ML22068A234
| ML22068A234 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/18/2022 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Schuetz R Energy Northwest |
| Chawla M | |
| References | |
| EPID L-2022-LLA-0023, TSTF-505, Rev 2 | |
| Download: ML22068A234 (10) | |
Text
March 18, 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 - REGULATORY AUDIT PLAN IN SUPPORT OF REVIEW FOR LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-505, REVISION 2 (EPID L-2022-LLA-0023)
Dear Mr. Schuetz:
By letter dated February 3, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22034A992), Energy Northwest (the licensee) submitted a license amendment request for Columbia Generating Station (Columbia). The proposed amendment would modify the Columbia Technical Specification requirements to permit the use of risk-informed completion times in accordance with Technical Specifications Task Force (TSTF)
Traveler TSTF-505, Provide Risk-informed Extended Completion Times - RITSTF
[Risk-Informed TSTF] Initiative 4b, Revision 2.
The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine the licensees non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit virtually at NRC Headquarters in Rockville, Maryland, via a licensee-established electronic portal available to NRC staff from approximately 2 weeks from the date of this audit plan through November 10, 2022, with formal audit meetings to be scheduled during this period as needed. The detailed audit plan is enclosed with this letter.
If you have any questions, please contact me at (301) 415-8371 or by 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
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST TO ADOPT RISK-INFORMED COMPLETION TIMES ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397
1.0 BACKGROUND
By letter dated February 3, 2022 (Reference 1) Energy Northwest (the licensee) submitted a license amendment request (LAR) to amend Renewed Facility Operating License No. NPF-21 for Columbia Generating Station (Columbia). The proposed amendment would modify the Columbia Technical Specification (TS) requirements to permit the use of risk-informed completion times (RICTs) in accordance with Technical Specifications Task Force (TSTF)
Traveler TSTF-505, Provide Risk-informed Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative 4b, Revision 2 (Reference 2). These RICTs would apply to certain actions required when limiting conditions for operation are not met.
The U.S. Nuclear Regulatory Commission (NRC) staff from the Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures, Revision 6 (Reference 3).
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information identified during the audit that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1 (Reference 4), with exceptions noted within this audit plan.
The NRC staff will perform the audit to support its evaluation of whether the licensees LAR can be approved per Title 10 of the Code of Federal Regulations Section 50.90, Application for amendment of license, construction permit, or early site permit. The NRC staffs review will be informed by 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 Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis, dated June 2007 (Reference 5). The audit will assist the NRC staff with understanding the licensees proposed program to implement RICTs for certain TSs.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY NRCs objectives of the audit are the following:
Learn how the licensees proposed program implements TSTF-505 and conforms to NRC-endorsed guidance in Nuclear Energy Institute (NEI) report NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification (RMTS) Guidelines, dated November 2006 (Reference 6).
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of the plants design features and its implications for the LAR.
Identify any information needed to enable the NRC staffs evaluation of the technical acceptability of the probabilistic risk assessment (PRA) used for this application.
Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information, dated August 9, 2021 (Reference 7).
The NRC staff will audit the PRA methods that the licensee would use to determine the risk impact from which the revised completion times would be obtained, including the licensees assessments of internal events (including internal flooding), fire, and seismic PRAs. The NRC will also audit the licensees assessment of risk from other external events, and the licensees evaluation of defense-in-depth.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff will request information and an audit meeting(s) throughout the audit period. The NRC staff will use an audit items list to identify the information (e.g., methodology, process information, and calculations) to be audited. The NRC staff will document the final audit items list as an enclosure to the audit summary report, which will be publicly available. The attachment to this audit plan includes the initial audit items list. Throughout the audit period, the NRC staff will provide the licensee with audit questions and audit-related requests so that the licensee can better prepare for audit discussions with NRC staff. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff. The NRC staff requests the licensee to have the requested audit information listed in the audit items list to be readily available and accessible for the NRC staffs review via a Web-based portal.
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR and contractors.
