ML18304A362

NRC Integrated Inspection Report 05000397/2018003

ML18304A362
Person / Time
Site:	Columbia
Issue date:	10/31/2018
From:	Mark Haire NRC/RGN-IV/DRP
To:	Sawatzke B Energy Northwest
References
IR 2018003
Download: ML18304A362 (36)

See also: IR 05000397/2018003

Text

.

October 31, 2018

Mr. Brad Sawatzke, Chief Executive Officer

Energy Northwest

MD 1023

P.O. Box 968

Richland, WA 99352

SUBJECT:

COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION

REPORT 05000397/2018003

Dear Mr. Sawatzke:

On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an

inspection at your Columbia Generating Station. On October 15, 2018, the NRC inspectors

discussed the results of this inspection with Mr. Alex Javorik, Vice President, Engineering, and

other members of your staff. The results of this inspection are documented in the enclosed

report.

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

These findings involved violations of NRC requirements. The NRC is treating these violations

as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.

Further, inspectors documented a licensee-identified violation which was determined to be of

very low safety significance in this report. The NRC is also treating this violation as an NCV

consistent with Section 2.3.2 of the Enforcement Policy.

If you contest the violations or significance of these NCVs you should provide a response within

30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with

copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the

NRC resident inspectors at the 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 inspectors at the Columbia Generating Station.

B. Sawatzke

2

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 Haire, Branch Chief

Project Branch A

Division of Reactor Projects

Docket No. 50-397

License No. NPF-21

Enclosures:

1. Inspection Report 05000397/2018003

2. Request for Information: Occupational

Radiation Safety Inspection

Enclosure 1

U.S. NUCLEAR REGULATORY COMMISSION

Inspection Report

Docket Number:

05000397

License Number:

NPF-21

Report Number:

05000397/2018003

Licensee:

Energy Northwest

Facility:

Columbia Generating Station

Location:

Richland, Washington

Inspection Dates:

July 1, 2018 to September 30, 2018

Inspectors:

G. Kolcum, Senior Resident Inspector

L. Brandt, Resident Inspector

R. Alexander, Senior Project Engineer

N. Hernandez, DRS Operations Engineer

J. ODonnell, DRS Health Physicist

Approved By:

M. Haire, Branch Chief

Project Branch A

Division of Reactor Projects

2

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

findings are summarized in the table below. A licensee-identified non-cited violation is

documented in the Inspection Results at the end of this report.

List of Findings and Violations

Failure to Follow Radiologically Controlled Area Procedures

Cornerstone

Significance

Cross-cutting

Aspect

Inspection

Procedure

Occupational

Radiation

Safety

Green

NCV 05000397/2018003-01

Opened and Closed

H.12 - Avoid

Complacency

71124.01 -

Radiological

Hazard

Assessment

and

Exposure

Controls

The inspectors reviewed a self-revealed Green, non-cited violation of Technical

Specification 5.4.1(a) when the licensee failed to implement radiation control procedures.

Failure to Control Workers in a High Radiation Area (>1.0 rem per hour)

Cornerstone

Significance

Cross-cutting

Aspect

Inspection

Procedure

Occupational

Radiation

Safety

Green

NCV 05000397/2018003-02

Opened and Closed

H.4 -

Teamwork

71124.01 -

Radiological

Hazard

Assessment

and

Exposure

Controls

The inspectors reviewed a self-revealed Green, non-cited violation of Technical

Specification 5.7.2(b) and (e) when the licensee failed to control worker activities in a locked

high radiation area in accordance with the requirements of the radiation work permit and failed

to determine radiological conditions in the work area prior to the start of work.

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Failure to Adequately Control Work Hours for Covered Personnel

Cornerstone

Significance

Cross-cutting

Aspect

Inspection

Procedure

Emergency

Preparedness

Green

NCV 05000397/2018003-03

Opened and Closed

H.5 - Work

Management

71152 -

Problem

Identification

and

Resolution

The inspectors identified a Green, non-cited violation of 10 CFR 26.205 associated with the

licensees failure to adequately schedule and control work hours for personnel subject to work

hour controls. Specifically, the licensee failed to appropriately schedule and control work

hours for at least three Chemistry Technicians who were providing covered work as the

designated Emergency Response Organization Duty Chemistry Technician as defined by the

Columbia Generating Station Emergency Plan.

4

PLANT STATUS

The plant began the inspection period at 100 percent rated thermal power. On August 4, 2018,

the reactor unit was down powered to 93 percent to remove the adjustable speed drive from

service for maintenance. On August 5, 2018, the unit was down powered to 74 percent to

recover the adjustable speed drive channel, and the unit was returned to rated thermal power

later that same day. On September 22, 2018, the unit was down powered to 83 percent to

perform control rod sequence exchange and turbine bypass valve testing. The unit was

returned to rated thermal power on September 22, 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

71111.01 - Adverse Weather Protection

Seasonal Extreme Weather (1 Sample)

The inspectors evaluated readiness for seasonal extreme weather conditions prior to the

onset of seasonal hot temperatures on July 13 - 17, 2018.

71111.04 - Equipment Alignment

Partial Walkdown (5 Samples)

The inspectors evaluated system configurations during partial walkdowns of the following

systems/trains:

(1) low pressure core spray system on July 10, 2018

(2) high pressure core spray system on July 27, 2018

(3) control room emergency filter unit, WMA-FN-54A, on August 6, 2018

(4) reactor core isolation cooling system on August 21, 2018

(5) standby service water room coolers on September 20, 2018

Complete Walkdown (1 Sample)

The inspectors evaluated system configurations during a complete walkdown of the fuel pool

cooling system on September 28, 2018.

5

71111.05AQFire Protection Annual/Quarterly

Quarterly Inspection (5 Samples)

The inspectors evaluated fire protection program implementation in the following selected

areas:

(1) Fire Zones 47-64, transformer yard, on July 9, 2018

(2) Fire Area RC-1/2, radwaste building 437 feet elevation, on August 6, 2018

(3) Fire Area R-3/#, high pressure core spray pump room, on August 16, 2018

(4) Fire Area R-6/2, reactor core isolation cooling pump room, on August 16, 2018

(5) Fire Area R-4/2, residual heat removal system B pump room, on September 6, 2018

Annual Inspection (1 Sample)

The inspectors evaluated fire brigade performance on September 26, 2018.

71111.07Heat Sink Performance

Heat Sink (1 Sample)

The inspectors evaluated high pressure core spray diesel generator 3 diesel cooling water

heat exchanger, DCW-HX-1C, performance on August 29, 2018, and diesel generator 2

diesel cooling water heat exchangers, DCW-HX-1A1 and DCW-HX1A2, on

September 6, 2018.

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Operator Requalification (1 Sample)

The inspectors observed and evaluated a licensed operator requalification evaluated scenario

on August 6, 2018.

Operator Performance (1 Sample)

The inspectors observed and evaluated operator performance during residual heat removal

heat exchanger 1A testing on September 11, 2018.

