IR 05000397/2018004

NRC Integrated Inspection Report 05000397/2018004

ML19028A318
Person / Time
Site:	Columbia
Issue date:	01/28/2019
From:	Mark Haire NRC/RGN-IV/DRP/RPB-A
To:	Sawatzke B Energy Northwest
References
IR 2018004
Download: ML19028A318 (25)

Text

January 28, 2019

SUBJECT:

COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000397/2018004

Dear Mr. Sawatzke:

On December 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Columbia Generating Station. On January 10, 2019, the NRC inspectors discussed the results of this inspection with Mr. W. Grover Hettel, Chief Nuclear Officer/Vice President Nuclear Generation, and other members of your staff. The results of this inspection are documented in the enclosed report.

NRC inspectors documented two findings of very low safety significance (Green) in this report.

One of these findings involved a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violation or significance of the NCV, 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 the Columbia Generating Station.

If you disagree with a cross-cutting aspect assignment or a finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the 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 the 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Mark S. Haire, Branch Chief Project Branch A Division of Reactor Projects

Docket No. 50-397 License No. NPR-21

Enclosure:

Inspection Report 05000397/2018004 w/attachment: Documents Reviewed

Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number(s):

05000397

License Number(s):

NPF-21

Report Number(s):

05000397/2018004

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, Washington

Inspection Dates:

October 1, 2018 to December 31, 2018

Inspectors:

G. Kolcum, Senior Resident Inspector

L. Merker, Resident Inspector

J. Braisted, Reactor Inspector

M. Hayes, Operations Engineer

N. Hernandez, Operations Engineer

C. Smith, Reactor Inspector

Approved By:

M. Haire, Branch Chief

Project Branch A

Division of Reactor Projects

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Columbia Generating Station in accordance with the Reactor Oversight Process. 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. NRC-identified and self-revealed findings, violations, and additional items are summarized in the tables below.

List of Findings and Violations

Licensed Operator Failure Rate Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green FIN 05000397/2018004-01 Closed H.1 -

Resources 71111.11 The inspectors reviewed a self-revealed, Green finding associated with licensed operator performance on the biennial requalification exam. Specifically, 15 of 51 operators failed at least one portion of the biennial requalification examinations and 2 of 8 crews failed the simulator scenarios. Based on the licensee's successful remediation and subsequent retesting of individuals who failed a portion of the biennial requalification examination prior to returning to shift, no violation of regulatory requirements occurred.

Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program Cornerstone Significance Cross-cutting Aspect Inspection Procedure Mitigating Systems Green NCV 05000397/2018004-02 Closed H.4 -

Teamwork 71152 The inspectors identified a Green, non-cited violation of Columbia Generating Station Operating License Condition 2.C(14), Fire Protection Program (Generic Letter 86-10), because the licensee failed to perform hourly compensatory fire tours as required by the Licensee Controlled Specifications (LCS). Specifically, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct an hourly fire tour of the residual heat removal 2B pump room area.

Additional Tracking Items

Type Issue number Title Inspection Procedure Status URI 05000397/2014002-02 Unresolved Discrepancies in the Licensing Basis of the Tower Makeup System 71152 Closed

PLANT STATUS

The plant began the inspection period at 100 percent rated thermal power.

On December 6, 2018, condensate booster pump 2A tripped due to low section pressure.

Reactor feedwater pump 1B tripped due to the condensate booster pump 2A trip and caused a recirculation pump runback to 69 percent power. On December 7, 2018, operators returned reactor feedwater pump 1B and condensate booster pump 2A to service and restored power to 74 percent. On December 11, 2018, power ascension to 85 percent power was halted at 77 percent power due to a lockup of the rod drive control system. On December 12, 2018, the licensee increased reactor power to 92 percent by increasing recirculation flow. The unit was returned to rated thermal power on December 13, 2018.

On December 15, 2018, the unit was down powered to 62 percent to perform control rod sequence exchanges, turbine valve testing, and planned repairs to condensate booster pump 2B. The unit was returned to rated thermal power on December 16, 2018.

On December 23, 2018, the unit was down powered to 98 percent to perform main steam bypass valve testing. The unit was returned to rated thermal power on December 23, 2018, and remained at or near rated thermal power for the remainder 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 performed plant status activities described in IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem Identification and Resolution. 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.

REACTOR SAFETY

71111.01Adverse Weather Protection Impending Severe Weather

The inspectors evaluated readiness for impending adverse weather conditions for high winds on October 2 - 3, 2018.

