GO2-16-023, Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedure, Regarding Revision 19 to PPM 13.2.2, Determining Protective Action Recommendations.

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Independent Spent Fuel Storage Installation - Emergency Plan Implementing Procedure, Regarding Revision 19 to PPM 13.2.2, Determining Protective Action Recommendations.
ML16040A279
Person / Time
Site: Columbia  Energy Northwest icon.png
Issue date: 02/03/2016
From: Gregoire D
Energy Northwest
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
GO2-16-023
Download: ML16040A279 (19)
v • d • e


Text

Donald W. Gregoire

<ENERGY

....... Columbia Generating Station P.O. Box 968, PE20 Richiand, WA 99352-0968

~/NORTHWEST Ph. 509.377.86161] F. 509.377.4674 dwgregoire @energy-northwest.com FEB 032015 GO2-1 6-023 10 CFR 50.54(q)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397; INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-35; EMERGENCY PLAN IMPLEMENTING PROCEDURE (EPIP)

Dear Sir or Madam:

Revision 19 of Emergency Preparedness Implementing Procedure (EPIP) PPM 13.2.2, "Determining Protective Action Recommendations" was issued on January 5, 2016.

The changes to the procedure have been evaluated in accordance with 10 CER 50.54(q). The enclosed contains a summary of changes and evaluations performed.

These changes do not create a reduction in effectiveness of the approved emergency plan.

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.

'"(D. W. Gregoire Manager, Regulatory Affairs Executed on: ./F {(L*/J 2) 20/&

Enclosure:

1. Summary of Changes cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Sr. Resident Inspector/I988C Director - Spent Fuel Storage &Transportation, NMSS CD Sonoda, BPA / 1399 (email) 'a WA Horin - Winston & Strawn (email)

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Detail of changes made in Rev 19 of 13.2.2, Determining Protective Action Recommendations (PARs)

Summary of Changes The Columbia Generating Station Emergency Plan and EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" continues to be met with revision 19 of PPM 13.2.2, Determining Protective Action Recommendations.

PARs determination beyond 10 miles increases overall effectiveness from the previous revision. The procedure continues to meet the Columbia Generating St*.tion Emergency Plan for use of field team data if available and provides explicit direction to the Main Control Room (MCR), Technical Support Center (TSC), and Emergency Operations Facility (EOF) on how to perform PARs greater than (GT) 10 miles using dose projection. There is no change in timeliness, capability, or functionality in relation to NUREG 0654 Supplement 3 which would lead to a planning standard reduction in effectiveness for this procedure revision.

Table of revision comparisons with evaluation for potential Reduction in Effectiveness (RIE)

Rev 18 Section/IWording Rev 19 Change Comment/IEvaluation 1.0 The purpose of this procedure is to 1.0 The purpose of this procedure is to Purpose changed to meet purpose of provide instructions and guidance for the provide instructions and guidance for the procedure with no intent, commitment, formulation of onsite protective action formulation of offsite Protective Action or standard changed. Not a RIE.

decisions and offsite Protective Action Recommendations (PARs) based on plant or Recommendations (PARs) based on plant radiological conditions and determining onsite conditions or radiological releases, protective action decisions.

Page 1 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section 1Wording Rev 19 Change Comment I Evaluation 2.1 The responsibility for making Protective 2.1 The responsibility for making PARs resides No change in content, editorial rewrite.

Action Recommendations resides with the with the individual who has the responsibility of Not a RIE.

individual who has responsibility for the Emergency Director. Ifthe ERO is Emergency Direction and Control, the manned, The Emergency Director (ED) should Emergency Director. The Emergency obtain input from the Radiological Emergency Director should obtain input from the Manager (REM) in the EOF for offsite PARs, Radiation Protection Manager (RPM) in the and from the Radiation Protection Manager TSC for and recommendations for onsite (RPM) in the TSC for recommendations for protective actions, and from the Radiological onsite protective actions, ifpossible.

Emergency Manager (REM) in the EOF for and recommendations for offsite protective Emergency Response Organization actions if possible. (ERO) 2.2 PARs are based on radiological conditions 2.2 PARs are based on plant or radiological Deleted description for Plant based or plant conditions. Recommendations based conditions. PARs and Aligns step 2.2 with on plant conditions may result in more.. Recommendations for sections impacted are Attachment 7.1. No functional change.

conservative PARs. The downwind sections based on the following; Not a RI E.

evacuated for a plant based PAR (see table in *PatCniin s tahet71nt Attahmet ae tkenfromtheCGS5

71) "Downwind Section" table to define/select Evacuation Time Estimate study. h onidscins matd 2.3 For Plant Based PARS a table is used to thdonidscon)imae.

select the Downwind Sections. The table was

  • Radiological Conditions - use dose developed from information Tables 6.1 and projection program to define/select the Evacuation Time Estimate (ETE) 7.1 of the ETE. downwind section(s) impacted.________________

Page 2 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Commentl/ Evaluation 2.4 PARs are conservatively based on plant, 2.3 Additional EPZ sections should not be Deleted description. Rewording with no radiological, and meteorological conditions. recommended for evacuation unless change in intent. Not a RIE.

Additional sectors should not be evacuated conditions make it necessary to do so.

unless conditions make it necessary to do so. Expanding the evacuation zone when Expanding the evacuation zone when conditions do not require this action could conditions do not require this action presents present a greater hazard to evacuees than a greater hazard to evacuees than allowing allowing them to remain in place. Needless them to remain sheltered in place. Needless evacuation also reduces the effectiveness of evacuation also reduces the effectiveness of the offsite resources used to accommodate the the offsite resources used to accommodate evacuation.

the evacuation. Emergency Planning Zone (EPZ) 2.6 Industrial Development complex 2.5 Industrial Development Complex Deleted how part C notifications are personnel are evacuated at the Site Area personnel are evacuated at the Site Area implemented. This is a PAR procedure Emergency classification per PPM 13.5.1. Emergency classification per PPM 13.5.1. and how notifications are performed Part C Notifications implemented by the SOC does not meet purpose. IDC and PA announcements made by either SAS notification is still provided by PPM or the Security Manager meets this 13..4.1.043 step 4.1.5 Notifications requirement. procedure with Part C notification under the EP Phone Directory EPD-01.

No reduction in intent, commitment, or standard changed. Not a RIE.

Industrial Development Complex (IDC)

Security Communication Center (SCC)

Public Announcement (PA)

_____________________________ _____________________________Secondary Alarm Station (SAS)

Page 3 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment / Evaluation 2.7 Implementation of protective actions for 2.6 There are precautionary offsite protective Reformatted paragraph with no offsite areas within the 10 mile EPZ is the actions that are recommended automatically substantial change. Not a RIE.

responsibility of Benton and Franklin at the Site Area Emergency and General Counties. There are precautionary offsite Emergency classifications. These are protective actions that are implemented specified under the Site Area Emergency and automatically at Site Area Emergency and General Emergency boxes on the General Emergency classifications. These are Classification Notification Form (CNF) (Form specified under the Site Area Emergency and 24075). Ifthere are PARs in addition to General Emergency boxes (Item #5) on the those that are automatic, they are addressed Classification Notification Form (CNF) (Form for the General Emergency in box # 6a.

