ML22340A689
| ML22340A689 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/20/2022 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Schuetz R Energy Northwest |
| Chawla M | |
| References | |
| EPID L-2022-LLA-0023 | |
| Download: ML22340A689 (1) | |
Text
December 20, 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
SUMMARY
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 Accession No. ML22034A992), as supplemented by letters dated October 4, 2022, and November 28, 2022 (ML22277A603 and ML22332A516, respectively), Energy Northwest (the licensee) submitted a license amendment request for Columbia Generating Station (Columbia).
The proposed amendment would change 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.
To support its review, the U.S. Nuclear Regulatory Commission staff conducted a remote regulatory audit on August 1-4, 2022. The NRC staff reviewed documents and held discussions with members of Energy Northwest and its contractors. The regulatory audit summary is enclosed with this letter.
If you have any questions, please contact me at (301) 415-8371 or 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:
Regulatory Audit Summary cc: Listserv
Enclosure OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY AUDIT
SUMMARY
FOR AUGUST 1-4, 2022 BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF REVIEW OF THE LICENSE AMENDMENT REQUEST TO ADOPT TSTF-505, REVISION 2 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397
1.0 BACKGROUND
By application dated February 3, 2022 (Agencywide Documents Access and Management System Accession No. ML22034A992) as supplemented by letters dated October 4, 2022, and November 28, 2022 (ML22277A603 and ML22332A516, respectively), Energy Northwest (the licensee) submitted a license amendment request (LAR) for Columbia Generating Station (Columbia). The amendment would revise technical specification (TS) requirements to allow the use of risk-informed completion times for actions to be taken when limiting conditions for operation are not met. The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision2, Provide Risk-Informed Extended Completion Times - RITSTF [Risk-Informed TSTF] Initiative4b, dated July 2, 2018 (ML18183A493). The U.S. Nuclear Regulatory Commission (NRC) issued a final model safety evaluation approving TSTF-505, Revision 2, on November 21, 2018 (ML18269A041).
An audit team consisting of NRC staff and an NRC contractor from the Pacific Northwest National Laboratory (PNNL), conducted a remote regulatory audit to support the review of the LAR on August 1-4, 2022. The purpose of the audit was to gain an understanding of the information needed to support the NRC staffs licensing decision regarding the LAR and to develop requests for additional information (RAIs).
The information submitted in support of the LAR is under final review, and any additional information needed to support the LAR review will be formally requested by the NRC staff using the RAI process in accordance with the Office of Nuclear Reactor Regulation Office Instruction LIC-101, Revision 6, License Amendment Review Procedures (ML19248C539).
The regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of a licensing or regulatory decision.
Performing a regulatory audit of the licensees information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensees processes or procedures.
Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, the NRC staff may review supporting information retained as records under Title 10 of the Code of Federal Regulations (10 CFR) 50.71, Maintenance of records and/or 10 CFR 54.37, Additional records and recordkeeping requirements, which, although not required to be submitted as part of the licensing action, would help the staff better understand the licensees submitted information.
2.0 AUDIT ACTIVITIES of this summary provides the list of attendees from NRC, PNNL, Energy Northwest, and other participants.
The NRC audit team held an entrance meeting on Monday, August 1, 2022, with the licensees staff and contractors. During the remainder of the audit, the NRC audit team participated in technical discussions with the licensee based on discipline according to the audit plan dated March 18, 2022, and agenda dated July 6, 2022 (ML22068A234 and ML22165A296, respectively). Technical discussions were focused on the following major areas: probabilistic risk assessment (PRA), external hazards, fire protection, TSs, electrical engineering, and instrumentation and controls. The NRC audit team participated in a meeting with the licensee on Thursday, August 4, 2022, where the NRC staff provided a brief conclusion of the teams goals, objectives, and technical discussions.
The NRC staff provided a brief conclusion of the audit objectives that were met and details on the path forward. A discussion of the licensees seismic mean remained an open audit item and was a deviation from the audit plan. The licensee committed to providing a supplement to the application to address audit discussion points, including the seismic mean. Attachment 2 contains a list of documents reviewed by the team during the audit.
