ML15168A238
| ML15168A238 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/15/2015 |
| From: | Division of Reactor Safety IV |
| To: | |
| References | |
| EA-15-038, NRC-1599 | |
| Download: ML15168A238 (149) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Regulatory Conference IN RE Columbia Generating Station Docket Number:
50-397 EA Number:
15-038 Location:
Arlington, Texas Date:
Monday, June 15, 2015 Work Order No.:
NRC-1599 Pages 1-141 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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REGULATORY CONFERENCE COLUMBIA GENERATING STATION
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EA No.15-038 Docket No. 50-397
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MONDAY, JUNE 15, 2015
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REGION IV OFFICE ARLINGTON, TEXAS
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The Meeting convened via teleconference, Mark Haire, Facilitator, presiding.
NRC PARTICIPANTS:
MARK HAIRE, Chief, Plant Support Branch 1, Division of Reactor Safety RACHEL BROWDER, Region IV JEFFREY CLARK, Deputy Director, Division of Reactor Safety MARC DAPAS, Regional Administrator, Region IV PAUL ELKMANN, Senior Emergency Preparedness Inspector GILBERT GUERRA, Emergency Preparedness Inspector ROBERT KAHLER, Chief, Inspection & Regulatory Improvements Branch, NSIR TROY PRUETT, Director, Division of Reactor Projects WAYNE WALKER, Chief, Branch A, Division of Reactor Projects LICENSEE PARTICIPANTS:
GROVER HETTEL, Vice President of Operations ANDREW BLACK, Emergency Services General Manager DAVID BROWN, Manager Planning/Scheduling, Outage SEAN CLIZBE, Emergency Preparedness Manager A.J. FAHNESTOCK, EP Program Manager KURT GOSNEY, Acting Emergency Services General Manager DONALD GREGOIRE, Regulatory Affairs Manager J. R. TRAUTVETTER, Regulatory Compliance Supervisor DESIREE WOLFGRAMM, Compliance Engineer
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 TABLE OF CONTENTS Introduction.......................................4 Summary of Apparent Violation.....................11 Regional Administrator Comments...................19 Licensee Presentation.............................22 Questions and Discussion..........................43 NRC Caucus......................................129 Questions and Discussion.........................129 Closing Remarks..................................138 Conference Adjournment
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P R O C E E D I N G S 1
2:01 p.m.
2 MR. HAIRE: Okay. Thanks. And just a 3
reminder to the folks in the room, the microphones that 4
are on the desks have a little green LED. When it's 5
lit, your mike is live if you touch the little push 6
button. When the green light is not lit, that means 7
you're not live and you're not being amplified for the 8
phone folks.
9 Also in the room, there is a wireless mike 10 on the stand for any members of the public. I don't 11 see any members of the public in the room at this time, 12 but they may join us later.
13 All right. So to kick off the meeting, 14 there are some opening remarks and statements that need 15 to be made, including some logistic comments. And I'll 16 be leading that charge, so I'll be reading through some 17 elements that need to be covered, and then I'll follow 18 the agenda.
19 So step one is to go through the conference 20 opening. So my name is Mark Haire. I'm the Branch 21 Chief for the Emergency Preparedness and Security 22 Inspectors in the NRC's Region IV Office. Welcome to 23 the reg conference between the NRC and Energy Northwest 24 Columbia Generating Station.
25 Today, we will be discussing the finding 26 related to the Columbia Generating Station's failure 27 to follow requirements of their site emergency plan, 28 specifically that emergency plan implementing 29 procedures were changed so that the procedures did not 30 continue to provide an option to recommend 31 shelter-in-place as a protective action recommendation 32 for the public when it's appropriate. The revised 33 procedure also did not continue to provide further 34 development of protective action recommendations for 35 an intentional release of radioactive material and 36 inappropriately delegated some responsibilities of a 37 senior reactor operator in the control room for making 38 protective action recommendations.
39 This conference is open to public 40 observation. However, this is an enforcement 41 regulatory conference, and, as such, it is a meeting 42 between the NRC and Columbia Generating Station. And 43 during the meeting, comments and questions will not be 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 taken from members of the public. But following the 1
conference, NRC staff will be available to answer 2
questions and receive comments from members of the 3
public concerning matters discussed here at the 4
conference or any other questions, as Marc Dapas, our 5
regional administrator, has mentioned.
6 It's important to note that this phone 7
bridge is being recorded. Both the recording and the 8
transcript will be made publicly available soon after 9
this meeting. The Columbia Generating Station's 10 representatives have provided slides for their 11 presentation, and those slides have been made available 12 at the NRC's public meeting web page. It's at 13 www.nrc.gov, and you would click on the "public 14 meetings and involvement" tab and then click on the 15 "public meetings schedule" link and scroll down and see 16 today's meeting listed, and you'd click on the "more" 17 tab and you'd see the related documents include the 18 slides that Columbia Generating Station has provided.
19 And those slides that are on that link are the updated 20 slides that Columbia provided to the NRC today. So 21 those are the updated slides.
22 All right. Some administrative items 23 before we review the rest of the agenda. For those in 24 the room, the closest restrooms are out the door to the 25 left, pass the guard station, and then they'll be on 26 the right close to the lobby. If there is an emergency, 27 we need to listen to the announcements over the intercom 28 system. And if an evacuation of the building is 29 required, the nearest exits are either at the main 30 building entrance where you came in, which is left out 31 of this room, or on the side of the building to the right 32 there's an emergency exit.
33 For the microphones, we ask that all NRC 34 and Columbia Generating Station personnel who will be 35 speaking, please use the microphones so that the people 36 on the phone will be able to hear.
37 We should have sign-in sheets available.
38 I don't know if they've been passed around yet, but if 39 they haven't we'll make sure that those get passed 40 around. We'd like to have a record of everyone's 41 attendance to the meeting. And if there are any 42 members of the public in the room, we'll provide you 43 with feedback so that you can provide comments to the 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 NRC.
1 A meeting summary will be made available 2
by the NRC within 30 days of this meeting.
3 So a quick review now of the agenda of the 4
meeting. The meeting will open with the opening 5
comments by me, which I've done. Next, we'll go 6
through introductions of the key participants from both 7
organizations. Then I will go through a summary of the 8
regulatory process and the apparent violation at stake 9
that be discussed today. And then Marc Dapas, our 10 regional administrator, will make some opening 11 remarks, and then we'll turn it over to Columbia 12 Generating Station to make any remarks and presentation 13 that they'd like to make.
14 Throughout the presentation, we'll be 15 engaging with questions during that process. Then 16 after your presentation and after we've had a chance 17 to ask some questions, the NRC will disengage from the 18 meeting for a timeout. We'll exit the room, have a 19 caucus in a separate room where we'll discuss what we've 20 heard and if we have any additional questions. It will 21 probably take us 15 - 20 minutes to do that.
22 And we'll reconvene the meeting after that caucus for 23 any final questions that we have.
24 And then I'll offer the opportunity for our 25 senior managers, including Marc Dapas, to make any 26 closing comments. And then I'll make some comments 27 about the closing of the business of the meeting, and 28 then I'll invite at that time the operator to allow 29 members of the public to ask questions, and the NRC will 30 be happy to entertain those and answer those.
31 So that's how the meeting will progress.
32 So at this point, I'd like to engage in some 33 introductions, starting on the NRC side. I've already 34 introduced myself. I'm Mark Haire. I'm the Branch 35 Chief for Emergency Preparedness and Security 36 Inspectors.
37 MR. DAPAS: Well, I'm Marc Dapas. I'm the 38 Regional Administrator for our Region IV Office.
39 MR. KAHLER: Bob Kahler. I'm the Branch 40 Chief with the Inspection of Regulatory Improvements 41 Branch with NSIR at the Rockville, Maryland NRC 42 Headquarters office.
43 MR. CLARK: I'm Jeff Clark, Deputy 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Director of Division of Reactor Safety.
1 MR. WALKER: And I'm Wayne Walker. I'm 2
the Branch Chief for Columbia in the Division of Reactor 3
Projects.
4 MR. HAIRE: And the next table back.
5 MR. PRUETT: Troy Pruett, Director of 6
Projects in Region IV.
7 MR. ELKMANN: Paul Elkmann, Inspector, 8
Region IV.
9 MR. GUERRA: Gilbert Guerra, Inspector, 10 Region IV.
11 MS. BROWDER: Rachel Browder, Senior 12 Enforcement Specialist.
13 MR. HAIRE: Okay. Thanks. And if, Mr.
14 Hettel, if you'll introduce your team.
15 MR. HETTEL: Okay. My name is Grover 16 Hettel. I'm the Vice President of Operations at the 17 Columbia Generating Station for Energy Northwest, and 18 I'll let my team introduce themselves.
19 MR. GREGOIRE: I'm Don Gregoire. I'm the 20 Manager of Regulatory Affairs.
21 MR. CLIZBE: Sean Clizbe. I'm the 22 Emergency Preparedness Manager at Energy Northwest.
23 MR.
BROWN:
Dave
- Brown, Planning, 24 Scheduling, and Outage Manager, also Emergency 25 Director.
26 MR.
GOSNEY:
Kurt
- Gosney, Acting 27 Emergency Services General Manager.
28 MR. BLACK: Andy Black. I'm the 29 Emergency Services General Manager. Although I've 30 been on loan to capital projects for the last five 31 months, I still retain ownership of EP in my division.
32 MR. FAHNESTOCK: A.J. Fahnestock, EP 33 Program Manager.
34 MR. TRAUTVETTER: J.R. Trautvetter, 35 Regulatory Affairs Compliance Supervisor.
36 MS.
WOLFGRAMM:
Desiree Wolfgramm, 37 Compliance Engineer.
38 MR. HAIRE: Okay. That is a full 39 introduction of the folks in the room. We don't have 40 any members of the public, a couple of observers from 41 the NRC staff in the room. And I do believe we have 42 some folks from the NRC staff also listening on the 43 line.
44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So now I'm going to summarize where we're 1
at in the regulatory process, what the apparent 2
violation at stake is today, and then we'll move forward 3
with the agenda. So a bit of a lengthy description, 4
so bear with me.
5 So in accordance with the NRC's regulatory 6
process, after a potentially risk-significant finding 7
is identified and characterized by our significance 8
determination process as potentially greater than 9
green, we offer licensees an opportunity for regulatory 10 conference. In this case, Columbia Generating Station 11 requested that a conference be held to discuss the issue 12 and its significance.
13 It is the responsibility of NRC licensees 14 to provide protective action recommendations to local 15 and state officials. Those local and state officials 16 then consider the plant's recommendations if they make 17 protective action decisions to protect the health and 18 safety of the public. And we're here today because, 19 in 2014, Columbia Generating Station made a change to 20 their emergency plan implementing procedures that 21 deleted shelter-in-place as a possible outcome from 22 their flowchart used to make protective action 23 recommendations and they deleted instructions to 24 develop protective action recommendations when the 25 release was intentional and they added limitations on 26 the protective action recommendation choices available 27 to the senior reactor operator in the control room.
28 So let me give a little more detail about 29 that, those issues. When an emergency occurs that may 30 present a risk to the public, the NRC requires that 31 licensees consider a range of protective actions to 32 arrive at a recommendation for the safest overall 33 action for the public to take. Often, but not always, 34 that action is evacuation. Sometimes, the most 35 protective action is to shelter-in-place. Outside 36 authorities consider a licensee's recommendation, 37 along with other information about the event, in 38 deciding what measures to implement. But a licensee's 39 recommendation to the outside authorities is important 40 because it communicates the radiological risk to the 41 public.
42 Columbia Generating Station's original 43 approved emergency plan and all subsequent revisions 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 up through the current plan has included a range of 1
protective actions appropriate to a spectrum of 2
emergency events. The emergency plan describes both 3
evacuation and shelter-in-place as potential actions 4
that may be recommended to off-site officials for the 5
protection of the public.
6 In a specific event, the choice is based 7
on plant and radiological conditions, the EPA 8
Protective Action Guidance, and the radiation dose that 9
could be avoided. NRC concluded that the Columbia 10 emergency plan appropriately describes the protective 11 measures to be taken in the event of an emergency.
12 However, June 16th, 2014, Columbia changed their 13 procedures for developing protective action 14 recommendations and inappropriately removed 15 shelter-in-place from the procedure text and from the 16 primary decision tool, which is a flowchart used to 17 determine which protective measures would be 18 recommended to the public.
19 The removal of those instructions reduced 20 the number of options that would be considered and then 21 a shelter-in-place recommendation could only be 22 arrived at by going outside of the procedure, even in 23 the unusual circumstance where shelter would provide 24 a dose savings and, therefore, more protection for the 25 public. And I think it's important to note that our 26 guidance defines shelter-in-place as a dose-saving 27 protective action involving people going into their 28 houses, closing their doors, closing their windows, 29 turning off their ventilation, and attempting to avoid 30 dose. It's a dose-avoidance protective action.
31 The same procedure also failed to ensure 32 that the need for additional protective measures would 33 be evaluated if Columbia was intentionally venting 34 radioactive
- material, so intentionally venting 35 radioactive material, and also delegated the decisions 36 about protective measures for some areas of the senior 37 reactor operator in the control room to other company 38 officials in other facilities. And the responsibility 39 to make protective action recommendations is not 40 delegable. It must remain with the individual 41 exercising command and control. Because those other 42 facilities might not be staffed when conditions require 43 a recommendation, the procedure could have caused 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 delays in protecting the public.
1 As a result of procedure changes, Columbia 2
no longer complied with the NRC requirements to follow 3
their emergency plan and no longer provided for a range 4
of protective actions. Therefore, this apparent 5
violation is associated with a finding that has 6
preliminarily been determined to be of White 7
significance. Note that we use phrases like "apparent 8
violation" at a conference like this because the NRC 9
will not make its final determination on the violation 10 or its significance until after the conference.
11 The White significance indicates the NRC 12 has preliminarily concluded that Columbia degraded 13 their ability to implement a
risk-significant 14 emergency preparedness function. We use this phrase 15 "risk significant" to denote those functions with the 16 most immediate impact on the licensee's ability to 17 protect the health and safety of the public, such as 18 event classification, offsite response organization 19 notification, radiological assessment, and protective 20 action recommendations.
21 Their ability to implement a
22 risk-significant function was degraded because the 23 procedure change narrowed the protective measure 24 options and could have delayed making some 25 recommendations. The NRC takes this very seriously.
26 So having said all of that, let me 27 summarize, actually let me read the proposed apparent 28 violation. Title 10 of the Code of Federal 29 Regulations, Part 50.54(q)(2) requires, in part, that 30 a holder of a license under 10 CFR Part 50 shall follow 31 and maintain the effectiveness of their emergency plan 32 that meets the requirements of Appendix E to 10 CFR Part 33 50 and the planning standards of 10 CFR 50.47(b).
34 Now, Title 10 of the CFR Part 50.47(b)(10) 35 requires, in part, that a range of protective actions 36 has been developed for the plume exposure pathway 37 emergency planning zone for the public. And in 38 developing this range of protective
- actions, 39 consideration has been given to evacuation and 40 sheltering, as appropriate. A Columbia Generating 41 Station Emergency Plan Revision 59, which was dated 42 September 10th, 2013, through the Revision 61, which 43 was dated September
- 2014, and Section 2.1, 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Organizational Concepts, required, in part, that the 1
responsibility for emergency direction and control 2
comprises the overall direction of the plant's 3
emergency
- response, which must include the 4
non-delegable responsibilities for emergency 5
classification, the decision to notify and recommend 6
protective actions to authorities responsible for 7
offsite emergency measures.
8 Columbia Generating Station Emergency 9
Plan Section 5.5, Protective Action Responsibilities, 10 required, in part, that the appropriate protective 11 actions for an airborne release of radioactive material 12 are evacuation and sheltering and that the decision to 13 evacuate or shelter is made based on the dose to be 14 avoided by the protective action relative to the risk 15 associated with implementing the protective action, 16 and that protective action recommendation shall be made 17 based on plant and radiological conditions.
18 Contrary to the above, between June 26, 19 2014 and April 23rd, 2015, Columbia Generating Station 20 failed to follow and maintain the effectiveness of 21 their emergency plan, which meets the requirements of 22 Appendix E of 10 CFR Part 50 and 10 CFR 50.47(b).
23 Specifically, Columbia Generating Station's procedure 24 13.2.2, which is titled "Determining Protective Action 25 Recommendations," Rev 18, Section 4.5.1 did not 26 implement the requirements of the emergency plan in 27 Section 2.1 because the procedure required the 28 emergency director in the control room to delegate the 29 formulation of protective action recommendations to 30 the technical support center or the emergency operation 31 facility.
- However, protective actions are 32 non-delegable responsibilities of the emergency 33 director.
34 In addition, Procedure 13.2.2 Rev 18 did 35 not implement the requirements of Emergency Plan 36 Section 5.5 because it did not provide for the 37 development of shelter-in-place as a protective action 38 recommendation and did not provide for protective 39 action recommendations to protect against planned 40 releases of radiological material. Now, the licensee 41 has entered this issue into their corrective action 42 process, Corrective Action Request 320790 dated 43 January 19th, 2015 and several other corrective action 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 documents.
1 All right. That is the proposed apparent 2
violation. This proposed apparent violation, along 3
with an option to request a regulatory conference, were 4
communicated to Columbia Generating Station Power 5
Plant during an exit meeting on April 23rd, 2015 and 6
in the NRC Inspection Report 05000397/2015502, which 7
was dated May 7th, 2015. This regulatory conference 8
is the last step of the inspection process before the 9
NRC makes its final decision on the significance of the 10 inspection finding.
11 And the purpose of the conference today is 12 to allow you, Columbia Generating Station, to provide 13 your position with respect to the facts and assumptions 14 used by the NRC to make our preliminary significance 15 determination and to allow you to present any new 16 information that may assist us in arriving at the most 17 appropriate final significance determination.
18 In addition to discussing your views on the 19 significance of the finding, you may want to present 20 your views on the identified apparent violation.
21 It is important to note that the decision 22 to conduct this conference does not mean that the NRC 23 has made a final determination that a violation has 24 occurred, and the enforcement related to the finding 25 being discussed today will be assessed in accordance 26 with the Commission's enforcement policy. I should 27 also note at this time that any statements of view or 28 expressions of opinion made by NRC employees at this 29 conference do not represent final agency 30 determinations or beliefs relative to the matter before 31 us today.
32 Following this conference, the regional 33 and NRC Headquarters staff will reach a significance 34 determination and an enforcement decision. The NRC's 35 goal is to issue the final significance determination 36 by July 10th, 2015.
37 And that concludes my rather lengthy 38 discussion of the regulatory process and the apparent 39 violation. And I'd like to turn it over now to Marc 40 Dapas, Regional Administrator, for his opening 41 remarks.
42 MR. DAPAS: Thank you, Mark. First and 43 foremost, I'm sure that the Columbia team appreciates 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that developing protective action recommendations is 1
an important process. It provides for the local and 2
state government officials to be able to make informed 3
decisions regarding what the protective action 4
decision will be, mainly the decision regarding what 5
actions members of the public need to take to minimize 6
exposure in the unlikely event that there is a release 7
of radiation resulting from some upset condition at the 8
plant.
9 And you heard Mr. Haire describe how your 10 emergency plan does provide for shelter-in-place, but 11 the issue that we identified was your emergency plan 12 implementing procedures did not provide specific 13 direction.
14 It's my understanding that, based on the 15 inspection team's interactions with various folks on 16 the licensee's staff, that it was the intent in applying 17 the guidance in NUREG-0654 Supplement 3, which provides 18 an acceptable method for complying with Appendix E of 19 10 CFR Part 50 and 10 CFR 50.47(b), which are the 20 emergency planning standards, that the intent behind 21 the guidance there when it came to shelter-in-place was 22 to provide for those instances where there is a 23 rapidly-developing event and your evacuation time 24 estimates would indicate that you can evacuate the 25 affected population in less than three hours, I think 26 it is, that you can go ahead and forego shelter-in-place 27 and actually recommend to the local and state 28 authorities a protective action recommendation that 29 would dictate evacuation versus shelter-in-place, and 30 that was meant to apply to that unique circumstance 31 where you have a rapidly-developing event. And it's 32 my understanding that the inspection team, from talking 33 to members of your team, was told that it was the plan 34 to remove shelter-in-place, that they had intended to 35 remove that from the implementing procedure. You 36 know, in other words, they had made a mistake in 37 following or implementing the guidance in NUREG-0654 38 Supplement 3.
39 So if you have a different view, I'd want 40 to understand that. I need to understand and reconcile 41 the difference between what was communicated to the 42 team as they execute the inspection process and what 43 is your current position because it is my understanding 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that you have a differing view on the violations that 1
we have communicated to you.
2 And, again, as you heard Mark go through 3
his description of the issues, he did talk about how 4
we have preliminarily concluded there's a proposed 5
apparent violation. We have not made an enforcement 6
decision regarding the existence of a violation here 7
or the final significance determination associated 8
with that violation. So it's very important that we 9
develop a shared understanding of the facts and that 10 we hear from you what your assumptions are and then we 11 have the opportunity to have further dialogue on our 12 assumptions, so we can reach the most informed decision 13 here regarding the existence of a violation and then 14 what is the associated significance for that particular 15 violation.
16 So I look forward to hearing the discussion 17 and your planned presentations. So with that, I'll 18 turn it back over to you, Mr. Hettel, to begin any 19 discussion or presentation that you would like to 20 provide us.
21 MR. HETTEL: Mr. Dapas, we do take the 22 protection of the health and safety of the public very 23 seriously. So this afternoon, we'll be presenting our 24 perspective on the information NRC used to arrive at 25 the proposed White finding. And we'll also take the 26 opportunity to fully discuss the changes that were made 27 to our procedures back in June of last year. We will 28 lay out our facts, again, as we see them, and we'll 29 discuss how we reached our conclusion on the subject 30 relevant to the level of significance of the White 31 timing.
32 Our procedures do provide the appropriate 33 level of protection for the health and safety of the 34 public.
They still provide an option for 35 shelter-in-place should the conditions warrant to 36 protect the public from the effects of a possible 37 radioactive release. We believe that, through our 38 discussion today, you'll find our procedures are, in 39 fact, consistent with our emergency plan. And as far 40 as you look on this slide 3 with the agenda, again, we'll 41 step through the apparent violation, and we'll talk 42 about our emergency planning commitments and how the 43 regulatory guidelines are applied and also how our 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 procedures interact with that and demonstrate that we 1
follow our emergency plan and then also share some of 2
our lessons learned. And then we'll wrap it up with 3
a summary, and then I'll close. So that's kind of the 4
high-level agenda that we'll be going through.
5 So with that, I'll turn it over to Don 6
Gregoire.
7 MR. GREGOIRE: Okay. So I'd like to just 8
be clear on our position with regard to the apparent 9
violation. As mentioned, there's two sections of our 10 emergency plan that NRC has concluded that we failed 11 to follow, so I'll speak to each one separately. The 12 first one is in regard to Section 2.1 of the emergency 13 plan in which it was communicated that our procedure 14 did not implement the requirements of Section 2.1 15 because the procedure required the emergency director 16 in the control room to delegate the formulation of 17 protective action recommendations to the technical 18 support center or the emergency operations facility.
19 However, protective actions are a non-delegable 20 responsibility.
21 So I have three points that I'd like to 22 mention with that regard. And by the way, this is a 23 high-level review. I'm not going to cover in great 24 detail. We'll discuss it more in the later slides.
25 With regard to the first point, step 4.5.1 26 of the current version of the procedure, it is our 27 position, correctly transfers protective action 28 recommendations for expansion beyond ten miles to the 29 TSC or EOF because the procedure points to the use of 30 both dose projection and field teams to make the 31 necessary determination. This is consistent with 32 industry practice. The field team monitoring is an 33 augmented ERO function. Augmented ERO, emergency 34 response organization, is a function that is managed 35 by either our technical support center or emergency 36 operations facility. If either of these augmented 37 areas have been established, the emergency director 38 responsibility would have been transferred in 39 accordance with the station's emergency plan 40 implementing procedures, including protective action 41 recommendation responsibilities.
42
- Thirdly, the transfer of emergency 43 director responsibilities are carried out consistent 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 with our Emergency Plan Sections 2.1 and I'd like to 1
point out Section 5.5.2 for relying on field team data 2
when you get beyond the ten-mile EPZ.
3 The second area of non-compliance noted in 4
the NRC inspection report on page nine relates to two 5
examples where it was stated that we were non-complying 6
with Section 5.5, the first being we did not provide 7
for the development of shelter-in-place protective 8
action recommendations and, secondly, that we did not 9
provide for protective action recommendations to 10 protect against planned releases of radioactive 11 materials.
12 So I'd like to treat them separately, and 13 the first I'll speak to is the shelter-in-place 14 protective action recommendation.
So 15 shelter-in-place, it is our position shelter-in-place 16 was not removed as a protective action recommendation.
17 It can be recommended as a protective action by use of 18.1 and 7.2 of our procedure. And you'll 19 note the inspection report made no mention of 20.2.
21 The guidance in our procedure is based on 22 Supplement 3, 2011 version. And Supplement 3 clearly 23 states that it provides an acceptable mean for 24 complying with Appendix E and 10 CFR 50.47(b). In that 25 document, you will find no mention of planned releases, 26 puff releases. However, we still address it, and we 27 will speak to that in later time.
28 And, lastly, we will share with you how our 29 emergency plan points to sheltering and evacuation 30 guidance based on this NUREG document.
31 The second example of non-compliance with 32 Section 5.5 had to deal with planned releases.
33 Although a planned puff release is not explicitly 34 called out in the procedure in the current version, a 35 planned release continues to be addressed in the 36 procedure in another manner than in the previous 37 revision using Attachment 7.1 and 7.2. The ability to 38 use Attachment 7.1 and 7.2 provides consistency with 39 commitments made in Section 5.5.2 of the emergency 40 plan.
41 I want to sum it up this way. The 42 inspection report gives this picture that the emergency 43 plan says this and the procedures don't say that. As 44
17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a matter of fact, it's quoted on page five of the 1
inspection report. However, Revision 18 of the 2
procedure no longer follows the above-quoted sections 3
of the station's emergency plan. From August 2014 4
through March of this year, there have been a lot of 5
back-and-forth discussion on changes to our 6
implementing procedures and a lot had to deal with, 7
revolve around planned releases or puff releases, 8
which, again, as I mentioned, is no longer discussed 9
in the NUREG document.
10 When we saw the conclusions of the 11 inspection report, it appeared to us that a number of 12 points had not been reflected in the report, the number 13 of points that we had made. We believe that the 14 inspection report doesn't give a fair characterization 15 of this issue or the conversations that were held.
16 We're here to discuss those things that were either not 17 quoted or not emphasized in the determination of a 18 performance deficiency.
19 MR. DAPAS: Just to make sure I have clear 20 clarification, it's your contention that the station's 21 perspective regarding these issues was clearly 22 communicated during the inspection process and the 23 inspection report does not accurately reflect the 24 discussion that your staff had with our team?
25 MR. HETTEL: I was going to kind of bring 26 it back up or address it in the closing. I'm not sure 27 what, you know, Marc, maybe what transpired. We didn't 28 either communicate well enough, or I guess we're not 29 wanting to say that, you know, I guess we weren't going 30 to get into that, basically. We just feel that we have 31 not maybe communicated as clearly as we should, so we 32 want to, again, present our facts as we see them, again, 33 and I'll stress as we see them, you know, because, 34 again, you know, views are different and we understand 35 that. So I just think, as we went through the 36 conversations, we didn't make ourselves clear enough.
37 MR. DAPAS: Well, I think it's important, 38 and I stressed this in my opening here, it was my 39 understanding that the conclusions developed via the 40 inspections process was a function of interactions with 41 your staff. So if there was information that your 42 staff felt they communicated and it's not apparent how 43 that was considered as part of the inspection process, 44
18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you know, that's a potential disconnect there and we 1
need to understand that.
2 I certainly want to hear the licensee's 3
official position today regarding these apparent 4
violations, but I do want to understand what occurred 5
during the inspection process because I had, quite 6
frankly, a different understanding here from talking 7
to Mark here to my right. And he'll have the 8
opportunity to engage you, but I think that's an 9
important element that we reach closure on so that we 10 understand that because we rely on the inspection 11 function and we communicate preliminary conclusions 12 and the basis for that and we conduct debriefs and exit 13 meetings, and that's clearly an opportunity for any 14 member of your team that interacted with our staff to 15 say, wait a minute, you know, I had a discussion with 16 you on Wednesday and we talked about X, and how did you 17 consider that?
18 So I think that's important that we flush 19 that out, whether it be here or whether we do it 20 subsequently. I mean, the focus of this conference is 21 to make sure we understand your position clearly, you, 22 the licensee. But we want to make sure that we address 23 any inspection function disconnects that occurred.
24 MR. GREGOIRE: And we agree. We know 25 there were some areas we could improve overall in 26 understanding where the NRC was coming from and how we 27 translated the information to the NRC. But we agree 28 it's very important to have that dialogue.
29 I think the rest of our communication here 30 today is really to try to highlight some of those ares 31 as that we felt probably should be reflected on and 32 given a little more attention. So on our next slide, 33 you'll note that I have a star on this slide, and the 34 star is really trying to symbolize the areas where we 35 think there's some gaps in the communication and things 36 that we think should be added to the conversation. And 37 so any slide where you see a star on it, it's really 38 to address that information we think was not emphasized 39 enough earlier on in discussions.
40 So to this point, with regard to shelter 41 and evacuation and the consideration for shelter and 42 evacuation, it's our position that the emergency plan 43 specifically points to federal guidance on how you 44
19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 consider shelter and evacuation in your procedures for 1
protective action recommendations. We'll present 2
more information beyond that cited in the inspection 3
report that we believe is relevant to the finding.
4 Next slide. So just starting with the 5
foundation here, the regulation, as you know, 10 CFR 6
50.47 governs or describes a number of standards that 7
are required for emergency response plans. With 8
regard to this one specifically, 10 CFR 50.47(b)(10),
9 I won't read the whole thing to you but the very last 10 paragraph there is the guidelines for the choice of 11 protective actions during emergency consistent with 12 federal guidance are developed and in place.
13 So our message here today is that we have 14 four things that we're going to focus on in our 15 presentation: emergency planning commitments, what do 16 they actually say, what was omitted; what does the 17 federal guidance say and how did we evaluate that 18 federal guidance; what is the actual implementing 19 procedure, how do we use it, how would our emergency 20 director look at that procedure; and then, lastly, our 21 classification notification form where the protective 22 action gets issued. So we'll speak to all of that.
23 I do want to mention that the regulation 24 has consider shelter and evacuation but doesn't tell 25 us how to apply them in our procedures or action 26 schemes. Our emergency plan does point to federal 27 guidance that describes how we do this, and we'll walk 28 through that shortly. But the four elements here are 29 interlinked together to assure that appropriate 30 protective action recommendations will be made.
31 So the first point that we would like to 32 emphasize that we disagree with the conclusion on is 33 the statement that says that we failed to follow Section 34 5.5 of our plan. Now, as you see there, it mentions 35 we're required to have appropriate protective actions 36 for an airborne release of radioactivity, which were 37 evacuation and sheltering; and then the decisions to 38 evacuate or shelter or based on dose avoided; and then, 39 lastly, the protective actions are based on plant or 40 radiological conditions. What that doesn't say is how 41 that's implemented.
42 If we look to the next slide, this is a 43 section of 5.5 that was not included in the inspection 44
20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 report, but it goes on to further say that protective 1
action guidance discussed in Section 5.5.2 provide 2
preplanned guidance for making response decisions. So 3
it is directing us towards the federal guidance that 4
we would use for developing our protective action 5
scheme. We'll show later how that ties in.
6 Let's go to the next slide. So, again, 7
here's another slide. You know, this was referenced 8
in the inspection report, but we don't believe it was 9
given, you know, the proper emphasis. There's a 10 presumption that sheltering must always be considered 11 in every scenario. What we did, we evaluated 12 NUREG-0654. It describes sheltering and evacuation, 13 and it tells you how to consider it in your pre-planned 14 procedures.
15 I do want to emphasize that in this 16 commitment here in our emergency plan it says that our 17 shelter and evacuation guidance are based on both the 18 EPA document, as well as the NUREG-0654 Supplement 3 19 document. At this point, I don't believe there's any 20 concern or issue with our compliance with the EPA 21 document, so we're only going to go forward and speak 22 to the NUREG-0654 document.
23 The protective action recommendation 24 decision-making tool found in PPM 13.2.2, the tool that 25 specifies how shelter and evacuation are applied during 26 any general emergency at Columbia, is based on these 27 documents. What they do is guide us for a limited set 28 of scenario or conditions on how to consider 29 shelter-in-place versus evacuate for these scenarios.
30 Meeting these guides, in essence, meets the commitments 31 described in Section 5.5 of the emergency plan. And, 32 again, we'll describe how we meet that and how we 33 actually have additional guidance in our procedure 34 above and beyond the NUREG.
35 So I'll turn it over to Sean.
36 MR. CLIZBE: I'd like to discuss 37 NUREG-0654 Supplement 3 and our evaluation of it and 38 implementation of it in our procedures, so my intent 39 here isn't to read the regulation to you but more to 40 just describe our evaluation of the applicable section.
41 So from Supplement 3 guidance, it is clear 42 that application of the guidance is an acceptable 43 method to comply with 10 CFR Appendix E Part 50 and 44
21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 provide the guidance for the provisions of 10 CFR 1
50.47(b)(10). It also clearly supports that it's 2
acceptable guidance for developing a range of 3
protective action recommendations prior to an 4
emergency and not during the actual emergency itself.
5 This is the guidance that our Emergency 6
Plan Section 5.5.2.2 for developing protective action 7
recommendations at Columbia. Columbia used this 8
guidance for the development of our procedure 13.2.2 9
to meet our emergency planning commitments and develop 10 appropriate protective action recommendations. The 11 next two slides will walk through our development 12 process using the supplemental guidance and how it was 13 applied in developing our appropriate protective 14 action recommendation strategy.
15 So in Section 1.2 from the NUREG, I'd like 16 to discuss that Energy Northwest voluntarily used the 17 guidance that it demonstrated compliance with Appendix 18 E and 50.47(b)(10) and, secondly, the changes to our 19 procedure did not require an emergency plan change when 20 we implemented our shelter and evacuation protective 21 action recommendation tool. The change that we made 22 did not require an emergency plan change from our 23 procedure.
24 So as you look through the Supplement 3 25 guidance, it's noted that in Section 2.1 of the guidance 26 it suggests that licensees should use the attachment 27 and supplement to develop protective action 28 recommendation procedures and decision logic. What 29 we'd like to point out is Energy Northwest did use the 30 attachment for formulation of protective action 31 recommendation procedure, and it was the basis of 32 Revision 18 to 13.2.2.
33 So next we'll take a high-level walk 34 through of the attachment. So this tool is used 35 throughout the development process of our protective 36 action recommendation procedure. This tool is generic 37 to the industry and designed to be used by all nuclear 38 sites. With the tool being generic to all sites, there 39 is site-specific information that must be included to 40 make the tool useful. The tool starts off with a 41 general emergency, and it flows different directions 42 based on emergency conditions. Our decision-making 43 tool is similar to attachment, as we use this guidance 44
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to make our procedure change.
1 As we step through our procedure later in 2
the presentation, note the similar tool used in 3.1 and 7.2 of our procedure.
4 Next slide. As mentioned in the previous 5
slide, the guidance is generic to all sites. In here, 6
it's noted nuclear power plants should develop 7
site-specific strategies when using the guidance.
8 Additionally, as noted, the licensees are encouraged 9
to collaborate with off-site response organizations 10 during the development process.
11 Energy Northwest did develop a
12 site-specific strategy and did collaborate with 13 offsite response organizations. In our case, it's to 14 be Benton and Franklin County, the State of Washington, 15 and the Department of Energy.
16 In collaboration, Energy Northwest issued 17 Revision 18 to Procedure 13.2.2. The guidance clearly 18 suggests that the protective action recommendation 19 strategy should be developed prior to the emergency and 20 all invested parties should participate.
21 During collaboration with the offsite 22 response organizations, it was clear throughout the 23 process that Energy Northwest protective action 24 recommendations must align with federal guidance, and 25 ours does.
26 In the next few slides, we'll provide some 27 site-specific information that we used during our 28 development process that we think is important.
29 MR. DAPAS: Before you go on, I had a 30 question just following your flowchart here. On the 31 flowchart you've got on page 18, are you equating all 32 others to monitor and prepare to shelter?
33 MR. CLIZBE: So we haven't implemented the 34 monitor and prepare section, but we do have, in our 35 procedure, when we walk through it, we'll step through 36 when we shelter, the remaining sections would be 37 shelter-in-place.
38 MR. DAPAS: I look forward to that 39 discussion because I looked at your implementing 40 procedure relative to the Supplement 3, and, certainly, 41 in my view, it was intended to be monitor and prepare 42 and I thought your shelter remaining sections was your 43 phraseology for the monitor and prepare, and if your 44
23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 position is that that meant shelter-in-place I think 1
we really need to understand that.
2 MR. CLIZBE: Do you want to discuss it now 3
or later?
4 MR. DAPAS: Whenever it's convenient. If 5
you want to wait until we get to the actual slide, I 6
think that has that specific language.
7 MR. CLIZBE: This is, up on the slide, a 8
general representation of Energy Northwest emergency 9
planning zone. I circled the representation of the 10 two-mile, five-mile, and ten-mile distances. So this 11 site-specific consideration was used in the 12 development process, as suggested by the guidance.
13 And it's important to note the limited population and 14 the location of population being on the outer edge of 15 the emergency planning zone. This factors into the 16 evaluation process when determining whether shelter or 17 evacuation is appropriate. The low-population 18 density and distant location of the population within 19 the emergency planning zone informed the collaborative 20 evaluation process that which we revised our procedure.
21 Also note that Columbia Generating Station 22 max 90-percent evacuation time estimate is two hours 23 and 15 minutes.
24 So kind of walking through what our site 25 looks like. You know, obviously, we have a lot of 26 desert surrounding our site. We're on the Hanford 27 Nuclear Reservation. Most of our population resides 28 on the outer edges of the EPZ, this being the cities 29 of West Richland at the very bottom here, and over here 30 across the river is Franklin County which is a farming 31 community. So there's zero population in the two 32 miles, and in the five-mile there's a total of, well, 33 approximately 55 people residing over here in the 34 farming community, and then approximately 300 people 35 in our emergency planning zone. This kind of gives you 36 a look at what we're having to deal with in our planning 37 process.
38 Next slide, please. So looking through 39 NUREG-0654, this is the decision point in the 40 supplemental flowchart previously discussed where 41 consideration of evacuation versus shelter is 42 addressed. The guidance states that if the 90-percent 43 evacuation time estimate is less than three hours for 44
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a rapidly-progressing scenario, the most appropriate 1
or safest protective action is evacuation. Energy 2
Northwest 90-percent evacuation time estimate is two 3
hours and 15 minutes, and it's less than three hours 4
for the entire emergency planning zone.
5 As a result, Energy Northwest determined 6
the most appropriate protective action for a 7
rapidly-progressing scenario is evacuation.
8 Additionally, the low-population density and distant 9
location result in short evacuation times. Columbia 10 continues to recommend evacuation corrective action 11 recommendations for the zero-to two-mile and two-to 12 ten-mile distances as our PARTICULAR strategy for these 13 conditions.
14 As a result, there's no benefit to adopting 15 a staged evacuation, so no benefit in holding people 16 up. We have the ability to evacuate.
17 MR. HAIRE: This is Mark Haire. I just 18 want to make sure I clarify the particular section in 19 NUREG-0654 Supplement 3, the section you're pointing 20 to is Section 2.7, which is particular guidance for a 21 rapidly-progressing scenario. So there's lots of 22 other scenarios that need to be considered in your plan.
23 This is guidance for a rapidly-progressing scenario, 24 and we understand you applied the guidance out of Sup 25 3 for rapidly-progressing scenarios in consideration 26 of your evacuation time estimate and decided 27 evacuation, per the NUREG, was appropriate for 28 rapidly-progressing scenarios.
29 MR. CLIZBE: That's correct.
30 MR. HETTEL: And I would say it's 31 consistent with the attachment in the NUREG as far as 32 the tool that you use to determine your protective 33 action scheme.
34 MR. DAPAS: Right. And I guess I would 35 just add that we're very, very interested in how you 36 guys handle your guidance for PARs for things other than 37 rapidly-progressing scenarios because we're familiar 38 with our guidance for rapidly-progressing scenarios, 39 and we don't take exception to what you did for that.
40 MR. HETTEL: So can I just be clear?
41 We're talking about scenarios that are not currently 42 described in NUREG-0654; is that correct? And Section 43 2.7 talks about rapidly-progressing scenarios.
44
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. DAPAS: Right. So it's a particular 1
section, and then there are other, obviously, possible 2
scenarios that aren't described.
3 MR. HETTEL: They're all described in 4
5 MR. DAPAS: Yes. The long and short of 6
it, as I said in my opening, and perhaps this is not 7
a reflection on what occurred at the station, but it 8
was my understanding from talking to the team that you 9
applied that particular guidance for 10 rapidly-developing scenarios and inadvertently 11 removed guidance, I don't know if it was inadvertent 12 or by design but removed guidance regarding 13 shelter-in-place for other scenarios other than 14 rapidly-developing scenarios. So we're looking to see 15 where there is, in your implementing procedure, very 16 clearly direction to consider shelter-in-place for 17 other scenarios based on the dose-avoidance concept.
18 That's really, in my mind, the crux of it.
19 MR. CLIZBE: We agree with you, and we will 20 show you.
21 MR. HETTEL: If I can, too, I mean, we keep 22 using the terms "rapidly-progressing scenarios."
23 However, this is a specific type of an event. It's a 24 severe accident, so it is defined within the supplement 25 to a severe accident and also in an FAQ follow-up that 26 was asked by the industry and responded to what 27 constitutes a severe accident. So it's a specific type 28 of event that is expected to take place rapidly and 29 severe enough that it would be something handled within 30 the control room such that this would be the leg that 31 the control room emergency director would most likely 32 be entering without the assistance of anyone else. So 33 it's that type of severe accident.
34 MR. CLIZBE: I'd like to just also 35 emphasize that, you know, part of the struggle that 36 we've had with the communication up to this point is 37 we removed portions of our procedure dealing with a puff 38 release or planned release. And then we were asked how 39 did we address that, and we tried to address it in the 40 context of what's in NUREG-0654 or tried to use the 41 guidance in NUREG-0654 to address how we would look at 42 that scenario. So I think maybe some of the confusion 43 that has transpired between us is our attempts to try 44
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to fit, you know, something that was not clearly 1
described in the new guidance and to try to make it work.
2 So we'll gladly speak more on that if 3
anyone has any questions, but I think, you know, Mark, 4
you had mentioned some of the concerns about 5
communication. I think that was one issue there.
6 MR. CLIZBE: So the next consideration for 7
sheltering versus evacuation in the supplement is 8
associated with impediments to evacuation. Each one 9
of these impediments was evaluated and discussed with 10 the offsite response organizations and the appropriate 11 decisions are reflected in Revision 18 to Procedure 12 13.2.2.
13 Additionally, our procedure allows for 14 consideration of impediments not clearly identified in 15 the supplement, and we'll discuss that later. Next, 16 we'll discuss our evaluation of each impediment in the 17 following slides.
18 First, we'll start off with evacuation 19 support. The guidance states that lack of traffic 20 control may not be considered as an impediment when 21 there's low-population density within two miles.
22 Energy Northwest has a low population within two miles 23 of the site, and, through collaboration with the 24 offsite response organizations, it was determined the 25 lack of traffic control would not be an impediment to 26 evacuation. In fact, there's zero permanent residents 27 within two miles of our site.
28 This evaluation was incorporated into our 29 procedure, and Revision 18 has evacuation support not 30 being considered an impediment to evacuation.
31 Next, we'll take a look at hostile actions 32 as an impediment. The hostile action impediment 33 consideration was discussed with our offsite response 34 organizations and determined that, due to low 35 population surrounding the site, that an appropriate 36 protective action recommendation during this event 37 would be evacuate. Due to low population surrounding 38 the site, zero residents within two miles, the 39 evacuation recommendation would not be putting people 40 at risk of inadvertently becoming involved in hostile 41 action. We came to this agreement, and this analysis 42 was included in Revision 18 of our procedure as the 43 appropriate protective action.
44
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Next, we'll discuss adverse weather as an 1
impediment. During the collaboration process, it was 2
determined that the offsite response organizations 3
would have a better understanding of any adverse 4
weather impediments at the time of the event, 5
especially when the location of the at-risk population 6
is taken into account, that being on the outer edges 7
of our emergency planning zone. Therefore, Energy 8
Northwest did not include consideration of adverse 9
weather impediments in the protective action 10 recommendation process.
11 Additional considerations were given to 12 the evacuation time estimate values when evaluating the 13 impediment. The evacuation time estimate for all 14 populations in the emergency planning zone for the 15 adverse weather scenario were less than three hours.
16 While it was determined that Energy 17 Northwest did not need to consider adverse weather as 18 an impediment in our protective action recommendation 19 for the standard protective action recommendation, it 20 was taken into consideration for radiological release, 21 as described in Attachment 7.2 of our procedure. And 22 so we'll discuss that further.
23 So in summary, NUREG-0654 Supplement 3 24 guidance encourages licensees to use the guidance for 25 developing the protective action recommendation 26 strategies. Energy Northwest did use this guidance 27 and, with offsite response organization collaboration, 28 implemented Revision 18 to Procedure 13.2.2. The 29 NUREG was fully evaluated, revealing that evacuation 30 is the most appropriate protective action 31 recommendation for offsite emergency planning zone for 32 the scenarios that are described in the NUREG.
33 As we'll demonstrate, our procedure still 34 retains the mechanism for issuing a shelter-in-place 35 protective action recommendation when conditions not 36 specifically described in the NUREG warrant. Before 37 we demonstrate this, we'll take a quick review of the 38 changes to our procedure.
39 MR. GREGOIRE: I'd like to just point out 40 the inspection report makes these three conclusions 41 that we disagree with. The first is that the 42 assumption that we removed shelter-in-place as a 43 protective action; number two, that we removed a 44
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 recommendation of protective actions for planned 1
releases; and, three, that we eliminated the ability 2
of the emergency response organization to recommend 3
protective actions outside the plume exposure zone.
4 Revision 18 eliminated specific language 5
for shelter-in-place for some cases. However, it did 6
not remove shelter-in-place considerations or limit 7
abilities associated with protective action 8
recommendations within or outside the plume exposure 9
emergency planning zone.
10 I'll turn it back over to Sean.
11 MR. CLIZBE: So I'm going to walk through 12 our Procedure 13.2.2 Revision 17 and Revision 18 13 changes; but, first, I wanted to discuss why we made 14 the change in June of 2014. So the reason the change 15 occurred was to implement the 2011 version of 16 Supplement 3 to NUREG-0654 with the objective of 17 reducing potential health effects in the event of a 18 nuclear power plant
- accident, incorporated 19 shelter-in-place considerations in the structure of 20 protective action recommendation decision-making 21
- tool, and also implemented some formatting 22 improvements based on our site process. But the only 23 reason that we implemented this guidance is it's the 24 best guidance, and it's based on real large emergency 25 operating experience and it's the safest for the 26 public.
27 Next, I'll walk through major changes to 28 our procedure that are relevant for discussion today.
29 So on the screen, we have Revision 17 and our current 30 revision, Revision 18, up. There's kind of some 31 administrative things to take care of first. So the 32 only text on Revision 17 that you'll see is text that 33 changed. Green text in Revision 18 is text that was 34 added, and blue text in both revisions is text that 35 hasn't changed but is relevant to the discussion today.
36 So the changes that were made here were to 37 include a statement and updates to ensure the 38 dose-projection tool was the first tool available for 39 use, and the table in the back has a backup.
40 Additionally, we split it into two sections for 41 clarity. These changes do not impact the range of 42 protective action recommendations to be considered by 43 the emergency director, nor the obligation to make 44
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 protective action recommendations beyond the emergency 1
planning zone.
2 The only change in this section here is we 3
removed the mention of a planned puff release. That 4
language is no longer included in NUREG-0654 Supplement 5
3, 2011, and so that's a removal of -- it's hard to see, 6
I guess, from here but removal of this 4.3.5 step.
7 While we did remove the step, the concept of a planned 8
release is still considered in our procedure. And, 9
again, we're going to walk through that in detail.
10 And also in step 4.3.5, there's a known 11 impediment language in there, and this was also still 12 addressed and it's addressed in Attachment 7.2 in our 13 Revision 18 procedure.
14 Step 4.4.4 in Revision 18, and it says 15 "focus on how to implement a protective action 16 recommendation and not what protective action 17 recommendation should be made." It's simply letting 18 the offsite response organization know that we're going 19 to vent containment so they can prepare.
20 So what didn't change? The blue text, 21 4.4.2. It still requires the use of Attachment 7.2 for 22 updating protective action recommendations. The 23 procedure points to 7.1 and 7.2, which provides the 24 mechanism for an emergency director to consider shelter 25 employees. Attachment 7.2 wasn't mentioned in the 26 inspection report, and we think it's important to the 27 conversation
- today, as this is part of the 28 decision-making process for the emergency director.
29 So we're going to discuss each attachment next.
30 MR. ELKMANN: Just a second. Go back to 31 that last slide. This is Paul Elkmann. You talked a 32 couple of times about how Supplement 3, you talked about 33 the need for, how Supplement 3 took away the need for 34 puff releases. I'm not sure that we would agree that 35 the guidance took away that. It wasn't mentioned, but 36 that doesn't mean that it supersedes previous guidance 37 on puff releases. In discussions that we had over the 38 winter with the staff, we were told that you understood 39 the old puff release to be the same as 40 rapidly-progressing, and I guess if you could explain 41 a little bit about why you came to that conclusion.
42 MR. CLIZBE: So the point we're trying to 43 make here is that the term "planned puff release" is 44
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 no longer in the guidance, but our procedure still does 1
take into consideration a planned release. And that's 2
the part we're going to walk through, and we think that 3
that's specifically the part that maybe wasn't 4
communicated clearly enough in our original 5
conversations.
6 MR. ELKMANN: But we're saying that, 7
because you read Supplement 3 as being silent on the 8
puff release, you didn't have to address it?
9 MR. CLIZBE: We addressed planned release 10 in our procedure.
11 MR. GREGOIRE: I do want to mention again, 12 you go to the intro of the NUREG and it says you comply 13 with this, you meet the regulation. It doesn't speak 14 to it. And albeit, an EPFAQ a few years later, 2013, 15 where the industry asked the question, hey this 16 guidance doesn't mention it, how do you treat it, 17 essentially.
18 And we are treating it, but we're just not 19 treating it in a direct manner because, again, like I 20 said, the NUREG0654 doesn't treat it in a direct manner.
21 But we are addressing it in another manner and we will 22 speak to that.
23 MR. HETTEL: I can point, I guess, state at 24 least in through my understanding and kind of 25 discussion on this, when you take a look at the 4.4.4 26 and it's also about containment vent, in essence what 27 puff releases whether it's short release or release 28 with a known duration so to speak. I mean, you're 29 basically - mini-containment's probably going to be the 30 most likely situation.
31 So, again, like I think Don and them have 32 been saying, we have the ability to, whether you call 33 a puff release, whether you call it mini-containment, 34 regardless of what you want to call the name of it, our 35 procedures would still evaluate the PAR for that and 36 sheltering-in-place would be one of those that we'd be 37 evaluating.
38 MR. CLIZBE: Yes. I think that's the 39 bottom line here.
40 MR. HETTEL: Yes.
41 MR. CLIZBE: Whether NUREG-0654 talks about 42 plan release, whether it was previously termed a puff 43 release in your implementing procedures. My interest 44
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 is, do you have a process to provide for a protective 1
action recommendation in this scenario where you would 2
need to vent containment. Which is a planned release 3
here.
4 MR. HETTEL: Yes.
5 MR. CLIZBE: And I think we need to talk a 6
bit about -- discuss the proposed activity with offsite 7
authorities to assist them with protective action 8
implementation or is it the expectation that you 9
actually have a protective action recommendation 10 you're providing versus that engagement with offsite 11 authorities. I think we need to understand that 12 aspect.
13 MR. GREGOIRE: I think we'll be very clear 14 on it when he gets to -- Dave Brown, he'll actually speak 15 through how he uses the guidance to reach that. So I 16 think if you'd give us a few moments, we'll get to that 17 point.
18 MR. HAIRE: This is Mark here again. I 19 just, not to belabor the point, but I want to make sure 20 I understand. So we understand in our review that you 21 still mention a discussion of shelter-in-place as a 22 potential protective action in your Attachment 7.2.
23 And your view is that the way that, that could get 24 implemented by Control Room staff or Emergency Director 25 staff is by virtue of this reference to it in Step 4.4.2, 26 where it says --
27 MR. GREGOIRE: That's for the updated PARs, 28 yes.
29 MR.
HAIRE:
It
- says, determine the 30 appropriate offsite PAR by comparing the 31 plume-projected dose and field monitoring team data 32 with a protective action guidance provided in 33 for the early phase of the nuclear 34 incident. So that's your view is that's the staff's 35 connection to potentially making a shelter-in-place.
36 MR. GREGOIRE: Yes. This is one of the 37 points on the conversation we had on the phone, I 38 believe it was in February time frame, where we were 39 told that our staff would specifically jump over that 40 step. And Dave Brown will speak to that and how he uses 41 the procedure.
42 But we don't agree with that conclusion, 43 so, again, if you would allow us to wait until Dave 44
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Brown, who is one of our Emergency Directors, to walk 1
through that.
2 MR. CLIZBE: Next, we'd like to discuss 3.1 and Revision 17 and 18, in just kind of 4
a high-level walkthrough familiarity. Entering the 5
top of the flow chart, General Emergency, down to 6
determine is it a release in progress? Yes, go to the 7
right. Which is going to drive you to look at the next 8
Attachment, which is 7.2, which we've been discussing 9
quite a bit.
10 And then if it's no, then it drives you down 11 to these actions in this note box. So previously in 12 the previous Revision, this is where we had a "See Note" 13 for puff release, so that's what was removed in the 14 Revision 18. Okay.
15 Now I'll use the closer one so you guys can 16 see it better, how about that? So removal of the 17 terminology puff release, again, was removed for 18 consistency as we removed it in Step 4.3.5 of the 19 procedure.
20 And there were no substantial changes to 21 the release in progress path other than we had 22 additional footnotes added. And, again, after we get 23 done with my portion of the procedure changes, we'll 24 have an Emergency Director walk you through the use of 25 the procedure and the associated attachments.
26 MR. GREGOIRE: I do want to make this quick 27 point. Mark, you had asked me if there was any 28 differences between what we had sent earlier and the 29 newer version. So on Slide 31, I just wanted to point 30 out that the previous version didn't have green text 31 or highlighted the section areas. We actually changed 32 those that had changed text. But in case somebody's 33 looking at a previous version of the presentation.
34 MR. DAPAS: Just so I'm clear, and thank you 35 for that, the box it talks about evacuate sections where 36 EPA protective action guidelines are projected to be 37 exceeded based on dose assessments or actual survey 38 readings.
39
- Plus, the next if not previously 40 recommended, then evacuate all sections there to two 41 miles and ten miles downwind and shelter remaining 42 sections. Is it your contention that, that in 43 shelter remaining sections meaning shelter-in-place?
44
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CLIZBE: That's the current definition 1
we have in our emergency plan is shelter is a 2
shelter-in-place definition.
3 MR. DAPAS: So shelter remaining sections 4
you're maintaining is that every other section -- the 5
population that exists in all the rest of the remaining 6
sectors, other than zero to two miles and ten miles 7
downwind, you would shelter-in-place as a dose 8
avoidance versus when you go look at the NUREG it talks 9
about monitor and prepare? That your plan was to have 10 everyone shelter?
11 MR. CLIZBE: Yes.
12 MR. DAPAS: That's always been the intent?
13 MR. CLIZBE: That's been the intent.
14 MR. DAPAS: Okay.
15 MR. CLIZBE: We're working with our offsite 16 response organizations and we currently were working 17 through them when this came up to implement a better 18 monitor and prepare strategy. And we'll continue to 19 work with them and get that -- the intent is to work 20 with the offsite response organizations to implement 21 the monitor and prepare language that's in this.
22 MR. DAPAS: Well, this is important here.
23 Because what I'm hearing you say is -- I want to 24 understand if you truly intended that to be 25 shelter-in-place and the individuals that would 26 implement this understood it or is it meant to be 27 monitor and prepare and you used the words shelter 28 remaining sections. In my view, this is an important 29 distinction and I want to understand your view on that 30 and the basis for that.
31 MR. GREGOIRE: Dave, you should speak to 32 that.
33 MR. BROWN: Yes. So, this particular box 34 and that language did not change with Rev 18. So it 35 has been our station policy, we call it the Standard 36 PAR, to at a general emergency evacuate zero to two 37 miles, evacuate downwind sectors, shelter remaining 38 sectors. So that's our station emergency plan 39 guidance. I think Sean and/or Don can talk about what 40 the offsites describe shelter as being because I've 41 seen that definition as we prepared for this 42 conference.
43 MR. HAIRE: Hi Dave, this is Mark Haire. I 44
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 know we're beating the horse to death here, but as Marc 1
said this is an important distinction for us. And as 2
you mentioned and we saw, that language about evacuate 3
certain sectors and downwind and then shelter everybody 4
else, that language was in your previous version.
5 The previous version also included 6
distinct and separate considerations for potential 7
shelter-in-place PAR for dose avoidance. And in fact, 8
your Attachment 7.2 talks about a separate PAR for dose 9
avoidance.
10 And the way you're using this language here 11 in the flow chart and the way similar language is used 12 in the NUREG implies not that you'd be telling everybody 13 that doesn't evacuate to go indoors, close their 14 windows, turn off their air conditioning, and hide from 15 dose, but rather you're telling them to hang out and 16 wait for further instructions. Which to us is a very 17 different issue.
18 MR. BROWN: Right.
19 MR. HAIRE: It's not a protective action 20 recommendation to tell everybody you're not protecting 21 to standby. Which is what it sounds like you're using 22 this flow chart to mean.
23 MR. BROWN: So I will go through the flow 24 chart with some examples where I will use Attachment 25 7.2 in that discussion. What I was really trying to 26 get it is the Standard PAR language was not part of our 27 change. It's been in the procedure as long as I can 28 remember and I've been a licensed operator at the site 29 since 1998.
30 MR. HAIRE: Right.
31 MR. BROWN: So I've been through a lot of 32 training and I've seen this --
33 MR. HAIRE: I guess our --
35 MR. HAIRE: Our concern though, the 36 distinction we're trying to understand is when you have 37 issued the protective action recommendation for two 38 miles evacuate, ten miles downwind evacuate, shelter 39 everybody else, were you trying to protect everybody 40 else with a shelter PAR by telling them to turn off their 41 air conditioning and close their doors or were you just 42 telling everybody else standby and wait for further 43 instructions? Because those are very, very different.
44
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. GREGOIRE: We know the NUREG0654 uses 1
the monitor and prepare language and we haven't built 2
that into our process yet. Our definition for shelter 3
still is the same in the emergency plan. So we haven't 4
changed that.
5 We know that there's a -- we were going to 6
proceed towards down that path. But the other thing 7
to consider, I realize you don't call it a protective 8
action, but having people not travel through the plume 9
zone is an important detail for protection even though 10 we're asking them to go inside, shut the door, shut the 11 windows, even if they're not in the plume zone area.
12 So in essence, we're still -- it may not 13 be called a protective action because they're not in 14 the plume zone, but also keeping them out of traveling 15 through the plume zone is somewhat of a protective 16 action. I know it hasn't been dialogued much on, but 17 that hasn't changed.
18 So we want to make the point that this 19 hasn't changed, although that we were working towards 20 the process of implementing something along that line 21 of monitor and prepare. We have to change our forms, 22 we have to change our procedures, we have to change 23 agreements with the offsites.
24 MR. HAIRE: I just want to make sure -- why 25 we're pursuing this is because it's my understanding 26 that you're contending that the shelter-in-place was 27 always an aspect that you'd consider by virtue of this 28 shelter remaining sections, right?
29 MR. GREGOIRE: That's one part of it, yes.
30 MR. HAIRE: That's one part. And we'll get 31 to 7.2 here, but I'd like to know, when you conducted 32 exercises and you had the general emergency scenario 33
- here, was your Emergency Director directing 34 evacuations zero to two miles and then ten miles 35 downwind and then for everyone else shelter-in-place 36 and that was part of your protective action 37 recommendation and that's what you actually practiced 38 when you had exercises.
39 Versus did you actually practice what is 40 considered this monitor and prepare and is that what 41 you did during the exercises or did you actually expect 42 and issue a protective action recommendation that would 43 have every other section, you'd have the populace there 44
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 sheltering-in-place. Which gets to closing windows, 1
turning off air conditioning.
2 And that was part of your protective action 3
recommendation. If that's what you're maintaining 4
here that, that was the intent. Did you practice that 5
in your exercises?
6 MR. GREGOIRE: Yes. So we went through and 7
validated with our offsite response organizations on 8
what it meant when we gave the message out. What was 9
the message that the public was receiving? And the AS 10 messages that they were giving for shelter was the 11 shelter-in-place definition that's in our emergency 12 plan.
13 MR. HAIRE: So their exercises, the shelter 14 remaining sections was translated to shelter-in-place.
15 That was part of your PAR? And that's what you have 16 done for each exercise that reaches the general 17 emergency where there's a release involved, right?
18 MR. GREGOIRE: Yes.
19 MR. HAIRE: Okay. So we should've had the 20 opportunity via observation of those exercises to 21 validate that, right? All right. Let's move on.
22 MR.
CLIZBE:
So next we'll discuss 23.2. And this is where the consideration 24 for sheltering versus evacuation is located. So the 25 previous section for release in progress drives you to 26 use Attachment 7.2.
27 And this is where it's found and it has not 28 changed from Revision 17 to Revision 18. The one minor 29 change here was that we added a reminder that no matter, 30 regardless of the protective action recommendation 31 that we give, it's the offsite response organizations 32 have the final say on the decision.
33 This Attachment, like I mentioned, is the 34 tool for determining shelter versus evacuation and it 35 wasn't specifically referenced in the Inspection 36 Report, but we think it's important to our conversation 37 today. And, again, we'll walk through it with an 38 Emergency Director to show us appropriate use. I'm 39 going to turn it over to Don here.
40 MR. GREGOIRE: Okay. So with regards to 41 the Inspection Report --
42 MR. DAPAS: Can I ask you to indulge me.?
43 Since we've spent a fair amount of time talking about 44
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 this, can we go and have you walk through exactly how 1
you would, if you were an Emergency Director, refer to 2.1 and 7.2 and how you would make that 3
shelter-in-place protective action recommendation?
4 It seems appropriate in my mind to do that.
5 MR. GREGOIRE: Okay. So what we'll do is 6
jump to Slide 37 and turn it over to Dave Brown, our 7
Emergency Director, to do that.
8 MR. BROWN: Okay. Good afternoon. Again, 9
my name's Dave Brown. I've been Emergency Director 10 since 2003 when I qualified as a Shift Manager. Been 11 through annual training on emergency plans since 1998 12 when I obtained an SRO license. So been through a lot 13 of training, drills, evaluations, actual alert 14 activation, I was there.
15 And so when I walk through the procedure, 16 I'm going to explain from my perspective what the words 17 mean. Okay. In my experience. Also, I'll try to 18 highlight where training has emphasized different 19 things.
20 So starting with PPM 13.2.2, Initial Plant 21 Based PARs. When the plant has reached or is about to 22 reach a general emergency for a classification 23 occurring at the station. I've used Section 4.2 in the 24 procedure and I'm going to try to use my pointer and 25 start with step 4.2.1.
26 So the thing about procedure use 27 fundamentals at our site, if the steps have numbers, 28 you do them in sequence one after the other. You don't 29 skip around unless that procedure gives you permission 30 to do that. So what would be different is if the steps 31 are just bulleted, then those steps could be done in 32 any order.
33 So I'm going to step right through this 34 procedure starting with Step 4.2.1 and that's going to 35 drive me to evaluate my decision for protective action 36 recommendation in accordance with Attachment 7.1.
37 That's the next slide.
38 So Attachment 7.1 for the case we're on in 39 a general emergency, and I have a release in progress, 40 or I have a planned release I'm about to take, I'm going 41 to enter this chart in the same spot. Enter up here 42 in the upper arrow where it says "Enter if site area 43 emergency or general emergency is declared." With the 44
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 general emergency, I'm going to go down.
1 So the only difference there in my 2
discussion is that if we're at a site area emergency 3
and we plan on doing a planned release, well I'm going 4
to upgrade to a general as a part of that evolution and 5
move down through the chart. And then I'm going to 6
evaluate this decision that I'm in.
7 Do I have a release in progress? And I 8
move over to the right and that points me to evaluate 9
my protective action recommendation in accordance with 10.2.
11 MR. DAPAS: Dave, could I just back you up 12 for a second? You used the word evaluate per 13, but your procedure says evacuate --
14 MR. BROWN: Right.
15 MR. DAPAS: -- per Attachment 7.2.
16 MR. BROWN: So the direction is to evacuate 17 sections where EPA PAGs are projected to be exceeded 18 based on dose assessments. Attachment 7.2 is the 19 dialogue or expectations in the procedure that I have 20 to consider a
shelter-in-place if extreme 21 circumstances are warranted. So that's what I was just 22 getting ready to explain.
