Text

License Amendment Request to Revise Emergency Plan
	ML24030A844
Person / Time
Site:	Columbia
Issue date:	01/30/2024
From:	David Brown; Energy Northwest
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	GO2-24-004
	Download: ML24030A844 (1)
	v • d • e

David P. Brown Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 509.377.8385 dpbrown@energy-northwest.com GO2-24-004 10 CFR 50.90 10 CFR 50, Appendix E U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 LICENSE AMENDMENT REQUEST TO REVISE COLUMBIA GENERATING STATION EMERGENCY PLAN

Dear Sir or Madam:

In accordance with 10 CFR 50.90 and 10 CFR 50, Appendix E, Energy Northwest requests an amendment to revise the Emergency Plan for Columbia Generating Station (Columbia).

Federal requirements 10 CFR 50.47(b) and 10 CFR 50, Appendix E, establish emergency planning standards that require: 1.) adequate staffing, 2.) satisfactory performance of key functional areas and critical tasks, and 3.) timely augmentation of the response capability. Energy Northwest is requesting U.S. Nuclear Regulatory Commission (NRC) approval of proposed changes to the Columbia Emergency Plan.

The proposed Columbia Emergency Plan was developed based upon the updated NRC guidance contained in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 2. This includes revisions to align staffing with the functions and major task delineations, specifically the on-shift and minimum augmenting Emergency Response Organization (ERO) positions assigned within these functional areas. Consistent with NUREG-0654, Revision 2, the proposed changes would remove references to non-minimum augmented ERO positions from the Columbia Emergency Plan while retaining appropriate positions in the applicable implementing procedures.

An evaluation of the proposed changes pursuant to 10 CFR 50.54, Conditions of Licenses, Paragraph (q), Emergency Plans, has determined that the proposed changes result in a potential reduction of effectiveness of the Columbia Emergency Plan and therefore, require prior NRC approval.

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January 30, 2024 ENERGY NORTHWEST

GO2-24-004 Page 2 of 2 contains the results of analyses conducted in support of this application, specifically, an evaluation of the proposed changes, which includes a detailed description, technical and regulatory evaluation supporting a no significant hazards consideration, and environmental consideration. Enclosure 2 of this submittal is the full proposed Columbia Emergency Plan. Enclosure 3 contains information related to the review of proposed changes by the affected state and counties.

Approval of the proposed amendment is requested within one year from the date of this letter. Once approved, the amendment shall be implemented no later than December 31, 2025.

There are no regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this amendment request, with enclosures, is being provided to the designated Washington State Official.

If there are any questions or if additional information is needed, please contact Mr. R.

M. Garcia at 509-377-8463.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this ______ day of ___________ 2024.

Respectfully, David P. Brown Site Vice President

Evaluation of Proposed Changes with Attachment : Columbia Generating Station Emergency Plan : Concurrence Letters from Off-site Response Organizations cc:

NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C CD Sonoda - BPA/1399 EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH

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GO2-24-004 Page 1 of 52 EVALUATION OF PROPOSED CHANGES

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GO2-24-004 Page 2 of 52 Table of Contents 1.0

SUMMARY

DESCRIPTION.............................................................................................. 3 2.0 DETAILED DESCRIPTION............................................................................................... 3 2.1 Proposed Changes................................................................................................ 3 2.2 Reason for the Proposed Changes....................................................................... 4 2.3 Current Columbia Emergency Plan Background................................................... 5

3.0 TECHNICAL EVALUATION

.............................................................................................. 5 3.1 Analysis 1 - Emergency Response Organization Key Function Analysis............. 5 3.2 Analysis 2 - Emergency Response Organization Augmentation Analysis.......... 14 3.3 Analysis 3 - Emergency Response Organization Task Analysis........................ 27 3.4 Analysis 4 - Approved to Current Emergency Plan Comparison Analysis.......... 31 3.5 Analysis 5 - Current to Proposed Emergency Plan Comparison Analysis.......... 31 3.6 Analysis 6 - Site-Specific Emergency Preparedness Commitment Analysis...... 32 3.7 Proposed Emergency Plan to NUREG-0654/FEMA-REP-1, Revision 2 Comparison Analysis........................................................................................... 33 3.8 On-Shift Staffing Analysis.................................................................................... 43 3.9 Impact of Proposed Changes on State Emergency Plan.................................... 43

4.0 REGULATORY EVALUATION

........................................................................................ 43 4.1 Applicable Regulatory Requirements/Criteria...................................................... 43 4.2 Precedent............................................................................................................ 44 4.3 No Significant Hazards Consideration Determination Analysis........................... 44 4.4 Conclusions......................................................................................................... 46

5.0 ENVIRONMENTAL CONSIDERATION

.......................................................................... 46

6.0 REFERENCES

................................................................................................................ 46 Attachments - Emergency Response Organization Staffing Plan Comparison Table.............. 49

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GO2-24-004 Page 3 of 52 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Energy Northwest requests an amendment to the license for Columbia Generating Station Unit 2 (Columbia). Specifically, the proposed changes would revise the license to adopt the proposed Emergency Plan. The proposed Emergency Plan establishes an updated licensing basis that complies with current U.S.

Nuclear Regulatory Commission (NRC) regulations in 10 CFR 50.47, Emergency Plans, 10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and the applicable portions of NUREG-0654/FEMA-REP-1, Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants: Final Report.

Energy Northwest has developed the proposed Emergency Plan using the NUREG-0654/FEMA-REP-1, Revision 2 outline and organized it such that each evaluation criterion (or planning element) is explicitly stated, followed by a description of how the Columbia Emergency Plan will address that criterion.

The proposed Emergency Plan provides the basis for response actions that would be implemented in an emergency and the requirements for maintenance and administration of the Columbia Emergency Preparedness Program.

The formal Columbia Emergency Plan consists of the following separately maintained Emergency Preparedness (EP) licensing basis documents, all of which are subject to the requirements of 10 CFR 50.54(q), Conditions of Licenses, Emergency Plans:

x Emergency Plan x

Emergency Action Level Technical Basis x

On-Shift Staffing Analysis x

Evacuation Time Estimate Study x

Protective Action Recommendation Strategy Technical Basis x

Alert and Notification System Design Report. of this submittal contains the proposed Emergency Plan. This License Amendment Request (LAR) is limited to the proposed Emergency Plan, which requires NRC approval. The remaining Emergency Plan licensing basis documents are not affected by the transition of the Columbia Emergency Plan to a NUREG-0654/FEMA-REP-1, Revision 2 basis.

2.0 DETAILED DESCRIPTION 2.1 Proposed Changes The proposed Emergency Plan was developed based upon NRC guidance contained in NUREG-0654/FEMA-REP-1, Revision 2.

The proposed changes to the Emergency Plan align the Emergency Response Organization (ERO) staffing plan with the functions and major task delineations, specifically the on-shift and minimum augmenting ERO positions assigned within these functional areas. Consistent with NUREG-0654/FEMA-REP-1, Revision 2, the proposed changes will also remove reference to non-minimum augmenting ERO positions from the

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GO2-24-004 Page 4 of 52 Emergency Plan while retaining appropriate non-minimum augmenting ERO positions in implementing procedures.

Changes in the proposed Emergency Plan that could be considered a reduction in effectiveness (RIE) from the updated NUREG-0654/FEMA-REP-1, Revision 2 guidance or from the current Columbia Emergency Plan have been identified in this document as deviations. Detailed justification is provided for those deviations in Section 3, Technical Evaluation, to document that the changes to the proposed Emergency Plan do not degrade or lose the capability to perform a function, and the Emergency Plan continues to provide an effective means to protect the health and safety of the public.

x Section 3.1 documents and dispositions the deviations identified in the ERO key function analysis.

x Section 3.2 documents and dispositions the deviations identified in the ERO augmentation analysis.

x Section 3.3 documents and dispositions the deviations identified in the ERO task analysis.

x Section 3.4 documents and dispositions the deviations identified in the approved Emergency Plan to current Emergency Plan comparison analysis.

x Section 3.5 documents and dispositions the deviations identified in the current Emergency Plan to proposed Emergency Plan comparison analysis.

x Section 3.6 documents the results of the site-specific EP commitment analysis.

x Section 3.7 documents and dispositions the non-ERO deviations identified in the proposed Emergency Plan to NUREG-0654/FEMA-REP-1, Revision 2 comparison analysis.

x Section 3.8 documents the results of the ERO on-shift staffing analysis.

x Section 3.9 documents the impact of the proposed changes to Off-site Response Organization (ORO) Emergency Plans.

Additionally, an Emergency Plan to 10 CFR 50 Appendix E comparison analysis was developed. The results of this analysis are documented in Appendix 2 of the proposed Emergency Plan (Enclosure 2 of this submittal).

2.2 Reason for the Proposed Changes The NUREG-0654/FEMA-REP-1, Revision 2 update reflects changes to both NRC and the Federal Emergency Management Agency (FEMA) regulations, guidance, policies, and doctrine, as well as advances in technology and best practices that have occurred since the document was originally issued in November 1980. The update to NUREG-0654/FEMA-REP-1, Revision 2 also incorporates the four supplemental documents and addenda that have been issued in the intervening years and is intended to modernize and consolidate the guidance.

With the incorporation of the guidance in NUREG-0654/FEMA-REP-1, Revision 2, Energy Northwest will have aligned and formatted Columbias Emergency Plan consistent with the new demonstration criteria and level of detail, as well as removed non-essential ERO positions. It is important to note that no requests are being made to change the current NRC-approved ERO on-shift staffing in support of a 90-minute augmentation with the proposed update to the Emergency Plan.

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GO2-24-004 Page 5 of 52 2.3 Current Columbia Emergency Plan Background The Columbia Emergency Plan, Revision 3, was approved in April 1983 and established the initial NRC-approved licensing basis for the Emergency Plan.

In March 1994, Revision 14 to the Emergency Plan reduced the Minimum Shift Staffing in Modes 4 and 5.

In August 2004, Revision 39 to the Emergency Plan obtained NRC approval to extend the ERO augmentation time from 60 minutes to 90 minutes.

In August 2017, Revision 65 to the Emergency Plan obtained NRC approval to implement an Emergency Action Level (EAL) scheme based on guidance in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.

3.0 TECHNICAL EVALUATION

3.1 Analysis 1 - Emergency Response Organization Key Function Analysis The ERO key function analysis identified 10 deviations. The deviation evaluation and justification sections below establish that no degradation or loss of function, task misalignment, or loss of task assignment occur as a result of the proposed changes to the on-shift and augmenting ERO positions.

The identified changes continue to support timely and effective performance of the Major Functional Areas and Major Tasks listed in NUREG-0654/FEMA-REP-1, Revision 2, Table B-1: Emergency Response Organization (ERO) Staffing and Augmentation Plan.

3.1.1 [Deviation 1-1] No Minimum Staff Technical Support Center Emergency Coordinator Position The proposed Emergency Plan does not assign a minimum staff Technical Support Center (TSC) Manager ERO position to the Command and Control function.

This change deviates from current Emergency Plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 guidance for minimum staff ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

This function is important for effective emergency response because adequate command and control enables a licensee to effectively develop priorities for response planning and corrective action(s) and to provide a unified approach to the event response by providing a single individual with overall command and control authority. This function is also consistent with the Incident Command portion of the National Incident Management System (NIMS), dated December 2008. It should be staffed and maintained at all times. This function is typically assigned to the Operations Shift Manager (OSM). The augmentation (relief) of this position is intended to relieve the OSM of EP functions so that the OSM can focus on the event response from an operations perspective. This should occur within 60-minutes of an Alert ECL declaration, or greater, and is typically a position staffed within the TSC.

For a SAE ECL, or greater, these functions (or a subset of them), typically those

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GO2-24-004 Page 6 of 52 associated with protective action recommendations (PARs), should be assigned to an Emergency Director located in the EOF within 60-minutes of the SAE ECL, or greater, being declared.

NUREG-0654/FEMA-REP-1, Revision 2 assigns one minimum staff TSC Emergency Coordinator ERO position at the Alert emergency classification level to the Command and Control function, which is transferred to the Emergency Operating Facility (EOF)

Emergency Director at the Site Area Emergency classification level.

The current Emergency Plan assigns one minimum staff TSC Manager ERO position and one minimum staff EOF Manager ERO position at the Alert emergency classification level to the Command and Control function. The proposed Emergency Plan does not assign a minimum staff Emergency Coordinator ERO position in the TSC to the Command and Control function.

NUREG-0654/FEMA-REP-1, Revision 2 guidance is based on TSC activation at the Alert emergency classification level and EOF activation at the Site Area Emergency classification level.

Both the current and proposed Emergency Plans require simultaneous activation of the TSC and EOF at an Alert emergency classification level. The current Emergency Plan anticipates relief of command and control from the Shift Manager to the EOF Manager directly but allows the TSC Manager to relieve the Shift Manager in the absence of the EOF Manager. The proposed Emergency Plan does not provide for the relief of command and control by the TSC Manager to focus TSC responsibilities on response functions and on-site related event analysis. Simultaneous activation of the TSC and EOF at the Alert emergency classification level has been demonstrated in multiple drills and exercises.

The intent of the NUREG-0654/FEMA-REP-1, Revision 2 staffing guidance for the Command and Control function is satisfied by providing a dedicated minimum staff EOF Manager at the Alert emergency classification level.

This is an alternative to the current Emergency Plan staffing plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance; however, Energy Northwest continues to maintain the capability to perform the Command and Control function.

3.1.2 [Deviation 1-2] No Minimum Staff Technical Support Center Off-site Response Organization Communicator Position The proposed Emergency Plan does not assign a minimum staff TSC ORO Communicator ERO position to the ORO aspect of the Communications function.

This change deviates from current Emergency Plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 guidance for minimum staff ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

This function should consist of 2 staff members to fulfill the communication needs, at a minimum 1 for ORO notification and status updates. Additional communicators may be called upon as needed, and at the discretion of the licensee. These are typically located in the TSC. For an SAE ECL, or greater, at least 1 additional communicator should be staffed in the EOF.

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GO2-24-004 Page 7 of 52 NUREG-0654/FEMA-REP-1, Revision 2 assigns one minimum staff TSC ORO Communicator ERO position at the Alert emergency classification level, and one minimum staff EOF ORO Communicator ERO position at the Site Area Emergency classification level, to the ORO aspect of the Communications function.

The current Emergency Plan assigns the ORO aspect of the Communications function as a collateral duty1 to the minimum staff TSC Operations Manager and the non-minimum staff Assistant EOF Manager ERO positions at the Alert emergency classification level. The proposed Emergency Plan assigns the ORO aspect of the Communications function as a collateral duty to the minimum staff Assistant EOF Manager ERO position at the Alert emergency classification level.

NUREG-0654/FEMA-REP-1, Revision 2 guidance designates the ORO (State/County) communication location as typically in the TSC based on TSC activation at the Alert emergency classification level and EOF activation at the Site Area Emergency classification level.

Both the current and proposed Emergency Plans require simultaneous activation of the TSC and EOF at an Alert emergency classification level. The current Emergency Plan anticipates relief of ORO Communication from the dedicated on-shift State/County Notifier to the non-minimum staff Assistant EOF Manager directly but allows the TSC Operations Manager to relieve the on-shift State/County Notifier if ORO Communications cannot be performed in the EOF. The proposed Emergency Plan transfers the ORO aspect of the Communications function from the dedicated on-shift State/County Notifier to the minimum staff Assistant EOF Manager, making it unnecessary to staff an TSC ORO Communicator ERO position.

The intent of the NUREG-0654/FEMA-REP-1, Revision 2 staffing guidance for the ORO aspect of the Communications function is satisfied by providing both a dedicated on-shift State/County Notifier and a minimum staff Assistant EOF Manager ERO position at the Alert emergency classification level.

This is an alternative to the current Emergency Plan staffing plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance and continues to maintain the capability to perform the ORO aspect of the Communications function.

3.1.3 [Deviation 1-3] No Minimum Staff Technical Support Center Dose Assessor Position The proposed Emergency Plan does not assign a minimum staff TSC Dose Assessor ERO position to the Dose Assessments/Projections function.

This deviates from NUREG-0654/FEMA-REP-1, Revision 2 guidance for minimum staff ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

The augmentation (relief) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC. For an SAE ECL, or greater, this position should be staffed in the EOF as the EOF is primarily intended to coordinate with offsite response officials when developing protective action strategies for the public.

1 The functions of Emergency Classification (Classification Advisor) and Communications (ORO Communicator) are performed by single ERO positions at Columbia. This process of two functions being assigned to a single ERO position is not being altered in the proposed Emergency Plan.

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GO2-24-004 Page 8 of 52 NUREG-0654/FEMA-REP-1, Revision 2 assigns one minimum staff TSC Dose Assessor ERO position to the Dose Assessments/Projections function at the Alert emergency classification level, which is shifted to the EOF at the Site Area Emergency classification level.

The current Emergency Plan assigns two minimum staff ERO positions to the Dose Assessments/Projections function as a collateral duty (one in the TSC and one in the EOF), and one dedicated non-minimum staff ERO position in the EOF. The proposed Emergency Plan does not assign an ERO position in the TSC to the Dose Assessments/Projections function. The proposed Emergency Plan assigns a minimum staff EOF Dose Assessor ERO position to the Dose Assessments/Projections function at the Alert emergency classification level.

NUREG-0654/FEMA-REP-1, Revision 2 guidance designates the Dose Assessments/Projections function location as typically in the TSC based on TSC activation at the Alert emergency classification level and EOF activation at the Site Area Emergency classification level.

Both the current and proposed Emergency Plans require simultaneous activation of the TSC and EOF at an Alert emergency classification level. The current Emergency Plan anticipates the relief of the Dose Assessments/Projections function from the on-shift Dose Assessor to the EOF Radiological Emergency Manager directly but allows the TSC Radiation Protection (RP) Manager to relieve the on-shift Dose Assessor if dose assessment cannot be performed in the EOF. The proposed Emergency Plan transfers the Dose Assessments/Projections function from the on-shift Dose Assessor to the dedicated minimum staff EOF Dose Assessor, making it unnecessary to staff a TSC Dose Assessor ERO position.

Additionally, the minimum staff EOF Radiological Emergency Manager ERO position is qualified to perform dose assessment as a collateral duty, which provides additional resources for the Dose Assessments/Projections function.

The intent of the NUREG-0654/FEMA-REP-1, Revision 2 staffing guidance for the Dose Assessments/Projections function is satisfied by providing a dedicated minimum staff EOF Dose Assessor at the Alert emergency classification level.

This is an alternative to the current Emergency Plan staffing plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance and continues to maintain the capability to perform the Dose Assessments/Projections function.

3.1.4 [Deviation 1-4] On-Shift Chemistry Technician Position Removed The proposed Emergency Plan removes the on-shift Chemistry Technician.

This change deviates from current Emergency Plan requirements for on-shift ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

The Chemistry/Rad Chemistry function listed in Table B-1 to Revision 1 of NUREG-0654/FEMA-REP 1, is no longer needed as the need for immediate reactor coolant sampling has been reduced due to the variety of plant indications of fuel damage available to licensees.

NUREG-0654/FEMA-REP-1, Revision 2 guidance does not assign on-shift Chemistry personnel to the Repair Team Activities function.

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GO2-24-004 Page 9 of 52 The current Emergency Plan assigns one on-shift Chemistry Technician to a Nuclear Chemistry function based on compliance with NUREG-0654/FEMA-REP-1, Revision 1.

The proposed Emergency Plan does not use the Chemistry Technician to perform ERO tasks or functions.

This change aligns the proposed Emergency Plan with the NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance.

3.1.5 [Deviation 1-5] No Minimum Staff On-site Field Monitoring Team Driver Position The proposed Emergency Plan does not assign a minimum staff on-site Field Monitoring Driver ERO position to the Field Monitoring Teams function.

This change deviates from current Emergency Plan requirement and from NUREG-0654/FEMA-REP-1, Revision 2 guidance for minimum ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

An onsite FMT should be staffed, consisting of a monitor and a driver. This onsite FMT is responsible for radiological monitoring of the sites Protected Area.

i.

The monitor should be qualified to assess radiation and contamination levels, but need not be an ANSI qualified RP Technician as long as the FMT is under the direct supervision of senior staff in the TSC or EOF.

iii. The driver should be knowledgeable about the vehicle and the proposed routes to be traversed.

NUREG-0654/FEMA-REP-1, Revision 2 assigns one minimum staff on-site Field Monitoring Team (FMT) Driver ERO position at the Alert emergency classification level to the on-site field monitoring aspect of the Field Monitoring Teams function.

The current Emergency Plan assigns two minimum staff FMT Members at the Alert emergency classification level to the on-site field monitoring aspect of the Field Monitoring Teams function, one of which is a driver. The proposed Emergency Plan does not assign an on-site FMT Driver ERO position. On-site field monitoring activities in the proposed Emergency Plan are performed by the FMT Technician on foot.

The proposed Emergency Plan specifies the on-site aspect of field monitoring as inside the Protected Area fence, and the off-site aspect of field monitoring as outside the Protected Area fence. The Protected Area boundary is relatively small can be traversed on foot or in a utility vehicle. On-site survey activities may be performed without a vehicle since the site Protected Area is limited in size, and plume tracking while driving is not applicable. Thus, there is no site-specific need for an on-site FMT Driver at Columbia.

The intent of the NUREG-0654/FEMA-REP-1, Revision 2 staffing guidance for the on-site field monitoring aspect of the Field Monitoring Teams function is satisfied by providing a dedicated minimum staff on-site FMT Technician at the Alert emergency classification level.

This is an alternative to the current Emergency Plan staffing plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance and continues to maintain the capability to perform the on-site field monitoring aspect of the Field Monitoring Teams function.

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GO2-24-004 Page 10 of 52 3.1.6 [Deviation 1-6] Minimum Staff Technical and Operations Manager Positions Removed The proposed Emergency Plan does not assign a minimum staff Technical Manager ERO position or a minimum staff Operations Manager ERO position for the Engineering function.

This change deviates from current Emergency Plan requirements for minimum staff ERO positions.

Deviation Evaluation and Justification NUREG-0654/FEMA-REP-1, Revision 2 does not assign minimum staff Operations or Technical Manager ERO positions to the Engineering function.

The current Emergency Plan assigns minimum staff Operations Manager and Technical Manager ERO positions at the Alert emergency classification level to the Engineering function. The proposed Emergency Plan retains a non-minimum staff Operations Manager ERO Position and eliminates the Technical Manager ERO position.

The Technical Manager ERO position, having an Engineering background, was responsible for analysis of plant data and the development of plans and procedures in direct support of Operations personnel. This position supervised the analysis of plant safety parameters by the plant technical and Operations staff. There is no site-specific basis that requires the Technical Manager as a minimum staff ERO position. The proposed Emergency Plan retains the minimum staff Core/Thermal Hydraulics Engineer, Electrical/I&C Engineer, and Mechanical Engineer, which meets the requirement of NUREG-0654/FEMA-REP-1, Revision 2 for the Engineering function.

The Operations Manager ERO position, having an Operations background, was responsible for providing oversight of, and direction to, Control Room Operators and for communications between the TSC and Control Room. In addition, the Operations Manager could act as the ORO communicator when the TSC Manager had command and control. Oversight and direction of Control Room operations remains with the Shift Manager, Shift Technical Advisor (STA), and Control Room Supervisor. Interface with the Control Room is performed directly by the TSC Manager when needed, or by the Control Room Information Coordinator (a non-minimum staff position) when full ERO staffing occurs. Command and control is transferred directly from the Shift Manager to the EOF Manager in the proposed Emergency Plan, thus the ORO Notification function is no longer performed in the TSC.

This change aligns the proposed Emergency Plan with the NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance.

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GO2-24-004 Page 11 of 52 3.1.7 [Deviation 1-7] Single Minimum Staff Maintenance Lead Position The proposed Emergency Plan replaces three non-minimum Operations Support Center (OSC) Maintenance Leads (one Electrical, one I&C, and one Mechanical) with one minimum staff Maintenance Lead ERO position for the Supervision of Repair Team Activities function.

This change deviates from current Emergency Plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 guidance for minimum ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

An Electrical Supervisor, a Mechanical Supervisor, an I&C Supervisor should be staffed within 90-minutes of an SAE ECL, or greater, and is typically staffed in the OSC. The OSC Supervisor can effectively manage the craft [personnel] resources for the additional 30-minutes prior to the [supervisory] respond, as demonstrated through drills and exercises, without compromising the staffs reasonable assurance finding in accordance with 10 CFR 50.47(a).

NUREG-0654/FEMA-REP-1, Revision 2 assigns three minimum staff OSC Maintenance supervisors (Mechanical, Electrical and I&C) to the Supervision of Repair Team Activities function.

The current Emergency Plan assigns non-minimum staff Mechanical, Electrical and I&C Lead ERO positions in the OSC. The proposed Emergency Plan assigns a single minimum staff Maintenance Lead ERO position in the OSC.

NUREG-0654/FEMA-REP-1, Revision 2, Table B-1 allows the combining of Electrical and I&C supervisory roles.

The normal station Maintenance organization allows for management of craft personnel under a single supervisor hierarchy. The position of Maintenance Lead is filled by management and supervisory personnel with common qualifications from the Maintenance department who provide direction to multiple craft disciplines. This change aligns the ERO staffing for the Supervision of Repair Team Activities function using normal site practices.

The intent of the NUREG-0654/FEMA-REP-1, Revision 2 staffing guidance for the Supervision of Repair Team Activities function is satisfied by providing a dedicated minimum staff Maintenance Lead at the Alert emergency classification level.

This is an alternative to the current Emergency Plan staffing plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance and continues to maintain the capability to perform the Supervision of Repair Team Activities function.

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GO2-24-004 Page 12 of 52 3.1.8 [Deviation 1-8] Fewer Minimum Staff Craft Personnel The proposed Emergency Plan reduces the number of minimum staff positions assigned to the Repair Team Activities function. Specifically:

x Electricians reduced from two to one x

Radiological Waste (Radwaste) Operator removed x

Chemistry Technician removed.

This change deviates from current Emergency Plan requirements for minimum staff ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

The augmentation (support) of the electrician and mechanic positions should occur within 60-minutes of an Alert ECL, (or greater), and is typically staffed in the OSC.

The augmentation (support) of the I&C position should occur within 90-minutes of an Alert ECL, or greater, and is typically staffed in the OSC. The OSC is the emergency response facility associated with maintenance tasks, as directed by the command and control staff in the TSC.

NUREG-0654/FEMA-REP-1, Revision 2 guidance assigns one minimum staff Electrician at the Alert emergency classification level to the Repair Team Activities function.

NUREG-0654/FEMA-REP-1, Revision 2 guidance does not assign a Radwaste Operator or a Chemistry Technician to the Repair Team Activities function.

The current ERO minimum staffing of OSC craft personnel is based upon NUREG-0654/FEMA-REP-1, Revision 1 staffing guidance. There are no site-specific bases for the number or composition of OSC Maintenance personnel other than those contained in NUREG-0654/FEMA-REP-1, Revision 1. Analysis performed in accordance with NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, validated that the NUREG-0654/REMA-REP-1, Revision 2 staffing levels are sufficient.

The current and proposed Emergency Plan OSC Maintenance staffing does not assign Emergency Plan tasks to Maintenance personnel outside of their job area. Maintenance personnel designated as minimum staff ERO are used as needed for skill-of-craft tasks.

This change aligns the proposed Emergency Plan with the NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance.

3.1.9 [Deviation 1-9] No Minimum Staff Technical Support Center Security Liaison Position The proposed Emergency Plan does not assign a minimum staff Security Liaison ERO position to the Security function.

This deviates from NUREG-0654/FEMA-REP-1, Revision 2 guidance for minimum staff ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

The licensees Security Force is controlled and maintained by the licensees NRC approved physical security plan and does not need to be reflected in the Emergency Plan. However, the establishment of a Security Liaison position in the TSC is advantageous to ensure effective coordination between the security force and the

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GO2-24-004 Page 13 of 52 ERO, particularly for events where offsite resources are necessary as well as for security related events and site personnel accountability.

NUREG-0654/FEMA-REP-1, Revision 2 assigns one minimum staff TSC Security Liaison ERO position at the Alert emergency classification level to the Security function.

Both the current and proposed Emergency Plans assign two on-shift Security positions that coordinate security-related activities with the ERO (Security Communications Center (SCC) Duty Officer and Security Lieutenant/Sergeant) and one non-minimum staff EOF Security Manager ERO position at the Alert emergency classification level to the Security function.

The current Security organization staffing at Columbia is such that the requirements of the Physical Security Plan and the proposed Emergency Plan can be performed simultaneously for any event, and does not require direct relief from a minimum staff ERO position.

The intent of the NUREG-0654/FEMA-REP-1, Revision 2 staffing guidance for the Security function is satisfied by providing sufficient on-shift personnel resources and a dedicated non-minimum staff EOF Security Manager at the Alert emergency classification level.

This is an alternative to the current Emergency Plan staffing plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance and continues to maintain the capability to perform the Security function.

3.1.10 [Deviation 1-10] No Minimum Staff Information Technology Lead Positions The proposed Emergency Plan does not assign the Information Technology function as a collateral duty to minimum staff positions in the TSC and EOF.

This change deviates from current Emergency Plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 guidance for collateral duties assigned to minimum staff ERO positions.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO staffing states that:

If the implementation of the emergency plan is so reliant on this technology that without it, the emergency plan could not be implemented, then an IT Lead should augment (support) the response within 60-minutes of an Alert ECL, or greater, if the TSC/OSC has this technology; and within 60-minutes of an SAE ECL, or greater, if the EOF or JIC/JIS has this technology. If the licensee has capable backup plans for if/when this technology fails, then this function is not necessary. In other words, if the ERO is reliant upon technology such that its loss would prevent the ERO from functioning, then a support position should be part of the ERO to assist in recovery of this technology. If the loss of this technology would lead to the implementation of backup strategies, then this position would not need to be part of the ERO and can be called upon as-needed. Licensees should consider using the listing of critical digital assets, identified in accordance with 10 CFR 73.54, as the basis for determining if this position should be considered part of the EROs augmented response.

NUREG-0654/FEMA-REP-1, Revision 2 assigns a TSC Information Technology (IT)

Lead as a collateral duty to a minimum staff position at the Alert emergency classification level and an EOF IT Lead as a collateral duty to a minimum staff position at the Site Area Emergency classification level.

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GO2-24-004 Page 14 of 52 The current Emergency Plan assigns a dedicated minimum staff EOF Telecommunications (Telecomm) Manager ERO position at the Alert emergency classification level. The proposed Emergency Plan assigns a dedicated non-minimum staff EOF Telecomm Manager ERO position at the Alert emergency classification level.

NUREG-0654/FEMA-REP-1, Revision 2 guidance only requires IT staff ERO positions be provided in the Emergency Plan if Critical Digital Assets (CDA) are identified in the emergency response facilities (ERF) per 10 CFR 73.54, Protection of Digital Computer and Communication Systems and Networks.

Each of the EP-related digital assets were evaluated as part of implementation of the Cyber Security Rule, 10 CFR 73.54(b). Under NEI 13-10, Cyber Security Control Assessments, EP CDAs have been assessed and controls have been put in place to protect the assets against cyber-attack. In conjunction with these controls, alternate administrative, non-digital, or adequately independent means have been put in place for performing each EP function, should the digital component or program fail.

Performance of digital equipment used by EP has shown to be acceptable during drills and exercises, and through routine surveillance checks. Performance of digital assets is monitored through either the Corrective Action Program or the EP drill and exercise critique process. Performance trends are monitored, corrective actions are identified, and compensatory measures are taken as necessary.

With continuous remote coverage of the IT department (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s/day, 7 days/week), and built-in redundancy for communication systems and digital EP assets, Energy Northwest has identified that there is no need to maintain the Information Technology function as a collateral duty for a minimum staff ERO position in the TSC or EOF.

The intent of the NUREG-0654/FEMA-REP-1, Revision 2 staffing guidance for the Information Technology function is satisfied by providing continuous IT department remote coverage and a dedicated non-minimum staff EOF Telecomm Manager at the Alert emergency classification level.

This is an alternative to the current Emergency Plan staffing plan requirements and NUREG-0654/FEMA-REP-1, Revision 2 staffing plan guidance and continues to maintain the capability to perform the Information Technology function.

3.2 Analysis 2 - Emergency Response Organization Augmentation Analysis The ERO augmentation analysis comparison identified 11 deviations. The deviation evaluation and justification sections below establish that a response time of 90 minutes versus 60 minutes does not adversely delay turnover of responsibilities or negatively impact/overburden the ability of the on-shift personnel to perform operational and Emergency Plan actions, functions, or key tasks.

The identified changes continue to support timely and effective performance of the Major Functional Areas and Major Tasks listed in NUREG-0654/FEMA-REP-1, Revision 2, Table B-1.

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GO2-24-004 Page 15 of 52 3.2.1 [Deviation 2-1] Emergency Director at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff EOF Manager ERO position that performs the Command and Control function.

