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| {{#Wiki_filter:Enclosure DRAFT REQUEST FOR ADDITIONAL INFORMATION COLUMBIA GENERATING STATION EMERGENCY ACTION LEVEL SCHEME CHANGE TO NEI 99-01, REVISION 5 DOCKET NO. 50-397 | | {{#Wiki_filter:DRAFT REQUEST FOR ADDITIONAL INFORMATION COLUMBIA GENERATING STATION EMERGENCY ACTION LEVEL SCHEME CHANGE TO NEI 99-01, REVISION 5 DOCKET NO. 50-397 By letter dated August 25, 2010, Energy Northwest - Columbia Generating Station (CGS), |
| | | (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102430334) requested prior approval for a revised emergency action level (EAL) scheme for Columbia Generating Station. |
| By letter dated August 25, 2010, Energy Northwest - Columbia Generating Station (CGS), (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102430334) requested prior approval for a revised emergency action level (EAL) scheme for Columbia Generating Station. | | CGSs letter stated that the current EAL scheme is based on generic development guidance from NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, Revision 2, dated January 1992, (ADAMS Accession No. ML041120174). Since 1992, numerous enhancements and clarification efforts have been made to the generic EAL development guidance resulting in the most latest document, Nuclear Energy Institute (NEI) 99-01, Revision 5, Methodology for Development of Emergency Action Levels, (ADAMS Accession No. ML080450149), which was found to be acceptable for use as generic EAL development guidance by the Nuclear Regulatory Commission (NRC) staff by letter dated February 22, 2008 (ADAMS Accession No. ML080430535). |
| CGS's letter stated that the current EAL scheme is based on generic development guidance from NUMARC/NESP-007, "Methodology for Development of Emergency Action Levels,"
| |
| Revision 2, dated January 1992, (ADAMS Accession No. ML041120174). Since 1992, numerous enhancements and clarification efforts have been made to the generic EAL development guidance resulting in the most latest document, Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," (ADAMS Accession No. ML080450149), which was found to be acceptable for use as generic EAL development guidance by the Nuclear Regulatory Commission (NRC) staff by letter dated February 22, 2008 (ADAMS Accession No. ML080430535). | |
| The proposed EAL scheme was developed using the generic development guidance from NEI 99-01, Revision 5 with numerous differences and deviations based upon design criteria applicable to CGS as well as licensee preferences for terminology, format, and other licensee desired modifications to the generic EAL scheme provided in NEI 99-01 Revision 5. | | The proposed EAL scheme was developed using the generic development guidance from NEI 99-01, Revision 5 with numerous differences and deviations based upon design criteria applicable to CGS as well as licensee preferences for terminology, format, and other licensee desired modifications to the generic EAL scheme provided in NEI 99-01 Revision 5. |
| Attached are the draft requests for additional information (RAIs) to facilitate the technical review being conducted by the Operating Reactor Licensing and Outreach Branch staff. Timely and accurate response to these draft RAIs is requested. | | Attached are the draft requests for additional information (RAIs) to facilitate the technical review being conducted by the Operating Reactor Licensing and Outreach Branch staff. Timely and accurate response to these draft RAIs is requested. |
| : 1. Section 2.0, "Discussion." This section does not contain information on the treatment of multiple events and classification upgrading as outlined in the endorsed guidance. Please provide justification for this inconsistency, or revise accordingly. 2. Step 2.13, "Validation of Indications, Reports and Conditions," step 2.13.2, states, in part, that "If a meter is broke, compensatory measures should be established to monitor the affected parameter." Please explain why this implies an option versus being a requirement as stated in 10 CFR 50.54(q), or revise to state "-shall- ." 3. The use of the following abbreviations is considered unadvisable from a human factors perspective as their use could cause significant confusion. Please explain why the staff should consider allowing these abbreviations to be implemented, or revise to use generally accepted nomenclature. | | : 1. Section 2.0, Discussion. This section does not contain information on the treatment of multiple events and classification upgrading as outlined in the endorsed guidance. |