23 So with any release that we have, it 24 doesn't matter if it's a planned release or an 25 unisolable leak, I'm in this box and I'm going to 26 evaluate -- I'm going to evacuate sectors, excuse me, 27 I used the wrong word, in accordance with Attachment 28 7.2. Did I clarify your question?
29 MR. DAPAS: Well, I just wanted to make sure 30 that we were speaking the same language. And to me, 31 if I'm following the procedure and I read the word 32 evaluate per 7.2, then I think I've got to go to 7.2 33 and evaluate what the right PAR is.
34 But when I read the word in the procedure 35 evacuate where PAGs are being exceeded per 7.2 and I'm 36 not going to 7.2 to assess whether I'm going to shelter, 37 I'm going to 7.2 to assess what parts to evacuate.
38 That's --
39 MR. BROWN: Okay.
40 MR. DAPAS: -- the part I'm trying to 41 understand is if we're using this as a tool to say we 42 would get to 7.2 and consider shelter, are we following 43 the procedure? That's what I'm trying to understand.
44
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. BROWN: Yes. So let me clarify that.
1 So the next slide is Attachment 7.2 and let me point 2
out something. So back to my training and experience.
3 So we have the Standard PAR that we issue for general 4
emergency of zero to two miles evacuate, evacuate 5
downwind, shelter remaining sections. That's our 6
Standard PAR.
7 I've been taught use Attachment 7.2 to 8
decide if you need to deviate from that Standard PAR.
9 And it gives some specific considerations here. Where 10 sheltering may be preferred protective action when it 11 will provide protection equal to or greater than 12 evacuation.
13 I've read those words for 17 years.
14 They're not any different last year than they are today.
15 And like I said, I've been taught in training, I've been 16 coached on it, that in certain circumstances, like 17 severe weather, you don't evacuate. You do need to 18 consider sheltering.
19 And so that's really what it amounts to is 20 that the direction is to evacuate. That is our 21 Standard PAR. The procedure also tells me to consider 22 these other circumstances.
23 MR. ELKMANN: Dave, two questions on that 24 if you would? The first is, I thought we heard earlier 25 that you agreed with your offsite authorities that in 26 circumstances such as severe weather there might 27 impediments, but that you were not going to consider 28 those as part of your process.
29 MR. CLIZBE: So with the exception -- on 30 that slide with the exception of the radiological 31 release scenario.
32 MR. ELKMANN: That's not what you discussed 33 earlier.
34 MR. BROWN: Okay. So with the release in 35 progress, we do go to this chart, this Attachment, 36 excuse me. And then based on the circumstances -- I 37 tend to want to point over here, but I know that's hard 38 for you guys to read and I'm hitting Grover in the head.
39 MR. GREGOIRE: Can we just make a -- address 40 one point. And Paul, I know you've mentioned something 41 that we said. If you look on Slide 25, it specifically 42 says there that we retain consideration for sheltering 43 in adverse weather conditions during a radioactive 44
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 release. Maybe we didn't emphasize that clearly when 1
we were at that slide. But on Slide 25.
2 MR.
ELKMANN:
That doesn't seem to 3
completely jive with the description of your process.
4 The second question goes to the first part of the vote.
5 Go back to 7.2, Attachment 7.2, Slide 39.
6 That first -- where it starts when shelter 7
would be the preferred in red, as a Command and Control 8
individual, what process do you have to know whether 9
protection is greater than or equal as far as 10 sheltering? It doesn't seem to provide me a tool for 11 making that decision.
12 MR. BROWN: Right. So the tools that we 13 have available, I talk to my team including at the 14 table, we have offsite representation. So they can 15 weigh in. If they have particular details that we 16 don't have in terms of impediments, they can bring that 17 up.
18 As far as dose, the Radiological Emergency 19 Manager and I talk about it. We use the dose assessment 20 tool that we have in front of us for that release. And 21 use that to help us make our decision.
22 So part of what we're able to do with our 23 dose assessment tool is show how far into the emergency 24 planning zone are we above one Rem or five Rem CDE. So 25 that's just a -- using different dose assessments, you 26 can show where the plume is at in the planning zone and 27 you can make a decision from there.
28 MR. ELKMANN: So does your dose assessment 29 tool provide you an assessment of the dose under the 30 shelter-in-place option versus the dose under the 31 evacuate option so you can make the comparison?
32 MR. BROWN: The dose assessment tool 33 doesn't tell you what to do. You use your professional 34 judgment. So right now what we're doing is we're 35 considering these impediments, including roads that 36 might be closed due to severe accident or competing 37 disasters and things like that. That's something our 38 Security Manager might be privy to as he's talked with 39 the local law enforcement.
40 So this is clearly a judgment space that 41 we're in. When we're using Attachment 7.2, applying 42 it to the circumstances, we are using our collective 43 experience and our tools. Any other questions on that?
44
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. DAPAS: Yes. I have a question here.
1 If I heard you correctly, this evacuate sections where 2
EPA PAGs, and there's reference to Attachment 7.2, are 3
projected to be exceeded, that's where you go to 7.2 4
and you evaluate whether you should evacuate or 5
shelter-in-place. Am I hearing you correctly?
6 MR. BROWN: So, like I said, I've 7
interpreted this table for many years to apply that the 8
direction in Attachment 7.1 says evacuate sectors above 9
one and five. I've interpreted this table and I've 10 been reinforced in my training that you evacuate unless 11 you meet one of these thresholds for sheltering, then 12 you shelter.
13 MR. DAPAS: Yes. I appreciate that.
14 Because when I read that evacuate sections where EPA 15 PAGs, Attachment 7.2, that tells you what the EPA PAGs 16 are, the one to five Rem TEDE or 5 to 25 Rem CDE thyroid 17 or 50 to 500 Rem skin.
18 If any of those PAGs are exceeded or 19 projected to be exceeded, based on the dose assessments 20 or actually survey readings, so you are evacuating 21 those sections plus if not previously recommended, then 22 evacuate all sections zero to two miles and ten miles 23 downwind and shelter remaining sections. And it's 24 been your contention that shelter remaining sections 25 meant shelter-in-place.
26 It's not clear to me why you're going 27 through this, an evaluation of shelter-in-place when 28 you've got specific direction here that tells you 29 you're going to shelter all the other sections 30 in-place. It seems like this is inappropriate given 31 the directions.
32 So now you're telling me, and I'm seeking 33 to understand, you're telling me that this evacuate 34 sections where EPA PAGs, and because it has reference 35 to Attachment 7.2, that has been your trigger point to 36 go to 7.2 and determine whether evacuation is 37 appropriate or shelter-in-place. Independent of the 38 subsequent guidance there that would tell you to 39 shelter all sections, remaining sections.
40 MR. BROWN: Yes. So I believe I said that.
41 And that is my position that the shelter-in-place 42 discussion is really pertinent to the downwind sectors 43 because our Standard PAR is to shelter remaining 44
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 unaffected sectors.
1 So what we're applying Attachment 7.2 to 2
is that downwind sector. Do we evacuate or do we 3
shelter that section? Every other sector two miles to 4
ten miles is being sheltered.
5 MR. GREGOIRE: I do want to mention that 6
when this was first brought to our attention in the 7
phone call, I believe it was in February time frame, 8
me personally as the Reg Affairs Manager, I had some 9
concerns. Was our staff interpreting that step there 10 and disregarding or feeling like they did not or they 11 should not consider sheltering in-place in Attachment 12 7.2?
13 Knowing that our staff hadn't been 14 interviewed in this process, I wanted to know for myself 15 from a safety prospective, how are they using the table?
16 So we interviewed the four emergency operation facility 17 Emergency Directors and how they would use the 18 procedure and if under certain scenarios, and maybe 19 this is leading, but I wanted to know does the procedure 20 work for them? How do they get to shelter-in-place?
21 And they all pointed to using this box, 22 this section, that Attachment 7.2 as what they would 23 use to introduce shelter-in-place considerations for 24 a planned release.
25 MR. HETTEL: Don, you said four, we actually 26 interviewed three and then we didn't take the other one.
27 MR. GREGOIRE: Yes. So we actually had 28 three that were onsite and the fourth one was out for 29 medical reasons. And when he came back we actually dry 30 ran him through a scenario and tabletop and he was able 31 to use the procedure to reach a shelter-in-place 32 consideration.
33 MR. HETTEL: It's for -- any containment 34 scenario.
35 MR. KAHLER: Excuse me. Bob Kahler from 36 NRC Headquarters. I guess then, during the inspection 37 process to better understand what the actual 38 individuals would do during a real event, following the 39 changes that were made between Rev 17 and Rev 18, the 40 questions started coming up.
41 Discussion turned to training modules as 42 to the change that was incorporated into Rev 18 and what 43 was intended to change in the training modules to 44
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 reflect that change. Now, I understand what you're 1
talking about in the past, which was associated with 2
Rev 17. What we're discussing is the Rev 18.
3 And it was my understanding that during 4
that discussion with the staff at Columbia, that a 5
discussion on the training module occurred and about 6
action items that had not yet been completed the 7
training that it intended to train individuals for the 8
removal of shelter from even the judgment piece that 9
was in Table 7.2.
10 To continue on and then all the training 11 was yet to take place, training changes were yet to take 12 place. Some of them had occurred already to discuss 13 the shelter being removed from the Attachment 7.1, 14 where you go through the flow chart. It no longer 15 discusses the use of sheltering even after ten miles.
16 And the fact that I believe during that 17 discussion was discussed what was meant by sheltering 18 outside of that zero to two and downwind legs. That 19 the shelter was not the same as it was previously and 20 that a difference of how that shelter would be looked 21 at in the future was to be made. And it was only the 22 monitor and prepare.
23 So the changes have not yet been made to 24 the training module. So can you explain a little bit 25 about that discussion and where maybe the discussion 26 that, I guess, we heard and that you said may have 27 difference in what was made between Rev 17 and 18 and 28 what was planned to occur during the training modules 29 as per the action item that you had initiated?
30 MR. GOSNEY: Sure. I'll --
31 MR. KAHLER: We're around in circles there, 32 but --
33 MR. GOSNEY: Maybe A.J. can jump in here, 34 he's in charge of the training program. But we 35 recognize when we're going through the process and 36 certain discussions that our training required some 37 additional updates. When we talked with Mr. Elkmann 38 we recognized that.
39 We put all of our training on hold. No one 40 had received any training. And evaluated the training 41 module and it does need updated to incorporate the 42 changes that we made to Revision 18, incorporating the 43 0654 guidance. So that's really the way the discussion 44
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 went. I can't recall any additional conversations. I 1
don't know if A.J. can --
2 MR. FAHNESTOCK: So, I can jump in.
3 MR. GOSNEY: -- jump in. You need a 4
microphone.
5 MR. FAHNESTOCK: I need a microphone.
6 MR. GOSNEY: Do you want to come up here and 7
use mine?
8 MR. FAHNESTOCK: So I'll jump in Kurt's 9
position. My name is A.J. Fahnestock. As Sean 10 mentioned, I work for him in Emergency Preparedness.
11 So the discussion was about some changes 12 that we had made to the training materials which removed 13 the reference to what was, I believe, Attachment 7.3, 14 which had times associated with it, evacuation time 15 estimates associated with it and was referenced to 16 Section 4.3.5 in the procedure which talked about the 17 use of those evacuation time estimates for puff 18 release.
19 That had been sequentially removed from 20 the procedure. And we had some dialogue about the 21 process by which that was done. We didn't end up 22 writing a Condition Report prior to that conversation 23 about the timing of that removal. It was something 24 that did not meet our standards at the station -- the 25 timing of the removal did not. Again, that was to align 26 it with the procedure changes that were made in June 27 of 2014.
28 The discussion having to do with 29 shelter-in-place was certainly not as crisp as it 30 could've been. In fact, we came back to the table on 31 a subsequent phone call and provided information 32 directly out of our county's EAS messaging system, 33 follow-on message for EAS broadcast and, in fact, read 34 the language directly out of that follow-on message.
35 And if you'd like, I could repeat that here today.
36 This is the EAS follow-on message that Sean 37 referenced earlier having to do with shelter-in-place.
38 And it actually describes the actions that the public 39 should take for shelter-in-place. And while we 40 recognize that, that discussion may not have been as 41 crisp as it needed to be, we did initiate a follow-on 42 dialogue to clarify that position on a subsequent phone 43 call. And I can read you that language if you like.
44
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Okay. So this comes right out of the 1
county EAS message. And it states, "If you live or work 2
in an area that was asked to take shelter, go into a 3
house or other well-built structure. Close all 4
windows and outside doors. Close anything else that 5
might bring air in from the outside, which would include 6
HVAC potentially, such as fireplace damper, range fan, 7
bathroom vents or clothes dryer vents. Turn off range 8
fans and clothes dryers."
9 And it goes on to provide additional 10 information that's not really relevant to the 11 conversation here. But in short, the public is told 12 to shelter, which involves shelter-in-place. Go 13 indoors, close off access to outside air. And that was 14 communicated subsequently.
15 MR. ELKMANN: So just so I'm clear. It's 16 an important point in my mind.
17 MR. FAHNESTOCK: Yes.
18 MR. ELKMANN: In practice and during the 19 exercise, and you contend in an actual event, when 20 you're following Attachment 7.1, you would evacuate all 21 sections zero to two miles and ten miles downwind and 22 you would shelter-in-place remaining sections. And 23 that message that you just referred to is what would 24 be shared --
25 MR. FAHNESTOCK: That's correct.
26 MR. ELKMANN: -- as part of the protective 27 action recommendation and Mr. Brown would evacuate 28 sections where EPA PAGs are projected to be exceeded 29 based on dose assessments.
30 That you looked at Attachment 7.2 and when 31 you were just considering the downwind sector, that's 32 when you decided whether it needed to be 33 shelter-in-place or evacuation. Even though this 34 would say evacuate sections where EPA PAGs are 35 exceeded. And that's how you applied this guidance 36 here in Attachment 7.2?
37 So you expected to evacuate zero to two, 38 ten miles downwind, shelter all other sections, right?
39 Shelter-in-place for all other sections, because 40 that's what this guidance says.
And the 41 shelter-in-place comes into play there in terms of any 42 discretionary decision is downwind?
43 MR. BROWN: So, yes. And let me clarify 44
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what I mean by downwind. So the dose assessment would 1
show us which sectors are affected from the ongoing 2
release. It could be more than one.
3 So when we say downwind, we're talking 4
about those sectors where the dose assessment has 5
projected dose rates above one Rem TEDE, five Rem CDE.
6 So when I say I would consider sheltering the downwind 7
sectors, I'm talking about those sectors that are 8
potentially affected by the offsite release.
9 MR. DAPAS: So the point is, where it say 10 evacuate sections where EPA PAGs are exceeded --
11 MR. BROWN: Yes.
12 MR.
DAPAS:
you would look at 13 shelter-in-place, right?
14 MR. BROWN: As it pertains to the special 15 circumstances on this slide, yes I would.
16 MR. DAPAS: Okay. And the expectation is 17 that you evacuate zero to two miles, ten miles downwind, 18 and you shelter all the other sections. So the 19 discretionary aspect is those sections where the EPA 20 PAGs are exceeded and you have the option of 21 shelter-in-place?
22 MR. BROWN: Yes, I do.
23 MR. DAPAS: Okay. So that's how you 24 applied that?
25 MR. BROWN: Yes. And like I mentioned, 26 this Attachment really hasn't changed in all my years 27 as a licensed operator --
28 MR. DAPAS: Okay.
29 MR. BROWN: -- it has not changed.
30 MR. DAPAS: And the government's found, to 31 me, from listening to the discussion that you're 32 planned training would reinforce that expectation. It 33 sounds like there was a disconnect there on what your 34 planned training was. Is that right?
35 MR. BROWN: Well, I've been taught that for 36 years.
37 MR. DAPAS: No. I'm talking about --
38 MR. BROWN: Oh --
39 MR.
DAPAS:
change where you're 40 implementing --
41 MR. BROWN: -- okay.
42 MR. DAPAS: -- Revision 18. I would offer 43 from what I heard, would not be consistent with what 44
47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you just said was how you would practically apply that 1
direction in that box.
2 MR. GREGOIRE: Yes. We recognize we didn't 3
-- in the revision process, we didn't do a good job in 4
training on the subject of what we implemented. In the 5
interview process, we specifically asked them what kind 6
of training did you get on this? And it really wasn't 7
very much training on it to make any changes in how they 8
would use the table. So there was nothing that would 9
alter how they would use it.
10 MR. HETTEL: So, it's worth mentioning, Mr.
11 Dapas, that the training that had previously been 12 provided on Attachment 7.2, which was not as involved 13 and lengthy as what had been provided on the Section 14 I spoke of that was removed, has not changed. That has 15 not -- as Mr. Brown pointed out, has not been altered 16 in the last period of time, I don't know that I could 17 quote 17 years the way he did. But it has not --
18 MR. DAPAS: Okay.
19 MR. HETTEL: -- been altered.
20 MR. DAPAS: The reason why I am engaging to 21 the degree I am on this is because you've got an 22 inspection team that interacts with your staff, walks 23 away with a certain understanding here, that's the 24 basis for the apparent violations and the basis for the 25 preliminary significance in determination, right?
26 And what I'm hearing here is how this 27 guidance was intended to be applied, how it's always 28 been applied, and how it would applied as a result of 29 Revision 18 is that shelter-in-place is part and parcel 30 of your protective action recommendation process. And 31 the implementing of Revision 18 in accordance with 32 NUREG0654 Supplement 3 didn't change that.
33 That's a disconnect from we obviously 34 preliminarily concluded.
That's why you're 35 challenging that. But I'm really trying to understand 36 how we were so disconnected here between the inspection 37 team's findings based on interaction with the staff and 38 what your position was communicated based on those 39 interactions and what I'm hearing here today.
40 Now, going forward, it's important that we 41 understand what your position is. And then we're going 42 to have make a value judgment, quite frankly, whether 43 we agree with that, whether we think that's reasonable, 44
48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 et cetera. Okay?
1 MR. GREGOIRE: Yes. And like I said, we 2
agree that the communication process along the way, we 3
certainly could've improved it. We could've gathered 4
a better understanding of really what the issue was.
5 Because it really wasn't until late where it was 6
formulated that this is what the issue was.
7 Up to, I believe, around the February time 8
frame, it was more of an information gathering, we were 9
trying to address questions as best we could. So, we 10 realize there are some areas for improvement in our 11 interaction there.
12 MR. HETTEL: Because we didn't just -- to 13 give you an example, Mark was -- his interaction asking 14 us, and I thought, what I was getting from it was, okay, 15 when we say shelter, do we mean shelter-in-place? In 16 essence, what's our definition?
17 At least, that's what I thought you were 18 getting and not being answered by four or five different 19 other things before they finally answered your 20 question. So, again, I'll take that back with our 21 interactions during the inspection. I think that was 22 a lot of what was going on.
23 We either, we weren't seeking to really 24 understand the question well enough. And we were 25 answer what we thought the question was. And then, 26 maybe the inspector was receiving the answer to what 27 he thought he was asking. And, again, they just kind 28 of missed each other or something.
29 I wish I had a better explanation, but, 30 again, I just saw an exhibition of it and you asked the 31 question on shelter and, again, what the question was 32 and even back to the procedures, I agree. When you say 33 evacuate sections, okay how did we come up with 34 evaluation on that?
35 But again, you hear and we got it 36 consistent from the other Emergency Directors that we 37 got, that's how they were trained. You got forward to 38 Section 7.2 and you're going to evaluate. So, again, 39 I wish I had a better explanation, but --
40 MR. DAPAS: I appreciate that. I have to 41 tell you, I'm struggling with this shelter remaining 42 sections to mean shelter-in-place here. When you're 43 talking about a wind direction that doesn't impact 44
49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 those particular sectors and you're communicating what 1
shelter-in-place is.
2 And I, quite frankly, am struggling with, 3
is that truly what you intended? Or did you intend this 4
monitor and prepare? Because the monitor and prepare 5
makes sense to me. Sheltering-in-place every other 6
unaffected sector here, I struggle with.
7 And doing that as a dose avoidance 8
protective action recommendation when you already know 9
the areas for which you have projected dose levels that 10 would exceed the PAGs, you've already got the zero to 11 two miles, you've got the ten miles downwind. And 12 every other section, it was your intent, to 13 shelter-in-place.
14 When you go back and you look at the generic 15 guidance and it talks about monitor and prepare, and 16 this is language that you had in your procedures, so 17 I'm going to assume every exercise you conducted, you 18 clearly communicated when you had a general emergency 19 that all other sections, other than zero to two miles 20 and ten miles downwind, you would shelter-in-place.
21 And that was part of your PAR. And we 22 should be able to go back and validate that, that's what 23 you recommended during the exercises.
24 MR. GREGOIRE: I do want to point out that 25 the monitor and prepare language actually showed up in 26 the 2011 NUREG documents. So prior to that time, it 27 really wasn't -- maybe it had a different form, but that 28 term monitor and prepare actually showed up in that 29 document. And it is something that, like I said, we've 30 considered as far as moving forward and how we're going 31 to adopt that in our process.
32 MR. DAPAS: Yes. But the point there is 33 that you always adopted the shelter-in-place for that.
34 Whether in 2011 there's specific reference to monitor 35 and prepare, what was your behavior? And your 36 behavior, is what I'm hearing is the --
37 MR. GREGOIRE: That's correct.
38 MR. DAPAS: -- shelter-in-place.
39 MR. GREGOIRE: That's correct.
40 MR. DAPAS: Independent of this monitor and 41 prepare language introduced in 2011. Right?
42 MR. GREGOIRE: That's correct.
43 MR. DAPAS: Which brings me to the curious 44
50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 question as to if you're discussing Supplement 3 and 1
I heard at the beginning of the conference that if we 2
met what Supplement 3 provided to us in guidance, you 3
were being compliant to regulation, you adopted 4
everything that was in Supplement 3, but yet, the piece 5
on monitor and prepare was not adopted.
6 So, I guess I need to know more about why 7
you're saying now that you did not adopt monitor and 8
prepare and you're saying the shelter-in-place that you 9
will do for the rest of remaining EPZ is the same as 10 if it were to be for dose avoidance. When Supplement 11 3, one of the major differences from Supplement 3 and 12 any previous guidance was to identify the rest of the 13 EPZ to monitor and prepare. And that was a major change 14 and was identified as such numerous occasions before 15 it was issued.
16 You adopted and you say you used everything 17 else out of Supplement 3, but you didn't use that piece.
18 What was the reasoning behind that and why you're 19 continuing to say that your shelter-in-place for the 20 remainder of the EPZ is the same as if it was for dose 21 avoidance?
22 MR. CLIZBE: So we were working through the 23 monitor and prepare language and working with the 24 outside response organizations in adding it to the 25 program. When this came up, we kind of stopped 26 discussions to understand what the regulatory issue was 27 last August.
28 And it is our intent to include the monitor 29 and prepare language with offsite response 30 organization collaboration. To be clear, we think 31 it's an appropriate tool. So we're working towards it.
32 We recognize we have some terminology differences.
33 And we stopped after we were informed of the issue.
34 MR. ELKMANN: So you're saying you have not 35 completed all of your changes to your PAR strategies?
36 MR. CLIZBE: The only one that we didn't --
37 MR. ELKMANN: With --
38 MR. CLIZBE: Yes.
39 MR. ELKMANN: -- the guidance provided in 40 Supplement --
41 MR. CLIZBE: Yes. That --
42 MR. ELKMANN: -- 3 through August of last 43 year?
44
51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CLIZBE: Correct. The additional 1
language of monitor and prepare into the strategy 2
impacts messaging, public documentation, and those 3
kinds of things. And we have not done that yet.
4 MR. ELKMANN: I wanted to return a little 5
bit to the training module. And to the recollection 6
document that A.J. mentioned a couple of minutes ago.
7 We did ask for the training module that underlies 8
essentially your 7.2 for the PAR procedures, the 9
version that was changed in June of 2014.
10 And going through there, we looked at it 11 and noticed that nothing was added to that module that 12 references the shelter had been deleted. And then in 13 January of this year, we were provided the corrective 14 action report which says that you intended to remove 15 additional references to shelter, essentially, but you 16 didn't complete the initial revision.
17 It kind of -- just to be clear, the current 18 training for PARs, if you go through that computer based 19 module, there is no explicit reference to this 20.2 and in particular to the notes 21 associated with it. Is that correct?
22 MR. GREGOIRE: So we don't have a copy of 23 the training material right here before us. It's 24 something we can follow-up on, on that material.
25 MR. FAHNESTOCK: But it is important to 26 note, Paul, that the training, the CBT is currently on 27 hold and has been since that time.
28 MR. ELKMANN: And what training that you've 29 given to your -- you have an annual training requirement 30 for your Command and Control individuals. How have you 31 been fulfilling it if your training module's on hold?
32 MR. FAHNESTOCK: So that was actually in 33 progress at the time that we made the determination call 34 and was near completion. So that did go forward and 35 was completed with the current materials. But that was 36 almost complete at the time that we noted the 37 discrepancy and generated the Condition Report. Since 38 then it's been on hold.
39 MR. ELKMANN: I think that's a big -- that 40 really gets to the intent of whether Attachment 7.2 41 would not be used if you intended not to reference it 42 in training, that would make it difficult to understand 43 why you think it would be used if it wasn't being trained 44
52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 on.
1 MR. DAPAS: I think I've heard the 2
acknowledgment that your training was not what you 3
expected here. If you are going to use 7.2 as part of 4
the decision process and that's a tool that you have 5
for your decision makers, that it would be appropriate 6
to reference that in your training.
7 So what I'm hearing from the licensee is 8
that while there's the recognition that the training 9
module did not capture 7.2, it's your view that 10 individuals that have served in that Command and 11 Control function would in fact have exercised the 12 guidance like you said, Mr. Brown --
13 MR. BROWN: Right.
14 MR. DAPAS: -- with the shelter-in-place 15 considerations. That's what I've heard. Is that 16 correct?
17 MR. BROWN: That's correct.
18 MR. DAPAS: And I know we haven't gone on 19 to Slide 40, but just to make sure here, that if there's 20 no release in progress, you still would've sheltered 21 all the remaining sections with the shelter-in-place, 22 even though there's no release, right? That's the 23 expectation. That's what you exercised.
24 MR. BROWN: That's correct. I will walk 25 through the rest of my procedure presentation --
26 MR. DAPAS: Yes.
27 MR. BROWN: -- if you're ready for that.
28 MR. DAPAS: Yes. Sure.
29 MR. BROWN: Okay. So the next slide -- so 30 here's the case where we're looking at initial PARs in 31 a general emergency with no release in progress. We 32 do work through the Attachment 7.1 in a similar fashion, 33 go down the general emergency path, evaluate release 34 in progress. The answer to that is no.
35 And then we issue the Standard PAR, 36 evacuate all sectors zero to two miles, ten miles 37 downwind. And shelter remaining sections.
38 So even though we don't have a release in 39 progress, our dose assessment will show us a downwind 40 sector and that's what we use as a basis for issuing 41 the Standard PAR. Any questions on that? Okay. So, 42 I'll move on to a discussion about the updating PARs.
43 MR. GREGOIRE: We did just put this in here 44
53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 because there was a reference in the Inspection Report 1
that with regard to how we handled a planned release 2
and regard to Step 4.4.4 and in the last statement it 3
said that it concluded that a discussion intended to 4
assist offsite authorities is not equivalent to a 5
protective action recommendation.
6 And we agree with that, but that's 7
referencing those steps. You'll find that later on, 8
we speak to Step 4.4.6, that does provide the protective 9
action recommendation.
10 MR. BROWN: So next slide. So in the case 11 that I was just discussing, if we're in a general 12 emergency and we have no release in progress, and when 13 we decide to either do a planned release or a release 14 develops, I would be using the updated PAR section of 15 the procedure.
16 And I'll point to Step 4.4.2, which says 17 to determine the appropriate offsite PAR by comparing, 18 again, your dose assessment data to Attachment 7.2.
19 And use the guidance in Attachment 7.2 to make your 20 decision.
21 So, updating PARs, I would do the same 22 thing. I would get a dose assessment. I would look 23 at Attachment 7.2 for any special circumstances. And 24 then I'd move on in the procedure.
25 The next slide shows where Step 4.4.4 is, 26 if we plan on doing a planned release, I would discuss 27 with the offsites. So, I've already made my decision 28 on the updated PAR at this point. What I'm talking to 29 them about is we're going to do a planned release that 30 has a finite duration to protect our primary 31 containment. And we're going to do that as directed 32 by the emergency operating procedures. After the 33 Emergency Director, who is myself, has concurred with 34 that action as the Control Room is wanting to do it.
35 But, as it relates to the offsites, what 36 we're doing is we're giving them advance notice that 37 we're going to update our PAR for this particular 38 scenario of a planned release. And that helps them 39 with their planning. And you can see the step language 40 says to assist them with their protective action 41 implementation.
42 The next step, when you turn the page in 43 the procedure, I communicate the updated PAR with a new 44
54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CNF form, Classification Notification Form, in Step 1
4.4.6. So that's how we officially notify the offsites 2
with that updated PAR. Any questions on that? Okay.
3 Next slide, I'll move on to --- okay.
4 MR. DAPAS: Again, I see 4.4.4 that talks 5
about discuss the proposed activity with offsite 6
authorities, but show me where it is in your procedure 7
again that you would make a PAR. Because --
8 MR. BROWN: Okay. So the PAR --
9 MR. DAPAS: -- I'm looking at that --
10 MR. BROWN: The PAR is actually made in Step 11 4.4.2, so if I go back to the previous slide. I'm 12 making my decision for the updated PAR in Step 4.4.2.
13 Again, I'm going to be directed to consider special 14 circumstances that might be defined in Attachment 7.2.
15 MR. DAPAS: Well, let's step back. You've 16 got a planned release. This isn't updating a PAR based 17 on new information. You have a planned release.
18 Where in your procedure does it have you recommend a 19 protective action -- provide a protective action 20 recommendation associated with a planned release?
21 MR. GREGOIRE: So the title here, it says 22 "Updated Offsite PARs Based on Projected Doses."
23 MR. DAPAS: Okay.
24 MR. GREGOIRE: So it's assumed that if 25 you're having a planned release, you're going to have 26 a dose to go with that.
27 MR. DAPAS: Okay.
28 MR. GREGOIRE: So it, again, we mentioned 29 it earlier that it's not speaking directly, but it is 30 inferred in our existing guidance that is there.
31 MR. BROWN: So whether we open the valves 32 and do the release ourselves or whether the release 33 occurs, it is a release. And so my path from that point 34 is the same. We do a dose assessment, we look at the 35 consequences, and we update the PAR. And this 36 discussion with the offsites, Step 4.4.4, is to help 37 them with that PAR implementation.
38 MR. HAIRE: Paul, did you have a question?
39 MR. ELKMANN: Yes. I'm looking at that.
40 That presupposes you have a dose to look at. If you 41 go to your dose assessment procedure, you have 42 direction in there on how to estimate the radiological 43 consequences of a planned release. But you don't have 44
55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that monitor data.
1 You have dose assessment for a release 2
occurring when you release by accidental reasons.
3 You've got either direct field measurements or you have 4
a radiation monitored number, which you put into dose 5
assessment, but then you've got producing dose.
6 But do you have directions for doing that 7
with a release for so many minutes at so much pressure 8
and so much moisture in the air so that you actually 9
arrive at a dose assessment for the projected release 10 that you could trust?
11 MR. BROWN: So to answer your question, I 12 think I'd have to defer to someone who's a little bit 13 closer to the dose assessment, the nuts and bolts of 14 entering the data into it. So I don't know, A.J., if 15 you could answer his question?
16 MR. FAHNESTOCK: This is going to come into 17 the category that Don mentioned earlier, we don't have 18 a copy of the dose procedure here with us today. So 19 it would be speculative of me to speak to that answer.
20 MR. BROWN: Okay. So, Paul, we can owe you 21 that information. I think it's a very good question.
22 I apologize that I don't have it off the tip of my 23 tongue.
24 MR. FAHNESTOCK: So, let me make one other 25 point. And that is that the software -- we can say this 26 alters what I said earlier, but the software has the 27 ability to run dose projections based upon our 28 understanding and a Radiological Emergency Manager's 29 understand of what those instrument readings are likely 30 to be.
31 And given containment readings, they would 32 be able to formulate that reasonably well, I would say.
33 But, again, we don't have a copy of the procedure with 34 us. So I can't definitively answer your question.
35 MR. CLIZBE: If I can, before we got on to 36
-- it looks like you're getting into your concluding 37 type of area here. Talking about some requirements.
38 Will we be able to go over Slides 33, 34, and 35, related 39 to the Control Room and exceeding the 10 mile EPZ?
40 Because we kind of skipped over top of that as we went 41 through the implementation procedures. Just to make 42 sure we cover all that too because there is some items 43 in there I think we need to hear about.
44
56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. BROWN: So if I might, if I can finish 1
my section, then we'll go back and finish Sean's section 2
on the procedure changes. Because he's going to talk 3
to that point.
