ML13325B216
| ML13325B216 | |
| Person / Time | |
|---|---|
| Site: | Columbia |
| Issue date: | 11/21/2013 |
| From: | Thomas Farnholtz Region 4 Engineering Branch 1 |
| To: | Reddemann M Energy Northwest |
| References | |
| IR-13-007 | |
| Download: ML13325B216 (3) | |
Text
November 21, 2013 Mr. Mark E. Reddemann Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
ERRATUM FOR COLUMBIA GENERATING STATION - NRC COMPONENT DESIGN BASES INSPECTION REPORT 05000397/2013007
Dear Mr. Reddemann:
Please replace page 4 of Inspection Report 05000397/2013007 (ML13275A213) with the page enclosed in this letter. This erratum corrects the Summary of Findings to reflect that the correct significance of the NRC-identified, Severity Level IV non-cited violation was Severity Level IV not Green.
In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Thomas R. Farnholtz, Branch Chief Engineering Branch 1 Division of Reactor Safety Docket: 50-397 License: NPF-21
Enclosure:
Erratum for Inspection Report 05000397/2013007 cc w/encl:
Electronic Distribution for the Columbia Generating Station UNITED STATES NUCLEAR REGULATORY COMMI SSION RE G IO N I V 1600 EAST LAMAR BLVD ARLINGTON, TEXAS 76011-4511
M. Reddemann Electronic distribution by RIV:
Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Steven.Reynolds@nrc.gov)
DRP Director (Kriss.Kennedy@nrc.gov)
DRP Deputy Director (Troy.Pruett@nrc.gov)
DRS Director (Tom.Blount@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Jeremy.Groom@nrc.gov)
Resident Inspector (Dan.Bradley@nrc.gov)
Branch Chief, DRP/D (Ryan.Lantz@nrc.gov)
Senior Project Engineer, DRP/D (Bob.Hagar@nrc.gov)
Project Engineer, DRP/D (Brian.Parks@nrc.gov)
Public Affairs Officer (Victor.Dricks@nrc.gov)
Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Lauren.Gibson@nrc.gov)
Branch Chief, DRS/TSB (Ray.Kellar@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov)
Regional Counsel (Karla.Fuller@nrc.gov)
Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV/ETA: OEDO (Daniel.Rich@nrc.gov)
Inspection Reports/MidCycle and EOC Letters to the following:
ROPreports S:\\DRS\\REPORTS\\Reports Drafts\\CGS 2013007-ERRATA-GAG.docx ML ADAMS No Yes SUNSI Review Complete Reviewer Initials: GAG Category B.1 Publicly Available Non-sensitive Category A Non-publicly Available Sensitive KEYWORD:
Sensitive:
RIV:
DRS/EB1/SRI DRS/EB1/BC GAGeorge TRFarnholtz
/RA/
/RA/
11/21/13 11/21/13 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
The team determined that failure to establish procedures for filling and venting diesel engine fuel oil storage tanks after tornado damage in accordance with Technical Specification 5.4.1(a) was a performance deficiency. The performance deficiency was more than minor, and therefore a finding. Because it was associated with the procedures attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.
Using the NRC Manual Chapter 0609, Appendix A, Exhibit 4, the inspectors determined a detailed risk evaluation was necessary because, during an external initiating event, the finding would degrade one or more trains of a system that supports a risk significant system or function; therefore, the senior reactor analyst performed a bounding detailed risk evaluation. The analyst determined that the change in core damage frequency was 1.2E-8 per year (Green). Since the change in core damage frequency was less than 1E-7 per year, the finding was not significant to the larger early release frequency. This finding had a crosscutting aspect in the area of problem identification and resolution, corrective action program component, because the licensee failed to take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. P.1(d) (Section 1R21.2.3)
Severity Level IV. The team identified a Severity Level IV non-cited violation of 10 CFR 50.71(e), which states, in part, that each person licensed to operate a nuclear power reactor shall update, periodically, the final safety analysis report originally submitted as part of the application for the license, to assure that the information included in the report contains the latest information. Specifically, from May 2009 to August 22, 2013, the team identified that the diesel engine fuel oil storage tanks cleaning and inspection frequency was not updated in the final safety analysis report to include the latest information developed. This violation was entered into the licensees corrective action program as Action Request 292360.
The violation did not represent an immediate safety concern.
The licensees failure to update the final safety analysis report to reflect the cleaning and inspection frequency of the diesel engine fuel oil storage tanks in Section 9.5.4.4 Testing and Inspection Requirements was a violation of the NRC requirements.
The inspectors determined that this violation was also a performance deficiency.
However, the inspectors determined that the performance deficiency was minor. The inspectors considered this issue to be within the traditional enforcement process because it had the potential to impact the NRC's ability to perform its regulatory oversight function. The inspectors used the NRC Enforcement Policy to evaluate the significance of this violation. The inspectors determined that the violation was a Severity Level IV because it was similar to an example provided in Section 6.1 of the NRC Enforcement Policy. The inspectors did not assign a cross-cutting aspect to this non-cited violation because there was no finding associated with this traditional enforcement violation. (Section 1R21.2.3)
Green. The team identified a Green non-cited violation of Title 10 CFR Part 50, Appendix B, Criterion III, Design Control, which states in part, that design control measures shall provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational