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Significance:
Mar 31, 2008
Identified By: NRC
Item Type: NCV NonCited Violation
Failure to Control Design of Residual Heat Removal Shutdown Cooling Suction Header Bypass Line
Green. An NRC identified noncited violation of 10 CFR Part 50, Appendix B, Criterion III, “Design Control,” was identified for Energy Northwest’s failure to adequately review a design change to the facility in 1994. The design change installed a bypass line around a residual heat removal pump shutdown cooling suction header isolation valve to bleed pressure from the header. This would be done in the event of leakage past the shutdown cooling suction header reactor coolant system pressure isolation valves. The design change failed to consider the thermal effects of introducing hot reactor coolant system water into the residual heat removal shutdown cooling suction header at a design maximum flowrate of 0.75 gpm. As a result, operation of the bypass line would have resulted in saturation conditions being achieved in the suction header causing flashing across the isolation valves and potentially degrading the valve disk and seating surfaces. This could result in increased reactor coolant system leakage past the isolation valves beyond the capacity of the bypass line. However, in the event of leakage in excess of the ability of the bypass line, Energy Northwest would have received a control room alarm which would have alerted operators to the degraded condition allowing the operators to take prompt action to define the actual leakage and to take actions as needed. Energy Northwest entered the issue into the corrective action program and took immediate action to monitor suction header temperature with the bypass line in service to assure that saturation conditions would not develop.
This finding was more than minor because it was a design control issue which affected the initiating events cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, degradation of reactor coolant system pressure isolation valves would occur with the bypass line in service at the maximum allowable design flowrate. This was considered to be a primary system loss of coolant accident initiator contributor (i.e. intersystem loss of coolant accident). The finding was determined to be of very low risk significance (Green) because assuming worst case degradation, the finding would not result in exceeding any Technical Specification limits for reactor coolant system leakage. Additionally, the finding would not have likely affected other mitigation systems resulting in a total loss of their safety function. A crosscutting aspect was not identified due to the performance deficiency occurring in 1994 (Section 1R15).
Inspection Report# : 2008002 (pdf)
Significance: Mar 31, 2008
Identified By: NRC
Item Type: NCV NonCited Violation
Failure to Take Adequate Corrective Actions to Address Deficient Emergency Procedure
Green. An NRC identified noncited violation of Technical Specification 5.4.1.a was identified for an inadequate emergency support Procedure PPM 5.5.26, “Overriding RHR [Residual Heat Removal] Shutdown Cooling Return Valve Isolations,” Revision 5. The deficient procedure could have resulted in portions of the RHR Trains A and B injection lines inadvertently draining during emergency response to an anticipated transients without scram event. Although Energy Northwest identified the deficiency with Procedure PPM 5.5.26 in June 2006 and had taken action to implement a procedure change, it was not until the inspectors prompted Energy Northwest regarding status of the procedure change and lack of apparent timeliness in issuing a revision to the procedure that Energy Northwest issued the revision. Procedure PPM 5.5.26, Revision 6, was issued on February 6, 2008. As a result of the value added by the inspectors, this finding is considered to be NRC identified.
The finding was more than minor because it was a procedure quality issue
which affected the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, implementation of Procedure PPM 5.5.26 during an anticipated transients without scram condition could have resulted in an inadvertent draining of RHR and subsequent damage to RHR piping and supports during subsequent initiation of injection. The finding was determined to be of very low risk significance (Green) because the finding did not represent an actual loss of safety function, did not represent a loss of system safety function, was not a design or qualification deficiency that resulted in a loss of operability, and was not risk significant due to external initiating events. The deficiency associated with Procedure PPM 5.5.26 would only occur during an anticipated transients without scram which is a non-design bases accident or event. A crosscutting aspect in problem identification and resolution with a corrective action program component [P.1.d] was identified in that the inadequate procedure, although entered into the corrective action program, was not corrected in a timely manner commensurate with safety. This was attributed to a shortage of qualified operations department procedure writers (Section 1R04.2).