This change deviates from NUREG-0654/FEMA-REP-1, Revision 2 guidance for a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

The augmentation (relief) of this position [Shift Manager] is intended to relieve the OSM of EP functions so that the OSM can focus on the event response from an operations perspective. This should occur within 60-minutes of an Alert ECL declaration, or greater, and is typically a position staffed within the TSC.

Guidance from the NRCs RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, contains considerations for extension of ERO augmentation times. This guidance states that:

Per the guidance in NUREG-0654, Table B-1, an augmented Senior Manager should fulfill the Emergency Operations Facility Director major task at 60 minutes. A licensee requesting a change in staff augmentation requirements that would have the lead manager unavailable to assume command and control within 60 minutes of the initial emergency declaration should show that the on-shift staff includes enough qualified supervision such that one supervisor will assume the emergency director role. The licensee should show that the on-shift supervisor performing the manager actions will not have any additional duties (e.g., each unit under the direction of a unit supervisor, a shift manager providing oversight of the plant response, and a designated emergency director responsible for emergency plan implementation).

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies that the Shift Manager be relieved of the Command and Control function within 60 minutes of the Alert emergency classification level. RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

The proposed Emergency Plan assigns a 90-minute minimum staff EOF Manager ERO position at the Alert emergency classification level to the Command and Control function.

The proposed Emergency Plan continues to maintain the Shift Manager and the STA, or third Senior Reactor Operator (SRO), as dedicated ERO positions on-shift. This staffing arrangement conforms to RIS 2016-10 considerations for extension of ERO augmentation time for the Emergency Director ERO Position.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The On-shift Staffing Analysis based on guidance in NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, identified no task overlap or overburden of the Command and Control function to 90 minutes.

The 90-minute response time of the Emergency Director in the proposed Emergency Plan does not impact the capability or timeliness to perform the Command and Control function.

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GO2-24-004 Page 16 of 52 3.2.2 [Deviation 2-2] Classification Advisor at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff Assistant EOF Manager ERO position that performs the Emergency Classification function.

This change deviates from NUREG-0654/FEMA-REP-1, Revision 2 guidance for a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

The augmentation (relief) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC.

Maintaining the ability to perform this function at all times ensures that ECL decisions, and as applicable, the PAR decisions, are timely and accurate as these decisions have a direct relationship to public health and safety from the consequences of a radiological event. This function shall work in coordination with the OSM, or Emergency Coordinator, depending on which position is in command and control, and as a result should be available on shift and in the TSC.

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies that the on-shift Classification Advisor be relieved of the Emergency Classification function within 60 minutes of the Alert emergency classification level. RIS 2016-10 does not provide guidance on the Emergency Classification function.

The proposed Emergency Plan assigns the 90-minute minimum staff Assistant EOF Manager ERO position at the Alert emergency classification level to the Emergency Classification function. The proposed Emergency Plan upgrades the non-minimum staff Assistant EOF Manager ERO position to a 90-minute minimum staff ERO position to support this new function.

The proposed Emergency Plan continues to maintain the Shift Manager and the STA, or third SRO, as dedicated ERO positions on-shift.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the Emergency Classification function out to 90 minutes.

The 90-minute response time of the Assistant EOF Manager in the proposed Emergency Plan does not impact the capability or timeliness to perform the Emergency Classification function.

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GO2-24-004 Page 17 of 52 3.2.3 [Deviation 2-3] Off-site Response Organization Communicator at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff Assistant EOF Manager ERO position that performs the ORO aspect of the Communications function as a collateral duty.

This change deviates from NUREG-0654/FEMA-REP-1, Revision 2 guidance for a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

The augmentation (relief) of this position should occur within 60-minutes of an Alert ECL, or greater, and is intended to relieve the on-shift staff of this EP function. This function should consist of 2 staff members to fulfill the communication needs, at a minimum 1 for ORO notification and status updates. Additional communicators may be called upon as needed, and at the discretion of the licensee.

RIS 2016-10 considerations for extension of ERO augmentation times states that:

To adequately support the elimination or extension of the two 60-minute responders, the licensee should show that two on-shift positions are identified to fill the 60-minute responders role to Notify licensee, State, local and Federal personnel [and]

maintain communication. The licensee should show that these positions are not assigned other tasks that may prevent the timely performance of their assigned notification or communication functions, as specified in the emergency plan. The licensee should discuss how communication technologies employed by the proposed on-shift staff will support timely, effective, and reliable notifications. Additionally, the communications technologies should be referenced in the emergency plan to ensure that future changes are reviewed using the RG 1.219 change process, as they were used as the basis for the proposed change.

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies that the on-shift communicator be relieved of the ORO aspect of the Communications function within 60 minutes of the Alert emergency classification level. RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

The proposed Emergency Plan assigns the ORO aspect of the Communications function as a collateral duty to the 90-minute minimum staff Assistant EOF Manager ERO position at the Alert emergency classification level.

The proposed Emergency Plan continues to maintain a dedicated on-shift ORO Communicator ERO position. This staffing arrangement conforms to RIS 2016-10 considerations for extension of ERO augmentation time for the ORO Communicator.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the ORO aspect of the Communications function out to 90 minutes.

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GO2-24-004 Page 18 of 52 The 90-minute response time of the Assistant EOF Manager in the proposed Emergency Plan does not impact the capability or timeliness to perform the ORO aspect of the Communications function.

3.2.4 [Deviation 2-4] Emergency Notification System Communicator at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff TSC Plant/NRC Liaison ERO position that performs the Emergency Notification System (ENS) aspect of the Communications function.

This change deviates from NUREG-0654/FEMA-REP-1, Revision 2 guidance for a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

The augmentation (relief) of this position should occur within 60-minutes of an Alert ECL, or greater, and is intended to relieve the on-shift staff of this EP function. This function should consist of 2 staff members to fulfill the communication needs, at a minimum: 1 for the NRC and 1 for ORO notification and status updates. Additional communicators may be called upon as needed, and at the discretion of the licensee.

RIS 2016-10 considerations for extension of ERO augmentation times states that:

To adequately support the elimination or extension of the two 60-minute responders, the licensee should show that two on-shift positions are identified to fill the 60-minute responders role to Notify licensee, State, local and Federal personnel [and]

maintain communication. The licensee should show that these positions are not assigned other tasks that may prevent the timely performance of their assigned notification or communication functions, as specified in the emergency plan. The licensee should discuss how communication technologies employed by the proposed on-shift staff will support timely, effective, and reliable notifications. Additionally, the communications technologies should be referenced in the emergency plan to ensure that future changes are reviewed using the RG 1.219 change process, as they were used as the basis for the proposed change.

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies that the on-shift communicator be relieved of the ENS aspect of the Communications function within 60 minutes of the Alert emergency classification level. RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

The proposed Emergency Plan specifies a 90-minute minimum staff TSC Plant/NRC Liaison ERO position at the Alert emergency classification level to the ENS aspect of the Communications function.

The proposed Emergency Plan continues to maintain a dedicated on-shift ENS Communicator ERO position. This staffing arrangement conforms to RIS 2016-10 considerations for extension of ERO augmentation time for the ENS Communicator.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

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GO2-24-004 Page 19 of 52 The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the ENS aspect of the Communications function out to 90 minutes.

The 90-minute response time of the TSC Plant/NRC Liaison in the proposed Emergency Plan does not impact the capability or timeliness to perform the ENS aspect of the Communications function.

3.2.5 [Deviation 2-5] Technical Support Center Radiation Protection Manager at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff TSC RP Manager ERO position that performs the Supervision of Radiation Protection Staff and Site Radiation Protection function.

This change deviates from the NUREG-0654/FEMA-REP-1, Revision 2 guidance of a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

This function is important for effective emergency response to a radiological event because the management of RP resources, and the assistance this position provides the Emergency Coordinator, is crucial for response to radiological events.

Radiological events can be very significant and constantly evolving, and require significant expertise in radiation and radiological consequences. The evaluation of radiological events, and the development of effective protective action recommendations, requires this expertise to support the Emergency Coordinator in making these decisions. This position is also responsible for the direction and protection of FMTs. The augmentation (relief) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC.

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies that the Shift Manager be relieved the Supervision of Radiation Protection Staff and Site Radiation Protection function within 60 minutes of the Alert emergency classification level. RIS 2016-10 does not provide guidance on the Supervision of Radiation Protection Staff and Site Radiation Protection function.

The proposed Emergency Plan assigns the 90-minute minimum staff TSC RP Manager ERO position to relieve the Shift Manager of the Supervision of Radiation Protection Staff and Site Radiation Protection function.

The proposed Emergency Plan continues to maintain three on-shift Health Physics (HP)

Technicians. While the Shift Manager has overall authority of all on-shift personnel, direct supervision of RP personnel by the Shift Manager is not required since station procedures are in place to direct response actions.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the Supervision of Radiation Protection Staff and Site Radiation Protection function out to 90 minutes.

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GO2-24-004 Page 20 of 52 The 90-minute response time of the TSC RP Manager in the proposed Emergency Plan does not impact the capability or timeliness to perform the Supervision of Radiation Protection Staff and Site Radiation Protection function.

3.2.6 [Deviation 2-6] Dose Assessor at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff Dose Assessor ERO position that performs the Dose Assessments/Projections function.

This change deviates from the NUREG-0654/FEMA-REP-1, Revision 2 guidance of a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

The augmentation (relief) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC. For an SAE ECL, or greater, this position should be staffed in the EOF as the EOF is primarily intended to coordinate with offsite response officials when developing protective action strategies for the public.

Maintaining the ability to perform dose assessments/projections at all times ensures that the consequences of a radiological event, to the public, are effectively mitigated by providing timely dose related information to the Emergency Coordinator (TSC) or Emergency Director (EOF) depending on which position is in command and control.

As a result, this position (function) is expected to be available on shift, in the TSC, and in the EOF depending on the ECL declared.

RIS 2016-10 considerations for extension of ERO augmentation times states that:

Table B-1 of NUREG-0654 assigns the major task of Offsite Dose Assessment as requiring augmented support by one individual within 30 minutes. To adequately support the proposed elimination or extension of the one 30-minute responder, licensees should identify an on-shift position as capable of initially filling the 30-minute responders role of Offsite Dose Assessment. The NRC staff will review whether this position is assigned other tasks that may prevent the timely performance of its assigned off-site dose assessment functions, as specified in the emergency plan. Alternatively, a licensee could demonstrate that installed automated systems or information technologies eliminate the need for an additional on-shift responder. The NRC staff will consider whether the change basis adequately describes supportive features that promote timely, effective, and reliable off-site dose assessment (e.g., an automated computer program), and reliance upon installed and calibrated effluent monitors that would be available under accident conditions.

Additionally, the automated systems or information technologies should be referenced in the emergency plan to ensure that future changes are reviewed using the RG 1.219 change process, as they were used as the basis for the proposed change.

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies that the on-shift Dose Assessor be relieved of the Dose Assessments/Projections function within 60 minutes of the Alert emergency classification level. RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

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GO2-24-004 Page 21 of 52 The proposed Emergency Plan assigns one 90-minute minimum staff EOF Dose Assessor ERO position at the Alert emergency classification level to the Dose Assessments/Projections function.

The proposed Emergency Plan continues to state that SRO license holders (which include Shift Managers, Control Room Supervisors and Incident Advisors) and STAs are available on-shift to perform off-site dose assessment at all times.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the Dose Assessments/Projections function out to 90 minutes.

The 90-minute response time of the EOF Dose Assessor in the proposed Emergency Plan does not impact the capability or timeliness to perform the Dose Assessments/

Projections function.

3.2.7 [Deviation 2-7] Radiation Protection Personnel at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the five minimum staff HP Technicians that perform the Radiation Protection function.

This change deviates from the NUREG-0654/FEMA-REP-1, Revision 2 guidance of a 60-minute response time for three HP Technicians.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

While not all Alert ECLs (or lower) have radiological consequences, licensees should develop their ERO staffing plans for a worst-case scenario from a radiological risk perspective, i.e., an event which results in the immediate (within 60-minutes) loss of 2 or more fission product barriers leading to significant and unknown radiological conditions. The augmentation (support) of this position should occur in two stages:

within 60 minutes of an Alert ECL or greater, 3 additional qualified RP staff should be available, and within 90 minutes of an Alert ECL, or greater, an additional 3 additional qualified RP staff should be available, and both are typically staffed in the OSC.

RIS 2016-10 considerations for extension of ERO augmentation times states that:

Radiation protection personnel perform multiple roles during normal and emergency plant operations. These roles include access control, personnel monitoring, and dosimetry, in addition to HP coverage for repair and corrective actions, search and rescue, first aid, and firefighting during emergency response operations. Per the guidance in Table B-1 of NUREG-0654, there should be two augmented responders at 60 minutes for the major task of Radiation Protection. To adequately support an extension in response timing of the two radiation protection 60-minute responders to 90 minutes, the licensee should show that the on-shift HP staffing includes as a minimum, four HP technicians in total for the site. The extra HP technicians are needed for in-plant protective actions for the other personnel added to the on-shift staffing to compensate for the extension in augmentation time, and to assess any off-site releases of radioactive materials. Additionally, the licensee request should

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GO2-24-004 Page 22 of 52 demonstrate that on-shift HP technicians will be relieved of the need to perform access control, personnel monitoring, and dosimetry-related tasks, thereby freeing these personnel to cover vital response activities (e.g., HP coverage for repair and corrective actions, search and rescue, first aid, and firefighting). NRC staff will consider whether the basis for the justification includes the availability of installed area, process, airborne and effluent radiation monitors, automated systems and information technology solutions, and enhanced work processes. The licensee should include supporting tools and processes that will be considered such as portal monitors, self-alarming dosimeters, and automated access control systems for the RCA that maintain active radiation work permits that are readily available if an emergency is declared (e.g., the system verifies qualifications, dose margins, and access requirement).

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies three 60-minute minimum staff RP Technicians and three 90-minute minimum staff RP Technicians at the Alert emergency classification level. RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

The proposed Emergency Plan assigns five 90-minute minimum staff HP Technicians at the Alert emergency classification level to the Radiation Protection function.

The proposed Emergency Plan continues to maintain three on-shift HP Technicians (one above the requirement of two).

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the Radiation Protection function to 90 minutes.

The 90-minute augmentation of five HP Technicians in the proposed Emergency Plan does not impact the capability or timeliness to perform the Radiation Protection function.

3.2.8 [Deviation 2-8] Field Monitoring at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff Field Monitoring personnel that perform the on-site and off-site field monitoring aspects of the Field Monitoring Teams function.

This change deviates from the NUREG-0654/FEMA-REP-1, Revision 2 guidance of a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

An onsite FMT should be staffed, consisting of a monitor and a driver. This onsite FMT is responsible for radiological monitoring of the sites Protected Area. This team should be staffed within 60-minutes of an Alert ECL, or greater, in order to be ready to respond to a radiological release, or to detect radiation in the field thus confirming and quantifying the release. This supports the applicable PAR decision-makers in developing effective PARs.

i The monitor should be qualified to assess radiation and contamination levels, but need not be an American National Standards Institute (ANSI) qualified RP

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GO2-24-004 Page 23 of 52 Technician as long as the FMT is under the direct supervision of senior staff in the TSC or EOF.

ii. The onsite FMT should not be staffed if the radiological conditions jeopardize the safety of the FMT, typically after a Site Area Emergency has been declared.

iii. The driver should be knowledgeable about the vehicle and the proposed routes to be traversed.

RIS 2016-10 considerations for extension of ERO augmentation times states that:

A licensee could show that other on-shift positions have the training and qualifications needed to perform on-site surveys, and demonstrate that the survey results supplied by these positions would be sufficient to support initial emergency response actions until augmented by additional HP technicians.

Licensees may consider alternative approaches for staffing this functional area by training non-HP personnel to perform these tasks. An example of this alternative approach is provided in the guidance in ANSI/ANS 3.8.5-1992, Criteria for Emergency Radiological Field Monitoring, Sampling, and Analysis. This example provides criteria for emergency radiological field monitoring for training personnel assigned to perform radiological surveys. Training should be provided on the nature of the radiological hazards and associated effects that the survey team members are likely to encounter. Periodic retraining, as well as participation in drills and exercises, should also be specified as part of the training program. Job-specific training, both theoretical and hands-on, should be provided for all personnel assigned to radiological monitoring responsibilities. The training should include all phases of their emergency duties and the equipment that they may be required to operate to perform these duties. Task-qualified personnel assigned to these survey teams should follow the direction of fully qualified HP personnel, as discussed in NUREG/CR-5569, Health Physics Positions [HPPOS] Data Base, Revision 1,12 and HPPOS-238, Health Physics Position on Task Qualification of HP Technicians.