| : a. GE: Numerous EALs use this as an abbreviation for "greater than or equal to." Please explain, in detail, why the use of "" or spelling out the words will not suffice, or revise accordingly wherever used. b. GT: Numerous EALs use this as an abbreviation for "greater than." Please explain, in detail, why the use of ">" or spelling out the words will not suffice, or revise accordingly wherever used. c. LE: Numerous EALs use this as an abbreviation for "less than or equal to." Please explain, in detail, why the use of "" or spelling out the words will not suffice, or revise accordingly wherever used. d. LT: Numerous EALs use this as an abbreviation for "less than." Please explain, in detail, why the use of "<" or spelling out the words will not suffice, or revise accordingly wherever used. 4. EAL RS1.1 and RG1.1: Please explain why the CGS basis information contains information about the Radwaste Building Exhaust (WEA-RIS-14(A)) being applicable when Table R-1 shows these to not be applicable to these EALs. 5. EAL RG1.3: Please explain why the note related to EAL declaration timing was not incorporated in this EAL, or revise accordingly. 6. EAL RA3.1: Please explain, in more detail, why the Central Alarm Station (CAS) is not applicable to this EAL or revise accordingly. 7. EAL CU5.1 and SU6.1: Please explain how the State/County Notification (CRASH) System will notify the NRC of a declared event at CGS or revise accordingly. 8. Fission Barrier Matrix: Please explain why no "other" site specific indicators have not been developed for this matrix, particularly when the current EAL scheme (based upon NUMARC/NESP-007) has several indicators not carried over into this proposed matrix considering that the matrix from NEI 99-01 Revision 5 is very similar. 9. The staff approved License Amendment No. 218 for CGS in response to the licensee's application dated April 28, 2010. However, the staff finds no evidence that this amendment has been carried over into this request to revise the CGS EAL scheme. Please explain, in detail, why this license amendment has not been carried over into this EAL scheme change request, or revise accordingly. 10. EAL EU1.1: The EAL states, "Multi Purpose Container (MPC) CONFINEMENT BOUNDARY breach". As worded this EAL would require an actual breach of the boundary versus damage to the confinement boundary for EAL declaration. Please provide justification for this inconsistency, or revise accordingly.}} | | Please provide justification for this inconsistency, or revise accordingly. |
| | : 2. Step 2.13, Validation of Indications, Reports and Conditions, step 2.13.2, states, in part, that If a meter is broke, compensatory measures should be established to monitor the affected parameter. Please explain why this implies an option versus being a requirement as stated in 10 CFR 50.54(q), or revise to state shall . |
| | : 3. The use of the following abbreviations is considered unadvisable from a human factors perspective as their use could cause significant confusion. Please explain why the staff should consider allowing these abbreviations to be implemented, or revise to use generally accepted nomenclature. |
| | Enclosure |
| | : a. GE: Numerous EALs use this as an abbreviation for greater than or equal to. |
| | Please explain, in detail, why the use of or spelling out the words will not suffice, or revise accordingly wherever used. |
| | : b. GT: Numerous EALs use this as an abbreviation for greater than. Please explain, in detail, why the use of > or spelling out the words will not suffice, or revise accordingly wherever used. |
| | : c. LE: Numerous EALs use this as an abbreviation for less than or equal to. |
| | Please explain, in detail, why the use of or spelling out the words will not suffice, or revise accordingly wherever used. |
| | : d. LT: Numerous EALs use this as an abbreviation for less than. Please explain, in detail, why the use of < or spelling out the words will not suffice, or revise accordingly wherever used. |
| | : 4. EAL RS1.1 and RG1.1: Please explain why the CGS basis information contains information about the Radwaste Building Exhaust (WEA-RIS-14(A)) being applicable when Table R-1 shows these to not be applicable to these EALs. |
| | : 5. EAL RG1.3: Please explain why the note related to EAL declaration timing was not incorporated in this EAL, or revise accordingly. |
| | : 6. EAL RA3.1: Please explain, in more detail, why the Central Alarm Station (CAS) is not applicable to this EAL or revise accordingly. |
| | : 7. EAL CU5.1 and SU6.1: Please explain how the State/County Notification (CRASH) |
| | System will notify the NRC of a declared event at CGS or revise accordingly. |
