ML18088A015

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

ML18088A015
Person / Time
Site:	Columbia
Issue date:	03/29/2018
From:	Mark Haire NRC/RGN-IV/DRP/RPB-A
To:	Reddemann M Energy Northwest
Alexander R
References
IR 2018010
Download: ML18088A015 (7)

See also: IR 05000397/2018010

Text

March 29, 2018

Mr. Mark E. Reddemann

Chief Executive Officer

Energy Northwest

MD 1023

P.O. Box 968

Richland, WA 99352

SUBJECT: COLUMBIA GENERATING STATION - 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

INFORMATION

Dear Mr. Reddemann:

The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC)

staff will conduct a mitigation strategies for beyond-design-basis external events, spent fuel pool

instrumentation, and emergency preparedness enhancements inspection at the Columbia

Generating Station, from June 11 - 15, 2018. The inspection will consist of two reactor

inspectors from the NRCs Region IV office, one Resident Inspector from another Region IV

reactor site, plus one of the assigned Resident Inspectors at the Columbia Generating Station

for one week. The inspection will be conducted in accordance with the NRCs Temporary

Instruction 2515/191, Inspection of the Implementation of Mitigating Strategies and Spent Fuel

Pool Instrumentation Orders, and Emergency Preparedness Communication/Staffing/Multi-Unit

Dose Assessment Plans.

Experience has shown that this inspection is resource intensive both for the NRC inspectors

and licensee staff. In order to minimize the impact to your onsite resources and to ensure a

productive inspection, we have enclosed a request for documents needed for this inspection

activity. Please note that the documents are requested to be provided by May 18, 2018. During

the onsite inspection, inspectors will verify that plans for complying with NRC Orders EA-12-049

and EA-12-051 are in place and are being implemented. Inspectors will also verify the

establishment of staffing and communications plans provided in response to the

March 12, 2012, request for information letter, and multi-unit dose assessment information

provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency

Preparedness for Japan Lessons Learned, dated March 27, 2013. These plans and information

were provided in the site specific submittals, which were subsequently reviewed by the NRC

staff for understanding and documented in the NRCs plant safety evaluations (SEs) and safety

assessments. Therefore, appropriate personnel knowledgeable of the stations FLEX

strategies, spent fuel pool instrumentation, and emergency preparedness enhancements should

be available to support the inspectors at the site during the inspection.

M. E. Reddemann 2

We have discussed the schedule for this inspection activity with your staff and understand that

our regulatory contact for this inspection will be Richard Wynegar of your Regulatory

Compliance organization. If there are any questions about this inspection or the material

requested, please contact the lead inspector, Ryan D. Alexander, by telephone at 817-200-1195

or by e-mail at ryan.alexander@nrc.gov.

This letter 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, 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.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document system

(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA Chris Newport Acting for/

Mark S. Haire, Branch Chief

Project Branch A

Division of Reactor Projects

Docket: 50-397

License: NPF-21

Enclosure:

FLEX Strategies, Spent Fuel Pool

Instrumentation, & EP Enhancements

Inspection Request for Information

Request for Information

FLEX Strategies, Spent Fuel Pool Instrumentation, & EP Enhancements Inspection

Columbia Generating Station

Inspection Report: 05000397/2018010

Inspection Dates: June 11 - 15, 2018

Inspection Procedure: Temporary Instruction 2515/191, Inspection of the

Implementation of Mitigating Strategies and Spent Fuel Pool

Instrumentation Orders, and Emergency Preparedness

Communication/Staffing/Multi-Unit Dose Assessment Plans

Inspectors: Ryan D. Alexander, Team Lead, Sr. Project Engineer, Region IV

Eduardo Uribe, Reactor Inspector, Region IV

Daniel Bradley, Sr. Resident Inspector, Callaway Plant

Gregory Kolcum, Sr. Resident Inspector, Columbia Generating

Station

Information Requested for the In-Office Preparation Week

The following information should be sent to the Region IV office in hard copy or electronic

format (use of the Certrec IMS information portal is preferred), to the attention of Ryan

Alexander, by May 18, 2018. Additionally, a copy of any material physically sent to the Region

IV office (e.g., CD/DVDs) should also be delivered to the resident inspectors office at Columbia

Generating Station. The inspectors will select specific items from the information requested

below and then request from your staff additional documents needed during the onsite

inspection week. Also, we request that you categorize the documents in your response with the

numbered list below. Please provide requested documentation electronically if possible. If

requested documents are large and only hard copy formats are available, please inform the lead

inspector, and provide subject documentation during the first day of the onsite inspection. If you

have any questions regarding this information request, please call the lead inspector as soon as

possible.

