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                                          October 31, 2018
Mr. Brad Sawatzke, Chief Executive Officer
Energy Northwest
MD 1023
October 31, 2018  
P.O. Box 968
Richland, WA 99352
SUBJECT:       COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION
                REPORT 05000397/2018003
Mr. Brad Sawatzke, Chief Executive Officer  
Dear Mr. Sawatzke:
Energy Northwest  
On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an
MD 1023  
inspection at your Columbia Generating Station. On October 15, 2018, the NRC inspectors
P.O. Box 968  
discussed the results of this inspection with Mr. Alex Javorik, Vice President, Engineering, and
Richland, WA 99352  
other members of your staff. The results of this inspection are documented in the enclosed
report.
SUBJECT:  
NRC inspectors documented three findings of very low safety significance (Green) in this report.
COLUMBIA GENERATING STATION - NRC INTEGRATED INSPECTION  
These findings involved violations of NRC requirements. The NRC is treating these violations
REPORT 05000397/2018003  
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
Dear Mr. Sawatzke:  
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.
On September 30, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an  
If you contest the violations or significance of these NCVs you should provide a response within
inspection at your Columbia Generating Station. On October 15, 2018, the NRC inspectors  
30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear
discussed the results of this inspection with Mr. Alex Javorik, Vice President, Engineering, and  
Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with
other members of your staff. The results of this inspection are documented in the enclosed  
copies to the Regional Administrator, Region IV; the Director, Office of Enforcement; and the
report.  
NRC resident inspectors at the Columbia Generating Station.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
NRC inspectors documented three findings of very low safety significance (Green) in this report.
response within 30 days of the date of this inspection report, with the basis for your
These findings involved violations of NRC requirements. The NRC is treating these violations  
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.  
Washington, DC 20555-0001; with copies to the Regional Administrator, Region IV; and the
NRC resident inspectors at the Columbia Generating Station.
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
B. Sawatzke  
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document
2  
Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
 
                                                Sincerely,
This letter, its enclosure, and your response (if any) will be made available for public inspection  
                                                /RA/
and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document  
                                                Mark Haire, Branch Chief
Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for  
                                                Project Branch A
Withholding.  
                                                Division of Reactor Projects
Sincerely,  
Docket No. 50-397
License No. NPF-21
/RA/  
Enclosures:
1. Inspection Report 05000397/2018003
2. Request for Information: Occupational
Mark Haire, Branch Chief
    Radiation Safety Inspection
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  


                          U.S. NUCLEAR REGULATORY COMMISSION
 
                                        Inspection Report
Docket Number:         05000397
License Number:       NPF-21
Report Number:         05000397/2018003
Enclosure 1
Enterprise Identifier: I-2018-003-0030
Licensee:             Energy Northwest
 
Facility:             Columbia Generating Station
U.S. NUCLEAR REGULATORY COMMISSION  
Location:             Richland, Washington
Inspection Report  
Inspection Dates:     July 1, 2018 to September 30, 2018
Inspectors:           G. Kolcum, Senior Resident Inspector
                      L. Brandt, Resident Inspector
Docket Number:
                      R. Alexander, Senior Project Engineer
05000397  
                      N. Hernandez, DRS Operations Engineer
                      J. ODonnell, DRS Health Physicist
Approved By:           M. Haire, Branch Chief
License Number:  
                      Project Branch A
NPF-21  
                      Division of Reactor Projects
                                                            Enclosure 1
Report Number:  
05000397/2018003  
Enterprise Identifier: I-2018-003-0030  
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  


                                            SUMMARY
 
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Columbia Generating Station in
2
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
SUMMARY  
documented in the Inspection Results at the end of this report.
                                  List of Findings and Violations
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees  
  Failure to Follow Radiologically Controlled Area Procedures
performance by conducting an integrated inspection at Columbia Generating Station in  
  Cornerstone     Significance                                     Cross-cutting     Inspection
accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs  
                                                                      Aspect            Procedure
program for overseeing the safe operation of commercial nuclear power reactors. Refer to  
  Occupational     Green                                             H.12 - Avoid     71124.01 -
https://www.nrc.gov/reactors/operating/oversight.html for more information. NRC-identified  
  Radiation        NCV 05000397/2018003-01                          Complacency      Radiological
findings are summarized in the table below. A licensee-identified non-cited violation is  
  Safety          Opened and Closed                                                  Hazard
documented in the Inspection Results at the end of this report.  
                                                                                        Assessment
                                                                                        and
                                                                                        Exposure
List of Findings and Violations  
                                                                                        Controls
  The inspectors reviewed a self-revealed Green, non-cited violation of Technical
Failure to Follow Radiologically Controlled Area Procedures  
  Specification 5.4.1(a) when the licensee failed to implement radiation control procedures.
Cornerstone  
  Failure to Control Workers in a High Radiation Area (>1.0 rem per hour)
Significance  
  Cornerstone     Significance                                     Cross-cutting     Inspection
Cross-cutting  
                                                                      Aspect            Procedure
Aspect
  Occupational Green                                                 H.4 -             71124.01 -
Inspection  
  Radiation        NCV 05000397/2018003-02                          Teamwork          Radiological
Procedure  
  Safety          Opened and Closed                                                  Hazard
Occupational  
                                                                                        Assessment
Radiation
                                                                                        and
Safety
                                                                                        Exposure
Green  
                                                                                        Controls
NCV 05000397/2018003-01
  The inspectors reviewed a self-revealed Green, non-cited violation of Technical
Opened and Closed
  Specification 5.7.2(b) and (e) when the licensee failed to control worker activities in a locked
H.12 - Avoid  
  high radiation area in accordance with the requirements of the radiation work permit and failed
Complacency
  to determine radiological conditions in the work area prior to the start of work.
71124.01 -  
                                                2
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.  


Failure to Adequately Control Work Hours for Covered Personnel
 
Cornerstone       Significance                                     Cross-cutting   Inspection
                                                                    Aspect          Procedure
3
Emergency         Green                                             H.5 - Work      71152 -
Preparedness NCV 05000397/2018003-03                               Management      Problem
                  Opened and Closed                                                 Identification
 
                                                                                    and
                                                                                    Resolution
Failure to Adequately Control Work Hours for Covered Personnel  
The inspectors identified a Green, non-cited violation of 10 CFR 26.205 associated with the
Cornerstone  
licensees failure to adequately schedule and control work hours for personnel subject to work
Significance  
hour controls. Specifically, the licensee failed to appropriately schedule and control work
Cross-cutting  
hours for at least three Chemistry Technicians who were providing covered work as the
Aspect
designated Emergency Response Organization Duty Chemistry Technician as defined by the
Inspection  
Columbia Generating Station Emergency Plan.
Procedure  
                                                3
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.


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
4
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
PLANT STATUS  
returned to rated thermal power on September 22, 2018, and remained at or near rated thermal
power for the remainder of the inspection period.
The plant began the inspection period at 100 percent rated thermal power. On August 4, 2018,  
INSPECTION SCOPES
the reactor unit was down powered to 93 percent to remove the adjustable speed drive from  
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
service for maintenance. On August 5, 2018, the unit was down powered to 74 percent to  
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
recover the adjustable speed drive channel, and the unit was returned to rated thermal power  
their attached revision histories are located on the public website at http://www.nrc.gov/
later that same day. On September 22, 2018, the unit was down powered to 83 percent to  
reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were
perform control rod sequence exchange and turbine bypass valve testing. The unit was  
declared complete when the IP requirements most appropriate to the inspection activity were
returned to rated thermal power on September 22, 2018, and remained at or near rated thermal  
met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
power for the remainder of the inspection period.  
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
INSPECTION SCOPES  
Identification and Resolution. The inspectors reviewed selected procedures and records,
observed activities, and interviewed personnel to assess licensee performance and compliance
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in  
with Commission rules and regulations, license conditions, site procedures, and standards.
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with  
REACTOR SAFETY
their attached revision histories are located on the public website at http://www.nrc.gov/  
71111.01 - Adverse Weather Protection
reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were  
    Seasonal Extreme Weather (1 Sample)
declared complete when the IP requirements most appropriate to the inspection activity were  
    The inspectors evaluated readiness for seasonal extreme weather conditions prior to the
met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection  
    onset of seasonal hot temperatures on July 13 - 17, 2018.
Program - Operations Phase. The inspectors performed plant status activities described in  
71111.04 - Equipment Alignment
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem  
    Partial Walkdown (5 Samples)
Identification and Resolution. The inspectors reviewed selected procedures and records,  
    The inspectors evaluated system configurations during partial walkdowns of the following
observed activities, and interviewed personnel to assess licensee performance and compliance  
    systems/trains:
with Commission rules and regulations, license conditions, site procedures, and standards.  
    (1) low pressure core spray system on July 10, 2018
    (2) high pressure core spray system on July 27, 2018
REACTOR SAFETY  
    (3) control room emergency filter unit, WMA-FN-54A, on August 6, 2018
    (4) reactor core isolation cooling system on August 21, 2018
71111.01 - Adverse Weather Protection  
    (5) standby service water room coolers on September 20, 2018
    Complete Walkdown (1 Sample)
Seasonal Extreme Weather (1 Sample)  
    The inspectors evaluated system configurations during a complete walkdown of the fuel pool
    cooling system on September 28, 2018.
The inspectors evaluated readiness for seasonal extreme weather conditions prior to the  
                                                  4
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.  


71111.05AQFire Protection Annual/Quarterly
 
  Quarterly Inspection (5 Samples)
  The inspectors evaluated fire protection program implementation in the following selected
5
  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
71111.05AQFire Protection Annual/Quarterly  
  (5) Fire Area R-4/2, residual heat removal system B pump room, on September 6, 2018
  Annual Inspection (1 Sample)
Quarterly Inspection (5 Samples)  
  The inspectors evaluated fire brigade performance on September 26, 2018.
71111.07Heat Sink Performance
The inspectors evaluated fire protection program implementation in the following selected  
  Heat Sink (1 Sample)
areas:  
  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
(1) Fire Zones 47-64, transformer yard, on July 9, 2018  
  diesel cooling water heat exchangers, DCW-HX-1A1 and DCW-HX1A2, on
(2) Fire Area RC-1/2, radwaste building 437 feet elevation, on August 6, 2018  
  September 6, 2018.
(3) Fire Area R-3/#, high pressure core spray pump room, on August 16, 2018  
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
(4) Fire Area R-6/2, reactor core isolation cooling pump room, on August 16, 2018  
  Operator Requalification (1 Sample)
(5) Fire Area R-4/2, residual heat removal system B pump room, on September 6, 2018  
  The inspectors observed and evaluated a licensed operator requalification evaluated scenario
  on August 6, 2018.
Annual Inspection (1 Sample)  
  Operator Performance (1 Sample)
  The inspectors observed and evaluated operator performance during residual heat removal
The inspectors evaluated fire brigade performance on September 26, 2018.  
  heat exchanger 1A testing on September 11, 2018.
71111.12Maintenance Effectiveness
71111.07Heat Sink Performance  
  Routine Maintenance Effectiveness (1 Sample)
  The inspectors evaluated the effectiveness of routine maintenance activities associated
Heat Sink (1 Sample)  
  with the following equipment and/or safety significant functions:
  (1) high pressure core spray system planned maintenance, week of July 23, 2018
The inspectors evaluated high pressure core spray diesel generator 3 diesel cooling water  
                                                5
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