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies one on-site and one off-site FMT respond at 60 minutes of the Alert emergency classification level for the Field Monitoring Teams function. RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

The proposed Emergency Plan assigns one 90-minute minimum staff on-site FMT Technician and one 90-minute minimum staff off-site FMT (technician and driver) at the Alert emergency classification level to the on-site and off-site field monitoring aspects of the Field Monitoring Teams function.

The NRC Safety Evaluation dated August 5, 2004 found this 90-minute response time acceptable based on remote location of the Columbia site (no permanent residents within three miles of the site and a limited permanent resident population within three to five miles), and technological advances implemented since the issuance of NUREG-0654/FEMA-REP-1, Revision 1. The permanent residential population remains at zero within four miles and 83 within five miles of the plant.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the Field Monitoring Teams function to 90 minutes.

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GO2-24-004 Page 24 of 52 The 90-minute augmentation of Field Monitoring personnel in the proposed Emergency Plan does not impact the capability or timeliness to perform the Field Monitoring Teams function.

3.2.9 [Deviation 2-9] Technical Support Center Engineers at 90 Minutes The proposed Emergency Plan specifies a 90-minute response time for the three minimum staff TSC Engineering ERO positions that perform the Engineering and Plant Monitoring function.

This change deviates from the NUREG-0654/FEMA-REP-1, Revision 2 guidance of a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

An engineer to monitor and evaluate changing core/thermal hydraulic issues is important to effective emergency response because monitoring and evaluating core conditions, or thermal hydraulic conditions of the reactor coolant system, can support timely corrective action(s), ECL declarations, and subsequent PARs. Radiological events from a power reactor come from damage to an operating reactor core, or the systems used to cool the core, and engineering expertise in this area can greatly benefit the licensees response. The augmentation (relief) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC An engineer to provide expertise in electrical/instrumentation and control (I&C) systems and equipment supports the evaluation of these systems/equipment and supports the development of repair plans if necessary. The augmentation (support) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC An engineer to provide expertise in mechanical systems and equipment supports the evaluation of these systems/equipment and supports the development of repair plans if necessary. The augmentation (support) of this function should occur within 60-minutes of an Alert ECL, or greater, and is typically staffed in the TSC RIS 2016-10 considerations for extension of ERO augmentation times states that:

Table B-1 of NUREG-0654 assigns the major task of Technical Support to the Shift Technical Advisor on shift to perform core damage assessments and additional support with one individual within 30 minutes. To adequately support an elimination or extension of the one 30-minute technical support responder, the licensee should show that an on-shift position is identified as capable of initially filling the 30-minute responders role of Core/Thermal Hydraulics. Typically, this position will be the shift technical advisor. The licensee should show that this position has the necessary expertise with core/thermal hydraulics, and possesses the ability to offer adequate functional oversight to assess core conditions. The licensee should also show that the augmenting staff with core/thermal hydraulics expertise will be available within an appropriate time frame. NRC staff will review whether the justification identifies procedure and information technology advances since the implementation of NUREG-0654 such as improvements that allow using a symptom-based emergency operating procedure network, and computerized or automated systems for the acquisition and display of parameters used to evaluate core conditions.

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GO2-24-004 Page 25 of 52 NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies one Reactor Engineer, one Mechanical Engineer, and one Electrical/I&C Engineer respond within 60 minutes of the Alert emergency classification level for the Engineering and Plant Monitoring function.

RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

The proposed Emergency Plan assigns one 90-minute minimum staff Core/Thermal Hydraulics Engineer, one 90-minute minimum staff Electrical/I&C Engineer, and one 90-minute minimum staff Mechanical Engineer at the Alert emergency classification level to the Engineering and Plant Monitoring function.

The NRC Safety Evaluation dated August 5, 2004 found this 90-minute response time acceptable based on; (1) the capabilities of various on-shift personnel to recognize core damage indications, (2) technological advances since the implementation of NUREG-0654/FEMA-REP-1, Revision 1, and (3) that the STA is trained to provide engineering and accident assessment expertise to shift management. Energy Northwest continues to maintain a dedicated on-shift STA or third SRO, and continues to use the technological capabilities described in the submittal letters related to the 2004 NRC Safety Evaluation.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the Engineering function to 90 minutes.

The 90-minute augmentation of the three minimum staff TSC Engineering ERO positions in the proposed Emergency Plan does not impact the capability or timeliness to perform the Engineering function.

3.2.10 [Deviation 2-10] Operations Support Center Manager at 90 minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff OSC Manager ERO position that performs the Supervision of Repair Team Activities function.

This change deviates from the NUREG-0654/FEMA-REP-1, Revision 2 guidance of a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

An OSC Supervisor should be staffed within 60-minutes of an Alert ECL, (or greater),

and is typically staffed in the OSC. The OSC Supervisor is considered part of the Emergency Coordinators command and control staff, and should respond within 60-minutes of an Alert ECL, or greater, to ensure that the Emergency Coordinator has access to the resources and expertise of the site staff in order to develop response plans for a wide-spectrum of events.

NUREG-0654/FEMA-REP-1, Revision 2 guidance specifies that an OSC Supervisor respond within 60 minutes of the Alert emergency classification level for the Supervision of Repair Team Activities function. RIS 2016-10 does not provide guidance on the Supervision of Repair Team Activities function.

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GO2-24-004 Page 26 of 52 The proposed Emergency Plan assigns the 90-minute minimum staff OSC Manager ERO to the Supervision of Repair Team Activities function.

The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan. The 90-minute minimum staff response time was approved in the NRC Safety Evaluation dated August 5, 2004, for Columbia Emergency Plan, Revision 39.

The NEI 10-05 based On-shift Staffing Analysis identified no task overlap or overburden of the Supervision of Repair Team Activities function out to 90 minutes.

The 90-minute augmentation of the OSC Manager in the proposed Emergency Plan does not impact the capability or timeliness to perform the Supervision of Repair Team Activities function.

3.2.11 [Deviation 2-11] Operations Support Center Craft at 90 minutes The proposed Emergency Plan specifies a 90-minute response time for the minimum staff OSC Mechanic and Electrician that perform the Repair Team Activities function.

This change deviates from the NUREG-0654/FEMA-REP-1, Revision 2 guidance of a 60-minute response time.

Deviation Evaluation and Justification The NUREG-0654/FEMA-REP-1, Revision 2 technical basis for ERO augmentation guidance states that:

a minimum number of maintenance personnel should respond to an event as part of the ERO, with more personnel available on an as-needed basis depending on the event. The augmentation (support) of the electrician and mechanic positions should occur within 60-minutes of an Alert ECL, (or greater), and is typically staffed in the OSC. The augmentation (support) of the I&C position should occur within 90-minutes of an Alert ECL, or greater, and is typically staffed in the OSC.

RIS 2016-10 considerations for extension of ERO augmentation times states that:

Table B-1 of NUREG-0654 calls for the addition of one Mechanical Maintenance, one Rad Waste Operator, and an added Electrical Maintenance person within 60 minutes. To adequately support an extension of the response time for these responders, the licensee should demonstrate that the responsibilities of these positions can be covered with on-shift staff or earlier responders.

NUREG-0654/FEMA-REP-1, Revision 2 guidance calls for the augmentation of one Mechanic and one Electrician within 60 minutes of the Alert emergency classification level. RIS 2016-10 contains allowance to extend the augmentation time provided additional staffing resources are available on shift.

The proposed Emergency Plan assigns one 90-minute minimum staff Mechanic and one 90-minute minimum staff Electrician at the Alert emergency classification level to the Repair Team Activities function.

The NRC Safety Evaluation dated August 5, 2004 found this 90-minute response time acceptable based on adequate resource availability, the cross-training of on-shift Equipment Operators (EO) in mechanical, electrical, and I&C maintenance activities, and inclusion of all four on-shift EOs to support essential repair and corrective actions within 90 minutes of event classification, prior to staff augmentation.

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GO2-24-004 Page 27 of 52 The Columbia ERFs are staffed and activated within 90 minutes of the Alert emergency classification level. The on-shift ERO staffing is not changed in the proposed Emergency Plan.

The 90-minute augmentation of the Mechanic and Electrician in the proposed Emergency Plan does not impact the capability or timeliness to perform the Repair Team Activities function.

3.3 Analysis 3 - Emergency Response Organization Task Analysis The task analysis found no required task to be unassigned.

The ERO Task Analysis indicates, based on tasks assignments, that the capability to perform Emergency Plan functions will continue to be met without overburdening the ERO positions in the proposed Emergency Plan.

3.3.1 Major Process and Task Re-Assignment Changes The major process and task re-assignments are associated with the following:

1) The Command and Control function, along with all non-delegable responsibilities, are transferred directly from the Shift Manager to the EOF Manager and remain in the EOF throughout a declared emergency.

2) The Joint Information System (JIS) function is provided by the Public Affairs department, with support from other Energy Northwest personnel. JIS functionality is described in more detail in the proposed Emergency Plan, Section G, Public Education and Information.

3.3.2 On-Shift Emergency Response Organization Positions NUREG-0654/FEMA-REP-1, Revision 2 revised the staffing plan to remove on-shift positions not directly associated with key function areas having Emergency Plan response task assignments.

On-shift ERO positions retained in, or added to, the Emergency Plan are shown below.

x Shift Manager.................................................................................................. Retained x

Shift Technical Advisor or 3rd SRO.................................................................. Retained x

State/County Notifier....................................................................................... Retained x

ENS Communicator......................................................................................... Retained x

HP Technician................................................................................................. Retained x

SCC Duty Officer............................................................................................. Retained x

Security Lieutenant.......................................................................................... Retained x

Classification Advisor (collateral duty of the STA or 3rd SRO)......................... Retained x

Shift Dose Assessor (collateral duty of the STA or 3rd SRO).......................... Retained x

Maintenance*.................................................................................................. Retained

Clarified as collateral duty assignment to one of the four shift EOs or filled by an extra EO or dedicated Maintenance individual placed on-shift.

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GO2-24-004 Page 28 of 52 On-shift ERO positions removed from the Emergency Plan are shown below.

x Control Room Supervisor................................................................. Non-ERO Position x

Reactor Operator.............................................................................. Non-ERO Position x

Equipment Operator......................................................................... Non-ERO Position x

Chemistry Technician....................................................................... Non-ERO Position x

Fire Brigade...................................................................................... Non-ERO Position x

First Aid Team.................................................................................. Non-ERO Position 3.3.3 Minimum Staff Emergency Response Organization Positions Minimum staff ERO positions retained in, or added to, the Emergency Plan are as shown.

TSC x

TSC Manager.................................................................................................. Retained x

Plant/NRC Liaison........................................................................................... Retained x

Radiation Protection Manager......................................................................... Retained x

Core/Thermal Hydraulic Engineer................................................................... Retained x

Electrical Engineer.......................................................................................... Retained x

Mechanical Engineer....................................................................................... Retained OSC x

OSC Manager................................................................................................. Retained x

HP Lead.......................................................................................................... Retained x

HP Technician................................................................................................. Retained x

Mechanic......................................................................................................... Retained x

Electrician (from 2 to 1)................................................................................... Retained x

I&C Technician................................................................................................ Retained x

Maintenance Lead............................... Changed from Non-Minimum to Minimum Staff EOF x

EOF Manager.................................................................................................. Retained x

Radiological Emergency Manager.................................................................. Retained x

Field Monitoring Team Coordinator................................................................. Retained x

Off-site Environmental Field Team.................................................................. Retained x

On-site Environmental Field Monitor............................................................... Retained x

Assistant EOF Manager...................... Changed from Non-Minimum to Minimum Staff x

Dose Assessor.................................... Changed from Non-Minimum to Minimum Staff Minimum staff ERO positions removed from the Emergency Plan are shown below.

TSC x

Operations Manager............................ Changed from Minimum to Non-Minimum Staff x

Technical Manager......................................................................... Position Eliminated OSC x

Radwaste Operator........................................................................ Position Eliminated x

Chemistry Technician..................................................................... Position Eliminated

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GO2-24-004 Page 29 of 52 EOF x

Telecommunications Manager............ Changed from Minimum to Non-Minimum Staff x

On-site FMT Driver......................................................................... Position Eliminated Joint Information Center (JIC) x JIC Manager........................................ Changed from Minimum to Non-Minimum Staff 3.3.4 Non-Minimum Staff Emergency Response Organization Positions Tasks assigned to non-minimum staff ERO positions in the current Emergency Plan were reviewed against NUREG-0654/FEMA-REP-1, Revision 2 guidance to ensure tasks for key functional areas are retained and performed by minimum staff ERO positions contained the proposed Emergency Plan.

All non-minimum staff ERO positions have been removed from the Emergency Plan, but several will be retained in the Emergency Plan Implementing Procedures (EPIP). The non-minimum staff ERO positions in the implementing procedures will be notified at the same time as the minimum staff ERO and will respond to their respective ERF at an Alert or higher emergency classification level. However, non-minimum staff ERO positions are not required to be present to activate the facility and do not relieve the on-shift ERO of any EP responsibilities. Non-minimum staff ERO positions have no augmentation time requirement.

All tasks previously assigned to eliminated ERO positions that involve response actions for key functions continue to be performed by the remaining ERO positions in the proposed Emergency Plan.

Additional non-ERO personnel can be called as needed to support ERO response activities. These personnel will perform activities related to their normal jobs (such as engineering, procurement, maintenance planning, administration, etc.) and will be notified to support the ERO as warranted.

Non-minimum staff ERO positions added to, or remaining in, the implementing procedures are shown below.

TSC x

Operations Manager............................ Changed from Minimum to Non-Minimum Staff x

TSC Information Coordinator.......................................................................... Retained x

Plant Administrative Manager......................................................................... Retained x

TSC Manager Secretary.................................................................................. Retained OSC x

Repair Team Coordinator................................................................................ Retained x

Team Tracker (from 2 to 1)............................................................................. Retained EOF x

Telecommunications Manager............ Changed from Minimum to Non-Minimum Staff x

EOF Information Coordinator.......................................................................... Retained x

Site Support Manager..................................................................................... Retained x

Security Manager........................................................................................... Retained x

EOF Manager Secretary................................................................................. Retained x

Manpower Scheduler...................................................................................... Retained x

Public Information Officer (PIO)...................................................................... Retained

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GO2-24-004 Page 30 of 52 x

State/County Technical Liaison....................................................................... Retained x

Energy Northwest County EOC Representative............................................. Retained x

Energy Northwest State EOC Representative................................................ Retained JIC x

JIC Manager........................................ Changed from Minimum to Non-Minimum Staff x

Social Media Coordinator.................................................................................... Added x

Energy Northwest Spokesperson.................................................................... Retained x

Technical Spokesperson................................................................................. Retained x

Assistant JIC Manager - Press Conferences.................................................. Retained x

Assistant JIC Manager - News Release Coordinator..................................... Retained x

Media Coordinator........................................................................................... Retained x

Support Manager............................................................................................. Retained x

Information Manager....................................................................................... Retained x

Phone Team Supervisor (from 2 to 1)............................................................. Retained x

News Release Editor....................................................................................... Retained x

Media Phone Team (from 4 to 3).................................................................... Retained x

Public Phone Team (from 4 to 2).................................................................... Retained x

Distribution Team (from 2 to 1)........................................................................ Retained x

Audio/Visual.................................................................................................... Retained x

JIC Secretary................................................................................................... Retained Non-minimum staff ERO positions removed from the Emergency Plan and not retained in the implementing procedures are shown below.

TSC x

Chemistry/Effluent Manager x

Maintenance Manager x

Computer Engineer x

Administrative Support Staff EOF x

Engineering Manager x

Radiation Detection Systems Engineer x

Field Team Dispatcher x

Plant Display and Information System (PDIS) Analyst x

Administrative Support Staff x

PIO Technical Support x

Industrial Development Authority JIC x

Health Physics Spokesperson x

Distribution Team Supervisor x

Receptionist

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GO2-24-004 Page 31 of 52 3.4 Analysis 4 - Approved to Current Emergency Plan Comparison Analysis This analysis identifies the differences between the approved Emergency Plan and the current Emergency Plan (Revision 68). The approved Emergency Plan consists of the following documents:

x Columbia Emergency Plan, Revision 3, dated April 1983, which established the initial NRC approved licensing basis for the Emergency Plan.

x Columbia Emergency Plan, Revision 14, dated March 1994, which reduced the Minimum Shift Staffing in Modes 4 and 5.

x Columbia Emergency Plan, Revision 39, dated November 2004, which extended the ERO augmentation time goal from 60 minutes to 90 minutes.

x Columbia Emergency Plan, Revision 65, dated September 2017, which implemented an EAL scheme based on NEI 99-01, Revision 6.

Differences between the content of those NRC-approved Emergency Plans and the current Emergency Plan were evaluated to determine whether any reductions in effectiveness were introduced by changes made to what was originally approved by the NRC. The results of the comparison between the approved Emergency Plan and the current Emergency Plan revealed no reduction in effectiveness.