Inspection Report# : 2008002 (pdf)
Significance: Dec 31, 2007
Identified By: NRC
Item Type: NCV NonCited Violation
Failure to Conduct Engineering Evaluation in Accordance with Scaffold Procedure
Green. An NRC identified noncited violation of 10 CFR Part 50, Appendix B, Criterion V, “Instructions, Procedures, and Drawings,” was identified for Energy Northwest’s failure to follow Procedure PPM 10.2.53, “Seismic Requirements for Scaffolding, Ladders, Man-Lifts, Tool Gang Boxes, Hoists, Metal Storage Cabinets, and Temporary Shielding Racks,” Revision 26. Specifically, a protective cover (type of scaffold) was constructed over a safety-related battery with portions of the cover installed within 2 inches of the battery requiring an engineering evaluation to be conducted to assess the seismic qualification of the installation. Contrary to the procedure, no engineering evaluation was conducted until prompted by the inspectors. Although a subsequent evaluation determined that the installed cover was acceptable, Energy Northwest determined that historically battery protective covers had always been installed without a supporting engineering evaluation.
This finding was more than minor because it was a human performance error which affected the Mitigating Systems Cornerstone objective to ensure the availability and reliability of systems that respond to initiating events to prevent undesirable consequences. Although the licensee subsequently assessed the as-found installation of the protective cover as acceptable during mock-up testing, the inspectors concluded that the failure to evaluate past installations in accordance with Procedure PPM 10.2.53, was not commensurate with ensuring the reliability and availability of Battery E-B1-1. This was determined to be consistent with NRC Manual Chapter 0612, “Power Reactor Inspection Reports,” Appendix E, Example 4.a. for being more than minor risk significance because Energy Northwest had routinely failed to perform the requisite engineering evaluation during past installations. The finding was determined to be of very low risk significance (Green) because no actual loss of safety function occurred and the finding did not screen as potentially risk significant due to external events. Specifically, the as-found installation of the protective cover was determined to not adversely affect seismic qualification of the battery. A crosscutting aspect in human performance with a work practices component [H.4.b] was identified in that Energy Northwest failed to follow Procedure PPM 10.2.53 on December 3, 2007, resulting in a failure to conduct an engineering analysis associated with a safety-related battery protective cover (Section 1R04).
Inspection Report# : 2007005 (pdf)
Significance: Dec 31, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Provide Adequate Procedures for Shutdown of the High Pressure Core Spray Diesel Generator
Green. A self-revealing Green noncited violation of Technical Specification 5.4.1.a (2 examples) was identified for failure to provide adequate procedures for shutdown of the high pressure core spray diesel generator resulting in inoperability of the diesel generator. Specifically, Procedure OSP-ELEC-C703, “HPCS Diesel Generator AC Source Operability Check,” Revision 8, and Procedure TSP-DG-E501, “Simultaneous Start of All Three Diesel Generators,” Revision 2, were inadequate in that each procedure directed shutting down the high pressure core spray diesel generator by placing the diesel engine control switch to STOP resulting in an over excited condition of the generator and subsequent clearing of relay and metering circuit fuses and inoperability of the electronic governor. Performance of Procedure OSP-ELEC-C703 on October 19, 2007, resulted in the inoperability of the diesel generator until discovery of the blown fuses on November 8, 2007 and subsequent troubleshooting and repairs were completed on November 10, 2007. Performance of Procedure TSP-DG-E501, on May 3, 2005, also resulted in the inoperability of the high pressure core spray diesel generator through June 5, 2005, when the cleared fuses were identified although the diesel generator was not required to be operable due to the plant being in Modes 4 and 5 at the time.
This self-revealing finding was more than minor because the finding had an attribute of procedure quality which affected the Mitigating Systems Cornerstone objective to ensure the reliability of systems that respond to initiating events to prevent undesirable consequences. The finding was of very low safety significance (Green) because, although the high pressure core spray diesel generator’s electronic governor was inoperable, the diesel generator was capable of completing its safety function of supplying rated electrical power to the high pressure core spray pump and associated loads on its backup mechanical governor. Additionally, the finding was not associated with a qualification deficiency and was not risk significance due to external initiating events. A crosscutting aspect in human performance with a resources component [H.2.c] was identified in that Energy Northwest failed to provide adequate test procedures resulting in subsequent inoperability of the high pressure core spray diesel generator (Section 1R15).