71111.13Maintenance Risk Assessments and Emergent Work Control (8 Samples)
 
  The inspectors evaluated the risk assessments for the following planned and emergent
  work activities:
6
  (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
71111.13Maintenance Risk Assessments and Emergent Work Control (8 Samples)  
  (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
The inspectors evaluated the risk assessments for the following planned and emergent  
  (7) green risk for reactor building crane roof operations, week of September 17, 2018
work activities:  
  (8) yellow risk for standby gas treatment train B maintenance, week of September 24, 2018
71111.15Operability Determinations and Functionality Assessments (3 Samples)
(1) yellow risk for reactor core isolation cooling surveillances, week of July 9, 2018  
  The inspectors evaluated the following operability determinations and functionality
(2) orange risk due to high pressure core spray system maintenance, week of July 23, 2018  
  assessments:
(3) green risk during control room envelope test, week of August 6, 2018
  (1) fire pump FP-P-110 failed to start on July 17, 2018
(4) yellow risk for reactor core isolation cooling maintenance, week of August 13, 2018  
  (2) reactor pressure vessel level transmitter MS-LT-61A, leaking fitting, on August 1, 2018
(5) yellow risk for reactor core isolation cooling surveillances on September 14, 2018  
  (3) Division 1 and Division 2, 120 Vac power supply inverter and inverter transfer switch, on
(6) yellow risk for standby service water system B maintenance, September 17-18, 2018  
      August 31, 2018
(7) green risk for reactor building crane roof operations, week of September 17, 2018  
71111.19Post Maintenance Testing (6 Samples)
(8) yellow risk for standby gas treatment train B maintenance, week of September 24, 2018  
  The inspectors evaluated the following post maintenance tests:
  (1) low pressure core spray circuit breaker and mechanism operated cell (MOC) switch on
71111.15Operability Determinations and Functionality Assessments (3 Samples)  
      July 3, 2018
  (2) high pressure core spray maintenance on July 25, 2018
The inspectors evaluated the following operability determinations and functionality  
  (3) reactor pressure vessel level transmitter MS-LT-61A leak repair on August 1, 2018
assessments:  
  (4) adjustable speed drive maintenance on August 4, 2018
  (5) control room emergency filter unit WMA-FN-54A maintenance on August 8, 2018
(1) fire pump FP-P-110 failed to start on July 17, 2018  
  (6) reactor core isolation cooling keepfill pump replacement on August 15, 2018
71111.22Surveillance Testing
(2) reactor pressure vessel level transmitter MS-LT-61A, leaking fitting, on August 1, 2018  
  The inspectors evaluated the following surveillance tests:
  Routine (4 Samples)
(3) Division 1 and Division 2, 120 Vac power supply inverter and inverter transfer switch, on  
  (1) OSP-MS-Q701, Turbine Valve Surveillance, Revision 1, on July 1, 2018
August 31, 2018  
                                                  6
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  


  (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,
7
        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)
(2) OSP-SLC/IST-Q701, Standby Liquid Control Pumps Operability Test, Revision 27, on  
  (1) OSP-LPCS/IST-Q702, LPCS System Operability Test, Revision 42, on July 3, 2018
July 11, 2018  
71114.06Drill Evaluation
  Drill/Training Evolution (1 Sample)
(3) OSP-HPCS/IST-Q701, High Pressure Core Spray Quarterly Surveillance Test,  
  The inspectors evaluated the Emergency Plan drill on September 25, 2018.
Revision 54, on July 25, 2018  
RADIATION SAFETY
71124.01Radiological Hazard Assessment and Exposure Controls
(4) OSP-SW/IST-Q702, Standby Service Water Loop B Operability, Revision 34,on  
  Radiological Hazard Assessment (1 Sample)
September 18, 2018  
  The inspectors evaluated radiological hazards assessments and controls.
  Instructions to Workers (1 Sample)
In-service (1 Sample)  
  The inspectors evaluated worker instructions.
  Contamination and Radioactive Material Control (1 Sample)
(1) OSP-LPCS/IST-Q702, LPCS System Operability Test, Revision 42, on July 3, 2018  
  The inspectors evaluated contamination and radioactive material controls.
  Radiological Hazards Control and Work Coverage (1 Sample)
71114.06Drill Evaluation  
  The inspectors evaluated radiological hazards control and work coverage.
  High Radiation Area and Very High Radiation Area Controls (1 Sample)
Drill/Training Evolution (1 Sample)  
  The inspectors evaluated risk-significant high radiation area and very high radiation area
  controls.
The inspectors evaluated the Emergency Plan drill on September 25, 2018.  
  Radiation Worker Performance and Radiation Protection Technician Proficiency (1 Sample)
  The inspectors evaluated radiation worker performance and radiation protection technician
RADIATION SAFETY  
  proficiency.
                                                7
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.  


71124.03In-Plant Airborne Radioactivity Control and Mitigation
 
  Engineering Controls (1 Sample)
  The inspectors evaluated airborne controls and monitoring.
8
  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.
71124.03In-Plant Airborne Radioactivity Control and Mitigation  
OTHER ACTIVITIES - BASELINE
Engineering Controls (1 Sample)  
71151Performance Indicator Verification (3 Samples)
  The inspectors verified licensee performance indicators submittals listed below:
The inspectors evaluated airborne controls and monitoring.  
  (1)     MS05: Safety System Functional Failures (SSFFs) Sample (06/01/2017 -
          06/30/2018)
Use of Respiratory Protection Devices (1 Sample)  
  (2)     OR01: Occupational Exposure Control Effectiveness Sample (04/01/2017 -
          06/30/2018)
The inspectors evaluated respiratory protection.  
  (3)     PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation
          Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent
Self-Contained Breathing Apparatus for Emergency Use (1 Sample)  
          Occurrences Sample (04/01/2017 - 06/30/2018)
71152Problem Identification and Resolution
The inspectors evaluated the licensees self-contained breathing apparatus program.  
  Annual Follow-up of Selected Issues (2 Samples)
  The inspectors reviewed the licensees implementation of its corrective action program
OTHER ACTIVITIES - BASELINE  
  related to the following issues:
  (1) management of personnel work hours per the Fatigue Rule (10 CFR 26, Subpart I) on
71151Performance Indicator Verification (3 Samples)  
      June 21 - July 31, 2018
  (2) standby service water B pumphouse tornado missile door on August 20, 2018
The inspectors verified licensee performance indicators submittals listed below:
                                              8
(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  


INSPECTION RESULTS
 
                  Licensee-Identified Non-Cited Violation                     71124.01-
                                                                              Radiological Hazard
9
                                                                              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
INSPECTION RESULTS  
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
Licensee-Identified Non-Cited Violation  
conspicuous sign bearing the radiation symbol and the words "CAUTION, RADIATION
71124.01-
AREA."
Radiological Hazard  
  Contrary to the above, from November 9, 2017 to November 13, 2017, the licensee failed to
Assessment and  
post a radiation area with a conspicuous sign bearing the radiation symbol and the words
Exposure Controls  
"CAUTION, RADIATION AREA."
This violation of very low safety significance was identified by the licensee and has been  
  The licensee moved two resin liners with high dose rates into the turbine building truck bay.
entered into the licensee corrective action program and is being treated as a non-cited  
Once the resin liners were in the turbine building truck bay, a high radiation area boundary
violation, consistent with Section 2.3.2 of the Enforcement Policy.  
was posted around them. However, the dose rates outside the truck bay doors were not
Violation: Title 10 CFR 20.1902(a) requires the licensee to post each radiation area with a  
verified. On November 13, 2017, the licensee, while conducting routine area surveys,
conspicuous sign bearing the radiation symbol and the words "CAUTION, RADIATION  
identified an unposted radiation area outside the turbine building truck bay doors, which
AREA."  
resulted from the resin liners inside of the truck bay area. The licensee secured the radiation
   
area and adequately posted it, as required.
Contrary to the above, from November 9, 2017 to November 13, 2017, the licensee failed to  
  Significance/Severity Level: Green
post a radiation area with a conspicuous sign bearing the radiation symbol and the words  
  Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety
"CAUTION, RADIATION AREA."  
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
The licensee moved two resin liners with high dose rates into the turbine building truck bay.
potential for overexposure, and the ability to assess dose was not compromised. For these
Once the resin liners were in the turbine building truck bay, a high radiation area boundary  
reasons, the inspectors concluded that the finding is of very low safety significance (Green).
was posted around them. However, the dose rates outside the truck bay doors were not  
  Corrective Action Reference: AR 00373739
verified. On November 13, 2017, the licensee, while conducting routine area surveys,  
  Failure to Follow Radiologically Controlled Area Procedures
identified an unposted radiation area outside the turbine building truck bay doors, which  
Cornerstone       Significance                     Cross-cutting Aspect   Inspection Procedure
resulted from the resin liners inside of the truck bay area. The licensee secured the radiation  
  Occupational      Green                             H.12 - Avoid           IP 71124.01 -
area and adequately posted it, as required.  
Radiation        NCV 05000397/2018003-01          Complacency            Radiological Hazard
   
Safety            Opened and Closed                                        Assessment and
Significance/Severity Level: Green  
                                                                            Exposure Controls
   
The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification
Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety  
5.4.1(a) when the licensee failed to implement radiation control procedures.
Significance Determination Process, dated August 19, 2008, the inspectors determined the  
                                                  9
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.


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
10
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
Description: On June 1, 2017, a supplemental health physics technician (HPT) entered a  
exit point, in order to obtain survey instruments for the job coverage. The HPT proceeded to
posted locked high radiation area without a functioning electronic dosimeter (ED). Although  
the dress out area and then to the TIP Mezzanine room, where he entered with a survey
the area was posted as a locked high radiation area (LHRA), there were no measured dose  
meter. After about 10 minutes in the room, the HPT looked at his ED and noticed that it was
rates in excess of 1 rem per hour during this entry.  
in pause mode (i.e., not functioning). The HPT informed the worker he was covering, and
they both left the LHRA.
The HPT logged on to Radiation Work Permit (RWP) 30003852 and entered the radiologically  
During the RWP logging process, there was an error when the HPTs ED was being
controlled area (RCA) to cover a job to add additional shielding in the travelling in-core probe  
programmed that went unnoticed. As a result, the HPT was signed-on to the RWP, but the
(TIP) Mezzanine room. The HPT entered the RCA through the HP swing gate near the RCA  
ED was not programmed and active. Because the HPT used the HP swing gate at the RCA
exit point, in order to obtain survey instruments for the job coverage. The HPT proceeded to  
exit rather than the normal access point with electronic turnstiles that verify ED function, this
the dress out area and then to the TIP Mezzanine room, where he entered with a survey  
errant condition was not identified. The swing gate used was intended for HPTs assigned to
meter. After about 10 minutes in the room, the HPT looked at his ED and noticed that it was  
assist workers with contamination alarms at the RCA exit, not as an RCA entry point to
in pause mode (i.e., not functioning). The HPT informed the worker he was covering, and  
perform work or cover a job.
they both left the LHRA.  
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
During the RWP logging process, there was an error when the HPTs ED was being  
ensure that electronic dosimetry is on immediately before entering the RCA. The HPT neither
programmed that went unnoticed. As a result, the HPT was signed-on to the RWP, but the  
used the electronic turnstiles nor checked to see if the ED was on prior to entering the RCA.
ED was not programmed and active. Because the HPT used the HP swing gate at the RCA  
Additionally, licensee Procedure 11.2.7.3 High Radiation Area, Locked High Radiation Area,
exit rather than the normal access point with electronic turnstiles that verify ED function, this  
and Very High Radiation Area Controls, Section 3.2.4 Coverage and Monitoring of Work,
errant condition was not identified. The swing gate used was intended for HPTs assigned to  
paragraph (d), describes conducting a peer-check prior to LHRA entries, by the job coverage
assist workers with contamination alarms at the RCA exit, not as an RCA entry point to  
HPT, to verify that workers are wearing an active ED (i.e., not in pause mode) in the
perform work or cover a job.  
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.
Licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From Radiologically  
Multiple barriers that could have prevented this situation from occurring were either ineffective
Controlled Areas, Section 4.13 Dosimetry and Log-in, paragraph (e), requires workers to  
or not used. Had the error reduction/prevention measures been used, the ED programming
ensure that electronic dosimetry is on immediately before entering the RCA. The HPT neither  
error during RWP log on would have been identified.
used the electronic turnstiles nor checked to see if the ED was on prior to entering the RCA.  
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
Additionally, licensee Procedure 11.2.7.3 High Radiation Area, Locked High Radiation Area,  
incident and coaching on use of the procedures related to the verification of dosimetry and
and Very High Radiation Area Controls, Section 3.2.4 Coverage and Monitoring of Work,  
peer-checking prior to entry into LHRAs.
paragraph (d), describes conducting a peer-check prior to LHRA entries, by the job coverage  
Corrective Action Reference: AR 00366701
HPT, to verify that workers are wearing an active ED (i.e., not in pause mode) in the  
Performance Assessment:
appropriate location on the body. The job coverage HPT checked to see that workers had an  
Performance Deficiency: Failure to follow station procedures for entry into a radiologically
ED appropriately placed, but did not check the ED setpoints or if the ED was active.  
controlled area is a performance deficiency.
                                                10
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.  