24075). Ifthere are PARs in addition to those Implementation of protective actions for that are automatic, they are addressed in Item offsite areas within the 10 mile EPZ is the

  1. 6 for the General Emergency. responsibility of Benton and Franklin Counties and DOE-RL officials.

2.8 The protective actions outlined in this 2.7 The protective actions outlined in this Added statement "and actions to procedure are limited to actions for minimizing procedure are limited to actions for minimizing determine PARs beyond 10 mile EPZ" the exposure of the public within the 10 mile the exposure of the public within the 10 mile which is in accordance with step 4.5.

EPZ to external and internal radiation EPZ to external and internal radiation Deleted procedure reference and exposure from plume passage or inhalation of exposure from plume passage or inhalation of added PARs beyond 10 mile EPZ. No the radioactive plume. Other protective the radioactive plume and actions to determine reduction in intent, commitment, or actions for minimizing public exposure via the PARs beyond the 10 mile EPZ. Other standard was changed. Not a RIE.

ingestion pathway will be determined and protective actions for minimizing public implemented by Energy Northwest and exposure via the ingestion pathway will be Washington State in accordance with EPIP determined and implemented by Energy 13.8.1. Northwest and Washington State.

Page 4 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment I Evaluation 2.9 Plant and offsite officials should continue 2.8 Plant and offsite officials should continue Deleted "...to locate areas with high assessment actions based on additional plant assessment actions based on additional plant levels of contamination (hot spots)."

information, dose projections, and field information, dose projections, and field The purpose of the field teams is to monitoring results. After performing the initial monitoring results. After performing the initial map the plume and minimize individual early evacuation actions near the plant, early evacuation actions near the plant, exposure (ALARA) within the plume.

licensee and offsite officials should modify licensee and offsite officials should modify their The existence of hot spots will be their protective action recommendations as protective action recommendations as provided and mapped as part of necessary based on (1) field monitoring to necessary based on field monitoring and dose defining the plume pathway. This locate areas with high levels of contamination projections, which indicate that EPA protective change does not reduce intent, (hot spots) and (2) dose projections which action guide doses may be exceeded in areas commitments, or standards but clarifies indicate that EPA protective action guide beyond those that have been evacuated. On field team responsibilities for plume doses may be exceeded in areas beyond the basis of this information, plant and offsite identification. Not a RIE.

those that have been evacuated. On the basis officials may expand the evacuations to of this information, plant and offsite officials encompass other areas in the plume EPZ and, may expand the evacuations to encompass for the worst case accidents; protective actions other areas in the plume EPZ and, for the may be required beyond the plume EPZ.

worst case accidents, protective actions may be required beyond the plume EPZ.

3.2.1 Providing radiological expertise to 3.2.1 Assess offsite doses and make Radiation Protection Manager (RPM) determine appropriate PAR based on onsite recommendations concerning protective responsibilities are not changed, the radiological conditions and/or offsite actions to the TSC Manager until the procedure update is explicit to who he conditions if the REM is unavailable. Radiological Emergency Manager at the EOF reports. No functional change. Not a takes over this function. RIE.

3.3.1 Providing radiological expertise to 3.3.1 Managing radiological dose Better delineation of responsibilities for determine appropriate PAR based on offsite assessment and field monitoring activities, the Radiological Emergency Manager radiological conditions. 3.3.2 Assists in development of PARs and, (REM) in the EOF; the function does during the late phases of the response, not change. Not a RIE.

coordinates this activity with the States of Washington and Oregon and the US DOE and provides offsite radiological PARs to the EOF Manager. ________________

Page 5 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment I Evaluation 4.2 NOTE: Do not delay recommending Added note. This is in agreement with off site protective actions for areas within the current Attachment 7.1 and is EP__Z, while waiting for field monitoring results informational only. Not a RIE.

to verify the accuracy of the dose projec~tion results.

4.2 Initial Plant Based PARs for General 4.2 Initial PARs for General Emercqencv Unified RASCAL Interface (URI)

Emergency Classifications Classifications automatically provides sector 4.2.1 REFER to Attachment 7.1, Decision 4.2.1 REFER to Attachment 7.1, Decision evacuation information at the GE Guide for Offsite Protective Action Guide for Offsite Protective Action based upon Meteorological conditions.

Recommendations to ensure appropriate Recommendations at a GE, to ensure With a release below PAG limits, the PAR is determined. appropriate PAR is determined, program will not identify evacuation

a. IF a dose projection has been made, a. IF a dose projection has been made, and sectors so table in attachment 7.1 will THEN DETERMINE appropriate downwind indicate either; be used. This is not a change from Rev section(s) based on the dose projection >-1000 mRem TEDE or >-5000 mRem 18 attachment 7.1 guidance to Rev 19 program output. CDE Thyroid (PAGs), THEN guidance. Not a RIE.
b. IF NO dose projection is made, THEN DETERMINE appropriate downwind USE the "Downwind Sections Table" in section(s) based on the dose projection attachment to determine appropriate program output.

sections. b. IF a dose projection has been made, and indicate both;

<1000 mRem TEDE and <5000 mRem CDE Thyroid (PAGs), THEN DETERMINE the appropriate downwind section(s) based on attachment 7.1 note 5 "Downwind Section" table. Total Effective Dose Equivalent

c. IF NO dose projection has been made, (TEDE)

THEN DETERMINE the appropriate Committed Effective Dose Equivalent downwind section(s) based on attachment (CEDE)

_________ ____ _____ ____ ____ ____ 7.1 note 5 "Downwind Section" table. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Page 6 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section 1Wording Rev 19 Change Comment!/Evaluation 4.2.2 INDICATE the PAR on the 4.2.2 INDICATE the PAR on the Reformatted the procedure. Not a RIE.

Classification Notification Form (CNF), Form Classification Notification Form, Form 24075 24075, (ONE).

