GO2-19-002, Summary of Changes and Analysis for Revision 66 of EP-01, Emergency Plan, and Revision 34 of PPM 13.1.1.A, Classifying the Emergency - Technical Bases and Revision 18 of PPM 13.13.2, Emergency Event Termination and Recovery
| ML19010A407 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/10/2019 |
| From: | Gregoire D Energy Northwest |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| GO2-19-002 | |
| Download: ML19010A407 (9) | |
Text
ENERGY Donald W. Gregoire Columbia Generating Station P.O. Box 968, PE20 NORTHWEST Richland, WA 99352-0968 Ph. 509.377.86161 F. 509.377.4674 dwgregoire@energy-northwest.com January 10, 2019 G02-19-002 10 CFR 50.54(q)
U.S. Nuclear Regulatory Commission A TIN : Document Control Desk Washington, D.C. 205551
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397, INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-35;
SUMMARY
OF CHANGES AND ANALYSIS FOR REVISION 66 OF EP-01, COLUMBIA GENERATING STATION EMERGENCY PLAN, AND REVISION 34 OF PPM 13.1.1.A, CLASSIFYING THE EMERGENCY - TECHNICAL BASES
- AND REVISION 18 OF PPM 13.13.2, EMERGENCY EVENT TERMINATION AND RECOVERY
Dear Sir or Madam:
Enclosed is the summary of changes and analysis for Revision 66 of the Columbia Generating Station Emergency Plan (EPlan), Revision 34 of Plant Procedures Manual (PPM) 13.1.1.A Classifying the Emergency - Technical Bases and Revision 18 of PPM 13.13.2 Emergency Event Termination And Recovery issued on December 18, 2018.
The changes to the EPlan and PPM have been evaluated in accordance with 10 CFR 50.54(q) and 10 CFR 72.44(f). The EPlan and PPMs, as revised, continue to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50 Appendix E. The Enclosure contains a summary of changes and evaluations performed. Each change was evaluated in accordance with the station's 10 CFR 50.54(q) evaluation process.
These changes do not create a Reduction in Effectiveness of the approved EPlan.
This submittal contains no new or revised regulatory commitments. Should you have any questions or desire additional information regarding these matters, please contact Sean E. Clizbe at (509) 377-4398.
Executed on the /0-th day of 3(./\<X<C( , 2019.
~ 'kc .
D. W. Gregoire ~
Manager, Regulatory Affairs
GO-19-002 Page 2
Enclosure:
Summary of Changes and Analysis cc: NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector / 988C Director - Spent Fuel Storage & Transportation, NMSS CD Sonoda, BPA / 1399 (email)
WA Horin - Winston & Strawn (email)
Enclosure Summary of Changes and Analysis The change to the Emergency Plan (EPlan) and EPIP 13.1.1A, CLASSIFYING THE EMERGENCY - TECHNICAL BASES: (HU2.1 Bases), which supports the replacement of the Plant Seismic Instrumentation under EC 15891 impacting 10 CFR 50.47(b)(4). The EPlan and EPIP 13.13.2 include an update that impacts planning standards 10 CFR 50.47(b)(13), to eliminate recovery plan review by the Corporate Nuclear Safety Review Board (CNSRB). The Recovery Plan is coordinated with the State, Department of Energy -
Richland (DOE-RL), Counties, Federal Emergency Management Administration (FEMA), and Nuclear Regulatory Commission (NRC).
These organizations will continue to review the results of the recovery plan and provide input to the Recovery Manager who will assess and implement those activities deemed necessary for safe recovery operations. The EPlan is also being updated for editorial changes such as updating titles and updating internal processes which do not contribute to public health and safety. These changes do not change compliance with regulation; they do not impact timeliness and capability of the EPlan or planning standards. Therefore, these changes do not represent a Reduction in Effectiveness (RIE) to implement the EPlan to protect the health and safety of the public. The change to the EAL HU2.1 bases is in compliance with NEI 99-01 Revision 6 and updating the description of the seismic instrumentation is a difference and not a deviation and can be implemented under the 10 CFR 50.54(q) process.
Change Doc Original Language New Language Change Justification No. Sectio n#
1 13.1.1A CGS has seismic instrumentation Original description included information CGS seismic instrumentation HU2.1 which detects and provides on the Minimum Seismic Earthquake.
consists of a Kinemetrics SMA-alarms for earthquakes. The This is no longer in our current EAL 3 Strong Motion Accelerograph seismic instrumentation provides scheme. The new wording also and associated sensors that indication of an earthquake to the describes the seismic instrumentation are equipped with seismic Main Control Room via receipt of system and its output. Added new triggers set to initiate recording an alarm from H13.P851.S1.5-1 current references. This change is in at an acceleration equal to or (OPERATING BASIS compliance with NEI 99-01 Rev 6 and exceeding 0.01 g (ref. 1, 2).