71111.04Equipment Alignment Partial Walkdown

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) fuel pool cooling component check, system A, on November 21, 2018

(2) fuel pool cooling component check, system B, on November 21, 2018

71111.05AQFire Protection Annual/Quarterly Quarterly Inspection

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Fire Area DG-2/1, diesel generator 1, on October 15, 2018

(2) Fire Area R-18/2, motor control center room, Division 2, on October 17, 2018

(3) Fire Area RE-3/1, cable chase, on October 17, 2018

(4) Fire Area DG-3/2, diesel generator 2, on October 22, 2018

(5) Fire Area DG-1/1, diesel generator 3, on October 29, 2018

(6) Fire Area R-1/1, general floor area, reactor building, on October 29, 2018

71111.07Heat Sink Performance Heat Sink (Triennial)

The inspectors evaluated exchanger/sink performance on the following components from December 10, 2018, to December 13, 2018:

(1) control room chiller condenser CCH-CU-1B, Section 02.02b

(2) diesel cooling water heat exchanger DCW-HX-1A1, Section 02.02b

(3) residual heat removal pump seal cooler RHR-HX-2A, Section 02.02b

(4) residual heat removal pump room cooling Coil RRA-CC-3, Section 02.02b

71111.11Licensed Operator Requalification Program and Licensed Operator Performance Operator Requalification

The inspectors observed and evaluated a licensed operator requalification evaluated scenario on October 9, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated licensed operator performance associated with the following:

(1) standby liquid control, system A and B testing, on October 18, 2018

(2) tower makeup pump 1C trip, on November 25, 2018

Operator Exams (1 Sample)

The inspectors reviewed and evaluated requalification examination results on December 28, 2018, with the exception of three outstanding exams which will be administered the first week of January 2019.

Operator Requalification Program (1 Sample)

The inspectors evaluated the operator requalification program from October 15, 2018 to December 28, 2018.

71111.13Maintenance Risk Assessments and Emergent Work Control

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) yellow risk for diesel generator 1 maintenance, week of October 1-5, 2018

(2) yellow risk for reactor core isolation cooling surveillances, on October 10-12, 2018

(3) orange risk during high pressure core spray battery charger C1-1 maintenance, on October 12, 2018

(4) yellow risk for residual heat removal system B maintenance, on October 15-16, 2018

(5) yellow risk for residual heat removal system A maintenance, on December 13, 2018

71111.15Operability Determinations and Functionality Assessments

The inspectors evaluated the following operability determinations and functionality assessments:

(1) high pressure core spray battery charger low voltage, on October 11, 2018

(2) reactor building stack monitor fault, PRM-SR-1, on November 14, 2018

(3) reactor core isolation cooling system surveillance results, on December 13, 2018

71111.19Post Maintenance Testing

The inspectors evaluated the following post-maintenance tests:

(1) standby diesel generator 1 load testing, on October 3, 2018

(2) high pressure core spray battery charger testing, on October 12, 2018

(3) fuel pool cooling tank 1B high level control indication switch replacement, FPC-LIS-2B, on October 31, 2018

(4) fuel pool cooling system A maintenance, on November 9, 2018

(5) fuel pool cooling system B maintenance, on November 28, 2018

71111.22Surveillance Testing The inspectors evaluated the following surveillance tests: Routine

(1) ISP-RCIC-Q903, reactor core isolation cooling surveillances, on October 10, 2018

(2) ISP-RCIC-Q901, reactor core isolation cooling surveillances, on October 11, 2018

In-service (1 Sample)

(1) OSP-CCH/IST-M702, control room emergency chiller system B, on October 18, 2018

Reactor Coolant System Leak Detection (1 Sample)

(1) SOP-FDR-OPS, floor drain system operation, on November 9, 2018

Containment Isolation Valve (1 Sample)

(1) OSP-RCIC/IST-Q701, reactor core isolation cooling valve V-19, on December 13,

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification

The inspectors verified licensee performance indicators submittals listed below:

(1) BI01: Reactor Coolant System (RCS) Specific Activity Sample (10/01/2017-09/30/2018)

(2) BI02: RCS Leak Rate Sample (10/01/2017-09/30/2018)

71152Problem Identification and Resolution Semiannual Trend Review

The inspectors reviewed the licensees corrective action program for trends that might be indicative of a more significant safety issue. The inspectors reviewed a potential trend of missed fire tours and documented one observation and an NRC-identified violation (NCV 05000397/2018004-02, Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program) on December 13, 2018.

Annual Follow-up of Selected Issues (3 Samples)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) hourly fire tours of residual heat removal pump 2B, pump room, on October 26, 2018

(2) low standby service water flow alarms, on December 18, 2018

(3) discrepancies in the licensing basis of the tower makeup system, on December 14, 2018

71153Follow-up of Events and Notices of Enforcement Discretion Events

(1) The inspectors evaluated the functionality assessment of reactor building stack monitor, PRM-SR-1, and the licensees response on November 14, 2018.

(2) The inspectors evaluated the recirculation pump runback to 69 percent reactor power and the licensees response on December 6,

INSPECTION RESULTS

Observation 71152 The inspectors performed an in-depth review of the licensees evaluation and corrective actions related to a potential trend in missed fire tours. Since July 1, 2018, the licensee initiated four Action Requests documenting missed fire tours: Action Requests 382646, 383676, 384338, and 385266. Three of the missed fire tours were of minor significance; however, one fire tour was of more than minor significance and is documented in this report as NCV 05000397/2018004-02, Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program.

