ML18088A015
| ML18088A015 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/29/2018 |
| From: | Mark Haire NRC/RGN-IV/DRP/RPB-A |
| To: | Reddemann M Energy Northwest |
| Alexander R | |
| References | |
| IR 2018010 | |
| Download: ML18088A015 (7) | |
See also: IR 05000397/2018010
Text
March 29, 2018
Mr. Mark E. Reddemann
Chief Executive Officer
Energy Northwest
MD 1023
P.O. Box 968
Richland, WA 99352
SUBJECT:
COLUMBIA GENERATING STATION - NOTIFICATION OF NRC INSPECTION
OF THE IMPLEMENTATION OF MITIGATION STRATEGIES AND SPENT
FUEL POOL INSTRUMENTATION ORDERS AND EMERGENCY
PREPAREDNESS COMMUNICATION/STAFFING/MULTI-UNIT DOSE
ASSESSMENT PLANS (05000397/2018010) AND REQUEST FOR
INFORMATION
Dear Mr. Reddemann:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)
staff will conduct a mitigation strategies for beyond-design-basis external events, spent fuel pool
instrumentation, and emergency preparedness enhancements inspection at the Columbia
Generating Station, from June 11 - 15, 2018. The inspection will consist of two reactor
inspectors from the NRCs Region IV office, one Resident Inspector from another Region IV
reactor site, plus one of the assigned Resident Inspectors at the Columbia Generating Station
for one week. The inspection will be conducted in accordance with the NRCs Temporary
Instruction 2515/191, Inspection of the Implementation of Mitigating Strategies and Spent Fuel
Pool Instrumentation Orders, and Emergency Preparedness Communication/Staffing/Multi-Unit
Dose Assessment Plans.
Experience has shown that this inspection is resource intensive both for the NRC inspectors
and licensee staff. In order to minimize the impact to your onsite resources and to ensure a
productive inspection, we have enclosed a request for documents needed for this inspection
activity. Please note that the documents are requested to be provided by May 18, 2018. During
the onsite inspection, inspectors will verify that plans for complying with NRC Orders EA-12-049
and EA-12-051 are in place and are being implemented. Inspectors will also verify the
establishment of staffing and communications plans provided in response to the
March 12, 2012, request for information letter, and multi-unit dose assessment information
provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency
Preparedness for Japan Lessons Learned, dated March 27, 2013. These plans and information
were provided in the site specific submittals, which were subsequently reviewed by the NRC
staff for understanding and documented in the NRCs plant safety evaluations (SEs) and safety
assessments. Therefore, appropriate personnel knowledgeable of the stations FLEX
strategies, spent fuel pool instrumentation, and emergency preparedness enhancements should
be available to support the inspectors at the site during the inspection.
M. E. Reddemann
2
We have discussed the schedule for this inspection activity with your staff and understand that
our regulatory contact for this inspection will be Richard Wynegar of your Regulatory
Compliance organization. If there are any questions about this inspection or the material
requested, please contact the lead inspector, Ryan D. Alexander, by telephone at 817-200-1195
or by e-mail at ryan.alexander@nrc.gov.
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. The NRC may not conduct or sponsor, and a person is not required to
respond to, a request for information or an information collection requirement unless the
requesting document displays a currently valid Office of Management and Budget control
number.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document 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 Chris Newport Acting for/
Mark S. Haire, Branch Chief
Project Branch A
Division of Reactor Projects
Docket: 50-397
License: NPF-21
Enclosure:
FLEX Strategies, Spent Fuel Pool
Instrumentation, & EP Enhancements
Inspection Request for Information
Request for Information
FLEX Strategies, Spent Fuel Pool Instrumentation, & EP Enhancements Inspection
Columbia Generating Station
Inspection Report: 05000397/2018010
Inspection Dates:
June 11 - 15, 2018
Inspection Procedure:
Temporary Instruction 2515/191, Inspection of the
Implementation of Mitigating Strategies and Spent Fuel Pool
Instrumentation Orders, and Emergency Preparedness
Communication/Staffing/Multi-Unit Dose Assessment Plans
Inspectors:
Ryan D. Alexander, Team Lead, Sr. Project Engineer, Region IV
Eduardo Uribe, Reactor Inspector, Region IV
Daniel Bradley, Sr. Resident Inspector, Callaway Plant
Gregory Kolcum, Sr. Resident Inspector, Columbia Generating
Station
Information Requested for the In-Office Preparation Week
The following information should be sent to the Region IV office in hard copy or electronic
format (use of the Certrec IMS information portal is preferred), to the attention of Ryan
Alexander, by May 18, 2018. Additionally, a copy of any material physically sent to the Region
IV office (e.g., CD/DVDs) should also be delivered to the resident inspectors office at Columbia
Generating Station. The inspectors will select specific items from the information requested
below and then request from your staff additional documents needed during the onsite
inspection week. Also, we request that you categorize the documents in your response with the
numbered list below. Please provide requested documentation electronically if possible. If
requested documents are large and only hard copy formats are available, please inform the lead
inspector, and provide subject documentation during the first day of the onsite inspection. If you
have any questions regarding this information request, please call the lead inspector as soon as
possible.