71111.12Maintenance Effectiveness

Routine Maintenance Effectiveness (1 Sample)

The inspectors evaluated the effectiveness of routine maintenance activities associated

with the following equipment and/or safety significant functions:

(1) high pressure core spray system planned maintenance, week of July 23, 2018

6

71111.13Maintenance Risk Assessments and Emergent Work Control (8 Samples)

The inspectors evaluated the risk assessments for the following planned and emergent

work activities:

(1) yellow risk for reactor core isolation cooling surveillances, week of July 9, 2018

(2) orange risk due to high pressure core spray system maintenance, week of July 23, 2018

(3) green risk during control room envelope test, week of August 6, 2018

(4) yellow risk for reactor core isolation cooling maintenance, week of August 13, 2018

(5) yellow risk for reactor core isolation cooling surveillances on September 14, 2018

(6) yellow risk for standby service water system B maintenance, September 17-18, 2018

(7) green risk for reactor building crane roof operations, week of September 17, 2018

(8) yellow risk for standby gas treatment train B maintenance, week of September 24, 2018

71111.15Operability Determinations and Functionality Assessments (3 Samples)

The inspectors evaluated the following operability determinations and functionality

assessments:

(1) fire pump FP-P-110 failed to start on July 17, 2018

(2) reactor pressure vessel level transmitter MS-LT-61A, leaking fitting, on August 1, 2018

(3) Division 1 and Division 2, 120 Vac power supply inverter and inverter transfer switch, on

August 31, 2018

71111.19Post Maintenance Testing (6 Samples)

The inspectors evaluated the following post maintenance tests:

(1) low pressure core spray circuit breaker and mechanism operated cell (MOC) switch on

July 3, 2018

(2) high pressure core spray maintenance on July 25, 2018

(3) reactor pressure vessel level transmitter MS-LT-61A leak repair on August 1, 2018

(4) adjustable speed drive maintenance on August 4, 2018

(5) control room emergency filter unit WMA-FN-54A maintenance on August 8, 2018

(6) reactor core isolation cooling keepfill pump replacement on August 15, 2018

71111.22Surveillance Testing

The inspectors evaluated the following surveillance tests:

Routine (4 Samples)

(1) OSP-MS-Q701, Turbine Valve Surveillance, Revision 1, on July 1, 2018

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(2) OSP-SLC/IST-Q701, Standby Liquid Control Pumps Operability Test, Revision 27, on

July 11, 2018

(3) OSP-HPCS/IST-Q701, High Pressure Core Spray Quarterly Surveillance Test,

Revision 54, on July 25, 2018

(4) OSP-SW/IST-Q702, Standby Service Water Loop B Operability, Revision 34,on

September 18, 2018

In-service (1 Sample)

(1) OSP-LPCS/IST-Q702, LPCS System Operability Test, Revision 42, on July 3, 2018

71114.06Drill Evaluation

Drill/Training Evolution (1 Sample)

The inspectors evaluated the Emergency Plan drill on September 25, 2018.

RADIATION SAFETY

71124.01Radiological Hazard Assessment and Exposure Controls

Radiological Hazard Assessment (1 Sample)

The inspectors evaluated radiological hazards assessments and controls.

Instructions to Workers (1 Sample)

The inspectors evaluated worker instructions.

Contamination and Radioactive Material Control (1 Sample)

The inspectors evaluated contamination and radioactive material controls.

Radiological Hazards Control and Work Coverage (1 Sample)

The inspectors evaluated radiological hazards control and work coverage.

High Radiation Area and Very High Radiation Area Controls (1 Sample)

The inspectors evaluated risk-significant high radiation area and very high radiation area

controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)

The inspectors evaluated radiation worker performance and radiation protection technician

proficiency.

8

71124.03In-Plant Airborne Radioactivity Control and Mitigation

Engineering Controls (1 Sample)

The inspectors evaluated airborne controls and monitoring.

Use of Respiratory Protection Devices (1 Sample)

The inspectors evaluated respiratory protection.

Self-Contained Breathing Apparatus for Emergency Use (1 Sample)

The inspectors evaluated the licensees self-contained breathing apparatus program.

OTHER ACTIVITIES - BASELINE

71151Performance Indicator Verification (3 Samples)

The inspectors verified licensee performance indicators submittals listed below:

(1)

MS05: Safety System Functional Failures (SSFFs) Sample (06/01/2017 -

06/30/2018)

(2)

OR01: Occupational Exposure Control Effectiveness Sample (04/01/2017 -

06/30/2018)

(3)

PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation

Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent

Occurrences Sample (04/01/2017 - 06/30/2018)

71152Problem Identification and Resolution

Annual Follow-up of Selected Issues (2 Samples)

The inspectors reviewed the licensees implementation of its corrective action program

related to the following issues:

(1) management of personnel work hours per the Fatigue Rule (10 CFR 26, Subpart I) on

June 21 - July 31, 2018

(2) standby service water B pumphouse tornado missile door on August 20, 2018

9

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation

71124.01-

Radiological Hazard

Assessment and

Exposure Controls

This violation of very low safety significance was identified by the licensee and has been

entered into the licensee corrective action program and is being treated as a non-cited

violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Title 10 CFR 20.1902(a) requires the licensee to post each radiation area with a

conspicuous sign bearing the radiation symbol and the words "CAUTION, RADIATION

AREA."

Contrary to the above, from November 9, 2017 to November 13, 2017, the licensee failed to

post a radiation area with a conspicuous sign bearing the radiation symbol and the words

"CAUTION, RADIATION AREA."

The licensee moved two resin liners with high dose rates into the turbine building truck bay.

Once the resin liners were in the turbine building truck bay, a high radiation area boundary

was posted around them. However, the dose rates outside the truck bay doors were not

verified. On November 13, 2017, the licensee, while conducting routine area surveys,

identified an unposted radiation area outside the turbine building truck bay doors, which

resulted from the resin liners inside of the truck bay area. The licensee secured the radiation

area and adequately posted it, as required.

Significance/Severity Level: Green

Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety

Significance Determination Process, dated August 19, 2008, the inspectors determined the

finding was not related to ALARA planning, did not involve an overexposure or substantial

potential for overexposure, and the ability to assess dose was not compromised. For these

reasons, the inspectors concluded that the finding is of very low safety significance (Green).

Corrective Action Reference: AR 00373739

Failure to Follow Radiologically Controlled Area Procedures

Cornerstone

Significance

Cross-cutting Aspect Inspection Procedure

Occupational

Radiation

Safety

Green

NCV 05000397/2018003-01

Opened and Closed

H.12 - Avoid

Complacency

IP 71124.01 -

Radiological Hazard

Assessment and

Exposure Controls

The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification 5.4.1(a) when the licensee failed to implement radiation control procedures.

10

Description: On June 1, 2017, a supplemental health physics technician (HPT) entered a

posted locked high radiation area without a functioning electronic dosimeter (ED). Although

the area was posted as a locked high radiation area (LHRA), there were no measured dose

rates in excess of 1 rem per hour during this entry.

The HPT logged on to Radiation Work Permit (RWP) 30003852 and entered the radiologically

controlled area (RCA) to cover a job to add additional shielding in the travelling in-core probe

(TIP) Mezzanine room. The HPT entered the RCA through the HP swing gate near the RCA

exit point, in order to obtain survey instruments for the job coverage. The HPT proceeded to

the dress out area and then to the TIP Mezzanine room, where he entered with a survey

meter. After about 10 minutes in the room, the HPT looked at his ED and noticed that it was

in pause mode (i.e., not functioning). The HPT informed the worker he was covering, and

they both left the LHRA.

During the RWP logging process, there was an error when the HPTs ED was being

programmed that went unnoticed. As a result, the HPT was signed-on to the RWP, but the

ED was not programmed and active. Because the HPT used the HP swing gate at the RCA

exit rather than the normal access point with electronic turnstiles that verify ED function, this

errant condition was not identified. The swing gate used was intended for HPTs assigned to

assist workers with contamination alarms at the RCA exit, not as an RCA entry point to

perform work or cover a job.

Licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From Radiologically

Controlled Areas, Section 4.13 Dosimetry and Log-in, paragraph (e), requires workers to

ensure that electronic dosimetry is on immediately before entering the RCA. The HPT neither

used the electronic turnstiles nor checked to see if the ED was on prior to entering the RCA.