3.0 RESULTS OF THE AUDIT The LAR supplement was provided to the NRC on October 4, 2022 (ML22277A603). A request for additional information was issued to the licensee on October 28, 2022 (ML22301A143). The licensee provided the response in a supplement dated November 28, 2022 (ML22332A516).
Attachments:
- 1. List of Participants
- 2. List of Documents Reviewed During Audit
List of Participants U.S. Nuclear Regulatory Commission (NRC) Audit Team NRC Staff Role Mahesh Chawla Project Manager, NRR1/DORL2/LPL43 Kristy Bucholtz Team Lead, Reviewer, DRA4/APLA5 Robert Pascarelli Branch Chief, DRA/APLA Todd Hilsmeier Reviewer, DRA/APLA Naeem Iqbal Reviewer, DRA/APLB6 J. S. Hyslop Reviewer, DRA/APLB Keith Tetter Reviewer, DRA/APLC7 De Wu Reviewer, DRA/APLC Shilp Vasavada Branch Chief (Acting), DRA/APLC Andrea Russell Reviewer, DSS8/STSB9 Steve Wyman Reviewer, DEX10/EEEB11 Edmund Kleeh Reviewer, DEX/EEEB Ming Li Reviewer, DEX/EICB12 William Roggenbrodt Reviewer, DEX/EICB Thomas Byrd Observer, DORL Elias Kokkinis Observer, DRA/APLB Pacific Northwest National Laboratory (PNNL) Team Member Mark Wilk PRA Reviewer Energy Northwest - Columbia Generating Station, (Columbia) Team Rick Garcia Licensing Supervisor David Clymer PRA Engineering Supervisor Zach Dunham Assistant Operations Manager, Work Control Habib Shtaih Blake Smith Mark Rice David Dearing Kris Stauffer Al Maysam 1 Office of Nuclear Reactor Regulation (NRR) 2 Division of Operating Reactor Licensing (DORL) 3 Plant Licensing Branch IV 4 Division of Risk Assessment 5 Probabilistic Risk Assessment (PRA) Licensing Branch A 6 PRA Licensing Branch B 7 PRA Licensing Branch C 8 Division of Safety Systems 9 Technical Specifications Branch 10 Division of Engineering and External Hazards 11 Electrical Engineering Branch 12 Instrumentation and Controls Branch Enercon Justin Wheat Neil Johnson Tim Sande JensenHughes Francisco Joglar
List of Documents Reviewed During the Audit Columbia Generating Station, Documents Available for Review on the Energy Northwest Portal/Laptop The licensee provided an extensive list of supporting documents (e.g., analyses, calculations, reports, drawings, and procedures) on the Columbia Generating Station document portal available during the week of the audit.
Application Specific Documents Energy Northwest Report ENGNW-00554-REPT-005, Revision 1, Columbia Generating Station (CGS) - Risk Informed Completion Time (RICT) Quantifications for License Amendment Request.
Energy Northwest Report ENGNW-00554-REPT-003, Revision 1, Columbia Generating Station (CG.0S) - Risk Informed Completion Time (RICT) Review of Technical Specifications to PRA [Probabilistic] Model Capability.
Energy Northwest Report ENGNW-00554-REPT-004, Revision 0, CGS Impact of Model Uncertainty to RICT process.
PRA Acceptability Energy Northwest Report SYS-4-34, Revision 11, PSA [Probabilistic Safety Analysis]
Configuration Control.
Columbia Generating Station Unit 2, December 2009, PRA Peer Review Report Using ASME [American Society of Mechanical Engineers] PRA Standard Requirements.
Jensen Hughes, Letter Report 026014-RPT-01, Revision 1, Determination of PRA Maintenance vs. Upgrade for Columbia Generating Station.
Jensen Hughes, Letter Report 026022-RPT-01, Revision 0, Columbia Generating Station PRA Finding Level Fact and Observation Independent Assessment &
Focused-Scope Peer Review - Addendum 1.
