IR 05000397/2006010
| ML061210473 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/26/2006 |
| From: | Clay Johnson NRC/RGN-IV/DRP/RPB-A |
| To: | Parrish J Energy Northwest |
| References | |
| IR-06-010 | |
| Download: ML061210473 (13) | |
Text
April 26, 2006J. (Mail Drop 1023)Chief Executive Officer Energy Northwest
P.O. Box 968 Richland, WA 99352-0968SUBJECT: COLUMBIA GENERATING STATION - NRC SUPPLEMENTAL INSPECTIONREPORT 05000397/2006010
Dear Mr. Parrish:
On March 23, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed a supplementalinspection pursuant to Inspection Procedure 95001 at your Columbia Generating Station. Theenclosed inspection report documents the inspection findings, which were discussed at the exit meeting on March 23, 2006, with Mr. D. Atkinson, Vice-President Nuclear Generation, andother members of your staff. The licensee's readiness for supporting the supplemental inspection was completed February 28, 2006.The NRC performed this supplemental inspection to assess your evaluation associated withevents reported as safety system functional failures between May 2003 and April 2004. Theevents included two reports concerning shutdown cooling isolations which your staff withdrew.
Had these reports remained in the SSFF Performance Indicator, it would have changed colors from Green to White. The inspection concluded that the common cause evaluation addressed by PerformanceEvaluation Request (PER) 206-0119 adequately defined and understood root causes and corrective actions were appropriately addressed.Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document system(ADAMS). ADAMS is accessible from the NRC Web site at http://www.gov/reading-rm/adams.html (The Public Electronic Reading Room).
Sincerely,
/RA/
Claude E. Johnson, ChiefProject Branch A Division of Reactor Projects Energy Northwest- 2 -Docket: 50-397License: NPF-21
Enclosure:
NRC Inspection Report 05000397/2006010
REGION IV Docket:50-397License:NPF-21 Report:05000397/2006010 Licensee:Energy Northwest Facility:Columbia Generating StationLocation: Richland, Washington Dates:March 13-23, 2006 Inspectors:T. O. McKernon, Senior Operations Engineer, Operations Branch,Division of Reactor Safety (DRS)Approved By:C. E. Johnson, Chief, Project Branch A, DRP ATTACHMENT:Supplemental Information Enclosure
SUMMARY OF FINDINGS
IR 05000397/2006010; 03/13/2006 - 03/23/2006; Columbia Generating Station. InspectionProcedure 95001 Supplemental Inspection.The report covered a 1-1/2 week period of inspection by a region-based inspector. Noviolations were identified. The significance of most findings is indicated by their color (Green,
White, Yellow, or Red) using Inspection Manual Chapter 0609, "Significance Determination Process." Findings for which the significance determination process does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program foroverseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.
Cornerstone: Mitigating SystemsThe U.S. Nuclear Regulatory Commission performed this supplemental inspection toassess the licensee's evaluation associated with two shutdown cooling events that thelicense withdrew as reports from the safety system functional failure performanceindicator tracking system and other events reported between May 2003 and April 2004. Had the two reports not been withdrawn, the performance indicator would have changed
from Green to
- White.
During this supplemental inspection, performed in accordance with Inspection Procedure 95001, the inspector determined that the licensee identifiedweak human performance as a common thread in their common cause analysis. For the eight events evaluated, the licensee adequately determined root and contributingcauses and established corrective actions to prevent recurrence.
Enclosure-1-Report Details 01
INSPECTION SCOPE
The U.S. Nuclear Regulatory Commission (NRC) performed this supplementalinspection to assess the licensee's evaluation associated with safety system functionalfailure performance indicator (PI) that, except for two retracted reports, would have crossed the Green-White threshold between May 2003 and April 2004.The primary cause of the potential Green-White threshold PI crossing was due to twoshutdown cooling system isolations during May and June 2003. The first shutdowncooling isolation event occurred as a result of maintenance workers disconnecting wiring from a wrong relay, which caused inboard isolation Valve RHR-V-9 to close. Thesecond shutdown cooling isolation event occurred during performance of SurveillanceProcedure TSPCONT/ISOL-B501, when operators depressed the manual pushbutton for the Train B nuclear steam supply shutoff system (NSSSS) inititation logic. A reviewof the subject PI indicated that, when these two events were considered along with five other SSFFs during the reporting period, the PI would have crossed the Green-White threshold. The licensee retracted the two shutdown system isolation reports andprovided them as "info-only." This supplemental inspection was focused on the events occurring between May 2003and April 2004, whether root causes and contributing causes were understood, whetherextent of conditions and extent of causes were identified, and whether sufficientcorrective actions were taken to prevent recurrence.2EVALUATION OF INSPECTION REQUIREMENTS 02.01Problem Identification a.