Additionally, licensee Procedure 11.2.7.3 High Radiation Area, Locked High Radiation Area,

and Very High Radiation Area Controls, Section 3.2.4 Coverage and Monitoring of Work,

paragraph (d), describes conducting a peer-check prior to LHRA entries, by the job coverage

HPT, to verify that workers are wearing an active ED (i.e., not in pause mode) in the

appropriate location on the body. The job coverage HPT checked to see that workers had an

ED appropriately placed, but did not check the ED setpoints or if the ED was active.

Multiple barriers that could have prevented this situation from occurring were either ineffective

or not used. Had the error reduction/prevention measures been used, the ED programming

error during RWP log on would have been identified.

Corrective Action(s): An immediate corrective action, in addition to the HPT being restricted

from the RCA, was a stand down conducted with radiation protection personnel about this

incident and coaching on use of the procedures related to the verification of dosimetry and

peer-checking prior to entry into LHRAs.

Corrective Action Reference: AR 00366701

Performance Assessment:

Performance Deficiency: Failure to follow station procedures for entry into a radiologically

controlled area is a performance deficiency.

11

Screening: The inspectors determined the performance deficiency was more than minor

because it adversely affected the program and process attribute of the Occupational

Radiation Safety Cornerstone to ensure the adequate protection of the worker health and

safety from exposure to radiation from radioactive material during routine civilian nuclear

reactor operation, in that failure to comply with exposure monitoring and radiation protection

controls has the potential to increase dose. Specifically, licensee requirements to control

workers exposure were not implemented by the HPT.

Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety

Significance Determination Process, dated August 19, 2008, the inspectors determined

finding was not related to ALARA planning, did not involve an overexposure or substantial

potential for overexposure, and the ability to assess dose was not compromised. For these

reasons, the inspectors concluded that the finding is of very low safety significance (Green).

Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated

with avoiding complacency, in that the individual did not implement appropriate error

reduction tools. Specifically, the individual failed to use the electronic turnstile and also failed

to check to see if the electronic dosimeter was on prior to entering the posted locked high

radiation area [H.12].

Enforcement:

Violation: Technical Specification 5.4.1(a) requires, in part, the implementation of written

procedures as outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978,

Section 7(e), Radiation Protection Procedures.

Contrary to the above, on June 1, 2017, the licensee failed to implement written procedures

for radiation protection. Specifically, the licensee failed to implement Sections 3.4 and

4.1.3(e) of licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From

Radiologically Controlled Areas.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Failure to Control Workers in a High Radiation Area (>1.0 rem per hour)

Cornerstone

Significance

Cross-cutting

Aspect

Inspection Procedure

Occupational

Radiation Safety

Green

NCV 05000397/2018003-02

Opened and Closed

H.4 - Teamwork IP 71124.01 - Radiological

Hazard Assessment and

Exposure Controls

The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification (TS) 5.7.2(b) and (e) when the licensee failed to control worker activities in a locked high

radiation area in accordance with the requirements of the RWP and failed to determine

radiological conditions in the work area prior to the start of work.

Description: On June 20, 2017, the licensee failed to control the work activities of riggers

working in a locked high radiation area. The high risk activity involved moving an unshielded

TTDF-34 filter vessel that was used for the wet well cleanup from the 471 foot elevation of the

12

reactor building (RX 471) to the 441 foot elevation of the reactor building (RX 441) truck bay

to place it in a disposable shield. The unshielded filter vessel radiation levels were 84.3 rem

per hour on contact and 52.8 rem per hour at 30 centimeters. The truck bay was closed and

guarded as a locked high radiation area (LHRA) during the filter vessel movement.

At 1:30 pm, a high risk brief was conducted for the filter vessel movement followed by a

briefing for the LHRA conditions and restrictions of the radiation work permit (RWP). The

brief included discussion of information on the RWP including the expected (i.e., calculated)

radiological conditions at various distances from the filter vessel, the use of continuous

radiation protection coverage for fields greater than 0.8 rem per hour, the electronic dosimeter

(ED) setpoints of 200 millirem for dose and 1.2 rem per hour for dose rate. The brief also

addressed the use of pre-staged shielding and long handled tools by the riggers. The HPT

conducting the brief (the job-coverage HPT) stated that an HPT must be present to approach

the filter vessel and informed the riggers not to be closer than thirty feet from the unshielded

filter vessel. The riggers asked if the setpoints were high enough and the HPT confirmed that

they were. At about 2:30 p.m., the two riggers logged on to RWP 3001279.

At 2:52 p.m., prior to the movement of the filter vessel from RX 471 to the truck bay on

RX 441, the two riggers entered the truck bay to prepare their work area. Once the filter

vessel was in motion from RX 471, the HPT covering the filter vessel movement proceeded to

the truck bay to provide radiation protection coverage for the two riggers as the filter vessel

was being lowered. The HPT arrived at the guarded truck bay door expecting to find the

riggers outside, but the riggers were already inside the truck bay. At 5:38 p.m., the HPT

entered the truck bay and found the riggers standing about 10 feet away from the shielded

cask with the unshielded filter vessel suspended about 15 feet overhead. At that point, one of

the riggers ED was alarming, with a dose rate of 1.52 rem per hour. Both riggers were

informed by the HPT to immediately leave the area. In order to leave the work in a safe

condition, the master rigger signaled the crane operator to stop movement and proceeded to

exit.

Subsequent to the event, the master rigger who received the ED alarm stated that he was

required to be in the truck bay when a load is being lifted out of or lowered into it. He stated

that he believed he was about 15 feet away from the filter vessel and that the position was as

far from the filter vessel as he could be to safely see the load being lowered.

The inspectors noted that the LHRA technical specification (TS 5.7.2) requires that activities

in LHRAs shall be controlled by means of an RWP that includes specification of dose rates in

the immediate work area and other appropriate radiation protection measures. Additionally,

entry into LHRAs shall be made only after dose rates in the area have been determined and

entry personnel made knowledgeable of them.

The inspectors also noted that licensee Procedure 11.2.7.3 High Radiation Area, Locked

High Radiation Area, and Very High Radiation Area Controls, Section 6.3, Controls to

Prevent Unplanned or Excessive Personnel Exposures, states in paragraph 6.3.6 that work

areas with dose rates greater than 1.5 rem per hour require continuous RP coverage as

either by line-of-sight or by remote means, and that continuous coverage means that the HPT

is capable of intervening to control a workers actions through direct or remote means.

Paragraph 6.3.6 continues by stating that continuous monitoring without the means to control

or constrain worker actions should not be used in place of continuous coverage.

13

Discussions with the licensee revealed that the estimated dose rates specified in the RWP

were calculated based on the contact readings of the unshielded filter vessel. However, no

confirmatory measurements were made of the RX 441 truck bay to determine the actual dose

rates prior to allowing worker entry. As such, the riggers entered the truck bay without the

required coverage HPT present and without the benefit of a survey of current radiological

conditions. The unanticipated ED alarm was an indication that riggers were unaware of the

current dose rates in the truck bay and that they were higher than what was calculated given

the indicated distance and the ED response.

Effective communication and coordination of this activity could have prevented this situation

from occurring. The licensees investigation of the ED alarm revealed that rigger workers

were used to conducting this work activity in a certain manner (i.e., positioning themselves to

see the load being safely lowered). From the riggers perspective, to ensure safety during the

lift, they needed to approach the vessel in order to direct the crane operator to land the load

safely. The riggers questioned the dose rate setpoint during the LHRA brief, but were told by

the HPT that it was sufficient without understanding the riggers safety perspective. As a

result, the riggers failed to understand the radiological restrictions and instructions conveyed

during the RWP and high risk briefings.