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
11
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.
Screening: The inspectors determined the performance deficiency was more than minor  
Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety
because it adversely affected the program and process attribute of the Occupational  
Significance Determination Process, dated August 19, 2008, the inspectors determined
Radiation Safety Cornerstone to ensure the adequate protection of the worker health and  
finding was not related to ALARA planning, did not involve an overexposure or substantial
safety from exposure to radiation from radioactive material during routine civilian nuclear  
potential for overexposure, and the ability to assess dose was not compromised. For these
reactor operation, in that failure to comply with exposure monitoring and radiation protection  
reasons, the inspectors concluded that the finding is of very low safety significance (Green).
controls has the potential to increase dose. Specifically, licensee requirements to control  
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated
workers exposure were not implemented by the HPT.  
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
Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation Safety  
to check to see if the electronic dosimeter was on prior to entering the posted locked high
Significance Determination Process, dated August 19, 2008, the inspectors determined  
radiation area [H.12].
finding was not related to ALARA planning, did not involve an overexposure or substantial  
Enforcement:
potential for overexposure, and the ability to assess dose was not compromised. For these  
Violation: Technical Specification 5.4.1(a) requires, in part, the implementation of written
reasons, the inspectors concluded that the finding is of very low safety significance (Green).  
procedures as outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978,
Section 7(e), Radiation Protection Procedures.
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated  
Contrary to the above, on June 1, 2017, the licensee failed to implement written procedures
with avoiding complacency, in that the individual did not implement appropriate error  
for radiation protection. Specifically, the licensee failed to implement Sections 3.4 and
reduction tools. Specifically, the individual failed to use the electronic turnstile and also failed  
4.1.3(e) of licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From
to check to see if the electronic dosimeter was on prior to entering the posted locked high  
Radiologically Controlled Areas.
radiation area [H.12].  
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Enforcement:  
Failure to Control Workers in a High Radiation Area (>1.0 rem per hour)
Violation: Technical Specification 5.4.1(a) requires, in part, the implementation of written  
Cornerstone           Significance                 Cross-cutting     Inspection Procedure
procedures as outlined in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978,  
                                                    Aspect
Section 7(e), Radiation Protection Procedures.  
Occupational          Green                       H.4 - Teamwork IP 71124.01 - Radiological
Radiation Safety      NCV                                            Hazard Assessment and
Contrary to the above, on June 1, 2017, the licensee failed to implement written procedures  
                      05000397/2018003-02                            Exposure Controls
for radiation protection. Specifically, the licensee failed to implement Sections 3.4 and  
                      Opened and Closed
4.1.3(e) of licensee Procedure GEN-RPP-04, Entry Into, Conduct In, and Exit From  
The inspectors reviewed a self-revealed Green, non-cited violation of Technical Specification
Radiologically Controlled Areas.  
(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
Enforcement Action: This violation is being treated as a non-cited violation, consistent with  
radiological conditions in the work area prior to the start of work.
Section 2.3.2 of the Enforcement Policy.  
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
                                                  11
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  


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
12
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)
reactor building (RX 471) to the 441 foot elevation of the reactor building (RX 441) truck bay  
radiological conditions at various distances from the filter vessel, the use of continuous
to place it in a disposable shield. The unshielded filter vessel radiation levels were 84.3 rem  
radiation protection coverage for fields greater than 0.8 rem per hour, the electronic dosimeter
per hour on contact and 52.8 rem per hour at 30 centimeters. The truck bay was closed and  
(ED) setpoints of 200 millirem for dose and 1.2 rem per hour for dose rate. The brief also
guarded as a locked high radiation area (LHRA) during the filter vessel movement.  
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
At 1:30 pm, a high risk brief was conducted for the filter vessel movement followed by a  
the filter vessel and informed the riggers not to be closer than thirty feet from the unshielded
briefing for the LHRA conditions and restrictions of the radiation work permit (RWP). The  
filter vessel. The riggers asked if the setpoints were high enough and the HPT confirmed that
brief included discussion of information on the RWP including the expected (i.e., calculated)  
they were. At about 2:30 p.m., the two riggers logged on to RWP 3001279.
radiological conditions at various distances from the filter vessel, the use of continuous  
At 2:52 p.m., prior to the movement of the filter vessel from RX 471 to the truck bay on
radiation protection coverage for fields greater than 0.8 rem per hour, the electronic dosimeter  
RX 441, the two riggers entered the truck bay to prepare their work area. Once the filter
(ED) setpoints of 200 millirem for dose and 1.2 rem per hour for dose rate. The brief also  
vessel was in motion from RX 471, the HPT covering the filter vessel movement proceeded to
addressed the use of pre-staged shielding and long handled tools by the riggers. The HPT  
the truck bay to provide radiation protection coverage for the two riggers as the filter vessel
conducting the brief (the job-coverage HPT) stated that an HPT must be present to approach  
was being lowered. The HPT arrived at the guarded truck bay door expecting to find the
the filter vessel and informed the riggers not to be closer than thirty feet from the unshielded  
riggers outside, but the riggers were already inside the truck bay. At 5:38 p.m., the HPT
filter vessel. The riggers asked if the setpoints were high enough and the HPT confirmed that  
entered the truck bay and found the riggers standing about 10 feet away from the shielded
they were. At about 2:30 p.m., the two riggers logged on to RWP 3001279.
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
At 2:52 p.m., prior to the movement of the filter vessel from RX 471 to the truck bay on  
informed by the HPT to immediately leave the area. In order to leave the work in a safe
RX 441, the two riggers entered the truck bay to prepare their work area. Once the filter  
condition, the master rigger signaled the crane operator to stop movement and proceeded to
vessel was in motion from RX 471, the HPT covering the filter vessel movement proceeded to  
exit.
the truck bay to provide radiation protection coverage for the two riggers as the filter vessel  
Subsequent to the event, the master rigger who received the ED alarm stated that he was
was being lowered. The HPT arrived at the guarded truck bay door expecting to find the  
required to be in the truck bay when a load is being lifted out of or lowered into it. He stated
riggers outside, but the riggers were already inside the truck bay. At 5:38 p.m., the HPT  
that he believed he was about 15 feet away from the filter vessel and that the position was as
entered the truck bay and found the riggers standing about 10 feet away from the shielded  
far from the filter vessel as he could be to safely see the load being lowered.
cask with the unshielded filter vessel suspended about 15 feet overhead. At that point, one of  
The inspectors noted that the LHRA technical specification (TS 5.7.2) requires that activities
the riggers ED was alarming, with a dose rate of 1.52 rem per hour. Both riggers were  
in LHRAs shall be controlled by means of an RWP that includes specification of dose rates in
informed by the HPT to immediately leave the area. In order to leave the work in a safe  
the immediate work area and other appropriate radiation protection measures. Additionally,
condition, the master rigger signaled the crane operator to stop movement and proceeded to  
entry into LHRAs shall be made only after dose rates in the area have been determined and
exit.  
entry personnel made knowledgeable of them.
The inspectors also noted that licensee Procedure 11.2.7.3 High Radiation Area, Locked
Subsequent to the event, the master rigger who received the ED alarm stated that he was  
High Radiation Area, and Very High Radiation Area Controls, Section 6.3, Controls to
required to be in the truck bay when a load is being lifted out of or lowered into it. He stated  
Prevent Unplanned or Excessive Personnel Exposures, states in paragraph 6.3.6 that work
that he believed he was about 15 feet away from the filter vessel and that the position was as  
areas with dose rates greater than 1.5 rem per hour require continuous RP coverage as
far from the filter vessel as he could be to safely see the load being lowered.  
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.
The inspectors noted that the LHRA technical specification (TS 5.7.2) requires that activities  
Paragraph 6.3.6 continues by stating that continuous monitoring without the means to control
in LHRAs shall be controlled by means of an RWP that includes specification of dose rates in  
or constrain worker actions should not be used in place of continuous coverage.
the immediate work area and other appropriate radiation protection measures. Additionally,  
                                                12
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.  