TI 2515/191 - Appendix A
A. Provide current revision of the FLEX Final Integrated Plan (i.e., current FLEX Program
Document), including any revisions since August 2017 submission to the NRC.
B. Provide the FLEX Strategy Basis Document.
C. Provide each operating, off-normal, abnormal, and/or emergency procedures where entry
into one or more FLEX Support Guidelines are initiated.
D. Provide a list and copies of every FLEX Support Guideline (FSG) or equivalent procedure
which you developed or revised to implement your mitigating strategies.
E. Provide a list of key pieces of equipment that directly perform a FLEX mitigation strategy for
core cooling, containment, and/or spent fuel pool cooling.
F. Provide a listing/summaries of plant modifications completed related to the FLEX program.
G. Provide a listing of calculations, evaluations, and 50.59 reviews related to the FLEX program
and modifications.
2
H. Applicable site specific hazards for the Columbia Generating Station:
1) Provide documents which show the locations and configuration of structure(s) which
store FLEX equipment.
2) Seismic
(a) Provide evaluation/evidence as to how FLEX equipment is stored to meet (i) the
stations seismic design basis (e.g., in an existing safety-related structure); (ii) in a
structure that meets the design requirements as described in ASCE 7-10, Minimum
Design Loads for Buildings and Other Structures, with a Building Risk Category of
IV; OR (iii) Outside a structure and evaluated for seismic interactions to ensure
equipment is not damaged by non-seismically robust components or structures.
(b) Provide the travel route(s) for FLEX equipment from storage location(s) to their
location(s) of use, AND evaluation(s) which demonstrate that for the potential for soil
liquefaction is not of a concern for these travel route(s).
(c) Seismic concerns for water source(s)
(1) If the FLEX water sources are seismically robust, then provide the assessment
that shows that they are.
(2) If the FLEX water sources are not seismically robust, then provide:
(a) an assessment of alternate water sources, and
(b) the procedure(s) which describe when and how to access those sources.
3) External Flooding {CGS screened-out relative to design basis external flooding hazard}
No documents requested.
4) Severe storms with high winds {CGS screened-out relative to high winds hazard}
No documents requested.
5) Snow, Ice, and Extreme Cold
For each key piece of equipment described in Item E (above) that directly performs or
implements a FLEX mitigation strategy:
(a) Provide procedures/documents demonstrating how the FLEX equipment is
maintained at a temperature within a range to ensure that it will function when called
upon.
(b) Proved procedures/documents demonstrating how the FLEX equipment can be
moved from the storage location to its deployment location during extreme snowfall
and ice storms.
6) Extreme high temperatures
For each key piece of equipment described in Item E (above) that directly performs or
implements a FLEX mitigation strategy:
(a) Provide procedures/documents which describes the high-temperature limit of the
range within which the equipment will function.
(b) Provide procedures/documents which describe how the equipment is maintained
below that limit in its storage location.
3
7) Volcanic Ash
For each key piece of equipment described in Item E (above) that directly performs or
implements a FLEX mitigation strategy:
(a) Provide procedures/documents which describe how the equipment is
stored/protected from the volcanic ash fall hazard applicable to the station.
(b) Provide procedures/documents which describe how the equipment has been
evaluated to ensure manual actions required by plant personnel can be
accomplished during volcanic ash fall conditions.
(c) Provide procedures/documents which describe how the equipment is maintained
functional when providing their FLEX functions during volcanic ash fall conditions.