The inspectors concluded that two of the conditions for LHRA entry were not met. The

riggers failed to understand the radiological control requirements, and entered the truck bay

(impending LHRA) without continuous RP coverage, contrary to the RWP requirement.

Additionally, there was no radiological survey of the truck bay with the filter vessel present to

validate the calculated estimate so that the riggers could be made knowledgeable of the

conditions. Further, as the filter vessel was lowered creating the LHRA conditions, the HPT

was not in position to determine the radiological conditions or to control (intervene) in the

activities of the workers.

Corrective Action(s): The individuals involved exited the area and a recovery plan was

implemented. The riggers were coached on the requirements to follow the RWP and all

briefing instructions.

Corrective Action References: ARs 00368063 and 00368480

Performance Assessment:

Performance Deficiency: The failure to control worker activities and to determine current

radiological conditions prior to entry into a locked high radiation area was a performance

deficiency.

Screening: The inspectors determined the performance deficiency was more than minor

because it adversely affected the program and process attribute of the Occupational

Radiation Safety Cornerstone to ensure the adequate protection of the worker health and

safety from exposure to radiation from radioactive material during routine civilian nuclear

reactor operation. Specifically, the failure to comply with exposure control measures in a

locked high radiation area has the potential for increased dose.

Significance: Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation

Safety Significance Determination Process, dated August 19, 2008, the finding was not an

ALARA finding, there was no overexposure or substantial potential for overexposure, and the

14

licensees ability to assess dose was not compromised. Therefore the safety significance of

the finding would be very low (Green).

Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated

with teamwork, in that individuals and work groups did not communicate and coordinate their

activities within and across organizational boundaries to ensure nuclear safety is maintained.

Specifically, the riggers and the health physics technician failed to effectively communicate

their perspectives and expectations on safety for this high risk evolution and also failed to

effectively coordinate their activities in the locked high radiation area during the evolution

[H.4].

Enforcement:

Violation: Technical Specification 5.7.2, High Radiation Areas with Dose Rates Greater

than 1.0 rem/hour (at 30 cm from the radiation source), paragraph (b) requires, in part, that

activities shall be controlled by means of a radiation work permit that includes specification of

appropriate radiation protection measures, and paragraph (e) requires, in part, that entry shall

be made only after dose rates in the area have been determined and entry personnel are

knowledgeable of them.

Contrary to the above, on June 20, 2017, during work in a high radiation area with dose rates

greater than 1.0 rem per hour, the licensee failed to control activities by means of a radiation

work permit that included specification of appropriate radiation protection measures, and

entry was made prior to dose rates in the area having been determined and entry personnel

knowledgeable of them. Specifically, two workers entered the reactor building truck bay (a

locked high radiation area) and were present as a filter vessel with a dose rate of 52.8 rem

per hour at 30 cm was being lowered into it. Prior to arrival of the health physics technician,

required by the radiation work permit for continuous radiation protection coverage for work in

whole body dose rates greater than 800 millirem per hour, one of the workers received a dose

rate alarm of 1.52 rem per hour. Because a health physics technician was not present to

determine the actual dose rates (in contrast to calculated dose rates that had been briefed) in

the area while the load was being lowered, the workers were uninformed of the radiological

conditions.

Enforcement Action: This violation is being treated as a non-cited violation, consistent with

Section 2.3.2 of the Enforcement Policy.

Failure to Adequately Control Work Hours for Covered Personnel

Cornerstone

Significance

Cross-cutting

Aspect

Report

Section

Emergency

Preparedness

Green NCV

NCV 05000397/2018003-03

Opened and Closed

H.5 - Work

Management

71152

The inspectors identified a Green, non-cited violation of 10 CFR 26.205 associated with the

licensees failure to adequately schedule and control work hours for personnel subject to work

hour controls. Specifically, the licensee failed to appropriately schedule and control work

hours for at least three Chemistry Technicians who were providing covered work as the

designated Emergency Response Organization (ERO) Duty Chemistry Technician as defined

by the Columbia Generating Station Emergency Plan.

15

Description: In reviewing licensee documentation relative to work hour controls in accordance

with the requirements in 10 CFR 26, Subpart I (10 CFR 26.205), for various workgroups

across the station, the inspectors noted an example where a Chemistry staff member

appeared to have worked 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in a 7-day period on at least one occasion in

September 2017. The inspectors noted that this was in excess of the limits established in the

licensees Procedure SWP-FFD-004, Work Hour Controls, Revision 9, Section 3.4.4, which

states in part The following controls apply to covered workers (Definition 5.9) regardless of

unit status No more than 72 work hours in any 7 day period. The inspectors identified

this apparent issue to the licensee to determine if the Chemistry staff member was completing

covered work during the period, and whether a waiver had been processed to allow this staff

member to exceed the work hour requirement in accordance with Section 3.6 of

SWP-FFD-004.

In response to the inspectors questions, the licensee determined that a work hour controls

waiver had not been processed for the particular instance noted by the inspectors. Further,

the licensee noted that the one staff member exceeded 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7-day period on three

separate occasions in late August through late September 2017. The same staff member did

not receive the 34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br /> off in a 9-day period two times in that period, and also did not have

the required average days off over a 6-week cycle twice during the period. (These additional

controls are further requirements described in Section 3.4.4 of SWP-FFD-004.) As part of an

extent of condition review, the licensee identified a total of 11 examples where Chemistry staff

members worked hours in excess of the controls described in SWP-FFD-004, Section 3.4.4,

and no waiver was processed, in the period of review of July 2017 through April 2018. The

licensees review found the following contributed to the issues identified:

1. The supervisors lack of verification and validation of the data being input into the work

hours tracking software.

2. A breakdown in communication between the supervisor and technicians as to whether

or not a work hours waiver was necessary, and the actions required of the parties

involved to request the waivers.

3. General lack of familiarity by the Chemistry staff with Procedure SWP-FFD-04 and the

requirements associated with obtaining a waiver.

4. Inadequate validation of assumptions by the Chemistry staff members that a waiver

would cover them to exceed specific work hour/fatigue rules for an extended period of

time.

Also, the inspectors reviewed additional work hour records for other departments whose staff

were subject to work hour/fatigue rules and could involve staff transitioning between covered

and non-covered work activities. Specifically, records from Radiation Protection, Operations

(whose members support the Fire Brigade), and Security were reviewed for the same time

periods described above. The inspectors review of the work hour records for these additional

departments did not identify any additional discrepancies/violations of the work hour/fatigue

rules within or outside of the Chemistry Department. As such, the inspectors concluded that

the issues identified appear to have been isolated within the Chemistry Department.

16

Corrective Actions: The licensee entered the identified violations of the work hours rules into

the corrective action program, and initiated the following corrective actions:

1. Creation of a job aid to assist Chemistry staff/supervisors in implementing work hours

and overtime controls, in support of data entry into the station tracking software.

2. Additional training to supervisors and staff with job-related functions in the work hours

tracking software and the impacts of SWP-FFD-04.

3. Revision of Procedure CI-1.14, Chemistry Department FFD Fatigue Management, to

implement a process for an independent check of the Chemistry Department data

entered into the work hours tracking software in accordance with SWP-FFD-04.

Corrective Action References: AR 00379991, AR 00381017, and AR 00381551

Performance Assessment:

Performance Deficiency: The licensees failure to control work hours for Chemistry staff

covered by the requirements of 10 CFR 26.205, was determined to be a performance

deficiency.