Inspection Report# : 2007005 (pdf)
Significance: Jul 13, 2006
Identified By: NRC
Item Type: AV Apparent Violation
Lack of an Evaluation of the Effect of Fire on the Reactor Protection System / Scram Capability
The team identified an apparent violation (AV) of License Condition 2.C.(14) concerning failure to evaluate the potential effect of fire damage on the Reactor Protection System circuits relied upon for reactor scram capability in the approved fire protection program. Although the reactor protection and control rod drive systems are identified as part of the minimum safe shutdown systems necessary to accomplish the reactivity control shutdown function, and are credited in the post-fire safe shutdown procedures developed by the licensee, the potential for fire to cause a loss of this required shutdown function had not been evaluated. The licensee’s post-fire safe shutdown analysis included the assumption that the operator would initiate and confirm shutdown before control circuits were damaged, therefore, evaluation of the effects of fire damage to the reactor protection (RPS) and control rod drive (CRD) systems was not necessary. Review of the RPS circuits identified the potential for a fire in the control room to prevent the scram of one rod group.
The finding is greater than minor in that it affected the ability to achieve and maintain hot shutdown following a control room fire. This finding is associated with the Mitigating Systems cornerstone and the respective attribute of protection against external factors (e.g., fire). This finding impacted the mitigating systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to external events (such as fire) to prevent undesirable consequences. It is the NRC’s understanding that the licensee does not consider these circuit vulnerabilities to be violations of NRC requirements. The licensee considers multiple hot shorts due to fire in the control room to be outside of the plant licensing basis for the Fire Protection Program. Specifically, in this case, two hot shorts due to fire induced circuit damage would be required to prevent the scram of one rod group. The NRC staff and the industry are currently working on developing a resolution methodology to address these types of potential fire induced circuit failures. The team concluded that this violation meets the criteria of the NRC Enforcement Manual Section 8.1.7.1 for deferring enforcement actions for postulated fire induced circuit failures.
Inspection Report# : 2006008 (pdf)
Significance: Mar 31, 2008
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Preclude a Recurrence and Further Degradation of Secondary Containment
• Green. A self-revealing noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, “Corrective Action,” was identified for the failure to promptly correct a condition adverse to quality to preclude further degradation of a secondary containment sealing surface. As a result of untimely corrective actions to repair a previously identified breach in secondary containment, further degradation of secondary containment occurred due to high winds. Energy Northwest entered the issue into the corrective action program and took action to implement interim corrective actions so that operability of secondary containment was ensured.
This self-revealing finding was more than minor in accordance with Manual Chapter 0612, Appendix B, because it had an attribute of configuration control and design control that affected the barrier integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. Using Manual Chapter 0609, Significance Determination Process,” Phase 1 work sheet, the inspectors determined that the finding was of very low risk significance (Green) since the finding only represented a degradation of the radiological barrier function provided for the reactor building. Specifically, the finding resulted in significant erosion of the design margin of allowable secondary containment breach size in the reactor building to support standby gas treatment system and secondary containment operability. However, standby gas treatment and secondary containment remained operable during and following the high wind event. A cross-cutting aspect in human performance with a work control component [H.3.a] was identified in that Energy Northwest did not plan and prioritize work activities associated with final repair of the reactor building siding considering the potential for additional high wind events that could further degrade secondary containment. As a result, in February 2008, a high wind event further damaged the reactor building causing additional erosion of the secondary containment design margin for allowable breach size (Section 4OA3.1).
Inspection Report# : 2008002 (pdf)
Significance: Jun 30, 2008
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Control Access to an Area with Radiation Levels in excess of 1.0 Rem/hr
Green. The inspectors reviewed a self-revealing noncited violation of Technical Specification 5.7.2 for failure to control a high radiation area with dose rates in excess of 1.0 rem per hour. Specifically, on January 30, 2008, a worker, within the 512' reactor traversing incore probe mezzanine room, received an electronic dosimeter alarm and the investigation survey found that Valve RFW-V-70 had a dose rate of 4.2 rem per hour on contact and 1.2 rem per hour at 30 centimeters. The area was immediately controlled as required per Technical Specifications. Review of this occurrence revealed surveys indicating an upward trend of radiation levels on the valve in the May and June 2007 time frame. The review also revealed that several crud burst causing evolutions occurred around the June to July 2007 time frame and there was no process in place for radiation protection to be informed so that they could adequately monitor for changing radiological conditions throughout the plant. The issue was entered into the licensee’s corrective action program as Action Report/Condition Report Numbers 00176887 and 00178189. Initial corrective actions included controlling the area as required by Technical Specifications and procedure changes to ensure radiation protection is notified of such evolutions and enhancement of radiation protection procedures to include additional areas of the plant to be monitored upon notification of crud burst causing evolutions.