| | : 8. Fission Barrier Matrix: Please explain why no other site specific indicators have not been developed for this matrix, particularly when the current EAL scheme (based upon NUMARC/NESP-007) has several indicators not carried over into this proposed matrix considering that the matrix from NEI 99-01 Revision 5 is very similar. |
| | : 9. The staff approved License Amendment No. 218 for CGS in response to the licensees application dated April 28, 2010. However, the staff finds no evidence that this amendment has been carried over into this request to revise the CGS EAL scheme. |
| | Please explain, in detail, why this license amendment has not been carried over into this EAL scheme change request, or revise accordingly. |
| | : 10. EAL EU1.1: The EAL states, Multi Purpose Container (MPC) CONFINEMENT BOUNDARY breach. As worded this EAL would require an actual breach of the boundary versus damage to the confinement boundary for EAL declaration. Please provide justification for this inconsistency, or revise accordingly.}} |
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Category:Request for Additional Information (RAI)
MONTHYEARML24011A1522024-01-10010 January 2024 March 2024 Emergency Preparedness Exercise Inspection-Request for Information ML23110A2642023-04-20020 April 2023 Request for Information License Renewal Phase 2 Inspection ML22343A1802022-12-0808 December 2022 February 2023 Emergency Preparedness Program Inspection - Request for Information ML22301A1432022-10-28028 October 2022 NRR E-mail Capture - Final - Request for Additional Information - Columbia Generating Station - License Amendment Request to Adopt TSTF-505 - EPID L-2022-LLA-0023 ML22242A1082022-08-30030 August 2022 Information Request, Information Request, Security IR 2022404 ML22235A1052022-08-22022 August 2022 August 2022 Emergency Preparedness Exercise Inspection Request for Information ML22145A4462022-06-0606 June 2022 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000397/2022401 ML22144A0342022-05-18018 May 2022 NRR E-mail Capture - Draft - Request for Additional Information - Columbia Generating Station - LAR to Change TS 3.4.11 - Reactor Coolant System Pressure and Temperature Limits - EPID L-2021-LLA-0191 ML22041A4572022-02-10010 February 2022 Notification of NRC Design Bases Assurance Inspection (Team) (05000397/2022010) and Request for Information ML21277A3572021-10-12012 October 2021 CGS Brq RFI Letter, Columbia Generating Station - Notification of Inspection (NRC Inspection Report 05000397/2021004) and Request for Information ML21216A0502021-08-0303 August 2021 NRR E-mail Capture - Final - Request for Additional Information - Columbia - License Amendment Request to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO EPID L-2021-LLA-0259 ML21209A9792021-07-28028 July 2021 NRR E-mail Capture - Final - Request for Additional Information - Columbia Generating Station - License Amendment Request to Remove License Condition 2.C.(34) and Revise License Condition 2.C.(35) - EPID L-2021-LLA-0074 ML21120A1182021-04-30030 April 2021 NRR E-mail Capture - Final - Request for Additional Information - Columbia Generating Station - On-Site Cooling System Sediment Disposal Approval Request - EPID L-2020-LLL-0031 ML21068A2842021-03-0404 March 2021 2021002 Inservice Inspection (ISI) Request for Information (RFI) ML20336A1852020-11-30030 November 2020 NRR E-mail Capture - Final - RAI - Columbia - One -Time Exemption from 10 CFR 73, App B, Sect VI, Subsection C.3.(l)(1) Regarding Annual Force-On-Force Exercises Due to COVID-19 Pandemic - EPID L-2020-LLE-0172 ML20325A0402020-11-19019 November 2020 NRR E-mail Capture - Draft - RAI - Columbia - One -Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force -On-Force Exercises Due to COVID-19 Pandemic - EPID L-2020-LLE-0172 ML20267A5162020-09-23023 September 2020 NRR E-mail Capture - Columbia Generating Station - Final - Request for Additional Information - Fourth Ten-Year Interval Inservice Inspection (ISI) Program Relief Request 4ISI-09 - EPID L-2020-LLR-0068 ML20245E2822020-08-31031 August 2020 NRR E-mail Capture - Columbia Additional Request for Additional Information: Exigent License Amendment Request to Extend Technical Specification 3.8.7, Distribution Systems - Operating, Completion Time ML20239A9702020-08-26026 August 2020 NRR E-mail Capture - Columbia Additional Request for Additional Information: Exigent License Amendment Request to Extend Technical Specification 3.8.7, Distribution Systems - Operating, Completion Time ML20149K4362020-05-26026 May 2020 NRR E-mail Capture - Formal RAIs for Columbia (COVID-19) QA Plan Change Surveillance, Request Response by Tuesday June 2, 2020 ML20112F4572020-04-21021 April 2020 NRR E-mail Capture - Official Release of NRC RAIs for Columbia Covid Exigent Due Friday April 24, 2020 ML20034E6082020-02-0303 February 