Determination of who (i.e., licensee, self-revealing, or NRC) identified the issue andunder what conditionsThis supplemental inspection focused on events which took place between May 2003and April 2004. Two of the events were loss of shutdown cooling events, two events were related to inoperability of high pressure core spray system (HPCS), and two eventswere inoperability of the reactor core isolation cooling system (RCIC). All six events,reviewed and documented by the licensee in Performance Evaluation Request (PER)206-0119, were self-revealing.
b. Determination of how long the issue existed and prior opportunities for identification
The two shutdown cooling isolation events were caused by human error and proceduralinadequacy. In the first instance, maintenance workers erroneously lifted an electrical lead from the wrong relay which caused Valve RHR-V-9 to close, resulting in a trip ofthe running shutdown cooling pump. In the second instance, during performance of Surveillance Procedure TSP-CONT/ISOL-B501 operators depressed the manual Train B logic pushbutton for the NSSSS, which caused containment isolation Valve RHR-V-8 to
-2-close, resulting in a trip of the 'A' shutdown cooling pump. The first inoperability eventof HPCS occurred when operators through human performance error lost suction to the HPCS-P-1, resulting in tripping the pump. The second occurrence happened when the HPCS waterleg piping was inadvertently isolated during maintenance work. The first instance of RCIC system inoperability occurred in August 2003 when a battery cell in theDivision 1 250 Vdc Battery E-B2-1 failed to meet its Technical Specification parameter requirements. The second instance occurred in February 2004, when control power was lost to reactor pressure vessel injection Valve RCIC-V-13. The loss of control power was caused by the failure of a normally energized relay coil.In most of the instances discussed above the Licensee had no prior opportunities foridentification of the issue. However, in the second occurrence of shutdown cooling isolation, the operators had the opportunity to identify potential plant impacts and makepeople aware during pre-job briefs. Further, this was not the first time the surveillanceTSP-CONT/ISOL-B501 had been performed and any procedural weaknesses could have been resolved in the past.
c.
Determination of the plant-specific risk consequences (as applicable) and complianceconcerns associated with the eventsThe two loss of shutdown cooling events were considered of low risk significance in thatshutdown cooling was returned to service within a short time (10-12 minutes). The two events were documented in NRC Inspection Report 05000397/2003005 and a noncitedviolation was issued with very low safety significance (Green). The two RCIC inoperability events were documented in NRC Inspection Reports 05000397/2003006and 05000397/2004002. One of the events was classified as noncited violation forfailure to follow procedures, which had very low safety significance (Green). The HPCS inoperability event occurred in October 2003, was documented in NRC InspectionReport 05000397/2004004, and identified no compliance issues. 02.02Root Cause and Extent of Condition Evaluations a. Evaluation of method(s) used to identify root causes and contributing causesThe licensee used a common cause analysis approach to evaluating all eventsdocumented in PER 206-0119. Since, at the time of the events, the corrective actionprogram Procedure SWP-CAP-02 allowed for resolving extent of condition reviews by means of the apparent cause process, extent of condition reviews were generally weak.
The inspector determined that the licensee followed it's procedural guidance.
b. Level of detail of the Common Cause EvaluationThe Licensee's common cause evaluation was thorough and identified a commonthread of weak human performance as a root cause to a majority of the events reviewed in PER 206-0119. The evaluation indicated that the licensee understood the rootcauses and contributing causes of risk significant performance issues of events between May 2003 and April 2004.
-3- c.Consideration of prior occurrences of the problem and knowledge of prior operatingexperienceThe licensee's evaluation included a review to ascertain if similar problems related to theloss of shutdown cooling had been reported. The licensee determined that a similarevent occurred in 2001 but was not reported. The inspector's review of historical information (i.e., licensee event reports, inspection reports, PERs, condition reports)indicated that the licensee was consistent in not reporting the loss of shutdown coolingoccurrences as long as the Technical Specification action requirements (compliance standards) were satisfied.
d. Consideration of potential common causes and extent of condition reviewsThe licensee evaluated their prior reviews and root cause analyses for the eventscontained in PER 206-0119 and determined that their extent of condition reviews weregenerally weak. Further, extent of cause reviews were not completed because the corrective action program procedure guidance, at the time, did not require the reviews for resolution of problems through the apparent cause process. In January 2004, the licensee revised the corrective action program Procedure SWP-CAP-02 to require root cause analyses for all reported events. The inspector reviewed the PER 206-0119 associated reports, evaluations, and subsequent common cause evaluation and determined that the licensee had determined that, during the time period, humanperformance errors were the major contributor to risk significant performance issues. In many instances, the licensee identified weak procedural guidance, poor pre-job briefings, or inadequate operator's understanding of plant impact from surveillanceprocedure performance as root or contributing causes. The inspector concluded that the licensee's evaluations of events during the period were more comprehensive for equipment related events than human performance related events.02.03Corrective Actions a. Appropriateness of corrective action(s)The licensee's corrective actions were sufficient to address the events' root and contributing causes and to prevent recurrence. Since January 2004, no additional examples of performance issues were reported via PIs that resulted in crossing a new PI threshold, nor were there any new or additional examples of performance issues identified during this inspection which were safety significant. In addition, the inspector reviewed other licensee event reports since January 2004 andsampled fifty condition reports from a total population of 1500. The inspector agreed with the licensee's evaluations and disposition of the related corrective actions. As part of the licensee's corrective actions, Energy Northwest had industry experts and industry organizations review the shutdown cooling isolation events and bench marked other plants. These reviews supported Energy Northwest's position that the shutdown coolingisolation events were nonreportable. The licensee communicated this information and reiterated their nonreportable position in letter G02-04-102, dated May 26, 2004.
