ML22032A014
| ML22032A014 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/09/2022 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Schuetz R Energy Northwest |
| Chawla M | |
| References | |
| EPID: L-2021-LLA-0207 10 CFR 50.69 | |
| Download: ML22032A014 (7) | |
Text
February 9, 2022
Mr. Robert Schuetz Chief Executive Officer Energy Northwest 76 North Power Plant Loop P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352
SUBJECT:
COLUMBIA GENERATING STATION - AUDIT PLAN AND SETUP OF ONLINE REFERENCE PORTAL FOR LICENSE AMENDMENT REQUEST TO ADOPT 10 CFR 50.69, RISK-INFORMED CAT EGORIZATION AND TREATMENT OF STRUCTURES, SYSTEMS AND COMPONENTS FOR NUCLEAR POWER REACTORS (EPID L-2021-LLA-0207)
Dear Mr. Schuetz:
By application dated November 9, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21314A224), Energy Northwest (th e licensee), submitted a license amendment request for Columbia Generating Station (Colu mbia). The proposed amendment would modify Columbias operating license by the addition of a license condition that would allow for the implementation of the provisions of Ti tle 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk informed categorization and tre atment of structures, systems and components for nuclear power reactors.
To improve the efficiency of the U.S. Nuclear Regulatory Commission (NRC) staff reviews, the licensees representatives and the NRC staff have discussed hav ing a virtual audit using an online reference portal. The NRC staff plans to initially cond uct a review of the documentation provided on the portal. The audit meeting with the licensee is scheduled for March 30-31, 2022. The online reference portal would allow the NRC staff to audit documents referenced in the request to determine whether the information included in th e documents is necessary to reach a safety conclusion on the proposed amendment. The licen see will be formally requested to submit information needed to reach a safety conclusion on th e NRC docket. Use of the online reference portal is acceptable as long as the following conditions are met:
The online reference portal will be password-protected and passwords will be assigne d to those directly involved in the review on a need-to-know basi s;
The online reference portal will be sufficiently secure to pre vent NRC staff and contractors from printing, saving, or downloading any documents ; and
Conditions of use of the online reference portal will be displayed on the login screen a nd will require concurrence by each user.
R. Schuetz - 2 -
The NRC staff would like to request that the portal be populate d with the documents listed in the enclosure to this letter. This is the initial list identified by the NRC staff. The NRC staff may request additional documents during the review via email. Plea se provide the NRC staff with access to the portal and send me the information needed for access, such as username and password, as soon as possible. The conditions associated with the online reference portal must be maintained throughout the duration of the audit. Please provide written confirmation that Energy Northwest agrees to the terms and conditions set forth i n this letter.
If you have any questions regarding this matter, I may be reach ed at (301) 415-8371 or via e-mail at Mahesh.Chawla@nrc.gov.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket No. 50-397
Enclosure:
Audit Plan
cc: Listserv AUDIT PLAN
REGARDING RISK-INFORMED CATEGORIZATION AND TREATMENT OF
STRUCTURES, SYSTEMS, AND COMPONENTS
ENERGY NORTHWEST
COLUMBIA GENERATING STATION
LICENSE AMENDMENT REQUEST TO ADOPT 50.69 CATEGORIZATION PROCESS
DOCKET NO. 50-397
1.0 BACKGROUND
By application dated November 9, 2021 (Agencywide Documents Acc ess and Management System (ADAMS) Accession No. ML21314A224), Energy Northwest (th e licensee) submitted a license amendment request (LAR) for Columbia Generating Station (Columbia). The proposed amendment would modify the Columbia license by the addition of a license condition that would allow for the implementation of the provisions of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.69, Risk informed categorization and treatment of structures, systems and components for nuclear power reactors. The proposed chang es are based on Nuclear Energy Institute (NEI) 00-04, 10 CFR 50.69 SSC [Structure, Sys tem, and Component]
Categorization Guideline, Revision 0, dated July 2005 (ADAMS A ccession No. ML052910035).
2.0 REGULATORY AUDIT BASES, SCOPE, AND METHODOLOGY
A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed informatio n. The audit is conducted to identify material required to be on the docket to support the b asis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the U.S. Nuclear Regulatory Commission (NRC) staff in efficiently conducting its review of the LAR and to gain insights of the licensees processes and procedures.
The bases for this remote audit are the licensees LAR for Colu mbia, and NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:
LWR [Light-Water Reactor] Edition, Section 19.2, Review of Ri sk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance dated June 2007 (ADAMS Accession No. ML071700658).
The remote audit will be performed consistent with NRC Office o f Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 2019 (ADAMS Accession No. ML19226A274). The NRC staff plans to initially c onduct a desk audit to review the documentation provided on the portal. The audit meeting wi th the licensee is scheduled for March 30-31, 2022. An audit was determined to be the most effi cient approach toward a timely resolution of issues associated with this LAR review. The NRC staff will have an opportunity to minimize the potential for multiple rounds of requests for addi tional information (RAIs) and ensure no unnecessary burden will be imposed by requiring the licensee to address issues that
Enclosure
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are no longer necessary to make a safety determination. Audit review items include the following:
Understand how the licensees proposed program implements the risk-informed application.
Gain a better understanding of the detailed calculations, analyses, and ba ses underlying the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the NRC staffs eval uation of the technical acceptability of the probabilistic risk assessment (PRA) used f or this application.
Identify any information needed to enable the NRC staffs eval uation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis function s.