2020 NRR E-mail Capture - RAI Formal Release Columbia TSTF 563 LAR, 30 Day Response Period Due March 3, 2020 ML20028E1512020-01-27027 January 2020 Notification of Evaluations of Changes, Tests, and Experiments Inspection (Inspection Report 05000397/2020002) and Request for Information ML19267A1842019-09-24024 September 2019 Request for Information for Upcoming Open Phase Condition Inspection at Columbia Generating Station ML19232A2282019-08-20020 August 2019 NRR E-mail Capture - Formal Release of RAIs Ref: Columbia Exigent Amendment - One Electrical RAI, ML19183A4752019-07-0202 July 2019 NRR E-mail Capture - Formal Release of RAIs Ref: Columbia HVAC LAR L-2019-LLA-0034 ML18088A0152018-03-29029 March 2018 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 ML17341B0272017-12-0707 December 2017 NRR E-mail Capture - RAI Associated with Columbia Amendment Request Revise Tech Spec 5.5.12 for Permanent Extension of Type a and Type C Containment Testing Frequencies for MF9469, EPID: L-2017-LLA-0197, ILRT, LLRT LAR - New RAI Response Da ML17292A0572017-10-18018 October 2017 NRR E-mail Capture - New RWCU RAI Due Date Now November 24, 2017 ML17249A6882017-09-0606 September 2017 NRR E-mail Capture - RAIs for Columbia Relief Request RAI (MF8925), 3ISI-19 ML17205A3152017-07-20020 July 2017 Notification of Evaluations of Changes, Tests, and Experiments Inspection (05000397/2017004) and Request for Information ML17193A2192017-07-12012 July 2017 NRR E-mail Capture - Columbia RWCU LAR MF8318, Formal Release of RAIs ML17144A1702017-05-24024 May 2017 NRR E-mail Capture - NRC RAIs for Columbia Relief Request MF8922, 3ISI-16 ML17047A7492017-02-16016 February 2017 Response to Request for Additional Information, Columbia Mur LAR Evib Rais ML17006A0922017-01-0404 January 2017 NRR E-mail Capture - Eicb RAIs for Columbia Mur ML17006A0902017-01-0404 January 2017 NRR E-mail Capture - Non Proprietary Request for Additional Information Regarding Columbia Mur Power Uprate ML16356A1382016-12-21021 December 2016 NRR E-mail Capture - Columbia Mur LAR Evib RAIs Non - Proprietary Version - Revise Operating License and Technical Specifications for Measurement Uncertainty Recapture Power Uprate ML16342C4322016-12-0707 December 2016 NRR E-mail Capture - Columbia Measurement Uncertainty Recapture Power Uprate LAR Rais: Human Performance: MF8060, Formal Release for Response on Monday January 9, 2017 ML16327A1842016-11-22022 November 2016 NRR E-mail Capture - Non Proprietary Request for Additional Information Regarding Columbia Mur Power Uprate ML16323A1192016-11-16016 November 2016 NRR E-mail Capture - Eicb RAIs for Columbia Mur ML16218A3902016-08-0808 August 2016 Supplemental Information Needed for Acceptance of Requested Licensing Action, Request for Measurement Uncertainty Recapture (Mur) Power Uprate (from 3486 Mwt to 3544 Mwt) ML16194A3702016-07-11011 July 2016 Notification of NRC Triennial Heat Sink Performance Inspection 05000397/2016003 and Request for Information ML16069A3592016-03-0909 March 2016 NRR E-mail Capture - Second Round Rais: Columbia MF6042 LAR TSTF-425 ML16061A5542016-03-0101 March 2016 Notification of NRC Design Bases Inspection (05000397/2016007) and Initial Request for Information ML16061A5662016-03-0101 March 2016 Notification of Design Bases Inspection (Programs)(Inspection Report 05000397/2016008) and Initial Request for Information ML15254A2572015-09-16016 September 2015 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.1 Seismic Reevaluations ML15215A0432015-08-18018 August 2015 Request for Additional Information Associated with Near-Term Task Force Recommendation 2.1, Seismic Reevaluations ML14262A3412014-09-24024 September 2014 Request for Additional Information, Round 2, License Amendment Request to Revise TS Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level - High ML14192B0312014-08-13013 August 2014 Redacted, Request for Additional Information, Nrr/Dss/Scvb, Request to Modify Emergency Core Cooling Systems Surveillance Requirements for Low Pressure Core Spray and Low Pressure Coolant Injection Pump Flows ML14206A0112014-07-31031 July 2014 Request for Additional Information, License Amendment Request to Revise TS Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level - High 2024-01-10
[Table view] |
Text
DRAFT REQUEST FOR ADDITIONAL INFORMATION COLUMBIA GENERATING STATION EMERGENCY ACTION LEVEL SCHEME CHANGE TO NEI 99-01, REVISION 5 DOCKET NO. 50-397 By letter dated August 25, 2010, Energy Northwest - Columbia Generating Station (CGS),
(Agencywide Documents Access and Management System (ADAMS) Accession No. ML102430334) requested prior approval for a revised emergency action level (EAL) scheme for Columbia Generating Station.
