GO2-25-067, Summary of Changes and Analysis for Revision 69 of the EP-01 Emergency Plan
| ML25099A214 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/09/2025 |
| From: | Dunham Z Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-25-067 | |
| Download: ML25099A214 (1) | |
Text
Zachary K. Dunham Columbia Generating Station P.O. Box 968, PE20 Richland, WA 99352-0968 Ph. 509.377.4735 zkdunham@energy-northwest.com GO2-25-067 10 CFR 50.54(q)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 205551
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397;
SUMMARY
OF CHANGES AND ANALYSIS FOR REVISION 69 OF THE EP-01 COLUMBIA GENERATING STATION EMERGENCY PLAN
Dear Sir or Madam:
Enclosed is the summary of changes and analysis for Revision 69 of the EP-01 Columbia Generating Station Emergency Plan issued on April 1, 2025. The changes to the Emergency Plan have been evaluated in accordance with 10 CFR 50.54(q) and 10 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 stations 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 __________________, 2025.
Respectfully, Z.K. Dunham 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
April 9, 2025 ENERGY NORTHWEST
GO2-25-067 Enclosure EP-01, Rev. 69 Summary of Changes and Analysis
The following is a summary of changes that were made to the EPlan with Revision 69.
Modified the definitions of Augmenting and Support Emergency Response Organization (ERO) personnel to facilitate pooling as opposed to on call duty teams.
Removed mention of pagers as a way to notify ERO personnel.
Added in the term Automated Notification System in place of the term Automatic Dialer.
Eplan Section Change Justification for change Section 2.3 Modified the definitions of Augmenting and Support ERO personnel to remove mention of rotating on-call list and by electronic or manual means to the augmenting definition for consistency.
Also, added editorial word essential to ensure clarity on which ERO personnel the sentence is referring to.
See 10CFR50.54(q) #2025-01. This ensures clarity that augmenting and support ERO personnel are not required to be assigned to on call duty teams.
Section 4.6.1 Removed a radio paging system and ERO paging system. Removed Auto-dialer telephone system. Added Automated Notification System.
Removed The Duty Officer is able to manually activate the radio paging system, and this system will serve as a backup notification method. Added The Energy Northwest phone system in conjunction with the Emergency Phone Directory will be used as a back up to the Automated Notification System.
See 10CFR50.54(q)#2025-02. This provides clarity for removal of pagers as a means of notification to the Emergency Response Organization (ERO).
Section 6.6.6 Removed Area Wide Radio Paging and A Radio Paging System is used to alert on call members of Energy Northwests emergency response organization of an emergency See 10CFR50.54(q)#2025-02. This provides clarity for removal of pagers as a means of notification to the Emergency Response Organization (ERO).
Section 6.6.9 Removed Automatic Dialer. Added Automated Notification System.
Removed automatic dialing system.
Added Automated Notification System. Removed similarly to and at times in conjunction with the area wide radio paging system.
See 10CFR50.54(q)#2025-02. This provides clarity for removal of pagers as a means of notification to the Emergency Response Organization (ERO).
Section 6.7.3 Removed Automatic Dialer. Added Automated Notification System.
Removed pager.
See 10CFR50.54(q)#2025-02. This provides clarity for removal of pagers as a means of notification to the Emergency Response Organization (ERO).
Eplan Section Change Justification for change Section 6.7.4 Removed Area Wide Radio Paging operational test quarterly. This changes Fire Brigade Equipment from 6.7.4 b to 6.7.4 a.
See 10CFR50.54(q)#2025-02. This provides clarity for removal of pagers as a means of notification to the Emergency Response Organization (ERO).
Section 3.6.1 Removed by pager and/or.
See 10CFR50.54(q)#2025-02. This provides clarity for removal of pagers as a means of notification to the Emergency Response Organization (ERO).
Section 5.5.1 Removed pager notification.
See 10CFR50.54(q)#2025-02. This provides clarity for removal of pagers as a means of notification to the Emergency Response Organization (ERO).
Pooling Change Analysis:
Planning Standard 10 CFR 50.47(b)(2) - Onsite Emergency Organization On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
Planning Standard Onsite Emergency Organization requires timely augmentation of response capabilities.
Energy Northwest has established an all-call/all-come response process for non-essential ERO personnel to facilitate their removal from on-call duty teams. The all-call/all-come ERO augmentation practice is common in the industry.
CGS essential ERO positions are currently and will continue to be assigned to on-call duty teams and continue to follow an all-call/all-come process.
NUREG-0654 Revision one states:
The minimum ERO staffing plan is that which is required to effectively implement the site-specific emergency plan (i.e., the emergency plan cannot be effectively implemented without this staff). The emergency plan should only describe the minimum ERO staffing plan, while supporting implementing procedures can describe any additional staff response desired by the licensee, as this additional staff is not critical to effective emergency plan implementation.