Identify questions and requests that may become formal RAIs consistent w ith the guidance in NRR Office Instruction LIC-115, Revision 1, Proces sing Requests for Additional Information, dated August 9, 2021 (ADAMS Accession No. ML21141A238).
3.0 INFORMATION AND OTHER MATERIALS NECESSARY FOR THE REGULATORY REMOTE AUDIT
The NRC staff will request information as needed. The NRC staff will use an audit items list to identify the information (e.g., methodology, process informatio n, and calculations) to be audited and the subjects of requested interviews and meetings. The NRC staff requests the licensee to have the requested audit information listed in the audit document request to be readily available and accessible for the NRC staffs review via a Web-based porta l.
The NRC staff requests the licensee to have the information ref erenced in the Attachment to this audit plan available and accessible for the NRC staffs re view via an online reference portal within 2 weeks of the date of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within 1 week of the date of the NRCs notification to the licensee of the new requests.
The NRC audit team consists of the Division of Operating Reacto r Licensing (DORL) licensing project manager; NRC staff from the Division of Risk Assessment (DRA), PRA Licensing Branch A (APLA), PRA Licensing Branch B (APLB), PRA Licensing Branch C (APLC), and PRA Oversight Branch (APOB); and two NRC contractors from United St ates Department of Energy Pacific Northwest National Laboratory (PNNL). The NRC staff wi ll audit the PRA methods that the licensee plans to use to determine the risk impact, including the licensee assessments of internal events (including internal flooding) and fire PRAs. T he NRC staff will also audit the licensees quantification of risk from significant external eve nts, whether the licensee uses PRA or bounding methods, and the licensees evaluation of defense-i n-depth. The specific audit team is described below in Section 4.0.
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4.0 AUDIT TEAM
NRR Staff/Contractor Email RTR QA Division/Branch DORL PM Mahesh.Chawla@nrc.gov DORL/LPL4 APOB Lead RTR John.Hughey@nrc.gov X DRA/APOB APLA QAr Adrienne.Driver@nrc.gov X DRA/APLA APLB Lead RTR Naeem.Iqbal@nrc.gov X DRA/APLB APLB QAr JS.Hyslop@nrc.gov X DRA/APLB APLC Lead RTR Alissa.Neuhausen@nrc.gov X DRA/APLC APLC QAr Keith.Tetter@nrc.gov X DRA/APLC PNNL Mark.Wilk@pnnl.gov X -
PNNL Steve.Short@pnnl.gov X -
Note: reactor technical reviewer (RTR), quality assurance (QA), and quality assurance reviewer (QAr)
5.0 SPECIAL REQUESTS
The NRC staff requests access to requested documents and information through an online reference portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online reference portal must be maintained while the NRC staff and contractors have access to t he online portal
The online portal will be password-protected. A separate pass word will be assigned to each member of the NRC staff and each of the NRC contractors participating in the audit.
The online portal will prevent the NRC participants from print ing, saving, downloading, or collecting any information directly from the online reference p ortal.
Conditions of use of the online reference portal will be displ ayed on the login screen and will require acknowledgment by each user.
Username and password information should be provided directly t o members of the NRC staff and contractors. The NRC licensing project manager will provid e the licensee names and contact information of the NRC staff and contractors participat ing in the audit. All other communications should be coordi nated through the NRC licensing project manager.
6.0 DELIVERABLES
The NRC staff would like access to the documents requested thro ugh the online reference portal that allows the NRC staff and contractors to access doc uments remotely by February 15, 2022. The NRC staff and contractors access to the online port al should be terminated by June 30, 2022. The NRC staff will issue an audit summary repor t within 90 days of the completion of the audit. The NRC staff will develop any RAIs, as needed, consistent with the guidance in NRR Office Instruction LIC-115, Revision 1, and iss ue such RAIs separately from audit-related correspondence.
Attachment:
Requested Audit Materials List REQUESTED AUDIT MATERIALS LIST
ITEM AUDIT DOCUMENT REQUEST 1 Reports of all peer reviews (full-scope and focused-scope), s elf-assessments, and facts & observations (F&Os) closure reviews for the internal events, internal flooding, fire, and seismic probabilistic risk assessment (PRA) cited in Columbia Generating Station (Columbia) Title 10 of the Code of Federal Regulation s (10 CFR)
Section 50.69 license amendment request (LAR).
2 Uncertainty notebooks for the Columbia internal events, internal flooding, fire, and seismic PRAs related to PRA model assumptions and sources of un certainty.
3 Documentation on evaluation of the generic and plant specific uncertainties with respect to the Columbia 10 CFR 50.69 LAR.
4 PRA notebooks for the modeling of Diverse and Flexible Coping Strategies (FLEX) equipment and FLEX human error probabilities, if credited in th e PRA.
5 Available 10 CFR 50.69 structures, systems, and components ca tegorization program procedures (e.g., categorization review and adjustment process, decision criteria for Integrated Decisionmaking Panel).
6 Any notebooks and peer reviews on the screening of other exte rnal hazards.
7 Any other supporting documentation that the licensee may determine is responsive to the above U.S. Nuclear Regulatory Commission staffs information requests.
Attachment
ML22032A014 *concurrence via e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DRA/APLA/BC* NRR/DRA/APLB/BC*
NAME MChawla PBlechman RPascarelli JWhitman DATE 1/31/2022 2/3/2022 1/24/2022 1/25/2022 OFFICE NRR/DRA/APLC/BC* NRR/DRA/APOB/BC* NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*
NAME SRosenberg AZoulis JDixon-Herrity MChawla DATE 1/27/2022 1/24/2022 2/8/2022 2/9/2022