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
13
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
Discussions with the licensee revealed that the estimated dose rates specified in the RWP  
the indicated distance and the ED response.
were calculated based on the contact readings of the unshielded filter vessel. However, no  
Effective communication and coordination of this activity could have prevented this situation
confirmatory measurements were made of the RX 441 truck bay to determine the actual dose  
from occurring. The licensees investigation of the ED alarm revealed that rigger workers
rates prior to allowing worker entry. As such, the riggers entered the truck bay without the  
were used to conducting this work activity in a certain manner (i.e., positioning themselves to
required coverage HPT present and without the benefit of a survey of current radiological  
see the load being safely lowered). From the riggers perspective, to ensure safety during the
conditions. The unanticipated ED alarm was an indication that riggers were unaware of the  
lift, they needed to approach the vessel in order to direct the crane operator to land the load
current dose rates in the truck bay and that they were higher than what was calculated given  
safely. The riggers questioned the dose rate setpoint during the LHRA brief, but were told by
the indicated distance and the ED response.
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
Effective communication and coordination of this activity could have prevented this situation  
during the RWP and high risk briefings.
from occurring. The licensees investigation of the ED alarm revealed that rigger workers  
The inspectors concluded that two of the conditions for LHRA entry were not met. The
were used to conducting this work activity in a certain manner (i.e., positioning themselves to  
riggers failed to understand the radiological control requirements, and entered the truck bay
see the load being safely lowered). From the riggers perspective, to ensure safety during the  
(impending LHRA) without continuous RP coverage, contrary to the RWP requirement.
lift, they needed to approach the vessel in order to direct the crane operator to land the load  
Additionally, there was no radiological survey of the truck bay with the filter vessel present to
safely. The riggers questioned the dose rate setpoint during the LHRA brief, but were told by  
validate the calculated estimate so that the riggers could be made knowledgeable of the
the HPT that it was sufficient without understanding the riggers safety perspective. As a  
conditions. Further, as the filter vessel was lowered creating the LHRA conditions, the HPT
result, the riggers failed to understand the radiological restrictions and instructions conveyed  
was not in position to determine the radiological conditions or to control (intervene) in the
during the RWP and high risk briefings.  
activities of the workers.
Corrective Action(s): The individuals involved exited the area and a recovery plan was
The inspectors concluded that two of the conditions for LHRA entry were not met. The  
implemented. The riggers were coached on the requirements to follow the RWP and all
riggers failed to understand the radiological control requirements, and entered the truck bay  
briefing instructions.
(impending LHRA) without continuous RP coverage, contrary to the RWP requirement.
Corrective Action References: ARs 00368063 and 00368480
Additionally, there was no radiological survey of the truck bay with the filter vessel present to  
Performance Assessment:
validate the calculated estimate so that the riggers could be made knowledgeable of the  
Performance Deficiency: The failure to control worker activities and to determine current
conditions. Further, as the filter vessel was lowered creating the LHRA conditions, the HPT  
radiological conditions prior to entry into a locked high radiation area was a performance
was not in position to determine the radiological conditions or to control (intervene) in the  
deficiency.
activities of the workers.  
Screening: The inspectors determined the performance deficiency was more than minor
because it adversely affected the program and process attribute of the Occupational
Corrective Action(s): The individuals involved exited the area and a recovery plan was  
Radiation Safety Cornerstone to ensure the adequate protection of the worker health and
implemented. The riggers were coached on the requirements to follow the RWP and all  
safety from exposure to radiation from radioactive material during routine civilian nuclear
briefing instructions.  
reactor operation. Specifically, the failure to comply with exposure control measures in a
locked high radiation area has the potential for increased dose.
Corrective Action References: ARs 00368063 and 00368480  
Significance: Using Inspection Manual Chapter 0609, Appendix C, Occupational Radiation
Safety Significance Determination Process, dated August 19, 2008, the finding was not an
Performance Assessment:  
ALARA finding, there was no overexposure or substantial potential for overexposure, and the
                                                13
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  


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
14
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
licensees ability to assess dose was not compromised. Therefore the safety significance of  
effectively coordinate their activities in the locked high radiation area during the evolution
the finding would be very low (Green).  
[H.4].
Enforcement:
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated  
Violation: Technical Specification 5.7.2, High Radiation Areas with Dose Rates Greater
with teamwork, in that individuals and work groups did not communicate and coordinate their  
than 1.0 rem/hour (at 30 cm from the radiation source), paragraph (b) requires, in part, that
activities within and across organizational boundaries to ensure nuclear safety is maintained.
activities shall be controlled by means of a radiation work permit that includes specification of
Specifically, the riggers and the health physics technician failed to effectively communicate  
appropriate radiation protection measures, and paragraph (e) requires, in part, that entry shall
their perspectives and expectations on safety for this high risk evolution and also failed to  
be made only after dose rates in the area have been determined and entry personnel are
effectively coordinate their activities in the locked high radiation area during the evolution  
knowledgeable of them.
[H.4].  
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
Enforcement:  
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
Violation: Technical Specification 5.7.2, High Radiation Areas with Dose Rates Greater  
knowledgeable of them. Specifically, two workers entered the reactor building truck bay (a
than 1.0 rem/hour (at 30 cm from the radiation source), paragraph (b) requires, in part, that  
locked high radiation area) and were present as a filter vessel with a dose rate of 52.8 rem
activities shall be controlled by means of a radiation work permit that includes specification of  
per hour at 30 cm was being lowered into it. Prior to arrival of the health physics technician,
appropriate radiation protection measures, and paragraph (e) requires, in part, that entry shall  
required by the radiation work permit for continuous radiation protection coverage for work in
be made only after dose rates in the area have been determined and entry personnel are  
whole body dose rates greater than 800 millirem per hour, one of the workers received a dose
knowledgeable of them.  
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
Contrary to the above, on June 20, 2017, during work in a high radiation area with dose rates  
the area while the load was being lowered, the workers were uninformed of the radiological
greater than 1.0 rem per hour, the licensee failed to control activities by means of a radiation  
conditions.
work permit that included specification of appropriate radiation protection measures, and  
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
entry was made prior to dose rates in the area having been determined and entry personnel  
Section 2.3.2 of the Enforcement Policy.
knowledgeable of them. Specifically, two workers entered the reactor building truck bay (a  
Failure to Adequately Control Work Hours for Covered Personnel
locked high radiation area) and were present as a filter vessel with a dose rate of 52.8 rem  
Cornerstone           Significance                               Cross-cutting     Report
per hour at 30 cm was being lowered into it. Prior to arrival of the health physics technician,  
                                                                  Aspect            Section
required by the radiation work permit for continuous radiation protection coverage for work in  
Emergency             Green NCV                                   H.5 - Work        71152
whole body dose rates greater than 800 millirem per hour, one of the workers received a dose  
Preparedness          NCV 05000397/2018003-03                     Management
rate alarm of 1.52 rem per hour. Because a health physics technician was not present to  
                      Opened and Closed
determine the actual dose rates (in contrast to calculated dose rates that had been briefed) in  
The inspectors identified a Green, non-cited violation of 10 CFR 26.205 associated with the
the area while the load was being lowered, the workers were uninformed of the radiological  
licensees failure to adequately schedule and control work hours for personnel subject to work
conditions.  
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
Enforcement Action: This violation is being treated as a non-cited violation, consistent with  
designated Emergency Response Organization (ERO) Duty Chemistry Technician as defined
Section 2.3.2 of the Enforcement Policy.  
by the Columbia Generating Station Emergency Plan.
                                                  14
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.


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
15
appeared to have worked 84 hours 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
Description: In reviewing licensee documentation relative to work hour controls in accordance  
this apparent issue to the licensee to determine if the Chemistry staff member was completing
with the requirements in 10 CFR 26, Subpart I (10 CFR 26.205), for various workgroups  
covered work during the period, and whether a waiver had been processed to allow this staff
across the station, the inspectors noted an example where a Chemistry staff member  
member to exceed the work hour requirement in accordance with Section 3.6 of
appeared to have worked 84 hours in a 7-day period on at least one occasion in  
SWP-FFD-004.
September 2017. The inspectors noted that this was in excess of the limits established in the  
In response to the inspectors questions, the licensee determined that a work hour controls
licensees Procedure SWP-FFD-004, Work Hour Controls, Revision 9, Section 3.4.4, which  
waiver had not been processed for the particular instance noted by the inspectors. Further,
states in part The following controls apply to covered workers (Definition 5.9) regardless of  
the licensee noted that the one staff member exceeded 72 hours in a 7-day period on three
unit status No more than 72 work hours in any 7 day period. The inspectors identified  
separate occasions in late August through late September 2017. The same staff member did
this apparent issue to the licensee to determine if the Chemistry staff member was completing  
not receive the 34 hours off in a 9-day period two times in that period, and also did not have
covered work during the period, and whether a waiver had been processed to allow this staff  
the required average days off over a 6-week cycle twice during the period. (These additional
member to exceed the work hour requirement in accordance with Section 3.6 of  
controls are further requirements described in Section 3.4.4 of SWP-FFD-004.) As part of an
SWP-FFD-004.  
extent of condition review, the licensee identified a total of 11 examples where Chemistry staff
In response to the inspectors questions, the licensee determined that a work hour controls  
members worked hours in excess of the controls described in SWP-FFD-004, Section 3.4.4,
waiver had not been processed for the particular instance noted by the inspectors. Further,  
and no waiver was processed, in the period of review of July 2017 through April 2018. The
the licensee noted that the one staff member exceeded 72 hours in a 7-day period on three  
licensees review found the following contributed to the issues identified:
separate occasions in late August through late September 2017. The same staff member did  
    1. The supervisors lack of verification and validation of the data being input into the work
not receive the 34 hours off in a 9-day period two times in that period, and also did not have  
        hours tracking software.
the required average days off over a 6-week cycle twice during the period. (These additional  
    2. A breakdown in communication between the supervisor and technicians as to whether
controls are further requirements described in Section 3.4.4 of SWP-FFD-004.) As part of an  
        or not a work hours waiver was necessary, and the actions required of the parties
extent of condition review, the licensee identified a total of 11 examples where Chemistry staff  
        involved to request the waivers.
members worked hours in excess of the controls described in SWP-FFD-004, Section 3.4.4,  
    3. General lack of familiarity by the Chemistry staff with Procedure SWP-FFD-04 and the
and no waiver was processed, in the period of review of July 2017 through April 2018. The  
        requirements associated with obtaining a waiver.
licensees review found the following contributed to the issues identified:  
    4. Inadequate validation of assumptions by the Chemistry staff members that a waiver
1. The supervisors lack of verification and validation of the data being input into the work  
        would cover them to exceed specific work hour/fatigue rules for an extended period of
hours tracking software.  
        time.
Also, the inspectors reviewed additional work hour records for other departments whose staff
2. A breakdown in communication between the supervisor and technicians as to whether  
were subject to work hour/fatigue rules and could involve staff transitioning between covered
or not a work hours waiver was necessary, and the actions required of the parties  
and non-covered work activities. Specifically, records from Radiation Protection, Operations
involved to request the waivers.  
(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
3. General lack of familiarity by the Chemistry staff with Procedure SWP-FFD-04 and the  
departments did not identify any additional discrepancies/violations of the work hour/fatigue
requirements associated with obtaining a waiver.  
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.
4. Inadequate validation of assumptions by the Chemistry staff members that a waiver  
                                                15
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.  