Jensen Hughes, Letter Report 026016-RPT-02, Revision 0, Columbia Generating Station HRA [Human Reliability Analysis] Finding-Level Fact and Observation Independent Assessment.
Jensen Hughes, Letter Report 026016-RPT-01, Revision 0, Columbia Generating Station PRA Finding-Level Fact and Observation Independent Assessment &
Focused-Scope Peer Review.
Energy Northwest Report PSA-2-QU-0001, Revision 9, Quantification.
Internal Events PRA Energy Northwest PSA Support Document, PSA-2-QU-0001, Revision 9, Quantification.
Energy Northwest PSA Support Document, PSA-02-HR-0001, Revision 5, Human Reliability Assessment.
Energy Northwest PSA Support Document, PSA-02-AS-0001, Revision 8, Accident Sequence Evaluation.
Energy Northwest Action Request Report 00431267 Fire PRA Columbia Generating Station, August 2021, Fire PRA Facts and Observations Independent Assessment Report Using NEI [Nuclear Energy Institute] 17-07 Appendix E.
Columbia Generating Station, May 2021, Fire PRA Peer Review Report Using ASME/ANS [American Nuclear Society] PRA Standard Requirements.
Energy Northwest Report FPSA-2-UNC-0001, Revision 1, CGS Fire PRA Uncertainty and Sensitivity Analysis Notebook."
Energy Northwest Report FPSA-2-FQ-0001, Revision 1, CGS Fire PRA Summary and Quantification Notebook."
Energy Northwest Report FPSA-2-CFMLA-0001, Revision 1, CGS Fire PRA Circuit Failure Mode Likelihood Analysis."
Energy Northwest Report FPSA-2-MCR-0001, Revision 0, CGS Fire PRA Fire Main Control Room Analysis."
Energy Northwest Report FPSA-2-SCA-0001, Revision 1, CGS Fire PRA Single Compartment Analysis."
Seismic PRA Energy Northwest PSA Support Document, SPR-QU, Revision 6, Columbia Generating Station Seismic Probabilistic Risk Assessment Quantification.
Energy Northwest PSA Support Document, SPSA-2-QU-0001, Revision 6, PSA Revision Model 8.2, Revision Log.
Energy Northwest Report ENGNW-00449-REPT-001, Revision 0, Evaluation of Secondary Containment Effectiveness Model Against the ASME PRA Standard and ASME/ANS Standard Code Case 1.
Energy Northwest Report ENGNW-00449-REPT-002, Revision 0, F&O [Fact and Observation] Closure Review for Evaluation of Secondary Containment Effectiveness.
Columbia Generating Station, February 2019, Revision 0, Seismic PRA Peer Review Report Using ASME/ANS PRA Standard Requirements.
Jensen Hughes, Letter Report 026022-RPT-01, Revision 0, Columbia Generating Station PRA Finding-Level Fact and Observation Independent Assessment &
Focused-Scope Peer Review.
External Hazards Energy Northwest Report IPEEE-2-EH-0001, Revision 0, CGS External Hazard Assessment."
Maracor Report, Revision 0, Re-Examination of External Events Evaluation in the IPEEE [Individual Plant Examination of External Events], Columbia Generating Station.
Washington Public Power Supply System Main Report, Revision 0, Individual Plant Examination of External Events Washington Nuclear Plant 2.
Erin Engineering and Research, Inc. Report, Revision 0, Columbia Generating Station Evaluation of Tornado Frequency.
Electrical Energy Northwest Drawing, E503-6, Revision 119, Auxiliary One Line Diagram.
Energy Northwest Drawing, E503-9, Revision 95, Auxiliary One Line Diagram.
Energy Northwest Drawing, E505-1, Revision 113, DC [Direct Current] One Line Diagram.
Energy Northwest Drawing, E505-2, Revision 16, DC One Line Diagram.
Energy Northwest Drawing, E504-1, Revision 7, Vital One Line Diagram.