4 MR. CLIZBE: Okay. Just so we don't forget 5
about it.
6 MR. BROWN: That's right. Okay. I'll 7
move this on then to the next slide. We're talking with 8
the offsites, letting them know about the planned 9
activity. Next slide, I'm completing the updated PAR 10 related to the planned release.
11 And then the next slide is a copy of our 12 Classification Notification Form. So what we've got 13 here, I just wanted to highlight a couple aspects of 14 this form. One is that very little of the information 15 is automatically populated. Okay.
16 So the user, in my case, this is filled out 17 by the Assistant EOF Manager and then presented to me.
18 And we have quite a few discussions as we fill it out.
19 But I'll highlight two aspects of the form that are not 20 auto-populated.
21 When we select the emergency action level 22 that we're in, in this case it's an intentional vent 23 of containment, we then select the offsite release, 24 yes, and put in the time of that offsite release 25 starting. So that's not a default value. So I just 26 want to highlight that.
27 And over in the PAR area, for general 28 emergency, when we select the general emergency, this 29 is all blank. Okay. All these fields you have to 30 manually select each one. So, I'm making decisions on 31 zero to two miles, we click the evacuate button. For 32 the affected sections, I'm making decisions, shelter 33 or evacuate.
34 All the way across the board. And we just 35 wanted to highlight that as part of our communication 36 with the offsites that nothing's really taken away from 37 me. Okay.
38 And with regard to the procedure changes, 39 it's my professional judgment that the procedure change 40 did not put me in a corner as an Emergency Director.
41 It didn't really change the way that I evaluate whether 42 I shelter or evacuate. Right.
43 So the point I was trying to make is that 44
57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 when the Condition Report was written at our station 1
for this violation, we entered it into -- we developed 2
a compensatory measure for the Emergency Directors and 3
emphasized the fundamentals of shelter-in-place as it 4
pertains to a planned release activity or other rapidly 5
developing activity.
6 And when I read that, I said, this doesn't 7
change any -- I already have this direction. Why do 8
I need a comp measure? That was my reaction. Okay.
9 So I'm here to tell you today that I can use this 10 procedure to arrive at a shelter or evacuation PAR based 11 on circumstances.
12 And it really -- definitely there are 13 changes in the procedure, but it doesn't change the way 14 I look at it. It doesn't change the way that I perform 15 when it comes down to it. So that's what I wanted to 16 leave you with as it relates to the procedure changes 17 and how I use them.
18 MR. HAIRE: Dave, this is Mark Haire.
19 Before we leave this slide, I just want to I guess one 20 more time to achieve clarity, when you click the button 21 shelter for any one of those sections, it means the same 22 thing to the op sites for making their protective action 23 decisions, and that is that it means to go into the 24 house, shut the doors, close the windows, turn off the 25 ventilation as was read by A.J., regardless of whether 26 it's a downwind sector or an unaffected sector. The 27 word shelter on that form gets the same direction to 28 the same recommendation to the op sites, which would 29 translate to the same actions for the public, whether 30 they're in an affected downwind zone or an unaffected 31 downwind zone.
32 MR. CLIZBE: So you are correct. Okay, so 33 I think you wanted to go back to slide 33, the procedures 34 changes.
35 MR. ELKMANN: Before we leave that topic, 36 can I ask one last question. I was interested in, you 37 know, we talked a lot about Attachment 7.2 and how it 38 existed a long time prior to June 2014 for most 39 radiological emergencies. Did you look at whether in 40 actual global exercises, you have any record of an 41 exercise in which a shelter recommendation was about 42 not using Attachment 7.2 vice 7.1 in evacuation? Post 43 June 2014, you probably haven't run very many 44
58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 exercises, so you may not have much exercise history 1
there, but certainly, you know, given your discussion 2
that the Attachment hasn't changed in a very long time, 3
and its understanding hasn't changed, one would expect 4
some history on it actually being used in practice. So 5
did you look at that?
6 MR. CLIZBE: Yes, well we didn't go back 7
and look at that, and I think we went back 12 years to 8
see if we had any scenarios that would have driven an 9
emergency director to make a shelter--pick an actual 10 recommendation, and we did not have a scenario that 11 would have driven them to a shelter. The only one that 12 we did have was during hostile action base exercise, 13 where they issued a shelter, but it was inappropriately 14 issued and critiqued in the team.
15 MR. ELKMANN: In the last 12 years, you've 16 never had a general emergency with a release as part 17 of an exercise?
18 MR. CLIZBE: With a release, but none a 19 scenario drew an emergency director to make a shelter 20 protective action recommendation for downwind.
21 MR. ELKMANN: When you have a release in 22 progress and you're at a general emergency, you're 23 evacuating zero to two miles and 10 miles downwind and 24 sheltering all--
25 MR. CLIZBE: Sheltering, I'm talking 26 about down winds, I'm sorry. Down winds.
27 MR. ELKMANN: But they have not run an 28 exercise where they had to use this option for the 29 downwind shelter?
30 MR. BROWN: Okay, so I would also clarify 31 that I know we've had discussions during my role as the 32 emergency director during drills. I definitely talked 33 with my team about whether it's appropriate for shelter 34 or evacuation, and that's why I've circled back to that 35 comment many times during our presentation today.
36 Whether we finally concluded that sheltering was more 37 appropriate in that circumstance, I couldn't point to, 38 but I know that's part of our discussion.
39 MR. ELKMANN: This is just a follow on 40 question, and I appreciate your providing your 41 perspective as a person that has acted as the emergency 42 director right at the facility, but you're confident 43 you've engaged others that would be in that position 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and they would apply the guidance in a consistent manner 1
as we've heard from Mr. Brown?
2 MR. GREGOIRE: That's correct. Like I 3
said, when it was asserted that our staff would not use 4
that, it raised concerns for me as the reg affairs 5
manager, you know. Are we not using it or can we not 6
use it, and through the interview process we determined 7
that they would all use that, even through a table top 8
that demonstrated that they would use that for the 9
unique situation, again, like I said, keeping in mind 10 our EPZ is very--most folks are on the outside area, 11 but yes, we would still use it for rack incineration.
12 MR. ELKMANN: All right, thanks.
13 MR. HAIRE: I guess--this is Mark Haire, 14 and before we leave that topic, I guess one of the 15 questions that's still lingering in my mind is, hearing 16 the testimony of Mr. Brown for what he would do and what 17 it means to him, and then understanding what we see in 18 the training modules raises the question is the 19 perspective that Mr. Brown has a legacy of better 20 training in the past, and are new emergency directors 21 going to continue that perspective, because the text 22 in front of us doesn't lead us to logically draw those 23 conclusions.
24 MR. GREGOIRE: That's a very good 25 question, and it's something we will look at going 26 forward, but I mean all of this, it raises our awareness 27 that real people that could step into this look at it 28 differently, and for us to re-evaluate and go back and 29 see if there's some improvements we can do in this 30 process. But we kind of wanted to see this play all 31 the way out or not. We have currently a number of staff 32 people right now that have gone through the previous 33 training, but we agree with you on that point.
34 MR. ELKMANN: I believe you had some 35 experience with that before.
36 MR. GREGOIRE: Yes, I think our youngest 37 emergency director is about two years qualified, and 38 then the most--and they all average out to somewhere 39 around five to seven years. I'm sorry, should be 40 specific; those were the emergency operating facility 41 emergency directors.
42 MR. DAPAS: I think the important point I 43 was asking Mr. Haire here, because you indicated 44
60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Mr.--how do I pronounce your name?
1 MR. GREGOIRE: Gregoire, like jaguar.
2 MR. DAPAS: Okay, got it. I would ask if 3
you own one here, but you know, you made the comment 4
that when you heard from the team, that your emergency 5
directors wouldn't follow the guidance, you wanted to 6
know if there was a gap there. Well that was based on 7
a read of the guidance and trying to follow it, not based 8
as I understand it from interviews with emergency 9
directors regarding, you know, how they would apply 10 that, okay.
11 MR. GREGOIRE: Yes, we understood that.
12 We knew that at that time, none of the staff had been 13 interviewed, and it was a conclusion that was being 14 reached, and it was just from the office as to how we 15 were looking at it, so yes, we understand that.
16 MR. DAPAS: Okay, thank you.
17 MR. GREGOIRE: Are we ready to go back to 18 slide 33? Okay, this is a point we wanted to emphasize 19 again with regard to protective action recommendations 20 that are beyond the emergency planning zone. This is 21 a sectional procedure that refers to the updated 22 sections for the EPZ. So in the inspection report on 23 page 4, it states that we removed the responsibility 24 of emergency coordinator in the control room to the 25 shift manager to make protective action 26 recommendations for areas outside the plume face. As 27 we'll show, we actually didn't change anything in the 28 procedure, and it's been that way since 1999. As far 29 as the conclusion, we disagree on the conclusion 30 itself. Again, I want to emphasize this section 31 relates to updated PARs for beyond their emergency 32 planning zone, and when--you know, one thing that we've 33 learned from industry events is that accurate 34 information to federal, state and local agencies is 35 important as the event continues on, and that the 36 further you get away from the plant's met towers, the 37 more difficult it is to be accurate.
38 So what we're speaking about here is 39 subsequent period where environmental measurements 40 would permit inaccurate assessment. I want to point 41 to the two sections in our emergency plan. As culled 42 out in the inspection report, section 2.1 speaks to the 43 responsibilities for the emergency direction and 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 control and how that for a protective action 1
recommendation, this is normally transferred from the 2
shift manager to the EOF manager or the emergency 3
operating facility manager. And then I also want to 4
introduce section 5.5.2, which is language that's 5
common to actually the previous version of the new reg, 6
but we didn't change this, and we believe it's still 7
consistent with the current version of the new reg that 8
protective actions, these supplemental protective 9
actions beyond those that you've already evaluated says 10 these protective actions should be based on field 11 monitoring data and dose projection in areas beyond 12 those that have been evacuated.
13 So when you take section 2.1 and 5.5.2 14 together, they help support what we have in the 15 procedure, and our procedure incorporates both of these 16 provisions and does not allow delegation of 17 classification notification or PARs to any 18 non-emergency director. Our procedure doesn't allow 19 that. And that field teams are deployed as part of our 20 technical support center or emergency operations 21 facility, and so therefore the protective action 22 recommendations would be based on the field team data 23 that we would get for this beyond the EPZ.
24 Again, we want to emphasize that this is 25 consistent with industry practice and that when you get 26 beyond the EPZ, there's a lot more that's going to be 27 required for the--to determine where you should 28 actually make your PAR recommendations, and it is kind 29 of scenario, if you can imagine that we're talking, you 30 know, if it's still in the control room, it means to 31 some of the guys that the emergency response 32 organization hasn't been implemented yet, but it must 33 be a rapidly progressing scenario, something pretty 34 severe to be happening where the on shift folks would 35 need to be handling--managing the event as well as 36 trying to determine what the protective action 37 recommendations are. Anyhow, I'll turn it over to Sean 38 to walk through the procedure.
39 MR. CLIZBE: So this is Revision 17 and 18 40 of the procedure, and nothing changed in this section 41 of the procedural onsets since 1999, and it's aligned 42 with section 5.5.2 of the emergency plan, and 43 additionally it was aligned with section 2.9 of the 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 procedure. The procedure doesn't delegate taking 1
actions and responsibilities, but it transfers the 2
responsibility to a qualified emergency director with 3
augmenting staff support. Additionally, use of field 4
team data to formulate protective action 5
recommendations beyond 10 miles is in alignment with 6
our emergency plan, and aligns with a large majority 7
of the industry.
8 So this is supported by the EP FAQ 2013 TAC 9
004; essentially not burdening the on shift or control 10 rooms staff decision makers, minimizing the demand on 11 them so they can stay focused on mitigating the 12 emergency at hand. Additionally, the accuracy of PARs 13 beyond 10 miles for those initial folks, it's going to 14 affected beyond 10 miles, and you have the potential 15 of actually evacuating people into the plume zone 16 without, you know, a real accurate analysis. And our 17 dose assessment team would be responding in their 18 approved times, and RPL teams would be responding in 19 their approved times in accordance with our plan, and 20 we'd use that data to support our prote4ctive action 21 recommendation beyond the EPZ.
22 MR. GREGOIRE: Any other questions on 23 that? If not, we'll move on to--
24 MR. HAIRE: This is Mark Haire; I've got 25 a question on this. So I think I may have pointed this 26 out earlier, but our primary concerns here with this 27 text, and I appreciate that you're highlighting the 28 text was also present in Rev 17; we may not have caught 29 that, but the concern that we had with the text, 30 regardless of how many years it's been present, is that 31 if I'm the emergency director by default in the control 32 room because it's early in the event, and your emergency 33 response facilities have not stood up and are not ready 34 to receive a transfer of the emergency director 35 authority, it's possible that a rapidly progressing 36 severe accident could put the control room staff in the 37 position of needing to face protective action 38 recommendations for outside of 10 miles. And if I'm 39 your emergency director in the control room, this 40 procedure puts me in a quandary--as we read it, it puts 41 me in quandary of saying in order to follow the 42 procedure, I've got to wait until the EOF and the TSC 43 are stood up before PARs can be made, and I don't think 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that's consistent with what the guidance and 1
requirements are.
2 MR. GREGOIRE: I'd like to say two things 3
with regard to that. The first is accurate PARs. When 4
you get beyond EPZ, it's very difficult for the control 5
room without having the benefit of field teams to be 6
able to give accurate PARs, and I think accurate is a 7
piece of the protective action recommendation you want 8
to continue to demand of a protective action 9
recommendation. And the second point is, and I 10 really--I understand the concern; I guess maybe if this 11 moves on, I would ask maybe a consideration for a 12 generic approach to this, because I believe this is the 13 common industry practice, and this may reflect on the 14 generic approach and how you deal with these updating 15 PARs beyond the EPZ and dealing with accuracy and the 16 demands you're putting on the control room in a very 17 short period of time and the concern for nuclear safety, 18 as a matter of fact. So I guess I would just ask for 19 some consideration, that maybe a generic approach, if 20 you continue to move forward and want to raise this as 21 a finding for us.
22 MR. HAIRE: Well is it your view then that 23 other licensees have the same type of language?
24 MR. GREGOIRE: Yes.
25 MR. HAIRE: Okay.
26 MR. GREGOIRE: Very similar, yes.
27 MR. HAIRE: Got it. I'm trying to 28 envision a scenario rapidly progressing where you have 29 a release of such a magnitude here that you've got 30 indications based on dose projection that you're 31 exceeding the tags at 10 miles and they need to look 32 at protective action recommendations beyond 10 miles.
33 That's what we're talking about.
34 MR. GREGOIRE: And the left side of the 35 chart for the severe accidents. So with accidents that 36 are so severe, early in the stages, and that's how we 37 answered the FAQ, where it is--the probability begins 38 to increase as to PAGs being exceeded beyond 10 miles, 39 those type of accident scenarios, sequences in which 40 the control room would be in the position for 41 determining that PAR for that type of accident in the 42 initial stages and getting the initial dose projection 43 that said it exceeds one Rem beyond 10 miles. That's 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what we're discussing here, and it would appear as if 1
what you had here, procedures would permit the control 2
room emergency director to provide that PAR up to 10 3
miles.
4 MR. HAIRE: Yes.
5 MR. GREGOIRE: But await the TSC and EOF, 6
even though the dose projection indicates it is 7
exceeded beyond 10 miles greater than one Rem.
8 Now keep in mind that the MET tower that we have is right 9
there at the station; you get beyond the 10 miles and 10 you're not going to find MET towers beyond the EPZ that 11 you would find here. And as Sean had mentioned, there 12 was some concerns for are you evacuating the right 13 people, are you moving them into a plume area when maybe 14 they shouldn't be moving into that area. So again, I 15 would just emphasize the need for accuracy beyond that 16 EPZ, as well as reducing the burden on the control room 17 to have to try to go figure it out, geopolitically 18 getting all the information without having the 19 benefit of a field team to make those accurate PARs.
20 MR. DAPAS: But what I hear you saying 21 then is it would be appropriate for the shift manager 22 in this case to wait until the TSC or EOF are manned 23 is what you're saying?
24 MR. GREGOIRE: Yes.
25 MR. DAPAS: And I guess our view when we 26 have to look at this is, you know, are the scenarios 27 where that shift manager may have to make a decision 28 because of the severe accident nature there? I 29 understand accuracy of information is paramount, but 30 it's got to be balanced with what your dose projection 31 tone based on--so I understand the point, you would 32 expect in most scenarios that the TSC would be manned 33 or EOF to make a more informed assessment.
34 MR. GREGOIRE: We do indicate to the 35 offsite responsible organizations as well that dose PAG 36 may be exceeded, and the additional notes on the 37 classification notification form if that was the case, 38 they're trained to identify that response and 39 understand.
40 MR. DAPAS: Well I assume too you have 41 confidence in your shift manager if they found 42 themselves in that situation, they're going to make a 43 recommendation that they think is appropriate and not 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 say well, the TSC isn't manned yet, the EOF isn't manned 1
yet, and I'm going to wait on that. And even though 2
the procedure might imply that could potentially be 3
problematic from the way the procedure is written, I 4
sure would hope that your shift manager as the emergency 5
director is going to do what they think is the right 6
thing to do there, right?
7 MR. HETTEL: I would say yes based on what 8
we've learned from Fukushima and how the operators and 9
what they were thinking, their mindsets. So yes.
10 MR. BROWN: So if I could add just one 11 clarifying point. I think what's been said is 12 accurate. I was a shift manager and as an emergency 13 director, I feel that it's my duty to accept the 14 responsibilities as soon as my center is manned. For 15 the control room, they're directed to notify the 16 offsites that PAGs may be exceeded beyond 10 miles, and 17 that's what they do. The rest of this procedure, it 18 is hard for them to implement from the control room.
19 They need the assistance of the teams and the additional 20 data that the teams can develop to be accurate in those 21 PARs. So that's really where we're trying to say is 22 the balancing act is timeliness and accuracy, okay.
23 MR. ELKMANN: If you were earlier in a 24 severe accident or in progress and you were just 25 starting to notify the emergency response 26 organization. So what kind of delays, worst case, 27 would we be talking about while we're waiting for the 28 ERO and then they dispatch an environmental survey team 29 and waited to come in?
30 MR. CLIZBE: Our approved response time is 31 90 minutes.
32 MR. ELKMANN: That's for staff in the 33 facility?
34 MR. CLIZBE: Yes.
35 MR. ELKMANN: And then how long further 36 after that to get a team out and a team to the northeast 37 where the most population is?
38 MR. CLIZBE: I'd be guessing right now to 39 give you that. I can get it for you if you like.
40 MR. ELKMANN: So I think that's where the 41 procedure leads us to believe that you've removed--I 42 understand, Dave, when you're saying you feel as if you 43 would do the right thing, but the procedure, and that's 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what we have to base a lot of what we're deciding upon 1
and discussions with staff, the procedure doesn't 2
provide that latitude; the procedure directs the 3
control room emergency director to wait for the TSC and 4
EOF to be activated. So it does not provide that 5
latitude, and I'm sure that's the way it's trained upon 6
and what you're exercises have shown. So I think 7
that's our--that's the underlying concern, is that the 8
procedure provide a little bit more latitude with that 9
control room emergency director, rather than directing 10 them to await the TSC and EOF activation as we're 11 discussing here now, 90 minutes during a severe 12 accident. That would be our concern.
13 MR. GREGOIRE: And we understand that, and 14 like I said, knowing that we've had this in place for 15 a number of years, and we were concerned; are we unique, 16 are we not; why are we treating this differently than 17 many other utilities. And we come to find out that 18 we're in the majority of the way the industry treats 19 this matter. So it's something that we can strengthen 20 the process, we agree. And what's happening, we've 21 done some background information with it, it's 22 something for us to follow up on I'm sure to find out 23 if clarification may be needed in this area.
24 MR. ELKMANN: I didn't appreciate earlier 25 when I made the rather definitive statement about what 26 I would expect the control room shift manager to do.
27 I didn't appreciate that it was that directive in 28 nature, so.
29 MR. HAIRE: This is Mark; let me just add 30 to the discussion that while we appreciate the desire 31 for accuracy and the balance between delay versus 32 accuracy, I'll note that your procedure, the one we're 33 talking about right now, 13.2.2, in section 4.4 it has 34 a note for updating PARs, and the note says "do not delay 35 recommending offsite protective actions while waiting 36 for field monitoring results to verify accuracy of dose 37 projections," and that's consistent with I think the 38 way the Agency views the need for early notification 39 as opposed to delay for accuracy.
40 MR. GREGOIRE: Yes, if you actually will 41 go a little bit further down in the procedure there, 42 4.4.3--I'm sorry, 4.4.2.(b). "If dose projections or 43 survey results indicate a PAG may be exceeded beyond 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the 10 miles, then refer to section 4.5." So it 1
actually kicks you out of that section and you go to 2
the other section, which then treats it in a little bit 3
different manner. So give it over to Sean, I mean to 4
Kurt.
5 MR. GOSNEY: We looked at the different 6
opinions around this issue and the significant amount 7
of time that's went to it. We asked ourselves what 8
could we have done differently. Since this issue 9
originated in August of 2014, with question regarding 10 our implementation of the NUREG, Supplement 3, we 11 looked for areas we could improve our performance 12 related to implementation of new federal guidance.
13 The first one I'd like to speak to is engagement with 14 the NEI Emergency Planning Working Group. This 15 working group provides an opportunity for 16 benchmarking, industry alignment and engagement with 17 NSIR on key issues affecting the industry. For many 18 years in the past, we relied on USAs as our 19 representation of voice rather than regularly 20 attending ourselves. Over the last year though, we've 21 significantly improved our engagement with this 22 working group with regular attendance. In fact, our 23 Chief Nuclear Officer, Mr. Brad Sawatzke, has 24 recently been selected as the chair for the group, and 25 we feel this will be significant in the world of EP going 26 forward.
27 MR. ELKMANN: My former job as a deputy in 28 the Office of Nuclear Security and Response, I've 29 attended several of those nuclear security, I should 30 say emergency preparedness working group, and I didn't 31 appreciate that your representative for Columbia was 32 USA?
33 UNIDENTIFIED SPEAKER: Utility Service 34 Alliance.
35 MR. ELKMANN: Utility Service Alliance.
36 I didn't appreciate that; I assumed that one of your 37 EP managers--because I agree, that's a very valuable 38 forum for qualification, like on this issue we were just 39 talking about. I could see that being a forum where 40 the industry raises that for consideration.
41 MR. GOSNEY: Yes, this--like I said, our 42 CEO is now chair, I think he's been to three meetings 43 this year, if not two or three, and over the past year 44
68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 we've had regular attendance there.
1 MR. ELKMANN: Okay, thanks. So he took 2
over Tom Joyce's spot on that? Okay.
3 MR. GOSNEY: That's correct. And the 4
next thing I'll speak to is engagement with NSIR itself.
5 Section 2 of our guide 1.2.19 provides guidance on when 6
prior discussion with NRC headquarters is encouraged 7
before making changes to an emergency plan. While the 8
guidance in this case doesn't specifically deal with 9
the types of changes we made, we do feel that this would 10 have been an area that we could have pursued maybe in 11 this case, and certainly we'll look at that in the 12 future if we have some key implementation of guidance 13 involved in our emergency plan in the future.
14 MR. GREGOIRE: I'm Don, I'd like to just 15 speak to the last one, since this falls under my 16 organization. While we're not in total agreement with 17 many of the items in the report, especially those that 18 reference conversations over the last nine months, and 19 the interpretation of our procedures, we recognize that 20 we, Energy Northwest, had difficulty in really gaining 21 an appreciation or understanding for what was the issue 22 underlying the NRC's concern. And we also had 23 difficulty effectively communicating our response or 24 position trying to, as I mentioned earlier, trying to 25 fit the discussion into the regulatory guidance, 26 especially with planned pub releases, but we have been 27 looking at how we can improve that in our area, 28 especially with having more direct communication, even 29 if we have to come down here to try to have more 30 face-to-face discussions to try to really understand 31 what was going on.
32 We're taking that back as a need for my area 33 to improve the engagement and understanding of issues, 34 you know, speak--you know, listen before you speak, do 35 a much better job at that. So we're working on how we 36 can improve that interaction. We'd certainly welcome 37 any comments or feedback as to how we can improve that 38 so that we can truly get to the root of the concerns, 39 and that we can be--especially in this subject here 40 where you know, it is to some degree a little bit 41 complex, but we can clearly communicate our positions 42 and our role with that and interpretations of our 43 procedures and what not.
44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. CLIZBE: I just want to kind of add on 1
a little bit and I'll do so as the manager of the 2
department, you know, it's my responsibility to 3
understand what the issues are and get the clarity that 4
I needed, and I may have some opportunities in there 5
to really understand what the inspector was requesting 6
from Columbia, so just to add on to what Don was saying.
7 MR. GREGOIRE: So in wrapping up our 8
discussion, and like I mentioned, we don't believe we 9
have a performance deficiency in that the inspection 10 report we no longer provided a mechanism for making a 11 shelter-in-place protective action recommendation, 12 and again, we pointed to Attachment 7.1 and 7.2 as 13 providing that means. With regard to no longer having 14 protective action in the event of a planned release, 15 as we mentioned, we would the use the flow chart in 16.1 since a planned release would result in 17 a release in progress, we'd use that flow path to help 18 us consider the recommendations, protective action 19 recommendations which could include also 20 shelter-in-place. Next.
21 The inspection report mentioned that we 22 removed the responsibility; I won't belabor that point.
23 In regards to the next slide--and if I'm moving too 24 fast, this is just a wrap up of all of this, but in the 25 next two slides deals with the specific statements 26 regard to our non-compliance with our emergency plan.
27 Let me just spend a little bit more time on that. So 28 the first one points to Emergency Plan Section 2.1, and 29 again if you consider the text in Section 5.5.2, you'll 30 find that it does include the need for field monitoring 31 for making that assessment. Now our field monitoring 32 is part of our augmented organization, and that our 33 procedure correctly refers to the protective action 34 recommendation being developed with the assistance of 35 the field teams, which would be an augmenting function.
36 With regard to the Section 5.5, again we'd 37 just like to emphasize here that Section 5.5.2 and 38 additional text in Section 5.5 help formulate the how 39 you actually develop shelter-in-place considerations.
40 Section 5.5 states that protective action guides 41 discussed in Section 5.5.2 provide that pre-planning 42 guidance; Section 5.5.2 points to the federal guidance, 43 and again we walked through how we would have used the 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 guidance to develop what we have in place. Again, I 1
would just like to summarize that although we may have 2
some differences about how we can improve the 3
procedure, how we can communicate more clearly on this 4
matter, we still believe that there's not a performance 5
deficiency involved here.
6 MR. DAPAS: One comment. I think you 7
certainly have explained the basis for your conclusion 8
that you need to wait for field information if you will 9
from your dose sensitive measuring teams that go out 10 in the field. I think we talked about your scenarios 11 where your dose projection is such that you may need 12 to consider PARs beyond 10 miles; you'd indicated that 13 your approach is consistent with how the rest of or the 14 majority of the industry approaches that, and so we'll 15 look at that. But you know, your comment about which 16 requires field monitoring an augmented function to 17 support conclusions, I'm not sure we're in full 18 agreement right now with that.
19 MR. GREGOIRE: I understand.
20 MR. DAPAS: But I do think we may want to 21 look at does your emergency director, if it happens to 22 be the shift manager, for those rapidly developing 23 scenarios where the dose projection would say the 24 dosage is going to be greater than the EPA PAGs at 10 25 miles, does he have the latitude to make what he thinks 26 is the right decision there if you find yourself in a 27 case where the TSC is not manned, the EOF is not manned, 28 or as I think Paul mentioned, you know, it's going to 29 take a while before that field monitoring team, 30 depending on the wind direction, gets you some 31 meaningful data from out in the field. So you need to 32 consider that I think.
33 MR. GREGOIRE: Right. We will take that 34 as an action measure to follow up with our shift 35 managers on their decision process. Okay, in regards 36 to the significance assessment, again this makes it a 37 little bit difficult to speak to in that the statement 38 is " the licensee could no longer recommendations for 39 the public to shelter-in-place when appropriate, and 40 that limitations could result in delays in making 41 appropriate protective action recommendations." As 42 mentioned before, we clearly are, you know, believe 43 that we have guidance in place, and we understand we 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 are going to go back and talk to our shift managers about 1
the possibility for generating protective action 2
recommendations for beyond EPZ.
3 And we're also--as a matter of fact, we're 4
also engaged with the EP Working Group to help have 5
further dialogue on this. So if you still agree that 6
there's a performance deficiency here, I do want to make 7
just a few comments with regard to significance. One, 8
in using the tool from NUREG-0654, which encourages 9
site-specific development, our protective action 10 scheme is site-specific; it was developed in 11 cooperation with our offsite response organizations, 12 the county, the state, Department of Energy. We've all 13 agreed to the protective action recommendation scheme 14 that we have currently in the procedure. In 15 consideration of our topography, our very low 16 population density, our very short evacuation times, 17 evacuation is the most appropriate PAR to ensure that 18 dose is avoided in most cases.
19 While we understand that a procedure could 20 be viewed and interpreted differently, interviews with 21 our staff, you know, emergency directors conclude that 22 the use of the procedure can in fact help them reach 23 their shelter-in-place consideration if the conditions 24 warranted it. Just a few examples we brought up here 25 with regard to other stations, I don't have all the 26 details, I'm not trying to state that I know all the 27 facts behind it, but just a little bit of comparison.
28 Here is, for example, in 2015, a Region I plant modified 29 their procedures that would in essence recommend 30 evacuation of downwind areas and many more emergency 31 response planning areas than intended. It was 32 determined to have very low safety significance.
33 And there's another example, two Region IV 34 plants, they both had a similar issue or concern that 35 is not the same as Columbia, but they failed to follow 36 their federal guidance, EPA guidance, and they 37 introduced automatic extended protective actions 38 for--I'm sorry, based on plant conditions and changes 39 in wind without consideration for dose. In contrast, 40 just a couple of stations that did receive low to 41 moderate safety significance findings, white findings, 42 recently in 2015, a Region IV plant totally removed 43 their PARs or protective action recommendations for a 44
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 certain portion of their EPZ, and secondly a Region III 1
plant, they had changed their PAR procedure to 2
eliminate decision-making process for PARs beyond EPZ.
3 And again, I want to emphasize that 4
Columbia still has protective actions in place for all 5
sections in the emergency planning zone, and in most 6
cases, evacuation would be the clear choice; however, 7
for a very few cases, shelter-in-place would still be 8
a consideration. For those very few cases at Columbia, 9
Attachment 7.2 would have us consider 10 shelter-in-place. So in summary, it's our position 11 that Columbia continues to meet the emergency plan 12 commitments, that all considerations for 13 shelter-in-place found in the applicable federal 14 guidance and NUREG-0654 Supplement 3 2011 version were 15 addressed and are implemented in our procedure, and 16 that Supplement 3 clearly states that compliance with 17 it demonstrates compliance with 50.47(b)(10). And 18 lastly, I'd like to just emphasize that in our case, 19 public health and safety is appropriately protected 20 with our current protective action scheme.
21 MR. DAPAS: Can I ask a clarifying 22 question, Mr. Gregoire? Just to make sure I 23 understood, your point here in talking about the Region 24 I plant for which the assessment was very low safety 25 significance--
26 MR. GREGOIRE: Yes.
27 MR. DAPAS: --in comparison to whether it 28 was low to moderate safety significance here, Region 29 III plant and the Region IV plant, which is the criteria 30 for a white finding. You were saying that if we decide 31 the performance deficiency remains valid, that you 32 think the safety significance, given these examples, 33 is more in keeping with the green finding versus white?
34 Is that the overarching point?
35 MR. GREGOIRE: Yes. If you continue to 36 believe there's a performance deficiency here, we don't 37 believe that the--in our situation and our 38 circumstances compare to the plants that have the white 39
- finding, but are more characteristically more 40 associated with those that are in the green area.
41 MR. DAPAS: Okay, thank you.
42 MR. GREGOIRE: So with that, I'll turn it 43 over to Grover.
44
73 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. HETTLE: Okay, thanks. In closing, 1
I'd like to emphasize this issue has been under review 2
since last August, and it's really taken us some time 3
to understand all the facts associated with it, and even 4
you know, per our discussion today, we can still see 5
that maybe we're still gaining some understanding with 6
this, so. But as we stated, our procedures were 7
developed based on a good faith effort to implement the 8
federal guidance, and it was done in collaboration with 9
the offsite response organizations, with the best 10 interests of public safety in mind. We believe our 11 procedures continue to provide an option for sheltering 12 in place should the conditions warrant it to prote4ct 13 the public from the effects of a possible radioactive 14 release.
15 And as Don stated, we do not believe that 16 there is a performance deficiency here, but again, if 17 it is determined that there is one, we do believe that 18 it wouldn't raise to a level greater than green. I'll 19 also state though that we've talked about a couple of 20 things here that we know are some strong learnings for 21 us to go back and reflect on and take some actions on 22 because again, I think they were just reiterated here 23 today when we talk about the clarity of our procedures.
