ML22235A105

August 2022 Emergency Preparedness Exercise Inspection Request for Information

ML22235A105
Person / Time
Site:	Columbia
Issue date:	08/22/2022
From:	Sean Hedger NRC Region 4
To:	Cook D Energy Northwest
Hedger S
References
Download: ML22235A105 (4)

Text

ADAMS Accession# ML22235A105 From: Hedger, Sean To: Kuklinski, Jennifer L.; Cook, Daniel D.

Subject:

RFI for Columbia Generating Station EP Exercise Inspection (October 2022)

Date: Monday, August 22, 2022 2:49:00 PM Attachments: CGS EP Exercise Inspection RFI 2022.pdf Ms. Kuklinski, Mr. Cook:

This e-mail serves to transmit a request for information to support and prepare for the Emergency Preparedness (EP) Exercise inspection at Columbia Generating Station, scheduled to occur the week of October 24, 2022.

By design, the biennial EP Exercise inspection includes the use of Inspection Procedures (IP) 71114.01, 71114.04, 71114.08, and 71151, to assess the overall health and maintenance of the stations EP program during the inspection year when the biennial EP Program inspection is not conducted. Details of the requested materials are included in the attachment to this e-mail. As noted in the attached, due to the ongoing Public Health Emergency, if possible, please make the requested materials available to me in electronic format using the online document portal of the stations choice, by the dates stated within the attachment. If you are unable to complete the request by this date, please contact me at the phone number listed below to discuss alternative options.

This letter/e-mail 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 under 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.

This email and its enclosures will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sean Hedger Senior Emergency Preparedness Inspector NRC, Region IV 817-200-1556

Request for Information for EP Exercise and Performance Indicator Verification Inspection Docket 05000397 (Columbia Generating Station) Inspection Reports 2022003 and 2022004 Inspection Procedures 71114.08, 71114.01, 71114.04, and 71151 Draft Scenario In-Office Review: August 26 - September 23, 2022 Onsite/Inspection Week: October 24 - 28, 2022 Please provide the following to support the inspection consistent with the methods and timeframes listed for each.

1) IP 71114.08: Exercise Evaluation - Scenario Review a) The licensee will be submitting the draft exercise scenario package to the NRC, with the 60-day submission due date of 08/26/2022. The inspectors will conduct a review of the scenario over the coming weeks in accordance with IP 71114.08.

The NRC Lead Inspector will schedule a teleconference to communicate the inspectors comments and observations associated with the review of the scenario no later than 30 days prior to the exercise. Since the 30 day mark falls on a weekend, a plan is being developed to conduct a teleconference providing comments the week of September 19, 2022.

b) Consistent with the new NRC Temporary Staff Guidance (NSIR/TSG 2020-02, Temporary Staff Guidance - Additional Guidance for EP Inspections During the PHE),

the NRC inspectors are expected to obtain and review Extent of Play agreements for both the onsite and ORO performance prior to the conduct of the exercise, depending on the applicable regulatory requirements the licensee chooses to demonstrate (e.g., 10 CFR Part 50, Appendix E, Section IV.F.2.b and/or 2.c). Specific guidance in Section 3.9 and Attachments 1 and 2 of the TSG describe the bases and scope of the review. As such, please provide a copy of all Extent of Play agreements associated with the October 25, 2022 plume phase exercise once they are available.

2) IP 71114.01: Exercise Evaluation a) First day of Onsite Inspection (10/24/2022) - Please provide hard/paper copies of the final, full Exercise Manual, one copy per inspector, plus one more for an exercise observer (5 total).

b) First day of Inspection (10/24/2022) - Provide a single hard copy document of the current site Emergency Plan and complete set of Emergency Plan Implementing Procedures. These will be used/referenced by the inspection team and returned at the conclusion of the exercise inspection week.

c) No later than 8:00 AM on Wednesday, 10/26/2022 (morning after the exercise) - Provide copies of all documents generated by participants (players, controllers, and evaluators) in the conduct of the exercise on 10/25/2022, separated by Emergency Response Facility (preferred).

Items 2.d - 2.f may be provided prior to the onsite inspection via the electronic portal of the stations choosing, in hard copy for review starting on the first day of inspection, or combination thereof (whichever is more readily available and convenient for the station):

d) Copies of all Drill and Exercise reports since CY2020, including standalone drills, team drills, dress-rehearsals, etc.

e) In addition, a copy of the 2018 and 2021 Biennial EP Exercise Reports (if not provided as part of Item 2.d).

f) Listing of all EP-related Corrective Action Documents/CRs generated since CY2020, in a sortable/searchable format. (Specific full CR documents may be subsequently requested based on sampling and review by the inspectors.)

3) IP 71114.04: EAL and Emergency Plan Changes Items 3.a - 3.c are requested to be provided approximately two weeks prior to the onsite inspection (10/11/2022) via the electronic portal of the stations choosing:

a) Copy of the 50.54(q) procedure (current revision) b) Listing of all of 50.54(q) reviews and screens performed since September 2021.

c) Copy of all 50.54(q) evaluations completed since September 2021.

i. Including copies of all evaluations completed [per 50.54(q) or other corrective action program process] to implement compensatory measures/contingency plans to ensure E-Plan requirements continued to be met during COVID-19 Public Health Emergency (PHE).

4) IP 71151: PI Verification (ERO Participation, DEP, and ANS) - ANNUAL review a) Please provide the applicable EP-related Performance Indicator data for:

4th Quarter 2021 through 3rd Quarter 2022 (4 quarters)

The bulleted items below include materials and data that licensees may maintain in support of the collection and reporting of the EP-related Performance Indicators. The list is illustrative and may not be all inclusive. In general, the inspectors are requesting access to the specific materials and data that Columbia Generating Station used to report the EP indicators.

Any information provided may be done so prior to the onsite inspection via the electronic portal of the stations choosing, in hard copy for review starting on the first day of inspection, or combination thereof (whichever is more readily available and convenient for the station):

• Station procedure for Alert & Notification System (ANS) Siren Testing.

• ANS Siren Test reports for the 4 quarters.

• Station procedure(s) for EP Performance Indicator data collection and submission.

• List of the DEP opportunities used in developing the PI values for the 4 quarters.

• All supporting documentation used to assess the DEP opportunities in the 4 quarters, which may include: (a) Drill/Exercise/LORT session reports, (b) actual declared emergency reports/assessments (if any), and (c) copies of notification forms associated with each of the DEP opportunities.

• Quarterly qualification rosters (or similar) for the key ERO members who were included in the ERO Participation data for the 4 quarters.

• Qualification records for the key ERO members who were included in the ERO Participation date for the 4 quarters.

• If not included in the supporting documentation for DEP opportunities (5th bullet above), drill/exercise attendance records and any other supporting documentation used to develop the reported ERO participation PI data for 4 quarters.

Items 4.b - 4.d are requested to be provided approximately two weeks prior to the onsite inspection (10/11/2022) via the electronic portal of the stations choosing:

b) Listing of all CRs related to ANS Siren failures and/or corrective maintenance during the 4 quarters, in a sortable/searchable format.

c) Listing of all CRs related to DEP opportunity failures during the 4 quarters, in a sortable/searchable format.

d) Listing of all CRs related to ERO qualification issues/deficiencies during the 4 quarters, in a sortable/searchable format.

If there are any challenges or questions related to providing the requested materials, please contact the lead inspector (Sean Hedger, phone: 817-200-1556), at the stations earliest convenience.

This request 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 under 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.

This e-mail and its enclosures will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.