GO2-23-019, Emergency Plan - Summary of Changes and Analysis for Revision 68 of the EP-01
| ML23039A208 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/08/2023 |
| From: | Wolfgramm D Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-23-019 | |
| Download: ML23039A208 (1) | |
Text
February 8, 2023 ENERGY NORTHWEST GO2-23-019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 205551 Desiree M. Wolfgramm Columbia Generating Station P.O. Box 968, PE20 Richland, WA 99352-0968 Ph. 509.377.4792 dmwolfgramm@energy-northwest.com 10 CFR 50.54(q)
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397;
SUMMARY
OF CHANGES AND ANALYSIS FOR REVISION 68 OF THE EP-01 COLUMBIA ~ENERATING STATION EMERGENCY PLAN
Dear Sir or Madam:
Enclosed is the summary of changes and analysis for Revision 68 of the EP-01 Columbia Generating Station Emergency Plan issued on January 26, 2023. The changes to the Emergency Plan have been evaluated in accordance with 1 0 CFR 50.54(q) and 1 0 CFR 72.44(f). The Emergency Plan, as revised, continues 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 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 Jennifer Kuklinski at (509) 377-4133.
Executed on the ~
day of 1-ibru"~
, 2023.
D.M. Wolfgramm Manager, Regulatory Affairs
Enclosure:
Summary of Changes and Analysis cc:
NRC Region IV Administrator NRC NRR Project Manager NRC Sr. Resident Inspector Director - Spent Fuel Storage & Transportation, NMSS CD Sonoda, BPA
GO2-23-019 Enclosure Summary of Changes and Analysis for Revision 66 of the Columbia Generating Station Emergency Plan
The following is a summary of changes that were made to the EPlan with revision 68.
Deleted the definition for the term "thermoluminescent dosimeter (TLD)" and added the definition of the term "dosimeter. Deleted the acronym TLD Thermoluminescent Dosimeter.
Added HP Lead to Table 2-2 (which aligns with E-Plan Section 2.3.2.j) and adjusted the number for the HP Tech (Protective Actions) to 3 which had previously included the HP Lead, as this clarifies that the HP Lead was credited as one of the listed HP Techs (Protective Actions) in Table 2.2. Added "Center" to Operations Support Manager.
Reformatted Figure 2-1, Energy Northwest Emergency Response Organization Chart.
Changed the word "process" to "progress" in definitions for Unusual Event, Alert, Site Area Emergency, and General Emergency.
Changed reference number from "*50.54(hh)" to "*50.155(b)(2)".
Page#
Change Justification for change EP Added the Term and Definition for "Dosimeter" Changing the terminology for dosimetry technology Section 1.7 from TLD to Dosimeter is to align with the ODCM Page 7 and current implementation of REMP dosimetry.
EP Deleted the Term and Definition for Changing the terminology for dosimetry technology Section 1.7 "Thermoluminescent Dosimeter (TLD)"
from TLD to Dosimeter is to align with the ODCM Page 11 and current implementation of REMP dosimetry.
EP Deleted the acronym TLD Thermoluminescent Changing the terminology for dosimetry technology Section 1.8 Dosimeter from TLD to Dosimeter is to align with the ODCM Page 13 and current implementation of REMP dosimetry.
Added HP Lead to Table 2-2 (which aligns with E-Plan Section 2.3.2.j) and adjusted the number EP for the HP Tech (Protective Actions) to 3 which had previously included the HP Lead, as this These are clarifying changes only and do not Table 2-2 clarifies that the HP Lead was credited as one change staffing requirements.
Page 36 of the listed HP Techs (Protective Actions) in Table 2.2.
Added "Center" to Operations Support Manager EP Reformatted Figure 2-1, Energy Northwest These are clarifying changes only and do not Figure 2-1 Page 37 Emergency Response Organization Chart change staffing requirements.
EP Changed the word "process" to "progress" in Section 4.4 These are clarifying changes only and not intended Pages 55, 56 definitions for Unusual Event, Alert, Site Area to change the meaning of any definition.
& 57 Emergency, and General Emergency EP Removed references to thermoluminescent Changing the terminology for dosimetry technology Section 5.1 dosimeter and added the word "dosimeter in its from TLD to Dosimeter is to align with the ODCM Page 65 place.
and current implementation of REMP dosimetry.
EP Removed references to thermoluminescent Changing the terminology for dosimetry technology Section 5.2.2 dosimeter and TLD and added the word from TLD to Dosimeter is to align with the ODCM Page 68 "dosimeter in its place.
and current implementation of REMP dosimetry.
EP Edited header of figure 5-2 from "TLD" to Changing the terminology for dosimetry technology Figure 5-2 "Dosimeter
from TLD to Dosimeter is to align with the ODCM Page 84 and current implementation of REMP dosimetry.
EP Changed reference number from "*50.54(hh)" to The reference was moved from 1 0CFR50.54(hh)(2)
Table 8-1
"*50.155(b )(2)"
to 1 0CFR50.155(b )(2) in the Code of Federal Page 124 Regulations.
Page 1 of 2
10 CFR 50.47(b)(9)-Emergency Assessment Capability (From RG-1.219)
- a. The regulation at 10 CFR 50.47(b)(9) states the following:
"Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use."
- d. The following examples would generally not require prior NRC approval:
(1) A change that replaces existing field monitoring equipment with equipment of like quality, reliability, performance, and user interface would generally not require prior NRC approval (the licensee's 10 CFR 50.54(q) evaluation must document the basis of this equivalency conclusion).
Evaluation:
The function provided by the Thermoluminescent Dosimeter (TLD) will be continued by the Optically Stimulated Luminescence (OSL) Dosimeter. The E-Plan change will only change the name of the equipment that is performing the function.
An OSL Dosimeter is an alternative to the TLD Dosimeter. The materials that are used to create a OSL Dosimeter are similar to the materials that are used to create a TLD Dosimeter (they are composed of crystalline solids). These crystalline solids are used to determine the effective dosage of radiation that an individual is exposed to.
OSL Dosimeters are commonly used for personnel dosimetry, just as TLD Dosimeters are.
OSL Dosimeters are suitable for being used for remote dosimetry, and they provide users with accurate dosimetric measurements concerning radiation levels in their immediate environment. OSL Dosimeters are typically used in situations where real-time information of radiation levels is not required. Instead, they provide a detailed record of the accumulated dose of radiation over time. These records can either be used as a comparison to field measurements, or for determining the long-term potential for various negative health effects of radiation.
The essential difference between a TLD Dosimeter and an OSL Dosimeter regarding the way that each dosimeter works is that a TLD Dosimeter requires heat in order to function, whereas an OSL Dosimeter only requires optical stimulation. An OSL Dosimeter uses aluminum oxide (Al203) in order to absorb X-ray energy, release it, and measure the precise dose of ionizing radiation that is received.
Conclusion The evaluation of the function of OSL Dosimeter against the function of the TLD Dosimeter indicates that the function of monitoring the environment and providing that information will be maintained. Therefore, a Reduction in Effectiveness will not occur.
The proposed changes do not affect planning standard 10 CFR 50.47(b)(9)-Emergency Assessment Capability or the E-Plan, because the required function remains performed by the replacement of the TLD Dosimeter with the OSL Dosimeter (Dosimeter).
The E-Plan has been evaluated to include the latest NRC approved E-Plan and subsequent changes Page 2 of 2