Screening: The performance deficiency is more than minor because it is associated with the

ERO [emergency response organization] readiness attribute of the Emergency Preparedness

cornerstone and adversely affects the cornerstone objective that the licensee is capable of

implementing adequate measures to protect the health and safety of the public in the event of

a radiological emergency. Specifically, the Chemistry staff members in question were

providing covered work as the designated ERO Duty Chemistry Technician as defined by the

Columbia Generating Station Emergency Plan, and therefore were subject to the work hour

controls to manage worker fatigue as described in 10 CFR 26, Subpart I, as implemented by

licensee Procedure SWP-FFD-004. As such, the licensee emergency response personnel

(on-shift chemistry staff) may not have been capable of implementing adequate measures to

protect the health and safety of the pubic if they were excessively fatigued.

Significance: The finding was evaluated using Inspection Manual Chapter 0609, Appendix B,

Emergency Preparedness Significance Determination Process, dated September 22, 2015,

and was determined to be of very low safety significance (Green). The finding had a very low

safety significance because it was a failure to comply with NRC requirements, was not

associated with a risk significant planning standard function, and was not a loss of planning

standard function. The finding was not a loss of planning standard function because there

was not a loss of emergency response organization minimum staffing (on-shift Chemistry).

Specifically, this finding was determined to be associated with a degraded planning standard

function in that the process to ensure that the on-shift chemistry technician was staffed with a

non-fatigued individual was challenged on several occasions during the period of July through

October 2017.

Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated

with work management, in that the organization did not implement a process of planning,

controlling, and executing work activities such that nuclear safety is the overriding priority,

including the identification and management of risk commensurate to the work. Specifically,

the licensee failed to establish a verification/validation process for the Chemistry supervisors

17

to provide reasonable assurance that the technician work hours were accurately entered and

tracked [H.5].

Enforcement: Title 10 CFR 26.4(a) states in part that "All persons who are granted

unescorted access to nuclear power reactor protected areas by the licensees in § 26.3(a) ...

and perform the following duties shall be subject to a [fitness for duty] program..." and lists

one function as "(2) Performing health physics or chemistry duties required as a member of

the onsite emergency response organization minimum shift complement." Further,

10 CFR 26.205 states, in part, that individuals who perform duties identified in § 26.4(a)(1)

through (a)(5) shall be subject to the requirements of 10 CFR 26, Subpart I, and that

licensees shall calculate, schedule, and control the work hours of individuals who are subject

to that section.

Contrary to the above, from July through October 2017, for at least three individuals

performing chemistry duties required as a member of the onsite emergency response

organization minimum shift complement (to which 10 CFR 26.205 applies), the licensee failed

to assure that work hours were scheduled and controlled. In response to this issue, the

licensee developed actions to ensure that work hours for chemistry technicians were

adequately controlled including development of a user aid, additional training, and

independent validation of information entered into the work hours tracking software. This

issue does not represent an immediate safety concern because at the time of discovery no

personnel were in excess of work hour requirements, and the licensee took actions to prevent

occurrence in the future.

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

On September 19, 2018, the inspectors presented the radiation protection baseline inspection

results to Mr. R. Schuetz, Vice President, Operations, Mr. A. Javorik, Vice President,

Engineering, and other members of the licensee staff. The inspectors verified no proprietary

information was retained or documented in this report. On October 3, 2018, the inspectors held

a follow-up telephonic exit with Mr. R. Schuetz, Vice President, Operations, Mr. D. Brown,

General Manager, Plant Operations, and other members of the licensee staff to clarify the

significance of an additional radiation protection issue discussed during the inspection, but not

presented in the on-site exit meeting stated above. The additional issue was a minor violation,

so the call was administrative in nature to validate the licensee understood the issues

significance. On October 15, 2018, the inspectors held a follow-up telephonic exit with Mr. R.

Schuetz, Vice President, Operations, Mr. D. Brown, General Manager, Plant Operations, and

other members of the licensee staff to communicate a change in the characterization of the

inspection results.

On October 15, 2018, the inspectors presented the quarterly resident inspector inspection

results to Mr. A. Javorik, Vice President, Engineering, and other members of the licensee staff.

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

18

DOCUMENTS REVIEWED

71111.01 - Adverse Weather Protection

Action Requests

370257

379411

369975

370063

382228

380608

380616

380310

382752

382753

382754

Work Orders

29137990

29137991

02098735

Procedures

(Number)

Title

Revision

SOP-COLDWEATHER-OPS

Cold Weather Operations

030

SOP-HOTWEATHER-OPS

Hot Weather Operations

006

SOP-WARMWEATHER-

OPS

Warm Weather Operations

015

SOP-SW-SPRAY

Standby Service Water Spray Header Operations

000

Miscellaneous

Documents

(Number)

Title

Revision

ME-02-92-43

Calculation for Room Temperature for DG Building and

R and W and SW Pumphouse Under Design Basis

Accident Conditions

012

ME-02-92-41

Calculation for Ultimate Heat Sink Analysis

007

ME-02-85-79

Calculation for Spray Pond Temperature Transient

Without Sprays

003

71111.04 - Equipment Alignment

Procedures

(Number)

Title

Revision

1.3.29

Locked Valve Checklist

079

ABN-FPC-LOSS

Loss of Fuel Pool Cooling

016

ABN-HPCS-DEPRESS

HPCS Recovery Following Depressurization From

Keep Fill Failure

003

SOP-FPC-ASSIST-ALT

Alternate Fuel Pool Cooling Assist

011

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

SOP-HPCS-LV

HPCS Valve and Breaker Lineup

004

SOP-HPCS-M102

HPCS Valve Lineup

004

SOP-HPCS-STBY

Placing HPCS in Standby Status

003

19

Procedures

(Number)

Title

Revision

SOP-LPCS-STBY

Placing LPCS in Standby Status

002

SOP-LPCS-LU

LPCS Valve and Breaker Lineup

003

SOP-RCIC-LU

RCIC Valve and Breaker Lineup

004

SOP-RCIC-STBY

Placing RCIC in Standby Status

011

SOP-SW-M103

HPCS Service Water Valve Position Verification

024

Drawings

(Number)

Title

Revision

M519

Reactor Core Isolation Cooling System Flow Diagram

102

M520

HPCS and LPCS Systems Reactor Building Flow Diagram

104

M200-103

Low Pressure Core Spray System Isometric Diagram

017

RCIC-656-5.8

Suction from Suppression Pool to RCIC Pump RCIC-P-1

017

RCIC-659-1.2

RCIC Pump to RCIC Vessel

011

71111.05AQFire Protection Annual/Quarterly

Action Requests

382268

382272

383100

385162

Procedures

(Number)

Title

Revision

1.3.10

Plant Fire Protection Program Implementation

034

1.3.10A

Control of Ignition Sources

017

1.3.10B

Active Fire System Operability and Impairment Control

015

1.3.10C

Control of Transient Combustibles

020

1.9.13

Transformer Yard Access and Controls

019

FPP-1.7

Fire Tour Implementation

006

PFP-MN-XMR-YD-MISC

PFP-MN-XMR-YD-MISC Bldgs

006

PFP-RB-422

Reactor 422

006

PFP-RW-437-452

RADWASTE 437-452

005

SFI-26

Fire Tour

002

SWP-FPP-01

Nuclear Fire Protection Program

008

Miscellaneous

Documents

(Number)

Title

Revision or

Date

FP-02-85-03

Calculation for FSAR Update Including Fire Loading in

General Room and Floor Areas

010

Fire Brigade Training Drill Cycle 18-1 Crew E Critique

January 18, 2018

Fire Brigade Training Drill Cycle 18-3 Crew F Critique

May 31, 2018

Fire Brigade Training Drill Cycle 18-4 Crew F Critique

August 23, 2018

Fire Brigade Unannounced Drill 18-001 Crew A Critique

October 1, 2018

71111.07Heat Sink Performance

Action Requests

384028

384029

20

Work Orders

02100975

02123992

02126970

02126200

02126970

02100975

02080164

02105918

02023553

02106204

02084429

02106205

02084430

Procedures

(Number)