The inspectors assessed the licensees problem identification threshold, evaluations, and corrective actions and noted that the licensee appropriately considered extent of condition and extent of cause for the planned corrective action assignments. The inspectors determined the cause of each missed fire tour was unique and not indicative of a negative trend.

Unresolved Item (Closed)

Unresolved Discrepancies in the Licensing Basis of the Tower Makeup System 05000397/2014002-02 71152

Description:

This item was opened to review the adequacy of several changes the licensee made to the Columbia Generating Station Final Safety Analysis Report that redefined the role of the tower makeup (TMU) system as the ultimate heat sink following a design-basis tornado and changed the system description from safety-related to nonsafety-related. Additional inspection was required to determine whether the licensee made the subject changes in full compliance with 10 CFR 50.59. By memorandum, dated November 10, 2014 (ADAMS Accession No. ML14316A634), the U.S. Nuclear Regulatory Commission Region IV, Division of Reactor Projects, requested assistance from the NRC Office of Nuclear Reactor Regulation (NRR) to conduct a technical assessment of the Columbia Generating Station design and licensing bases for the TMU system.

Corrective Action Reference(s): Action Requests 302227, 304186, 308224, 312331, 346049

Closure Basis: The inspectors did not identify any findings during the follow-up inspection of this Unresolved Item. In a letter, dated October 17, 2018 (ADAMS Accession No. ML15191A2891), the NRR staff concluded that the TMU system is not part of the ultimate heat sink complex and that the requirement of Technical Specification 3.7.1, Standby Service Water (SW) System and Ultimate Heat Sink (UHS), is not applicable to the TMU system.

The NRR staff also concluded that the TMU system piping and components were not designated as Safety Class components and are not subject to the quality assurance requirements pursuant to Appendix B to Part 50 of Title 10 of the Code of Federal Regulations. This Unresolved Item is closed.

Licensed Operator Failure Rate Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems

Green FIN 05000397/2018004-01 Closed H.1 - Resources 71111.11 The inspectors reviewed a self-revealed, Green finding associated with licensed operator performance on the biennial requalification exam. Specifically, 15 of 51 operators failed at least one portion of the biennial requalification examinations, and 2 of 8 crews failed the simulator scenarios. Based on the licensee's successful remediation and subsequent retesting of individuals who failed a portion of the biennial requalification examination prior to returning to shift, no violation of regulatory requirements occurred.

Description:

During the facility-administered biennial requalification examination of licensed operators, the licensee training staff evaluated crew performance during dynamic simulator scenarios and individual operator performance during job performance measures and on the biennial written examination. Facility results of the biennial requalification examination showed that 15 of 51 licensed operators (29.4 percent) failed at least one portion of the biennial requalification examination and 2 of 8 crews (25 percent) failed the simulator scenarios, exceeding the threshold failure rate of 20 percent.

Corrective Actions: All individual and crew failures will be remediated and retested prior to performing licensed operator activities; and the licensee will perform an organizational and programmatic investigation (similar to a root cause investigation).

Corrective Action Reference: Action Request 387428

Performance Assessment:

Performance Deficiency: The inspectors determined that the high rate of licensed operator examination failures constituted a performance deficiency because licensed operators are expected to operate the plant within acceptable standards of knowledge and abilities demonstrated through periodic testing as required by 10 CFR 55.59(a)(2).

Screening: The inspectors determined the performance deficiency was more than minor because it adversely affected the human performance attribute of Mitigating Systems cornerstone. Specifically, 15 of 51 licensed operators and 2 of 8 crews, failed to demonstrate a satisfactory understanding of the required knowledge and abilities required to safely operate the facility under normal, abnormal, and emergency conditions.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Appendix I, "Licensed Operator Requalification Human Performance Significance Determination Process," dated December 6, 2011. This finding was of very low safety significance (Green) because the finding was related to the requalification exam results with a failure rate greater than 20 percent, but less than 40 percent.

Cross-cutting Aspect: This finding has a cross-cutting aspect in the area of human performance associated with resources, because the licensee failed to ensure that personnel were adequately trained to assure nuclear safety. Specifically, the licensee failed to use sufficiently challenging training evolutions during the training cycle to train and assess licensed operator knowledge [H.1].

Enforcement:

This finding does not involve enforcement action because no violation of regulatory requirements was identified.

Failure to Perform Hourly Fire Tours as Required by the Fire Protection Program Cornerstone Significance Cross-cutting Aspect Report Section Mitigating Systems

Green NCV 05000397/2018004-02 Closed H.4 - Teamwork 71152 The inspectors identified a Green, non-cited violation of Columbia Generating Station Operating License Condition 2.C(14), Fire Protection Program (Generic Letter 86-10),because the licensee failed to perform hourly compensatory fire tours as required by the LCS.

Specifically, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct an hourly fire tour of the residual heat removal 2B pump room area.

Description:

The Columbia Fire Protection Plan is the combination of Final Safety Analysis Report, Appendix F, and Procedure SWP-FPP-01, Nuclear Fire Protection Program, Revision 8.