3.5 Analysis 5 - Current to Proposed Emergency Plan Comparison Analysis This analysis compares the current Emergency Plan to the proposed Emergency Plan.

The results of the comparison between the current Emergency Plan and the proposed Emergency Plan revealed the following deviations that could be considered potential reductions in effectiveness.

This comparison establishes that no degradation or loss of function would occur as a result of any changes in the proposed Emergency Plan. The changes identified, although differing from the commitments of the current Emergency Plan, continue to support timely and effective implementation of the Columbia Emergency Plan.

3.5.1 [Deviation RIE 5-1] Emergency Response Organization Staffing Changes Deviation Evaluation and Justification See Section 3.1 of this enclosure for ERO position deviation evaluation and justification documentation.

Current Emergency Plan Proposed Emergency Plan Refer to Section 2.3 and Table 2-1: Energy Northwest Emergency Response Organization Minimum Staffing Requirements Refer to Section B and Table B-1: On-Shift and Augmenting ERO Staffing Plan

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GO2-24-004 Page 32 of 52 3.5.2 [Deviation RIE 5-2] Biennial Call-In Drills Current Emergency Plan Proposed Emergency Plan 6.7.3 Notification Systems

d. Automatic Dialer

1) Perform pager activation test/notification drill - quarterly.

N.4.i Off-Hours Call-In Drills Off-hours call-in drills are conducted quarterly, such that each ERO members normally expected response time is assessed at least biennially based on call-in drill responses or an alternate means for determining response time.

Some drills are unannounced.

Energy Northwest will conduct an off-hours unannounced ERO call-in drill biennially to validate each ERO members response time.

The off-hours unannounced ERO call-in drill will require collection of the estimated response times to the applicable facility.

Completion of an Element N.4.h off-hours unannounced ERO report-in drill satisfies the requirements of the off-hours unannounced ERO call-in drill in this element.

Deviation Evaluation and Justification The current Columbia Emergency Plan requires quarterly ERO notification drills.

NUREG-0654/FEMA-REP-1, Revision 2, Element N.4.h requires that off-hours call-in drills be conducted at least quarterly, such that each ERO members response time is validated at least biennially (with some drills being unannounced).

The proposed Emergency Plan specifies that off-hours call-in drills be performed biennially.

Notification of the ERO at Columbia is an all-call process for the minimum staffing positions, which for call-in drills will collect response time estimates from those positions required to activate the ERFs. The all-call nature of response for the minimum staffing positions ensures that each required position is assessed at least biennially, as all ERO members filling minimum staffing positions are required to respond to notifications.

Successful activation of the ERFs is based on the shortest response time of all qualified responders for each minimum staffing position, not a specific ERO members response time.

More frequent testing of individual ERO member response times is not necessary since it has no direct bearing on successful ERF activation. Removing the quarterly test of a portion of the ERO response and retaining the biennial test for the minimum staffing ERO meets the intent of the NUREG-0654/FEMA-REP-1, Revision 2 element.

3.6 Analysis 6 - Site-Specific Emergency Preparedness Commitment Analysis This analysis identifies the Columbia site-specific Emergency Preparedness commitments made to the NRC and determines whether they continue to be met in the proposed Emergency Plan.

The results of the analysis of the NRC commitments documented in the Columbia Commitment Tracking Log revealed two EP related site-specific NRC commitments, which are listed and described below, and are referenced in Appendix 2 of the proposed Emergency Plan.

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GO2-24-004 Page 33 of 52 Site-Specific EP Commitment Emergency Plan

1. Letter from Energy Northwest to the NRC, License Amendment Request to Eliminate Requirements for Post Accident Sampling System (PASS), dated October 22, 2002: Columbia Generating Station will maintain the capability for classifying fuel damage events at the Alert Level threshold. This capability may utilize the normal sampling system and/or correlations of radiation readings to radioisotope concentrations in the reactor coolant. (ML023050386)

This commitment is met through Columbias EAL scheme, which is based on guidance in NEI 99-01. The EAL scheme includes fuel clad fission product barrier threshold indications based on fuel damage at the Alert emergency classification level. (ML17188A230)

D.1.a

2. Letter from Energy Northwest to the NRC, License Amendment Request to Eliminate Requirements for Post Accident Sampling System (PASS), dated October 22, 2002: Columbia Generating Station will maintain I-131 site survey detection capability, including the ability to assess radioactive iodines released to offsite environs, by using effluent monitoring systems or portable sampling equipment.

(ML023050386)

This commitment is met directly in Elements I.1.a and I.7 of NUREG-0654/FEMA-REP-1, Revision 2.

I.1.a I.7 3.7 Proposed Emergency Plan to NUREG-0654/FEMA-REP-1, Revision 2 Comparison Analysis Each element of NUREG-0654/FEMA-REP-1, Revision 2 is clearly stated in the proposed Emergency Plan. The proposed plan/annex deviates from the following NUREG-0654/FEMA-REP-1, Revision 2 elements:

3.7.1 [Deviation 7-1] Alteration of Minimum Staff Emergency Response Organization Positions and Augmentation Time Proposed Emergency Plan NUREG-0654/FEMA-REP-1, Revision 2 Refer to Section B and Table B-1: On-Shift and Augmenting ERO Staffing Plan Refer to Section B and Table B-1: On-Shift and Augmenting ERO Staffing Plan Deviation Evaluation and Justification See Sections 3.1 and 3.2 of this enclosure for ERO position and augmentation time deviation evaluation and justification documentation.

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GO2-24-004 Page 34 of 52 3.7.2 [Deviation 7-2] Reference and Scope Change for Mitigation of Beyond-Design-Basis Events Exercises Proposed Emergency Plan NUREG-0654/FEMA-REP-1, Revision 2 Energy Northwest will conduct at least one scenario requiring demonstration of the ability to transition between procedures and select the strategy(ies) for preventing or mitigating fuel damage and limiting radiological releases, within an eight-year cycle.

The mitigation of beyond-design-basis events (MBDBE) exercise scenario will be based on one of the site specific strategies used to mitigate Spent Fuel Pool damage scenarios or one of the 10 strategies for boiling water reactors (BWR) used to mitigate reactor accidents and maintain containment integrity.

The MBDBE exercise may be conducted separately from the main exercise timeline and sequence of events. This includes the (simulated) deployment and use of equipment associated with these strategies. At a minimum, TSC and OSC ERO staff will participate in this portion of the exercise.

Participation of Control Room, EOF, JIC ERO, and off-site officials may be simulated.

Methods to accomplish this demonstration are dependent upon the nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies. These methods involve a demonstration of the transition from a controlling abnormal or emergency procedure into the Extensive Damage Mitigation Guidelines (EDMG), FLEX Support Guidelines (FSG), or Severe Accident Management Guidelines (SAMG), and conducting any of the following:

x A demonstration of the use of EDMGs.

x A demonstration of the use of FSGs.

x A demonstration of the use of SAMGs.

N.3.e 10 CFR 50 54(hh)(2) Strategies Demonstration of the use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.54(hh)(2).

Deviation Evaluation and Justification NUREG-0654/FEMA-REP-1, Revision 2 Element N.3.e calls for the demonstration of the use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.54(hh)(2). 10 CFR 50.54(hh)(2) has been replaced by 10 CFR 50.155(b)(2);

language of the two regulations is shown below.

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GO2-24-004 Page 35 of 52 10 CFR 50.54(hh)(2) (74 FR 13925) 10 CFR 50.155(b)(2) (84 FR 39684)

Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire, to include strategies in the following areas:

(i) Fire fighting; (ii) Operations to mitigate fuel damage; and (iii) Actions to minimize radiological release.

Extensive damage mitigation guidelines Strategies and guidelines to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant impacted by the event, due to explosions or fire, to include strategies and guidelines in the following areas:

(i) Fire fighting; (ii) Operations to mitigate fuel damage; and (iii) Actions to minimize radiological release.

Scope of Strategies Used in an Emergency Plan Related MBDBE Exercise The Federal Register content (74 FR 13925) for implementation of 10 CFR 50.54(hh)(2) provided the following discussion:

Section 50.54(hh)(2) requires licensees to develop guidance and strategies for addressing the loss of large areas of the plant due to explosions or fires from a beyond-design basis event through the use of readily available resources and by identifying potential practicable areas for the use of beyond-readily-available resources. These strategies are to address a licensee's responses to events that are beyond the design basis of the facility. The requirements in the final rule are based on similar requirements originally found in the ICM order of 2002. Ultimately, these mitigative strategies were further developed and refined through extensive interactions with licensees and industry. The NRC recognizes that these mitigative strategies are beneficial for the mitigation of all beyond-design basis events that result in the loss of large areas of the plant due to explosions or fires. Current reactor licensees comply with these requirements through the use of the following 14 strategies that have been required through an operating license condition. These VWUDWHJLHVIDOOLQWRWKHWKUHHJHQHUDODUHDVLGHQWLILHGE\\KKLLLDQG

(iii). The fire-ILJKWLQJUHVSRQVHVWUDWHJ\\UHIOHFWHGLQKKLHQFRPSDVVHV

the following elements:

1. Pre-defined coordinated fire response strategy and guidance.

2. Assessment of mutual aid fire fighting assets.

3. Designated staging areas for equipment and materials.

4. Command and control.

5. Training of response personnel.

The operations to mitigate fuel damage SURYLVLRQLQKKLLLQFOXGHV

consideration of the following:

1. Protection and use of personnel assets.

2. Communications.

3. Minimizing fire spread.

4. Procedures for implementing integrated fire response strategy.

5. Identification of readily-available, pre-staged equipment.

6. Training on integrated fire response strategy.

7. Spent fuel pool mitigation measures.

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GO2-24-004 Page 36 of 52 7KHDFWLRQVWRPLQLPL]HUDGLRORJLFDOUHOHDVHSURYLVLRQLQKKLLLLQFOXGHV

consideration of the following:

1. Water spray scrubbing.

2. Dose to onsite responders.

The Commission considered specifically including these 14 strategies in

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performance-EDVHGODQJXDJHLQKKZDVDEHWWHUDSSURDFKWR account for future reactor facility designs that may contain features that preclude the need for some of these strategies. New reactor licensees are required to employ the same strategies as current reactor licensees to address core cooling, spent fuel pool cooling, and containment integrity. The mitigative strategies employed by new reactors as required by this rule would also need to account for, as appropriate, the specific features of the plant design, or any design changes made as a result of an aircraft assessment that would be performed in accordance with the proposed Aircraft Impact Assessment rule (72 FR 56287; October 3, 2007).

As shown above, the actual number/list of strategies was not included in the body of the 10 CFR 50.54(hh)(2) regulation.

Subsequent regulatory guidance clarified the list of EDMG response strategies, and the NRC endorsement of NEI 06-12, B.5.b Phase 2 & 3 Submittal Guideline, specifically provided 10 EDMG strategies for BWRs, which have been tied to 10 CFR 50 Appendix E.IV.F.2.j.(iii)(4):

Manual operation of Reactor Core Isolation Cooling or isolation of the Condenser Direct current power supplies to allow depressurization of the Reactor Pressure Vessel and injection with a portable pump Utilization of the Feedwater and Condensate Systems Makeup to the Hotwell Makeup to the Condensate Storage Tanks Maximization of the Control Rod Drive System Procedure to isolate the Reactor Water Clean Up System Manually open Containment vent lines Inject water into the Drywell Portable sprays.

In this regard, NUREG-0654/FEMA-REP-1, Revision 2 guidance on the demonstration of the use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(2)] are shown below.

These exercises should address development and maintenance of the following skills associated with the 10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(2)] strategies:

Use of the strategies to mitigate spent fuel pool damage scenarios. All applicable strategies, such as makeup, spray, and leakage control, should be addressed, but not every variation of a given strategy needs to be addressed; and Use of the strategies to mitigate reactor accidents and maintain containment.

Each of the 10 strategies for BWRs or 7 strategies for PWRs should be addressed based on the type of reactor, but not every variation of a given strategy needs to be addressed.

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GO2-24-004 Page 37 of 52 Thus, the scope of strategies applicable to an Emergency Plan MBDBE exercise in the proposed Emergency Plan include the site-specific strategies used to mitigate Spent Fuel Pool damage scenarios and the 10 strategies for BWRs used to mitigate reactor accidents and maintain containment integrity.

Strategy Frequency Used in an Emergency Plan Related MBDBE Exercise 10 CFR 50 Appendix E.IV.F.2.j.(iii), states that licensees shall vary the content of scenarios during exercises. MBDBE exercises are one of five types of exercise scenarios listed in 10 CFR 50 Appendix E, each of which have multiple variations.

Demonstration of all or multiple variations for each type of exercise scenario is not the intent of the regulation, and performance of all the possible exercise variations/strategies is not possible in the four NRC evaluated biennial exercises conducted within the cycle.

As it is, the current list of exercise scenario types must already be combined in order to be demonstrated during a biennial NRC evaluated exercise.

Thus, only one MBDBE strategy needs to be performed in a biennial NRC evaluated exercise within the cycle. Similar to the scenario variations for the other types for exercises, MBDBE strategies are expected to be varied between exercise evaluations.

An exercise with multiple strategies or more than one MBDBE based exercise within the cycle is not required by the proposed Emergency Plan.

Extent of Play Used in an Emergency Plan Related MBDBE Exercise The relocation of 10 CFR 50.54(hh)(2) content to 10 CFR 50.155(b)(2) involved only minor wording changes. However, included in the movement of the regulation was the specific intent to not regulatorily require drills or exercises, as provided by the following discussion in the Federal Register (84 FR 39684):

The NRC noted that the conduct of drills or exercises was not included as a requirement in the Mitigation Strategies Order, instead being an element of an acceptable approach to meeting the order's requirement for training. Drills are addressed in the regulatory guidance for the Mitigation Strategies Order contained in section 11.6.5 of NEI 12-06, as endorsed by JLD-ISG-2012-01 and carried forward to the regulatory guidance for the final rule. NEI 12-06, Revisions 0 and 2 contained guidance on the content and periodicity of these drills, specifying the same 8-year period as was proposed for this rule. NEI 12-06, Revision 4, which is endorsed by the final version of Regulatory Guide 1.226, incorporates by reference further guidance on the performance of drills contained in the industry document NEI 13-06, Revision 1, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, which also specifies the 8-year period that was proposed for drill performance for this rule.

The NRC concludes that the requirements imposed by the Mitigation Strategies Order were sufficient to provide reasonable assurance of adequate protection and no new information was developed with regard to drills or exercises that would modify this conclusion. The NRC similarly concludes that imposing a requirement for drills and exercises would not provide a substantial increase in the overall protection of public health and safety. Therefore, the imposition of a requirement for drills or exercises would not meet the provisions of the Backfit Rule. The requirement for drills and exercises has been removed from the final rule.

In addition, the NRC did not revise the MBDBE drill frequency because it is specified in the regulatory guidance for the final rule in response to these comments. The NRC concluded that the 8-year periodicity strikes the correct balance in terms of providing an appropriate level of regulatory assurance, and, by aligning with the current emergency preparedness exercise requirements, it provides licensees with flexibility

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GO2-24-004 Page 38 of 52 should they choose to implement the drills in conjunction with emergency preparedness drills or exercises.

However, 10 CFR 50 Appendix E does require licensees to provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to respond to a scenario under § 50.155(b)(2) once in each eight calendar year cycle in an exercise.

In this regard, NUREG-0654/FEMA-REP-1, Revision 2 guidance on the demonstration of the use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(2)] are shown below.

The portion of a biennial exercise that involves demonstration of strategies associated with 10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(2)] may be conducted separately from the main exercise timeline and sequence of events. Thus, the initiating event(s) for entry into site-specific guidelines or procedures associated with 10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(2)] may differ from the initiating event(s) of the main exercise scenario and could involve an initiating event other than hostile action, such as a fire, flood, or explosion affecting large areas of the site, or station blackout. At a minimum, TSC and OSC staff would need to participate in this portion of the exercise. Participation of CR personnel, EOF staff, JIC staff, and offsite officials may be simulated consistent with the purpose of this portion of the exercise to maintain key ERO skills for familiarity with guidelines, procedures, and strategies associated with 10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(2)]. This includes the (simulated) deployment and use of equipment associated with these strategies and intended to maintain or restore core cooling, containment, and/or spent fuel pool cooling. The portion of the exercise scenario addressing demonstration of 10 CFR 50.54(hh)(2) [10 CFR 50.155(b)(2)] related strategies should be included in the licensees submittal of the biennial exercise scenario for NRC review. Exercises may also include the use of the NRC-endorsed mitigation strategies described in NEI 12-06, Revision 0, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide.

NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Events and Severe Accidents, endorsed by the NRC and included in the Federal Register notice for implementation of 10 CFR 50.155(b)(2), provides additional information regarding the extent of play of MBDBE drills:

5.3.1 Industry Performance Standards for BDB Event Response Drills Each licensee should demonstrate the capability for effective integrated use of their accident mitigation and management procedure and guideline sets. In particular, the ability to transition between procedure and guideline sets, and select the best strategy for preventing or mitigating fuel damage and limiting radiological releases, is demonstrated. Complementary methods will be necessary to accomplish this demonstration since the procedures and guidelines implemented for a given scenario are dependent upon the nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies. The use of complementary methods will also promote more effective use of resources (e.g., facilitates targeted drill objectives, avoids excessive drill down time and durations, etc.), and minimize potential safety challenges to personnel and equipment. These methods are discussed below and involve conducting:

A drill that demonstrates the integrated use of FLEX strategies under the control of an Abnormal Operating Procedure (AOP) or Emergency Operating Procedure (EOP), as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.4.

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GO2-24-004 Page 39 of 52 A drill that demonstrates the transition from a controlling AOP, EOP or Extensive Damage Mitigation Guidelines (EDMG) into Severe Accident Management Guidelines (SAMGs), and the selection of appropriate severe accident management strategies. The integrated use of FLEX strategies may occur if directed by the controlling SAMG and as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.5.

A drill that demonstrates the use of EDMG strategies. The integrated use of AOPs and EOPs, and FLEX strategies, may occur if directed by the controlling EDMG as appropriate to the postulated scenario. Specific considerations for this drill are discussed in section 5.3.6.

Thus, the extent of play applicable to an Emergency Plan MBDBE exercise in the proposed Emergency Plan specifies that only TSC and OSC ERO personnel are required staffing (although other ERFs may be included), and demonstration involves:

1. the transition from emergency operating procedures into EDMGs, FSGs, or SAMGs, and

2. use of the EDMG, FSG, or SAMG from a decision-making and communications aspect with simulated field actions.

Summary The proposed Emergency Plan replaces the NUREG-0654/FEMA-REP-1, Revision 2 element reference from 10 CFR 50.54(hh)(2) to 10 CFR 50.155(b)(2) and establishes the scope (meaning type of MBDBE strategies), number (meaning how many MBDBE strategies must be demonstrated within the cycle) and the EROs extent of play of those exercises.

This detailed specification is consistent with 10 CFR 50 Appendix E.IV.F.2.j.(iii).

Other drills and training that involve personnel and response actions outside the scope of the Emergency Plan will continue to be conducted under the MBDBE Program.

3.7.3 [Deviation 7-3] Biennial Report-in-Drills Proposed Emergency Plan NUREG-0654/FEMA-REP-1, Revision 2 Energy Northwest will conduct an off-hours unannounced ERO report-in drill at least once within an eight-year cycle.

The off-hours unannounced ERO report-in drill will require actual response to the assigned facility and the ability to perform turnover of responsibilities from the on-shift ERO.

N.4.h Off-Hours Report-In Drills Off-hours report-in drills are conducted biennially and are unannounced.

Deviation Evaluation and Justification The current Emergency Plan has no requirement for off-hours report-in drills. NUREG-0654/FEMA-REP-1, Revision 2, Element N.4.h requires that off-hours report-in drills be unannounced and conducted biennially. The proposed Emergency Plan specifies that an unannounced off-hours report-in drill be performed once per eight-year cycle.

Establishing the period for the off-hours report-in drill as once per eight-year cycle is based on the NUREG-0654/FEMA-REP-1, Revision 2, Element N.1.c requirement for a 6:00 p.m. and 4:00 a.m. drill or exercise to be performed once per cycle (which is considered off-hours).

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GO2-24-004 Page 40 of 52 In addition to the requirement of Element N.1.c, every biennial exercise requires demonstration of ERO response and ERF activation following declared emergencies.

Requiring additional biennial off-hours report-in drills is a burden to the organization without a commensurate level of benefit to the Emergency Preparedness Program.

Performance of the Element N.4.h call-in drill within the cycle periodicity provides sufficient demonstration of off-hours augmentation capability without significant impact on employees during late non-working hours.

3.7.4 [Deviation 7-4] Biennial Call-In Drills Proposed Emergency Plan NUREG-0654/FEMA-REP-1, Revision 2 Energy Northwest will conduct an off-hours unannounced ERO call-in drill biennially to validate each ERO members response time.

The off-hours unannounced ERO call-in drill will require collection of the estimated response times to the applicable facility.

Completion of an Element N.4.h off-hours unannounced ERO report-in drill satisfies the requirements of the off-hours unannounced ERO call-in drill in this element.

N.4.i Off-Hours Call-In Drills Off-hours call-in drills are conducted quarterly, such that each ERO members normally expected response time is assessed at least biennially based on call-in drill responses or an alternate means for determining response time.

Some drills are unannounced.

Deviation Evaluation and Justification The current Emergency Plan requires quarterly ERO notification drills. NUREG-0654/FEMA-REP-1, Revision 2, Element N.4.h requires that off-hours call-in drills be conducted at least quarterly, such that each ERO members response time is validated at least biennially (with some drills being unannounced).

The proposed Emergency Plan specifies that off-hours call-in drill be performed biennially.

Notification of the ERO at Columbia is an all-call process for the minimum staffing positions, which for call-in drills will collect response time estimates from those positions required to activate the ERFs. The all-call nature of response for the minimum staffing positions ensures that each required position is assessed at least biennially, as all ERO members filling minimum staffing positions are required to respond to notifications.

Successful activation of the ERFs is based on the shortest response time of all qualified responders for each minimum staffing position, not a specific ERO members response time.

More frequent testing of individual ERO member response times is not necessary since it has no direct bearing on successful ERF activation. Removing the quarterly test of a portion of the ERO response and retaining the biennial test for the minimum staffing ERO meets the intent of the NUREG-0654/FEMA-REP-1, Revision 2 element.

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GO2-24-004 Page 41 of 52 3.7.5 [Deviation 7-5] Response Personnel Retraining Periodicity Not Specified Proposed Emergency Plan NUREG-0654/FEMA-REP-1, Revision 2 Initial training is provided to all new ERO candidates. Refresher training is provided to the ERO as specified by the systematic approach to training (SAT) process. Categories of personnel requiring training include:

1. Shift Managers and Emergency Directors

2. Accident Assessment Personnel

3. Radiological FMT Personnel

4. Dose Assessment Personnel

5. ORO and NRC Communicators

6. Security Personnel x Individuals assigned to site security receive required Emergency Plan training as part of their normal job-specific training program.

x Security management/supervisory personnel assigned to an ERO position receive additional training on EP-related tasks as part of the ERO training program.

7. Fire Brigade Personnel x Individuals assigned to fire brigade maintain fire brigade qualifications by receiving initial and requalification training periodically as defined by the site Fire Protection Program.

8. Repair and Damage Control Team Personnel x Operations, Maintenance, Chemistry and Radiation Protection personnel who would be assigned to repair and damage control teams receive required Emergency Plan training as part of their normal job-specific training program.

9. Site First Aid Personnel x Individuals assigned as first aid responders maintain minimum qualifications equivalent to Red Cross Standard First Aid techniques.

10. Non-ERO Site Personnel x General employee (site access) training provides initial orientation and recurring training on general aspects of the Emergency Plan and non-ERO response. Personnel are familiarized with site emergency announcements, and assembly and evacuation processes.

O.1 Radiological Emergency Response Training Each organization ensures the training of emergency responders and other appropriate individuals with an operational role is described in the emergency plan. Initial training and at least annual retraining are provided.

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GO2-24-004 Page 42 of 52 Deviation Evaluation and Justification As stated in section O.2 of the proposed Emergency Plan, the ERO training program is developed and evaluated based on position-specific responsibilities/tasks using SAT principles, when applicable. The SAT process determines the necessary periodicity of the retraining (continuing training) on a task basis.

3.7.6 [Deviation 7-6] Training Program Review Periodicity Not Specified Proposed Emergency Plan NUREG-0654/FEMA-REP-1, Revision 2 Revisions to the training program are identified during EP assessments, drill and exercise critiques, and from training feedback.

Appropriate revisions to the training program are made using the principles of the SAT process.

O.2.a Radiological Emergency Response Training The ERO training program is reviewed at least annually and revised as necessary.

Deviation Evaluation and Justification As stated in section O.2 of the proposed Emergency Plan, the ERO training program is developed and evaluated based on position-specific responsibilities/tasks using SAT principles, when applicable. In addition to continuous training evaluation through drill and exercise critique process that identifies performance issues and initiates training reviews for particular tasks, the SAT process includes provisions for training program review.

3.7.7 [Deviation 7-7] Minimum Staff Emergency Response Organization Drill Each Cycle Proposed Emergency Plan NUREG-0654/FEMA-REP-1, Revision 2 Energy Northwest will conduct a minimum staffing drill at least once within an eight-year cycle.

A minimum staffing response drill requires demonstration of facility activation, transfer of responsibilities and response functions from the Control Room, and event assessment and response activities.

Not applicable.

Deviation Evaluation and Justification There is no requirement to perform minimum staffing ERO drills.

Energy Northwest has voluntarily added a requirement to conduct a minimum staff ERO drill once during each eight-year cycle to verify that the minimum augmenting ERO positions can effectively implement the Emergency Plan without additional support personnel.

Specific objectives will include demonstration of facility activation, transfer of command and control, event assessment and classification, and off-site notification.

This change exceeds the ERO drill requirements of the current Emergency Plan and NUREG-0654/FEMA-REP-1, Revision 2.

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GO2-24-004 Page 43 of 52 3.8 On-Shift Staffing Analysis RIS 2016-10 states that an on-shift staffing analysis (OSA) under 10 CFR 50, Appendix E, Section IV.A.9 should not be used to provide the primary basis to support the Technical Evaluation of a LAR. The OSA, however, may be utilized as part of the overall evaluation of staffing changes. The RIS states:

an evaluation performed using only the guidance of NEI 10-05 does not satisfy the requirement to identify and evaluate changes to ERO augmentation timing or ERO augmentation staffing that reduces the capability to perform an Emergency Planning function.

In conjunction with this LAR, Energy Northwest has performed and documented an OSA per 10 CFR 50, Appendix E, Section IV.A.9 following the guidance of NEI 10-05.

The results of the OSA conclude there are no task overlap or overburden of the on-shift staff; however, Energy Northwest understands that the OSA comprises a select set of identified scenarios and is not used as the sole basis for the conclusions in the Technical Evaluation supporting this amendment request.

3.9 Impact of Proposed Changes on State Emergency Plan A draft copy of the proposed Emergency Plan was sent to Washington State, Oregon State, Benton County, and Franklin County Emergency Preparedness representatives to inform them of the proposed changes and to solicit comments.

State and county personnel provided concurrence of Energy Northwests initiative to develop the Emergency Plan. Further concurrence will be acquired upon NRC approval of the proposed Emergency Plan and revisions to the ORO Emergency Preparedness Programs will be conducted during the requested implementation period.

Refer to Enclosure 3, Concurrence Letters from Off-site Response Organizations, of this submittal for agency responses regarding proposed changes to the Columbia Emergency Plan.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed Emergency Plan establishes an updated licensing basis for Columbia that complies with current NRC regulations in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

In addition, the formatting of the proposed Emergency Plan is based on the NRC-generated guidance in NUREG-0654/FEMA-REP-1, Revision 2.

RIS 2016-10 was also reviewed in support of this submittal.

The proposed changes have been evaluated against the applicable regulatory requirements and guidance criteria. Each section of the proposed Emergency Plan lists applicable regulations (all 10 CFR 50.47(b) planning standards are addressed) and Appendix 2 of the proposed plan includes a cross reference to the 10 CFR 50 Appendix E Section IV criteria. The proposed Emergency Plan continues to assure that regulatory requirements and planning standards associated with emergency response are met.

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GO2-24-004 Page 44 of 52 4.2 Precedent NUREG-0654/FEMA-REP-1, Revision 2, issued December 2019, reflects changes to both NRC and FEMA regulations, guidance, policies, and doctrine, as well as advances in technology and best practices that have occurred since the document was originally issued in November 1980. This update also incorporates the four supplemental documents and addenda that have been issued in the intervening years and is intended to modernize and consolidate the guidance making it easier for licensees to understand.

The following are industry precedents of licensees requesting and receiving approval for a change of the Emergency Plan based on NUREG-0654/FEMA-REP-1, Revision 2 guidance:

Duke Energy Corporation (ML21155A213)

South Texas Project Nuclear Operating Company (ML21007A231).

The safety evaluation from South Texas Project Nuclear Operating Company is also recent precedent of single site obtaining approval to adopt the NUREG-0654/FEMA-REP-1, Revision 2 guidance.

4.3 No Significant Hazards Consideration Determination Analysis Energy Northwest has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes do not increase the probability or consequences of an accident. The proposed changes do not impact the function of plant Structures, Systems, or Components (SSC). The proposed changes do not affect accident initiators or accident precursors, nor do the changes alter design assumptions. The proposed changes do not alter or prevent the ability of the on-site ERO to perform their intended functions to mitigate the consequences of an accident or event. No changes are proposed to emergency classifications, accident assessment, notification methods, facilities and equipment, training, or public agency support that would alter the consequences of an accident. The proposed changes establish a new Columbia Emergency Plan and modify the ERO. The proposed Emergency Plan continues to meet applicable requirements and standards as well as provide for effective emergency response. The proposed Emergency Plan also continues to provide necessary response staff for emergencies as demonstrated by functional analysis as well as staffing analysis in accordance with 10 CFR 50, Appendix E(IV)(a)(9).

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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GO2-24-004 Page 45 of 52

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes have no impact on the design, function, or operation of any plant SSCs. The proposed changes do not affect plant equipment or accident analyses. The proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new Operator actions. The proposed changes do not introduce failure modes that could result in a new accident, and the proposed changes do not alter assumptions made in the safety analysis. The proposed changes establish a new Columbia Emergency Plan and modify the ERO. The proposed Emergency Plan continues to meet applicable requirements and standards as well as provide for effective emergency response. The proposed Emergency Plan also continues to provide necessary response staff for emergencies as demonstrated by functional analysis as well as staffing analysis in accordance with 10 CFR 50 Appendix E(IV)(a)(9).

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public.

The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes. Margins of safety are unaffected by the proposed changes to the Columbia Emergency Plan.