AND MAKE the required offsite notifications in accordance with PPM 13.4.1, Emergency 4.2.5 COMPLETE the appropriate parts of Notifications. the ONF, and PERFORM the required notifications in accordance with PPM 13.4.1, Emergency Notifications._________________

4.4.4 IF there is to be a planned Release 4.2.3 IF there is to be a Controlled Release Format change only. Not a RIE.

(containment venting), THEN DISCUSS (such as containment venting), THEN proposed activity with offsite authorities to DISCUSS activity with offsite authorities to assist them with Protective Action inform them of the intent to vent the implementation, containment. _________________

4.4.5 WHEN circumstances such as 4.2.4 WHEN aware of circumstances such as Format change only. Not a RIE.

weather; distance or concurrent severe weather, or concurrent emergencies emergencies may that may impact specific areas for which impact specific areas for which PARs are PARs are being proposed, THEN INFORM being proposed, THEN INFORM the Benton the Benton and Franklin County EOCs which and Franklin County EOCs which sections sections are most affected (so that routes to are most affected so that routes to be taken be taken or avoided may be identified), or or avoided may be identified, or other special provide other special considerations in the considerations in the notification to offsite notification to offsite agencies. EegnyOeaigCne EO agencies. Emergency________Operating___ (E_____)

______enter_____

Page 7 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/IWording Rev 19 Change Comment/IEvaluation 4.3.2 CONTINUE event assessment after 4,2.6 CONTINUE event assessment after Format change only. For remaining of making the initial PAR for the General making the initial PAR for the General table, will not show format only Emergency classification based on: Emergency classification based on: changes due to step updates in new

  • available plant data,
  • available plant data, procedure. Not a RIE.
  • meteorological data
  • meteorological data
  • dose projections
  • dose projections
  • field monitoring data
  • field monitoring data 4.3 Monitor Conditions for Possible PAR Deleted this step. EOF is in the Changes process of going from status boards to
a. ENSURE PARs are indicated on the PAR computer screens. WebEOC will track Status Board by the use of colored marker. important items. This is information only and the new system is an increase in effectiveness. Not a RIE.

4.4 Updating Offsite PARs Based on 4.3 Updatingq Offsite PARs Based on Proiected Format change only, no RIE.

Projected Doses or Offsite Survey Results Doses or Offsite Field Monitoring Data 4.4.2 DETERMINE the appropriate offsite 4.3.2 DETERMINE if the dose projection or Procedure defines PAGs instead of PAR by comparing the plume projected dose survey data indicates either; >1000 mRem referencing an attachment; brings and/or Field Monitoring Team data with the TEDE or >5000 mRem CDE Thyroid (PAGs). statement in compliance with step Protective Action Guidelines (PAGs) and a. IF review of dose projections or survey 4.3.3 and as such, is not a new guidance provided in Attachment 7.1, PAGs results indicate the limit has been exceeded commitment, requirement, or changes for the Early Phase of a Nuclear Incident. in any sections not already evacuated, and the intent of the step. Not a RIE.

a. IF review of dose projections or survey evacuation is determined to be warranted, results indicate a PAG has been exceeded in THEN ISSUE a new PAR for additional any Sections not already evacuated, affected section(s).

THEN ISSUE a new PAR for additional affected Sections Page 8 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/IWording Rev 19 Change Comment/IEvaluation 4.4.6 IF any of the above actions result in a 4.3.4 IF any of the above actions result in a No substantive change, only change to established PARs, THEN change to established PARs; COMPLETE reformatting. Not a RIE.

COMPLETE the appropriate parts of the ONE, the appropriate parts of the ONE. PERFORM and make the required notifications in the required notifications in accordance with accordance with PPM 13.4.1, Emergency PPM 13.4.1, Emergency Notifications.

Notifications.

4.4 Updating Offsite PARs Based on Change Format procedure update, no new of Wind Direction with No PAG exceeded information provided. Not a RIE.

4.5 NOTE: If downwind field monitoring data Added note to PARs GT 10 miles, is not available, base PAR on dose projection emphasizes that dose assessment results. results should still be used to communicate with offsites. In agreement with EPlan, no change in

_ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ c a pab i l ity or t i m el i n ess . N ot a R IE .

Page 9 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Sectionl/Wording ~Rev 19 Change JCommentl/Evaluation 4.5.1 CONSIDER plume PARs beyond 10 4.5.1 CONSIDER plume PARs beyond 10 The procedure continues to meet the miles if dose proiections indicate PAGs at miles if dose projections indicate either; EPlan for use of field team data if 10 miles may be exceeded. >-1000 mRem TEDE or _>5000 mRem CDE available and provides explicit direction

  • For the Control Room, NOTIFY the Thyroid (PAGs), may be exceeded beyond to the Main Control Room (MCR) on offsite agencies via the Crash Phone that 10 miles. how to perform PARs GT 10 miles dose projections indicate that PAGs *For the Control Room, (Shift Manager as using dose projection. Increase in beyond 10 miles may be exceeded. Emergency Director): effectiveness from previous revision.

Indicate that the TSC or EOF will a. IF dose projections exceed PAGs Not a RIE.

formulate PARs for affected areas. beyond 10 miles, THEN OBTAIN downwind field monitoring data to verify dose projection results.

b. USE dose projection program 50 mile map to determine extent (distance) of the GE plume.
1. Determine the distance to the leading edge of the GE portion of the plume, then round up to the next whole mile.
2. Select the extended quadrant section(s).
c. MAKE Evacuation PAR to include the previously affected downwind section(s) and to the additional extent (distance beyond 10 miles) indicated for the extended quadrant section(s).
d. COMPLETE the appropriate parts of the CNF, and PERFORM the required notifications in accordance with PPM 13.4.1, Emerclencv Notifications.

Page 10 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/IWording fRev 19 Change ]Comment/IEvaluation 4.5.1 (cont) 4.5.1 (cont) Step 4.5.1.2 deleted: PARs are

  • For the TSC or EOF: *For the EOF or TSC, (EOF Manager or expected to be performed within 15 TSC Manager as Emergency Director): minutes and recommended to offsite agencies. State and counties continue
1. OBTAIN downwind field team readings to a. IF"dose projections exceed PAGs beyond to participate in ERO centers with verify dose projection results.

10 miles, THEN OBTAIN downwind field ongoing communications. This monitoring data to verify dose projection recognizes timeliness for PARs Not a

2. IF time permits, THEN CONSULT with Benton and results. RIE.

Franklin County EOCs on the b. USE dose projection program 50 mile 4.5.1 .b is a replacement for the old recommendation to evacuate beyond 10 map to determine area encompassed by precaution of 90 degree sector miles. the GE plume. boundary use and so meets step. Not

1. Determine the distance to the leading a RIE.
3. DO NOT USE 90 degree sector edge of the GE portion of the plume, 4.5.1 .d is additional information which boundaries to define the affected area then round up to the next whole mile. is in the process for notification. Not a beyond 10 miles for PARs beyond 10 RIE.

miles. 2. Select geo-political boundaries such as roads, rivers and county lines (that

4. USE geo-political boundaries such as encompass the GE portion of the roads, rivers and county lines to define plume) to define the boundaries of the the boundaries of the PAR beyond 10 PAR beyond 10 miles.

miles. c. MAKE Evacuation PAR to include the previously affected downwind section(s) an

5. INCLUDE those areas downwind where to the additional area indicated by the geo-the PAG values are projected to be political boundaries beyond 10 miles.

exceeded.

d. COMPLETE the appropriate parts of the
6. IF plume PARs are issued for areas CNF, and PERFORM the required beyond 10 miles that could affect areas notifications in accordance with PPM outside Benton and Franklin counties,. 13.4.1, Emergency Notifications.