Step 3.6.5 of Procedure SWP-FPP-01 states, in part, that an hourly fire tour is a common compensatory measure for impaired fire systems and identifies fire hazards and incipient fire/smokeand that a fire tour is performed in accordance with LCS 1.10, Plant Procedure Manual PPM 1.3.10B, PPM 1.3.57, and Fire Protection Program Procedure Manual FPP 1.7.

Licensee Controlled Specification 1.10.6, Essential Fire Detection, Revision 73, Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, lists the residual heat removal (RHR) 2B pump room as an area protected by essential fire detection that requires an hourly fire tour when the essential fire detection is inoperable.

On September 4, 2018, Fire Panel FP-CP-FCP1 was taken out of service for replacement per Work Order 02088112. The licensee activated fire protection system impairment (FPSI) 17-0367 and established an hourly fire tour of the affected areas in accordance with LCS 1.10.6, Essential Fire Detection, Revision 73, action statements A.1 and A.2, respectively. The work affected detection zone 13 which, per Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, Revision 73, included the residual heat removal 2A pump room, residual heat removal 2B pump room, residual heat removal 2C pump room, and the reactor core isolation cooling pump room, among others.

Security officers perform the hourly fire tours in accordance with Procedure SFI-26, Fire Tour, Revision 2. Step 4.3.7.b of Procedure SFI-26 states to complete and follow the Fire Tour Log as published, starting at the beginning of the first page. From September 4-6, 2018, the fire log listed [RB] 422 All Rooms and 441 Truck Bay, which included the residual heat removal 2B pump room. At the time of the required tours, the residual heat removal room 2B pump room was posted as a contaminated and high radiation area. Per plant procedures, entering a contaminated area and/or high radiation area during a fire tour is outside the scope for security personnel and as such, the security officers did not enter the residual heat removal 2B pump room as required. This was confirmed through interviews with plant personnel.

Multiple work groups are responsible for implementing the Columbia Fire Protection Plan when a fire protection system is impaired. Fire Protection personnel create the fire protection system impairments. Security personnel conduct the fire tours while Operations personnel provide oversight and ensure compliance with LCS 1.10.6. Meanwhile, radiation protection personnel maintain high radiation area, radiation area, and contamination area boundaries.

Communication between the work groups is essential to ensure that the fire tours are conducted in accordance with the fire protection system impairment while following radiation protection guidelines.

Corrective Actions: The licensees corrective actions included restoring functionality of the essential fire detection for the residual heat removal system 2B pump room by completing the maintenance on Fire Panel FP-CP-FCP1 and performing an apparent cause evaluation to identify the cause of the performance deficiency and implement further corrective actions.

Corrective Action Reference: Action Request 384338.

Performance Assessment:

Performance Deficiency: The failure to perform hourly compensatory fire tours in accordance with the LCS while a fire barrier component was out of service was a performance deficiency.

Screening: The performance deficiency was more than minor, and therefore a finding, because it was associated with the protection against external factors (i.e. internal fire)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 (i.e., core damage). Specifically, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct a compensatory hourly fire tour of the residual heat removal 2B pump room area for a period of approximately 2 days. Not performing these tours led to a condition where a fire in the residual heat removal pump 2B room would go unrecognized for a longer than anticipated period of time leading to increased fire risk to safety related components and systems.

Significance: The inspectors assessed the significance of the finding using Inspection Manual Chapter 0609, Attachment 04, Initial Characterization of Findings, and Appendix F, Fire Protection Significance Determination Process, dated May 2, 2018. The inspectors assigned the finding to Fire Finding Category 1.4.2 using Inspection Manual Chapter 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated May 2, 2018, because the finding involved a fire watch posted as a compensatory measure for a fixed fire protection system outage or degradation. The inspectors assigned the finding a high degradation rating using Inspection Manual Chapter 0609, Appendix F, 2, Degradation Rating Guidance, dated May 2, 2018, because the smoke detectors and fire panel annunciator for the affected room were nonfunctional during the panel replacement. Further, the inspectors determined a Phase 2 evaluation was required because the non-functional detection system adversely affected the ability of the system to protect equipment important to safe shutdown and the licensee did not have a fire PRA

[probabilistic risk assessment] capable of adequately evaluating the risk associated with the finding.

The senior reactor analyst performed a bounding risk evaluation for the performance deficiency and determined that the finding was of very low safety significance (Green). In the Washington Public Power Supply System Individual Plant Examination of External Events for the Washington Nuclear Plant 2, Revision 0, dated June 1995, Fire Zone R-4, RHR-B Room, was assigned a fire initiating event frequency of 5.0E-03/ year. The resulting baseline core damage frequency was calculated to be 2.57E-07. The performance deficiency existed for 2 days, from September 4 through 6, 2018. Applying the 2-day exposure period (5.48E-03), the resulting probability of a fire starting in the room over this period was calculated to be 2.74E-05. Because at least two trains of a multi-train injection system would be available following a postulated fire, the analyst assigned a bounding failure rate for a single multi-train system. Using Table 5, Mitigation Capability Credits for Installed Equipment, from Inspection Manual Chapter 0609, Appendix G, Attachment 3, Phase 2 Significance Determination Process Template for BWR during Shutdown, dated February 28, 2005, as best available information, the analyst assigned 1.0E-3 as the failure of the safe shutdown path failure probability. Therefore, the external events incremental conditional core damage probability from internal fire was 8.22E-08. The dominant sequence was a fire in the RHR-B Pump Room leading to a reactor trip followed by a failure of the following functions:

• main feedwater;

• high pressure core spray;

• reactor isolation core cooling;

• low pressure injection;

• condensate; and

• alternate low pressure injection.

