
Loading
Corrective Action Action Requests 408585, 420359, 420469, 420338, 422040, 425160, 425266
Documents (ARs)
Drawings 41A-00, 55,1 Valen Engineering - 20 & 24 Gate Valve 007
Procedures IST-4 Inservice Testing Program Plan Fourth Ten-Year Inspection 005
Interval
Work Orders 02144020, 02113444, 02144982, 02179902, 02181627
71111.18 Corrective Action Action Requests 422503, 422728
Documents (ARs)
Miscellaneous Control Room Operator Logs, June 30-July 1, 2021
MES-10 Motor Operative Valve Sizing and Switch Setting 010
MMDS RFW-MO- MOV Master Data Sheet 014
65A
Procedures 10.25.176 Back Seating Motor-Operated Valves (MOVs) 011
SWP-CM-02 Temporary Configuration Changes 004
Work Orders 02145404
71111.19 Corrective Action Action Requests 424287, 425269, 425268, 425265, 425257
Documents (ARs)
Corrective Action Action Requests 424228
Documents (ARs)
Resulting from
Inspection
Procedures SOP-ENTRY- Personnel Entry into Steam Tunnel 010
STMTNL
SWP-TST-01 Post-Maintenance Testing Program 017
Work Orders 02153296, 02160243, 02168154, 29162182, 02149044,
2181627
71111.22 Corrective Action Action Requests 425470
Documents (ARs)
Procedures SOP-DG2- Emergency Diesel Generator (DIV 2) Start 034
START
Work Orders 02147342, 02147639, 02180823
71114.06 Miscellaneous ERO Team 'C' Drill Report 03/09/2021
ERO Team 'B' Drill Report 04/06/2021
Team 'D' EP Drill Scenario 08/31/2021
Procedures 13.2.2 Determining Protective Action Recommendations 020
71124.05 Calibration 0060045 iDC Recalibration/Certification: Initial iDC calibration with 05/16/2020
Records DMC-3000 golden dosimeters. New drawer with DMC-3000
insert.
0060045 iDC Recalibration/Certification: Initial iDC calibration with 06/23/2020
new drawer with DMC-2000 insert.
HP-EQ-0064845 Hopewell Designs, Inc. BX3A Box Calibrator 01/24/2020
calibration/verification
NO16 Eberline (Thermo-Fisher) ASP-1 with NRD Probe - Neutron 01/07/2020
Transfer Standard
Shepard 149 Shepherd Panoramic Neutron lrradiator 01/27/2021
Calibration/Verification
Shepherd Gamma Irradiator Calibration: Shepherd 142-10 Verification 10/08/2020
0057267
Shepherd 28- Gamma Irradiator Calibration: Shepherd 28 Verification 10/07/2020
2711
Corrective Action Action Requests 415181, 416283, 361706, 401046, 401047, 402058, 405381,
Documents (ARs) 414236, 416283, 417658, 417740, 418254,
418272
Miscellaneous Calibration Lab Irradiator Periodic Dose Rate Decay 12/28/2020
Adjustment
Routine Calibration Sources - Process and Effluent Monitors 06/16/2021
Procedures CI-13.10 Canberra iSolo Alpha/Beta Counting System 005
CI-13.12 Global Value Gamma Ray Analyzer System 007
HPI-12.100 Calibration of the SAM12 Small Article Monitor 007
HPI-12.106 Calibration of the VF FCM-11 Large Area Probe 000
Contamination Monitor
HPI-12.92 Calibration of the Canberra GEM-5 Gamma Sensitive Portal 007
Monitor
HPI-12.98 Calibration of the Canberra Argos-5 A/B Whole Body 007
Contamination Monitor
HPI-5.6 Calibration of the Renaissance Fastscan Whole Body Count 008
System
HPI-7.23 Mirion TelePole II Telescopic Survey Meter Calibration 000
HPI-7.25 Ludlum Model 177 Alarm Ratemeter Calibration with GM 008
Probe
HPI-7.5 Eberline Model RO-2 and RO-2A Calibration 010
HPI-7.50 Calibration of the Eberline Model ASP-1 with NRD Neutron 006
Detector
HPI-7.52 Ludlum Model 14C Geiger Counter Calibration With 44-6 GM 004
Detector
HPI-7.59 MGP Model AMP Series Survey Meter Calibration 002
HPI-7.9 Calibration of the Teletector Model 6112 010
PPM 10.24.243 Eberline/Thermo Scientific AMS-4 Calibration 002
PPM 16.1.11 Reactor (Rx) Building Elevated Discharge Radiation Activity 003
Monitoring & Sampling System - CC/RC
Self-Assessments AR-SA 00413681 Snapshot Self-Assessment Report: NRC IP 71124.05 04/08/2021
Radiation Monitoring Instrumentation
AU-RP/RW-19 Quality Services Audit Report: Radiation Protection and 12/12/2019
AU-RP/RW-20 Quality Services Audit Report: Radiation Protection and 01/14/2021