THEN the Emergency Director should ENSURE that the State EOC is notified.

Page 11 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/Wording Rev 19 Change Comment I Evaluation References References updated with Volume 13 EOPs do not define PARs or what to procedures vice EOPs do with them unlike Volume 13 procedures, editorial. Not a RIE.

Attachment 7.1 Decision Guide for Offsite Attachment 7.1 Decision Guide for Offsite Format change. Not a RIE.

Protective Action Recommendations Protective Action Recommendations at a GE SA Asorntfo,PAP ....vauat G*ENEAL ~MERN*'Y Based upon best practices from

  • hoo * .*.;*,*,*benchmarking, incorporates 10 mile
  • Oisa, * ,,ddEPZ evacuation requirements plus
  • io *WoSA oveoc RptsttnnnoO Saa'Auldn incorporates impediment

... Meto*or**o.l,,oal Sts~o, °°l/ * " o ns-\N sesnaseoe, considerations.

The SAE automatic PARs in revision PAs(Atacreltff ,, --- 1 8 are part of the CNF form and are 7.21 are projected to be exceeded based on Dose "

PLUS no reiutyrcoveddTE EauteEAtjl.ot°o,*'*-

Cneto~tve covered by step 4.1 of the procedure RIJ o ALL r~osyr°rmneTT.H Sutlions02-2 Miles vca*2.rote rid10Mies downwind 2.1 oslias wed e (nt

t. H LR r (t

.10 dl, so are riot carried forward in the N PLUS (n0at'°=o* attachment to revision 19. Notes P0Aatcnla~tio PAR to evacuate Recreational SHELTER(noat 4)

  • .o*,E*°oo~scomplete the decision steps. Not a i RIE.

DoWnwind Sections EVACUATE(rota 31L*ensls Eracutle ALL Saclieso 01-2Mills and 10 Mites 2-too07° 5410d0 *ooo atins .atrlte eas, d.nwnvilrtdAND abetter remoatnlng Sections. .... Ot o"i (solo TI*m.6, Ste~ped AulaoralixrsPARantO Rcoolcroationel2° evacua-Lte~p o16* 4l.

147° to214' 1,.4, .+I Do*

, ,dd ,,,,,es rsku sat**,,,:,o,.

pasr~~ rke n

,,,,.,,G,,n,,aro.dejo+

  • wnyncsapo,+mp ao 4.32.

n ,=s,.

260Oto 304° 1, 2 Cotlu. esm nt-N

... ,++++ Site Area Em ergency ( AE beyoendtO Insrsler a Seams*4.4 225'to 226' . 2 -ote 9

____7__________________2,__ Notes to the flow chart continue below.

Page 12 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment/IEvaluation Note 1: Rapidly Progressing Severe Accident Detail on when standard GE PARs A rapidly progressing severe incident is a exists for the condition. Meets the General Emergency (GE) with rapid loss revision 18 attachment conditions with of containment integrity (emergency action levels indicate containment barrier more guidance. Not a RIE.

loss) and loss of ability to cool the core.

This path is used for scenarios in which containment integrity can be determined as bypassed or immediately lost during a GE with core damage.

If this scenario cannot be immediately confirmed, assume it is not taking place and answer "no" to this decision block.

A rapidly progressing severe incident may be defined as:

1. The PAR is the first after a GE has been declared.

AND

2. There is loss of the containment barrier per the Emergency Action Levels AND
3. EITHER of the following:
a. Containment Radiation Monitor CMS-RIS-27E and CMS-RIS-27F reading GT 14,000 R/Hr.

OR

b. A significant radiological release (greater than PAGs at 1.2 miles) in about

_________________________________an hour.

Page 13 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section I Wording Rev 19 Change Comment I Evaluation Note 2: Known Impediment(s) to Evacuation Incorporates planned releases due to or Controlled Release containment vent, which is an increase

  • If the General Emergency is due to in effectiveness to the last revision. Not Hostile Action, then this would be a RIE.

considered an Impediment to Evacuation. This impediment is effective until the Off-Site Incident Columbia Generating Station (CGS)

Commander has determined that conditions are safe for evacuations to proceed and communicated this to CGS Emergency Director.

  • If notified by OROs prior to beginning the PAR determination that; adverse weather, earthquake, Offsite Response Organization (0ORO) wildfire, etc... would preclude the safe or timely evacuation of the public at the time of the emergency, then that condition constitutes a known Impediment to Evacuation.
  • Controlled Release, Primary Containment venting that is performed to prevent containment failure and can be terminated within one hour. Controlled means that the release was initiated by Operator Action and can be terminated by Operator Action.

Page 14 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Sectionl/ Wording Rev 19 Change Comment I Evaluation Note 3: EVACUATE Discussion and explanation of Evacuation and control of access to evacuation, no change.

an affected area can be the most effective protective action for reducing the dose to the public unless circumstances as discussed

_____________________________________in note_2_exist.__________________

Page 15 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change jComment / Evaluation Note 4: SHELTER (Shelter in Place)

A type of protective action in which Discussion on shelter which is an increase in effectiveness over the last instructions are given to members of revision.

the public to remain indoors, turn off heating or air conditioning (as appropriate for the season), close windows, monitor communications channels, and prepare to evacuate.

Sheltering in buildings with windows and doors closed and ventilation turned off can provide partial protection from a passing radioactive plume. The extent of the protection depends on the duration and isotopic mixture of the release and the type of building.

Given that a decision could be made to Shelter for a short duration release (containment venting), it should be recognized that Shelter is a temporary measure and does not provide long-term protection from airborne radioactive materials. It loses effectiveness as interior air equalizes in concentration with the outside environment. Therefore, any recommendation for the public to Shelter should be followed by additional instructions at the appropriate time. See also note 6.

I I I Page 16 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment / Evaluation Note 5: Downwind Section(s) No change to revision 18.

Sections for the surrounding 10-mile EPZ are divided into 4 - 9Q0 sections.

Determining which section(s) that are impacted may be performed by:

,, Using dose projections software, or

  • Using the following table.

Downwind Sections Wind Sections Direction Impacted (from) ____

0120 to 0790 3 0800 to 1240 3,4 125° to 146° 4 147 0 to 2140 1,4 2150 to 2590 1 2600 to 34 04 1, 2 35 05 to 3260 2 3 2 7 0t o 0 1 1 0 3 2, 3_ _ _ _ _ _ __ _ _ _ _ _

Page 17 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment I Evaluation Note 6: Continue Assessments Format change only. Not a RIE.

Radiological and meteorological assessments should be continued and evacuation considered for any areas where dose projections or field measurements indicate that PAGs may be exceeded.

Note 7: Are Impediment(s) to Evacuation Further explanation of flow chart, Removed? And Controlled Release editorial in nature. Not a RIE.