24 And I thought one perfect example, again, with the 25 section or the Attachment 7.1 that talks about I think 26 it was evacuate sections instead of evaluate. When we 27 talked to all of our emergency operating facility 28 directors, if they came to the conclusion it was to 29 evaluate that, we'd go to that.
30 And again, I'll state too when we talked 31 to them, we understand that wasn't a perfectly sterile, 32 you know, test case study because again, we had already 33 started through the discussions and already put out the 34 communications. So again, we understand it wasn't a 35 perfect case study, but also I would say the 36 interaction, their interface skills definitely we've 37 got to improve there because again, just a simple 38 question asked and trying to get us to answer, you know 39 the shelter, the same thing with shelter in place, you 40 know, the same. We kind of went through quite a bit 41 of iteration before we finally answered the question 42 that was asked. So again, we understand that, and 43 we'll take appropriate actions to ensure that, again, 44
74 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that we get better in those areas with that. This does 1
complete our presentation; we do thank you for your 2
time.
3 MR. HAIRE: Okay. So at this point, I 4
think we're at the point in our agenda where we're going 5
to step out for a separate NRC caucus next door, so those 6
members of the NRC who are participating over the phone, 7
I believe you've been informed what bridge line to tie 8
into. Members of the public can just remain on the 9
bridge that they're on, and we will re-engage probably 10 in about 15 to 20 minutes.
11 MR. DAPAS: And the intent of that caucus 12 is to determine whether we have any additional 13 questions, not to determine the significance, but to 14 make sure we have all our questions answered. Thank 15 you.
16 (Whereupon, the above-entitled matter 17 went off the record at 4:44 p.m., and resumed at 5:17 18 p.m.)
19 MR. HAIRE: Okay this is Mark Haire with 20 the Nuclear Regulatory Commission, just letting the 21 folks on the phone know that we are ready to resume the 22 conference now that we've completed our separate NRC 23 caucus. And with that in mind, we did develop a follow 24 up question that we wanted to ask, and the context of 25 the question is that we as an inspection team, beginning 26 in August, July-August when we received the proposed 27 change, or the change that had been implemented to Rev 28 18, we began to read it, to engage the Columbia staff 29 to try to understand what does the change mean, what 30 was the intent behind the change. We had dialogue 31 about that, and interactions periodically for several 32 months, so through the January-February time frame, we 33 came away from those discussions with the understanding 34 that the intent that Columbia had for implementing that 35 change, and their understanding--your understanding of 36 the basis for the change, which was interpretation of 37 Supplement 3 guidance based on your evacuation time 38 estimates that evacuation was a better PAR given your 39 evacuation time estimates for rapidly progressing 40 events.
41 Our understanding of your intent for all 42 scenarios was to remove shelter from your procedure and 43 from your training, and to stick with evacuation 44
75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 exclusively based on your evacuation time estimates and 1
your interpretation of Supp 3. And we engaged, we 2
asked the questions, we understand that our questioning 3
impacted your processes for continuing those changes, 4
how you engaged the offsites about whether you were 5
going to change your wording from shelter to monitor 6
and prepare and those sorts of questions. What we want 7
to know here is what was your intent with the change 8
that you began implementing with Rev 18, and had we not 9
asked some questions, what would your procedures and 10 your training look like today? That's basically our 11 question.
12 MR. CLIZBE: So the intent of the 13 procedure change was to implement the supplemental 14 guidance. So the intent of the procedure change was 15 to implement the Supplement 3 guidance; that was the 16 intent, and what was your second question on training?
17 MR. HAIRE: Right, so given that intent, 18 was it your intent to remove guidance to provide shelter 19 in PARs completely from your procedures and your 20 training? We came away from our discussions with you 21 thinking that was your intent.
22 MR. CLIZBE: That was not the intent of the 23 procedure revision.
24 MR. GREGOIRE: And might I add, in the 25 phone call in February, when we walked through the 26 procedure with the NRC team, that we showed them where 27 this procedure still had it in place. And so we had 28 communicated that we hadn't taken out that portion of 29 the procedures, and that it still was there. So we had 30 the conversation in February, so I guess we were hoping 31 from that conversation that the staff could see that 32 as well, that we hadn't removed that.
33 MR. DAPAS: That doesn't get to the intent 34 though, frankly. I mean, that just is where you were 35 at the time. And what we're trying to understand here, 36 is we clearly had the inspection function here, at the 37 inspection interface here, the team that was involved 38 were talking to members of your staff were clearly left 39 with the impression that based on your interpretation 40 of NUREG-0654 Supplement 3, that it was the station's 41 intent to remove shelter in place as a mechanism for 42 developing a protective action recommendation, and 43 we're trying to understand was that the intent, and then 44
76 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 when we engaged and asked questions, you stepped back 1
and revisited that and said okay, and you looked at what 2
your training modules says--we're just trying to 3
understand what was the intent there.
4 That doesn't get to whether or not you had 5
that mechanism in place; I think you've explained to 6
us and walked us through how the mechanism still exists 7
and how it would be applied, but it certainly was our 8
understanding, at least the team when they went on site, 9
that it was clearly the station's intent to remove 10 sheltering in place given your evacuation time 11 estimates and given your interpretation of NUREG-0654 12 Supplement 3, not as just being applicable to a 13 rapidly developing event, but for all scenarios.
14 MR. CLIZBE; So it was not our intent to 15 remove shelter in place from our procedure.
16 MR. DAPAS: Okay. Do you have any other 17 questions? Okay thanks. With that, I'd like to 18 close. Clearly, you've communicated your basis for 19 concluding that reference to Attachment 7.1 and 7.2 are 20 your emergency plan implementing procedures, provide 21 a mechanism to consider shelter-in-place as a 22 protective action recommendation. I think it's 23 important that you look as an organization, that you 24 provide the tools for the staff to be successful. Does 25 training reinforce those expectations and concepts? I 26 think you've heard the team explain why when they looked 27 at this evacuate sections where EPA PAGs are projected 28 to be exceeded, and you had reference to 7.2, one could 29 interpret that where you go to 7.2 to validate the PAG 30 numbers if you will, right, and this reference to and 31 shelter remaining sections and you know, that was meant 32 to mean actually shelter-in-place and not this monitor 33 and prepare, and you know I heard what you said the 34 county supervisor would read, and that's the bottom 35 line.
36 That is the outcome when you communicate 37 that PAR about sheltering the remaining sections, that 38 it would translate to that county supervisor actually 39 communicating what shelter-in-place means, and that 40 clearly is in the context of, you know, a dose 41 avoidance. You know, I appreciate your statement 42 there that it was not the intent to remove that, and 43 we got some conflicting information based on the 44
77 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 inspection function.
And I
appreciate your 1
acknowledging that there were lessons learned 2
regarding the inspection interface; well we have some 3
learnings on our side as well, and I think you know, 4
Mark, we'll step back and look at are there learnings 5
in terms of how we communicated, what we communicated 6
when, who it is that we communicated our preliminary 7
conclusions to, our observations, et cetera, and what 8
was the interaction subsequent to that. As you said, 9
this issue's been under review since last August; we 10 should be able to reach closure on an issue sooner 11 than--we were coming up on, you know it's June here, 12 you know, what 10 months, and we're still trying to 13 figure out where are we with this issue, what are the 14 apparent violations, what is the safety significance.
15 So collectively, we've got--we spend resources in a 16 regulatory conference. We spend resources; if this is 17 something that could have been resolved sooner, we need 18 to, both of us, look at the both sides to look at that 19 and see if there are any learnings there.
20 You know I heard you, Mr. Gregoire, mention 21 that the procedure could be interpreted differently, 22 and based on your interviews, you indicated that it can 23 be implemented as intended regarding the 24 shelter-in-place for downwind sectors. You don't have 25 any exercises right where you actually challenged the 26 response team with that; it's based on discussions that 27 you had with some of your emergency directors. But 28 when you look at the specific wording, and my 29 understanding of your--the importance you place on 30 procedural usage here, you could have a new, a 31 relatively new emergency director here, and is he going 32 to have the same understanding as Mr. Brown has based 33 on his years of experience and how he applied that 34 guidance, and you have to look back and say what's the 35 training intent and are you reinforcing those 36 expectations.
37 So I think you need to step back and look 38 at that, so independent of whether it was your intent 39 or not, and I think you have communicated why you think 40 there is a mechanism in place and shelter-in-pace if 41 you will would have been considered as part of your 42 protective action recommendation development, we'll 43 take that information and look at it. I'm focusing on 44
78 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that aspect in particular because that's really what 1
drives the potentially greater than green issue here, 2
is the protective action recommendation associated 3
with that shelter-in-place.
4 Regarding the other two aspects there, you 5
know, regarding the control room and the shift manager 6
and what responsibilities does he have and how would 7
he approach it, I think you clearly explained to us your 8
view that it is appropriate for that shift manager to 9
wait until the EOF and TSC is manned. I think that's 10 an issue that should be gauged, should be further 11 dialogued via the Emergency Planning Working Group. I 12 don't know the validity frankly of your statement that 13 that's how the majority of the industry approaches it.
14 I don't know if that is the case, but I think we need 15 to understand that and ensure that that shift manager 16 is prepared if there is a rapidly developing event and 17 the dose projections are such that you could be 18 exceeding PAGs at the 10 miles point and you don't have 19 time to get meaningful, accurate information from the 20 dose monitoring teams; we need to look at that.
21 And then the--I think the last aspect there 22 was do you still provide for protective action 23 recommendations when there's a planned release. I 24 think you explained why you feel the procedures as 25 they're currently structured would provide for that 26 assessment in a protective action recommendation 27 that's appropriate to the planned release. So we'll 28 take that information on board here and we'll 29 communicate to you via separately our final 30 significance determination and our conclusions 31 regarding any apparent violations.
32 So you know, in summary, by your own 33 acknowledgment, the procedure could be interpreted 34 differently; I think you need to look at that to make 35 sure you don't create the potential for a procedure to 36 be interpreted differently, and you have communicated 37 to us clearly that you feel your staff would have 38 followed that procedural guidance in the manner that 39 was intended. Our staff looked at it, and we came to 40 a different conclusion regarding what was the intent 41 here. We didn't talk to the emergency directors to get 42 their view how would you interpret this guidance, how 43 would you implement that; we didn't do that back in the 44
79 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 original two months as we were developing this issue 1
here.
2 So you know, we didn't have the opportunity 3
to quite frankly test what I would call the as found 4
condition; what is the actual behaviors that would have 5
been exhibited at the time this issue was first 6
communicated versus where are you now after there's 7
been a lot of discussion internally here and on your 8
end regarding what the emergency directors would do.
9 But it gets back to are you providing them with the tools 10 for success. So I want to thank you for the information 11 that you've provided us, and the time you have spent; 12 I think we have a clear understanding of your position 13 and the basis for that, and we will take that under 14 consideration here, and we will communicate the results 15 of those internal deliberations here via separate 16 correspondence, and I would offer in a reasonable time 17 frame here. I'm sure we're going to be able to engage 18 here in the next couple of weeks here, and hopefully 19 reach closure on this soon so we can communicate the 20 results of our internal review. So with that, this 21 concludes our regulatory conference with Energy 22 Northwest, and we now will proceed to provide members 23 of the public that were on the phone an opportunity to 24 ask questions, so I'll turn it over to Mark.
25 MR. HAIRE: Yes, thanks Marc. Just a 26 couple of required closing statements for the end of 27 the conference. First, the apparent violation 28 discussed at this conference is subject to further 29 review and may change prior to any resulting 30 enforcement action; and second, statements of view or 31 expressions of opinion by the NRC employees at this 32 conference or the lack thereof are not intended to 33 be--to represent final Agency determinations or 34 beliefs at this time. So if the operator would go ahead 35 and queue up any folks that have questions on the phone, 36 we will be standing by ready to receive those questions 37 in the order you receive them.
38 OPERATOR: Thank you. If you would like 39 to ask a question, please press star one on your touch 40 tone phone, un-mute your phone, and record your name 41 clearly. If you would like to remove your question, 42 press star two. Again, to ask a question, please press 43 star one, it will take a few moments for those questions 44
80 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to come through; please stand by. The first question 1
comes from Charles Johnson; go ahead sir, your line is 2
open.
3 MR. JOHNSON: Thank you. I'm Charles J.
4 Johnson, and I'm the Director of the Joint Task Force 5
on Nuclear Power for Oregon and Washington Physicians 6
for Social Responsibility. I don't have a question, 7
I merely have a comment, which is that I'm glad to see 8
that the Nuclear Regulatory Commission and Energy 9
Northwest are discussing this issue of evacuation plans 10 and some apparent failings in the current plan, taking 11 it very seriously. Obviously what happened in 12 Fukushima in the aftermath of the tsunami, earthquake 13 and tsunami and the accident there illustrates how 14 chaotic a situation can become in an emergency 15 situation. You'd have people evacuated into high 16 radiation zones, and the authorities not knowing that 17 for several days, until several days later, and you had 18 confusion as to who was in charge of various operations 19 at the plant, including I believe some of the decisions 20 on evacuation.
21 So I'm very pleased to have listened to 22 this hearing, I believe the NRC is taking this very 23 seriously, I hope that Energy Northwest is as well, and 24 trust that they are, and that's all I have to say.
25 Thank you very much.
26 MR. DAPAS: This is Marc Dapas, I want to 27 thank you Mr. Johnson for your comment. I think it 28 really underscores the importance of having a very 29 specific emergency plan implementing procedure so that 30 clear guidance and tools are provided to the decision 31 makers regarding any protective action recommendation, 32 be it shelter-in-place or evacuation. So you know, you 33 don't want to be making decisions on the fly when you're 34 dealing with event response where there can be, you 35 know, a lot going on if you will. So I very much 36 appreciate your comment, and thank you.
37 OPERATOR: As a reminder, if you would 38 like to ask a question, please press star one; we 39 currently have no questions in the queue at this time.
40 MR. HAIRE: Why don't we put out one last 41 request and make sure everyone that's on the phone had 42 an opportunity to ask a question, so I'll give that just 43 about 30 more seconds. Are there any additional 44
81 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 questions from members of the public that are listening 1
to the conference? All right, well thank you, and this 2
concludes our question and answer session. Thank you 3
operator; you can disconnect us from the bridge line.
4 Thank you.
5 OPERATOR:
That concludes today's 6
conference; thank you for your participation.
7 (Whereupon, the above-entitled matter 8
went off the record at 5:34 p.m.)
9 10 11 12 13 14 15 16 17 18 19 20
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 1 NWX-US NUCLEAR REGULARY COM (US)
Moderator: Deborah Harrison June 15, 2015 11:45 am CT Coordinator:
Thank you for standing by. At this time, all participants are in a listen only mode. During the question and answer session, please press star and 1 on your touchtone phone. Todays conference is being recorded, you may disconnect at this time. I will turn the meeting over to Mr. Mark Haire. Sir, you may go ahead.
Mark Haire:
Okay. Thanks. And just a reminder to the folks in the room, the microphones that are on the desks have a little green LED when its lit. Your mike is live. If you touch the little push button and the green light is not lit, that means youre not live. And youre not being amplified for the phone folks. Also in the room there is a wireless mike on the stand for any members of the public.
Dont see any members of the public in the room at this time. But they may join us later. Alright. So to kick off the meeting, there are some opening remarks and statements that need to be made including some logistic comments. And Ill be leading that charge. So Ill be reading through some elements that need to be covered.
And then Ill follow the agenda. So step 1 is to go through the conference opening. So my name is Mark Haire. Im the Branch Chief for the Emergency Preparedness and Security Inspectors in the NRCs Region 4 office. Welcome to the Reg Conference between the NRC and Energy Northwest Columbia Generating Station.
Today, we will be discussing a finding related to the Columbia Generating Stations failure to follow requirements of their site emergency plan.
Specifically, that emergency plan implementing procedure were changed so that the procedures did not continue to provide an option to recommend shelter-in-place as a protective action recommendation for the public when its appropriate.
The revised procedure also did not continue to provide further development of protective active recommendations for an intentional release of radioactive material and in appropriately delegated some responsibilities of the senior reactor operation in the control room from making protective action recommendations. This conference is open to public observation.
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 2 However, this is an enforcement or a regulatory conference. And as such, it is a meeting between the NRC and Columbia Generating Station. And during the meeting, comments and questions will not be taken from members of the public. But following the conference, NRC staff will be available to answer questions and receive comments from members of the public concerning matters discussed here at the conference.
Marc Dapas:
Or any other...
(Mark Hare):
Or any other questions as Marc Dapas, our regional administrator has mentioned. Its important to note that this phone bridge is being recorded.
Both the recording and the transcript will be made publically available soon after this meeting. The Columbia Generating Station representatives have provided slides for their presentation. And those slides have been made available at the NRCs public meeting webpage. Its at www.nrc.gov and you would click on the Public Meetings and Involvement tab.
And then click on the Public Meetings Schedule link. And scroll down and see todays meeting listed. And youd click on the more tab and youd see the related documents include the slides that Columbia Generating Station has provided. And those slides that are on that link are the updated slides that Columbia provided to the NRC today.
So those are the updated slides. Alright. So administrative items before we review the rest of the agenda. For those in the room, the closest restrooms are out the door to the left past the guard station. And then theyll be on the right close to the lobby. If there is an emergency, we need to listen to the announcements over the intercom system.
And if an evacuation of the building is required, the nearest exists are either at the main building entrance where you came in which is left out of this room or on the side of the building to the right. Theres an emergency exit. For the microphones, we ask that all NRC and Columbia Generating Station personnel who will be speaking please use the microphones so that the people on the phone will be able to hear.
We should have sign in sheets available. I dont know if theyve been passed around yet. But if they havent, well make sure that those get passed around.
Wed like to have a record of everyones attendance to the meeting. And if there are any members of the public in the room, well provide you with feedback forms so that you can provide comments to the NRC.
A meeting summary will be made available by the NRC within 30 days of this meeting. So a quick review now of the agenda of the meeting. The meeting will open with the opening comments by me which Ive done. Next, well go
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 3 through introductions of the key participants from both organizations. Then I will go through a summary of the regulatory process and the apparent violation at stake thatll be discussed today.
And then Marc Dapas, our regional administrator will make some opening remarks. And then well turn it over to Columbia Generating Station to make any remarks and presentation that theyd like to make. Throughout the presentation, we will be engaging with questions during that process. Then after your presentation and after weve had a chance to ask some questions, the NRC will disengage from the meeting for a timeout.
Well exit the room. Have a caucus in a separate room where well discuss what weve heard. And if we have any additional questions, itll probably take us 15-20 minutes to do that. Then well reconvene the meeting after that caucus for any final questions that we have. And then Ill offer the opportunity for our senior managers including Marc Dapas to make any closing comments.
And then Ill make some comments about the closing of the business of the meeting. And then Ill invite at that time the operator to allow members of the public of ask questions. And the NRC will be happy to entertain those and answer those. So thats how the meeting will progress. So at this point, Id like to engage in some introductions starting on the NRC side.
Ive already introduced myself. Im Mark Haire. Im the branch chief for Emergency Preparedness and Security Inspections.
Marc Dapas:
Well, Im Marc Dapas. Im the Regional Administrator for our Region IV office.
Rob Kahler:
Im Rob Kahler. Im the Branch Chief with the Inspection and Regulatory Improvements Branch with NSIR at the Rockville, Maryland NRC Headquarters office.
Jeff Clark:
Im Jeff Clark, Deputy Director, Division of Reactor Safety.
Wayne Walker:
And Im Wayne Walker. Im the Branch Chief for Columbia and the Division of Reactor Projects.
Mark Haire:
And the next table back.
Troy Pruett:
Troy Pruett, Director of Reactor Projects, Division IV.
Paul Elkmann:
Paul Elkmann, Inspector, Region IV.
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 4 Bill Maier:
Bill Maier, Inspector Region IV.
Karla Fuller:
Karla Fuller, Regional Counsel.
Mark Haire:
Thanks. And if Mr. Hettel, if youll introduce your team.
Grover Hettel:
Yes. My name is Grover Hettel. Im the Vice President of Operations at the Columbia Generating Station for Energy Northwest. And Ill let my team introduce themselves.
Don Gregoire:
Im Don Gregoire. Im the Manager of Regulatory Affairs.
Sean Clizbe:
Sean Clizbe. Im the Emergency Preparedness Manager at Energy Northwest.
Dave Brown:
Dave Brown, Planning, Scheduling and Office Manager. Also Emergency Director.
Kurt Gosney:
Kurt Gosney, Acting Emergency Services General Manager.
Andy Black:
Andy Black. Im the Emergency Services General Manager although Ive been on loan to Capital Projects for the last 5 months. I still retain ownership of EP in my division.
AJ Fahnestock:
AJ Fahnestock. Im the EP Program Manager.
JR Trautvetter:
JR Trautvetter, Regulatory Affairs Compliance.
Desiree Wolfgramm: Desiree Wolfgramm, Complaints Engineer.
Mark Haire:
Okay. That is full introduction of the folks in the room. We dont have any members of the public. Couple of observers from the NRC staff in the room.
And I do believe we have some folks from the NRC staff also listening on the line. So now Im going to summarize where were at in the regulatory process.
What the apparent violation at stake is today.
And then well move forward with the agenda. So a bit of a lengthy description. So bear with me. So in accordance with the NRCs regulatory process after a potentially risk significant finding is identified and characterized by our significance determination process as potentially greater than green, we offer licensees an opportunity for regulatory conference.
In this case, Columbia Generating Station requested that a conference be held to discuss the issue and its significance. It is the responsibility of the NRC Licensees to provide protective action recommendations to local and state officials. Those local and state officials then consider the plants
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 5 recommendations as they make protective action decisions to protect the health and safety of the public.
And were here today because in 2014, Columbia Generating Station made a change to their emergency plan implementing procedures that deleted shelter and place as a possible outcome from their flow chart used to make protective action recommendations. And they deleted instructions to develop protective action recommendations when the release was intentional.
And they added limitations on the protective action recommendation choices available to the senior reactor operator in the control room. So let me give it a little bit more detail about that - those issues. When an emergency occurs, it may present a risk to the public. The NRC requires that Licensees consider a range of protective actions to arrive at a recommendation for the safest overall action for the public to take.
Often but not always that action is evacuation. But sometimes, the most protective action is to shelter-in-place. Outside authorities consider a Licensees recommendation along with other information about the event and deciding what measures to implement. But a Licensees recommendations of the outside authorities is important because it communicates the radiological risk to the public.
Columbia Generating Stations original approved emergency plan and all subsequent revisions up through the current plan have included a range of protective actions appropriate to a spectrum of emergency events. The emergency plan describes both evacuation and shelter-in-place as potential actions that may be recommended to offsite officials for the protection of the public.
In a specific event, the choice is based on plant and radiological conditions, the EPA Protective Action Guides and the radiation dose that could be avoided. The NRC concluded that the Columbia Emergency Plant appropriately describes the protective measures to be taken in the event of an emergency.
However, on June 16, 2014, Columbia changed their procedures for developing protective action recommendations and inappropriately removed shelter-in-place from the procedure text and from the primary decision tool which is a flow chart used to determine which protective measures would be recommended for the public.
The removal of those instructions reduced the number of options that would be considered and then put a shelter-in-place. Recommendation could only be arrived at by going outside of the procedure. Even in the unusual circumstance
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 6 where shelter would provide a dose-savings and therefore more protection to the public.
And I think its important to note that our guidance defines shelter-in-place as a dose saving protective action involving people going into their houses, closing their doors, closing the windows, turning off their ventilation and attempting to avoid dose. Its a dose protection - dose avoidance protective action.
Anyway, the same procedure also failed to ensure that the need for additional protective measures would be evaluated if Columbia was intentionally venting radioactive material, so intentionally venting radioactive material. And also delegated the decisions about protective measures for some areas of the senior reactor operation and the control room to other company officials and other facilities.
And the responsibility to make protective action recommendations is not delegable. It must remain with the individual exercising command and control. And because those other facilities might not be staffed when conditions are require a recommendation, the procedure could have caused delays in protecting the public.
As a result of procedure changes, Columbia no longer complied with the NRC requirements to follow their emergency plan and no longer provided for a range of protective actions. Therefore, this apparent violation is associated with a finding that has preliminary been determined to be of white significance.
Note that we use phrases like apparent violation at a conference like this because the NRC will not make its final determination on the violation or its significance until after the conference. The white significance in the case the NRC has preliminary concluded that Columbia degraded their ability to implement a risk significant emergency preparedness function.
We use this phrase risk significant to denote those functions with the most immediate impact on the Licensees ability to protect the health and safety of the public such as event classification, offsite response organization notification, radiological assessment and protective action recommendations.
Now their ability to implement a risk significant function was degraded because the procedure change narrowed the protective measure options and could have delayed making some recommendations.
The NRC takes this very seriously. So having said all of that, let me summarize - actually, let me read the proposed apparent violation. Title 10 of the Code of Federal Regulations, Part 50.54Q2 requires in part that a holder of
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 7 a license under 10 CFR Part 50 shall follow and maintain the effectiveness of their emergency plan that meets the requirements of Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b).
And Title 10 of the CFR Part 50.47(b)10 requires in part that a range of protective actions has been developed for the plume exposure pathway and emergency planning zone for the public. And in developing this range of protective actions, consideration has been given to evacuation and sheltering as appropriate.
At Columbia Generating Station Emergency Plan Revision 59 which was dated September 10, 2013 through the Revision 61 which was dated September 2014 in Section 2.1 Organizational Concepts Required in Part that the emergency direction and comprises the overall direction of the plants emergency response which must include the non-delegable responsibilities for emergency classification, the decision to notify and recommend protective actions to authorities responsible for offsite emergency measures.
Columbia Generating Station Emergency Plan Section 5.5 - Protective Action Responsibilities required in part that the appropriate protective actions for an airborne release of radioactive material are evacuation and sheltering. And that the decision to evacuate or shelter is made based on the dose to be avoided by the protective action relative to the risk associated with implementing the protective action.
And that protective action recommendation shall be made based on plant and radiological conditions. Contrary to the above, between June 26, 2014 and April 23, 2015, Columbia Generating Station failed to follow and maintain the effectiveness of the emergency plan which meets the requirements of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b).
Specifically, Columbia Generating Stations Procedure 13.2.2 which is titled Determining Protective Action Recommendations, Reg 18 Section 4.5.1 did not implement the requirements of the emergency plan Section 2.1 because procedure required the emergency director and the control room to delegate the formulation of protective action recommendations to the technical support center or the emergency operation facility.
However, protective actions are non-delegable responsibilities of the emergency director. In addition, Procedure 13.2.2 Rev 18 did not implement the requirements of the 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 protective action recommendations to protect against planned releases of radiological material.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 8 And the Licensee has entered this issue into their corrective action process.
Corrective Action Request 320790 dated January 19, 2015 and several other corrective action documents. Alright. That is the proposed apparent violation.
This proposed apparent violation with an option to request a regulatory conference were communicated to Columbia Generating Station Power Plant during an exit meeting on April 23, 2015 and in the NRC Inspection Report 05000397/2015 502 which was dated May 7, 2015.
This regulatory conference is the last step of the inspection process before the NRC makes its final decision on the significance of the inspection finding.
And the purpose of the conference today is to allow you, Columbia Generating Station to provide your position with respect to the facts and assumptions used by the NRC to make our preliminary significance determination and to allow you to present any new information that may assist us in arriving at the most appropriate significant - final significance determination.
In addition to discussing your views on the significance of the finding, you may want to present your views on the identified apparent violation. It is important to note that the decision to conduct this conference does not mean that the NRC has made a final determination that a violation had occurred. In the enforcement related to the finding being discussed today will be assessed in accordance with the commission enforcement policy.
I should also note at this time that any statements of view or expressions of opinion made by NRC employees at this conference do not represent final agency determinations or beliefs relative to the matter before us today.
Following this conference, the regional and NRC headquarter staff will reach a significance determination and an enforcement decision.
NRCs goal is to issue the final significance determination by July 10, 2015.
And that concludes my rather lengthy discussion of the regulatory process and the apparent violation. Id like to turn it over now to Marc Dapas, our Regional Administrator, for his opening remarks.
Marc Dapas:
Thank you, Mark. First and foremost, Im sure that the Columbia team appreciates that developing protection action recommendations is an important process. It provides for the local and state government officials to be able to make informed decisions regarding what the protective action decision will be, mainly the decision regarding what actions members of the public need to take to minimize exposure in the unlikely event that there is a release of radiation resulting from some upset condition at the plant.
And you heard Mr. Haire describe how your emergency plan does provide for shelter-in-place. But the issue that we identified was your emergency plan
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 9 implementing procedures did not provide specific direction. Its my understanding that based on the inspection teams interactions with various folks, the Licensees staff, that it was the intent in implying the guidance in NUREg-0654 Supplement 3 which provides an acceptable method for complying with Appendix E of 10 CFR Part 50 and 10 CFR 50.47(b) which are the emergency planning standards.
That the intent behind the guidance there when it came to shelter-in-place was to provide for those instances where there is a rapidly developing event. And your evacuation time estimates would indicate that you could evacuate the effected population in less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> I think it is. That you can go ahead and forego shelter-in-place and actually recommend through the local and state authorities protective action recommendation that would dictate evacuation versus shelter-in-place.
And that was meant to apply to that unique circumstance where you have a rapidly developing event. And its my understanding that the inspection team from talking to members of your team was told that it was the plan to remove shelter-in-place. That they had intended to remove that from the implementing procedure. You know in other words, they had made a mistake in following or implementing the guidance in NUREG-0654 Supplement 3.
So, if you have a different view, I want to understand that. I need to understand and reconcile the difference between what was communicated to the team as they execute the inspection process and what is your current position because it is my understanding that you have a different view on the violations that we have communicated to you. And again, as you heard Mark go through his description of the issues, he did talk about how we have preliminarily concluded theres a proposed apparent violation.
We have not made an enforcement decision regarding the existence of a violation here or the final significance determination associated with that violation. So its very important that we develop a shared understanding of the facts. And then we hear from you what youre assumptions are. And then we have the opportunity to have further dialogue in our assumption as owe can reach the most informed decision here regarding the existence of a violation and then what is the associated significance for that particular violation.
So I look forward to hearing the discussion and your planned presentations.
So with that, Ill turn it back over to you, Mr. Hettel to begin any discussion or presentation that you would like to provide us.
Grover Hettel:
Mr. Dapas, we do take the protection and the health and safety of the public very seriously. So this afternoon, well be presenting our perspective on the information NRC used to arrive at the proposed white finding. And well also
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 10 take the opportunity to fully discuss the changes that we made to our procedure back in June of last year.
We will layout our facts again as we see them. And well discuss how we reached our conclusion on the subject relevant to the level of significance of the white findings. Our procedures do provide the appropriate level of protection for the health and safety of the public. You know they still provide an option for sheltering in place should the conditions warrant to protect the public from the effects of the possible radioactive release.
We believe that through our discussion today, youll find our procedures are in fact consistent with our emergency plan. And as far as you look on Slide 3 with the agenda, again, well step through the apparent violation. And well talk about our emergency plan commitments and how the regulatory guidelines, lasting guidelines are applied. And also how our procedures interact with that.
And demonstrate that we follow our emergency plan. And then also share some of lessons learned. Then well wrap it up with a summary. And then Ill close. Thats kind of the high level agenda that well be going through. So with that, Ill turn it over to Don Gregoire.
Don Gregoire:
Okay. So Id like to just be clear on our position with regard to the apparent violation. As mentioned, theres two sections of our emergency plan that NRC has concluded that we failed to follow. So Ill speak to each one separately.
The first one is in regard to Section 2.1 of the Emergency Plan in which it was communicated that our procedure did not implement the requirements of Section 201 because the procedure required the Emergency Director in the control room to delegate the formulation of protective action recommendations to the technical support center or the emergency operations facility.
However, protective actions are non-delegable responsibility. So I have 3 points that Id like to mention with that regard. The first - and by the way, this is a high level review. Im not going to cover in great detail. Well discuss it more in the later slides. So with regard to the first point, Sub 4.5.1 of the current version of the procedure, it is our position, can correctly transfers its protective action recommendations for expansion beyond 10 miles to the TSC or EOF because the procedure points to use of both those projection and field teams to make the necessary PAR determination.
This is consistent with industry practice. The field team monitoring is an augmented EOR function. Augmented ERO is Emergency Response Organizati0n is a function that is managed by our - either our technical support center or emergency operations facility. If either of these augmented
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 11 areas have been established, the Emergency Director responsibility would have been transferred in accordance with the stations emergency plan implementing procedures, including protective action recommendation responsibilities.
Thirdly, the transfer of Emergency Director responsibilities are carried out consistent with our emergency plan Sections 2.1 and Id like to point out Section 5.5.2 for relying on field team data when you get beyond the 10 mile EPZ.
The second area of noncompliance noted in the NRC inspection report on page 9 relates to two examples where it stated that we were noncomplying with Section 5.5, the first being we did not provide for the development of shelter-in-place protective action recommendations. And secondly, that we did not provide for protective action recommendations to protect against planned releases of radioactive materials.
So Id like to treat them separately. And the first Ill speak to is the shelter-in-place protective action recommendation. So shelter-in-place - and its our position shelter-in-place was not removed as a protective action recommendation. It can be recommended a protective action by use of.1 and 7.2 of our procedure.
And you will note the inspection report made no mention of Section -.2. The guidance in our procedure is based on Supplement 3 2011 version. And as Supplement 3 clearly states that it provides an acceptable mean for complying with Appendix E and 10 CFR 50.47(b). In that document, you will find no mention of plan releases, puff releases.
However, we still address it. And we will speak to that in later time. And lastly, we will share with you how our emergency plan points to sheltering and evacuation guidance based on this new Reg document. The second example of non-compliance with Section 5.5 had to deal with planned releases.
Although a planned puff release is not explicitly called in the procedure, in the current version, a planned release continues to be addressed in the procedure and in other manners than in the previous revision using Attachment 7.1 and 7.2. The ability to use 7.1 and 7.2 provides consistency with commitments made in Section 5.5.2 of the emergency plan.
I want to sum it up this way. The inspection report gives this picture that the emergency plan says this and the procedures dont say that. As a matter fact, its quoted on Page 5 of the inspection report, However, Revision 18 of the
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 12 procedure no longer follows the above quoted sections of the stations emergency plan.
From August 2014 through March of this year, there have been a lot of back and forth discussion on changes to our implementing procedures. And a lot had to deal with - revolve around plan release or puff release which again as I mentioned is no longer discussed in the new Reg document. When we saw the conclusions of the inspection report, it appeared to us that a number of points has not been reflected in the report.
Number of points that we had made. We believe that the inspection report doesnt give a fair characterization of this issue or the conversations that were held. Were here to discuss those things that were either not quoted or not emphasized in the determination of a performance deficiency.
Marc Dapas:
Just to make sure I have a clear clarification, its your contention that the stations perspective regarding these issues was clearly communicated during the inspection process. And the inspection report does not accurately reflect the discussions that your staff had with our team.
Grover Hettel:
I guess I was going to kind of bring it back up or address it in my closing. I think - Im not sure what you know Marc, what maybe transpired. We didnt either communicate well enough or you know I guess were not wanting to that you know - we werent going to get into that basically.
We just feel that we have not maybe communicated as clearly as we should.
So we want to again present our facts as we see them. Again, and Ill stress as we see them you know because again you know views are different. So - and we understand that. So, now I just think as we went through the conversations, we - we undoubtedly didnt make ourselves you know clear enough so.
Marc Dapas:
Well, I think its important - and I stress this in my opening here. I mean it was my understanding that the conclusions developed during the inspection process was a function of interactions with your staff. So if there was information that your staff felt they communicated. And its not apparent how that was considered as part of the inspection process, you know thats a potential disconnect there.
And we need to understand that. I certainly want to hear the Licensees official position today regarding this apparent violations. But I do want to understand what occurred during the inspection process because I had a - quite frankly a different understanding here from talking to Mark Haire to my right.
And hell have the opportunity to engage you.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 13 But I think thats an important element that we reach closure on so we understand that because we rely on the inspection function. And we communicate preliminary conclusions and the basis for that when we conduct debriefs and exit meetings. And thats clearly an opportunity for any member of your team that interacted with our stuff to say, Wait a minute. You know I had a discussion with you on Wednesday. And we talked about X. How did you consider that?
So I think thats important that we - we flush that out.
Grover Hettel:
Okay.
Marc Dapas:
Whether it be here or whether we do it subsequently, I mean the focus of this conference is to make sure we understand your position clearly, you the Licensee. But I want to make sure that we address any inspection functions disconnects that occur.
Don Gregoire:
And we agree. We know there was some areas we can improve overall in understanding where the NRC was coming from and how we translated the information to the NRC. But we agree, its very important to have that dialogue. I think the rest of our communication here today is really to try to highlight some of those areas that we felt probably should be reflected on and given a little more attention.
So on the next slide, youll note that I have a star on this slide. And the star is really trying to symbolize the areas where we think theres some gaps in the communication. And things that we think should be added to the conversation.
And so any slide where you see a star on it, its really to address that information we think was not emphasized enough earlier on in discussions.
So to this point, with regard to shelter and evacuation and the consideration for shelter and evacuation, its our position that the emergency plan specifically points to Federal guidance on how you consider shelter and evacuation in your procedures for protective action recommendations. Well present more information beyond that cited in the inspection that we believe is relevant to the finding.
Next slide. So just starting with the foundation here, the regulation as you know 10 CFR 50.47 governs our - describes the number of standards that are required for emergency response plans. With regard to this one specifically, 10 CFR 50.57(b)(10) - I wont read the whole thing to you. But the very last paragraph there is Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 14 So our message here today is that we have four things that were going to focus on in our presentation, Emergency Plan Commitments, what do they actually say; what was omitted. What does the Federal Guidance say and how did we evaluate the Federal Guidance. What is the actual implementing procedure?
How do we use it? How would our emergency director look at that procedure?
And then lastly, our classification/notification form where the protective action gets issued. So well speak to all of that. I do want to mention that the regulation has us consider shelter and evacuation, but doesnt tell us how to apply them in our procedures or action schemes.
Our emergency plan does point to Federal Guidance that describes how we do this. And well walk through that shortly. But the four elements are interlinked together to assure that appropriate protective action recommendations will be made. So the first point that we would like to emphasize that we disagree with the conclusion on is a statement that says that we failed to follow Section 5.5 of our plan.
Now as you see there, it mentions were required to have appropriate protective actions for an airborne release of radioactivity which were evacuation and sheltering. And the decisions to evacuate or shelter based on dose avoided. And then lastly, the protective actions are based on plant or radiological conditions.
What that doesnt say is how thats implement. If we look to the next slide.
This is a Section of 5.5 that was not included in the inspection report. But it goes on to further say that Protective Action Guides, discussed in Section 5.5.2, provide pre-planned guidance for making response decisions. So its directing us towards the Federal Guidance that we would use for developing our protective action scheme.
Well show later how that ties in. But lets go to the next slide. So again, theres another slide we think was - you know this was referenced in the inspection report. But we dont believe it was given you know proper emphasis. Theres a presumption that sheltering must always be considered in every scenario.
What we did, we evaluated NUREG-0654. It describes sheltering and evacuation. And it tells you how to consider it in your pre-plan procedures. I do want to emphasize that in this commitment here in our emergency plan that it says that our shelter and evacuation guidance are based on both the EPA document as well as the NUREG-0654 Supplement 3 document.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 15 At this point, I dont believe theres any concern or issue with our compliance with the EPA document. So were only going to go forward and speak to the NUREG-0654 document. The Protective Action Recommendation decision making tool found in PPM 13.2.2, the tool that specifies how shelter and evacuation are applied during any general emergency at Columbia is based on these documents.
What they do is guide us for a limited set of scenario or conditions and how to consider shelter-in-place versus evacuate for these scenarios. Meeting these guides in essence meets the commitments described Section 5.5 of the Emergency Plan. And again, well describe how we meet that and how we actually have additional guidance in our procedure above and beyond the NUREG.
So Ill turn it over to Sean.
Sean Clizbe:
Id like to discuss our NUREG-0654 Supplement 3 and our evaluation and implementation of it in our procedures. So my intent here isnt to read the regulation to you, but more just describe our evaluation of the applicable sections. So from Supplement 3 guidance, it is clear that application of the guidance is an acceptable method to comply with 10 CFR Appendix E to Part 50 and provide the guidance for the provisions of 10 CFR 50.47(b)(10).
It also clearly supports that its acceptable guidance for developing a range of protective action recommendations prior to an emergency and not during the actual emergency itself. This is the guidance that our Emergency Plan Section 5.5 - 5.5.2.2 for developing corrective action recommendations at Columbia.
Columbia used this guidance for the development of our procedure 13.2.2 to meet our emergency plan commitments and develop appropriate protective action recommendations.
And the next few slides will walk through our development process using the supplemental guidance and how it was applied in developing our appropriate protective action recommendation strategy. So in Section 1.2 from the NUREG, I would like to discuss that Energy Northwest voluntarily used the guidance to demonstrate compliance with Appendix E and 50.57(b)(10).
And secondly, the changes to our procedure did not require an emergency plan change when we implemented our shelter and evacuation protective action recommendation tool. The change that we made did not require an emergency plan change from our procedure. So as we work through the Supplement 3 guidance, it is noted that in Section 2.1 of the guidance that suggests that Licensees should use the Attachment and supplement to develop protective action recommendation procedures and decision logic.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 16 What wed like to point out is Energy Northwest did use the attachment for formulation of our protective action recommendation procedure. And it was the basis of Revision 18 to 13.2.2. So next, well take a high level walk through of the attachment. So this tool was used throughout the development process of our protective action recommendation procedure.
This tool is generic to the industry and designed to be used by all nuclear sites.
With the tool being generic to all sites, there is site specific information that must be included to make the tool useful. The tool starts off with a general emergency and flows different directions based on emergency conditions. Our decision making tool is similar to the attachment as we use this guidance to make our procedure change.
As we step through our procedure later in the presentation, note the similar tool used in Attachment 7.1 and 7.2 of our procedure. Next slide. As mentioned in the previous slide, the guidance is generic to all sites. And here its noted, nuclear power plant should develop site specific strategies when using the guidance.
Additionally as noted, the Licensees are encouraged to collaborate with offsite response organizations during the development process. Energy Northwest did develop a site specific strategy and did collaborate with offsite response organizations. In our case, it was to be Benton and Franklin County, the State of Washington and the Department of Energy.
Through guidance use and collaboration, Energy Northwest issued Revision 18 to Procedure 13.2.2. The guidance clearly suggests that the protective action recommendation strategy should be developed prior to the emergency.
And all vested parties should participate. During collaboration with the offsite response organizations, it was clear throughout the process that Energy Northwest Protective Action recommendations must align with Federal Guidance. And ours does.
In the next few slides, well provide some site specific information that we used during our development process that we think is important.
Marc Dapas:
Before you go on, I had a question just following your flow chart here.
Sean Clizbe:
Yes.
Marc Dapas:
On the flowchart you had on page 18, are you equating all others monitor and prepare to shelter?
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 17 Sean Clizbe:
So we - we havent implemented the monitor and prepare section. But we do have - in our - if you - in our procedure when we walk through it, well step through when we shelter remaining sections would be shelter in place.
Marc Dapas:
I look forward to that discussion because I looked at your implementing procedure relative to the Supplement 3. And it certainly in my view is intended to be monitor and prepare. And I thought you you know shelter remaining sections was your phraseology for the monitor and prepare. And if your position is that that meant shelter-in-place, I think we really need to understand that.
Sean Clizbe:
Yes. Were - do you want to discuss it now or later?
Marc Dapas:
Whenever its convenient. If you want to wait until we get to the actual slide I think that has that specific language.
Sean Clizbe:
Okay. Well, this is up on the slide, a general representation of Energy Northwest Emergency Planning Zone. The circles a representation of the 2 mile, 5 mile, 10 mile distances. So this site specific consideration was used in the development process as suggested by the guidance. And its important to note the limited population and the location of population being on the outer edges of the emergency planning zone.
This factors into the evaluation process when determining whether shelter or evacuation is appropriate. The low population density and distant location of the population within the emergency planning zone informed a collaborative evaluation process by which we revised our procedure. Also note that Columbia Generating Station max 90% evacuation time estimate is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 15 minutes.
So kind of walking through our - what our site looks like. You know obviously we have a lot of dessert surrounding our site. Were on the Hanford Nuclear Reservation. Most of our population resides on the outer edges of the EPZ. Thats being the cities of Westland Richland, Richland at the very bottom here.
And then over here across the river is Franklin County which is a farming community. So theres zero population from in a zero to 2 miles. And in the five mile, theres a total of approximately 55 people. And residing over here in the farming community. And then approximately 5,300 people in our Emergency Planning Zone.
Then it gives you a look of what were having to deal with in our planning process. Next slide please. So working through NUREG-0654, this is the decision point in the supplemental flow chart previously discussed for its
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 18 consideration of evacuation versus shelter is addressed. The guidance states that if 90% evacuation time estimate is less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for rapidly progressing scenario, the most appropriate safest protective action is evacuation.
Energy Northwest 90% evacuation time estimate is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 15 minutes.
And its 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. As a result, Energy Northwest determined that the most appropriate protective action for rapidly progressing scenario is evacuation. Additionally, the low population density and distant location result in short evacuation times.
Columbia continues to recommend evacuation, restrictive action recommendation for the zero to 2 mile and 2 to 10 mile distances as our PAR strategy for these conditions. As a result, there is no benefit to adopting a staged evacuation. So no benefit in holding people up if we have ability to evacuate.
Mark Haire:
So Sean...
Sean Clizbe:
(Unintelligible).
Mark Haire:
This is Mark Haire. I just want to make sure I clarify the particular section in NUREG-0654 Supplement 3, the section youre pointing to is Section 2.7 which is particular guidance for a rapidly progressing scenario. So theres lots of other scenarios that need to be considered in your plan. This is guidance for rapidly progressing scenario And we understand you applied the guidance out of Sup 3 for rapidly progressing scenarios in consideration of your evacuation time estimate.
Sean Clizbe:
Yes.
Mark Haire:
And decided the evacuation per the NUREG was appropriate for rapidly progressing scenarios.
Sean Clizbe:
Thats correct. And I would say its consistent with the Attachment in the NUREG as far as the tool that you use to determine your protective actions scheme.
Mark Haire:
Right. And I guess I would just add that were very, very interested in how you guys handle your guidance for PARs for things other than rapidly progressing scenarios because were familiar with our guidance for rapidly progressing scenarios. And we dont take exception to what you did for you that.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 19 Sean Clizbe:
So can I just be clear. Were talking about scenarios that are not currently described in NUREG-0654. Is that correct? Because Section 2.7 talks about rapidly progressing scenarios.
Mark Haire:
Right. So its a particular section.
Sean Clizbe:
Right.
Mark Haire:
And there are other obviously possible scenarios that arent described.
Sean Clizbe:
They arent described in NUREG-0654.
Mark Haire:
Yes. The long and short of it is I said in my opening and perhaps this is not a reflection on what occurred at the station. But it was my understanding from talking to the team that you applied that particular guidance for rapidly developing scenarios. And inadvertently removed guidance - I dont know if it was inadvertent or by design, but removed guidance regarding shelter-in-place for other scenarios other than rapidly developing scenarios.
So were looking to see where there is in your implementing procedure very clearly direction to consider shelter-in-place for other scenarios based on the dose avoidance concept. Thats really in my mind the crux of it.
Grover Hettel:
We agree with you. And we will show you.
Sean Clizbe:
If I can too, we keep using the terms rapidly progressing scenarios. However, this is a specific type of an event. Its a severe accident. So it is defined within the supplement as to a severe accident and also you know the FAQ follow up that was asked by the industry and responded to what constitutes a severe accident.
So its a specific type of the event that is expected to take place rapidly and severe enough that it would be something handled within the control room such that this would be the leg that the control room emergency director would most likely be entering without the assistance of anyone else. So its that type of severe accident.
Grover Hettel:
Id like to just also emphasize that you know part of the struggle that weve had with the communication up to this point is we removed portions of our procedure dealing with the puff release or planned release. And then we were asked to how do we address that? And we tried to address it in the context of whats in NUREG-0654 or try to use the guidance in NUREG-0654 to address how we would look at that scenario.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 20 So I think maybe some of the confusion that has transpired between us is our attempts to try to fit you know something that was not clearly described in the new guidance and to try to make it work. So well gladly speak more on that if anyone has any questions. But I think its - you know Mark you had mentioned some of the concerns about communication.
I think that was one issue there.
Sean Clizbe:
Well, the next consideration for sheltering versus evacuation in the supplement is associated with impediment evacuation. Each one of these impediments were evaluated and discussed with the outside response organizations and appropriate decisions were reflected in Revision 18 to Procedure 13.2.2.
Additionally, our procedure allows for a consideration of impediments not clearly identified in the supplement. And well discuss that later. And next, well discuss our evaluation of each impediment in the following slides. First, well start off with evacuation support. The guidance states that lack of traffic control may not be considered as an impediment when theres low population density within 2 miles.
Energy Northwest has a low population within 2 miles of the site. And through collaboration with the offsite response organizations, it was determined the lack of traffic control would not be an impediment to evacuation. In fact, there are no - theres zero permanent residents within 2 miles - 2 miles of our site.
This evaluation was incorporated into our procedure in Revision 18 as evacuation support not being considered an impediment to evacuation. Next well take a look at hostile actions as an impediment. The hostile action impediment consideration was discussed with our offsite response organizations and determined that due to low population surrounding the site, that the appropriate protective action recommendation during this event would be evacuate.
Due to low population surrounding the site, zero residents within two miles, the evacuation recommendation would not be putting people at risk of inadvertently becoming involved in hostile action. We came to this agreement and this analysis was included in Revision 18 of our procedure as the appropriate protective action.
Next, well discuss adverse weather as an impediment. During the collaboration process, it was determined that the offsite response organizations would have a better understanding of any adverse weather impediment at the time of the event especially when the location of the at risk
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 21 population is taken into account, that being on the outer edges of our emergency planning zone.
Therefore, Energy Northwest did not include consideration of adverse weather impediments in the protective action recommendation process. Additional considerations were given to the evacuation time estimate values when evaluating the impediment. Evacuation time estimate for all population emergency planning zone for the adverse weather scenario was less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
While it was determined that Energy Northwest had not needed to consider adverse weather as an impediment in our protective action recommendation for the standard protective action recommendation, it was taken into consideration for radiological release as described in Attachment 7.2 of our procedure.
And so well discuss that further. So in summary, NUREG-0654 Supplement 3 guidance encourages Licensees to use the guidance for developing the protective action recommendation strategies. Energy Northwest did use this guidance. And with offsite response organization collaboration, implemented Revision 18 to Procedure 13.2.2.
The NUREG was fully evaluated revealing that evacuation is the most appropriate protective action recommendation for our site emergency planning zone for the scenarios that are described in the NUREG. As well demonstrate, our procedure still retains the mechanism for issuing a shelter-in-place protective action recommendation when conditions not specifically described in the NUREG warrant.
Before we demonstrate this, well take a quick review of the changes to our procedure.
Man:
Id like to just point out the inspection report makes these three conclusions that we disagree with. The first is that the assumption that we will remove shelter-in-place as a protective action. And No. 2, that we remove the recommendation of protective actions for plan releases. And 3, that we limited the ability the emergency response organization to recommend protective actions outside the plume exposures zone.
Revision 18 eliminated specific language for shelter-in-place for some cases.
However, it did not remove shelter-in-place considerations or limit abilities to associate with protective action and recommendations within our outside the plume exposure emergency planning zone. Ill turn it over to Sean.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 22 Sean Clizbe:
Im going to walk through our procedures 13.2.2, Revision 17 and Revision 18 changes. But first I wanted to discuss why we made the change in June of 2014. So the reason the change occurred was to implement 2011 version of Supplement 3 to NUREG-0654 with the objective of reducing potential health effects in the event of a nuclear power plan accident.
Incorporated shelter-in-place considerations in the structure of the protective action recommendation, a decision making tool. And also, we implemented some formatting improvements based on site process. But the real reason that were you know implementing this guidance is the best guidance thats based on real large emergency operating experience. And its the safest for the public.
The next, Ill walk through major changes to our procedure that are relevant for discussion today. So on the screen, we have Revision 17 and our current revision, Revision 18 up. Theres kind of some administrative things to take care of first. For the yellow text on Revision 17 there, youll see is text that changed - green text in Revision 18 is text that was added. And blue text in both revisions is text that hasnt changed, but is relevant to the discussion today.
So the changes that we made here were to include an If/Then statement and an update to insure that those projection tool was the first tool available for use.
And the table in the back as a backup. Initially, we split it into two sections for clarity. So these changes do not impact the range of protective action recommendations to be considered by the emergency director nor the obligation to make protective action recommendations beyond the emergency planning zone.
So the changes in this section here is we removed the mention of a planned puff release as that language is no longer included in NUREG-0654 Supplement 3 2011. And so that thats a removal of - hard to see I guess from here. But removal of this 4.3.5 step. While we did remove this step, the concept of a planned release is still considered in our procedure.
And again, were going to walk through that in detail. And also step 4.3.5, theres a known impediment language in there. And this is also still addressed.
And addressed in Attachment 7.2 in our - of our Revision 18 procedure.
Additionally, we had lots of discussion on step 4.4.4 in Revision 18.
And focus on how to implement a protective action recommendation and not what protective action recommendation should be made. Its simply letting offsite response organization know that were going to vent containment so they can prepare. So what didnt change? The blue text 4.4.2. It still requires the use of Attachment 7.2 for updating protective action recommendations.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 23 The procedure points to 7.1 and 7.2 which provides the mechanism for an emergency director to consider shelter-in-place. The one - Attachment 7.2 wasnt mentioned in the inspection report. We think its important the conversation today that this is part of the decision making process for the emergency director. So, were going to discuss each or each attachment next.
Man:
(Unintelligible). Go back to that last slide about (unintelligible). A couple of times about how...
Man:
Does he need a microphone?
Man:
You talked about the need for how Supplement 3 took away the need for puff releases. I dont - Im not sure that we would agree that this guidance took away that. It doesnt mention it. But that doesnt mean that it supersedes previous guidance on puff release. In discussions that we had over the winter with the staff, we recall that you understood old puff release to be the same as rapidly progressing.
I guess, if you could explain a little bit why you came to that conclusion.
Sean Clizbe:
So the point that were trying to make here is that the term planned puff release is no longer in the guidance. But our procedure still does take into consideration planned release. And thats the part were going to walk through. And we think thats specifically the part that maybe wasnt communicated clearly enough in our original conversations.
Man:
And youre saying that because you read Supplement 3 as being silent on the puff release, you didnt have to address it.
Sean Clizbe:
We addressed the planned release in our procedure.
Man:
I do want to make mention again, you go to the intro of the NUREG and it says you comply with this, you meet the regulation. It doesnt speak to it.
Albeit, an EPF AQ came out a few years later, 2013, where the industry asked the question, Hey, this guidance doesnt mention it. How do you treat it essentially?
And we are treating it. But were just not just treating it in a direct manner because again, like I said, the NUREG-0654 doesnt treat it in a direct manner. But we are addressing it in another manner. And we will speak to that.
Man:
I can point - I guess state because at least through my understanding and kind of discussion on this, when you take a look at the 4.4.4 and it talks about
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 24 containment vent, in essence, puff release is what is short release or release with a known duration so to speak. I mean youre basically venting containments probably going to be the most likely situation.
So again, I think as Don has been saying, we have the ability to - whether we call you call it a puff release or you call it mini containment, regardless of what you want to call the name of it, you know our procedures would still take you know evaluate the PAR for that. And sheltering-in-place would be one of those that wed be evaluating.
Man:
Yes. I think thats the bottom line there. Whether NUREG-0654 talks about planned release. Whether it was previously termed a puff release and youre implementing procedures. My interest is do you have a process to provide for a protective action recommendation in the scenario where you would need to vent containment which is a planned release here.
Man:
Yes.
Man:
And I think we need to talk a bit about - discuss the proposed activity with offsite authorities to assist them with protective action implementation. Or is the expectation that you actually have a protective action recommendation youre providing versus that engagement with offsite authorities. I think we need to understand that aspect.
Man:
I think well be very clear on it when it gets to Dave Brown. Hell actually speak through how he uses the guidance to reach that. So I think if youd give us a few moments, well get to that point.
Mark Haire:
This is Mark Haire again. I just - not to belabor the point, but I want to make sure I understand. So we understand in our review that you still mention a discussion of shelter-in-place as a potential protective action in your attachment 7.2. And youre view is that the way that that could get implemented by control room staff or emergency director staff is by virtue of this reference to it in Step 4.2 where it says...
Man:
Thats for the updated PAR, yes.
Mark Haire:
But it says determine the appropriate offsite PAR by comparing the plume projected dose and field monitoring team data with a protective action guides and guidance provided in Attachment 2 for the early phase of the nuclear incident. So thats - your view is thats the - the staffs connection to potentially making a shelter-in-place.
Man:
No. This is one of the points on a conversation we had on the phone. I believe it was in February timeframe where we were told that our staff would
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 25 specifically jump over that step. And Dave Brown will speak to that in how he uses the procedure. But we dont agree with that conclusion. So again, if you would allow us to wait until Dave Brown who is one of our emergency directors to walk through that.
Sean Clizbe:
Then next wed like to discuss Attachment 7.1 and Revision 17 and 18 and just kind of a high level walk through for familiarity. Entering in the top of the flowchart, general emergency down to determine is a release in progress. Yes.
Go the right which is going to drive you to look at the next attachment which is 7.2 which weve been discussing quite a bit.
And then if its no, then it drives you down to these actions in this note box.
So previously, in the previous revision, this is where we had a See note for puff release. So thats what was removed in their Revision 18. Okay. Yes. Ill use the (unintelligible) line so you guys can see it better. How about that? So the removal of terminology puff release again it was removed for a consistency as we moved it in Step 4.4.5 of the procedure.
And there were no substantial changes to the Release in Progress path other than we had additional footnotes added. And again, after we get done with my portion of the procedure changes, well have an emergency director walk you through the use of the procedure and the associated attachment.
Man:
So I do want to make just a quick point. Mark, you had asked me if there was any difference between what we had sent earlier and the new version. So on Slide 31, just wanted to point out that the previous version didnt have green text or highlighted the section areas. We actually changed those. But that had change text. But in case somebodys looking at a previous version of the presentation.
Man:
Just so Im clear and thank you for that. The box, it talks about evacuate sections where EPA protective action guidelines are projected to be exceeded based on dose assessments or actual survey readings plus the next if not previously recommended then evacuate all sections zero to 2 miles and 10 miles downwind in shelter remaining sections.
Is it your contention that in shelter remaining sections mean shelter-in-place?
Man:
Thats the current definition that we have in our emergency plan. The shelter is the shelter-in-place definition.
Man:
So shelter remaining sections youre maintaining that every other section -
every other - the population that exists you know and all the rest of the remaining sectors other than zero to 2 miles and 10 miles downwind, you
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 26 would shelter-in-place as a dose avoidance versus when you go look at the NUREG, it talks about monitor and prepare.
That your plan was to have everyone sheltered.
Man:
Yes.
Man:
Thats always been the intent?
Man:
Thats been the intent.
Man:
Okay.
Man:
The - were working with our offsite response organizations. And we currently were working through them when this came up to implement a better monitor and prepare strategy. And well continue to work with them and get that - the intent is to work with the offsite response organizations to implement the monitor and prepare language.
Man:
Well, this is important here because what Im hearing you say is you know I want to understand your - if you truly intended that to be shelter-in-place and the individuals that would implement this understood it. Or is it meant to be monitor and prepare. And we used the word shelter remaining sections. In my view, this is an important distinction.
And I want to understand your view on that and the basis for that.
Man:
Dave, you should speak to that.
Dave Brown:
Yes. So this particular box and that language did not change with Rev 18. So this has been our station policy. We call it the standard PAR to as a general emergency, evacuate zero to 2 miles, evacuate downwind sectors, shelter remaining sectors. So thats - thats our station emergency plan guidance, I think Sean and/or Don can talk about with the offsites describe shelter as being because Ive seen that definition as we prepared for this conference.
Mark Haire:
Yes, Dave. This is Mark Haire. I just - I know were beating the horse to death here. But this is, as Mark said, this is important distinction for us. And as you mentioned and we saw, that language about evacuate certain sectors and downwind and then shelter everybody else that language was in your previous version...
Dave Brown:
Thats right.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 27 Mark Haire:
Which also, the previous version also included distinct and separate considerations for potential shelter-in-place PAR for dose avoidance. And in fact, your section - your Attachment 7.2 talks about a separate PAR for dose avoidance. And the way youre using this language here in the flow chart and the way it - similar language is used in the - in the NUREG implies not that youd be telling everybody that doesnt evacuate to go indoors, close their windows, turn off their air conditioning and hide from the dose.
But rather, youre telling them to hang out and wait for further instructions which to us is a very different issue.
Dave Brown:
Right.
Mark Haire:
Its not a protective action recommendation to tell everybody youre not protecting to standby which is what it sounds like youre using this flow chart to mean.
Dave Brown:
So I will go through the flowchart with some examples where I will use.2 in that discussion. So what I was really trying to get at is the standard PAR language was not part of our change. Its been in the procedure as long as I can remember. And Ive been a licensed operator at the site since 1998. So...
Mark Haire:
Right.
Dave Brown:
Ive been through a lot of training and Ive see this...
Mark Haire:
I guess our concern though, the distinction were trying to understand is when you have issued the protective action recommendation for two miles evacuate, 10 miles downwind evacuate, shelter everybody else, were you trying to protect everybody else with a shelter PAR by telling them to turn off their air conditioning and close their doors?
Or were you just telling everybody else standby and wait for further instructions because those are very, very different?
Man:
You know we know the NUREG-0654 uses the monitor and prepare language.
And we havent built that into our process yet. Our definition for shelter still exist. It still is the same in the emergency plan. So we havent changed that.
We know that theres a - we were going to proceed towards down that path.
But the other thing to consider I realize you dont call it a protective action.
But having people not trans - you know travel through the plume zone is an important detail for protection even though you know were asking them to go inside, shut the door, shut the windows even if theyre not in the plume zone
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 28 area. So in essence, were still - you know it may not be called a protective action because theyre not in plume zone. But also keeping them out of traveling through the plume zone is somewhat of a protective action.
I know it hasnt been dialoged much on. But that hasnt changed. So we want to make the point that this hasnt changed although we were working towards the process of implementing something along that line of monitor and prepare.
We have to change our forms. We have to change our procedures. We have to change agreements with the offsites.
Man:
I just want to make sure - why were pursuing this is because its my understanding that you know youre contending that the shelter-in-place was always an aspect that you consider by virtue of the shelter remaining sections, right?
Man:
Thats one part of it yes.
Man:
Thats one part. And well get to 7.2 here. But Id like to know, when you conducted exercises and you had the general emergency scenario here, was your emergency director directing evacuations zero to 2 miles and then 10 miles downwind. And then for everyone else, shelter-in-place. And that was part of your protective action recommendation. And thats what you actually practiced when you had exercises versus did you actually practice what is considered this monitor and prepare.
And is that what you did during the exercises? Or did you actually expect an issue - a protective action recommendation that would have every other section. Youd have the populist there sheltering-in-place which gets to closing windows, turning off air conditioning. And that was part of your protective action recommendation.
If thats what youre maintaining here that that was the intent. Did you practice that in your exercises?
Man:
Yes. So we went through and validated what the offsite response organizations on what it meant when we gave the message out. What was the message the public was receiving. And the (AES) messages that they were giving for shelter was the shelter-in-place definition thats in our emergency plan.
Man:
So during exercises, the shelter remaining sections was translated to shelter-in-place. That was part of your PAR. And thats what you have done for each exercise that has - reaches the general emergency where theres a release involved, right?
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 29 Man:
Yes.
Man:
Yes.
Man:
Okay. So we should have had the opportunity. Your observation of those exercises to validate that, right. Alright. Lets move on.
Sean Clizbe:
So the next, well discuss Attachment 7.2. And this is where the consideration for sheltering versus evacuation is located. So the previous section for release in progress strategy is Attachment 7.2. And this is where its found. And it has not changed from Revision 17 to revision 18. The one minor change here was that we added a reminder that no matter - regardless of the protective action recommendation that we give, its the offsite response organizations have the final say on the decision.
So this attachment is like I mentioned is the tool for determining shelter versus evacuation. And it wasnt specifically referenced in the inspection report. But we think its important to our conversation today. And again, well walk through it with an emergency director to show its appropriate use.
Ill turn it over to Don here.
Don Gregoire:
Okay. So with respect to the inspection report...
Man:
Be sure to indulge me. Since we spent a fair amount of time talking about this, can we go and have you walk through exactly how you would 9f you were an emergency director refer to Attachment 7.1 and 7.2 and how you would make that shelter-in-place protective action recommendation. It seems appropriate in my mind to do that.
Don Gregorie:
Okay. So what well do is jump to Slide 37 and turn it over to Dave Brown, our emergency director to do that.
Dave Brown:
Okay. Good afternoon. Again, my name is Dave Brown. Ive been emergency director since 2003 when I qualified as a shift manager. Been through training, annual training on emergency plans since 1998 when I obtained an SLR license. So Ive been through a lot of training drills, evaluations, actual alert activation. I was there.