EARTHQUAKE EXCEEDED). therefore constitutes a difference and not This also annunciates the (ref. 1, 2, 3, 4) a deviation. No change in capability or seismic activity alarm timeliness for declaring the Unusual H13.P851.S1.2-5 Minimum CGS Basis Reference(s):
Event HU2.1, therefore not an RIE.
Seismic Earthquake Exceeded 1. CGS FSAR Section 3.7.4, (ref. 2, 3, 4).
Seismic Instrumentation
A seismic switch unit that is 2. Reg. Guide 1.12, similar to the seismic trigger Instrumentation for unit is also provided. The trip Earthquakes point of the seismic switch unit 3. PPM 4.851.S1-5.1, is set at the maximum Operating Basis acceleration corresponding to Earthquake Exceeded the OBE, and it provides 4. ABN-EARTHQUAKE, immediate Control Room Earthquake annunciation that the OBE has 5. NEI 99-01, HU2 been exceeded requiring declaration of an Unusual Event (ref. 1, 3, 4)
CGS Basis Reference(s):
- 2. ISP-SEIS-M201 Seismic Systems Channel Check
- 3. PPM 4.851.S1.2-5 Minimum Seismic Earthquake 2 EPlan Editorials such as figure and Editorials such as figure and table Editorial Changes per SWP-PRO-01and table title placement, title placement, capitalization, 02 include: obvious typographical errors, Various capitalization, clarifications, clarifications, reference and title including EPN errors and misplaced reference and title updates. updates. decimals, title changes, obvious grammatical errors, obvious incorrect units of measure, obvious errors in step EPIP and table references. These types of 13.13.2 changes do not impact timeliness or Step capability and therefore are not a RIE.
5.2.2
3 EPlan The offsite representative will The offsite representative will The Site Support Manager provides report to the Site Support report to the Engineering Logistical Support to the ERO, whereas 2.4.2.j Manager. Manager. the Engineering Manager provides Technical Support and assistance to the ERO. The alignment of the EN Reps to the State and County EOC allows for an individual of a more technical nature to be available for questions and communication necessary between the EOCs and the EOF. This is an enhancement because of the technical alignment of the EN reps and Engineering Manager. This is not an RIE.
4 EPlan The General Electric Company, The General Electric Company, Because this organization is a contact suppliers of the Columbia suppliers of the Columbia and not an emergency response 3.3.2 Generating Station nuclear Generating Station nuclear steam organization, their location does not steam supply system, provides supply system, provides a support impact implementation of the EPlan. This a support program utilizing the program utilizing the resources of change does not impact timeliness or resources of their Nuclear their Nuclear Energy Group. capability of the EPlan and therefore is Energy Group in San Jose, not an RIE.
5 EPlan Instrumentation used to monitor Instrumentation used to monitor EC 15891 removes the printout function earthquake seismic motion at earthquake seismic motion at and replaces it with a computer which 5.1.1 Columbia Generating Station Columbia Generating Station has capability to store and retrieve data, complies with Regulatory Guide complies with Regulatory Guide including printing the data. This printout 1.12 requirements and provides 1.12 requirements and provides was never used for classification or both a printout and an alarm alarm annunciation if certain provided to the ERO or ORO and
annunciation if certain levels of levels of seismic motion are therefore does not change timeliness or seismic motion are detected. detected. capability. This change does not create a RIE.
6 EPlan Corporate Nuclear Safety Following a Site Area Emergency 10 CFR 50.47 (b)(13) Recovery Actions:
Review Board (CNSRB) will or General Emergency, the 7.3 review and comment on the Recovery Manager will assure The Recovery Manager will implement recovery planning effort to that all nuclear safety aspects of activities deemed appropriate as part of assure that all nuclear safety the recovery are satisfied. the Recovery Plan. CNSRB review is aspects of the recovery are not required to be performed prior to satisfied (The CNSRB will implementing Recovery Plan activities.
report their findings to the While the elimination of CNSRB does Recovery Manager, who shall represent a lost additional layer of take the actions deemed overview, CNSRB is not necessary or appropriate for safe recovery required for the implementation of the operations.) Recovery Plan to ensure public health &
safety. The Recovery Plan is collaborated with the state, counties, DOE-RL, FEMA, and NRC. These EPlan Coordinate with the CNSRB to Ensure adequate review of the organizations will continue to review the ensure adequate review of engineering activities in the results of the recovery plan and provide 7.3.2 c.
engineering activities recovery plan and implementing input to the Recovery Manager who will and proper review and approval procedures. assess and implement those activities of the recovery plan and deemed necessary for safe recovery implementing procedures. operations.