Stopped? Both actions must be yes if either condition had occurred earlier (note 2) or the condition is not applicable. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .2 Attachment 7.2 Format changes only. Not a RIE.

]Page 18 of 18

Donald W. Gregoire

<ENERGY

....... Columbia Generating Station P.O. Box 968, PE20 Richiand, WA 99352-0968

~/NORTHWEST Ph. 509.377.86161] F. 509.377.4674 dwgregoire @energy-northwest.com FEB 032015 GO2-1 6-023 10 CFR 50.54(q)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397; INDEPENDENT SPENT FUEL STORAGE INSTALLATION, DOCKET NO. 72-35; EMERGENCY PLAN IMPLEMENTING PROCEDURE (EPIP)

Dear Sir or Madam:

Revision 19 of Emergency Preparedness Implementing Procedure (EPIP) PPM 13.2.2, "Determining Protective Action Recommendations" was issued on January 5, 2016.

The changes to the procedure have been evaluated in accordance with 10 CER 50.54(q). The enclosed contains a summary of changes and evaluations performed.

These changes do not create a reduction in effectiveness of the approved emergency plan.

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.

'"(D. W. Gregoire Manager, Regulatory Affairs Executed on: ./F {(L*/J 2) 20/&

Enclosure:

1. Summary of Changes cc: NRC Region IVAdministrator NRC NRR Project Manager NRC Sr. Resident Inspector/I988C Director - Spent Fuel Storage &Transportation, NMSS CD Sonoda, BPA / 1399 (email) 'a WA Horin - Winston & Strawn (email)

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Detail of changes made in Rev 19 of 13.2.2, Determining Protective Action Recommendations (PARs)

Summary of Changes The Columbia Generating Station Emergency Plan and EPA-400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" continues to be met with revision 19 of PPM 13.2.2, Determining Protective Action Recommendations.

PARs determination beyond 10 miles increases overall effectiveness from the previous revision. The procedure continues to meet the Columbia Generating St*.tion Emergency Plan for use of field team data if available and provides explicit direction to the Main Control Room (MCR), Technical Support Center (TSC), and Emergency Operations Facility (EOF) on how to perform PARs greater than (GT) 10 miles using dose projection. There is no change in timeliness, capability, or functionality in relation to NUREG 0654 Supplement 3 which would lead to a planning standard reduction in effectiveness for this procedure revision.

Table of revision comparisons with evaluation for potential Reduction in Effectiveness (RIE)

Rev 18 Section/IWording Rev 19 Change Comment/IEvaluation 1.0 The purpose of this procedure is to 1.0 The purpose of this procedure is to Purpose changed to meet purpose of provide instructions and guidance for the provide instructions and guidance for the procedure with no intent, commitment, formulation of onsite protective action formulation of offsite Protective Action or standard changed. Not a RIE.

decisions and offsite Protective Action Recommendations (PARs) based on plant or Recommendations (PARs) based on plant radiological conditions and determining onsite conditions or radiological releases, protective action decisions.

Page 1 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section 1Wording Rev 19 Change Comment I Evaluation 2.1 The responsibility for making Protective 2.1 The responsibility for making PARs resides No change in content, editorial rewrite.

Action Recommendations resides with the with the individual who has the responsibility of Not a RIE.

individual who has responsibility for the Emergency Director. Ifthe ERO is Emergency Direction and Control, the manned, The Emergency Director (ED) should Emergency Director. The Emergency obtain input from the Radiological Emergency Director should obtain input from the Manager (REM) in the EOF for offsite PARs, Radiation Protection Manager (RPM) in the and from the Radiation Protection Manager TSC for and recommendations for onsite (RPM) in the TSC for recommendations for protective actions, and from the Radiological onsite protective actions, ifpossible.

Emergency Manager (REM) in the EOF for and recommendations for offsite protective Emergency Response Organization actions if possible. (ERO) 2.2 PARs are based on radiological conditions 2.2 PARs are based on plant or radiological Deleted description for Plant based or plant conditions. Recommendations based conditions. PARs and Aligns step 2.2 with on plant conditions may result in more.. Recommendations for sections impacted are Attachment 7.1. No functional change.

conservative PARs. The downwind sections based on the following; Not a RI E.

evacuated for a plant based PAR (see table in *PatCniin s tahet71nt Attahmet ae tkenfromtheCGS5

71) "Downwind Section" table to define/select Evacuation Time Estimate study. h onidscins matd 2.3 For Plant Based PARS a table is used to thdonidscon)imae.

select the Downwind Sections. The table was

  • Radiological Conditions - use dose developed from information Tables 6.1 and projection program to define/select the Evacuation Time Estimate (ETE) 7.1 of the ETE. downwind section(s) impacted.________________

Page 2 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Commentl/ Evaluation 2.4 PARs are conservatively based on plant, 2.3 Additional EPZ sections should not be Deleted description. Rewording with no radiological, and meteorological conditions. recommended for evacuation unless change in intent. Not a RIE.

Additional sectors should not be evacuated conditions make it necessary to do so.

unless conditions make it necessary to do so. Expanding the evacuation zone when Expanding the evacuation zone when conditions do not require this action could conditions do not require this action presents present a greater hazard to evacuees than a greater hazard to evacuees than allowing allowing them to remain in place. Needless them to remain sheltered in place. Needless evacuation also reduces the effectiveness of evacuation also reduces the effectiveness of the offsite resources used to accommodate the the offsite resources used to accommodate evacuation.

the evacuation. Emergency Planning Zone (EPZ) 2.6 Industrial Development complex 2.5 Industrial Development Complex Deleted how part C notifications are personnel are evacuated at the Site Area personnel are evacuated at the Site Area implemented. This is a PAR procedure Emergency classification per PPM 13.5.1. Emergency classification per PPM 13.5.1. and how notifications are performed Part C Notifications implemented by the SOC does not meet purpose. IDC and PA announcements made by either SAS notification is still provided by PPM or the Security Manager meets this 13..4.1.043 step 4.1.5 Notifications requirement. procedure with Part C notification under the EP Phone Directory EPD-01.

No reduction in intent, commitment, or standard changed. Not a RIE.

Industrial Development Complex (IDC)

Security Communication Center (SCC)

Public Announcement (PA)

_____________________________ _____________________________Secondary Alarm Station (SAS)

Page 3 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment / Evaluation 2.7 Implementation of protective actions for 2.6 There are precautionary offsite protective Reformatted paragraph with no offsite areas within the 10 mile EPZ is the actions that are recommended automatically substantial change. Not a RIE.

responsibility of Benton and Franklin at the Site Area Emergency and General Counties. There are precautionary offsite Emergency classifications. These are protective actions that are implemented specified under the Site Area Emergency and automatically at Site Area Emergency and General Emergency boxes on the General Emergency classifications. These are Classification Notification Form (CNF) (Form specified under the Site Area Emergency and 24075). Ifthere are PARs in addition to General Emergency boxes (Item #5) on the those that are automatic, they are addressed Classification Notification Form (CNF) (Form for the General Emergency in box # 6a.