Because this core damage frequency is below the green/white threshold for large, early release frequency, no additional evaluation was necessary to determine that the finding was of very low safety significance with respect to containment failures.

Cross-cutting Aspect: This finding had a cross-cutting aspect in the area of human performance, teamwork, in that the licensee individuals and work groups failed to communicate and coordinate their activities within and across organizational boundaries to ensure nuclear safety was maintained. Specifically, there was a lack of communication between the operations, radiation protection, fire protection, and security work groups when implementing FPSI 17-0367 [H.4].

Enforcement:

Violation: Columbia Generating Station License Condition 2.C(14), Fire Protection Program (Generic Letter 86-10), requires, in part, that the licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in Section 9.5.1 and Appendix F of the Final Safety Analysis Report (FSAR) for the facility through Amendment

1. 39 and as described in subsequent letters to the staff referenced in the May 22, 1989, safety evaluation and as approved in the Safety Evaluation Report issued in March 1982, and subsequent supplements and safety evaluations. The Columbia Fire Protection Plan is the combination of Final Safety Analysis Report Appendix F and Procedure SWP-FPP-01, Nuclear Fire Protection Program, Revision 8. Step 3.6.5 of Procedure SWP-FPP-01 states, in part, that an hourly fire tour is a common compensatory measure for impaired fire systems and identifies fire hazards and incipient fire/smokeand that a fire tour is performed in accordance with LCS 1.10, Plant Procedure Manual PPM 1.3.10B, PPM 1.3.57, and Fire Protection Program Procedure Manual FPP 1.7. Licensee Controlled Specification 1.10.6, Essential Fire Detection, Revision 73, Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, lists the residual heat removal 2B pump room as an area protected by essential fire detection that requires an hourly fire tour when the essential fire detection is inoperable. FPSI 17-0367 established an hourly fire tour of the affected areas in accordance with LCS 1.10.6. The work affected detection zone 13 which, per Table 1.10.6-1, Area and Equipment Protected by Essential Fire Detection, Revision 73, included the residual heat removal 2A pump room, residual heat removal 2B pump room, residual heat removal 2C pump room, and the reactor core isolation cooling pump room, among others. Security officers perform the hourly fire tours in accordance with Procedure SFI-26, Fire Tour, Revision 2. Step 4.3.7.b of Procedure SFI-26 states to complete and follow the Fire Tour Log as published, starting at the beginning of the first page. From September 4-6, 2018, the fire log listed [RB] 422 All Rooms and 441 Truck Bay which included the residual heat removal 2B pump room.

Contrary to the above, from September 4-6, 2018, the licensee failed to implement all provisions of the approved fire protection program as described in Section 9.5.1 and Appendix F of the Final Safety Analysis Report (FSAR) for the facility through Amendment

1. 39 and as described in subsequent letters to the staff referenced in the May 22, 1989, safety evaluation and as approved in the Safety Evaluation Report issued in March 1982, and subsequent supplements and safety evaluations. Specifically, while the essential fire detection for the residual heat removal 2B pump room was out of service, the licensee did not conduct an hourly fire tour of the residual heat removal 2B pump room area for a period of approximately 2 days.

Disposition: This violation is being treated as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy.

EXIT MEETINGS AND DEBRIEFS

On December 13, 2018, the inspectors presented the triennial heat sink inspection results to Mr. B. Sawatzke, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

On December 28, 2018, the inspector presented the licensed operator requalification inspection results to Mr. G. Pierce, Acting Chief Nuclear Officer, and other members of the licensee staff.

The inspectors verified no proprietary information was retained or documented in this report.

On January 10, 2019, the inspectors presented the quarterly resident inspector inspection results to Mr. W. Grover Hettel, and other members of the licensee staff. The inspectors verified no proprietary information was retained or documented in this report.