Mahesh Chawla, Plant Licensing Branch IV (LPL4)
Todd Hilsmeier, PRA Licensing Branch A (APLA)
Kristy Bucholtz, APLA JS Hyslop, PRA Licensing Branch B (APLB)
Naeem Iqbal, APLB Thinh Dinh, APLB Keith Tetter, PRA Licensing Branch C (APLC)
Alissa Neuhausen, APLC Andrea Russell, Technical Specifications Branch (STSB)
Hanry Wagage, Containment and Plant Systems Branch (SCPB)
Ming Li, Instrumentation and Controls Branch (EICB)
William Roggenbrodt, EICB Edmund Kleeh, Electrical Engineering Branch (EEEB)
Steve Wyman, EEEB Chris Jackson, Nuclear Systems Performance Branch (SNSB)
To be determined, Pacific Northwest National Laboratory (PNNL)
To be determined, PNNL 6.0 LOGISTICS To support the review schedule communicated to the licensee when the NRC staff accepts the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and a Web-based portal or other virtual meeting space created by the licensee. NRC information requests and communications with licensee staff will be coordinated through the NRCs licensing project manager.
The audit period will begin approximately 2 weeks from the date of this audit plan and will last through November 10, 2022. The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC intends to establish an audit meeting(s) (e.g., a single, multi-day audit meeting; periodic audit meetings throughout the audit period) on mutually agreeable dates and times (to be determined) to discuss information needs and questions arising from the NRCs review of the audited items.
The NRC staff requests the licensee to have the information referenced in Section 4.0 of this audit plan available and accessible for the NRC staffs review via an internet-based 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 NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal. The NRC staff requests the licensee to notify the review team when an audit item is added to its portal by sending an e-mail to the review team e-mail address1 or the NRC licensing project manager.
1 ColumbiaTSTF-505@usnrc.onmicrosoft.com 7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a Web-based portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:
The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
Username and password and/or other Web-based portal access information should be provided directly to members of the NRC staff and contractors as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager.
8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, following guidance in NRR Office Instruction LIC-115 and issue such RAIs separately from audit-related correspondence. The NRC staff will issue an audit summary report prior to completing its review of the LAR.
9.0 REFERENCES
- 1.
Dittmer, J. K., Energy Northwest, letter to the U.S. Nuclear Regulatory Commission, Columbia Generating Station, Docket No. 50-397 License Amendment Request to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times -
RITSTF Initiative 4b, dated February 3, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22034A992).
- 2.
Technical Specifications Task Force, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-505, Provide Risk-Informed Extended Completion Times, and Submittal of TSTF-505, Revision 2, dated July 2, 2018 (ADAMS Accession No. ML18183A493).
- 3.
U.S. Nuclear Regulatory Commission, License Amendment Review Procedures, NRR Office Instruction LIC-101, Revision 6, dated July 31, 2020 (ADAMS Accession No. ML19248C539).
- 4.
U.S. Nuclear Regulatory Commission, Regulatory Audits, NRR Office Instruction LIC-111, Revision 1, dated October 31, 2019 (ADAMS Accession No. ML19226A274).
- 5.
U.S. Nuclear Regulatory Commission, NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition, Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, June 2007 (ADAMS Accession No. ML071700658).
- 6.
Nuclear Energy Institute, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specification (RMTS) Guidelines, NEI 06-09, Revision 0-A, dated November 2006 (ADAMS Accession No. ML12286A322).
- 7.
U.S. Nuclear Regulatory Commission, Processing Requests for Additional Information, NRR Office Instruction LIC-115, Revision 1, dated August 5, 2021 (ADAMS Accession No. ML21141A238)
Attachment:
Initial Audit Items List
Attachment COLUMBIA TSTF-505 INITIAL AUDIT ITEMS LIST Item #
Audit Item 1
Reports of full-scope and focused-scope peer reviews, facts and observations (F&Os) closure reviews, and any self-assessments referred to in the license amendment request (LAR) for the internal events, internal flooding, fire, and seismic probabilistic risk assessments (PRAs) cited in the LAR.
2 For the internal events, internal flooding, fire, and seismic PRAs, plant-specific documentation (e.g., uncertainty notebooks) related to:
- a. The review of the PRA model assumptions and sources of uncertainty (generic and plant-specific assumptions/uncertainties)
- b. Identification of key assumptions and sources of uncertainty for this LAR
- c. Parametric uncertainty and state-of-knowledge correlation evaluation.
