ML15163A180

Energy Northwest Columbia Generating Station Slides for Regulatory Conference June 15 2015-Final

ML15163A180
Person / Time
Site:	Columbia
Issue date:	06/15/2015
From:	Energy Northwest
To:	NRC Region 4
References
Download: ML15163A180 (57)

Text

Columbia Generating Station Regulatory Conference Emergency Plan Implementing Procedure Guidance June 15, 2015

Opening Remarks Grover Hettel, Vice President Operations

Understanding and Acknowledgement

Energy Northwest Perspective

Review of Agenda 2

Agenda

Apparent Violation Don Gregoire

Emergency Plan Commitments Don Gregoire

NUREG-0654 Supplement 3 (2011) Sean Clizbe

PPM 13.2.2 Rev 18 Changes Sean Clizbe

PPM 13.2.2 SIP Guidance Dave Brown

Lessons Learned Kurt Gosney

Summary of Differences Don Gregoire

Significance Assessment Don Gregoire

Closing Grover Hettel 3

Don Gregoire (Manager Regulatory Affairs)

Apparent Violation Columbia Generating Station failed to follow and maintain the effectiveness of an emergency plan meeting the requirements of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b).

Inspection Report Finding (Emergency Plan Section 2.1)

Specifically, Columbia Generating Station Procedure 13.2.2, Determining Protective Action Recommendations, Revision 18, Section 4.5.1, did not implement the requirements of Emergency Plan Section 2.1 because the procedure required the Emergency Director in the control room to delegate the formulation of protective action recommendations to the TSC or EOF. However, protective actions are a non-delegable responsibility of the Emergency Director.

4

Apparent Violation Energy Northwest Position (Emergency Plan Section 2.1)

(1) Procedure PPM 13.2.2, Revision 18, step 4.5.1 correctly transfers protective action recommendations (PARs) to the Technical Support Center (TSC) or Emergency Operations Facility (EOF) for the expansion of PARs beyond 10 miles because field monitoring, an augmented function, is important to the development of accurate PARs at these distances.

(2) Augmented emergency response organization (ERO) functions are under the oversight of either the TSC or EOF in which case the Shift Manager would have transferred responsibilities to the emergency director in one of these locations.

(3) Transfer of emergency director responsibilities to the TSC or EOF and the reliance on field team data for PARs beyond 10 miles is consistent with section 2.1 and 5.5.2 of the Columbia Emergency Plan.

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Apparent Violation Inspection Report Finding (Emergency Plan Section 5.5)

Procedure 13.2.2, Revision 18, did not implement the requirements of Emergency Plan Section 5.5 because it did not provide for the development of shelter-in-place as a protective action recommendation and did not provide for protection action recommendations to protect against planned releases of radioactive materials.

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Apparent Violation Energy Northwest Position (Emergency Plan Section 5.5)

Shelter-in-Place Protective Action Recommendations (1) Procedure PPM 13.2.2 Revision 18 Attachment 7.1 and 7.2 provide for the development of shelter in place as a protective action recommendation.

(2) Shelter and evacuation guidance in Attachment 7.1 and 7.2 is based on guidelines established in NUREG-0654 Supplement 3 (2011).

(3) NUREG-0654 Supplement 3 (2011) was provided to licensees as an acceptable method for complying with Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b).

(4) Basing shelter and evacuation guidance on NUREG-0654 Supplement 3 is consistent with Section 5.5 and 5.5.2 of Columbias Emergency Plan 7

Apparent Violation Energy Northwest Position (Emergency Plan Section 5.5)

Planned Release Protective Action Recommendations (1) Procedure PPM 13.2.2 Revision 18 Attachment 7.1 and 7.2 continue to provide for the development of PARs to protect against planned releases of radioactive material.

(2) Use of Attachment 7.1 and 7.2 for developing protective action recommendations during a planned release (controlled, short duration releases) is consistent with Emergency Plan Section 5.5.2.

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Simplified Finding Statement Emergency Plan PAR Procedure Apparent Violation E-Plan commitment says X and procedure does not implement X.

However, Revision 18 of Procedure 13.2.2 no longer follows the above quoted sections of the stations Emergency Plan.

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Emergency Plan PAR Procedure Energy Northwest Position E-Plan commitment says X is NUREG-0654 Supp 3 EPA-400-R-92-001 based on federal guidance, procedure implements federal guidance, therefore procedure meets X.