DOCUMENTS REVIEWED

71111.01Adverse Weather Protection

Action Reports

376979

376980

379000

379022

376079

Procedures

Number

Title

Revision

ABN-WIND

Tornado / High Winds

29

ABN-WIND

Tornado / High Winds

030

ABN-WIND

Tornado / High Winds

031

71111.04Equipment Alignment

Procedures

Number

Title

Revision

ABN-FPC-LOSS

Loss of Fuel Pool Cooling

016

SOP-FPC-ASSIST Alternate Fuel Pool Cooling Assist

011

SOP-FPC-LU

Fuel Pool Cooling and Cleanup System Valve and

Breaker Lineup

006

SOP-FPC-OPS

Fuel Pool Cooling and Cleanup Operations

007

SOP-FPC-

SHUTDOWN

FPC-Shutdown

003

SOP-FPC-SPC

FPC Suppression Pool Operations

011

SOP-FPC-SST

FPC Skimmer Surge Tank Operations

005

SOP-FPC-START Fuel Pool Cooling Start

006

Drawings

Number

Title

Revision

M526-1

Flow Diagram Fuel Pool Cooling and Clean-up System

103

M526-2

Flow Diagram Fuel Pool Cooling and Clean-up System

2

E519, Sheet 25

Motor Valve and Miscellaneous Control

E519, Sheet 25A

Motor Valve and Miscellaneous Control

Miscellaneous

Documents Number

Title

WNP-2 FSAR, Chapter 9

71111.05AQFire Protection Annual/Quarterly

Procedures

Number

Title

Revision

1.3.10

Plant Fire Protection Program Implementation

034

1.3.10A

Control of Ignition Sources

017

1.3.10C

Control of Transient Combustibles

20

FP-02-85-03

Combustible Loading Calculation

010

PFP-RW-467

Radwaste 467

005

PFP-RB-522

Reactor 522

005

71111.07Heat Sink Performance

Action Requests (Reviewed)

350866

354191

343378

2608

364408

384466

384628

384953

2614

387552

387548

310795

358871

Action Requests (Issued)

387786

387787

387825

Work Orders

2080963

2013391

2103028

2001311

2047406

2094831

2077068

Procedures

Number

Title

Revision

Service Water Reliability Program

003

ABN-HVAC

HVAC Trouble

013

HXP-01

Heat Exchanger Program

001

OSP-CCH/IST-

M702

Control Room Emergency Chiller System B Operability

040

OSP-SW-M101

Standby Service Water Loop A Valve Position Verification 039

TSP-SW-A101

Service Water Loop A Cooling Coil Heat Load Capacity

Test

003

Drawings

Number

Title

Revision

or Date

2C302FD

RHR Pump General Arrangement

November 23,

1971

CVI-215-11

Seal Injection Water Coolers

005

M521-1

Flow Diagram Residual Heat Removal System Loop A

117

RHR-4719-1

Seal Cooler Piping for RHR

001

Miscellaneous

Documents Number

Title

Revision

or Date

Control Room Envelope Habitability Program

000

Eddy Current Inspection Report, CCH-CR-1B

March 3, 2014

180734-01

Report of Analysis, Service Water Pond A Sediment

January 10,

2018

5059 SCREEN-16-

0157

354191-02 Evaluate CM to isolate

CCH-CR-1B AOP while in standby mode

000

AR-SA 332674

Focused Self-Assessment Report, GL 89-13 Service

Water Self-Assessment for Ultimate Heat Sink

Inspection

000

AR-SA 378472

Snapshot Self-Assessment Report

June 28, 2018

C94-0319

Component CER Summary Sheet, 2-CCH-P-1A and 2-

CCH-P-1B

003

CCH-02

Function Basis Document, Control Room Chilled Water

000

DBD 309

Design Basis Document, Standby Service Water System 018

GI2-97-039

Issuance of Amendment for the Washington Public

Power Supply System Nuclear Project No. 2

(TAC No. M94226)

March 4, 1997

LBD-IST-4

Inservice Testing Program Plan, Fourth Ten-Year

Inspection Interval

001

LDCN-17-014

Revise FSAR Habitability Temperature Discussion

000

SD000201

System Description, Control Room, Cable Room and

Critical Switchgear Rooms - HVAC (CR-HVAC)

015

Modifications

Number

Title

Revision

EC 12326

Approve the Use of CID 8741 for RRA-CC-3

Replacement and Eliminate the Cooling Coil Zinc Anodes

2

EC 14954

CCH Bypass Line AR 2246562246562

Calculations

Number

Title

Revision

ME-02-85-70

Seal Coolers for RHR-P-2A,-2B, &-2C

000

ME-02-92-43

Room Temperature Calculation for DG Building, Reactor

Building, Radwaste Building, and Service Water

2

ME-02-96-03

RHR Seal Cooler Performance Evaluation

000

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Action Reports

385920

358660

358602

358766

358890

2587

2548

2587

363586

366392

Action Reports

359162

375090

383090

359162

385010

359064

2548

Work Orders

2103901

2115120

Procedures

Number

Title

Revision

4.603.A7

603.A7 Annunciator Panel Alarms

054

4.603.A8

603.A8 Annunciator Panel Alarms

039

OI-09

Operations Standards and Expectation

070

OSP-INST-H101

Shift and Daily Instrument Checks (modes 1, 2, 3)