The proposed changes do not impact operation of the plant or its response to transients or accidents. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by these proposed changes. The proposed changes will continue to provide effective emergency response as well as the necessary on-site ERO response staff.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

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GO2-24-004 Page 46 of 52 4.4 Conclusions In conclusion, based on the considerations discussed above: 1) the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the Commission's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, Standards for Protection Against Radiation, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released off-site, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 10 CFR 50.47, Emergency Plans 6.2 10 CFR 50.54(q), Conditions of Licenses - Emergency Plans 6.3 10 CFR 50.90, Application for Amendment of License, Construction Permit, or Early Site Permit 6.4 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities 6.5 Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors, Revision 6, June 2021 6.6 Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Revision 1, July 2016 6.7 NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, Revision 0, November 2011 6.8 NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, November 1980 6.9 NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 2, December 2019

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GO2-24-004 Page 47 of 52 6.10 NUREG-0654/FEMA-REP-1 Supplement 3, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants - Guidance for Protective Action Strategies, Revision 1, November 2011 6.11 Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1,Section II.B, Emergency Response Organization (ML16117A427) 6.12 NUREG-0696, Functional Criteria for Emergency Response Facilities, February 1981 6.13 NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements -

Requirements for Emergency Response Capability, January 1983 6.14 RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, August 2016 6.15 NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0, June 2011 6.16 NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012 6.17 NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, November 2012 6.18 Columbia Generating Station Final Safety Analysis Report, as updated 6.19 Letter from NRC to Washington Public Power Supply System, Revisions 12-14 to the WNP-2 Emergency Plan, dated March 31, 1994 (ML17290B096) 6.20 Letter from NRC to Energy Northwest, Columbia Generating Station - Emergency Plan Changes, dated August 31, 2004 (ML042440479) 6.21 Letter from Energy Northwest to NRC, Energy Northwests NEI 12-01 Phase 2 Staffing Assessment, dated December 23, 2014 (ML15006A030) 6.22 Letter from NRC to Energy Northwest, Issuance of Amendment Regarding Emergency Action Level Scheme Change to Nuclear Energy Institute 99-01, Revision 6, dated August 28, 2017, (ML17188A230) 6.23 Letter from Duke Energy to NRC, License Amendment Request for Common Emergency Plan Consistent with NUREG-0654, Revision 2, dated September 3, 2020 (ML20247J468) 6.24 Letter from NRC to Duke Energy Corporation, Catawba Nuclear Station, Units 1 and 2; McGuire Nuclear Station, Units 1 and 2; Oconee Nuclear Station, Units 1, 2 and 3; Brunswick Steam Electric Plant, Units 1 and 2; Shearon Harris Nuclear Power Plant, Unit 1; and H. B. Robinson Steam Electric Plant, Unit No. 2 - Issuance of Amendments for Common Emergency Plan Consistent with NUREG-0654, Revision 2, dated August 26, 2021 (ML21155A213) 6.25 Letter from South Texas Project Nuclear Operating Company to NRC, License Amendment Request to Revise South Texas Project Electric Generating Station (STPEGS) Emergency Plan, dated March 30, 2020 (ML20090B745)

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GO2-24-004 Page 48 of 52 6.26 Letter from NRC to STP Nuclear Operating Company, South Texas Project, Units 1 and 2 - Correction to Amendment Nos. 221 and 206 to Authorize Revision of the Emergency Plan Based on NUREG-0654/FEMA-REP-1, Revision 2, dated May 11, 2021 (ML21120A184) 6.27 Letter from Florida Power & Light Company to NRC, License Amendment Request for Common Emergency Plan Consistent with NUREG0654, Revision 2, dated October 4, 2022 (ML22278A031)

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GO2-24-004 Page 49 of 52 - Emergency Response Organization Staffing Plan Comparison Table NUREG-0654, Rev. 2 Current E-Plan, Rev. 68 New E-Plan EPIP Function Position Title Alert Alert SAE Alert Alert Alert Min Non-Shift 60 Min 90 Min 60 Min Shift 90 Min Aug Supp Shift 90 Min Min Plant Systems Operations Control Room Supervisor (Shift) 1 Reactor Operator (Shift) 2 Equipment Operator (Shift) 2 Command and Control Shift Manager (Shift) 1 1

1 TSC Manager (TSC) 1 1

EOF Manager (EOF) 1 1

1 Supervision of On-Site Response Activities TSC Manager (TSC) 1 Emergency Classifications Incident Advisor (Shift) 1(a) 1(a) 1(a)

Operations Manager (TSC) 1(a)

Assistant EOF Manager (EOF) 1 1

1 Emergency Notification and Communications State/County Notifier (Shift) 1(a) 1 1(a) 1 1(a)

ENS Communicator (Shift) 1(a) 1 1

State/County Notifier (TSC) 1 1(a)

State/County Notifier (EOF) 1 1(a) 1(a)

Plant/NRC Liaison (TSC) 1 1

1 Industrial Development Authority 1

Inter-Facility Communications Control Room Info Coordinator (CR) 1 1

TSC Info Coordinator (TSC) 1 1

EOF Info Coordinator (EOF) 1 1

Liaisons Energy Northwest County EOC Rep (EOF) 2 2

Energy Northwest State EOC Rep (EOF) 1 1

State/County Technical Liaison (EOF) 1 1

Supervision of RP Activities Shift Manager (Shift) 1(a) 1(a)

RP Manager (TSC) 1 1

1 Radiological Emergency Manager (EOF) 1 1

1 Radiation Protection HP Tech-In-Plant Survey (Shift & OSC) 1 3

3 1

5 3

5 HP Tech-RP (Shift & OSC) 1 2

Chemistry Technician (Shift) 1 HP Center Staff 2(a)

Dose Assessments/

Projections Dose Assessor (Shift) 1(a) 1(a, b) 1(a, b)

Radiological Emergency Manager (EOF) 1(a) 1(a)

Chemistry/Effluent Manager (TSC) 1 1

Dose Projection HP (EOF) 1 1

1

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GO2-24-004 Page 50 of 52 - Emergency Response Organization Staffing Plan Comparison Table NUREG-0654, Rev. 2 Current E-Plan, Rev. 68 New E-Plan EPIP Function Position Title Alert Alert SAE Alert Alert Alert Min Non-Shift 60 Min 90 Min 60 Min Shift 90 Min Aug Supp Shift 90 Min Min Field Monitoring Teams Field Team Coordinator (EOF) 1 1

On-site FMT Tech (EOF) 1 1

1 On-site FMT Driver (EOF) 1 1

Off-site FMT Tech (EOF) 1 1

2 2

Off-site FMT Driver (EOF) 1 1

2 2

Field Team Dispatcher (EOF) 1 Supervision of Repair Team Activities OSC Manager (OSC) 1 1

1 HP Lead (OSC) 1 1

1 Electrical Lead (OSC) 1 1

1 I&C Lead (OSC) 1 Mechanical Lead (OSC) 1 1

Maintenance Manager (TSC) 1 Team Tracker (OSC) 2 1

Repair Team Coordinator (OSC) 1 1

Repair Team Activities EO (Shift)/Mechanic (OSC) 1 4(a) 1 4(c) 1 EO (Shift)/Electrician (OSC) 1 2

1 EO (Shift)/I&C Technician (OSC) 1 1

1 Radwaste Operator (OSC) 1 Chemistry Technician (OSC) 1 Engineering and Plant Monitoring STA or 3rd SRO (Shift) 1(a) 1(h) 1 Operations Manager (TSC) 1 1

Technical Manager (TSC) 1 Core Thermal Engineer (TSC) 1 1

1 Electrical Engineer (TSC) 1 1

1 Mechanical Engineer (TSC) 1 1

1 Engineering Manager (EOF) 1 Rad Detection System Eng (EOF) 1 Security Security Lieutenant (Shift) 1 1

SCC Duty Officer (Shift) 1 1

Security Force (Shift)

(d)

Security Manager (EOF) 1 1

1

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GO2-24-004 Page 51 of 52 - Emergency Response Organization Staffing Plan Comparison Table NUREG-0654, Rev. 2 Current E-Plan, Rev. 68 New E-Plan EPIP Function Position Title Alert Alert SAE Alert Alert Alert Min Non-Shift 60 Min 90 Min 60 Min Shift 90 Min Aug Supp Shift 90 Min Min Media Information JIS/JIC Staff (e)

(f)

(e, f)

JIC Manager (JIC) 1 1

Energy Northwest Spokesperson (JIC) 1 1

PIO (EOF) 1 1

Asst. JIC Mgr. - Press Conf (JIC) 1 1

Asst. JIC Mgr. - News Release (JIC) 1 1

Media Coordinator (JIC) 1 1

JIC Support Manager (JIC) 1 1

Information Manager (JIC) 1 1

Technical Spokesperson (JIC) 1 1

Phone Team Supervisor (JIC) 2 1

News Release Editor (JIC) 1 1

PIO Technical Support (EOF) 1 HP Spokesperson (JIC) 1 Media Phone Team (JIC) 4 3

Public Phone Team (JIC) 4 2

Audio/Visual (JIC) 1 1

Distribution Team Supervisor (JIC) 1 Distribution Team (JIC) 2 1

Social Media Coordinator 1

Secretary 1

1 Receptionist (JIC) 1 Information Technology Telecomm Manager (EOF) 1 1

(g)

(g) 1 PDIS Analyst (EOF) 1 Computer Engineer (TSC) 1 1

Fire & Rescue Fire Brigade EO (Shift) 2 Local Support Fire Brigade Plant Laborer (Shift) 1 Fire Brigade HP Tech & Chemistry Tech (Shift) 2(a)

First Aid Team (Shift) 2(a)

Local Support

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GO2-24-004 Page 52 of 52 - Emergency Response Organization Staffing Plan Comparison Table (a) Assigned as a collateral duty.

(b) SRO license holders (which include Shift Managers, Control Room Supervisors and Incident Advisors) and STAs are available on-shift to perform off-site dose assessment at all times.

(c) The four on-shift EOs are assigned on-shift maintenance Repair Team roles (mechanical, electrical and I&C) as a collateral duty. One or more of the maintenance roles may be given to an individual from the Maintenance organization provided all three maintenance areas (mechanical, electrical and I&C) remain represented by the four personnel assigned to this function.

(d) Per the Columbia Physical Security Plan.

(e) JIS staffed to address media inquiries within 60 minutes of an Alert emergency classification level.

(f) JIS/JIC staffed to perform related tasks. Activation of the JIC is coordinated with County and State representatives (positions and facility have no activation time requirement).

(g) IT personnel can monitor CDAs remotely and respond any time an issue is identified.

(h) On-shift as required by Technical Specifications in Modes 1, 2, and 3. Available within 90 minutes for call-in for Modes 4 and 5.

NUREG-0654, Rev. 2 Current E-Plan, Rev. 68 New E-Plan EPIP Function Position Title Alert Alert SAE Alert Alert Alert Min Non-Shift 60 Min 90 Min 60 Min Shift 90 Min Aug Supp Shift 90 Min Min

Response

Administration Plant Administrative Manager (TSC) 1 1

EOF Manager Secretary (EOF) 1 1

Manpower Scheduler (EOF) 1 1

Site Support Manager (EOF) 1 1

TSC Manager Secretary (TSC) 1 1

Administrative Support Staff (TSC) 1 Administrative Support Staff (EOF) 2 JIC Secretary 1

1 ERO Totals - All Categories 3

20 10 5

18 32 34 25 9

27 38 ERO Totals - Shift/Minimum/Non-Minimum 35 59 ERO Totals - Shift/Responders 38 91 65 ERO Totals - All ERO Positions 109 74

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GO2-24-004 COLUMBIA GENERATING STATION EMERGENCY PLAN (98 pages follow)

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Columbia Generating Station Emergency Plan Page 1 of 98 COLUMBIA GENERATING STATION (CGS)

EMERGENCY PLAN DOCKET NO. 50-397 LICENSE NO. NPF-21

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ENERGY NORTHWEST

Columbia Generating Station Emergency Plan Page 2 of 98 Table of Contents Introduction................................................................................................................................... 3

A:

Assignment of Responsibility............................................................................................... 5

B:

Emergency Response Organization.................................................................................. 13

C:

Emergency Response Support and Resources................................................................. 24

D:

Emergency Classification System...................................................................................... 28

E:

Notification Methods and Procedures................................................................................ 31

F:

Emergency Communications............................................................................................. 34

G:

Public Education and Information...................................................................................... 36

H:

Emergency Facilities and Equipment................................................................................. 40

I:

Accident Assessment......................................................................................................... 48

J:

Protective Response.......................................................................................................... 53

K:

Radiological Exposure Control........................................................................................... 60

L:

Medical and Public Health Support.................................................................................... 64

M:

Recovery, Reentry, and Post-Accident Operations............................................................ 66

N:

Exercises and Drills............................................................................................................ 69

O:

Radiological Emergency Response Training..................................................................... 78

P:

Responsibility for the Planning Effort Development........................................................... 81

Appendix 1, NRC Approval Listing and EP Commitment Cross-Reference............................... 85 Appendix 2, 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference.......... 86

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Columbia Generating Station Emergency Plan Page 3 of 98 INTRODUCTION

1. Description Columbia Generating Station (CGS) is a Boiling Water Reactor (BWR-5) with the reactor system supplied by the General Electric Company. This plant has an approximate electrical output of 1250 megawatts (MWe).

CGS leases 1089 acres of land on the Hanford Site, located north of Richland, Washington, and controlled by the Department of Energy (DOE). The land leased by CGS is approximately three miles west of the Columbia River and 12 miles north of the populated area of Richland.

The principal structures located on the plant site are shown in Figure 1-1.

2. Emergency Plan Structure The formal CGS Emergency Plan consists of the following documents:

x EP-01, Emergency Plan - The emergency plan identifies and describes the methods for responding to emergencies and maintaining emergency preparedness. The emergency plan is formatted using the NUREG-0654/FEMA-REP-1 Revision 2 (NUREG-0654 R2) outline style to: (1) document how each regulatory requirement of §50.47(b), as detailed by the NUREG-0654 R2 elements, and §50 Appendix E are met; and (2) provide a direct cross-reference to the elements of NUREG-0654 R2.

x EP-02, On-Shift Staffing Analysis - The on-shift staffing analysis documents the demonstration that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of Emergency Operating Procedure (EOP) and emergency plan actions prior to Emergency Response Organization (ERO) augmentation. The on-shift staffing analysis fulfills regulatory requirements of §50 Appendix E.IV.A.9.

x EP-03, Evacuation Time Estimate (ETE) Report - The ETE report defines the Plume Exposure Pathway (PEP) Emergency Planning Zone (EPZ), documents the population within defined areas of the PEP EPZ, and establishes evacuation routes and ETEs for different scenarios for those populations. The ETE report fulfills regulatory requirements of §50 Appendix E.IV paragraphs 2-7.

x EP-04, Alert & Notification System (ANS) Design Report - The ANS design report is the FEMA-approved document that contains the design, testing, and maintenance aspects of the system. The ANS design report fulfills regulatory requirements of §50 Appendix E.IV.D.3.

x EP-05, Columbia Generating Station Bases for Offsite Protective Actions - The Protective Action Recommendation (PAR) technical basis documents the site-specific offsite PAR strategy in accordance with NUREg-0654 Supplement 3. The PAR technical basis fulfills regulatory requirements of §50 Appendix E.IV paragraph 3.

x 13.1.1A, Emergency Action Level (EAL) Technical Basis - The EAL technical basis establishes the classification scheme used to declare emergencies and documents the references and inputs used to determine values or events that would result in declaration of an emergency. The EAL technical basis fulfills regulatory requirements of

§50 Appendix E.IV.B.1.

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Columbia Generating Station Emergency Plan Page 4 of 98 Figure 1-1: Columbia Generating Station Site Map

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Columbia Generating Station Emergency Plan Page 5 of 98 A:

Assignment of Responsibility Primary responsibilities for emergency response by the licensee, and by state and local organizations within the EPZs have been assigned, the emergency responsibilities of the various supporting organization have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

Regulatory

References:

10 CFR 50.47(b)(1); 44 CFR 350.5(a)(1);

10 CFR Part 50, Appendix E.IV.A A.1 The Federal, state, local, and tribal governments, licensee, and other private sector organizations that comprise the overall response for the EPZs are identified.

A.1.a.1 provides a summary description of the CGS response organizations overall concept of operation and relationship to other emergency management organizations for event response.

Detailed descriptions of the CGS ERO minimum staffing positions and their roles are contained in Section B.

The other sections under Element A.1.a provide a summary of federal, state, county, and governmental support organizations that encompass the emergency management response aspect for an event at CGS.

A.1.a The organizations having an operational role specify their concept of operations and relationship to the total effort.

1. Columbia Generating Station (CGS)

CGS performs event assessment and response activities related to the unit and the site, and recommends protective actions for the public outside the site boundary when required.

When an abnormal situation occurs the Shift Manager, using operating and emergency procedures, determines whether the event meets the conditions for an Emergency Classification Level (ECL). Emergencies are initially declared and responded to by the on-shift ERO under the direction of the Shift Manager. The on-shift ERO is augmented with additional ERO personnel at the Alert and higher ECLs. The augmenting ERO report to their assigned Emergency Response Facility (ERF) and relieve on-shift ERO shift personnel of emergency response functions not directly associated with plant operations.

The CGS Emergency Plan is integrated with response plans maintained by Washington State, Oregon State, Benton County, Franklin County, Department of Energy - Richland Operations (DOE-RL), and the Nuclear Regulatory Commission (NRC).

2. Federal Organizations Control, responsibility, and interface of federal organizations is governed by the National Response Framework (NRF) and its Nuclear/Radiological Incident Annex when an event occurs at a nuclear power plant. The NRF describes how the coordinating agencies such as the NRC, DOE, Federal Emergency Management Agency (FEMA), or Environmental Protection Agency (EPA) lead the response to radiological emergencies. In the event of a radiological emergency, a number of federal agencies can be called upon by the Department of Homeland Security (DHS) to support state and county activities through provisions contained in the NRF.

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Columbia Generating Station Emergency Plan Page 6 of 98 The main federal organizations that may be involved in a significant event at CGS are:

A. Department of Homeland Security (DHS)

DHS is responsible for overall coordination of all actual and potential Incidents of National Significance, including terrorist incidents involving nuclear materials in accordance with the Nuclear/Radiological Incident Annex of the NRF.

For an emergency classification of General Emergency, DHS would normally establish a response center in the Tri-Cities area. If resources are needed from DHS, the State of Washington or the NRC have the authority to request their assistance.

B. Nuclear Regulatory Commission (NRC)

The NRC is designated as a Coordinating Agency by the NRF. A Coordinating Agency is supported by Cooperating Agencies in the event that additional support from other agencies becomes necessary.