24075). Ifthere are PARs in addition to those Implementation of protective actions for that are automatic, they are addressed in Item offsite areas within the 10 mile EPZ is the

  1. 6 for the General Emergency. responsibility of Benton and Franklin Counties and DOE-RL officials.

2.8 The protective actions outlined in this 2.7 The protective actions outlined in this Added statement "and actions to procedure are limited to actions for minimizing procedure are limited to actions for minimizing determine PARs beyond 10 mile EPZ" the exposure of the public within the 10 mile the exposure of the public within the 10 mile which is in accordance with step 4.5.

EPZ to external and internal radiation EPZ to external and internal radiation Deleted procedure reference and exposure from plume passage or inhalation of exposure from plume passage or inhalation of added PARs beyond 10 mile EPZ. No the radioactive plume. Other protective the radioactive plume and actions to determine reduction in intent, commitment, or actions for minimizing public exposure via the PARs beyond the 10 mile EPZ. Other standard was changed. Not a RIE.

ingestion pathway will be determined and protective actions for minimizing public implemented by Energy Northwest and exposure via the ingestion pathway will be Washington State in accordance with EPIP determined and implemented by Energy 13.8.1. Northwest and Washington State.

Page 4 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment I Evaluation 2.9 Plant and offsite officials should continue 2.8 Plant and offsite officials should continue Deleted "...to locate areas with high assessment actions based on additional plant assessment actions based on additional plant levels of contamination (hot spots)."

information, dose projections, and field information, dose projections, and field The purpose of the field teams is to monitoring results. After performing the initial monitoring results. After performing the initial map the plume and minimize individual early evacuation actions near the plant, early evacuation actions near the plant, exposure (ALARA) within the plume.

licensee and offsite officials should modify licensee and offsite officials should modify their The existence of hot spots will be their protective action recommendations as protective action recommendations as provided and mapped as part of necessary based on (1) field monitoring to necessary based on field monitoring and dose defining the plume pathway. This locate areas with high levels of contamination projections, which indicate that EPA protective change does not reduce intent, (hot spots) and (2) dose projections which action guide doses may be exceeded in areas commitments, or standards but clarifies indicate that EPA protective action guide beyond those that have been evacuated. On field team responsibilities for plume doses may be exceeded in areas beyond the basis of this information, plant and offsite identification. Not a RIE.

those that have been evacuated. On the basis officials may expand the evacuations to of this information, plant and offsite officials encompass other areas in the plume EPZ and, may expand the evacuations to encompass for the worst case accidents; protective actions other areas in the plume EPZ and, for the may be required beyond the plume EPZ.

worst case accidents, protective actions may be required beyond the plume EPZ.

3.2.1 Providing radiological expertise to 3.2.1 Assess offsite doses and make Radiation Protection Manager (RPM) determine appropriate PAR based on onsite recommendations concerning protective responsibilities are not changed, the radiological conditions and/or offsite actions to the TSC Manager until the procedure update is explicit to who he conditions if the REM is unavailable. Radiological Emergency Manager at the EOF reports. No functional change. Not a takes over this function. RIE.

3.3.1 Providing radiological expertise to 3.3.1 Managing radiological dose Better delineation of responsibilities for determine appropriate PAR based on offsite assessment and field monitoring activities, the Radiological Emergency Manager radiological conditions. 3.3.2 Assists in development of PARs and, (REM) in the EOF; the function does during the late phases of the response, not change. Not a RIE.

coordinates this activity with the States of Washington and Oregon and the US DOE and provides offsite radiological PARs to the EOF Manager. ________________

Page 5 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment I Evaluation 4.2 NOTE: Do not delay recommending Added note. This is in agreement with off site protective actions for areas within the current Attachment 7.1 and is EP__Z, while waiting for field monitoring results informational only. Not a RIE.

to verify the accuracy of the dose projec~tion results.

4.2 Initial Plant Based PARs for General 4.2 Initial PARs for General Emercqencv Unified RASCAL Interface (URI)

Emergency Classifications Classifications automatically provides sector 4.2.1 REFER to Attachment 7.1, Decision 4.2.1 REFER to Attachment 7.1, Decision evacuation information at the GE Guide for Offsite Protective Action Guide for Offsite Protective Action based upon Meteorological conditions.

Recommendations to ensure appropriate Recommendations at a GE, to ensure With a release below PAG limits, the PAR is determined. appropriate PAR is determined, program will not identify evacuation

a. IF a dose projection has been made, a. IF a dose projection has been made, and sectors so table in attachment 7.1 will THEN DETERMINE appropriate downwind indicate either; be used. This is not a change from Rev section(s) based on the dose projection >-1000 mRem TEDE or >-5000 mRem 18 attachment 7.1 guidance to Rev 19 program output. CDE Thyroid (PAGs), THEN guidance. Not a RIE.
b. IF NO dose projection is made, THEN DETERMINE appropriate downwind USE the "Downwind Sections Table" in section(s) based on the dose projection attachment to determine appropriate program output.

sections. b. IF a dose projection has been made, and indicate both;

<1000 mRem TEDE and <5000 mRem CDE Thyroid (PAGs), THEN DETERMINE the appropriate downwind section(s) based on attachment 7.1 note 5 "Downwind Section" table. Total Effective Dose Equivalent

c. IF NO dose projection has been made, (TEDE)

THEN DETERMINE the appropriate Committed Effective Dose Equivalent downwind section(s) based on attachment (CEDE)

_________ ____ _____ ____ ____ ____ 7.1 note 5 "Downwind Section" table. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Page 6 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section 1Wording Rev 19 Change Comment!/Evaluation 4.2.2 INDICATE the PAR on the 4.2.2 INDICATE the PAR on the Reformatted the procedure. Not a RIE.

Classification Notification Form (CNF), Form Classification Notification Form, Form 24075 24075, (ONE).