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
16
        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
Corrective Actions: The licensee entered the identified violations of the work hours rules into  
        implement a process for an independent check of the Chemistry Department data
the corrective action program, and initiated the following corrective actions:  
        entered into the work hours tracking software in accordance with SWP-FFD-04.
1. Creation of a job aid to assist Chemistry staff/supervisors in implementing work hours  
Corrective Action References: AR 00379991, AR 00381017, and AR 00381551
and overtime controls, in support of data entry into the station tracking software.  
Performance Assessment:
Performance Deficiency: The licensees failure to control work hours for Chemistry staff
2. Additional training to supervisors and staff with job-related functions in the work hours  
covered by the requirements of 10 CFR 26.205, was determined to be a performance
tracking software and the impacts of SWP-FFD-04.  
deficiency.
Screening: The performance deficiency is more than minor because it is associated with the
3. Revision of Procedure CI-1.14, Chemistry Department FFD Fatigue Management, to  
ERO [emergency response organization] readiness attribute of the Emergency Preparedness
implement a process for an independent check of the Chemistry Department data  
cornerstone and adversely affects the cornerstone objective that the licensee is capable of
entered into the work hours tracking software in accordance with SWP-FFD-04.  
implementing adequate measures to protect the health and safety of the public in the event of
Corrective Action References: AR 00379991, AR 00381017, and AR 00381551  
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
Performance Assessment:  
Columbia Generating Station Emergency Plan, and therefore were subject to the work hour
Performance Deficiency: The licensees failure to control work hours for Chemistry staff  
controls to manage worker fatigue as described in 10 CFR 26, Subpart I, as implemented by
covered by the requirements of 10 CFR 26.205, was determined to be a performance  
licensee Procedure SWP-FFD-004. As such, the licensee emergency response personnel
deficiency.  
(on-shift chemistry staff) may not have been capable of implementing adequate measures to
Screening: The performance deficiency is more than minor because it is associated with the  
protect the health and safety of the pubic if they were excessively fatigued.
ERO [emergency response organization] readiness attribute of the Emergency Preparedness  
Significance: The finding was evaluated using Inspection Manual Chapter 0609, Appendix B,
cornerstone and adversely affects the cornerstone objective that the licensee is capable of  
Emergency Preparedness Significance Determination Process, dated September 22, 2015,
implementing adequate measures to protect the health and safety of the public in the event of  
and was determined to be of very low safety significance (Green). The finding had a very low
a radiological emergency. Specifically, the Chemistry staff members in question were  
safety significance because it was a failure to comply with NRC requirements, was not
providing covered work as the designated ERO Duty Chemistry Technician as defined by the  
associated with a risk significant planning standard function, and was not a loss of planning
Columbia Generating Station Emergency Plan, and therefore were subject to the work hour  
standard function. The finding was not a loss of planning standard function because there
controls to manage worker fatigue as described in 10 CFR 26, Subpart I, as implemented by  
was not a loss of emergency response organization minimum staffing (on-shift Chemistry).
licensee Procedure SWP-FFD-004. As such, the licensee emergency response personnel  
Specifically, this finding was determined to be associated with a degraded planning standard
(on-shift chemistry staff) may not have been capable of implementing adequate measures to  
function in that the process to ensure that the on-shift chemistry technician was staffed with a
protect the health and safety of the pubic if they were excessively fatigued.  
non-fatigued individual was challenged on several occasions during the period of July through
Significance: The finding was evaluated using Inspection Manual Chapter 0609, Appendix B,  
October 2017.
Emergency Preparedness Significance Determination Process, dated September 22, 2015,  
Cross-cutting Aspect: The finding had a human performance cross-cutting aspect associated
and was determined to be of very low safety significance (Green). The finding had a very low  
with work management, in that the organization did not implement a process of planning,
safety significance because it was a failure to comply with NRC requirements, was not  
controlling, and executing work activities such that nuclear safety is the overriding priority,
associated with a risk significant planning standard function, and was not a loss of planning  
including the identification and management of risk commensurate to the work. Specifically,
standard function. The finding was not a loss of planning standard function because there  
the licensee failed to establish a verification/validation process for the Chemistry supervisors
was not a loss of emergency response organization minimum staffing (on-shift Chemistry).
                                                16
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  


   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
17
  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,
to provide reasonable assurance that the technician work hours were accurately entered and  
  10 CFR 26.205 states, in part, that individuals who perform duties identified in § 26.4(a)(1)
tracked [H.5].  
  through (a)(5) shall be subject to the requirements of 10 CFR 26, Subpart I, and that
Enforcement: Title 10 CFR 26.4(a) states in part that "All persons who are granted  
  licensees shall calculate, schedule, and control the work hours of individuals who are subject
unescorted access to nuclear power reactor protected areas by the licensees in § 26.3(a) ...  
  to that section.
and perform the following duties shall be subject to a [fitness for duty] program..." and lists  
  Contrary to the above, from July through October 2017, for at least three individuals
one function as "(2) Performing health physics or chemistry duties required as a member of  
  performing chemistry duties required as a member of the onsite emergency response
the onsite emergency response organization minimum shift complement." Further,  
  organization minimum shift complement (to which 10 CFR 26.205 applies), the licensee failed
10 CFR 26.205 states, in part, that individuals who perform duties identified in § 26.4(a)(1)  
  to assure that work hours were scheduled and controlled. In response to this issue, the
through (a)(5) shall be subject to the requirements of 10 CFR 26, Subpart I, and that  
  licensee developed actions to ensure that work hours for chemistry technicians were
licensees shall calculate, schedule, and control the work hours of individuals who are subject  
  adequately controlled including development of a user aid, additional training, and
to that section.  
  independent validation of information entered into the work hours tracking software. This
Contrary to the above, from July through October 2017, for at least three individuals  
  issue does not represent an immediate safety concern because at the time of discovery no
performing chemistry duties required as a member of the onsite emergency response  
  personnel were in excess of work hour requirements, and the licensee took actions to prevent
organization minimum shift complement (to which 10 CFR 26.205 applies), the licensee failed  
  occurrence in the future.
to assure that work hours were scheduled and controlled. In response to this issue, the  
  Enforcement Action: This violation is being treated as a non-cited violation, consistent with
licensee developed actions to ensure that work hours for chemistry technicians were  
  Section 2.3.2 of the Enforcement Policy.
adequately controlled including development of a user aid, additional training, and  
EXIT MEETINGS AND DEBRIEFS
independent validation of information entered into the work hours tracking software. This  
On September 19, 2018, the inspectors presented the radiation protection baseline inspection
issue does not represent an immediate safety concern because at the time of discovery no  
results to Mr. R. Schuetz, Vice President, Operations, Mr. A. Javorik, Vice President,
personnel were in excess of work hour requirements, and the licensee took actions to prevent  
Engineering, and other members of the licensee staff. The inspectors verified no proprietary
occurrence in the future.  
information was retained or documented in this report. On October 3, 2018, the inspectors held
Enforcement Action: This violation is being treated as a non-cited violation, consistent with  
a follow-up telephonic exit with Mr. R. Schuetz, Vice President, Operations, Mr. D. Brown,
Section 2.3.2 of the Enforcement Policy.  
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
EXIT MEETINGS AND DEBRIEFS  
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
On September 19, 2018, the inspectors presented the radiation protection baseline inspection  
significance. On October 15, 2018, the inspectors held a follow-up telephonic exit with Mr. R.
results to Mr. R. Schuetz, Vice President, Operations, Mr. A. Javorik, Vice President,  
Schuetz, Vice President, Operations, Mr. D. Brown, General Manager, Plant Operations, and
Engineering, and other members of the licensee staff. The inspectors verified no proprietary  
other members of the licensee staff to communicate a change in the characterization of the
information was retained or documented in this report. On October 3, 2018, the inspectors held  
inspection results.
a follow-up telephonic exit with Mr. R. Schuetz, Vice President, Operations, Mr. D. Brown,  
On October 15, 2018, the inspectors presented the quarterly resident inspector inspection
General Manager, Plant Operations, and other members of the licensee staff to clarify the  
results to Mr. A. Javorik, Vice President, Engineering, and other members of the licensee staff.
significance of an additional radiation protection issue discussed during the inspection, but not  
The inspectors verified no proprietary information was retained or documented in this report.
presented in the on-site exit meeting stated above. The additional issue was a minor violation,  
                                                17
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.  


DOCUMENTS REVIEWED
 
71111.01 - Adverse Weather Protection
  Action Requests
18
        370257                 379411               369975               370063
        382228                 380608               380616               380310
        382752                 382753               382754
 
  Work Orders
DOCUMENTS REVIEWED  
      29137990               29137991               02098735
  Procedures
71111.01 - Adverse Weather Protection  
(Number)                       Title                                           Revision
   
SOP-COLDWEATHER-OPS           Cold Weather Operations                         030
Action Requests  
SOP-HOTWEATHER-OPS             Hot Weather Operations                           006
370257  
SOP-WARMWEATHER-               Warm Weather Operations                         015
379411  
OPS
369975  
SOP-SW-SPRAY                   Standby Service Water Spray Header Operations   000
370063  
  Miscellaneous
382228  
  Documents
380608  
(Number)                 Title                                                 Revision
380616  
ME-02-92-43             Calculation for Room Temperature for DG Building and   012
380310  
                          R and W and SW Pumphouse Under Design Basis
382752  
                          Accident Conditions
382753  
ME-02-92-41             Calculation for Ultimate Heat Sink Analysis           007
382754  
ME-02-85-79             Calculation for Spray Pond Temperature Transient       003
   
                          Without Sprays
71111.04 - Equipment Alignment
Work Orders  
  Procedures
29137990  
(Number)                   Title                                               Revision
29137991  
1.3.29                     Locked Valve Checklist                             079
02098735  
ABN-FPC-LOSS               Loss of Fuel Pool Cooling                           016
   
ABN-HPCS-DEPRESS           HPCS Recovery Following Depressurization From       003
                            Keep Fill Failure
Procedures  
SOP-FPC-ASSIST-ALT         Alternate Fuel Pool Cooling Assist                 011
(Number)  
SOP-FPC-OPS                 Fuel Pool Cooling and Cleanup Operations           007
Title  
SOP-FPC-SHUTDOWN           FPC Shutdown                                       003
Revision  
SOP-FPC-SPC                 FPC Suppression Pool Operations                     011
SOP-COLDWEATHER-OPS  
SOP-FPC-SST                 FPC Skimmer Surge Tank Operations                   005
Cold Weather Operations  
SOP-FPC-START               Fuel Pool Cooling Start                             006
030  
SOP-HPCS-LV                 HPCS Valve and Breaker Lineup                       004
SOP-HOTWEATHER-OPS  
SOP-HPCS-M102               HPCS Valve Lineup                                   004
Hot Weather Operations  
SOP-HPCS-STBY               Placing HPCS in Standby Status                     003
006  
                                              18
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  


  Procedures
 
(Number)                     Title                                               Revision
   
SOP-LPCS-STBY               Placing LPCS in Standby Status                       002
19
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
Procedures  
  Drawings
(Number)  
(Number)             Title                                                       Revision
Title  
M519                 Reactor Core Isolation Cooling System Flow Diagram           102
Revision  
M520                 HPCS and LPCS Systems Reactor Building Flow Diagram         104
SOP-LPCS-STBY  
M200-103           Low Pressure Core Spray System Isometric Diagram             017
Placing LPCS in Standby Status
RCIC-656-5.8         Suction from Suppression Pool to RCIC Pump RCIC-P-1         017
002  
RCIC-659-1.2       RCIC Pump to RCIC Vessel                                     011
SOP-LPCS-LU  
71111.05AQFire Protection Annual/Quarterly
LPCS Valve and Breaker Lineup
  Action Requests
003  
382268               382272                   383100               385162
SOP-RCIC-LU  
  Procedures
RCIC Valve and Breaker Lineup  
(Number)                   Title                                                 Revision
004  
1.3.10                     Plant Fire Protection Program Implementation           034
SOP-RCIC-STBY  
1.3.10A                   Control of Ignition Sources                           017
Placing RCIC in Standby Status  
1.3.10B                   Active Fire System Operability and Impairment Control 015
011  
1.3.10C                   Control of Transient Combustibles                     020
SOP-SW-M103  
1.9.13                     Transformer Yard Access and Controls                   019
HPCS Service Water Valve Position Verification  
FPP-1.7                   Fire Tour Implementation                               006
024  
PFP-MN-XMR-YD-MISC         PFP-MN-XMR-YD-MISC Bldgs                               006
   