I. Provide the station-specific FLEX strategies time validation study(ies).
J. Provide the relevant station procedure(s)/guideline(s) which describe the testing and
maintenance program for FLEX equipment.
1) As applicable, also provide a listing of the model work orders established to conduct
period testing and maintenance activities for FLEX equipment.
NOTE - A sample of records for completed maintenance/testing activities will be
requested for review during the onsite inspection week.
K. Provide documents/procedures which describe the programmatic controls in place to ensure
that if equipment and applicable connections are unavailable (e.g., due to maintenance,
non-functionality), then compensatory measures are implemented in accordance with
guidance outlined NEI 12-06.
L. Provide the station-specific National SAFER Center Playbook
M. Relative to personnel training on FLEX strategies, provide:
1) FLEX training bases document(s)
2) Lesson plans/training documents for site emergency response leaders responsible for
the implementation of FLEX strategies.
NOTE - Records for staff completing this training may be requested for review during
the onsite inspection week.
3) Lesson plans/training documents for site personnel responsible for the execution of
mitigating strategies for BDBEEs (i.e., operators, craft personnel, security, radiation
protection, etc.).
NOTE - Records for staff completing this training may be requested for review during
the onsite inspection week.
N. A current copy of administrative procedure(s) for the Corrective Action Program,
modification program, operations procedure writing and implementation, and top-level
documents for the work control and work scheduling programs. (If FLEX related procedures
such as FSGs or the FIP/FLEX Program Document are maintained under a different
process, please include copies of those procedures.)
O. A current copy of the U/FSAR, Technical Specifications, and Technical Specification Bases
documents.
P. Listing of corrective action program document summaries generated related to FLEX
equipment, strategies, procedures, and/or training.
NOTE - Complete corrective action program documents for a selection of those included
in the summary will be requested for review during the onsite inspection week.
4
Q. A copy of any audits/self-assessments related to your preparation for this inspection, as well
as any related to the implementation or maintenance of the FLEX program.
TI 2515/191 - Appendix B
R. Provide the procedures implemented for maintenance, testing, calibration, and use of the
primary and backup Spent Fuel Pool (SFP) instrumentation channels.
S. Provide lesson plans/training documents which describe the training program that address
the use, maintenance, calibration, surveillance, and the use of alternate power to the
primary and backup SFP instrument channels.
TI 2515/191 - Appendix C
T. Communications:
1) Provide documents which show that the communications system(s), technologies,
equipment and power supplies would be available from the beginning of the event and
operate during an ELAP.
2) Provide the procedures and/or guidance used to implement the communication
capabilities.
3) Provide documents which show that you have added any new communications
equipment, portable power supplies and/or systems have been added to ongoing testing
and preventative maintenance programs.
U. Staffing:
1) Provide documents which show that onsite and augmented staff will be available to
implement the strategies in response to a large scale natural event that results an ELAP
and impedes access to the site, and that functions/tasks have been appropriately
staffed.
2) Provide documents which show that the site access methods (e.g., roadways, navigable
bodies of water and dockage, airlift, etc.) expected to be available following the event
and available to the Emergency Response Organization (ERO) [as described in the
Phase 1 and 2 staffing assessments and NRC safety assessment].
3) Provide documents which show the testing, training, and drills/exercises performed by
the station to demonstrate the EROs ability to utilize the communications systems
and/or equipment.
V. Provide documents and procedures which show that your dose assessment
process/program is capable of analyzing concurrent radiological releases from all on-site
significant sources, including releases from spent fuel pools (i.e., multi-unit/multi-source
dose assessment capability).
Lead Inspector Contact Information:
Ryan D. Alexander, Sr. Project Engineer
Mailing Address:
817-200-1195
U.S. NRC, Region IV
Ryan.Alexander@nrc.gov
Attn: Ryan Alexander, DRP
1600 East Lamar Blvd.
Arlington, TX 76011-4511
SUNSI Review
By: MHS/dll/rdr
ADAMS:
Yes No
Sensitive
Non-Sensitive
Non-Publicly Available
Publicly Available
Keyword
OFFICE
DRP/RPBA
C:DRP/RPBA
NAME
RAlexander
MHaire
SIGNATURE
/RA/
/RA CNewport Acting for/
DATE
03/22/2018
03/29/2018