71124.06 Calculations Dose assessments for January, February, and March 2020
according to PPM 16.12.2
Dose assessments for April, May, June, and November 2019
according to PPM 16.12.2
Corrective Action Action Requests 00401638, 00402154, 00402417, 00402685, 00403474,
Documents (ARs) 00403544, 00404378, 00404595, 00404595, 00405458,
00405883, 00406638, 00407257, 00407959, 00408042,
00409371, 00409571, 00409996, 00410046, 00410055,
00410573, 00410877, 00411390, 00411393, 00413884,
00413899, 00414374, 00414891, 00414891, 00415102,
00416525, 00417056, 00417107, 00418058, 00418760,
00418795, 00420004
Miscellaneous Energy Northwest Columbia Generating Station 2nd Quarter
2019 - Results of environmental cross check program
Energy Northwest Columbia Generating Station 3rd Quarter
2019 - results of radiochemistry cross check program
Procedures PPM 10.2.82 HEPA Filter In-Place Testing 008
PPM 12.5.35B TEA Temporary Cart Sampling and Flow Monitoring 012
PPM 16.1.11 Rx Bldg Elevated Discharged Radiation Activity Monitoring & 003
Sampling System - CC/RC
PPM 16.10.1 Radioactive Liquide Waste Discharge to the River 008
PPM 16.11.1 Monthly Grab Gas Samples 014
PPM 16.11.4 Monthly Composite Particulate Sample Analysis 008
PPM 16.11.5 Quarterly Composite Particulate Sample Analysis 008
PPM 16.11.6 Weekly Iodine, Particulate, and Tritium Analysis Results 025
PPM 16.12.1 Liquid Release Dose Assessments 007
PPM 16.12.2 Monthly Gaseous Release Dose Assessment 016
PPM 16.14.1 Gaseous Monitor Setpoint Determinations 006
PPM 16.14.2 Liquid Monitor Setpoint Calculations 007
SWP-PRO-02 Preparation, Review, Approval and Distribution of 053
Procedures
Self-Assessments AR-SA 00412732 Energy Northwest Snapshot Self-Assessment Report - NRC 02/25/2021
IP 71124.06 Radioactive Gaseous and Liquid Effluent
Treatment
AR-SA 00413740 Energy Northwest Snapshot Self-Assessment Report - 01/07/2021
Performance Indicator(PI) Verification PR-01: Radiological
Effluent Technical Specifications/Offsite Dose Calculation
Manual Radiological Effluent Occurrences
71124.07 Calibration WO 02080912 01 Flow Proportional Composite Water Sampler 09/22/2017
Records WO 02119828 01 Collins Automatic Samplers for Water Pollution Control 10/22/2019
WO 02141215 01 Wind Speed/Direction Channel Calibration 33 foot and 245 04/21/2021
foot
WO 02162662 01 Meteorology Temperature Monitoring Instruments 04/23/2021
Corrective Action Action Requests 00404038, 00404668, 00404711, 00407313. 00407596,
Documents (ARs) 00416009, 00416264, 00416842, 00415514, 00403088
Miscellaneous Columbia Generating Station Radiological and 04/14/2020
Environmental Monitoring Program 2019 Annual
Radiological Environmental Operating Report
Columbia Generating Station Radiological and 04/12/2021
Environmental Monitoring Program 2020 Annual
Radiological Environmental Operating Report
Procedures PPM 1.11.1 Radiological Environmental Monitoring Program 013
Implementation Procedure
PPM 10.24.74 Periodic Inspection of Meteorological System 017
SOP 08.06 REMP Sample Scheduling, Collection, and Shipping 004
SOP 09.10 Environmental TLD Calculations 001
SOP 11.06 Fish Collection and Preparation 003
SOP 11.07 REMP Water Sample Collection 007
SOP 11.08 Distribution and Collection of Environmental Dosimeters 011
SOP 11.09 REMP Air Sample Collection 007
SOP 12.07 Radiological Inter-Laboratory and Intra-Laboratory 001
Comparison Programs
Self-Assessments AR-SA 00413683 Energy Northwest Snapshot Self-Assessment Report 01/07/2021
Audit Report: Chemistry and Environmental Monitoring Program 10/14/2020
AU-CH-20
71124.08 Corrective Action Action Requests 00400816, 00401606, 00402288, 00403248, 00404206,
Documents (ARs) 00408435, 00409904, 00410019, 00410982, 00412657,
00413761, 00416263, 00419571
Corrective Action Action Requests 00422605
Documents (ARs)
Resulting from
Inspection
Miscellaneous Access Request/Termination Form 08/24/2020
Access Request/Termination Form 02/18/2021
20 Columbia Generating Station Scaling Factors 04/29/2021
Procedures 11.2.23.1 Shipping Radioactive Materials and Waste 022
11.2.23.14 Sampling of Radioactive Waste Streams 014
11.2.23.4 Packaging Radioactive Material and Waste 027
11.2.23.45 Management of Spent Fuel Pool Filters, Irradiated, and Non- 001
Irradiated Items to Support Packaging, Transportation, and
Disposal as Low-Level Radwaste
11.2.23.46 Shipment of Category 1 and 2 Material 000
11.2.23.50 Type B Packaging and Requirements Checklist 000
HPI-16.9 Radioactive Waste Shipping Training Requirements 000
HSP-SSC-O801 Sealed Source and Device Surveillance Testing 006
Part37-01 Columbia Generating Station Part 37 Security Plan for the 06/21/2018
Protection of Category 1 and Category 2 Quantities of (Rev. 2)
Radioactive Material
SPIP-SEC-66 Security Measures for the Protection of Category 1 and 000 (Minor
Category 2 Radioactive Materials 003)
SWP-RMP-01 Radioactive Waste Management Program 004
SWP-RMP-02 Radioactive Waste Process Control Program 008
SWP-RMP-04 Radioactive Shipping Program 001
Radiation VSDS_Prod-M- Building 167 and Storage Quarterly 05/19/2021
Surveys 20210519-14
VSDS_Prod-M- Outside LSA Pad and Spray Pond Monthly 06/07/2021
210607-7
VSDS_Prod-M- RW 437 NUPAC Update Survey after O/T Loading 06/21/2021
210621-5
Self-Assessments AR-SA 00399689 Snapshot Self-Assessment Report: Annual Review of 10/31/2019
Columbia Generating Station (CGS) Implementation of 10 CFR Part 37, Physical Protection of Category 1 and
Category 2 Quantities of Radioactive Material (Part 37 RAM)
AR-SA 00411466 Snapshot Self-Assessment Report: Annual 10 CFR Part 37 10/24/2020
Program Assessment
AR-SA 00413741 Snapshot Self-Assessment Report: Assess Columbia's 03/21/2021
Radiation Protection Organization readiness for NRC
Inspection 71124.08, Radioactive Solid Waste Processing
and Radioactive Material Handling, Storage, and
Transportation.
AU-RP-RW-20 Quality Services Audit Report: Radiation Protection and 01/14/2021
AU-RP/RW-19 Quality Services Audit Report: Radiation Protection and 12/12/2019
Shipping Records 2019 Radioactive Shipping Log
20 Radioactive Shipping Log
21 Radioactive Shipping Log
Shipment # 19- LSA-II, Condensate Filter Demineralizer (Resin) Liners 19- 12/18/2019
114 093-HP and 19-096-HP
Shipment # 20-01 >Type A LSA, Equipment Drain / Floor Drain Filter 01/16/2020
Demineralizer (Tank 22 Resin) Liner 19-075-HP, Category 2
Quantity
Shipment # 20-29 Type B, Reactor Water Clean Up (Resin) Liner 119-101-HP, 08/13/2020
Category 2 Quantity
Shipment # 21-68 LSA-II, Consolidated Dry Active Waste (Trash) Liner 19-107- 06/28/2021
Work Orders 02156377-01 HSP-SSC-O801 Sealed Source Check 09/15/2020
2171504-01 HSP-SSC-O801 Sealed Source Check 02/01/2021
71151 Corrective Action Action Requests 387833, 418190
Documents (ARs)
Miscellaneous MSPI Emergency AC Power System Derivation Reports 09/14/2021
MSPI High Pressure Injection System Derivation Reports 09/14/2021
Control Room Operator Logs for 7/1/2020 to 6/30/2021
MSPI Margin Report through June 2021 09/14/2021
MSPI UAI Derivation Report for RHR 06/30/2021
MSPI URI Derivation Report for RHR 06/30/2021
MSPI UAI Derivation Report for Heat Removal 06/30/2021
MSPI URI Derivation Report for Heat Removal 06/30/2021
MSPI UAI Derivation Report for Cooling Water 06/30/2021
MSPI URI Derivation Report for Cooling Water 06/30/2021
MSPI UAI Derivation Report for Emergency AC Power 06/30/2021
Systems
MSPI URI Derivation Report for Emergency AC Power 06/30/2021
Systems
MSPI UAI Derivation Report for High Pressure Injection 06/30/2021
Systems
MSPI URI Derivation Report for High Pressure Injection 06/30/2021
Systems
MSPI-01-BD- Mitigating System Performance Index Basis Document 021
0001
71152 Miscellaneous Main Control 06/16/2021
Room Logs
27