Title

Revision

1.5.13

Preventive Maintenance Optimization Living Program

040

8.4.54

Thermal Performance Monitoring for DCW-HX-1A1 and

DCW-HX-1A2

010

8.4.63

Thermal Performance Monitoring of DCW-HX-1C

010

Drawings

(Number)

Title

Revision

M512-2

Flow Diagram Diesel Oil & Miscellaneous Systems

037

M524-1

Flow Diagram Standby Service Water System Reactor,

Radwaste, D.G. Bldgs and Yard

138

Miscellaneous

Documents

(Number)

Title

Revision

02E22-07,54,3

HPCS Diesel Generator

012

ME-02-92-243

Calculation for DCW-HX-1C Design Performance

Requirements

003

MOT-HX-1-1

Heat Exchangers

012

71111.11Licensed Operator Requalification Program and Licensed Operator Performance

Procedures

(Number)

Title

Revision

1.3.1

Operating Policies, Programs and Programs

127

5.1.1

RPV Control

021

5.2.1

Primary Containment Control

027

5.3.1

Secondary Containment Control

020

13.1.1

Classifying the Emergency

049

OI-09

Operations Standards and Expectation

070

OSP-RCIC/IST-Q701

RCIC Operability Test

061

Miscellaneous

Documents

(Number)

Title

Revision

Crew D Evaluated Scenario Cycle 18-4, 4.0 Critique

Summary

000

LR002425

Cycle 18-4 Evaluated Scenario

000

21

71111.12Maintenance Effectiveness

Action Requests

369836

372031

366178

366220

368573

369803

363774

334979

336819

324924

340031

343726

351952

362949

364950

366788

Procedures

(Number)

Title

Revision

1.5.11

Maintenance Rule Program

015

OSP-SW/IST-Q703

HPCS Service Water Operability

027

SOP-HPCS-CST/SP

HPCS CST and Suppression Pool Operations

014

SYS-4-22

Maintenance Rule Program

014

71111.13Maintenance Risk Assessments and Emergent Work Control

Action Requests

337916

382706

Work Orders

02098551

02097647

02121918

02132528

02095968

02101599

02130842

Procedures

(Number)

Title

Revision

1.3.76

Integrated Risk Management

049

1.3.76

Integrated Risk Management

050

1.3.76

Integrated Risk Management

051

1.3.83

Protected Equipment Program

026

8.4.42

Thermal Performance Monitoring of RHR-HX-1A and

RHR-HX-1B

012

ESP-RCIC-X301

RCIC Turbine Speed Monitor - CC

004

ISP-RCIC-Q901

RCIC Isolation on RCIC Steam Supply Flow High

DIV 1-CFT/CC

024

ISP-RCIC-Q903

RCIC Isolation on RCIC Steam Supply Flow High

DIV 2-CFT/CC

019

OSP-RCIC/IST-Q701

RCIC Operability Test

061

OSP-RCIC/IST-Q702

RCIC Valve Operability Test

043

OSP-RCIC-M101

RCIC Fill, Flow Controllers, and Valve Lineup Verification

017

SOP-SW-DRAIN

Standby Service Water Drain

008

WCI-1

Unit Coordinator BPA Duties

008

22

71111.15Operability Determinations and Functionality Assessments

Action Requests

382900

382882

383452

383440

383703

383698

366967

383232

383236

383054

383057

Work Orders

02130891

02131541

02131542

02131543

02131544

02131545

02131593

Procedures

(Number)

Title

Revision

1.10.11

Technical Assessments Supporting Reportability and

Reportability Evaluations

002

OPEX-01

Operating Experience Program Implementation Manual

009

SWP-OPX-01

Operating experience Program

000

Drawings

(Number)

Title

Revision

E-504-1

Vital One Line Diagram

006

71111.19Post Maintenance Testing

Action Requests

265493

382110

382674

382784

PER 205-0024

382426

374860

Work Orders

02093978

02116384

02089875

02089987

02089995

02095010

02096336

02130586

02128698

02108899

02122111

02122391

02129438

Procedures

(Number)

Title

Revision

10.2.3

Pump Packing Replacement and Adjustment

013

10.2.54

Pump Testing

009

10.24.248

Visual Examination of Electronic Components, Circuit

Boards, and Solder Joints

000

10.25.105

Motor Control Center and Switchgear Maintenance

035

10.25.13

Westinghouse Medium Voltage Circuit Breakers

034

ISP-MS-X312, DIV 1

Channel A Isolation Actuation on Level 1 and Reactor

Level 2 - Channel Calibration

006

OSP-ELEC-S703

HPCS Diesel Generator Semi-Annual Operability Test

062

23

Procedures

(Number)

Title

Revision

OSP-LPCS/IST-Z702

LPCS System Operability Test

042

OSP-WMA-B701

Control Room Ventilation System A Pressurization Flow

Test

020

SOP-RCIC-FILL

RCIC Fill and Vent

017

Miscellaneous

Documents (Number)

Title

Revision

Channel A Isolation Actuation on Reactor Level 1 and

Reactor Level 2 - Channel Calibration

006

71111.22Surveillance Testing

Action Requests

353783

358013

359298

360016

360021

353864

382785

Work Orders

02090774

02094071

02098015

02114831

02122412

02117436

02114670

02130842

02103225

02101890

Procedures

(Number)

Title

Revision

4.601.A3

601.A3 Annunciator Panel Alarms

027

DBD 316

Design Specification for Low Pressure Core Spray

011

EWD-15E-014

Reactor Protection System Trip System B Sensor Relays

005

IST-4

Inservice Testing Program Plan Fourth Ten-Year

Inspection Interval

001

OSP-MS-S701

Turbine Valve Surveillance

001

OSP-RPS-Q401

Turbine Throttle Valve Closure CFT

002

OSP-RPS-S401

Turbine Throttle Valve Closure CFT

000

OSP-SLC/IST-Q701

Standby Liquid Control Pumps Operability Test

026

SD000192

System Description Low Pressure Core Spray (LPCS)

013

SWP-IST-01

ASME Inservice Testing

003

71114.06Drill Evaluation

Procedures

(Number)

Title

Revision

1.3.1

Operating Policy, Programs, and Practices

127

5.1.1

RPV Control

021

5.2.1

Primary Containment Control

027

5.3.1

Secondary Containment Control

020

13.1.1

Classifying the Emergency

049

24

Procedures

(Number)

Title

Revision

13.10.1

Control Room Operation and Shift Manager Duties

035

13.10.2

TSC Manager Duties

035

13.2.1

Emergency Exposure Levels, Protective Action Guides

022

13.2.2

Determining Protective Actions

020

13.4.1

Emergency Notifications

043

13.5.1

Local, Protected Area, or Site Evacuation

029

13.9.1

Environmental Field Monitoring Operations

045

13.10.9

Operations Support Center Manager and Staff Duties

049

13.11.1

EOF Manager Duties

044

13.13.1

Reentry Operations

010

13.13.3

Intermediate Phase MUDAC Operations

018

13.13.4

After Action Reporting

010

13.14.9

Drill and Exercise Program

029

OI-09

Operations Standards and Expectations

070

71124.01Radiological Hazard Assessment and Exposure Controls

Procedures

(Number)