3 As applicable, PRA notebooks for the modeling of Diverse and Flexible Coping Strategies (FLEX) equipment and FLEX human error probabilities credited in the PRAs.
4 As applicable, PRA notebook(s) pertaining to the modeling of digital control systems, including basis for the representative failure probabilities.
5 Documentation of how shared or cross-tied systems are modeled in the PRA.
6 Fire PRA notebooks containing the results of the fire PRA.
7 Primary fire PRA notebooks (for example, Fire Modeling Notebook, Main Control Board Analysis Notebook, Circuit Failure Mode Likelihood Analysis Notebook) that address the major elements of the fire PRA and the methods used in those elements.
8 Additional documentation that supports the seismic PRA and external events screening, including:
Determination of PRA Maintenance vs. Upgrade for Columbia Generating Station, Letter Report 026014-RPT-01, Revision 1 Columbia Generating Station Seismic Probabilistic Risk Assessment:
Quantification, SPR-QU, Revision 6 Individual Plant Examination of External Events [IPEEE], Revision 0 CGS External Hazard Assessment, IPEEE-2-EH-0001, Revision 0, Re-Examination of External Events Evaluation in the IPEEE, Revision 0 Quantification, PSA-2-QU-0001, Revision 9 Evaluation of Secondary Containment Effectiveness Model Against the American Society of Mechanical Engineers (ASME) PRA Code Standard and ASME/American Nuclear Society (ANS) Standard Code Case 1, ENGNW#00449-REPT-001, Revision 0 F&O Closure Review for Evaluation of Secondary Containment Effectiveness, ENGNW#00449-REPT-002, Revision 0 Columbia Generating Station Evaluation of Tornado Frequency, Revision 0.
Item #
Audit Item 9
If modeled, the PRA notebooks associated with the modeling of Open Phase Condition (OPC) in electrical switchyards and the Open Phase Isolation System (OPIS).
10 Documentation supporting the development of the real-time risk tool and benchmarking it against the PRA.
11 Documentation supporting the example risk informed completion times (RICT) calculations presented in LAR Enclosure 1, Table E1-2.
12 PRA configuration control and update procedures, including when the PRA is updated (i.e., unscheduled and scheduled PRA updates).
13 If available, final RICT program procedures (e.g., for risk management actions, PRA functionality determination, and recording limiting conditions for operation).
(The licensee may choose (optional) to provide draft RICT program procedures if final procedures are not available.)
14 Other documentation that the licensee determines to be responsive to the U.S. Nuclear Regulatory Commission staff's information requests 15 Design documentation:
Simplified one-line diagrams for alternating current (AC) and direct current (DC) power distribution systems Normal and emergency lineups for AC sources and distribution systems Offsite primary and secondary feeds and any other possibilities Normal and emergency lineups for DC sources and distribution systems Information on required engineered safety feature (ESF) buses Information on ESF bus tie-breakers (e.g., when used and under what conditions)
Information on diesel generators buses, loads, and supporting systems (e.g.,
when required, minimum required for each unit etc.)
Load list List of any loads shared in the AC distribution systems List of any loads shared in the DC distribution systems
- by email OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA*
NRR/DRA/APLA/BC*
NRR/DRA/APLC/BC*
NAME MChawla PBlechman RPascarelli SVasavada (SRosenberg for)
DATE 3/9/2022 3/11/2022 3/14/2022 3/16/2022 OFFICE NRR/DRA/APLB/BC* NRR/DEX/EEEB/BC*
NRR/DEX/EICB/BC*
NRR/DSS/SCPB/BC*
NAME JWhitman WMorton MWaters BWittick DATE 3/17/2022 3/16/2022 3/16/2022 3/14/2022 OFFICE NRR/DSS/SNSB/BC* NRR/DSS/STSB/BC*
NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME SKrepel VCusumano SLee (JDixon-Herrity for) MChawla DATE 3/16/2022 3/14/2022 3/18/2022 3/18/2022