10

Regulatory Compliance 10 CFR 50.47(b)(10)

A range of protective actions has been developed for the plume exposure Classification Emergency Plan pathway EPZ for emergency workers Notification Form Commitments and the public.

In developing this range of actions, Emergency Plan consideration has been given to Implementing Federal Guidance evacuation, sheltering, and, as a supplement to these, the prophylactic Procedures use of potassium iodide (KI), as appropriate

..Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place.

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Emergency Plan Commitments Emergency Plan Commitments Inspection Report

..the licensee failed to follow Sections5.5 of Emergency Planwhich required that the appropriate protective actions for an airborne release of radioactivity were evacuation and sheltering, that decisions to evacuate or shelter are made based on the dose avoided, that protective action recommendations are based on plant or radiological conditions..

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Emergency Plan Commitments Emergency Plan Section 5.5 Protective Action Guides, discussed in Section 5.5.2, provide pre-planned guidance for making response decisions. When applied with professional judgment, they help to ensure rapid action to protect members of the public.

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Emergency Plan Commitments Emergency Plan Section 5.5.2 Shelter, evacuation or access control guidelines are based on the EPA Protective Action Guidelines and NUREG-0654 Supplement 3 recommendations.

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Sean Clizbe (Manager Emerg Preparedness) Federal Guidance NUREG-0654 Supp 3 (2011)

Abstract The guidance of Supplement 3 provides an acceptable method to comply with Appendix E to Part 50, Title 10 of the Code of Federal Regulations (10 CFR)Section IV, paragraph 3 in the use of evacuation time estimates in the formulation of protective action recommendations (PARs) for the plume exposure emergency planning zone, and provides guidance for the provisions of 10 CFR 50.47(b)(10) in the development of a range of PARs.

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NUREG-0654 Supp 3 (2011) 1.2 Regulatory Basis Applicants and licensees2 may voluntarily3 use the guidance in this document to demonstrate compliance with Appendix E to Part 50,Section IV, paragraph 3 and the applicable provisions of section 50.47(b)(10)..

Licensees may use the information in this supplement for actions that do not require NRC review and approval such as changes to an emergency plan under 10 CFR 50.54 that do not require prior NRC review and approval.

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NUREG-0654 Supp 3 (2011)

2.1 Development of Site-Specific Protective Action Recommendation and Decision Logic The attachment to this supplement contains a protective action strategy development tool thatlicensees should use to develop PAR procedures.

Energy Northwest used the attachment of Supplement 3 for development of site specific PARS in procedure PPM 13.2.2 of Revision 18 17

NUREG-0654 General Emergency Declared Supplement 3 (2011) Yes Rapidly progressing severe accident?(1)

Continue assessment maintain PAR Attachment Tool No SIP (3) 2-mile radius No Do impediments to Yes and 5 miles downwind Impediments evacuation exist?(2) (4), all others monitor removed?

and prepare (5) (8)

Yes No Yes PAR for 2-mile radius and Evacuate 2 mile radius 2-5 mile downwind, depends on ETE (9), SIP and SIP (3) 5 miles Yes GE conditions 5-10 mile downwind (4), downwind (4), all remain? (6) all others monitor and others monitor and prepare (5) prepare (5)

No When safer to do so, begin staged GE conditions remain? (6) No evacuation of all affected areas (10) Expand PAR only to areas where PAGs could be exceeded Yes After 2-mile ETE (7) evacuate 2-5 miles downwind (4), all others monitor and prepare (5)

Continue assessment (11)

Protective action strategy development tool 18

NUREG-0654 Supp 3 (2011)

Protective Action Strategy Development Tool Notes It is not intended that licensees or offsite response organizations (OROs) have protective action implementing procedures that are exactly the same as provided here. Licensees for each nuclear power plant should develop site-specific strategies and decision tools/procedures for the site using the guidance provided below in collaboration with OROs responsible for protective action decision making.

Energy Northwest collaborated with Offsite Response Organizations in the development of appropriate PARs for Columbia using the attachment in Supplement 3 to arrive at our site-specific procedure 19

General Representation of Columbias EPZ 10 miles EPZ 5 miles 2 miles CGS Max. 90% ETE is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 15 minutes

NUREG-0654 Supp 3 (2011)

2.7 Strategy for Rapidly Progressing Scenarios For sites at which the 90-percent ETE for the general public of the full EPZ is less than approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, results showed that, for the rapidly progressing scenario, evacuation is the most appropriate protective action.