Title

Revision

GEN-RPP-04

Entry Into, Conduct In, and Exit From Radiologically

Controlled Areas

032

HPI-0.19

Radiation Protection Standards and Expectations

018

SWP-RPP-01

Radiation Protection Program

016

PPM 11.2.7.1

Area Posting

043

PPM 11.2.13.1

Radiation and Contamination Surveys

040

PPM 11.2.24.1

Radiation Protection Work Routines

035

PPM 11.2.7.3

High Radiation Area, Locked High Radiation Area, and Very

High Radiation Area Controls

042

PPM 11.2.14.4

Procurement, Receipt, Control and Leak Testing of

Radioactive Sealed Sources and Devices

024

PPM 11.2.13.8

Airborne Radioactivity Surveys

019

PPM 11.2.14.9

Control and Labeling of Radioactive Material

021

PPM 1.11.15

Control of Radioactive Material

013

PPM 6.1.1

Spent Fuel Pool Inventory

010

Audits and Self-

Assessments

(Number)

Title

Date

AR-SA 374280

Occupational Exposure Control Effectiveness

May 25, 2018

AR-SA 374283

Performance Indicator Verification PR-01

June 7, 2018

AR-SA 375035-06

Radiological Hazard Assessment and Exposure

Controls

July 9, 2018

AU-RP/RW-17

QA Audit: Radiation Protection and Process Control

Programs

December 18,

2017

25

Action Requests

366701

367332

368222

368480

368651

369180

370737

373739

379010

379636

381763

381764

Radiation Surveys

M-20170601-11

M-20170620-11

M-20170620-12

M-20170624-1

M-20170813-3

M-20170830-4

M-20170906-5

M-20180717-3

M-20180721-4

M-20180807-3

M-20180807-5

M-20180830-1

M-20180830-4

M-20180905-4

M-20180910-1

M-20180910-1

M-20180912-5

Air Samples

875805

875816

895915

907092

Radiation Work

Permits

Title

Revision

30001279

R23 WW Packaging TTDF-34 Filter *LHRA* *High Risk* STK

001

30003852

R23 RX/WW , RP Surveys & Job Coverage **LHR**

000

30003986

2017 RW 487 WEA Fan Rem/Replace Pre-Filter *HR*High

Contam*

001

30004141

2018 RX 501 TIP Room/TIP Drive Room **HRA**

000

30004147

2018 TG 501 W. Labyrinth PMs & Surveillance ***LHRA***

000

30004200

2018 RW 437 Waste Processing NUPAC Cage **LHRA**

001

Miscellaneous

Documents

(Number)

Title

Revision

or Date

CGS Radioactive Source Inventory - Non-Exempt

August 21,

2018

374337

Information for NSTS Annual Inventory Reconciliation

January 15,

2018

W/O 2119710

HSP-SSC-0801 Sealed Source Leakage Verification

April 9, 2018

30001279

High Risk Plan for R23 WW Packaging

TTDF-34 Filter

003

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation

Procedures

(Number)

Title

Revision

26

GEN-RPP-05

Respiratory Protection Program Description

015

GEN-RPP-10

Use of Respiratory Protection Equipment

012

HPI-15.1

Inspection and Storage of Respirators and Attachments

011

HPI-15.5

Set Up and Use of Bullard Air Line Filters

003

PPM 11.2.11.3

Issuance of Respiratory Protection Equipment

017

PPM 13.14.4

Emergency Equipment Maintenance and Testing

054

Audits and Self-

Assessments

(Number)

Title

Date

AR-SA 301868-03

Respiratory Protection Self-Assessment

April 14, 2017

AR-SA 00357502

71124.03 Self-Assessment

March 5,

2018

AU-RP/RW-17

QA Audit: Radiation Protection and Process Control

Programs

December 18,

2017

Action Requests

371385

347601

347688

347689

377412

Radiation Work

Permits (Number)

Title

Revision

30004034

R23 TG 501 Sandblasting Tent Work

000

30004161

2018 RW 437 / 452 / 467 High Rad Work ***HR***

002

30004152

2018 RW 487 Chemistry Lab High Radiation Areas *HR*

001

SCBA Records

(Number)

Title

Date

67833

Calibration Certificate

August 13,

2018

67958

Calibration Certificate

August 13,

2018

67993

Calibration Certificate

August 15,

2018

W/O 2123630

Fire Brigade Station Inventory TG 501 and MCR

July 26, 2018

In Place Filter

Testing Records

Work Order

Title

Date

02074192

MSP-WMA-B104 - WMA-FU-54B - Carbon Adsorber Test September 22,

2016

27

In Place Filter

Testing Records

Work Order

Title

Date

02074207

MSP-WMA-B102 - WMA-FU-54B - HEPA Filter Test

September 22,

2016

02081424

MSP-WMA-B101 - WMA-FU-54A - HEPA Filter Test

August 3,

2016

02083458

MSP-WMA-B103 - WMA-FU-54A - Carbon Adsorber Test August 3,

2016

02083554

AMA-CF-52 Replace Carbon, Inspect

(FILTR-1-1-9.3)

March 8, 2018

Miscellaneous

Documents (Number) Title

Date

OK 581518

Certificate of Analysis

June 20, 2018

SA-V-99/35

Analysis of Air Samples for Breathing Air

July 26, 2018

W/O 2123630

Fire Brigade Station Inventory TG 501 and MCR

September 26,

2018

71151Performance Indicator Verification

Procedures

(Number)

Title

Revision

SWP-OPS-02

Safety Function Determination Program

007

71152Problem Identification and Resolution

Action Requests

379991

381017

381551

379120

379504

307821

009924

383966

383951

280168

383773

Work Orders

02128878

02128879

02059398

Procedures

(Number)

Title

Revision

1.5.13

Preventive Maintenance Optimization Living Program

039

EC 17325

Evaluation for Service Water (SW) Pumphouse Swinging

Door B-DOOR-G200 Supporting SW Operability with the

Designated Shear Pins Not Engaged

000

SWP-FFD-03

Fatigue Management

005

SWP-FFD-04

Work Hour Controls

009

28

Drawings

(Number)

Title

Revision

AED-ARC-A555

Door Schedule Sheet 3

030

CVI-DWG-210-23

Spec. Section 8L Exterior Missile Doors G100 & G200

003

Miscellaneous

Documents

(Number)

Title

Revision

or Date

Schedule Report for Radiation Protection

(8/2017 - 10/2017, 1/2018 - 2/2018)

May 10, 2018

Schedule Report for Chemistry

(8/2017 - 10/2017, 1/2018 - 2/2018)

June 20, 2018

Schedule Report for Operations

(8/2017 - 10/2017, 1/2018 - 2/2018)

June 4, 2018

Schedule Report for Security

(8/2017 - 10/2017, 1/2018 - 2/2018)

May 9, 2018

Plant General Manager & Department Manager Work

Hour Reviews per SWP-FFD-04 (January 1 to June

30, 2017)

July 6, 2017

Plant General Manager & Department Manager Work

Hour Reviews per SWP-FFD-04 (July 1 to December

30, 2017)

January 30,

2018

AED-SPC-08L

Design Specification for Division 8 Section 8L Exterior

Missile Doors G100 and G200

002

29

Enclosure 2

The following items are requested for the

Occupational Radiation Safety Inspection

at Columbia

Dates of Inspection: 09/10/2018 to 09/14/2018

Integrated Report 2018003

Inspection areas are listed in the attachments below.

Please provide the requested information on or before Wednesday, August 22, 2018.

Please submit this information using the same lettering system as below. For example, all

contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled

1-A, applicable organization charts in file/folder 1-B, etc.

If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at

least 30 days later than the onsite inspection dates, so the inspector will have access to the

information while writing the report.

In addition to the corrective action document lists provided for each inspection procedure listed

below, please provide updated lists of corrective action documents at the entrance meeting.

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

entrance meeting.

If more than one inspection procedure is to be conducted and the information requests appear

to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which

file the information can be found.