AND MAKE the required offsite notifications in accordance with PPM 13.4.1, Emergency 4.2.5 COMPLETE the appropriate parts of Notifications. the ONF, and PERFORM the required notifications in accordance with PPM 13.4.1, Emergency Notifications._________________

4.4.4 IF there is to be a planned Release 4.2.3 IF there is to be a Controlled Release Format change only. Not a RIE.

(containment venting), THEN DISCUSS (such as containment venting), THEN proposed activity with offsite authorities to DISCUSS activity with offsite authorities to assist them with Protective Action inform them of the intent to vent the implementation, containment. _________________

4.4.5 WHEN circumstances such as 4.2.4 WHEN aware of circumstances such as Format change only. Not a RIE.

weather; distance or concurrent severe weather, or concurrent emergencies emergencies may that may impact specific areas for which impact specific areas for which PARs are PARs are being proposed, THEN INFORM being proposed, THEN INFORM the Benton the Benton and Franklin County EOCs which and Franklin County EOCs which sections sections are most affected (so that routes to are most affected so that routes to be taken be taken or avoided may be identified), or or avoided may be identified, or other special provide other special considerations in the considerations in the notification to offsite notification to offsite agencies. EegnyOeaigCne EO agencies. Emergency________Operating___ (E_____)

______enter_____

Page 7 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/IWording Rev 19 Change Comment/IEvaluation 4.3.2 CONTINUE event assessment after 4,2.6 CONTINUE event assessment after Format change only. For remaining of making the initial PAR for the General making the initial PAR for the General table, will not show format only Emergency classification based on: Emergency classification based on: changes due to step updates in new

  • available plant data,
  • available plant data, procedure. Not a RIE.
  • meteorological data
  • meteorological data
  • dose projections
  • dose projections
  • field monitoring data
  • field monitoring data 4.3 Monitor Conditions for Possible PAR Deleted this step. EOF is in the Changes process of going from status boards to
a. ENSURE PARs are indicated on the PAR computer screens. WebEOC will track Status Board by the use of colored marker. important items. This is information only and the new system is an increase in effectiveness. Not a RIE.

4.4 Updating Offsite PARs Based on 4.3 Updatingq Offsite PARs Based on Proiected Format change only, no RIE.

Projected Doses or Offsite Survey Results Doses or Offsite Field Monitoring Data 4.4.2 DETERMINE the appropriate offsite 4.3.2 DETERMINE if the dose projection or Procedure defines PAGs instead of PAR by comparing the plume projected dose survey data indicates either; >1000 mRem referencing an attachment; brings and/or Field Monitoring Team data with the TEDE or >5000 mRem CDE Thyroid (PAGs). statement in compliance with step Protective Action Guidelines (PAGs) and a. IF review of dose projections or survey 4.3.3 and as such, is not a new guidance provided in Attachment 7.1, PAGs results indicate the limit has been exceeded commitment, requirement, or changes for the Early Phase of a Nuclear Incident. in any sections not already evacuated, and the intent of the step. Not a RIE.

a. IF review of dose projections or survey evacuation is determined to be warranted, results indicate a PAG has been exceeded in THEN ISSUE a new PAR for additional any Sections not already evacuated, affected section(s).

THEN ISSUE a new PAR for additional affected Sections Page 8 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/IWording Rev 19 Change Comment/IEvaluation 4.4.6 IF any of the above actions result in a 4.3.4 IF any of the above actions result in a No substantive change, only change to established PARs, THEN change to established PARs; COMPLETE reformatting. Not a RIE.

COMPLETE the appropriate parts of the ONE, the appropriate parts of the ONE. PERFORM and make the required notifications in the required notifications in accordance with accordance with PPM 13.4.1, Emergency PPM 13.4.1, Emergency Notifications.

Notifications.

4.4 Updating Offsite PARs Based on Change Format procedure update, no new of Wind Direction with No PAG exceeded information provided. Not a RIE.

4.5 NOTE: If downwind field monitoring data Added note to PARs GT 10 miles, is not available, base PAR on dose projection emphasizes that dose assessment results. results should still be used to communicate with offsites. In agreement with EPlan, no change in

_ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ c a pab i l ity or t i m el i n ess . N ot a R IE .

Page 9 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Sectionl/Wording ~Rev 19 Change JCommentl/Evaluation 4.5.1 CONSIDER plume PARs beyond 10 4.5.1 CONSIDER plume PARs beyond 10 The procedure continues to meet the miles if dose proiections indicate PAGs at miles if dose projections indicate either; EPlan for use of field team data if 10 miles may be exceeded. >-1000 mRem TEDE or _>5000 mRem CDE available and provides explicit direction

  • For the Control Room, NOTIFY the Thyroid (PAGs), may be exceeded beyond to the Main Control Room (MCR) on offsite agencies via the Crash Phone that 10 miles. how to perform PARs GT 10 miles dose projections indicate that PAGs *For the Control Room, (Shift Manager as using dose projection. Increase in beyond 10 miles may be exceeded. Emergency Director): effectiveness from previous revision.

Indicate that the TSC or EOF will a. IF dose projections exceed PAGs Not a RIE.

formulate PARs for affected areas. beyond 10 miles, THEN OBTAIN downwind field monitoring data to verify dose projection results.

b. USE dose projection program 50 mile map to determine extent (distance) of the GE plume.
1. Determine the distance to the leading edge of the GE portion of the plume, then round up to the next whole mile.
2. Select the extended quadrant section(s).
c. MAKE Evacuation PAR to include the previously affected downwind section(s) and to the additional extent (distance beyond 10 miles) indicated for the extended quadrant section(s).
d. COMPLETE the appropriate parts of the CNF, and PERFORM the required notifications in accordance with PPM 13.4.1, Emerclencv Notifications.

Page 10 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/IWording fRev 19 Change ]Comment/IEvaluation 4.5.1 (cont) 4.5.1 (cont) Step 4.5.1.2 deleted: PARs are

  • For the TSC or EOF: *For the EOF or TSC, (EOF Manager or expected to be performed within 15 TSC Manager as Emergency Director): minutes and recommended to offsite agencies. State and counties continue
1. OBTAIN downwind field team readings to a. IF"dose projections exceed PAGs beyond to participate in ERO centers with verify dose projection results.

10 miles, THEN OBTAIN downwind field ongoing communications. This monitoring data to verify dose projection recognizes timeliness for PARs Not a

2. IF time permits, THEN CONSULT with Benton and results. RIE.

Franklin County EOCs on the b. USE dose projection program 50 mile 4.5.1 .b is a replacement for the old recommendation to evacuate beyond 10 map to determine area encompassed by precaution of 90 degree sector miles. the GE plume. boundary use and so meets step. Not

1. Determine the distance to the leading a RIE.
3. DO NOT USE 90 degree sector edge of the GE portion of the plume, 4.5.1 .d is additional information which boundaries to define the affected area then round up to the next whole mile. is in the process for notification. Not a beyond 10 miles for PARs beyond 10 RIE.

miles. 2. Select geo-political boundaries such as roads, rivers and county lines (that

4. USE geo-political boundaries such as encompass the GE portion of the roads, rivers and county lines to define plume) to define the boundaries of the the boundaries of the PAR beyond 10 PAR beyond 10 miles.

miles. c. MAKE Evacuation PAR to include the previously affected downwind section(s) an

5. INCLUDE those areas downwind where to the additional area indicated by the geo-the PAG values are projected to be political boundaries beyond 10 miles.

exceeded.

d. COMPLETE the appropriate parts of the
6. IF plume PARs are issued for areas CNF, and PERFORM the required beyond 10 miles that could affect areas notifications in accordance with PPM outside Benton and Franklin counties,. 13.4.1, Emergency Notifications.

THEN the Emergency Director should ENSURE that the State EOC is notified.