Columbias evacuation time estimate (ETE) less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for the entire Emergency Planning Zone (EPZ)

1.4 Background ETEs can be used as timing criteria to expand staged evacuation and for SIP versus evacuation decision making for large early release scenarios

Due to effect on ETE of low population in 0-5 miles, staged evacuation was judged to be unnecessary 21

NUREG-0654 Supp 3 (2011)

Note 2: Impediments to Evacuation Impediments to evacuation include the following:

Evacuation support (e.g., traffic control)

In a hostile-action-based GE (armed attack)

In the event of adverse weather

Energy Northwest evaluated each impediment and collaborated with OROs on PPM 13.2.2 procedure development 22

NUREG-0654 Supp 3 (2011)

Evacuation Support Many sites have a low population density within 2 miles, and lack of traffic control may not be considered an impediment. The licensee and OROs should discuss this element and reach an agreement The licensee would base procedures on the agreement and would not confer with OROs before making the initial PAR notification

Due to low population density evacuation support not a realistic impediment at Columbia.

OROs agreed.

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NUREG-0654 Supp 3 (2011)

Hostile Action OROs may determine that an initial recommendation to shelter in place (SIP) rather than evacuation is the preferred path. The licensee would discuss this element with OROs and reach an agreement during the development process. The licensee would base procedures on the agreement and would not confer with OROs before making the initial PAR notification.

Agreement reached with OROs prior to issuance of procedure. PPM 13.2.2 Revision 18 is based on agreement.

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NUREG-0654 Supp 3 (2011)

Adverse Weather In the event of adverse weather, licensees are not responsible for soliciting information or for making a determination that weather or other impediments (e.g., an earthquake or wildfire) for safe public evacuation exist at the time of the emergency. However, the licensee will consider an impediment to exist if OROs have previously notified it of such an impediment (e.g., roadways are closed because of deep snow). During the planning process, OROs may determine that the licensee does not need to consider adverse weather in its plant PAR procedures.

Agreement reached with OROs that adverse weather need not be considered in procedure. However, procedure still retains consideration for sheltering in adverse weather conditions during a radiological release.

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Supplement 3 (2011) Summary

Supplement 3 encourages licensees to use guidance within it for developing procedures to meet 50.47(b)(10)

Supplement 3 identifies evacuation as the most appropriate for rapidly progressing scenarios

Energy Northwest collaborated with OROs in the development of appropriate PARs for Revision 18 of PPM 13.2.2

Consistent with Emergency Plan section 5.5.2, protective action strategy for shelter and evacuation is based on NUREG-0654 Supplement 3 (2011) 26

Emergency Plan Implementing Procedures PPM 13.2.2 Revision 18 Changes Inspection Report Cover Letter Specifically, on June 16, 2014, when Columbia Generating Station implemented Revision 18 ofProcedure 13.2.2it inappropriately (1) removed shelter-in-place as a protective action that can be recommended to offsite authorities, (2) removed the recommendation of protective actions for planned releases of radioactive material during an accident, and (3) limited the ability of the emergency response organization to recommend protective actions outside of the plume exposure emergency planning zone.

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PPM 13.2.2 Revision 18 Changes

Implemented 2011 version of NUREG-0654 Supplement 3 Improved strategies for protection of public health and safety Incorporated results of evaluation of shelter-in-place considerations as described in Supplement 3

Formatting improvements 28

Initial PAR Revision 17 Revision 18 29

Revision 17 PAR Update Revision 18 30

Attachment 7.1 - Revision 17 Attachment 7.1 - Revision 18 31

Attachment 7.2 - Revision 17 Attachment 7.2 - Revision 18 32

PPM 13.2.2 Revision 18 Changes Inspection Report

.. Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, Determining Protective Action Recommendations, on June 16, 2014, so that it:

• Removed the responsibility of the emergency coordinator in the control room (shift manager) to make protective action recommendations for areas outside the plume phase (10-mile) emergency planning zone.

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PPM 13.2.2 Revision 18 Changes Emergency Plan Section 2.1 Responsibility for emergency direction and control (i.e., overall direction of the plant's emergency response which must include the non-delegable responsibilities for emergency classification, the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures) is normally transferred from the Shift Manager to the EOF Manager. However, if the situation dictates, the responsibilities may be transferred from the Shift Manager to the TSC Manager and then to the EOF Manager.