OSP-SLC-B703

SLC Pump Suction Flow Verification

009

SOP-RCIC-INJEC

TION-QC

RCIC RPV Injection - Quick Card

007

OI-69

Time Critical Operator Actions

010

TDI-06

Simulator Management

20

TDI-08

Licensed Operator Requalification Program

015

TDI-23

LORQ Annual Exam Development and Administration

009

TDI-24

Exam Security

006

1.3.1

Operating Policies, Programs and Practices

27

1.8.10

Administration of Medical Qualifications

011

1.8.11

Medical Examination Program for Licensed Operators

011

Drawings

Number

Title

Revision

EWD-10E-003

Electrical Wiring Diagram Standby Liquid Control System

Pump SLC-P-1A (C41-L001A) and Squib Valve SLC-V-4A

(C41A-F004A) (Explosive Injection Valve)

018

Scenario Based

Testing Number

Title

Week 2 Simulator Scenario 1

Week 2 Simulator Scenario 2

Week 2 Simulator Scenario 3

Week 2 Simulator Scenario 4

Miscellaneous

Documents Number

Title

2018 Operational Exam Week 2

2017 Training Remediation Analysis

OE 2017 LORQ

Miscellaneous

Documents Number

Title

OE 2018 LORQ

SRB 2017-4-17 Minutes

SRB 2017-9-05 Minutes

SRB 2018-2-08 Minutes

SRB 2018-6-27 Minutes

71111.13Maintenance Risk Assessments and Emergent Work Control

Action Reports

373410

373028

374072

378760

379507

2576

2706

385221

385048

Procedures

Number

Title

Revision

1.3.10

Plant Fire Protection Implementation

034

1.3.76

Integrated Risk Management

2

1.3.83

Protected Equipment Program

26

1.3.83

Protected Equipment Program

27

1.3.85

On-line Risk Management

005

ICP-RCIC-Q901

RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC

013

ISP-RCIC-Q901

RCIC Isolation on RCIC Steam Supply Flow High

DIV 1-CFT/CC

24

ISP-RCIC-Q903

RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC

019

71111.15Operability Determinations and Functionality Assessments

Action Reports

385634

385654

385674

386750

386861

387833

387990

386956

387479

Work Orders

29146086

29146159

29146182

29146189

2049828

2137070

2105341

Procedures

Number

Title

Revision

ESP-MOVTOL-

B301

MOV Thermal Overload Testing - CC

2

OSP-RCIC/

IST-Q701

RCIC Operability Test

2

Procedures

Number

Title

Revision

SOP-HOT

WEATHER-OPS

Hot Weather Operations

006

SOP-HPCS-

CST/SP

HPCS CST and Suppression Pool Operations

014

SOP-HPCS-

DRAIN

HPCS Drain

007

SOP-HPCS-FILL

HPCS Fill and Vent

013

SOP-HPCS-

INJECTION

HPCS RPV Injection

006

SOP-HPCS-

INJECTION-QC

HPCS-RPV Injection-Quick Cards

004

SOP-HPCS-LU

HPCS Valve and Breaker Lineup

004

SOP-HPCS-STBY Placing HPCS in Standby Status

003

Drawings

Number

Title

Revision

250-00.47.1

Valve Assembly, 2 inch. Y Type, Globe Valve, Motor

Operated, C.S

000

807EI72TC,

Sheets 1 - 8

G.E. Elementary Drawings

M520

High-Pressure Core Spray

Miscellaneous

Documents Number

Title

Revision

Columbia Generating Station FSAR, Chapters 6, 7, and

776-00.1.1

Stack Monitoring System Equipment, Instrumentation,

Dual Sum, Amplifier, Power Supply, Modular System and

Coaxicon Vendor Manual

2

RCIC-MO-19

MOV Master Data Sheet

013

Calculations

Number

Title

Revision

NE-02-09-12

CGS Emergency Action Levels (EALs) Technical Bases

004

NE-02-13-10

Determination of Low Range Stack Monitor Xe-133

Equivalent Efficiency

000

NE-02-15-07

Setpoint Calculation for Reactor Building Elevated

Discharge Radiation Monitor (Stack Monitor)