Page 11 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section/Wording Rev 19 Change Comment I Evaluation References References updated with Volume 13 EOPs do not define PARs or what to procedures vice EOPs do with them unlike Volume 13 procedures, editorial. Not a RIE.

Attachment 7.1 Decision Guide for Offsite Attachment 7.1 Decision Guide for Offsite Format change. Not a RIE.

Protective Action Recommendations Protective Action Recommendations at a GE SA Asorntfo,PAP ....vauat G*ENEAL ~MERN*'Y Based upon best practices from

  • hoo * .*.;*,*,*benchmarking, incorporates 10 mile
  • Oisa, * ,,ddEPZ evacuation requirements plus
  • io *WoSA oveoc RptsttnnnoO Saa'Auldn incorporates impediment

... Meto*or**o.l,,oal Sts~o, °°l/ * " o ns-\N sesnaseoe, considerations.

The SAE automatic PARs in revision PAs(Atacreltff ,, --- 1 8 are part of the CNF form and are 7.21 are projected to be exceeded based on Dose "

PLUS no reiutyrcoveddTE EauteEAtjl.ot°o,*'*-

Cneto~tve covered by step 4.1 of the procedure RIJ o ALL r~osyr°rmneTT.H Sutlions02-2 Miles vca*2.rote rid10Mies downwind 2.1 oslias wed e (nt

t. H LR r (t

.10 dl, so are riot carried forward in the N PLUS (n0at'°=o* attachment to revision 19. Notes P0Aatcnla~tio PAR to evacuate Recreational SHELTER(noat 4)

  • .o*,E*°oo~scomplete the decision steps. Not a i RIE.

DoWnwind Sections EVACUATE(rota 31L*ensls Eracutle ALL Saclieso 01-2Mills and 10 Mites 2-too07° 5410d0 *ooo atins .atrlte eas, d.nwnvilrtdAND abetter remoatnlng Sections. .... Ot o"i (solo TI*m.6, Ste~ped AulaoralixrsPARantO Rcoolcroationel2° evacua-Lte~p o16* 4l.

147° to214' 1,.4, .+I Do*

, ,dd ,,,,,es rsku sat**,,,:,o,.

pasr~~ rke n

,,,,.,,G,,n,,aro.dejo+

  • wnyncsapo,+mp ao 4.32.

n ,=s,.

260Oto 304° 1, 2 Cotlu. esm nt-N

... ,++++ Site Area Em ergency ( AE beyoendtO Insrsler a Seams*4.4 225'to 226' . 2 -ote 9

____7__________________2,__ Notes to the flow chart continue below.

Page 12 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment/IEvaluation Note 1: Rapidly Progressing Severe Accident Detail on when standard GE PARs A rapidly progressing severe incident is a exists for the condition. Meets the General Emergency (GE) with rapid loss revision 18 attachment conditions with of containment integrity (emergency action levels indicate containment barrier more guidance. Not a RIE.

loss) and loss of ability to cool the core.

This path is used for scenarios in which containment integrity can be determined as bypassed or immediately lost during a GE with core damage.

If this scenario cannot be immediately confirmed, assume it is not taking place and answer "no" to this decision block.

A rapidly progressing severe incident may be defined as:

1. The PAR is the first after a GE has been declared.

AND

2. There is loss of the containment barrier per the Emergency Action Levels AND
3. EITHER of the following:
a. Containment Radiation Monitor CMS-RIS-27E and CMS-RIS-27F reading GT 14,000 R/Hr.

OR

b. A significant radiological release (greater than PAGs at 1.2 miles) in about

_________________________________an hour.

Page 13 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section I Wording Rev 19 Change Comment I Evaluation Note 2: Known Impediment(s) to Evacuation Incorporates planned releases due to or Controlled Release containment vent, which is an increase

  • If the General Emergency is due to in effectiveness to the last revision. Not Hostile Action, then this would be a RIE.

considered an Impediment to Evacuation. This impediment is effective until the Off-Site Incident Columbia Generating Station (CGS)

Commander has determined that conditions are safe for evacuations to proceed and communicated this to CGS Emergency Director.

  • If notified by OROs prior to beginning the PAR determination that; adverse weather, earthquake, Offsite Response Organization (0ORO) wildfire, etc... would preclude the safe or timely evacuation of the public at the time of the emergency, then that condition constitutes a known Impediment to Evacuation.
  • Controlled Release, Primary Containment venting that is performed to prevent containment failure and can be terminated within one hour. Controlled means that the release was initiated by Operator Action and can be terminated by Operator Action.

Page 14 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Sectionl/ Wording Rev 19 Change Comment I Evaluation Note 3: EVACUATE Discussion and explanation of Evacuation and control of access to evacuation, no change.

an affected area can be the most effective protective action for reducing the dose to the public unless circumstances as discussed

_____________________________________in note_2_exist.__________________

Page 15 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change jComment / Evaluation Note 4: SHELTER (Shelter in Place)

A type of protective action in which Discussion on shelter which is an increase in effectiveness over the last instructions are given to members of revision.

the public to remain indoors, turn off heating or air conditioning (as appropriate for the season), close windows, monitor communications channels, and prepare to evacuate.

Sheltering in buildings with windows and doors closed and ventilation turned off can provide partial protection from a passing radioactive plume. The extent of the protection depends on the duration and isotopic mixture of the release and the type of building.

Given that a decision could be made to Shelter for a short duration release (containment venting), it should be recognized that Shelter is a temporary measure and does not provide long-term protection from airborne radioactive materials. It loses effectiveness as interior air equalizes in concentration with the outside environment. Therefore, any recommendation for the public to Shelter should be followed by additional instructions at the appropriate time. See also note 6.

I I I Page 16 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment / Evaluation Note 5: Downwind Section(s) No change to revision 18.

Sections for the surrounding 10-mile EPZ are divided into 4 - 9Q0 sections.

Determining which section(s) that are impacted may be performed by:

,, Using dose projections software, or

  • Using the following table.

Downwind Sections Wind Sections Direction Impacted (from) ____

0120 to 0790 3 0800 to 1240 3,4 125° to 146° 4 147 0 to 2140 1,4 2150 to 2590 1 2600 to 34 04 1, 2 35 05 to 3260 2 3 2 7 0t o 0 1 1 0 3 2, 3_ _ _ _ _ _ __ _ _ _ _ _

Page 17 of 18

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EPIPs)

Rev 18 Section / Wording Rev 19 Change Comment I Evaluation Note 6: Continue Assessments Format change only. Not a RIE.

Radiological and meteorological assessments should be continued and evacuation considered for any areas where dose projections or field measurements indicate that PAGs may be exceeded.

Note 7: Are Impediment(s) to Evacuation Further explanation of flow chart, Removed? And Controlled Release editorial in nature. Not a RIE.

Stopped? Both actions must be yes if either condition had occurred earlier (note 2) or the condition is not applicable. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .2 Attachment 7.2 Format changes only. Not a RIE.

]Page 18 of 18

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