CGSs letter stated that the current EAL scheme is based on generic development guidance from NUMARC/NESP-007, Methodology for Development of Emergency Action Levels, Revision 2, dated January 1992, (ADAMS Accession No. ML041120174). Since 1992, numerous enhancements and clarification efforts have been made to the generic EAL development guidance resulting in the most latest document, Nuclear Energy Institute (NEI) 99-01, Revision 5, Methodology for Development of Emergency Action Levels, (ADAMS Accession No. ML080450149), which was found to be acceptable for use as generic EAL development guidance by the Nuclear Regulatory Commission (NRC) staff by letter dated February 22, 2008 (ADAMS Accession No. ML080430535).
The proposed EAL scheme was developed using the generic development guidance from NEI 99-01, Revision 5 with numerous differences and deviations based upon design criteria applicable to CGS as well as licensee preferences for terminology, format, and other licensee desired modifications to the generic EAL scheme provided in NEI 99-01 Revision 5.
Attached are the draft requests for additional information (RAIs) to facilitate the technical review being conducted by the Operating Reactor Licensing and Outreach Branch staff. Timely and accurate response to these draft RAIs is requested.
- 1. Section 2.0, Discussion. This section does not contain information on the treatment of multiple events and classification upgrading as outlined in the endorsed guidance.
Please provide justification for this inconsistency, or revise accordingly.
- 2. Step 2.13, Validation of Indications, Reports and Conditions, step 2.13.2, states, in part, that If a meter is broke, compensatory measures should be established to monitor the affected parameter. Please explain why this implies an option versus being a requirement as stated in 10 CFR 50.54(q), or revise to state shall .
- 3. The use of the following abbreviations is considered unadvisable from a human factors perspective as their use could cause significant confusion. Please explain why the staff should consider allowing these abbreviations to be implemented, or revise to use generally accepted nomenclature.
Enclosure
- a. GE: Numerous EALs use this as an abbreviation for greater than or equal to.
Please explain, in detail, why the use of or spelling out the words will not suffice, or revise accordingly wherever used.
- b. GT: Numerous EALs use this as an abbreviation for greater than. Please explain, in detail, why the use of > or spelling out the words will not suffice, or revise accordingly wherever used.
- c. LE: Numerous EALs use this as an abbreviation for less than or equal to.
Please explain, in detail, why the use of or spelling out the words will not suffice, or revise accordingly wherever used.
- d. LT: Numerous EALs use this as an abbreviation for less than. Please explain, in detail, why the use of < or spelling out the words will not suffice, or revise accordingly wherever used.
- 4. EAL RS1.1 and RG1.1: Please explain why the CGS basis information contains information about the Radwaste Building Exhaust (WEA-RIS-14(A)) being applicable when Table R-1 shows these to not be applicable to these EALs.
- 5. EAL RG1.3: Please explain why the note related to EAL declaration timing was not incorporated in this EAL, or revise accordingly.
- 6. EAL RA3.1: Please explain, in more detail, why the Central Alarm Station (CAS) is not applicable to this EAL or revise accordingly.
- 7. EAL CU5.1 and SU6.1: Please explain how the State/County Notification (CRASH)
System will notify the NRC of a declared event at CGS or revise accordingly.
- 8. Fission Barrier Matrix: Please explain why no other site specific indicators have not been developed for this matrix, particularly when the current EAL scheme (based upon NUMARC/NESP-007) has several indicators not carried over into this proposed matrix considering that the matrix from NEI 99-01 Revision 5 is very similar.
- 9. The staff approved License Amendment No. 218 for CGS in response to the licensees application dated April 28, 2010. However, the staff finds no evidence that this amendment has been carried over into this request to revise the CGS EAL scheme.
Please explain, in detail, why this license amendment has not been carried over into this EAL scheme change request, or revise accordingly.
- 10. EAL EU1.1: The EAL states, Multi Purpose Container (MPC) CONFINEMENT BOUNDARY breach. As worded this EAL would require an actual breach of the boundary versus damage to the confinement boundary for EAL declaration. Please provide justification for this inconsistency, or revise accordingly.