PFP-RB-422                 Reactor 422                                           006
Drawings  
PFP-RW-437-452             RADWASTE 437-452                                       005
(Number)  
SFI-26                     Fire Tour                                             002
Title  
SWP-FPP-01                 Nuclear Fire Protection Program                       008
Revision  
  Miscellaneous
M519  
  Documents                                                                    Revision or
Reactor Core Isolation Cooling System Flow Diagram  
(Number)         Title                                                       Date
102  
FP-02-85-03     Calculation for FSAR Update Including Fire Loading in       010
M520  
                  General Room and Floor Areas
HPCS and LPCS Systems Reactor Building Flow Diagram  
                  Fire Brigade Training Drill Cycle 18-1 Crew E Critique     January 18, 2018
104  
                  Fire Brigade Training Drill Cycle 18-3 Crew F Critique     May 31, 2018
M200-103  
                  Fire Brigade Training Drill Cycle 18-4 Crew F Critique     August 23, 2018
Low Pressure Core Spray System Isometric Diagram  
                  Fire Brigade Unannounced Drill 18-001 Crew A Critique       October 1, 2018
017  
71111.07Heat Sink Performance
RCIC-656-5.8  
  Action Requests
Suction from Suppression Pool to RCIC Pump RCIC-P-1  
384028                 384029
017  
                                              19
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  


  Work Orders
 
02100975           02123992                 02126970             02126200
02126970           02100975                 02080164             02105918
20
02023553           02106204                 02084429             02106205
  02084430
   
  Procedures
 
(Number)           Title                                                     Revision
Work Orders  
1.5.13             Preventive Maintenance Optimization Living Program         040
02100975  
8.4.54             Thermal Performance Monitoring for DCW-HX-1A1 and         010
02123992  
                    DCW-HX-1A2
02126970  
8.4.63             Thermal Performance Monitoring of DCW-HX-1C               010
02126200  
  Drawings
02126970  
(Number)           Title                                                     Revision
02100975  
M512-2             Flow Diagram Diesel Oil & Miscellaneous Systems           037
02080164  
M524-1             Flow Diagram Standby Service Water System Reactor,         138
02105918  
                    Radwaste, D.G. Bldgs and Yard
02023553  
  Miscellaneous
02106204  
  Documents
02084429  
(Number)           Title                                                     Revision
02106205  
02E22-07,54,3       HPCS Diesel Generator                                     012
02084430
ME-02-92-243       Calculation for DCW-HX-1C Design Performance               003
                    Requirements
MOT-HX-1-1         Heat Exchangers                                           012
   
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
   
  Procedures
Procedures  
(Number)           Title                                                     Revision
(Number)  
1.3.1               Operating Policies, Programs and Programs                 127
Title  
5.1.1               RPV Control                                               021
Revision  
5.2.1               Primary Containment Control                               027
1.5.13  
5.3.1               Secondary Containment Control                             020
Preventive Maintenance Optimization Living Program  
13.1.1             Classifying the Emergency                                 049
040  
OI-09               Operations Standards and Expectation                       070
8.4.54  
OSP-RCIC/IST-Q701   RCIC Operability Test                                     061
Thermal Performance Monitoring for DCW-HX-1A1 and  
  Miscellaneous
DCW-HX-1A2  
  Documents
010
(Number)           Title                                                     Revision
8.4.63  
                    Crew D Evaluated Scenario Cycle 18-4, 4.0 Critique         000
Thermal Performance Monitoring of DCW-HX-1C  
                    Summary
010  
LR002425           Cycle 18-4 Evaluated Scenario                             000
   
                                          20
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  


71111.12Maintenance Effectiveness
 
  Action Requests
369836             372031                   366178                 366220
21
368573             369803                   363774                 334979
336819             324924                   340031                 343726
351952             362949                   364950                 366788
 
  Procedures
71111.12Maintenance Effectiveness  
(Number)             Title                                                     Revision
   
1.5.11               Maintenance Rule Program                                   015
Action Requests  
OSP-SW/IST-Q703     HPCS Service Water Operability                             027
369836  
SOP-HPCS-CST/SP     HPCS CST and Suppression Pool Operations                   014
372031  
SYS-4-22             Maintenance Rule Program                                   014
366178  
71111.13Maintenance Risk Assessments and Emergent Work Control
366220  
  Action Requests
368573  
337916             382706
369803  
  Work Orders
363774  
02098551           02097647                 02121918               02132528
334979  
02095968           02101599                 02130842
336819  
  Procedures
324924  
(Number)             Title                                                     Revision
340031  
1.3.76               Integrated Risk Management                                 049
343726  
1.3.76               Integrated Risk Management                                 050
351952  
1.3.76               Integrated Risk Management                                 051
362949  
1.3.83               Protected Equipment Program                               026
364950  
8.4.42               Thermal Performance Monitoring of RHR-HX-1A and           012
366788  
                      RHR-HX-1B
   
ESP-RCIC-X301       RCIC Turbine Speed Monitor - CC                           004
Procedures  
ISP-RCIC-Q901       RCIC Isolation on RCIC Steam Supply Flow High             024
(Number)  
                      DIV 1-CFT/CC
Title  
ISP-RCIC-Q903       RCIC Isolation on RCIC Steam Supply Flow High             019
Revision  
                      DIV 2-CFT/CC
1.5.11  
OSP-RCIC/IST-Q701   RCIC Operability Test                                     061
Maintenance Rule Program  
OSP-RCIC/IST-Q702   RCIC Valve Operability Test                               043
015  
OSP-RCIC-M101       RCIC Fill, Flow Controllers, and Valve Lineup Verification 017
OSP-SW/IST-Q703  
SOP-SW-DRAIN         Standby Service Water Drain                               008
HPCS Service Water Operability  
WCI-1               Unit Coordinator BPA Duties                               008
027  
                                          21
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  


71111.15Operability Determinations and Functionality Assessments
 
  Action Requests
382900               382882                   383452               383440
22
383703               383698                   366967               383232
383236               383054                   383057
  Work Orders
 
02130891             02131541                 02131542             02131543
71111.15Operability Determinations and Functionality Assessments  
02131544             02131545                 02131593
   
  Procedures
Action Requests  
(Number)             Title                                                   Revision
382900  
1.10.11               Technical Assessments Supporting Reportability and     002
382882  
                      Reportability Evaluations
383452  
OPEX-01               Operating Experience Program Implementation Manual     009
383440  
SWP-OPX-01           Operating experience Program                           000
383703  
  Drawings
383698  
(Number)             Title                                                   Revision
366967  
E-504-1               Vital One Line Diagram                                 006
383232  
71111.19Post Maintenance Testing
383236  
  Action Requests
383054  
265493               382110                   382674               382784
383057  
PER 205-0024         382426                   374860
   
  Work Orders
02093978             02116384                 02089875             02089987
02089995             02095010                 02096336             02130586
02128698             02108899                 02122111             02122391
  02129438
  Procedures
Work Orders  
(Number)             Title                                                   Revision
02130891  
10.2.3               Pump Packing Replacement and Adjustment                 013
02131541  
10.2.54               Pump Testing                                           009
02131542  
10.24.248             Visual Examination of Electronic Components, Circuit   000
02131543  
                      Boards, and Solder Joints
02131544  
10.25.105             Motor Control Center and Switchgear Maintenance         035
02131545  
10.25.13             Westinghouse Medium Voltage Circuit Breakers           034
02131593  
ISP-MS-X312, DIV 1   Channel A Isolation Actuation on Level 1 and Reactor   006
   
                      Level 2 - Channel Calibration
OSP-ELEC-S703         HPCS Diesel Generator Semi-Annual Operability Test     062
Procedures  
                                            22
(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  


  Procedures
 
(Number)               Title                                                   Revision
   
OSP-LPCS/IST-Z702       LPCS System Operability Test                             042
23
OSP-WMA-B701           Control Room Ventilation System A Pressurization Flow   020
                        Test
SOP-RCIC-FILL           RCIC Fill and Vent                                       017
 
  Miscellaneous
Procedures  
Documents (Number)     Title                                                   Revision
(Number)  
                        Channel A Isolation Actuation on Reactor Level 1 and     006
Title  
                        Reactor Level 2 - Channel Calibration
Revision  
71111.22Surveillance Testing
OSP-LPCS/IST-Z702  
  Action Requests
LPCS System Operability Test  
353783                 358013                   359298                 360016
042  
360021                 353864                   382785
OSP-WMA-B701  
  Work Orders
Control Room Ventilation System A Pressurization Flow  
02090774               02094071               02098015               02114831
Test  
02122412               02117436               02114670               02130842
020
02103225               02101890
SOP-RCIC-FILL  
  Procedures
RCIC Fill and Vent  
(Number)             Title                                                     Revision
017  
4.601.A3             601.A3 Annunciator Panel Alarms                           027
   
DBD 316               Design Specification for Low Pressure Core Spray           011
Miscellaneous  
EWD-15E-014           Reactor Protection System Trip System B Sensor Relays     005
Documents (Number)  
IST-4                 Inservice Testing Program Plan Fourth Ten-Year             001
Title  
                      Inspection Interval
Revision  
OSP-MS-S701           Turbine Valve Surveillance                                 001
OSP-RPS-Q401         Turbine Throttle Valve Closure CFT                         002
Channel A Isolation Actuation on Reactor Level 1 and  
OSP-RPS-S401         Turbine Throttle Valve Closure CFT                         000
Reactor Level 2 - Channel Calibration  
OSP-SLC/IST-Q701     Standby Liquid Control Pumps Operability Test             026
006
SD000192             System Description Low Pressure Core Spray (LPCS)         013
SWP-IST-01           ASME Inservice Testing                                     003
71111.22Surveillance Testing  
71114.06Drill Evaluation
   
  Procedures
Action Requests  
(Number)             Title                                                     Revision
353783  
1.3.1                 Operating Policy, Programs, and Practices                 127
358013  
5.1.1                 RPV Control                                               021
359298  
5.2.1                 Primary Containment Control                               027
360016  
5.3.1                 Secondary Containment Control                             020
360021  
13.1.1               Classifying the Emergency                                 049
353864  
                                              23
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  


  Procedures
 
(Number)           Title                                                     Revision
13.10.1             Control Room Operation and Shift Manager Duties           035
24
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
Procedures  
13.5.1             Local, Protected Area, or Site Evacuation                 029
(Number)  
13.9.1             Environmental Field Monitoring Operations                 045
Title  
13.10.9             Operations Support Center Manager and Staff Duties         049
Revision  
13.11.1             EOF Manager Duties                                         044
13.10.1
13.13.1             Reentry Operations                                         010
Control Room Operation and Shift Manager Duties
13.13.3             Intermediate Phase MUDAC Operations                       018
035
13.13.4             After Action Reporting                                     010
13.10.2
13.14.9             Drill and Exercise Program                                 029
TSC Manager Duties
OI-09               Operations Standards and Expectations                     070
035
71124.01Radiological Hazard Assessment and Exposure Controls
13.2.1
  Procedures
Emergency Exposure Levels, Protective Action Guides
(Number)           Title                                                     Revision
022
GEN-RPP-04         Entry Into, Conduct In, and Exit From Radiologically       032
13.2.2
                    Controlled Areas
Determining Protective Actions
HPI-0.19           Radiation Protection Standards and Expectations           018
020
SWP-RPP-01         Radiation Protection Program                               016
13.4.1
PPM 11.2.7.1       Area Posting                                               043
Emergency Notifications
PPM 11.2.13.1       Radiation and Contamination Surveys                       040
043
PPM 11.2.24.1       Radiation Protection Work Routines                         035
13.5.1
PPM 11.2.7.3       High Radiation Area, Locked High Radiation Area, and Very 042
Local, Protected Area, or Site Evacuation
                    High Radiation Area Controls
029
PPM 11.2.14.4       Procurement, Receipt, Control and Leak Testing of         024
13.9.1
                    Radioactive Sealed Sources and Devices
Environmental Field Monitoring Operations
PPM 11.2.13.8       Airborne Radioactivity Surveys                             019
045
PPM 11.2.14.9       Control and Labeling of Radioactive Material               021
13.10.9
PPM 1.11.15         Control of Radioactive Material                           013
Operations Support Center Manager and Staff Duties
PPM 6.1.1           Spent Fuel Pool Inventory                                 010
049
  Audits and Self-
13.11.1
Assessments
EOF Manager Duties
(Number)           Title                                                 Date
044
AR-SA 374280       Occupational Exposure Control Effectiveness           May 25, 2018
13.13.1
AR-SA 374283       Performance Indicator Verification PR-01               June 7, 2018
Reentry Operations
AR-SA 375035-06     Radiological Hazard Assessment and Exposure           July 9, 2018
010
                    Controls
13.13.3
AU-RP/RW-17         QA Audit: Radiation Protection and Process Control     December 18,
Intermediate Phase MUDAC Operations
                    Programs                                              2017
018
                                            24
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  