And so when I walk through the procedure, Im going to explain from my perspective what the words mean, okay. And my experience. Also, Ill try to highlight where training has emphasized you know different things. So, starting with Attachment or sorry, PPM 13.2.2. Initial Plant Based PARs, when the plant has reached or is about to reach a general emergency for a classification occurring at the station, Ive used Step 4.2 in the procedure.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 30 And Im going to try to use my pointer and start with Step 4.2.1. So the thing about procedure use fundamentals, at our site, if the steps have numbers, you do them in sequence one after the other. You dont skip around unless that procedure gives you permission to do that. So what would be different is if the steps are just bulleted.
Then those steps could be done in any order. But - so Im going to step right through this procedure starting with Step 4.2.1. And thats going to drive me to evaluate my decision for protective action recommendation in accordance with Attachment 7.1. Pass the next slide. So Attachment 7.1 for the case where Im and the general emergency and I have a release in progress or I have a planned release Im about to take, Im going to enter this chart in the same spot.
Enter up here in the upper arrow where it says, Enter if site area emergency or general emergency is declared. With the general emergency, Im going to go down. So the only difference there in my discussion is that if were at a site area emergency and we plan on doing a planned release, well, Im going to upgrade to a general as part of that evolution and move down through the chart.
And then Im going to evaluate this decision diamond do I have a release in progress. And I move over to the right. And that points me to evaluate my protective action recommendation in accordance with Attachment 7.2.
Man:
Dave, can I just back you up for a second. You used the word evaluate per. But your procedure says evacuate per section 7.2.
Dave Brown:
Right.
Man:.2.
Dave Brown:
So - so the direction is to evacuate sections where EPA PAGs are projected to be exceeded based on dose assessments. Attachment 7.2 is the dialogue or expectations in the procedure that I have to consider a shelter-in-place if extreme circumstances are warranted. Thats where I was just getting ready to explain.
So with any release that we have, it doesnt matter if its a planned release or an unisolable leak, Im in this box. And Im going to evaluate - or Im going to evacuate sectors - excuse me, I used the wrong word in accordance with.2. Did I clarify your question?
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 31 Man:
Well, I just wanted to make sure that we were speaking the same language.
And to me, if Im following the procedure and I read the words evaluate per 7.2, then I think Ive got to go to 7.2 and evaluate what the right PAR is. But when I read the word in the procedure evacuate where the PAGs are being exceeded for 7.2, then Im not going to 7.2 to assess whether Im going to shelter.
Im going to 7.2 to access what parts to evacuate.
Dave Brown:
Okay.
Man:
Thats the part Im trying to understand is if were using this as tool to say we would get the 7.2 and consider shelter, are we following the procedure. Thats what Im trying to understand.
Dave Brown:
Yes. So let me - let me clarify that. So next slide is Attachment 7.2. And let me point out something. So, back to my training and experience. So we have the standard PAR that we issue for general emergency. Zero to 2 miles, evacuate. Evacuate downwind. Shelter remaining sections. Thats our standard PAR.
Ive been thought use the Attachment 7.2 to decide if you need to deviate from that standard PAR. And it gives some specific considerations here.
Where Sheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation. Ive read those words for 17 years. They are not - theyre not any different last year than they are today.
And I - like I said, Ive been thought in training. Ive been coached on it.
That in certain circumstances like severe weather, you dont evacuate. You do need to consider sheltering. And so thats really what it amounts to is the direction is to evacuate. That is our standard PAR. The procedure also tells me to consider these other circumstances.
Man:
Two questions on that if you would. The first is I thought it was heard earlier that you agreed with your offsite authorities that in circumstances such as severe weather, there might be pediments that you were not going to consider those as part of your process.
Man:
So with the exception on that slide, with the exception of radiological release scenario.
Man:
So how would you discuss (unintelligible).
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 32 Dave Brown:
Okay so with the release in progress, we do go to this chart - this Attachment, excuse me. Based on the circumstances, I tend to want to point over here. But I know thats hard for you guys to read.
Man:
Can I just make a -address one point. Paul, I know you mentioned something that we said. If you look on Slide 25, it specifically says there that we retain consideration for sheltering in adverse weather conditions during a radioactive release. Maybe we didnt emphasize clearly when we were at that slide but on Slide 25.
Man:
(Unintelligible) the description of the process. The second question goes to the first part of the note...
Man:
Go back to...
Man:
To 7.2.
Dave Brown:.2. Slide 39 Man:
Slide 39.
Man:
Right. Thats first where it starts one shelter may be the preferred in red. As the management (unintelligible) individual, what process do you have to know whether protection is greater or equal as far as sheltering? It doesnt seem to provide you with tools to making that decision.
Dave Brown:
Right. So the - the tools that we have available, I talk to my team including at the table. We have offsite representation. So they can weight in if they have particular details that we dont have in terms of impediments. They can bring that up. As far as those - the radiological emergency manager and I talk about it. We use the dose assessment tool that we have in front of us for that release.
And use that as a - use that to help us make our decision. So part of what we are able to do with our dose assessment tool is show how far into the emergency planning zone are we above 1 REM or 5 REM SETI. Excuse me.
So thats just a - using different dose assessments, you can - you can show where the plumes at in the planning zone.
And you can make a decision from there.
Man:
So does your dose assessment tool provide you with an assessment of the dose under the shelter option - the shelter-in-place option versus the dose under the evacuate option to make the comparison?
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 33 Dave Brown:
The dose assessment tool doesnt tell you what to do. You use your professional judgment. So right now what were doing is were considering these impediments, including you know roads that might be closed due to severe accident or competing disasters and things like that. Thats something our security manager might be privy too as hes talked to the local law enforcement.
So this is clearly a judgment space that were in when were using Attachment 7.2 applying it to the circumstances. Were using our collective experience and our tools. Any other questions on that?
Man:
Yes. I have a question here. If I heard you correctly, this evacuate sections were EPA PEGs and theres reference to Attachment 7.2 are projected to be exceeded, thats where you go to 7.2 and you evaluate whether you should evacuate or shelter-in-place. Am I hearing you correctly?
Dave Brown:
So like I said, Ive interpreted this table for many years to apply that the direction in Attachment 7.1 says evacuate sectors above 1 and 5. Ive interpreted this table. And Ive been reinforced it in my training that you evacuate unless you meet one of these thresholds for sheltering. Then you shelter.
Man:
Yes. I appreciate that because when I read that evacuate sections where EPA PEGs Attachment 7.2, that tells you what the EPA PEGs are. The 1 to 5 Rem TEDE or 5-25 Rem CDE thyroid or 50 to 500 Rem skin. If those PEGs are exceeded or are projected to be exceeded based on the doses, estimates or actual survey readings, so you are evacuating those sections. Plus, if not previously recommended, then evacuate all sections 10 miles downwind and shelter remaining sections.
And its been your contention that shelter remaining sections meant shelter-in-place. Its not clear to me why youre going through this evaluation of shelter-in-place when youve got specific direction here that tells you youre going to shelter all the other sections in place. It seems like this is inappropriate given the direction.
So now youre telling me - and Im speaking to understand, youre telling me that this evacuate sections where EPA PEGs and because it has reference to.2, that has been your trigger point to go to 7.2 and determine whether evacuation is appropriate or shelter-in-place. Independent of the subsequent guidance there that would tell you to shelter all sections, remaining sections.
Dave Brown:
Yes. So I believe I said that. And it is my position that the shelter-in-place discussion is really pertinent to the downwind sectors because our standard
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 34 PAR is to shelter remaining unaffected sectors. So what were applying Attachment &.2 to is that downwind sector. Do we evacuate? Or do we shelter that section?
Everything else - every other sector 2 miles to 10 miles is being sheltered.
Don Gregoire:
I do want to mention that you know when this was first brought to our attention on the phone call I believe it was in February timeframe, me personally as a Reg Affairs manager, I had some concern. Was our staff interpreting that step there and disregarding or feeling like that did not or they should not consider sheltering-in-place in Attachment 7.2.
Knowing that our staff hadnt been interviewed in this process, I wanted to know for myself from a safety perspective, how are they using the table? So we interviewed all of our - the four emergency operations facility emergency directors and how they would use the procedure. And if under certain scenarios and maybe this is leading.
But I wanted to know does the procedure work for them. How do they get to shelter-in-place? And they all pointed to using this box, this section. That.2 as what they would use to introduce shelter-in-place considerations for a planned release.
Man:
Don, you said 4. We actually interviewed 3. And then we did a (unintelligible).
Don Gregorie:
Yes. So we actually had 3 that were on site. And the fourth one was out for medical reasons. And when he came back, we actually dry ran him through a scenario and table top. Im sorry, and he was able to use the procedure to reach a shelter-in-place consideration.
Robert Kahler:
Im sorry. Bob Kahler from NRC headquarters. I guess than during the inspection process to better understand what the actual individuals would do during a real event following the changes or maybe between Rev 17 or Rev 18, the question started coming up discussion turned to training modules as to the change that was incorporated in Rev 18.
And what was intended to change in the training modules to reflect that change. Now I understand what youre talking about in the past that was associated with Rev 17. What were discussing is the Rev 18. And it was my understanding that during the discussion with the staff at Columbia that a discussion on the training module occurred. And a lot of action items that had not yet been completed the training, that it intended to train individuals with removal shelter from even the judgement piece.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 35 That was in table 7.2 to continue on. And then all the training was yet to take place, training changes were yet to take place. Some of them had occurred already to discuss the shelter being removed from the - from the attachment 7.1 where you go through the flow chart, it no longer discusses the use of sheltering even after ten miles so and the fact that I believe during that discussion it was discussed what was meant by sheltering outside of that zero to two and down the wedge that the shelter was not the same as it was previously and a difference of how that shelter would be looked at in the future was to be made and it was only to be monitored and prepared. So the changes have not yet been made to the training module.
So can you explain a little bit about that discussion and where maybe the discussion that I guess we heard and that you said may have a difference in what was made between rev 17 and 18 and what was planned to occur during the training modules as per the action item that you had initiated?
(Kurt):
Sure. So Ill start this out.
Man:
I went around in circles there but...
(Kurt):
And maybe (AJ) can jump in here. Hes in charge of the training program but we recognize when were going through the process and through discussions that our training required some additional updates. When we talked with Mr.
(Elkman) we recognized that we put all of our training on hold. No one had received any training and evaluated the training module and it does need updated to incorporate the changes that we made to revision 18 - incorporating the 0654 guidance. So thats really the way that the discussion went. I cant recall any additional conversation. I dont know if (AJ) can jump in.
Man:
You need the microphone so do you want to come up here?
(AJ Famastock): So Ill jump in at (Kurt)s position. My name is (AJ Famastock). As (Shawn) mentioned, I work for him in emergency preparedness. So the discussion was about some changes that we had made to the training materials which were moved - the reference to what was I believe attachment 7.3 which had times associated with it - evacuation time estimates associated with it and was referenced to section 4.3.5 in the procedure that talked about the use of those evacuation time estimates for puff release.
That had been sequentially removed from the procedure and we had some dialogue about the process by which that was done. We didnt end up writing a condition report prior to that conversation about the timing of that removal.
It was something that did not meet our standards at the station - the timing of the removal did not. Again that was to align it with the procedure changes that were made in June of 2014.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 36 The discussion having to do with shelter in place was not as crisp - certainly not as crisp as it could have been. In fact we came back to the table on a subsequent phone call and provided information directly out of our countys EAS messaging system - follow-on message for EAS broadcast - and in fact read the language directly out of that follow-on message and if you like, I can repeat that here today.
This is our county - this is the EAS follow-on message that (Shawn) referenced earlier having to do with shelter in place and it actually describes the actions that the publisher should take for shelter in place and while we recognize that that discussion may not have been as crisp as it needed to be, we did initiate a follow-on dialogue to clarify that position on a subsequent phone call and I can read you that language if youd like.
Okay so this comes right out of the county EAS message and it states if you live or work in an area that was asked to take shelter, go into a house or other well-built structure, close all windows and outside doors. Close anything else that might bring air in from the outside which would include HVAC potentially such as fireplace damper, range fan, bathroom vent or clothes dryer vent, turn off range fans and clothes dryers. And it goes onto provide additional information thats not really relevant to the conversation here.
But in short the public is told a shelter which involves a shelter in place. Go in doors. Close off access to outside air and that was communicated subsequently.
Man:
So just so Im clear - this is an important point in my mind.
(AJ Famastock): Yes.
Man:
In practice and during the exercises and you contended an actual event and youre following attachment 7.1, you would evacuate all sections zero to two miles and ten miles downwind and you would shelter in place remaining sections and that message that you just referred to is what would be shared as part of the protective action recommendation and Mr. (Brown) this evacuate section where EPA pads are projected to be exceeded based on dose assessments that you looked at attachment 7.2 and when you were just considering the downwind sector, thats when you decided whether it needed to be shelter in place or evacuation, you know, even though this would say evacuate sections where EPA pads are exceeded and thats how you applied this guidance here in attachment 7.2.
So you expected to evacuate zero to two miles downwind, shelter all other sections - right - shelter in place for all other sections because thats what this
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 37 guidance says. And the shelter in place comes into play there for in terms of any discretionary decision is downwind.
(Kurt):
So yes and let me clarify what I mean by downwind. So the dose assessment would show us which sectors are affected from the ongoing release. It could be more than one. So when we say downwind, were talking about those sectors where the dose assessment has projected dose rates above one (remsedi), by (remsedi). So when I say I would consider sheltering the downwind sectors, Im talking about those sectors that are potentially affected by the offsite release.
Man:
So your point is where it says evacuate sections where EPA pads are exceeded, you would look at shelter in place, right?
(Kurt):
As it pertains to the special circumstances on this slide - yes I would. So...
Man:
Okay and the expectation is that you evacuate zero to two miles - ten miles downwind - and you shelter all the other sections so the discretionary aspect are those sections where the EPA pads are exceeded and you have the option of shelter in place.
(Kurt):
Yes, I do.
Man:
Okay so thats how you applied that.
(Kurt):
Yes and like I mentioned, this attachment really hasnt changed in all my years as a licensed operator. It has not changed.
Man:
And it doesnt sound to me from listening to the discussion that your plan training would reinforce that expectation. It sounds like there was a disconnect there in what your planned training was. Is that right?
(Kurt):
Well Ive been taught that for years so...
Man:
No, Im talking about the change for implementing revision 18. I would offer
- from what I heard - would not be consistent with what you just said was how you would practically apply that direction in that box.
Man:
Yes, we recognize it. We didnt - in the revision process we didnt do a good job in training on the subject of what we implemented. In the interview process we specifically asked them what kind of training did you get on this and it really wasnt very much training on it to make any changes in how they would use the table. So there was no - nothing that would alter how they would use it.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 38 Man:
So its worth mentioning (unintelligible) that the training that had previously been provided on attachment 7.2 which was not as involved and lengthy as what had been provided on the section I spoke of that was removed has not changed. That has not - as Mr. (Brown) pointed out - has not been altered in the last period of time. I dont know that I can quote 17 years the way you did but it has not hit on it.
Man:
Okay. The reason why I am engaging to the degree I am on this is because youve got an inspection team that interacts with your staff, walks away with a certain understanding here. Thats the basis for the apparent violations and the basis for the preliminary significant determination, right and what Im hearing here is how this guidance was intended to be applied, how its always been applied and how it would be applied as a result of revision 18 is that shelter in place is part and parcel of your protective action recommendation process and the implementing revision 18 in accordance with new reg 0654 supplement three didnt change that.
Thats a disconnect from what we obviously preliminarily concluded. Thats why youre challenging that but Im really trying to understand how we were so disconnected here between the inspection teams findings based on interaction with the staff and what your position was communicated based on those interactions and what Im hearing here today.
Now going forward its important that we understand what your position is and then were going to have to make a value judgment quite frankly whether we agree with that, whether we think thats reasonable, etcetera. Okay?
Man:
Yes and - like I said - we agree that the communication process along the way
- we certainly could have improved it. We could have gathered a better understanding of really what the issue was because it really wasnt until late where it was formulated that this is what the issue was. Up to I believe around the February timeframe it was more of an information gathering. We were trying to address questions the best we could. So we realize there are some areas for improvement in our interaction there.
Man:
Yes and because again Ill say the - maybe an example (Mark) was your interaction asking us - and I thought what I was gaining from it was - okay when we say shelter, do we mean shelter in place? In essence whats our definition? At least thats what I thought you were getting and my team answered about four or five different other things before they finally answered your question.
So again Ill take that back with our interactions during the, you know, the inspection. I think that was a lot of, you know, what was going on. We werent thinking to really understand the question well enough and we were
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 39 answering what we thought the question was and then, you know, maybe the inspector was receiving the question or the answers to what he thought he was asking and again they just kind of missed each other or something.
I wish I had a better explanation but again I just saw another exhibition of it when you asked the question on shelter and I, you know, again what the question was and even back to the procedures - I agree when you say evacuate, you know, sections - okay how do we come up with an evaluation on that? But again its here and weve got it consistent from the other emergency directors that we got. Thats how they were trained, you know.
You can go pull that, you know, section 7.2 and youre going to evaluate, you know, so again I wish I had a better explanation.
Man:
I appreciate that and I have to tell you Im struggling with this shelter remaining sections to mean shelter in place here when youre talking about a wind direction that doesnt impact those particular sectors and youre communicating what shelter in place is. And quite frankly I am struggling with is that what you truly intended or did you intend this monitor and prepare because the monitor and prepare makes sense to me.
Sheltering in place - every other unaffected sector here I struggle with and doing that is a dose avoidance protective action recommendation when you already know the areas for which you have projected pad, you know, dose levels that would exceed the pads. Youve already got the zero to two miles.
Youve got the ten miles downwind in every other section. Was your intent to shelter in place?
You know, when you go back and you look at the generic guidance and it talks about monitor and prepare and this is language that youve had in your procedures so Im going to assume every exercise youve conducted, you clearly communicated when you had a general emergency that all other sections other than zero to two miles and ten miles downwind you would shelter in place and that was part of your PAR and we should be able to go back and validate that thats what you recommended during the exercises.
Man:
I do want to point out that the monitor and prepare language actually showed up in the 2011 new reg document so prior to that time it really wasnt - maybe it had a different form but that term monitor and prepare actually showed up in that document and it is something that - like I said - weve considered as far as moving forward and how were going to adopt that in our process.
Man:
Right but the point there is that you always adopted the shelter in place for that, you know, whether 2011 theres specific reference to monitor and
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 40 prepare. What was your behavior and your behavior is what Im hearing is the shelter in place.
Man:
Thats right.
Man:
Independent of this monitor and prepare language introduced in 2011.
Man:
Thats right.
Man:
Which brings me to the curious question as to if youre discussing supplement three and I heard at the beginning of the conference that if we met what supplement three provided to us in guidance, you would be in compliance with regulation. You had thought that everything that was in supplement three but yet the piece on monitor and prepare was not adopted.
So I guess I need to know more about why youre saying now that you did not adopt monitor and prepare and youre saying the shelter in place that you will do for the rest of the remaining EPZ is the same as if it were to be for dose avoidance. On supplement three one of the major differences from supplement three and any previous guidance was to identify that rest of the EPZ to monitor and prepare and that was a major change and was identified on such numerous occasions before it was issued.
You adopted and you say you used everything else out of supplement three but you didnt use that piece. What was the reasoning behind that and why youre continuing to say that your shelter in place for the remainder of the EPZ is the same as if it was for dose avoidance?
Man:
So we were working through the monitor and prepare language and working with the outside response organizations and adding it to - adding it to the programs. When this came up we kind of stopped discussions to understand what the regulatory issue was last August and it is our intent to include the monitor and prepare language with the offsite authorization collaboration to include it. We think its an appropriate tool.
So were working towards it. We recognize we had some terminology differences and we stopped after we were informed of the, you know, issue.
Man:
Youre saying you had not completed all of your changes to your PAR strategies meaning...
Man:
The only one that we didnt...
Man:
With the guidance provided in supplement three through August of last year?
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 41 Man:
The additional language of monitor and prepare into the strategy impacts messaging, public documentation and those kinds of things and we had not done that yet.
Man:
(Unintelligible).
Man:
I wanted to turn a little bit to the training (unintelligible) and to the corrective action document that (AJ) mentioned a couple of minutes ago. We did ask for a training module that underlies essentially at 7.2 with the power procedures that was the one - the version that was changed in June of 2014. And going through there, we looked at it and noticed that nothing was added to that module, that references to shelter had been deleted and then in January of this year we were provided a corrective action report that says that you intended to remove additional references to shelter essentially that you didnt complete in the initial revision.
It kind of - just to be clear - the current training for PAR - if you go through that computer based module - there is no explicit reference to this attachment 7.2 and in particular to the notes associated with it. Is that correct?
Man:
We dont have a copy of the training material right here before us. Thats something we can follow-up on on that material.
Man:
It is important to note all of the training - the CPT (unintelligible).
Man:
It is important to note that the CPT is currently on hold and has been since (unintelligible).
Man:
And with training weve given to you - you have an annual training requirement for your (unintelligible). How have you been fulfilling it if your training modules on hold?
Man:
So that was actually in progress at the time that we made the determination on it and it was near completion so that did go forward and was completed with that - with the current materials - but that was almost complete at the time we noted the discrepancy and generated the condition. Since then that has been on hold.
Man:
I think that it kind of gets to the - it really gets to the intent of whether 7.2 -
task 7.2 would not be used if you intended not to reference it in training. That would make it difficult to understand why you think it would be used if it wasnt being trained on.
Man:
I think Ive heard the acknowledgement that your training was not what you expected here, you know, and if you are going to use 7.2 as part of the
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 42 decision process and thats a tool that you have for your decision makers then it would be appropriate to reference that in your training.
So what Im hearing is from the (unintelligible) is that while theres the recognition that the training module did not capture 7.2, its your view that individuals that have served in that command and control function would have in fact exercised the guidance like you said Mr. (Brown) you know, with the shelter in place considerations. Thats what Ive heard. Is that correct?
Man:
Thats correct.
Man:
And I know we havent gone onto slide 40 but just to make sure here that if theres no release in progress, you still would have sheltered all the remaining sections with the shelter in place even though theres no release, right. Thats the expectation. Thats what you exercised and...
Man:
Thats correct and - excuse me - I will walk through the rest of my procedure presentation if youre ready for that.
Man:
Yes, sure.
Man:
Okay. So the next slide - so heres a case where were looking at initial PARs in a general emergency with no release in progress. We do work through the attachment 7.1 in a similar fashion, go down the general emergency path, evaluate release in progress. The answer to that is no and then we issue the standard PAR - evacuate all sectors zero to two miles, ten miles downwind and shelter remaining sections.
So even though we dont have a release in progress, our dose assessment will show us a downwind sector and thats what we used as a basis for issuing this standard par. Any questions on that? Okay. So Ill move onto a discussion about the updating pars.
Man:
We did just put this in here because there was as reference in the inspection report that with regard to how we handled the plan release. In regard to step 4.4.4 in the last statement it said that it concluded that a discussion intended to assist offsite authorities is not equivalent to a protective action recommendation and we agree with that but thats referencing those steps.
Youll find that later on when we speak to step 4.4.6 that that does provide the protective action recommendation.
Man:
So next slide. So in the case that I was just discussing if were in a general emergency and we have no release in progress and then we decide to either do a planned release or a release develops, I would be using the updated PAR section of the procedure and Ill point to step 4.4.2 which says to determine
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 43 the appropriate offsite PAR by preparing again your dose assessment data to attachment 7.2 and use the guidance in attachment 7.2 to make your decision.
So updating PARs - I would do the same thing. I would get a dose assessment. I would look at attachment 7.2 for any special circumstances and then Id move on in the procedure. The next slide shows where step 4.4.4 is -
if we plan on doing a planned release, I would discuss with the off-sites. So Ive already made my decision on the PAR - the updated PAR at this point.
What Im talking to them about is were going to do a planned release that has a finite duration to protect our primary containment and were going to do that as directed by the emergency operating procedures after the emergency director who is myself has concurred with that action as the control room is wanting to do it.
But as it relates to the off-sites, what we are doing is were giving them advanced notice that were going to update our PAR for this particular scenario of a planned release and that helps them with their planning and you can see the step language. It says to assist them with their protective action implementation.
The next step or when you turn the page in the procedure, I communicate the updated PAR with a new CNF form - classification notification form - in step 4.4.6. So thats how we officially notify the off-sites of that updated par. Any questions on that? Okay, next slide. Ill move onto - okay.
Man:
Again, you know, I see 4.4.4 that talks about discuss the proposed activity with offsite authorities but show me where it is in your procedure again that you would make a PAR because I...
Man:
Okay so the PAR - the PAR is actually made in step 4.4.2. So if I go back to the previous slide, Im making my decision for the updated PAR in step 4.4.2.
Again Im going to be directed to consider special circumstances that might be defined in attachment 7.2.
Man:
Lets step back. Youve got a planned release. This isnt updating a PAR based on new information. You have a planned release. Where in your procedure does it have you recommend a protective action - provide a protective action recommendation associated with a planned release?
Man:
So looking at the title here, it says updated offsite PARs based on projected doses.
Man:
Okay.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 44 Man:
So its assumed that if youre having a planned release, youre going to have a dose to go with that.
Man:
Okay.
Man:
So again we mentioned earlier that its not speaking directly but it is inferred in our existing guidance that is there.
Man:
But so whether we open the valves and do the release ourselves or whether the release occurs, it is a release and so my path from that point is the same. We do a dose assessment, we look at the consequences and we update the par.
And this discussion with the off-sites - step 4.4.4 - is to help them with that PAR implementation. (Paul) did you have a question?
(Paul):
Yes, Im looking at that step. Who supposes you have those to look at? If you go to your dose assessment procedure, you have direction in there on how to estimate the radiological consequences of the planned release but you dont have rad monitor data. The inputs for dose assessment or a release occurring (unintelligible) by accidental reasons.
Youve got either a direct field measurement or you have a radiation monitor number that you would put into dose assessment. That ends up producing dose but do you have direction for doing that (unintelligible) released for so many minutes and so much pressure and so much source term in there so that you actually arrive at a dose assessment for the projected release that you could trust.
Man:
So to answer your question, I think Id have to defer to someone whos a little bit closer to the dose assessment - the nuts and bolts of doing the - entering the data into it. So I dont know if (AJ) if you could answer his question.
(AJ Famastock): I know this is going to come into the category that (Don) mentioned earlier.
We dont have a copy of the dose procedure here with us today so it would be speculative of me to speak to that answer.
Man:
Okay so (Paul) we can owe you that information. I think its a very good question. I apologize I dont have it off the tip of my tongue.
(AJ Famastock): Let me make one other point about it and that is that the (unintelligible) Id say this alters what I said earlier but the software has been ready to run dose projections based upon our understanding and our radiological emergency managers understanding of what those instrument readings are likely to be and given containment readings, they would be able to formulate that reasonably well. But again we dont have a copy of the procedure with us so we cant definitively answer your question.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 45 Man:
If I can, before we go onto - it looks like youre getting into your concluding type of area. Youre talking about lessons learned. Just - well be able to go over slides 33, 34 and 35 related to the control room and exceeding the ten mile EPZ because we kind of skipped over top of that as we went to the implementation procedures just to make sure we cover all of that too because there is some items in there I think we need to hear about.
Man:
So if I might if I can finish my section then well go back and finish (Shawn)s section on the procedure changes because hes going to talk to that point.
Man:
Just so we dont forget about it.
Man:
Thats right. Okay, Ill move us on then to the next slide. Were talking with the off-sites, letting them know about the planned activity. Next slide. Im completing the updated PAR with the - related to the planned release - and then the next slide is a copy of our classification notification form.
So what weve got here - I just wanted to highlight a couple of aspects of this form. One is that very little of the information is automatically populated, okay. So the user - in my case this is filled out by the assistant EOF manager and then presented to me and we may - we have quite a few discussions as we feel it out but Ill highlight two aspects of the form that are not auto populated.
When we select the emergency action level that were in - in this case its an intentional dent of containment - we then select the offsite release yes and put in the time of that offsite release starting. So thats not - thats not a default value so I just wanted to highlight that.
And over in the PAR area for general emergency - when you select the general emergency - this is all blank, okay. All these fields - you have to manually select each one. So Im making decisions on zero to two miles we click the evacuate button. For the affected sectors - sections - excuse me - Im making a decision shelter or evaluate all the way across the board and we just wanted to highlight that as part of our communication with the off-sites but then nothings really taken away from me, okay.
And with regard to the procedure changes, you know, its my professional judgment that the procedure change did not put me in a corner as the emergency director. It didnt really change the way that I evaluate whether I shelter or evacuate.
The - excuse me - right. So the point I was trying to make is that when the condition report was written at our station for this violation, we entered it into
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 46
- we developed a compensatory measure for the emergency directors and emphasized the fundamentals of shelter in place as it pertains to the planned release activity or other rapidly developing activity. And when I read that, I said this doesnt change any guide - I already have this direction. Why do I need a count measure? That was my reaction, okay.
So Im here to tell you today that I can use this procedure to arrive at a shelter or evacuation PAR based on circumstances and it really, you know, definitely there are changes in the procedure but it doesnt change the way I look at it. It doesnt change the way that I perform when it comes down to it.
So thats what I wanted to leave you with as it relates to the procedure changes and how I use them.
(Mark):
Okay, this is (Mark) here. Before we leave this slide, I just want to I guess one more time achieve clarity. When you click the button shelter for anyone of those sections, it means the same thing to the off-sites for making their protective action decisions and that is that it means to go into the house, shut the door, close the windows, turn off the ventilation as was read by (AJ) regardless of whether its a downwind sector or an unaffected sector.
The word shelter on that form gives the same direction to the same recommendation to the outsides which would translate to the same actions for the public whether theyre in an affected downwind zone or an unaffected downwind zone. Is that true?
Man:
You are correct.
Man:
Okay.
Man:
Okay so I think you wanted to go back to...
Man:
Slide 33.
Man:
The procedure changes.
Man:
Before we leave that topic, can I ask one last question? Im interested in, you know, we talked a lot about the test of 7.2 and how it existed a long time prior to June 2014 for use in radiological emergencies. Did you look at whether in actual drills or exercises you have any record of an exercise in which a shelter recommendation (unintelligible) user attachment 7.2 advice, 7.1 and evacuation?
Post 2014 you probably havent run very many exercises so you may not have much exercises there but certainly, you know, given your discussion that that
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 47 attachment hasnt changed in a very long time and its understanding hasnt changed, one would expect some history on it actually being used in practice so did you look at that?
Man:
Yes. Well we did go back and look at that and I think we went back 12 years and to see if we had any scenarios that would have driven a mercy director to make a shelter protective action recommendation and we did not have a scenario that would have driven him to a - driven him to a shelter.
The only one that we did have was during causal action based exercises where they issued a shelter but it was an appropriately issued and critiqued in the (unintelligible).
Man:
In the last 12 years youve not had a general emergency with a release as part of an exercise?
Man:
Weve had a release but not a scenario that drove the emergency director to make a shelter protective action recommendation for the downwind.
Man:
(Unintelligible).
Man:
Yes.
Man:
I thought when you have a release in progress and you had a general emergency, youre evacuating zero to two miles and ten miles downwind and sheltering all the rest.
Man:
Sheltering all the rest. Im talking about down winds. Im sorry - down winds section.
Man:
They have not run an exercise where they (unintelligible).
Man:
Okay.
Man:
So I would also clarify that I know weve had discussions during my role as the emergency director during drills. Ive definitely talked with my team about whether its appropriate for shelter or evacuation and thats why Ive circled back to that comment many times during our presentation today.
Whether we finally concluded that sheltering was more appropriate in that circumstance, I couldnt point to. But I know that thats part of our discussion.
Man:
This is just a follow-on question and I appreciate youre providing your perspective as a person that has acted as the emergency director and readied the facility but youre confident that youve engaged others that would be in
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 48 that position and they would apply the guidance system manner as weve heard from Mr. (Brown)?
Man:
Thats correct. We - like I said - when it was first asserted that our staff would not use that, it raised concerns for me as the reg affairs manager, you know.
Are we not using or can we not use it and through the interview process we determined that they would all use that, even through a tabletop. It demonstrated that they would use that for the unique situation - again like I said - keeping in mind our EPZ is very - most folks are on the extreme - on the outside area but yes, they would still use it for that consideration.
Man:
Alright, thanks.
(Mark):
I guess - this is (Mark) again. Before we leave that topic I guess one of the questions thats still lingering in my mind is hearing the testimony from Mr.
(Brown) for what he would do and what it means to him and then understanding what we see in the training module raises the question is the perspective that Mr. (Brown) has a legacy of better training in the past and are new emergency directors going to continue that perspective because the text in front of us doesnt lead us to logically draw those conclusions?
Man:
Thats a very good question and its something we will look at going forward but I mean all of this raises our awareness that there are people that could step into this, look at it differently and for us to reevaluate, go back and see if theres some improvements we can do in this process but we kind of wanted to see this, you know, play all the way out. Were not - we have currently a number of staff people right now that have gone through the previous training but we agree with you on that point.
Man:
(Unintelligible).