TI 2515/191 - Appendix A

A. Provide current revision of the FLEX Final Integrated Plan (i.e., current FLEX Program

Document), including any revisions since August 2017 submission to the NRC.

B. Provide the FLEX Strategy Basis Document.

C. Provide each operating, off-normal, abnormal, and/or emergency procedures where entry

into one or more FLEX Support Guidelines are initiated.

D. Provide a list and copies of every FLEX Support Guideline (FSG) or equivalent procedure

which you developed or revised to implement your mitigating strategies.

E. Provide a list of key pieces of equipment that directly perform a FLEX mitigation strategy for

core cooling, containment, and/or spent fuel pool cooling.

F. Provide a listing/summaries of plant modifications completed related to the FLEX program.

G. Provide a listing of calculations, evaluations, and 50.59 reviews related to the FLEX program

and modifications.

H. Applicable site specific hazards for the Columbia Generating Station:

1) Provide documents which show the locations and configuration of structure(s) which

store FLEX equipment.

2) Seismic

(a) Provide evaluation/evidence as to how FLEX equipment is stored to meet (i) the

stations seismic design basis (e.g., in an existing safety-related structure); (ii) in a

structure that meets the design requirements as described in ASCE 7-10, Minimum

Design Loads for Buildings and Other Structures, with a Building Risk Category of

IV; OR (iii) Outside a structure and evaluated for seismic interactions to ensure

equipment is not damaged by non-seismically robust components or structures.

(b) Provide the travel route(s) for FLEX equipment from storage location(s) to their

location(s) of use, AND evaluation(s) which demonstrate that for the potential for soil

liquefaction is not of a concern for these travel route(s).

(c) Seismic concerns for water source(s)

(1) If the FLEX water sources are seismically robust, then provide the assessment

that shows that they are.

(2) If the FLEX water sources are not seismically robust, then provide:

(a) an assessment of alternate water sources, and

(b) the procedure(s) which describe when and how to access those sources.

3) External Flooding {CGS screened-out relative to design basis external flooding hazard}

No documents requested.

4) Severe storms with high winds {CGS screened-out relative to high winds hazard}

No documents requested.

5) Snow, Ice, and Extreme Cold

For each key piece of equipment described in Item E (above) that directly performs or

implements a FLEX mitigation strategy:

(a) Provide procedures/documents demonstrating how the FLEX equipment is

maintained at a temperature within a range to ensure that it will function when called

upon.

(b) Proved procedures/documents demonstrating how the FLEX equipment can be

moved from the storage location to its deployment location during extreme snowfall

and ice storms.

6) Extreme high temperatures

For each key piece of equipment described in Item E (above) that directly performs or

implements a FLEX mitigation strategy:

(a) Provide procedures/documents which describes the high-temperature limit of the

range within which the equipment will function.

(b) Provide procedures/documents which describe how the equipment is maintained

below that limit in its storage location.

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7) Volcanic Ash

For each key piece of equipment described in Item E (above) that directly performs or

implements a FLEX mitigation strategy:

(a) Provide procedures/documents which describe how the equipment is

stored/protected from the volcanic ash fall hazard applicable to the station.

(b) Provide procedures/documents which describe how the equipment has been

evaluated to ensure manual actions required by plant personnel can be

accomplished during volcanic ash fall conditions.

(c) Provide procedures/documents which describe how the equipment is maintained

functional when providing their FLEX functions during volcanic ash fall conditions.

I. Provide the station-specific FLEX strategies time validation study(ies).

J. Provide the relevant station procedure(s)/guideline(s) which describe the testing and

maintenance program for FLEX equipment.