000

Modifications

Number

Title

Revision

EC 11288

Replace Stack Monitors

008

71111.19Post Maintenance Testing

Action Reports

386266

386407

383578

386511

386534

369412

375956

386788

387001

387128

387131

275278

Work Orders

2066474

2084370

2012402

2093087

2105297

2066473

2085665

2117254

2117272

2134934

2118420

2119131

2103360

2117248

2117266

2117733

2118376

2036318

2025412

2125833

2103028

2066474

2102737

2102767

Procedures

Number

Title

Revision

10.2.10

Fastener Torque and Tensioning

28

10.24.34

PM Calibration Test Barton Differential Indicating Switch 016

ESP-MOVTOL-

B301

MOV Thermal Overload Testing - CC

21

OSP-FPC/IST-

Q701

Fuel Pool Cooling System Operability Surveillance

037

TSP-DG1-B502

Standby Diesel Generator DG1 Load Testing

21

Drawings

Number

Title

Revision

EWD-69E-116

Condensate System Valve COND-SPV-42

010

Miscellaneous

Documents Number

Title

Revision

CVI 531-00, 1, 2

Barton Differential Pressure Indicating Switches, Unit,

Calibration, and Parts List Manual

003

71111.22Surveillance Testing

Action Reports

385817

386056

385829

Work Orders

2102754

2106212

2102737

2102767

2125833

2103028

Procedures

Number

Title

Revision

ABN-LEAKAGE

Reactor Coolant Leakage

006

CVI 02E31-03,4

Leak Detection System Design Specification

003

CVI 02E31-04,2,1 Leak Detection System Design Specification

018

Procedures

Number

Title

Revision

CVI 02E31-04,2,2 Leak Detection System Design Specification

013

ICP-RCIC-Q901

RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC

013

ISP-RCIC-Q901

RCIC Isolation on RCIC Steam Supply Flow High

DIV 1-CFT/CC

24

ISP-RCIC-Q903

RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC

019

ISP-FDR/

EDR-X301

Drywell Sump Flow Monitors - CC

011

OSP-CCH/

IST-M702

Control Room Emergency Chiller System B Operability

040

OSP-INST-H101

Shift and Daily Instrument Checks (Modes 1, 2, 3)

091

SOP-FDR-OPS

Floor Drain System Operation

003

SYS-2-19

Reactor Coolant System Leakage Best Practice

000

Drawings

Number

Title

Revision

M539

Floor Drain System Reactor Building Flow Diagram

088

M775

Flow Diagram Emergency Chilled Water Piping System

Control Room

28

Miscellaneous

Documents Number

Title

Revision

EDR-FRS-623

Instrument Master Data Sheet for EDR-FRS-623

013

FDR-FT-38

Instrument Master Data Sheet for EDR-FRS-623

009

FDR-SQRT-38

Instrument Master Data Sheet for FDR-SQRT-38

011

71151Performance Indicator Verification

Action Reports

2567

Work Orders

2100685

2092836

Procedures

Number

Title

Revision

CI-10.17

Iodine

2

CSP-I131-W101

Reactor Coolant Isotopic Analysis for I-131 Dose

Equivalent

009

OSP-INST-H101

Shift and Daily Instrument Checks (Modes 1, 2, 3)

091

71152Problem Identification and Resolution

Action Reports

383152

383417

385638

385266

384338

383676

2646

380257

384338

Procedures

Number

Title

Revision

1.3.10

Plant Fire Protection Program Implementation

034

1.3.10B

Active Fire System Operability and Impairment Control

015

FPP-1.7

Fire Tour Implementation

006

PFP-RB-422

Reactor 422

006

SFI-26

Fire Tour

2

SWP-FPP-01

Nuclear Fire Protection Program

008

Modifications

Number

Title

EC 17375

71153Follow-up of Events and Notices of Enforcement Discretion

Action Reports

386750

387596

387597

387594

388087

387651

387598

387621

387623

387611

386956

Work Orders

2136717

Procedures

Number

Title

Revision

ABN-CORE

Unplanned Core Operating Conditions

017

ABN-FWH-

HI/LEVEL-TRIP

Feedwater Header High Level Trip

007

ABN-HWC

Hydrogen Water Chemistry System Trouble

004

ABN-POWER

Unplanned Reactor Power Change

016

SOP-FWH-

SHUTDOWN

Extraction Steam and Heater Vents / Drains System

Shutdown

004

Drawings

Number

Title

Revision

M504-1

Flow Diagram Condensate and Feed Water Systems

111

Miscellaneous

Documents Number

Title

Revision

Operations Logs 12/5-12/7

000

358.00,1,5

O/M Manual for Type 701 Basic Controller

001

776-00.1.1

Stack Monitoring System Equipment, Instrumentation,

Dual Sum, Amplifier, Power Supply, Modular System

and Coaxicon Vendor Manual

2

Calculations

Number

Title

Revision

NE-02-09-12

CGS Emergency Action Levels (EALs) Technical Bases

004

NE-02-13-10

Determination of Low Range Stack Monitor Xe-133

Equivalent Efficiency

000

NE-02-15-07

Setpoint Calculation for Reactor Building Elevated

Discharge Radiation Monitor (Stack Monitor)

000

Modifications

Number

Title

Revision

EC 11288

Replace Stack Monitors

008

ML19028A318

SUNSI Review

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By:

Yes No

Publicly Available

Sensitive

NRC-002

OFFICE

SRI:DRP/A

RI:DRP/A

DRS/IPAT

DRS/EB1

DRS/EB2

DRS/PSB2

NAME

GKolcum

LMerker

RKellar

VGaddy

JDrake

HGepford

SIGNATURE

/RA/

/RA/

/RA/

/RA/

/RA/

/RA/

DATE

01/21/19

01/17/19

01/16/19

01/17/19

01/16/19

01/17/19

OFFICE

DRS/OB

SPE:DRP/A

BC:DRP/A

NAME

GWerner

RAlexander

MHaire

SIGNATURE

/RA/

/RA/

/RA/

DATE

01/20/19

01/22/19

01/28/19