The failure to control a high radiation area with dose rates in excess of 1.0 rem per hour was a performance deficiency. This finding is greater than minor because it is associated with the occupational radiation safety program and process attribute and affected the cornerstone objective, in that the failure to properly control a high radiation area with dose rates in excess of 1.0 rem per hour had the potential to increase personnel dose. This finding was evaluated using the Occupational Radiation Safety Significance Determination Process and determined to be of very low safety significance because it did not involve: (1) an as low as is reasonably achievable planning or work control issue, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. Additionally, the violation has a crosscutting aspect in the area of human performance associated with the work control component because of a lack of interdepartmental communication and the failure to keep radiation protection informed of evolutions that may cause a change in radiological conditions [H.3(b)] (Section 2OS1).
Inspection Report# : 2008003 (pdf)
Significance: Jun 30, 2008
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Barricade and Conspicuously Post a High Radiation Area
Green. The inspectors reviewed a self-revealing noncited violation of Technical Specification 5.7.1 for failure to barricade and conspicuously post a high radiation area. Specifically, a worker received a dose rate alarm of 216 millirem per hour while working in a HI-TRAC cask work area of the spent fuel pool floor on March 5, 2008. The worker was working on a radiation work permit that had a dose rate alarm setpoint of 80 millirem per hour. Radiation protection personnel performed radiation surveys following notification of the alarm and identified the area had radiation levels up to 230 millirem per hour on contact and 120 millirem per hour at 30 centimeters constituting a high radiation area. The issue was entered into the licensee’s corrective action program as Action Report/Condition Report Number 00178381.
The failure to barricade and conspicuously post a high radiation area was a performance deficiency. This finding is greater than minor because it is associated with the occupational radiation safety program and process attribute and affected the cornerstone objective, in that the failure to barricade and conspicuously post a high radiation area had the potential to increase personnel dose. This finding was evaluated using the Occupational Radiation Safety Significance Determination Process and determined to be of very low safety significance because it did not involve: (1) an as low as is reasonably achievable planning or work control issue, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. Additionally, the violation has a crosscutting aspect in the area of human performance associated with the work control component because the work planning did not appropriately plan work activities by incorporating job site conditions and appropriate equipment to use [H.3(a)] (Section 2OS1).
Inspection Report# : 2008003 (pdf)
Significance: Jun 30, 2008
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to Perform Radiological Survey
Green. The inspectors reviewed a self-revealing noncited violation of 10 CFR 20.1501(a) for failure to perform a survey of a potentially contaminated barrel, resulting in the contamination of a worker. Specifically, on October 5, 2007, a worker alarmed a personnel monitor with radioactive contamination on the back of the worker’s T-shirt. The worker showed radiation protection personnel the work area; a barrel of scrap metal with a label indicating contamination levels <1000 decays per minute per 100 centimeters squared. Smears of the inside of the drum and closure ring revealed contamination levels up to 4000 decays per minute per 100 centimeters squared. The ring was decontaminated, the barrel was sealed and labeled as radioactive material, and was placed in an appropriate storage area. No other contamination was found in the area and a random survey of other non radioactive barrels revealed no contamination. The issue was entered into the licensee’s corrective action program as Action Report Number 00056086.
The failure to perform surveys of potentially contaminated items is a performance deficiency. This finding is greater than minor because it is associated with the occupational radiation safety program and process attribute and affected the cornerstone objective, in that not completely evaluating the radiological conditions had the potential to increase personnel dose. This finding was evaluated using the Occupational Radiation Safety Significance Determination Process and determined to be of very low safety significance because it did not involve: (1) an as low as is reasonably achievable planning or work control issue, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. This finding has a crosscutting aspect in the area of human performance associated with work practices because the individual that performed the survey failed to use proper human error prevention techniques to ensure an adequate survey of the barrel [H.4(a)] (Section 2OS1).
Inspection Report# : 2008003 (pdf)
Significance: Dec 31, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to survey airborne radioactivity
Green. The inspector reviewed a self-revealing, noncited violation of 10 CFR 20.1501(a) resulting from the licensee’s failure to perform airborne radioactivity surveys during a work activity. The failure was discovered after five contract scaffold workers caused the personnel contamination monitors to alarm as they attempted to exit the radiologically controlled area. The workers had become internally contaminated and radiation protection personnel discovered there had been no air sampling conducted to verify airborne radioactivity concentrations in the work area. The licensee found a similar event had occurred in 2005 and the corrective action was ineffective to prevent recurrence because it lacked specific contamination control rules for areas with high levels of contamination. The licensee was developing more specific contamination controls.