If you have any questions or comments, please contact John O'Donnell at 817-200-1441 or via

e-mail at John.ODonnell@nrc.gov.

PAPERWORK REDUCTION ACT STATEMENT

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget,

control number 3150-0011.

30

1.

Radiological Hazard Assessment and Exposure Controls (71124.01) and

Performance Indicator Verification (71151)

Date of Last Inspection:

May 26, 2017

A.

List of contacts and telephone numbers for the Radiation Protection Organization Staff

and Technicians. Please include area code and prefix. If work cell numbers are

appropriate, then please include them as well.

B.

Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C.

Copies of audits, self-assessments, LARs, and LERs written since the last inspection

date, related to this inspection area

D.

Procedure indexes for the radiation protection procedures and other related disciplines.

E.

Please provide procedures related to the following areas noted below. Additional

procedures may be requested by number after the inspector reviews the procedure

indexes.

1. Radiation Protection Program

2. Radiation Protection Conduct of Operations, if not included in #1.

3. Personnel Dosimetry

4. Posting of Radiological Areas

5. High Radiation Area Controls

6. RCA Access Controls and Radiation Worker Instructions

7. Conduct of Radiological Surveys

8. Radioactive Source Inventory and Control

9. Fuel Pool Inventory Access and Control

F.

Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G.

Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) since the last inspection date.

1. Initiated by the radiation protection organization

2. Assigned to the radiation protection organization

NOTE: These lists should include a description of the condition that provides sufficient

detail that the inspector can ascertain the regulatory impact, the significance level

assigned to the condition, the status of the action (e.g., open, working, closed,

etc.) and the search criteria used. Please provide in document formats which are

sortable and searchable so that inspector can quickly and efficiently determine

appropriate sampling and perform word searches, as needed. (Excel

spreadsheets are the preferred format.) If codes are used, please provide a

legend for each column where a code is used.

H.

List of radiologically significant work activities scheduled to be conducted during the

inspection period. (If the inspection is scheduled during an outage, please also include a

list of work activities greater than 1 rem, scheduled during the outage with the dose

31

estimate for the work activity.) Please include the radiological risk assigned to each

activity.

I.

Provide a summary of any changes to plant operation that have resulted or could result

in a significant new radiological hazard. For each change, please provide the

assessment conducted on the potential impact and any monitoring done to evaluate it.

J.

List of active radiation work permits and those specifically planned for the on-site

inspection week.

K.

Please provide a list of air samples taken to verify engineering controls and a separate

list for breathing air samples in airborne radiation areas or high contamination work

areas. Please include the RWP the breathing air sampling supports.

L.

Please provide the current radioactive source inventory, listing all radioactive sources

that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,

Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and

current activity (w/assay date), and storage location for each applicable source.

M.

The last two leak test results for the Category 1 or 2 radioactive sources and any other

radioactive source(s) that have failed its leak test within the last two years. Provide any

applicable condition reports.

N.

A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate

dose rates (Contact / @ 30cm)

O.

A list of radiological controlled area entries greater than 100 millirem, since the last

inspection date. The list should include the date of entry, some form of worker

identification, the radiation work permit used by the worker, dose accrued by the worker,

and the electronic dosimeter dose alarm set-point used during the entry (for

Occupational Radiation Safety Performance Indicator verification in accordance with

IP 71151).

P.

A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.

Include their current status, locations, and control measures.

Q.

Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally

closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay

doors). Include any CRs associated with this monitoring or instrumentation.

32

3.

In-Plant Airborne Radioactivity Control and Mitigation (71124.03)

Date of Last Inspection:

March 4, 2016

A.

List of contacts and telephone numbers for the following areas. Please include area

code and prefix. If work cell numbers are appropriate, then please include them as well.

1. Respiratory Protection Program

2. Self-contained breathing apparatus

3. Ventilation Systems for breathing air (not effluents)

B.

Applicable organization charts including position or job titles. Please include as

appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),

Engineering, and Emergency Protection. (Recent pictures are appreciated.)

C.

Copies of audits, self-assessments, vendor, or NUPIC audits for contractor support

(SCBA), LARs, and LERs, written since the date of last inspection related to:

1. Installed air filtration systems

2. Self-contained breathing apparatuses

D.

Procedure index for Radiation Protection, Maintenance, I&C, and other related

disciplines.

1. Use, operation, and maintenance of installed and portable continuous air monitors

2. Use operation, and maintenance of installed air filtration units for breathing air (e.g.,

for airline respirators, emergency ventilation systems).

3. Use, operation, and maintenance of temporary air filtration units and vacuums

4. Respiratory protection and other related disciplines

E.

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

Additional Specific Procedures may be requested by number after the inspector reviews

the procedure indexes.

1. Respiratory protection program

2. Use and maintenance of self-contained breathing apparatuses

3. Air quality testing for SCBAs or other compressed or supplied air systems

4. Use and testing of installed plant air cleaning systems used for breathing air, such as

control room emergency ventilation, technical support center, operations support

center, and emergency operations facility (When containment purge is not used as

an effluent system, then it can be considered as a breathing air system used prior to

outages during RCS breach and flood up.)

F.

Please provide a list of NRC Regulatory Guides and NUREGs that you are currently

committed to relative to this program. Please include the revision and/or date for the

commitment and where this may be located in your current licensing basis documents.

G.

Please provide a summary list of corrective action documents (including corporate and

sub-tiered systems) written since the date of last inspection, related to the Airborne

Monitoring program including:

1. In-plant continuous air monitors (installed or portable), not effluent monitors

2. Self-contained breathing apparatus

3. Air Cleaning systems (not effluent)

4. Respiratory protection program

NOTE: These lists should include a description of the condition that provides

33

sufficient detail that the inspector can ascertain the regulatory impact, the

significance level assigned to the condition, the status of the action (e.g., open,

working, closed, etc.) and the search criteria used. Please provide in document

formats which are sortable and searchable so that inspector can quickly and

efficiently determine appropriate sampling and perform word searches, as needed.

(Excel spreadsheets are the preferred format.) If codes are used, please provide a

legend for each column where a code is used.

H.

List of SCBA qualified personnel - reactor operators and emergency response

personnel. For the control room individuals, please indicate their normally scheduled

shift and specific mask size, as well as note if they are permitted/fitted for eyewear.

I.

Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant

for use since the date of last inspection.

J.

SCBA training and qualification records for control room operators, shift supervisors,

STAs, and OSC personnel for the last year.

A selection of personnel may be asked to demonstrate proficiency in donning, doffing,

and performance of functionality check for respiratory devices.

K.

List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,

model, quantity by size, and location. Be prepared to demonstrate that these respirators

are NIOSH certified.

Include in the list the specific quantities and sizes staged for emergency use.

L.

Provide one-line drawings of the supplied air and air cleaning systems identified in E.3

and E.4 above.

M.

List work activities requiring respiratory protection and the type of respirator used

(include PAPRs).

N.

Please have available, on-site, the records demonstrating the compressed air for SCBAs

or supplied air for a breathing air system is at least Grade D.

ML18304A362

SUNSI Review

ADAMS:

Non-Publicly Available

Non-Sensitive

Keyword:

By:

MSH

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

GMiller

TFarnholtz

GWerner

HGepford

SIGNATURE

GJK

LNM

GBM

TRF

GEW

HJG

DATE

10/29/18

10/29/18

10/29/18

10/29/2018

10/29/2018

10/29/2018

OFFICE

DRS/OB

SPE:DRP/A

BC:DRP/A

NAME

VGaddy

RAlexander

MHaire

SIGNATURE

vgg

RDA

/MSH

DATE

10/29/18

10/29/2018

10/31/18