Emergency Plan Section 5.5.2 Plant and offsite officials will continue to assess plant conditions to determine additional protective actions. These protective actions should be based on field monitoring data and dose projections that indicate EPA PAGs may be exceeded in areas beyond those that have been evacuated.

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Expansion of Initial PARs Revision 17 Expansion of Initial PARs Revision 18 2.8 Plant and offsite officials should continue assessment actions based on 2.9 Plant and offsite officials should continue assessment actions based on additional plant information, dose projections, and field monitoring results. additional plant information, dose projections, and field monitoring results.

After performing the initial early evacuation actions near the plant, licensee After performing the initial early evacuation actions near the plant, licensee and offsite officials should modify their protective action recommendations as and offsite officials should modify their protective action recommendations as necessary based on (1) field monitoring to locate areas with high levels of necessary based on (1) field monitoring to locate areas with high levels of contamination (hot spots) and (2) dose projections which indicate that EPA contamination (hot spots) and (2) dose projections which indicate that EPA protective action guide doses may be exceeded in areas beyond those that protective action guide doses may be exceeded in areas beyond those that have been evacuated. On the basis of this information, plant and offsite have been evacuated. On the basis of this information, plant and offsite officials may expand the evacuations to encompass other areas in the plume officials may expand the evacuations to encompass other areas in the plume EPZ and, for the worst case accidents, protective actions may be required EPZ and, for the worst case accidents, protective actions may be required beyond the plume EPZ. beyond the plume EPZ.

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Emergency Plan Implementing Procedures PPM 13.2.2 Rev 18 SIP Guidance Inspection Report Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, Determining Protective Action Recommendations, on June 16, 2014, so that it:

• No longer provided a mechanism to make a shelter-in-place protective action recommendation;

• No longer ensured a protective action recommendation in the event of a planned release of radioactive material; 36

Dave Brown (Emergency Director)

PPM 13.2.2 Rev 18 SIP Guidance 4.2 Initial Plant Based PARs for General Emergency Classifications 4.2.1 REFER to Attachment 7.1, Decision Guide for Offsite Protective Action Recommendations to ensure appropriate PAR is determined.

a. IF a dose projection has been made, THEN DETERMINE appropriate downwind section(s) based on the dose projection program output.

b. IF NO dose projection is made, THEN USE the Downwind Sections Table in attachment to determine appropriate sections.

4.2.2 INDICATE the PAR on the Classification Notification Form (CNF), Form 24075, AND MAKE the required offsite notifications in accordance with PPM 13.4.1, Emergency Notifications.

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Attachment 7.1 - Initial PAR, General Emergency, Release in Progress or Planned Release ENTER IF SAE Automatic PAR to evacuate SAE or GE Recreational Areas and EPZ Declared Schools GE Recreational Areas:

Columbia River Ringold Fishing Area Horn Rapids Recreation Wahluke Hunting Area ENTER IF Area / ORV Park While at GE a change in Release Status or Meteorological Conditions occurs Evacuate Sections where EPA PAGs (Attachment 7.2) are projected to be exceeded based on Dose Assessments or actual survey readings. 1 & 2 PLUS Release in Yes IF not previously recommended, THEN Evacuate Progress? ALL Sections 0-2 Miles and 10 Miles downwind AND shelter remaining Sections. 1 PLUS Automatic PAR to evacuate Recreational No Areas and EPZ Schools Evacuate ALL Sections 0-2 Miles and 10 Miles downwind AND shelter remaining Sections.

PLUS Automatic PAR to evacuate Recreational Areas and EPZ Schools 38

Attachment 7.2 - PAGs for the Early Phase of a Nuclear Incident PROTECTIVE PAG COMMENTS ACTION (projected dose)

Evacuation 1 - 5 Rem TEDE Evacuation (or, for some (or sheltering1) OR situations, sheltering1) should 5 - 25 Rem CDE thyroid normally be initiated at the OR lowest level of the range.

50 - 500 Rem skin From EPA 400, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents 1 Sheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration of factors such as source term characteristics, and temporal or other site-specific conditions.

Evacuation vs. Sheltering Because of the higher risk associated with evacuation of some special groups in the population (e.g.

those who are not readily mobile), sheltering may be the preferred alternative for such groups as a protective action at projected doses up to 5 Rem TEDE. In addition, under unusually hazardous environmental conditions, use of sheltering at projected doses up to 5 Rem to the general population (and up to 10 Rem to special groups) may be justified. Offsite officials will determine when the use of sheltering is appropriate.