  Action Requests
 
366701                   367332                 368222                 368480
368651                   369180                 370737                 373739
25
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
Action Requests  
M-20180830-4           M-20180905-4         M-20180910-1         M-20180910-1
366701  
M-20180912-5
367332  
  Air Samples
368222  
        875805                 875816               895915                   907092
368480  
  Radiation Work
368651  
Permits           Title                                                             Revision
369180  
30001279         R23 WW Packaging TTDF-34 Filter *LHRA* *High Risk* STK           001
370737  
30003852         R23 RX/WW , RP Surveys & Job Coverage **LHR**                     000
373739  
30003986         2017 RW 487 WEA Fan Rem/Replace Pre-Filter *HR*High
379010  
                                                                                    001
379636  
                  Contam*
381763  
30004141         2018 RX 501 TIP Room/TIP Drive Room **HRA**                       000
381764  
30004147         2018 TG 501 W. Labyrinth PMs & Surveillance ***LHRA***           000
   
30004200         2018 RW 437 Waste Processing NUPAC Cage **LHRA**                 001
Radiation Surveys  
  Miscellaneous
M-20170601-11  
Documents                                                                       Revision
M-20170620-11  
(Number)                 Title                                                   or Date
M-20170620-12  
                        CGS Radioactive Source Inventory - Non-Exempt           August 21,
M-20170624-1  
                                                                                  2018
M-20170813-3  
374337                 Information for NSTS Annual Inventory Reconciliation     January 15,
M-20170830-4  
                                                                                  2018
M-20170906-5  
W/O 2119710             HSP-SSC-0801 Sealed Source Leakage Verification         April 9, 2018
M-20180717-3  
30001279               High Risk Plan for R23 WW Packaging                     003
M-20180721-4  
                        TTDF-34 Filter
M-20180807-3  
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
M-20180807-5  
  Procedures
M-20180830-1  
(Number)                 Title                                                     Revision
M-20180830-4  
                                              25
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  


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
26
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
 
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-
Audits and Self-
Assessments
Assessments  
(Number)         Title                                                   Date
(Number)  
AR-SA 301868-03 Respiratory Protection Self-Assessment                   April 14, 2017
Title  
AR-SA 00357502   71124.03 Self-Assessment                                 March 5,
Date  
                                                                          2018
AR-SA 301868-03  
AU-RP/RW-17     QA Audit: Radiation Protection and Process Control       December 18,
Respiratory Protection Self-Assessment  
                Programs                                                2017
April 14, 2017  
Action Requests
AR-SA 00357502  
371385               347601                 347688                 347689
71124.03 Self-Assessment  
377412
March 5,  
Radiation Work
2018  
Permits (Number) Title                                                   Revision
AU-RP/RW-17  
30004034         R23 TG 501 Sandblasting Tent Work                       000
QA Audit: Radiation Protection and Process Control  
30004161         2018 RW 437 / 452 / 467 High Rad Work ***HR***           002
Programs
30004152         2018 RW 487 Chemistry Lab High Radiation Areas *HR*     001
December 18,  
SCBA Records
2017  
(Number)         Title                                                   Date
67833           Calibration Certificate                                 August 13,
Action Requests  
                                                                          2018
371385  
67958           Calibration Certificate                                 August 13,
347601  
                                                                          2018
347688  
67993           Calibration Certificate                                 August 15,
347689  
                                                                          2018
377412  
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,
Radiation Work  
                                                                        2016
Permits (Number)  
                                          26
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  


  In Place Filter
 
Testing Records
Work Order       Title                                                   Date
27
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
In Place Filter  
02083458         MSP-WMA-B103 - WMA-FU-54A - Carbon Adsorber Test August 3,
Testing Records  
                                                                            2016
Work Order  
02083554         AMA-CF-52 Replace Carbon, Inspect                       March 8, 2018
Title  
                  (FILTR-1-1-9.3)
Date  
  Miscellaneous
02074207  
Documents (Number) Title                                                   Date
MSP-WMA-B102 - WMA-FU-54B - HEPA Filter Test  
OK 581518           Certificate of Analysis                               June 20, 2018
September 22,  
SA-V-99/35         Analysis of Air Samples for Breathing Air             July 26, 2018
2016  
W/O 2123630         Fire Brigade Station Inventory TG 501 and MCR         September 26,
02081424  
                                                                            2018
MSP-WMA-B101 - WMA-FU-54A - HEPA Filter Test  
71151Performance Indicator Verification
August 3,  
  Procedures
2016  
  (Number)           Title                                                 Revision
02083458  
  SWP-OPS-02         Safety Function Determination Program                 007
MSP-WMA-B103 - WMA-FU-54A - Carbon Adsorber Test August 3,  
71152Problem Identification and Resolution
2016  
  Action Requests
02083554  
  379991               381017                 381551                 379120
AMA-CF-52 Replace Carbon, Inspect
  379504               307821                 009924                 383966
(FILTR-1-1-9.3)  
  383951               280168                 383773
March 8, 2018
  Work Orders
   
  02128878             02128879               02059398
Miscellaneous  
  Procedures
Documents (Number) Title  
  (Number)           Title                                                     Revision
Date  
  1.5.13             Preventive Maintenance Optimization Living Program       039
OK 581518  
  EC 17325           Evaluation for Service Water (SW) Pumphouse Swinging     000
Certificate of Analysis  
                      Door B-DOOR-G200 Supporting SW Operability with the
June 20, 2018  
                      Designated Shear Pins Not Engaged
SA-V-99/35  
  SWP-FFD-03         Fatigue Management                                       005
Analysis of Air Samples for Breathing Air  
  SWP-FFD-04         Work Hour Controls                                       009
July 26, 2018  
                                            27
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  


Drawings
 
(Number)       Title                                                       Revision
AED-ARC-A555   Door Schedule Sheet 3                                       030
28
CVI-DWG-210-23 Spec. Section 8L Exterior Missile Doors G100 & G200         003
Miscellaneous
Documents                                                             Revision
 
(Number)       Title                                                   or Date
Drawings  
              Schedule Report for Radiation Protection               May 10, 2018
(Number)  
              (8/2017 - 10/2017, 1/2018 - 2/2018)
Title  
              Schedule Report for Chemistry                           June 20, 2018
Revision  
              (8/2017 - 10/2017, 1/2018 - 2/2018)
AED-ARC-A555  
              Schedule Report for Operations                         June 4, 2018
Door Schedule Sheet 3  
              (8/2017 - 10/2017, 1/2018 - 2/2018)
030  
              Schedule Report for Security                           May 9, 2018
CVI-DWG-210-23  
              (8/2017 - 10/2017, 1/2018 - 2/2018)
Spec. Section 8L Exterior Missile Doors G100 & G200  
              Plant General Manager & Department Manager Work         July 6, 2017
003  
              Hour Reviews per SWP-FFD-04 (January 1 to June
              30, 2017)
Miscellaneous  
              Plant General Manager & Department Manager Work         January 30,
Documents  
              Hour Reviews per SWP-FFD-04 (July 1 to December         2018
(Number)  
              30, 2017)
Title  
AED-SPC-08L   Design Specification for Division 8 Section 8L Exterior 002
              Missile Doors G100 and G200
Revision 
                                      28
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


                            The following items are requested for the
 
                            Occupational Radiation Safety Inspection
                                            at Columbia
                          Dates of Inspection: 09/10/2018 to 09/14/2018
29
                                    Integrated Report 2018003
Enclosure 2
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
The following items are requested for the  
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled
Occupational Radiation Safety Inspection  
1-A, applicable organization charts in file/folder 1-B, etc.
at Columbia  
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
Dates of Inspection: 09/10/2018 to 09/14/2018  
information while writing the report.
In addition to the corrective action document lists provided for each inspection procedure listed
Integrated Report 2018003  
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
Inspection areas are listed in the attachments below.
entrance meeting.
If more than one inspection procedure is to be conducted and the information requests appear
Please provide the requested information on or before Wednesday, August 22, 2018.  
to be redundant, there is no need to provide duplicate copies. Enter a note explaining in which
file the information can be found.
Please submit this information using the same lettering system as below. For example, all  
If you have any questions or comments, please contact John O'Donnell at 817-200-1441 or via
contacts and phone numbers for Inspection Procedure 71124.01 should be in a file/folder titled  
e-mail at John.ODonnell@nrc.gov.
1-A, applicable organization charts in file/folder 1-B, etc.  
                        PAPERWORK REDUCTION ACT STATEMENT
  This letter does not contain new or amended information collection requirements subject
If information is placed on ims.certrec.com, please ensure the inspection exit date entered is at  
    to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
least 30 days later than the onsite inspection dates, so the inspector will have access to the  
      collection requirements were approved by the Office of Management and Budget,
information while writing the report.  
                                  control number 3150-0011.
                                                  29                                    Enclosure 2
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.  