EPIP Coordinate with the Corporate Ensure adequate review of the There remains adequate overview and 13.13.2 Nuclear Safety Review Board engineering activities in the approval process for the Recovery Plan (CNSRB) to ensure adequate recovery plan and implementing via these organizations.
Step review of engineering activities procedures. There is no reduction in capability or 3.2 and proper review and approval timeliness for the development or of the recovery plan and implementation of the Recovery Plan.
implementing procedures. (continued on next page)
EPIP Following a Site Area Following a Site Area Emergency (continued)
13.13.2 Emergency or General or General Emergency, the Therefore, this change does not Emergency, the CNSRB Recovery Manager will assure represent an RIE for implementation of Step REVIEWS AND COMMENTS that all nuclear safety aspects of the Emergency Plan.
4.2.11 on the recovery planning effort the recovery are satisfied.
to assure that all nuclear safety aspects of the recovery effort are satisfied and addressed per 6 SWP-IRB-02.
Contd EPIP The CNSRB REPORTS their Deleted 13.13.2 findings to the Recovery Manager, who shall take the Step 4.2.12 actions, deemed appropriate for safe recovery operations.
Step SWP-IRP-02, Corporate 5.2.2 Nuclear Safety Review Board 7 EPlan The Manager, Emergency Deleted 10 CFR 50.47(b)(16):
Preparedness provides a The EPlan is a controlled document. The 8.2 distribution list of all process for distribution is controlled organizations and individuals under CGS SWP-DOC-01. This with responsibility for distribution process is the means that implementation of the makes the plan available to all ERO Emergency Plan. The personnel thru Portal J. This is a process Emergency Plan and all description and does not impact subsequent revisions are then timeliness or capability to protect public distributed through a manuals health and safety and therefore is not a control system which verifies RIE.
receipt of the revisions by the implementing organization or individual. Revised pages are dated and marked to indicate where changes have occurred.
If no revisions have occurred,
the Manager, Emergency Preparedness, will certify by letter to all Emergency Plan manual holders that the plan and supporting agreements have been reviewed and are current.
8 EPlan The Plant Operations The Plant Operations Committee Refer to Section 7.3 of this document Committee is responsible for is responsible for reviewing any 8.2 reviewing any proposed proposed changes.
changes and submittal of the proposed revision to the Corporate Nuclear Safety Review Board.
9 EPlan The Corporate Nuclear Safety Review of audits will be 8.3 Review Board has the performed in accordance with responsibility to review the OQAPD.
Emergency Preparedness Program audit findings to determine if the conduct is adequate, and if the audit responses are appropriate and timely. The Board may expand these audit activities if necessary.
CNSRB Summary 10 CFR 50 Appendix E, EPlan. These changes do NOT delete or contradict a regulatory requirement.
10 CFR 50.47(b)(13) Recovery Actions. Removal of CNSRB does not delete or contradict the planning standard. The EPlan and EPIP 13.13.2 include an update that impacts planning standards 10 CFR 50.47(b)(13), to eliminate recovery plan review by the Corporate Nuclear Safety Review Board (CNSRB). The Recovery Plan is coordinated with the State, Department of Energy - Richland (DOE-RL),
Counties, Federal Emergency Management Administration (FEMA), and Nuclear Regulatory Commission (NRC). These organizations will continue to review the results of the recovery plan and provide input to the Recovery Manager who will assess and implement those activities deemed necessary for safe recovery operations.
10 CFR 50.54(t) will continue to be met by the Quality Assurance department.
These changes to the Emergency Plan do not reduce the effectiveness of the plan; the EPlan continues to meet the requirements of 10 CFR 50, Appendix E; the planning standards of 10 CFR 50.47(b) are not impacted by the changes. The overall purpose of the plan to provide a structure that establishes the emergency preparedness concepts and protective actions necessary to limit the consequences of radiation accidents and other emergencies thereby ensuring the safety of the general public while safeguarding plant personnel and property is still maintained following these changes. No decrease in effectiveness is involved and compliance with the CFR is maintained following these changes.