Man:
Yes, I think our youngest emergency director is about two years qualified and then the most - and they all average out to somewhere around five to seven years. Im sorry. I should be specific. Those were the emergency operating facility emergency directors.
Man:
Yes, I think an important point I was asking Mr. (Hare) here because you indicated Mr. - how do I pronounce your last name?
Man:
(Greguar) like jaguar.
Man:
Im sorry. Okay, got it. I wont ask if you own one here but, you know, you made the comment that when you heard from the team that your emergency directors wouldnt follow the guidance, you wanted to know if there was a gap there. Well that was based on a read of the guidance and trying to follow it,
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 49 not based - as I understand it - on interviews with emergency directors regarding, you know, how they would apply that, okay.
Man:
Yes and we understood that and we knew that at that time none of our staff had been interviewed and there was a conclusion that was being reached that -
and it was just from the offices to how they were looking at it so yes, we understand that.
Man:
Okay, yes. Thank you.
Man:
Are we ready to go back to slide 33? Okay, this is a point we wanted to emphasize again with regard to protective action recommendations that are beyond the emergency planning zone. This is a section of the procedure that refers to the updated sections for beyond the EPZ.
Anyhow so in the inspection report on page four it states that we removed the responsibility of the emergency coordinator in the control room to the shift manager to make protective action recommendations for areas outside the plume face.
As well show, we actually didnt change anything in the procedure and its been that way since 1999. As far as the conclusion, we disagree on the conclusion itself. Again I want to emphasize this section relates to updated PARs for beyond the emergency planning zone and when, you know, one thing that weve learned from industry events is that accurate information to federal, state and local agencies is important as the event continues on and that the further you get away from the plants med towers, the more difficult it is to be accurate.
So what were speaking about here is a subsequent period where environmental measurements would permit an accurate assessment. I want to point to the two sections in our emergency plan as called out in the inspection report. Section 2.1 speaks to the responsibilities for the emergency direction and control and how that for protective action recommendations this is normally transferred from the shift manager to the EOF manager or the emergency operating facility manager.
And then I also want to introduce section 5.5.2 which is language is common to actually the previous version of the new reg but we didnt change this and we believe its still consistent with the current version of the new reg that protective actions - these supplemental protective actions beyond those that where youve already evacuated says these protective actions should be based on field monitoring data and dose projection in areas beyond those that have been evacuated.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 50 So when you take section 2.1 and 5.5.2 together, they help support what we have in the procedure and our procedure incorporates both of these provisions and does not allow delegation of classification, notification or PARs to any nonemergency director. Our procedure doesnt allow that and our field teams are deployed as part of our technical support center or emergency operations facility.
And so therefore the protective action recommendations would be based on the field team data that we would get for this beyond the EPZ. Again we want to emphasize that this is consistent with industry practice and that when you get beyond the EPZ, theres a lot more thats going to be required for the - to determine where you should actually make your PAR recommendations.
And in this kind of a scenario if you can imagine that were talking, you know, if its still in the control room, it means to some regard that the emergency response organization hasnt been implemented yet but it must be a rapidly progressing scenario - something pretty severe to be happening where the shift - on shift folks - would need to be handling and managing the event as well as trying to determine what the protective action recommendations are. But anyhow, Ill turn it over to (Shawn) to walk through the procedure.
(Shawn):
So this is revision 17 and 18 of the procedure and nothing changed in this section of the procedure like (Don) said since 1999 and this is aligned with section 5.5.2 of the emergency plan and additionally it was aligned with section 2.9 of the procedure.
The procedure doesnt delegate protective action responsibilities but transfers the responsibility to a qualified emergency director with augmenting staff support. Additionally the use of field team data to formulate protective action recommendation beyond ten miles is in alignment with our emergency plan and aligned with a large majority of the industry.
So its really supported by the EPFAQ 2013 tax 004 essentially not burdening the on shift or control room staff decision makers - minimizing the demand on it so they can stay focused on mitigating the emergency at hand.
Additionally the accuracy of PARs beyond, you know, ten miles for those initial folks - its going to be affected beyond ten miles and you have the potential of actually evacuating people into the plume zone without, you know, real accurate analysis.
In the EOS our dose assessment team would be responding in their approved times and our field teams would be responding in their approved times in
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 51 accordance with our plan and wed use that data to support our protective action recommendations beyond the EPZ.
Man:
And any other questions on that? If not, well move onto...
(Mark):
No, this is (Mark) here. Ive got a question on this. So I think I may have pointed this out earlier but our primary concern here with this text - and I appreciate that youre highlighting that the text was also present in reg 17.
And we may not have caught that but the concern that we have with the text -
regardless of how many years its been present - is that if Im the emergency director by default in the control room because its early in the event and your emergency response facilities have not stood up and are not ready to receive a transfer of the emergency director authority, its possible that a rapidly progressing severe accident could put the control room staff in the position of needing to face protective action recommendations for outside of ten miles.
And if Im your emergency director in the control room, this procedure puts me in a quandary - as we read it - it puts me I a quandary of saying in order to follow the procedure, Ive got to wait until the EOF and the TSC are stood up before PARs can be made and I dont think thats consistent with what the guidance and requirements are.
Man:
Id like to say two things with regard to that. The first is accurate pars. When you get beyond the EPZ, its very difficult for the control room without having the benefit of field teams to be able to give accurate PARs and I think accurate is a piece of the protective action recommendation. You want to continue demand of protective action recommendation.
And the second point is - and I really - I understand the concern. I guess maybe if this moves on, I would ask maybe a consideration for a generic, you know, approach to this because I believe this is a common industry practice and I think it, you know, this may reflect on a generic approach and how you deal with these updating PARs beyond the EPZ and dealing with accuracy and the demands youre putting on the control room in a very short period of time and the concerns for nuclear safety as a matter of fact.
So I guess I would just ask for some consideration - maybe a generic approach
- if you continue to move forward in thinking, you know, want to raise this as a finding for us.
Man:
Well is it your view then that other licensees have the same type of language?
Man:
Yes, very similar.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 52 Man:
Got it.
Man:
Im trying to envision a scenario rapidly progressing where you have a release of such a magnitude here that youve got indications based on dose projection that youre exceeding the pad at ten miles and we need to look at protective action recommendations beyond ten miles. Thats what youre talking about.
Man:
That is - that is the left side of the chart for the severe accidents - those accidents that are so severe, early in the stages and thats how we answered the FAQ where it is - the probability begins to increase as to pads being exceeded beyond ten miles - those types of accident scenario sequences in which the control room would be in the position for determining that PAR for that type of accident in the initial stages and getting the initial dose projection that said it exceeds one rem beyond ten miles.
Thats what were discussing here and it would appear as if what you have in your procedures would permit the control room emergency director to provide that PAR up to ten miles...
Man:
Yes.
Man:
But await the TSC and the EOF even though the dose projection indicates it is exceeded beyond ten miles greater than one rem.
Man:
Yes, keep in mind the med tower that we have is right there at the station. If you get beyond the ten miles and youre not going to find the med towers beyond the EPZ that you would find here. And as (Shawn) had mentioned, there is concerns for are you evacuating the right people. Are you moving them into a plume area when maybe they shouldnt be moving into that area?
So again I would just emphasize the need for accuracy beyond the EPZ as well as reducing the burden on the control room to have to try to go figure it out geopolitically - getting all the information - without having the benefit of a field team to make those accurate pars.
Man:
And what I hear you saying then is it would be appropriate for the shift manager in this case to wait until the TSC or EOF remand is what youre saying.
Man:
Yes.
Man:
And I guess our view when we have to look at this is, you know, are there scenarios where that shift manager may have to make a decision because of the severe accident nature there. I understand accuracy - the information is
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 53 paramount but its got to be balanced with what your dose projections telling you based on, you know, so I understand the point.
You would expect in most scenarios that the TSC would be manned or the EOF to make a more informed assessment.
Man:
We do indicate to the outside response organizations as well that dose pads may be exceeded and the additional notes on the conservation notification reforming - if that was the case - theyre trained to identify that to let the ops center response organizations understand.
Man:
And I assume too you have confidence in your shift manager that if they found themselves in that situation, theyre going to make a recommendation that they thinks appropriate and not say well the TSC isnt manned yet, the EOF isnt manned yet and Im going to wait on that even though the procedure might imply that could, you know, that could potentially be problematic from the way the procedure is written.
I sure would hope that your shift manager as the emergency director is going to do what they think is the right thing to do there, right?
Man:
I would say yes based on again what weve learned from the (unintelligible) you know, how the operators and what they were thinking - their mindsets so yes.
Man:
So if I could add just one clarifying point, I think whats been said is accurate.
I was a shift manager and as emergency director I feel that its my duty to accept the responsibilities as soon as my centers manned. For the control room theyre directed to notify the off-sites that the pads may be exceeded beyond ten miles and thats what they do. But the rest of this procedure - it is hard for them to implement from the control room.
They need the assistance of the teams and the additional data that the teams can develop to be accurate in those pars. So thats really where were trying to say is the balancing act is timeliness and accuracy.
Man:
You were earlier in a severe accident where we see it in progress for a minute and you were just starting to notify the emergency response organization. So what kind of delay worst case are we talking about while were waiting for the hero and the dispatch of environmental survey needed to come in?
Man:
Our approved response time is 90 minutes.
Man:
Thats for staffing the facility?
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 54 Man:
Correct.
Man:
And then how long further after that to get a team out and the team to the northeast where the most population is?
Man:
Id be guessing right now if I gave you that. I can get it for you thought if youd like.
Man:
So I think thats where the procedure leads us to believe that youve removed
- I understand (Dave) when youre saying you feel as if you would do the right thing but the procedure - and thats what we have to base a lot of what were deciding upon and discussions with the staff - the procedure doesnt provide that latitude. The procedure directs the control room emergency director to wait for the TSC and the UF to be activated. So it does not provide that latitude and Im sure thats the way its trained upon and what your exercises have shown.
So I think thats our - that was the underlying concern that if the procedure provided a little bit more latitude with that control room emergency director rather than it being directing them to await the TSC and the UF activation as were discussing here - no 90 minutes - during a severe accident. That would be our issue.
Man:
And we understand that and like I said - knowing that weve had this in place for a number of years and we were concerned - are we unique? Are we an outlier? Are we treating this differently than many other utilities and we come to find out that were in the majority of the way the industry treats this matter.
So its something that we can strengthen in the process and we agree.
Man:
And with that and youve done some background information with it, its something for us to follow-up on Im sure to find out if clarification may be needed in that area.
Man:
I didnt appreciate earlier when I made my rather definitive statement about what I would expect the control room shift manager to do, I didnt appreciate that it was that directive in nature, so.
(Mark):
This is (Mark). Let me just add to the discussion that we - while we appreciate the desire for accuracy and the balance between delay versus accuracy, Ill note that your procedure - the one were talking about right now - 13.2.2 - in section 4.4 it has a note for updating PARs and the note says do not delay recommending offsite protective actions while waiting for field monitoring results to verify accuracy of dose projections and thats consistent with I think the way the agency views the need for early notification as opposed to delay for accuracy.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 55 Man:
Yes, if you actually would go a little bit further down in the procedure there -
4.4.3 - Im sorry - 4.4.2 - bravo. It says if dose projections or survey results indicate a pad may be exceeded beyond the ten miles and refer to section 4.5.
So it actually kicks you out of that section and then you go to the other section which then treats it in a little bit different manner. Okay, yes.
So Ill give it over to (Shawn). I mean - sorry - (Kurt).
(Kurt):
When we looked at the different opinions surrounding this issue and this significant amount of time thats went into it, we ask ourselves what could we have done differently. Since this issue originated in August of 2014 with questions regarding our implementation of the new reg supplement three, we looked for areas we could improve our performance related to implementation of new federal guidance.
The first area Id like to speak to is engagement with the NEI emergency planning working group. This working group provides an opportunity for benchmarking, industry alignment and engagement within certain issues affecting the industry.
For many a years in the past we relied on USA as our representation and voice rather than regularly attending ourselves. Over the last year though weve significantly improved our engagement with this working group with regular attendance. In fact our chief nuclear officer - Mr. (Brad Suwosky) - has recently been selected as the chair for the group and we feel will be significant in the world of EP going forward.
Man:
My former job was a deputy in the Office of Nuclear Security and Response and Ive attended several of those nuclear security - I should say - emergency preparedness working group and I didnt appreciate that your representative for Columbia was USA.
Man:
Utility Services Alliance.
Man:
Utility Services Alliance - I didnt appreciate that. I assumed it was one of your EP managers because I agree thats a very valuable forum for clarification like on this issue we were just talking about. I could see that being a forum where the industry raises that or (unintelligible) consideration.
Man:
Yes, this - like I said - our CEO is now chair. I think hes been to three meetings as chair if not two or three. And over the past year weve had regular attendance there so...
Man:
Okay, thanks. So he took over (Tom Joyce)s spot on that?
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 56 Man:
Thats correct.
Man:
Thank you.
(Kurt):
The next - the next thing Ill speak to is an engagement with (unintelligible) itself. Section two reg guide 1.219 provides guidance on when prior discussion with NRC headquarters is encouraged before making changes to an emergency plan. While the guidance in this case doesnt specifically deal with the types of changes we made, we do feel that this would have been an area that we could have pursued maybe I this case and certainly well look at that in the future if we have some key implementation of guidance involving our emergency plan in the future.
(Don):
Id like to just speak to the last one since this falls under my organization.
While were not in total agreement with many of the items in the report -
especially in those that reference conversations over the last nine months - and the interpretation of our procedure, we recognize that we - Energy Northwest -
had difficulty in really gaining an appreciation or understanding of what was the issue underlying, you know, the NRCs concern.
And we also had difficulty effectively communicating our response or position trying to - as I mentioned earlier - trying to fit the discussion into the regulatory guidance, especially with planned puff releases. But we have been looking at how we can improve that in our - in our area - especially with having a more direct communication. Even if we have to, you know, come down here to try to have more face to face discussions to try to really understand what was going on.
Were taking that back as a need from my area to improve the engagement and understanding of issues, you know, speak before, you know, listen before you speak. Were doing a much better job at that so were working on how we can improve that interaction. We certainly welcome any comments or feedback as to how we can improve that so that we can truly get to the root of the concerns and that we can be - especially in this subject here where, you know, it is to some degree a little bit complex that we can, you know, clearly communicate our positions and our - where were at - and interpretations of our procedures and what not. Alright.
Man:
So I just want to kind of add onto that a little bit now too. So as the manager of the department, you know, its my responsibility to understand what the issues are in getting, you know, get the clarity that I needed, you know, and had some opportunities in there to really understand what the inspector was requesting from Columbia and clarify it. So just add onto what (Don) was saying.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 57 Man:
So in wrapping up our discussion - like I mentioned - we dont believe we have a performance deficiency in that the inspection report stated no longer -
we no longer provided a mechanism to make a shelter and place protective action recommendation and again we pointed to attachment 7.1 and 7.2 as providing that means.
With regard to no longer having a protective action in the event of a planned release - as we mentioned - we would use the flow chart in attachment 7.1 as since the planned release would result in a release in progress. Wed use that flow path to help us consider the recommendations - protective action recommendations - which could include also shelter in place.
Next, the inspection report mentioned that we removed the responsibility. I wont belabor that point. In regards to the next slide - and if Im moving too fast - this is just a wrap up of all of this. But in the next two slides deals with the specific statements in regard to our noncompliance with our emergency plan. Let me just spend a little bit more time on that.
So the first one points to this emergency plan section 2.1 and again if you consider the text in section 5.5.2, youll find that, you know, it does include the need for field monitoring for making that assessment that our field monitoring is part of our augmented organization and that our procedure correctly refers to the protective action recommendation being developed with the assistance of the field teams which would be an augmented function.
With regard to the section 5.5, again wed just like to emphasize here that section 5.5.2 and additional text in section 5.5 helped formulate how you actually develop shelter in place considerations. Section 5.5 states that protective action guidance - 5.5.2 provide that preplanned guidance. Section 5.5.2 points to the federal guidance and again we walked through how we would have used the guidance to develop what we have in place.
Again I would just like to summarize that although, you know, we may have some differences about how we can improve the procedure, how we can communicate more clearly on this matter. We still believe that theres not a performance deficiency involved here.
Man:
Ill offer one comment. I think certainly Ive explained the basis for your conclusion that you need to wait for field information if you will from your, you know, protective measure - your dose assessment measuring teams that go out in the field, right. I think we talked about there are scenarios where your dose projection is such that you may need to consider PARs beyond ten miles.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 58 Youve indicated that your approach is consistent with how the rest of the - or the majority of the industry approaches that.
Man:
Yes.
Man:
And so well look at that but, you know, your comment about which requires field monitoring and augmented function of support conclusions - Im not sure were in full agreement right now with that but...
Man:
We understand.
Man:
But I do think you may want to look at does your emergency director - if it happens to be the shift manager for those rapidly developing scenarios where the dose projection would say the dose is going to be greater than the pad at ten miles. Does he have the latitude to make what he thinks is the right decision there if you find yourself in a case where the TSC is not manned, the EOF is not manned or (unintelligible) forgot to mention, you know, its going to take a while before that field monitoring team - depending on the wind direction - gets you some meaningful data from out in the field. So you need to consider that I think.
Man:
Right. We will take that as an action out of here to follow-up with our shift managers on their decision process.
Okay, in regards to the significance assessment - again this makes it a little bit difficult to speak to in that the statement is that the licensee can no longer make recommendations for the public to shelter in place when appropriate and that limitations could result in delays in making appropriate protective action recommendations as we mentioned before.
We clearly are, you know, believe that we have guidance in place and I understand we are going to go back and talk to our shift managers about the possibility for generating protective action recommendations for beyond the EPZ and well also - as a matter of fact well also engage with the working group to have further dialog on this.
So if you still agree that theres a performance deficiency here, I do want to make, you know, just a few comments with regard to significance. One in using the tool from new reg 654 which encourages site specific development, you know, our protective action scheme is site specific. It was developed in cooperation with our offsite response organizations - the county, the state, Department of Energy.
Weve all agreed to the protective action recommendation scheme that we have currently in the procedure. In consideration of our topography, our very
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 59 low population density, our very short evacuation times, evacuation is the most appropriate PAR to insure that dose is avoided in most cases.
While we understand that our procedure could be viewed and interpreted differently, interviews with our staff, you know, emergency directors conclude that the use of the procedure can in fact help them reach a shelter in place consideration if the conditions warrant it.
Just a few examples we brought up here with regard to other stations. I dont have all the details. Im not trying to state that I know all the facts behind it but I just - a little bit of comparison here. For example in 2015 the region one plant modified their procedures that would in essence recommend evacuation of downwind areas and many more emergency response planning areas than intended. It was determined to have very low safety significance.
And theres another example. Two region four plants - they both had a similar issue or concern that is not the same as Columbia but they failed to follow their federal guidance - EPA guidance - and they introduced automatic extended protective actions for - Im sorry - based on plant conditions and changes in win without considerations for dose.
In contrast just a couple of stations that did receive low to moderate safety significance findings - wide findings. Recently in 2015 our region four plant totally removed their PARs or protective action recommendations for a certain portion of their EPZ. And secondly our region three plant - they had changed their PAR procedure to eliminate decision making process for PARs beyond EPZ.
And again I want to emphasize that Columbia still has protective actions in place for all sections of the emergency planning zone and in most cases evacuation would be the clear choice however for very few cases shelter in place would still be a consideration.
For those very few cases at Columbia - attachment 72 - would have that -
would have us consider shelter in place. So in summary its our position that Columbia continues to meet the emergency plan commitments, that all considerations for shelter in place found in the applicable federal guidance in new reg 654 supplement three 2011 version were addressed and are implemented in our procedure and that supplement three clearly states that compliance with it demonstrate compliance with 5047 bravo ten.
And lastly Id like to just emphasize that in our case public health and safety is appropriately protected with our current protective action scheme.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 60 Man:
Ive just got a clarifying question Mr. (unintelligible) just to make sure I understood your point here in talking about the region one plant for which the assessment very low safety significance in comparison to where there was low to moderate safety significance here - region three plant, the region four plant which is the criteria for a white finding.
Youre saying that if we decide the performance deficiency remains valid that you think the safety significance given these examples is more in keeping with the green finding versus the white. Is that the overarching point?
Man:
Yes. If you continue to believe theres a performance deficiency here, we dont believe in our situation and all the circumstances compare to the plants that had the white finding but are characteristically more associated with those that are in the green area.
Man:
Okay, thank you.
Man:
So with that, Ill turn it over to (Grover).
(Grover):
Okay, thanks. In closing Id like to emphasize this issues been under review since last August and its really taken us some time to understand all the facts associated with it and even, you know, through our discussion today we can still see that, you know, maybe were still gaining some understanding with this.
So because we - as we stated - our procedures were developed based on a good faith effort to implement the federal guidance as was done in collaboration with the offsite response organizations with the best interest of the public safety in mind.
You know, we believe our procedures continue to provide an option for filtering the place should the conditions warrant it to protect the public from the effects of a possible radioactive release. And as (Don) stated we, you know, we do not believe that theres a performance deficiency here but again if it is determined there is one, we do believe that it wouldnt raise to a level greater than green.
Ill also state though that, you know, weve talked about a couple of things here that we know are some strong learnings for us to go back and Ill say reflect on and take some actions on because again I think they were just reiterated here today when we talked about the clarity of our procedures. And I thought one, you know, perfect example is again with the attachment 7.1 that talked about - I think there was evacuation section instead of evaluate, you know.
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 61 When we talked all of our four emergency operating facility, you know, directors, they came to the conclusion oh, it was to evaluate, go to that and again Ill state too when we talked to them, we understand it wasnt a perfectly sterile, you know, test case either because again, you know, we had already started through the discussions and already put out the communications.
So again we understand its not a, you know, it wasnt a perfect case study but also Ill say the interaction - the interface skills - definitely weve got to improve there because again just the simple question asked and trying to get us to answer, you know, is shelter the same thing as shelter in place, you know, the same meaning and weve kind of went through quite a bit of iteration before we finally answered what, you know, the question that was asked.
So again we understand that and well take the appropriate actions to insure that again that we get better in those areas with that. This does conclude our presentation and we do thank you for your time.
Man:
Okay so at this point I think were at the point in our agenda where were going to step out for a separate NRC caucus next door so those members of the NRC who are participating over the phone - I believe youve been informed which bridge line to tie into. Members of the public can just remain on the bridge that theyre on and we will reengage probably in about 15 to 20 minutes.
Now the intent of that caucus is to determine whether we have any additional questions, not to determine the significance but to make sure we have all of our questions answered. Thank you.
Man:
Regulatory commission just letting the folks on the phone know that were ready to resume the conference now that weve completed our separate NRC caucus. So with that in mind, we did develop a follow-up question that we wanted to ask and the context of the question is that we as an inspection team beginning in August - July or August - when we received the proposed change or the change that had been implemented to reg 18, we began to read it, to engage the Columbia staff to try to understand what does the change mean, what was the intent behind the change.
We had dialogue about that and interactions periodically for several months.
So through the January/February timeframe we came away from those discussions with the understanding that the intent that Columbia had for implementing that change and their understanding - your understanding of the basis for the change which was interpretation of supplement three guidance
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 62 based on your evacuation time estimates that the evacuation was a better par given your evacuation time estimates for rapidly progressing events.
Our understanding of your intent for all scenarios was to remove shelter from your procedure and from your training and to stick with evacuation exclusively based on your evacuation timed estimates and your interpretation of sub three.
And we engaged, we asked the questions, we understand that our questioning impacted your process for continuing those changes, how you engaged the off-sites about whether youre going to change your wording from shelter to monitor and prepare and those sorts of questions. What we want to know here is what was your intent with the change that you began implementing with reg 18 and had we not asked any questions, what would your procedures and your training look like today. Thats basically our question.
Man:
So the intent of the procedure change was to implement the supplemental guidance.
Man:
(Unintelligible).
Man:
Oh, sorry. So the intent of the procedure change was to implement the supplementary guidance. That was the intent. And is your second question on the training?
Man:
Right so given that intent, was it your intent to remove guidance to provide sheltering PARs completely from your procedures and your training? We came away from our discussions with you thinking that was your intent.
Man:
That was not the intent of the procedure revision.
Man:
Might I add in a phone call in February these - when we walked through the procedure with these - with the NRC team that we showed them where the procedure still had it in place and so we had communicated that we hadnt taken out that portion of the procedure and that still that was there. So we had the conversation in February so I guess we were hoping from that conversation that the staff could see that as well that we hadnt removed that.
Man:
That doesnt get to the intent though frankly. I mean that just is where you were at the time and were trying to understand here because were clearly at the inspection function here, right - the inspection interface here. The team that was involved with talking to members of your staff were clearly left with the impression that based on your interpretation of new reg 0654 supplement three that it was the stations intent to remove shelter in place as a mechanism for developing a protective action recommendation.
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 63 Were trying to understand was that the intent and then when we engaged and asked questions, you stepped back and revisited that and said okay and you looked at what your training module says. Were just trying to understand what was the intent there.
That doesnt get to whether or not you have that mechanism in place and I think youve explained to us and walked us through how the mechanism still exists and how it would be applied but it certainly was our understanding - at least with the team when they were onsite - that it was clearly the stations intent to remove sheltering in place given your evacuation time estimates and given your interpretation of new reg 0654 supplement three, not as just being applicable to a rapidly developing event but for all scenarios.
Man:
So it was not our intent to remove shelter in place from our procedure.
Man:
Okay. Do we have any other questions? Okay, thanks. With that, Id like to close. Clearly you communicated your basis for concluding that reference to attachment 7.1 and 7.2 of your emergency plan implementing procedures, provide a mechanism to consider shelter in place as a protective action recommendation.
I think its important that you look as an organization do you provide the tools for the staff to be successful. Does training reinforce those expectations and concepts? I think youve heard the team explain why when they looked at this evacuate sections where EPA pads are projected to be exceeded and you have reference to 7.2, one could interpret that where you go to 7.2 to validate the pad numbers if you will, right. And this reference to in shelter remaining sections and, you know, that was meant to mean actually shelter in place and not this monitor and prepare.
You know, I heard what you said the county supervisor would read and thats the bottom line. That is the outcome when you communicate that PAR about sheltering the remaining sections that it would translate to that county supervisor actually communicating the - what shelter in place means and that clearly is in the context of, you know, dose avoidance.
You know, I appreciate your statement there that it was not the intent to remove that and we got some conflicting information based on the inspection function and I appreciate your acknowledging that there were lessons learned regarding the inspection interface. Well we have some learnings on our side as well and I think, you know, (Mark) will step back and look at, you know, are there learnings in terms of how we communicated, what we communicated, when, who it is that we communicated our preliminary
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Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 64 conclusions to - our observations, etcetera - and what was the interaction subsequent to that.
As you said, this issues been under review since last August, you know. We should be able to reach closure on an issue sooner than - I mean were coming up, you know, its June here, you know, like ten months and were still trying to figure out where are we with this issue. What are the apparent violations and what is the safety significance?
So collectively weve got, you know, you spend resources at a regulatory conference. We spend resources. If this is something that could have been resolved sooner, we need to - both of us - look at both sides and see if there are any learnings there.
You know, I heard you - Mr. (Gregori) - mentioned that the procedure could be interpreted differently and based on your interviews you indicated that it can be implemented as intended regarding the, you know, shelter in place for downwind sectors. You dont have any exercises, right where you actually challenged the response team with that. Its based on discussions that you had with some of your emergency directors.
Btu when you look at the specific wording and my understanding of the your -
the importance you place on procedural usage here - you could have a new - if you relatively knew, you know, emergency director here, is he going to have the same understanding as Mr. (Brown) has based on his years of experience and how he applied that guidance and you have to look back and say whats the training intent and are you reinforcing those expectations.
So I think you need to step back and look at that so independent of whether it was your intent or not and I think you have communicated why you think there is a mechanism in place and shelter in place if you will would have been considered as part of your protective action recommendation development.
Well take that information and look at it. Im focusing on that aspect in particular because thats really what drives the potentially greater than green issue here is the protective action recommendation associated with shelter in place.
Regarding the other two aspects there, you know, regarding the control room and the shift manager and what responsibilities does he have and how would he approach it - I think you clearly explained to us your view that it is appropriate for that shift manager to wait until the EOF and TSC is manned. I think thats an issue that should be engaged, you know, should be further dialogued via the emergency planning working group.
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 65 You know, I dont know the validity frankly of your statement that thats how the majority of the industry approaches it. I dont know if that is the case but I think we need to understand that and insure that that shift manager is prepared if there is a rapidly developing event in the dose projections or such that you could be exceeding pads at the ten mile point. You dont have time to get meaningful accurate information from the dose monitoring teams and we need to look at that.
And then I think the last aspect there was do you still provide for protective action recommendations when theres a planned release? I think you explained why you feel the procedures - as theyre currently structured -
would provide for that assessment in a protective action recommendation thats appropriate to the planned release.
So well take that information on board here and well communicate to you via separately our final significance determination and our conclusions regarding the apparent violations.
So, you know, in summary, you know, by your own acknowledgement the procedure could be interpreted differently. I think you need to look at that to make sure you dont create the potential for a procedure to be interpreted differently and you have communicated to us clearly that you feel your staff would have followed that procedural guidance in the manner that was intended. Our staff looked at it and we came to a difference conclusion regarding what was the intent here, you know.
We didnt talk to the emergency directors to get their view how would you interpret this guidance - how would you implement that. We didnt do that back, you know, back in the original few months since we were developing this issue here. So, you know, we didnt have the opportunity to quite frankly test what I would call the as found condition. What is the actual behaviors that would have been exhibited at the time this issue was first communicated versus where are you now after theres been a lot of discussion internally here on your end regarding what the emergency directors would do?
But it gets back to are you providing them with the tools for success. So I want to thank you for the information that you provided us and the time you spent. I think we have a clear understanding of your position and the basis for that and we will take that under consideration there and we will communicate the results of those internal deliberations here via separate correspondence.
And I would offer in a reasonable timeframe here Im sure were going to be able to engage here in the next, you know, couple of weeks here and hopefully reach closure on this soon so we can communicate the results of our internal review. So with that, this concludes our regulatory conference here with
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 66 Energy Northwest and we now will proceed to provide members of the public that were on the phone an opportunity to ask questions so Ill turn it over to (Mark).
(Mark):
Yes, thanks (Mark). Just a couple of required closing statements for the end of the conference. First the apparent violation discussed at this conference is subject to further review and may change prior to any resulting enforcement action and second, statements of view or expressions of opinion by the NRC employees at this conference or the lack thereof are not intended to be - to represent final agency determinations or beliefs at this time.
So if the operator would go ahead and queue up any folks that have questions on the phone, we will be standing by ready to receive those questions in the order you receive them.
Coordinator:
Thank you. If you would like to ask a question, please press star 1 on your touchtone phone, unmute your phone and record your name clearly. If you would like to remove your question, press star 2. Again to ask a question, please press star 1. And well take a few moments for those questions to come through. Please stand by.
The first question comes from (Charles Johnson). Go ahead, sir. Your line is open.
(Charles K Johnson): Thank you. Im (Charles K Johnson) and Im the director of the joint taskforce on nuclear power for Oregon and Washington physicians for social responsibility.
I dont have a question. I merely have a comment which is that Im glad to see that the Nuclear Regulatory Commission and Energy Northwest are discussing this issue of evacuation plans and some apparent failings in the current plan and taking it very seriously.
Obviously what happened in Fukushima in the aftermath of the tsunami -
earthquake and tsunami - and the accident there illustrates how chaotic a situation can become. In an emergency situation you had people evacuated into high radiation zones and the authorities not knowing that for several days
- until several days later - and you had confusion as to who was in charge of various operations of the plant including - I believe - some of the decisions on evacuation.
So Im very pleased to have listened to this hearing. I believe that the NRC is taking this very seriously. I hope that Energy Northwest is as well and trust that they are and thats all I have to say. Thank you very much.
NWX-US NUCLEAR REGULATORY COM (US)
Moderator: Deborah Harrison 06-15-15/11:45 am CT Confirmation # 3938019 Page 67 (Mark Dupae):
Well this is (Mark Dupae). I want to thank you Mr. (Johnson) for your comment. I think it really underscores the importance of having a very specific emergency plan implementing procedure so that clear guidance and tools are provided to the decision makers regarding any protective action recommendation be it shelter in place or evacuations.
So, you know, you dont want to be making decisions on the fly when youre dealing with event response where there can be, you know, a lot going on if you will. So I very much appreciate your comment and thank you.
Coordinator:
As a reminder if you would like to ask a question, please press star 1. We currently have no questions in the queue at this time.
Man:
Why dont we put out one last request and make sure everyone thats on the phone had an opportunity to ask a question. So Ill give just about 30 more seconds. Are there any additional questions from members of the public that are listening to the conference?
Alright, well thank you. This concludes our question and answer session.
Thank you, operator. You can disconnect us from the bridge line. Thank you.
Coordinator:
That concludes todays conference. Thank you for your participation. You may disconnect at this time.
END