Illustrative examples of situations or groups for which evacuation may not be appropriate at 1 Rem include: a) the presence of severe weather, b) competing disasters, c) institutionalized persons who are not readily mobile, and local physical factors which impede evacuation.

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Attachment 7.1 - Initial PAR, General Emergency, No Release in Progress ENTER IF SAE Automatic PAR to evacuate SAE or GE Recreational Areas and EPZ Declared Schools GE Recreational Areas:

Columbia River Ringold Fishing Area Horn Rapids Recreation Wahluke Hunting Area ENTER IF Area / ORV Park While at GE a change in Release Status or Meteorological Conditions occurs Evacuate Sections where EPA PAGs (Attachment 7.2) are projected to be exceeded based on Dose Assessments or actual survey readings. 1 & 2 PLUS Release in Yes IF not previously recommended, THEN Evacuate Progress? ALL Sections 0-2 Miles and 10 Miles downwind AND shelter remaining Sections. 1 PLUS Automatic PAR to evacuate Recreational No Areas and EPZ Schools Evacuate ALL Sections 0-2 Miles and 10 Miles downwind AND shelter remaining Sections.

PLUS Automatic PAR to evacuate Recreational Areas and EPZ Schools 40

Updating PARs Inspection Report Revision 18, Step 4.4.4, states, in part, IF there is to be a planned release (containment venting) THEN discuss the proposed activity with offsite authorities to assist them with protective action implementation.

Revision 18, Step 4.4.5, states, in part, WHEN circumstances such as weather, distance, or concurrent emergencies may impact specific areas for which PARs are being proposed, THEN inform the Benton and Franklin County EOFs The inspectors determined that Revision 17 required the licensee make a protective action recommendation to offsite authorities for planned releases of radioactive material into the environment, while Revision 18 requires the licensee to discuss a planned release with offsite authorities. The inspectors concluded that a discussion intended to assist offsite authorities is not equivalent to a protective action recommendation from the licensee to offsite authorities.

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Updating PARs 4.4 Updating Offsite PARs Based on Projected Doses or Offsite Survey Results NOTE: Do not delay recommending offsite protective actions while waiting for field monitoring results to verify the accuracy of the dose projection results.

4.4.1 OBTAIN AND REVIEW applicable offsite dose projection and/or survey data.

4.4.2 DETERMINE the appropriate offsite PAR by comparing the plume projected dose and/or Field Monitoring Team data with the Protective Action Guidelines (PAGs) and guidance provided in Attachment 7.2, PAGs for the Early Phase of a Nuclear Incident.

a. IF review of dose projections or survey results indicate a PAG has been exceeded in any Sections not already evacuated, THEN ISSUE a new PAR for additional affected Sections

b. IF dose projections or survey results indicate a PAG may be exceeded beyond, 10 miles, THEN REFER to step 4.5.

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Updating PARs 4.4.3 Updating Offsite PARs Based on Change of Wind Direction with NO PAG exceeded.

a. ISSUE a new PAR ONLY if the following conditions are met:

• The change in wind direction affects a downwind Section (see Attachment 7.1 for downwind Sections) for which an Evacuation PAR has NOT been issued.

AND

• Containment Radiation Monitor reading GT 14,000 R/hr.

AND

• LOSS OR POTENTIAL LOSS of Primary Containment as indicated by the Fission Product Barrier Degradation Table in PPM 13.1.1, Classifying the Emergency.

4.4.4 IF there is to be a planned Release (containment venting),

THEN DISCUSS proposed activity with offsite authorities to assist them with Protective Action implementation.

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Updating PARs 4.4.5 WHEN circumstances such as weather, distance or concurrent emergencies may impact specific areas for which PARs are being proposed, THEN INFORM the Benton and Franklin County EOCs which sections are most affected so that routes to be taken or avoided may be identified, or other special considerations in the notification to offsite agencies.

4.4.6 IF any of the above actions result in a change to established PARs, THEN COMPLETE the appropriate parts of the CNF, and make the required notifications in accordance with PPM 13.4.1, Emergency Notifications.

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Class/Notif Form Columbia Electronic Classification Notification Form 45

Kurt Gosney (Acting General Manager Emergency Services)

Lessons Learned

Engagement with NEI EPWG

Engagement with NSIR

Inspection Interface 46

Classification Emergency Plan Notification Form Commitments Don Gregoire (Manager Regulatory Affairs) Emergency Plan Implementing Federal Guidance Procedures Summary of Differences

Inspection Report Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, Determining Protective Action Recommendations, on June 16, 2014, so that it:

• No longer provided a mechanism to make a shelter-in-place protective action recommendation

Energy Northwest A mechanism for making a shelter-in-place protective action recommendation is provided via Attachment 7.1 and 7.2 of PPM 13.2.2 Revision 18.