Energy Northwest Drawing, E505-3, Revision 0, One Line Diagram Hardened Containment Vent 24 VDC [Volts Direct Current] System E-DP-S0/2.
Energy Northwest Drawing, EWD-46E-240, Revision 19, Electrical Wiring Diagram AC
[Alternating Current] Electrical Distribution System Power Panel E-PP-7AF.
Energy Northwest Drawing, EWD-46E-250, Revision 3, Electrical Wiring Diagram AC Electrical Distribution System Power Panel E-PP-8AB.
Energy Northwest Drawing, EWD-46E-253, Revision 5, Electrical Wiring Diagram AC Electrical Distribution System Power Panel E-PP-8AG.
Energy Northwest Drawing, Onsite AC Power Sub-Fed ESF [Engineered Safety Feature] Buses Columbia Generating Station Energy Northwest Drawing, E502-1, Revision 65, Main One Line Diagram.
Energy Northwest Drawing, E502-2, Revision 67, Main One Line Diagram.
Energy Northwest Drawing, E502-3, Revision 27, Main One Line Diagram.
Energy Northwest Drawing, E502-4, Revision 10, Main One Line Diagram.
Plant Procedures Manual, SOP-ELEC-DC-LU, Revision 011, DC Electrical Distribution System Breaker Lineup, dated May 20, 2021.
Columbia Generating Station Final Safety Analysis Report drawing, 950021.35, Figure 8.1-3, 230 kV [Kilovolt] Line Ties dated December 2007 Amendment 59 Columbia Generating Station Final Safety Analysis Report drawing, 950021.34, Revision 2, Figure 8.1-4, 115 kV Line Ties dated December 2017 Amendment 64 Columbia Generating Station Final Safety Analysis Report drawing, 960690.14, Figure 8.1-5, 230 kV and 115 kV Auxiliary Power Layout dated December 2017 Amendment 64 Energy Northwest Design Basis Document, Division 300, Section 310, Standby Power Systems, Revision 15, dated June 2019.
Calc.# E/I-02-90-01, Appendix A, Steady State Voltage & Loading Calculations.
Calculation E/I-02-87-07, Appendix A4, ETAP MCC [Motor Control Center] Load Input Data.
Calculation E/I-02-87-07, Appendix A3, ETAP Large Motor & Static Load Input Data.
Energy Northwest Design Basis Document, Division 300, Section 317-AC, AC Electrical Distribution System, Revision 8, dated June 2021.
Plant Procedures Manual, ABN-ELEC-DG3-CROSSTIE/SM8, Revision 012, DG3 Crosstie to SM-8, dated April 1, 2021.
Plant Procedures Manual, ABN-ELEC-DG3-CROSSTIE/SM7, Revision 011, DG3 Crosstie to SM-7, dated July 29, 2020.
Energy Northwest Calculation, E/I-02-91-03,Calculation for Division1 and 2 and 3 Diesel Generator Loading, Revision 22, dated September 9, 2021.
Plant Procedures Manual, 5.6.2, Revision 016, Station Blackout (SBO) and Extended Loss of AC Power ELAP [Extended Loss of Alternating Current Power] Attachments, dated February 25, 2021.
Plant Procedures Manual, 5.6.1, Revision 031, SBO/ELAP, dated November 9, 2020.
Plant Procedures Manual, SOP-ELEC-AC-LU, Revision 086, AC Electrical Distribution System Breaker Lineup, dated March 24, 2022.
- by email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DRA/APLA/BC NRR/DRA/APLC/BC NAME MChawla PBlechman RPascarelli SVasavada DATE 12/6/2022 12/7/2022 12/8/2022 12/12/2022 OFFICE NRR/DRA/APLB/BC NRR/DEX/EEEB/BC NRR/DEX/EICB/BC NRR/DSS/STSB/BC NAME JRobinson WMorton MWaters VCusumano DATE 12/12/2022 12/12/2022 12/19/2022 12/12/2022 OFFICE NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JDixon-Herrity MChawla DATE 12/20/2022 12/20/2022