1) As applicable, also provide a listing of the model work orders established to conduct

period testing and maintenance activities for FLEX equipment.

NOTE - A sample of records for completed maintenance/testing activities will be

requested for review during the onsite inspection week.

K. Provide documents/procedures which describe the programmatic controls in place to ensure

that if equipment and applicable connections are unavailable (e.g., due to maintenance,

non-functionality), then compensatory measures are implemented in accordance with

guidance outlined NEI 12-06.

L. Provide the station-specific National SAFER Center Playbook

M. Relative to personnel training on FLEX strategies, provide:

1) FLEX training bases document(s)

2) Lesson plans/training documents for site emergency response leaders responsible for

the implementation of FLEX strategies.

NOTE - Records for staff completing this training may be requested for review during

the onsite inspection week.

3) Lesson plans/training documents for site personnel responsible for the execution of

mitigating strategies for BDBEEs (i.e., operators, craft personnel, security, radiation

protection, etc.).

NOTE - Records for staff completing this training may be requested for review during

the onsite inspection week.

N. A current copy of administrative procedure(s) for the Corrective Action Program,

modification program, operations procedure writing and implementation, and top-level

documents for the work control and work scheduling programs. (If FLEX related procedures

such as FSGs or the FIP/FLEX Program Document are maintained under a different

process, please include copies of those procedures.)

O. A current copy of the U/FSAR, Technical Specifications, and Technical Specification Bases

documents.

P. Listing of corrective action program document summaries generated related to FLEX

equipment, strategies, procedures, and/or training.

NOTE - Complete corrective action program documents for a selection of those included

in the summary will be requested for review during the onsite inspection week.

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Q. A copy of any audits/self-assessments related to your preparation for this inspection, as well

as any related to the implementation or maintenance of the FLEX program.

TI 2515/191 - Appendix B

R. Provide the procedures implemented for maintenance, testing, calibration, and use of the

primary and backup Spent Fuel Pool (SFP) instrumentation channels.

S. Provide lesson plans/training documents which describe the training program that address

the use, maintenance, calibration, surveillance, and the use of alternate power to the

primary and backup SFP instrument channels.

TI 2515/191 - Appendix C

T. Communications:

1) Provide documents which show that the communications system(s), technologies,

equipment and power supplies would be available from the beginning of the event and

operate during an ELAP.

2) Provide the procedures and/or guidance used to implement the communication

capabilities.

3) Provide documents which show that you have added any new communications

equipment, portable power supplies and/or systems have been added to ongoing testing

and preventative maintenance programs.

U. Staffing:

1) Provide documents which show that onsite and augmented staff will be available to

implement the strategies in response to a large scale natural event that results an ELAP

and impedes access to the site, and that functions/tasks have been appropriately

staffed.

2) Provide documents which show that the site access methods (e.g., roadways, navigable

bodies of water and dockage, airlift, etc.) expected to be available following the event

and available to the Emergency Response Organization (ERO) [as described in the

Phase 1 and 2 staffing assessments and NRC safety assessment].

3) Provide documents which show the testing, training, and drills/exercises performed by

the station to demonstrate the EROs ability to utilize the communications systems

and/or equipment.

V. Provide documents and procedures which show that your dose assessment

process/program is capable of analyzing concurrent radiological releases from all on-site

significant sources, including releases from spent fuel pools (i.e., multi-unit/multi-source

dose assessment capability).

Lead Inspector Contact Information:

Ryan D. Alexander, Sr. Project Engineer Mailing Address:

817-200-1195 U.S. NRC, Region IV

Ryan.Alexander@nrc.gov Attn: Ryan Alexander, DRP

1600 East Lamar Blvd.

Arlington, TX 76011-4511

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ML18088A015

SUNSI Review ADAMS: Sensitive Non-Publicly Available Keyword

By: MHS/dll/rdr Yes No Non-Sensitive Publicly Available NRC-002

OFFICE DRP/RPBA C:DRP/RPBA

NAME RAlexander MHaire

SIGNATURE /RA/ /RA CNewport Acting for/

DATE 03/22/2018 03/29/2018