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Summary of Differences

Inspection Report Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, Determining Protective Action Recommendations, on June 16, 2014, so that it:

• No longer ensured a protective action recommendation in the event of a planned release of radioactive material

Energy Northwest A protective action for planned releases of radioactive materials is developed using Attachment 7.1 and 7.2 of PPM 13.2.2 Revision 18. In addition steps 4.2.2 (initial PAR) and 4.4.6 (updated PAR) ensure that notifications for a planned release of radioactive material are made.

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Summary of Differences

Inspection Report Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, Determining Protective Action Recommendations, on June 16, 2014, so that it:

• Removed the responsibility of the emergency coordinator in the control room(shift manager) to make protective action recommendations for areas outside the plume phase (10-mile) emergency planning zone.

Energy Northwest No responsibility was removed from the shift manager. Step 4.5.1 of PPM 13.2.2 Revision 18 correctly transfers responsibilities to the TSC or EOF for the expansion of PARs beyond the EPZ which requires field monitoring (an augmented function) to support conclusions. This is consistent with section 5.5.2 of the Columbia Emergency Plan.

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Summary of Differences

Inspection Report Specifically, the licensee failed to follow Sections 2.1of Emergency Plan, Revisions 59 through 61

Energy Northwest Energy Northwest complies with Emergency Plan section 2.1 based on taking into consideration the additional text of Section 5.5.2. Specifically, Section 5.5.2 states that subsequent protective action for areas beyond those evacuated should be based on both dose monitoring and dose projections. Consistent with federal guidance.

Dose monitoring is conducted by field teams which is an augmented ERO function. Augmented EROs are led by an Emergency Director in either the TSC or EOF.

Step 4.5.1 of PPM 13.2.2 Revision 18 requires field team data for PAR determination.

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Summary of Differences

Inspection Report Specifically, the licensee failed to follow Sections5.5 of Emergency Plan, Revisions 59 through 61

Energy Northwest Energy Northwest complies with Emergency Plan section 5.5 based on taking into consideration the entire text of Sections 5.5 and 5.5.2. Specifically:

Section 5.5 states that protective action guides discussed in section 5.5.2 provide pre-planned guidance for making response decisions Section 5.5.2 states that shelter and evacuation guidelines are based on EPA and NUREG-0654 Supplement 3 guidelines Protective action recommendation guidance in Attachment 7.1 and 7.2 of PPM 13.2.2 Revision 18 are based on EPA and NUREG-0654 Supplement 3 (2011) recommendations.

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Significance Assessment Stated Basis for Significance The planning standard function was degraded because, although the licensee could make appropriate recommendations for evacuation of the public, the licensee could no longer make recommendations for the public to shelter-in-place when appropriate, and limitations could result in delays in making appropriate protective action recommendations for areas outside the emergency planning zone.

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Significance Assessment Very Low Safety Significance

1. (2015) - Region I Plant Failure to maintain effectiveness of Emergency Plan Procedure changes made to PAR flowchart that would result in inappropriately recommending evacuation of downwind areas and many more emergency response planning areas (ERPAs) than intended Both downwind and many other areas affected with inappropriate evacuation 53

Significance Assessment

2. (2012/2011) - 2 Region IV Plants Failure to develop and have in place guidelines for the choice of protective actions consistent with federal guidance (procedure did not implement EPA-400-R 001)

Automatic process extended protective action for evacuation based on plant conditions and changes in wind direction without considering radiation dose 54

Significance Assessment Low to Moderate Safety Significance

1. (2015) - Region IV Plant Changed PAR procedure to eliminate PARs over the ocean within 10 mile EPZ

2. (2012) - Region III Plant Changed PAR procedure to eliminate decision-making process for PARs beyond EPZ Updated evacuation PAR during drill to Shelter 55

Summary of Significance

Columbia continues to meet Emergency Plan Commitments

All considerations for shelter-in-place found in applicable federal guidance are addressed in PPM 13.2.2 Rev 18

Compliance with NUREG-0654 Supplement 3 results in 10 CFR 50.47(b)(10) compliance

Public health and safety appropriately protected 56

Closing Grover Hettel Vice President Operations 57