This finding was greater than minor because it was associated with the occupational radiation safety program attribute of exposure control and affected the cornerstone objective in that the lack of knowledge of radiological conditions could increase personnel dose. The inspector determined that the finding was of very low safety significance because it did not involve: (1) an as low as reasonably achievable finding, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. Additionally, this finding had a crosscutting aspect in the problem identification and resolution area, associated with the corrective action program component, because the licensee did not take appropriate corrective actions to address safety issues in a timely manner [P1.d] (Section 2OS1).
Inspection Report# : 2007005 (pdf)
Significance: Dec 31, 2007
Identified By: Self-Revealing
Item Type: NCV NonCited Violation
Failure to use the correct radiation work permit and obtain a briefing of dose rates
Green. The inspector reviewed a self-revealing, noncited violation of Technical Specification 5.4.1 because a worker failed to use the correct radiation work permit and obtain a briefing of the dose rates in the work area. The worker had been working in the drywell, but entered the steam tunnel without changing radiation work permits or obtaining a briefing on the radiological hazards in the steam tunnel. The licensee was alerted to the situation when the worker’s electronic dosimeter alarmed. The licensee counseled the worker on the proper practice.
This finding was greater than minor because it was associated with the occupational radiation safety program attribute of exposure control and affected the cornerstone objective in that the lack of knowledge of radiological conditions could increase personnel dose. The inspector determined that the finding was of very low safety significance because it did not involve: (1) an as low as reasonably achievable finding, (2) an overexposure, (3) a substantial potential for overexposure, or (4) an impaired ability to assess dose. Additionally, this finding had a crosscutting aspect in the human performance area, associated with the work practices component, because the worker did not use human error prevention techniques such as self-checking (H4.A) (Section 2OS1).
Inspection Report# : 2007005 (pdf)
Significance: Dec 31, 2007
Identified By: Self-Revealing
Item Type: FIN Finding
ALARA Finding
Green. The inspector reviewed a self-revealing ALARA finding because performance deficiencies resulted in the collective dose of a work activity exceeding five person-rem and the legitimate dose estimate by more than 50 percent. The licensee estimated Radiation Work Permit 30001874, “R18 RX RRC/RWCU Chemical Decontamination,” would accrue 5.783 person-rem; however, the actual dose was 9.143 person-rem. The primary reason for exceeding the estimated dose was the need to perform work activities more than once. Lack of adequate planning and errors by craft workers resulted in the need to repeat activities, thereby increasing collective dose. Corrective action is being evaluated.
This finding is greater than minor because it is associated with the occupational radiation safety program attribute of exposure control and affected the cornerstone objective in that it caused increased collective radiation dose. The inspector determined this finding had very low safety significance. Although the finding involved ALARA planning and work controls, the licensee’s latest, official 3-year rolling average collective dose was less than 240 person-rem. Additionally, this finding had a crosscutting aspect in the human performance area, associated with the work control component, because work activities were not planned taking into account job site conditions [H3.a] (Section 2OS2).
Inspection Report# : 2007005 (pdf)
Although the NRC is actively overseeing the Security cornerstone, the Commission has decided that certain findings pertaining to security cornerstone will not be publicly available to ensure that potentially useful information is not provided to a possible adversary. Therefore, the cover letters to security inspection reports may be viewed.
Significance: SL-IV May 13, 2008
Identified By: NRC
Item Type: VIO Violation
Willful Violation by a project manager who instructed plant workers to reach across a contamination boundary without radiation protection approval
During an NRC investigation and subsequent in-office inspection completed on May 13, 2008, a violation of NRC requirements was identified. In accordance with the NRC Enforcement Policy, the violation is listed below:
Technical Specification 5.4.1.a states, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 7.e (1), specifies procedures for “Access Control to Radiation Areas Including a Radiation Work Permit System.”
Columbia Generating Station Procedure GEN-RPP-04, “Entry into, Conduct in, and Exit from Radiologically Controlled Areas,” Revision 14, states, in part, “Do not reach over, or cross contaminated area boundaries without RP approval.”
Contrary to the above, during repair of the HPCS-P-1 flange on June 16, 2007, a project manager instructed plant workers to reach across a contamination boundary without radiation protection approval.
This is a Severity Level IV violation. (Supplement IV)
Inspection Report# : 2008008 (pdf)
Last modified : November 26, 2008