-4-Since May 2004 the licensee and NRC has had a number of meetings andcommunications regarding the difference of professional opinion related to reporting loss of shutdown cooling events.Energy Northwest maintains the position that loss of shutdown cooling events are nonreportable as safety system functional failures (SSFFs) as long as the TechnicalSpecification action times can be met. The NRC contends that such events should bereported under the SSFF performance indicators.The NRC will pursue potential clarification to NUREG-1022 to clarify the reportingcriteria in FY 07.
b. Prioritization of corrective actionsThe inspector did not identify any specific methods utilized to prioritize the specifiedcorrective actions based on risk significance or regulatory compliance. However, no examples of inappropriate prioritization were noted. The inspector considered the prioritization of the established corrective actions to be consistent with risk consequences.
c. Establishment of schedule for implementing and completing the corrective actionsThe licensee established adequate schedules for completion of the specified correctiveactions. As appropriate, some corrective actions were scheduled in conjunction with refueling outages while others were more short term, such as procedure revisions or training updates. The inspector did not identify any specific concerns with the scheduling of completion for corrective actions.
d. Establishment of quantitative or qualitative measures of success for determining theeffectiveness of the corrective actions to prevent recurrenceThe licensee established effectiveness reviews for each of the evaluations reviewed. For example, effectiveness reviews for the evaluation associated with the February 2004 loss of control power to the RCIC system and subsequent inoperability. Correctiveactions included replacement of the failed relay, thermography on 43 other installed normally-energized relays, long-term actions to replace normally-energized relays in dc control circuity, development of preventive maintenanc e tasks to replace relays in dcswitchgear, and periodic reviews of existing and collection and submittal of operating experiences. The inspector interviewed station personnel involved in this effort and determined that progress was being made implementing the corrective actions. The evaluation specified the method, attributes, success criteria, and timing of actions in specific terms. The inspector identified no concerns in this area.
-5-3 MANAGEMENT MEETINGSExit Meeting SummaryOn March 23, 2006, the inspector (T. McKernon) presented the inspection results toMr. D. Atkinson, Vice President, Nuclear Generation, and members of his staff who acknowledged the findings. The inspector confirmed that proprietary information was provided or examined during the inspection and returned at the conclusion of the inspection.ATTACHMENT:
SUPPLEMENTAL INFORMATION
AttachmentA-1SUPPLEMENTAL INFORMATIONATTACHMENTSPersons Contacted
- J. Arbuckle, Quality and Corrective Action
- J. Bekhazi, Manager, Maintenance
- D. Brown, Operations Support Manager
- D. Coleman, Manager, Regulatory Affairs
- G. Cullen, Licensing Supervisor
- K. Engbarth, Corrective Action Program Manager
- C. King, Manager, Chemistry
- T. Lynch, Plant General Manager
- R. Torres, Manager, Quality and Corrective ActionDocuments ReviewedLicensee Event Reports1996-002-002004-004-002003-006-002004-005-00
2003-007-002004-008-00
2003-008-002005-001-00
2003-009-002005-002-00
2003-010-002005-003-00
2003-012-002005-004-00
2004-001-002005-005-00
2004-002-00PERS299-0871203-2645299-1162203-3111
299-1021203-3684
299-0882203-3975
299-1336203-4124
200-1051204-0570
200-1078205-0424
201-1171205-0428
203-1861205-0429
203-2411206-0119Action Request
7153
ProceduresSWP-CAP-02, Corrective Action Program, Revision 3, 3/31/05
AttachmentA-2Condition Reports2-04-000942-04-00174
2-04-00285
2-04-00350
2-04-00738
2-04-01006
2-04-01355
2-04-01458
2-04-01717
2-04-01827
2-04-02360
2-04-02626
2-04-02650
2-04-02850
2-04-02906
2-04-02921
2-04-03123
2-04-03379
2-04-04560
2-04-05718
2-04-06178
2-04-06642
2-04-06987
2-05-00110
2-05-00677
2-05-00720
2-05-01166
2-05-01771
2-05-01945
2-05-027112-05-028692-05-02966
2-05-03343
2-05-03487
2-05-03537
2-05-03570
2-05-03587
2-05-03625
2-05-03722
2-05-03902
2-05-04103
2-05-04222
2-05-04235
2-05-04559
2-06-00144