The Nuclear Regulatory Commission Region IV selected Columbia Generating Station to be one of eight plants for a Component Design Basis Inspection pilot program (reduction in the duration of CDBI from five weeks to three weeks). Inspectors performed the Environmental Qualification Program inspection May 9-13 and the conventional components inspection from June 6-24.

Preparation for the inspection began in December 2015 with a self-assessment performed for each of the two inspections. This was considered Phase 1 of our three phase approach for the CDBI. The second phase initiated in February closed gaps found from the self-assessments, reviewed previous CDBI violations at other stations, developed inspector violation profile history, and ensured proper closure of Columbia Generating Station’s previous CDBI violations. The team benchmarked South Texas Nuclear Project Electric Generating Station and Calvert Cliffs Nuclear Power Plant and industry peers from STP and LaSalle County Nuclear Generating Station supported the station’s self-assessment The benchmarking and assessment identified the need to implement swing shifts, lead and team composition, and improvements in the data collection process. The last phase consisted of the actual inspection, in which three NRC inspectors were on site for the programs inspection and seven for the conventional component inspection. Each inspector was assigned a site counterpart to capture questions and issues for response by subject matter experts to be delivered within four hours. NRC inspectors praised the timeliness and accuracy of our responses. One of the key learnings included maintaining open communication with the NRC team lead which was established during an initial on site data gathering trip in March and reinforced throughout the duration of the two inspections. The Columbia Generating Station inspection leads met with the team lead on a daily basis to review the team’s progress and specifically address any issues.

The team identified a few major lessons learned through the after action review.

• Engage all involved departments early. Specifically, Operations was not fully engaged during Phase 2 and this would have provided better preparation for Operations readiness when issues arose during the actual inspection.
• Have three experienced Operations crews available to validate and perform the simulator run would have been beneficial, as only two crews were utilized for this inspection.
• Understand knowledge gaps, either due to inexperienced or unavailable workers and supplement subject matter experts with external support. This proved to be beneficial to resolve open issues.
• Use a centralized war room and an established protocol to keep the team focused and minimize distractions to the response team.
• Use swing shift to resolve late day requests for information to provide information to the NRC first thing on the following morning. Ensure that there are good turnovers to and from swing shift.
• Ensure dedicated support by Operations (for simulator scenarios and performing time critical operator actions and Licensing to deal with strict compliance issues.) Include them with the swing shift as needed.
• Perform verification runs on time critical operator actions during the first week, if possible, as this will allow ample time for the station to respond to identified problems during the verification runs.
• Shadow senior subject matter experts to mentor and train engineers for future CDBIs.

The results of the combined inspections at Columbia Generating Station were one green non-cited violation and four minor violations. The non-cited violation was related to procedure use and adherence and a cross cutter was assigned under Human Performance; Resources (H-1). The minor violations were related to various technical issues and are documented in the Corrective Action Program. The inspection results were one of the best performances for the industry during this CDBI cycle, including pilot sites. All pilots complete at this time.