1. Radiological Hazard Assessment and Exposure Controls (71124.01) and
 
  Performance Indicator Verification (71151)
  Date of Last Inspection:         May 26, 2017
30
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
1.  
  appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
Radiological Hazard Assessment and Exposure Controls (71124.01) and  
  Engineering, and Emergency Protection. (Recent pictures are appreciated.)
Performance Indicator Verification (71151)  
C. Copies of audits, self-assessments, LARs, and LERs written since the last inspection
  date, related to this inspection area
Date of Last Inspection:  
D. Procedure indexes for the radiation protection procedures and other related disciplines.
May 26, 2017  
E. Please provide procedures related to the following areas noted below. Additional
  procedures may be requested by number after the inspector reviews the procedure
A.  
  indexes.
List of contacts and telephone numbers for the Radiation Protection Organization Staff  
  1.   Radiation Protection Program
and Technicians. Please include area code and prefix. If work cell numbers are  
  2.   Radiation Protection Conduct of Operations, if not included in #1.
appropriate, then please include them as well.  
  3.   Personnel Dosimetry
B.  
  4.   Posting of Radiological Areas
Applicable organization charts including position or job titles. Please include as  
  5.   High Radiation Area Controls
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),  
  6.   RCA Access Controls and Radiation Worker Instructions
Engineering, and Emergency Protection. (Recent pictures are appreciated.)  
  7.   Conduct of Radiological Surveys
C.  
  8.   Radioactive Source Inventory and Control
Copies of audits, self-assessments, LARs, and LERs written since the last inspection  
  9.   Fuel Pool Inventory Access and Control
date, related to this inspection area  
F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
D.  
  committed to relative to this program. Please include the revision and/or date for the
Procedure indexes for the radiation protection procedures and other related disciplines.  
  commitment and where this may be located in your current licensing basis documents.
E.  
G. Please provide a summary list of corrective action documents (including corporate and
Please provide procedures related to the following areas noted below. Additional  
  sub-tiered systems) since the last inspection date.
procedures may be requested by number after the inspector reviews the procedure  
  1. Initiated by the radiation protection organization
indexes.
  2. Assigned to the radiation protection organization
1. Radiation Protection Program  
  NOTE: These lists should include a description of the condition that provides sufficient
2. Radiation Protection Conduct of Operations, if not included in #1.  
            detail that the inspector can ascertain the regulatory impact, the significance level
3. Personnel Dosimetry  
            assigned to the condition, the status of the action (e.g., open, working, closed,
4. Posting of Radiological Areas  
            etc.) and the search criteria used. Please provide in document formats which are
5. High Radiation Area Controls  
            sortable and searchable so that inspector can quickly and efficiently determine
6. RCA Access Controls and Radiation Worker Instructions  
            appropriate sampling and perform word searches, as needed. (Excel
7. Conduct of Radiological Surveys  
            spreadsheets are the preferred format.) If codes are used, please provide a
8. Radioactive Source Inventory and Control  
            legend for each column where a code is used.
9. Fuel Pool Inventory Access and Control  
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
F.  
  list of work activities greater than 1 rem, scheduled during the outage with the dose
Please provide a list of NRC Regulatory Guides and NUREGs that you are currently  
                                              30
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  


  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
31
  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.
estimate for the work activity.) Please include the radiological risk assigned to each  
K. Please provide a list of air samples taken to verify engineering controls and a separate
activity.  
  list for breathing air samples in airborne radiation areas or high contamination work
I.  
  areas. Please include the RWP the breathing air sampling supports.
Provide a summary of any changes to plant operation that have resulted or could result  
L. Please provide the current radioactive source inventory, listing all radioactive sources
in a significant new radiological hazard. For each change, please provide the  
  that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,
assessment conducted on the potential impact and any monitoring done to evaluate it.  
  Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and
J.  
  current activity (w/assay date), and storage location for each applicable source.
List of active radiation work permits and those specifically planned for the on-site  
M. The last two leak test results for the Category 1 or 2 radioactive sources and any other
inspection week.  
  radioactive source(s) that have failed its leak test within the last two years. Provide any
K.  
  applicable condition reports.
Please provide a list of air samples taken to verify engineering controls and a separate  
N. A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate
list for breathing air samples in airborne radiation areas or high contamination work  
  dose rates (Contact / @ 30cm)
areas. Please include the RWP the breathing air sampling supports.  
O. A list of radiological controlled area entries greater than 100 millirem, since the last
L.  
  inspection date. The list should include the date of entry, some form of worker
Please provide the current radioactive source inventory, listing all radioactive sources  
  identification, the radiation work permit used by the worker, dose accrued by the worker,
that are required to be leak tested. Indicate which sources are deemed 10 CFR Part 20,  
  and the electronic dosimeter dose alarm set-point used during the entry (for
Appendix E, Category 1 or Category 2. Please indicate the radioisotope, initial and  
  Occupational Radiation Safety Performance Indicator verification in accordance with
current activity (w/assay date), and storage location for each applicable source.  
  IP 71151).
M.
P. A list describing VHRAs and TS HRAs (> 1 rem/hour) that are current and historical.
The last two leak test results for the Category 1 or 2 radioactive sources and any other  
  Include their current status, locations, and control measures.
radioactive source(s) that have failed its leak test within the last two years. Provide any  
Q. Temporary effluent monitor locations and calibrations (AMS-4) used to monitor normally
applicable condition reports.  
  closed doors or off-normal release points (e.g., equipment hatch or turbine heater bay
N.  
  doors). Include any CRs associated with this monitoring or instrumentation.
A list of all non-fuel items stored in the spent fuel pools, and if available, their appropriate  
                                              31
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.  


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
32
  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)
3.
B. Applicable organization charts including position or job titles. Please include as
In-Plant Airborne Radioactivity Control and Mitigation (71124.03)  
  appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),
  Engineering, and Emergency Protection. (Recent pictures are appreciated.)
Date of Last Inspection:  
C. Copies of audits, self-assessments, vendor, or NUPIC audits for contractor support
March 4, 2016  
  (SCBA), LARs, and LERs, written since the date of last inspection related to:
  1. Installed air filtration systems
A.  
  2. Self-contained breathing apparatuses
List of contacts and telephone numbers for the following areas. Please include area  
D. Procedure index for Radiation Protection, Maintenance, I&C, and other related
code and prefix. If work cell numbers are appropriate, then please include them as well.  
  disciplines.
1. Respiratory Protection Program  
  1. Use, operation, and maintenance of installed and portable continuous air monitors
2. Self-contained breathing apparatus
  2. Use operation, and maintenance of installed air filtration units for breathing air (e.g.,
3. Ventilation Systems for breathing air (not effluents)
      for airline respirators, emergency ventilation systems).
B.  
  3. Use, operation, and maintenance of temporary air filtration units and vacuums
Applicable organization charts including position or job titles. Please include as  
  4. Respiratory protection and other related disciplines
appropriate for your site, Site Management, RP, Chemistry, Maintenance (I&C),  
E. Please provide specific procedures related to the following areas noted below.
Engineering, and Emergency Protection. (Recent pictures are appreciated.)  
  Additional Specific Procedures may be requested by number after the inspector reviews
C.  
  the procedure indexes.
Copies of audits, self-assessments, vendor, or NUPIC audits for contractor support  
  1. Respiratory protection program
(SCBA), LARs, and LERs, written since the date of last inspection related to:
  2. Use and maintenance of self-contained breathing apparatuses
1. Installed air filtration systems  
  3. Air quality testing for SCBAs or other compressed or supplied air systems
2. Self-contained breathing apparatuses
  4. Use and testing of installed plant air cleaning systems used for breathing air, such as
D.  
      control room emergency ventilation, technical support center, operations support
Procedure index for Radiation Protection, Maintenance, I&C, and other related  
      center, and emergency operations facility (When containment purge is not used as
disciplines.  
      an effluent system, then it can be considered as a breathing air system used prior to
1. Use, operation, and maintenance of installed and portable continuous air monitors  
      outages during RCS breach and flood up.)
2. Use operation, and maintenance of installed air filtration units for breathing air (e.g.,  
F. Please provide a list of NRC Regulatory Guides and NUREGs that you are currently
for airline respirators, emergency ventilation systems).  
  committed to relative to this program. Please include the revision and/or date for the
3. Use, operation, and maintenance of temporary air filtration units and vacuums  
  commitment and where this may be located in your current licensing basis documents.
4. Respiratory protection and other related disciplines  
G. Please provide a summary list of corrective action documents (including corporate and
E.  
  sub-tiered systems) written since the date of last inspection, related to the Airborne
Please provide specific procedures related to the following areas noted below.
  Monitoring program including:
Additional Specific Procedures may be requested by number after the inspector reviews  
  1. In-plant continuous air monitors (installed or portable), not effluent monitors
the procedure indexes.
  2. Self-contained breathing apparatus
1. Respiratory protection program  
  3. Air Cleaning systems (not effluent)
2. Use and maintenance of self-contained breathing apparatuses  
  4. Respiratory protection program
3. Air quality testing for SCBAs or other compressed or supplied air systems  
      NOTE: These lists should include a description of the condition that provides
4. Use and testing of installed plant air cleaning systems used for breathing air, such as  
                                            32
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  


      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
33
      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.
sufficient detail that the inspector can ascertain the regulatory impact, the  
H. List of SCBA qualified personnel - reactor operators and emergency response
significance level assigned to the condition, the status of the action (e.g., open,  
  personnel. For the control room individuals, please indicate their normally scheduled
working, closed, etc.) and the search criteria used. Please provide in document  
  shift and specific mask size, as well as note if they are permitted/fitted for eyewear.
formats which are sortable and searchable so that inspector can quickly and  
I. Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant
efficiently determine appropriate sampling and perform word searches, as needed.  
  for use since the date of last inspection.
(Excel spreadsheets are the preferred format.) If codes are used, please provide a  
J. SCBA training and qualification records for control room operators, shift supervisors,
legend for each column where a code is used.  
  STAs, and OSC personnel for the last year.
H.  
  A selection of personnel may be asked to demonstrate proficiency in donning, doffing,
List of SCBA qualified personnel - reactor operators and emergency response  
  and performance of functionality check for respiratory devices.
personnel. For the control room individuals, please indicate their normally scheduled  
K. List of respirators (available for use) by type (APR, SCBA, PAPR, etc.), manufacturer,
shift and specific mask size, as well as note if they are permitted/fitted for eyewear.  
  model, quantity by size, and location. Be prepared to demonstrate that these respirators
I.  
  are NIOSH certified.
Inspection records for self-contained breathing apparatuses (SCBAs) staged in the plant  
  Include in the list the specific quantities and sizes staged for emergency use.
for use since the date of last inspection.  
L. Provide one-line drawings of the supplied air and air cleaning systems identified in E.3
J.  
  and E.4 above.
SCBA training and qualification records for control room operators, shift supervisors,  
M. List work activities requiring respiratory protection and the type of respirator used
STAs, and OSC personnel for the last year.  
  (include PAPRs).
A selection of personnel may be asked to demonstrate proficiency in donning, doffing,  
N. Please have available, on-site, the records demonstrating the compressed air for SCBAs
and performance of functionality check for respiratory devices.  
  or supplied air for a breathing air system is at least Grade D.
K.  
                                              33
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
  ML18304A362  
  SUNSI Review           ADAMS:           Non-Publicly Available         Non-Sensitive Keyword:
  SUNSI Review  
  By:       MSH           Yes  No        Publicly Available             Sensitive     NRC-002
ADAMS:  
OFFICE         SRI:DRP/A     RI:DRP/A       DRS/IPAT         DRS/EB1       DRS/EB2       DRS/PSB2
Non-Publicly Available  
NAME           GKolcum       LMerker       GMiller         TFarnholtz     GWerner       HGepford
Non-Sensitive  
SIGNATURE       GJK           LNM           GBM             TRF           GEW           HJG
Keyword:
DATE           10/29/18       10/29/18       10/29/18         10/29/2018     10/29/2018   10/29/2018
By:  
OFFICE         DRS/OB         SPE:DRP/A     BC:DRP/A
MSH  
  NAME           VGaddy         RAlexander     MHaire
Yes     No
  SIGNATURE       vgg           RDA           /MSH
  Publicly Available  
  DATE           10/29/18       10/29/2018     10/31/18
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
}}
}}

Latest revision as of 10:00, 5 January 2025

NRC Integrated Inspection Report 05000397/2018003
ML18304A362
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 10/31/2018
From: Mark Haire
NRC/RGN-IV/DRP
To: Sawatzke B
Energy Northwest
References
IR 2018003
Download: ML18304A362 (36)
v • d • e


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

Enterprise Identifier: I-2018-003-0030

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.

3

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

7

(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

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