The CGS essential ERO is synonymous with the NRC minimum staff ERO. The CGS essential ERO positions are those positions required to effectively implement the emergency plan and are associated with the minimum staff and key functions of NUREG-0654 Table B-1 and are assigned a 90-minute response time requirement.
The presence of additional non-essential ERO personnel in the emergency facilities that occurs during an emergency with the all-call/all-come process does not disrupt the timely augmentation of the essential ERO personnel; (1) as demonstrated in response tests conducted to verify the process at CGS.
(2) as demonstrated being a common industry practice.
The absence of non-essential ERO position(s) does not delay the ability of the essential ERO to relieve the on-shift ERO of EP related response functions. The CGS essential ERO positions are capable of relieving the on-shift ERO of all EP related response functions and implementing the emergency plan without the presence and support of non-essential ERO personnel.
The changes resulting from the activity do not remove the timely augmentation process in place at CGS, nor do they alter the timely augmentation process in such a way that the relief of the on-shift ERO or transfer of key functions is delayed. The changes resulting from the activity do not remove the means of ERO notification in place at CGS, nor do they alter the means of ERO notification in such a way that the relief of the on-shift ERO or transfer of key functions is delayed. The changes resulting from the activity continue to comply with all applicable regulatory requirements in 10 CFR 50.47(b) and 10 CFR 50 Appendix E.
The changes resulting from the activity do not alter the licensing basis with regard to the requirement for timely augmentation. There are no site-specific EP commitments related to this activity.
As documented above, the evaluation included a review of the latest NRC approved Emergency Plan and subsequent changes.
Pager Change Analysis P.S 50.47 (b) (5) - Notification Methods and Procedures
- ERO Notification Methods and Procedures P.S.50.47 (b) (6) - Emergency Communications
- Systems are established for prompt communication among principal emergency response organizations.
- Systems are established for prompt communication to emergency response personnel.
The ENW E-Plan (Rev 68) states The in-plant paging system, high noise area paging devices, a radio paging system and an Automated Notification System will be used to notify Energy Northwest ERO personnel. Instructions will be provided if protective measures are required.
Activation of response teams will be via the ERO paging system, Auto-dialer telephone system, and the in-plant public address system. The automatic notification system will normally be initiated by the Security Communication Center Duty Officer. The Emergency Director will direct the Duty Officer to make the notifications. The Duty Officer is able to manually activate the radio paging system, and this system will serve as a backup notification method.
NUREG-0654 states:
The minimum ERO staffing plan is that which is required to effectively implement the site-specific emergency plan (i.e., the emergency plan cannot be effectively implemented without this staff). The emergency plan should only describe the minimum ERO staffing plan, while supporting implementing procedures can describe any additional staff response desired by the licensee, as this additional staff is not critical to effective emergency plan implementation.
The CGS essential ERO is synonymous with the NRC minimum staff ERO. The CGS essential ERO positions are those positions required to effectively implement the emergency plan and are associated with the minimum staff and key functions of NUREG-0654 Table B-1 and are assigned a 90-minute response time requirement.
Removing the ERO paging system for notification does not disrupt the timely augmentation of the essential ERO personnel;
as demonstrated in response tests conducted to verify the process at CGS.
as demonstrated being a common industry practice.
The changes resulting from the activity do not impact the timely augmentation process in place at CGS, nor do they alter the timely augmentation process in such a way that the relief of the on-shift ERO or transfer of key functions is delayed. The changes resulting from the activity do not remove the means of ERO notification in place at CGS, nor do they alter the means of ERO notification in such a way that the relief of the on-shift ERO or transfer of key functions is delayed. The changes resulting from the activity continue to comply with all applicable regulatory requirements in 10 CFR 50.47(b) and 10 CFR 50 Appendix E.
The changes resulting from the activity do not alter the licensing basis with regard to the requirement for timely augmentation. There are no site-specific EP commitments related to this activity.
Columbia Generating Station started testing a response method known as All Call, All Come, in July 2023 and added the method into station procedures in April of 2024. All Call, All Come (AC/AC) is a now common industry practice to contact all individuals in all positions to respond instead of one individual per position which was CGSs practice until the testing of AC/AC.
The Emergency Response Organization (ERO) paging system is one of three methods of notification to the ERO. Based on data collected post implementation of All Call/All/Come, the Auto-dialer telephone system has consistently performed well in ERO notifications. ERO Support positions, while typically are not assigned pagers, have been notified effectively and responded in a timely manner.
Contacting the ERO by telephone calls has proved to be more reliable than the paging system.
Currently, testing is conducted on the Auto-dialer twice daily by Security personnel. This test verifies that the phone calls and pages would be sent as the system is designed. While there havent been any reports of telephone calls failing these tests, there haYH been problems identified with thH Pagers (14 Condition Reports (CRs) written over the past year).