The NRC maintains an Incident Response Plan (IRP). The NRC IRP governs the NRCs overall response to radiological incidents and emergency events, and is referenced by the NRF. The NRC IRP provides the basis for NRCs interface with licensees as an integral part of the overall response. The IRP objectives are to provide for protection of the public health and safety, property, and the environment, from the effects of radiological incidents that may occur at licensed facilities. NRC's principal role in the event of a power plant emergency is to ensure that appropriate protective actions are being taken. The NRC personnel also monitor actions by the licensee to provide any assistance requested by the licensee or offsite officials.

NRC headquarters and regional offices have established and maintain Incident Response Centers designed to centralize and coordinate their emergency response functions. Each NRC region is prepared to send a team of qualified specialists to the scene. All necessary emergency response supplies and equipment needed by the NRC are provided and maintained by the NRC. Communications links are established between the Control Room, Technical Support Center (TSC), Emergency Operations Facility (EOF), NRC headquarters, and NRC Region IV. The NRC has established lines of communications with state and local government, and other federal agencies and entities.

C. Department of Energy-Richland Operations (DOE-RL)

DOE-RL, located in Richland, Washington, has large resources of equipment and personnel available and capable of providing radiological response, such as laboratory facilities and technical individuals. DOE-RL can mobilize field monitoring teams on the Hanford site and provide additional federal field monitoring and dose assessment capability when requested.

A representative from DOE-RL may report to the EOF to coordinate their response activities.

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Columbia Generating Station Emergency Plan Page 7 of 98 x

Fire and Rescue The DOE-RL Hanford Fire Department provides fire and rescue response support to CGS. Hanford Fire Department personnel are specifically trained to handle nuclear facility fire incidents and have specially equipped vehicles and personnel for rescue and other emergencies.

Additional fire department response, if needed, is available through mutual aid agreements between DOE-RL and county and/or municipal fire departments.

Local support services fire organizations performing functions onsite interface directly with the CGS Fire Brigade Leader.

x Medical Transportation The DOE-RL Hanford Fire Department provides transportation of injured, or contaminated-injured personnel to a medical facility. Hanford Fire Department personnel are qualified to provide urgent pre-hospital treatment and stabilization for serious illness and injuries, and have specially equipped vehicles for response to facilities on the Hanford Site.

D. Federal Emergency Management Agency (FEMA)

FEMA acts as the lead federal agency for offsite, non-technical concerns. FEMA coordinates state requests for federal assistance, identifying which federal agency can best address specific needs. If deemed necessary by FEMA, it will establish a Federal Response Center from which it will manage its assistance activities.

CGS communicates with and obtains support from FEMA through the state.

E. United States Coast Guard (USCG)

The USCG, through the Thirteenth District Commander in Seattle, Washington, and the Captain of the Port in Portland, Oregon, regulates activities on navigable waters. USCG assistance, coordinated through Benton and Franklin Counties, provides response support at the Site Area or General Emergency classification levels.

The USCG may establish a "Safety Zone" on the Columbia River within the CGS PEP EPZ. This Safety Zone provides authority for DOE and Sheriff's Office patrol craft to control river access within the PEP EPZ. The USCG can also broadcast river closure notices to mariners.

Benton and Franklin counties maintain the plans and procedures that requests USCG support.

F. National Weather Service (NWS)

The NWS can be contacted to provide meteorological information during emergency situations. Data available will include existing and forecasted surface wind directions, wind speed with azimuth variability, and ambient surface air temperature.

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Columbia Generating Station Emergency Plan Page 8 of 98 G. U.S. Geological Survey (USGS)

The USGS maintains the National Earthquake Information Center (NEIC), accessed via the USGS website. The NEIC rapidly determines the location and size of all destructive earthquakes worldwide and immediately disseminates this information to concerned national and international agencies, scientists, and the general public. The NEIC is used as one of several sources to evaluate seismic events that may impact the site.

3. State Organizations A. State of Washington The Washington State emergency plan describes the detailed response which will be given during an emergency. Responsibilities are outlined for all state agencies which have a response role. The following content describes the primary state agencies with direct interface and coordination during a declared event at CGS.

x Emergency Management Division (EMD)

EMD is responsible for radiological response planning and coordination of operations. During state emergencies, EMD manages the State Emergency Operations Center (EOC) located on Camp Murray, near Tacoma, and coordinates the response. The EOC is designated as the states central location for information gathering, disaster analysis, and response coordination. At the EOC, information gathered is used by executives to make decisions concerning emergency actions and to identify and prioritize the use of state resources needed to respond to the emergency. The EOC may issue emergency warnings or disseminate critical information and instructions to government personnel and the public who may need to take emergency protective actions.

An EMD representative is expected to respond to the EOF at a Site Area or General Emergency classification level, and if conditions warrant during an Alert, to coordinate response and resources.

x Department of Health (DOH)

DOH is responsible for administering and directing radiation control program activities within the state. DOH provides local authorities with technical guidance, assistance in establishing monitoring and decontamination programs and recommending appropriate emergency countermeasures and recovery actions offsite.

DOH representatives are expected to respond to the Meteorology and Unified Dose Assessment Center (MUDAC) at an Alert or higher emergency classification level to coordinate environmental field monitoring teams, assessment of dose projection information, preparation of protective action recommendations for the PEP and Ingestion Exposure Pathway (IEP) EPZs, and estimation of total dose exposure.

x Washington State Patrol (WSP)

WSP will assist each affected county and provide, upon request from either state or county officials, law enforcement functions, communications support, and transportation assistance to other agencies when the WSP's law enforcement commitment is not jeopardized.

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Columbia Generating Station Emergency Plan Page 9 of 98 The WSP has jurisdiction of the Hanford Site highways and provides assistance to county sheriffs concerning traffic control and area access. The local WSP headquarters has direct radio communications with the Benton and Franklin County sheriffs and the Emergency Dispatch Center (SECOMM).

x Washington State Department of Agriculture (WSDA)

WSDA is responsible for the control and protection of agricultural products within the boundaries of Washington State. This is accomplished by implementing agricultural protection measures in coordination with other participating agencies and local jurisdictions. These measures include preparing and issuing agricultural advisories to protect the public; preparing and implementing plans in coordination with affected agencies and jurisdictions to reduce the Food Control Area, release food, dispose of contaminated food and conduct embargoes. They will also provide input, as requested by other agencies, in the areas of soil, water and crop decontamination; claims procedures; reduction of Food Control Area and public information.

B. State of Oregon Upon declaration of a Site Area Emergency classification level, Oregon will begin a limited activation of the Oregon Emergency Coordination Center (ECC) in Salem primarily to maintain communications and monitor the emergency event. Oregon will send one or more field teams to Morrow and Umatilla Counties and will provide field team assistance to Washington State as requested. In addition, Oregon will send representatives to the Washington State EOC.

If the emergency includes ingestion exposure considerations, Oregon will coordinate with CGS, Washington State, and federal response agencies to assess conditions within the state boundaries, initiate necessary public protective measures and provide public information (e.g., news releases) as may be required.

4. County Organizations A. Benton and Franklin County Emergency Management Benton and Franklin Counties have established a radiological emergency response program that includes coordination and assistance with local radiological emergency response planning, exchange of emergency preparedness information, development of emergency response capabilities, and emergency response training.

Activation of the Benton and Franklin County EOCs occur at an Alert or higher emergency classification level. When activated, Benton and Franklin County EOCs may dispatch county representatives to the EOF, when personnel are available and travel allows. County emergency response activities include providing local emergency public information and instruction, establishment of emergency worker and assistance centers, making offsite protective action decisions, activation of the early warning system, and coordination of local protective action implementation and support.

Benton and Franklin Counties also play an active role during recovery operations and work closely with Washington State and CGS to ensure appropriate measures are taken for affected members of the public within their jurisdiction.

Local law enforcement support for CGS is coordinated through the Benton Country EOC upon request.

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Columbia Generating Station Emergency Plan Page 10 of 98 B. Benton and Franklin County Sheriff Offices The Benton County Sheriff has jurisdiction for all civil disturbances or threats at CGS.

The Benton County Sheriff also has jurisdiction of the Hanford Site roadways.

Arrangements have been made with the sheriff to provide traffic control in order to limit access to the Hanford Site during an emergency at CGS. Local law enforcement agencies may also provide access control services for the Hanford Site through mutual aid agreement with the Benton County Sheriff. Request for assistance to the Benton County Sheriff are made to the Sheriff's office or through the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Emergency Dispatch Center (SECOMM) located in Richland.

Following receipt of a protective action decision by the applicable county authority, the Sheriffs of Benton and Franklin Counties, or local law enforcement, as applicable, are responsible for implementing evacuation, traffic control, community security, search and rescue activities, and river picket/enforcement of USCG river closure in their respective jurisdictions.

C. Counties within the Ingestion Exposure Pathway (IEP) EPZ Six Washington counties (in addition to Benton and Franklin Counties) and two Oregon counties are located within the IEP EPZ. A portion of the Yakama Indian Nation also falls within the IEP EPZ. Local governments are informed regarding the status of the plant and recommended protective actions by their respective state. The Yakama Indian Nation will be notified by Yakima County.

5. Private Organizations Private organizations are limited to support activities and are not used to perform operational roles or fill positions on the ERO. Such organizations are used to provide technical assistance or logistics support under the management and supervision of the ERO. Those organizations are described in Element B.5.

A.1.b Each organizations emergency plan illustrates these interrelationships in a block diagram.

Figure B-4 illustrates the relationship between CGS emergency centers and the various outside response agencies.

A.1.c Each organization identifies the individual, by title/position, who will be in charge of the emergency response.

The title of the individual who will be in charge of the emergency response is provided in Elements B.2 and B.2.a.

A.2 References to the applicable acts, codes, or statutes that provide the legal basis for emergency response-related authorities, including those that delegate responsibility and authority to state, local, and tribal governments are included.

Each emergency plan indicates who may declare a State of Emergency and the powers that ensue.

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 11 of 98 A.3 Each organization specifies the key individual(s), by title/position, responsible for the following functions, as applicable to that organization: command and control, alert and notification, communications, public information, accident assessment, public health and sanitation, social services, fire and rescue, traffic control, emergency medical services, law enforcement, transportation, protective response (including authority to request Federal assistance and to initiate other protective actions), and radiological exposure control.

Refer to Element B.1.a and Table B-1 for a list of key individuals responsible for command and control, alerting and notification, communications, public information, accident assessment, protective response (including authority to request federal assistance and to initiate other protective actions), and radiological exposure control.

A.4 Written agreements with the support organizations having an emergency response role within the EPZs are referenced. The agreements describe the concept of operations, emergency response measures to be provided, mutually acceptable criteria for their implementation, and arrangements for exchange of information.

Assistance will be provided, as necessary, by federal, state, and county agencies that are mandated by charter, regulation or law to protect public health and safety. Federal, state, and county organizations cooperate with CGS and have developed radiological emergency plans and procedures in an integrated manner. Letters of Agreement (LOAs) and Memoranda of Understanding (MOUs) are not required with these agencies:

x Department of Energy-Richland Operations x

State of Washington x

State of Oregon x

County of Benton x

County of Franklin Support agreements are necessary when an agency, organization or individual is expected to provide assistance to CGS and is not required otherwise to do so. To that extent, LOAs/MOUs have been developed between CGS and several entities to provide emergency response support and services consistent with this plan.

Specifically, minimum content in the agreement includes the following:

x A description of the concept of operations (mutually accepted criteria for implementation).

x When the support will be provided (as a minimum, the agreement states that the support will be provided during an emergency at the site, including during a Hostile Action).

x Identification of the support to be provided.

x Arrangements for exchange of information/communications.

A contract or purchase order with an organization is considered acceptable in lieu of a LOA/MOU for the specified duration of the contract. The current copies of applicable LOAs/MOUs and contracts, kept in the CGS records management system, are maintained with:

x Applied Process Engineering Laboratory (APEL) x Framatome

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Columbia Generating Station Emergency Plan Page 12 of 98 x

General Electric Company x

Hanford Fire Department x

Kadlec Regional Medical Center x

Landauer, Inc.

x Lourdes Medical Center x

Trios Health Southridge Hospital A.5 Each principal response organization is capable of continuous operations for a protracted period. The principal response organization specifies the individual, by title/position, who is responsible for ensuring continuity of resources (technical, administrative, and material).

CGS maintains a depth to the ERO that is capable of providing continuous (24 hour/day) operation for an extended period of time. Key functions are maintained throughout a declared emergency by providing relief of on-shift and augmenting ERO positions by qualified individuals.

ERO relief periods and schedules will be determined by the Emergency Director.

The Emergency Director is the individual responsible for assuring continuity of resources (technical, administrative, and material) within the ERO.

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Columbia Generating Station Emergency Plan Page 13 of 98 B:

Emergency Response Organization On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

Regulatory

References:

10 CFR 50.47(b)(2); 44 CFR 350.5(a)(2);

10 CFR Part 50, Appendix E.IV.A B.1 The emergency plan specifies how the requirements of 10 CFR 50.47(b)(2) and the applicable sections of Appendix E to 10 CFR Part 50 are met.

1. 10 CFR 50.47(b)(2) Compliance Regulatory Guide 1.101, Revision 6, states that NUREG-0654 R2, which provides specific acceptance criteria for complying with the planning standards set forth in 10 CFR 50.47, contains acceptable guidance for use when developing emergency preparedness and response plans.

The scope of NUREG-0654 R2 states NPP applicants and licensees may voluntarily use the guidance in this document to demonstrate compliance with the underlying NRC regulations.

The CGS Emergency Plan is based on the criteria contained in NUREG-0654 R2.

2. 10 CFR 50 Appendix E Compliance Refer to the 10 CFR 50 Appendix E.IV cross-reference in Appendix 2 of this emergency plan.

B.1.a The site-specific emergency response organization (ERO) is developed. Note that while other site programs, such as operations, fire response, rescue and first aid, and security, may be controlled via other licensing documents, it is only when these personnel are assigned EP functions that they become part of this regulatory standard. Consideration is given to ensure that EP functions are not assigned to individuals who may have difficulties performing their EP function(s) simultaneously with their other assigned (non-EP) duties. Appendix E to 10 CFR Part 50 requires licensees to perform an on-shift staffing analysis to ensure on-shift staff can support the EP functions assigned, as well as other assigned duties.

The CGS day-to-day operating organization is described in Section 13.1 of the Final Safety Analysis Report (FSAR).

The requirements for on-shift operations staff, security force staff, and fire brigade/first aid staff are controlled by Technical Specifications and other licensing, operations, and administrative documents. Positions from these departments are described in the CGS Emergency Plan only when assigned an emergency preparedness response function.

The CGS on-shift staffing analysis report has been developed in accordance with 10 CFR 50 Appendix E.IV.A.9 and NEI 10-05 and is maintained as part of the emergency plan.

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Columbia Generating Station Emergency Plan Page 14 of 98 The on-shift and augmenting minimum ERO staffing plan is composed of the following positions, which are assigned the following response functions (organized by facility):

1. Control Room (CR)

A. Shift Manager x

[A.1] Federal Assistance x

[B.1] Command and Control x

[C.3] Coordination of Principal Organizations (ORO EOCs/ECCs, ICP, etc.)

x

[C.5] NRC Notification and Communications x

[D.1] Event Classification x

[E.1] ERO Notification x

[E.2] State and Local Event Notification (ECL and PAR) x

[F.1] ERF Communications and Information Display Systems x

[I.2] Effluent Release and Dose Assessment x

[I.4] Radiological Field Monitoring Activities x

[I.6] Repair Team Priorities, Dispatch and Control x

[J.1] Site Assembly and Accountability x

[J.2] Site Evacuation x

[J.3] ERO Radiological Protection x

[J.4] Offsite Protective Action Recommendations x

[K.1] Emergency Exposure x

[M.1] Event Termination x

[X.1] Mitigation of Beyond-Design-Basis Events B. Shift Technical Advisor or 3rd SRO x

[C.5] NRC Notification and Communications x

[D.1] Event Classification x

[E.1] ERO Notification x

[E.2] State and Local Event Notification (ECL and PAR) x

[F.1] ERF Communications and Information Display Systems x

[I.2] Effluent Release and Dose Assessment x

[I.3] Core Damage Assessment x

[J.4] Offsite Protective Action Recommendations C. State and County Notifier x

[E.2] State and Local Event Notification (ECL and PAR)

D. ENS Communicator x

[C.5] NRC Notification and Communications E. Health Physics Technician x

[I.4] Radiological Field Monitoring Activities x

[I.5] Radiation Protection Activities

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Columbia Generating Station Emergency Plan Page 15 of 98 x

[K.1] Emergency Exposure F. Equipment Operator or Maintenance Technician x

[I.6] Repair Team Priorities, Dispatch and Control G. Security Communication Center (SCC) Duty Officer x

[B.4] External Support Services (management, technical, material, etc.)

x

[E.1] ERO Notification x

[E.2] State and Local Event Notification (ECL and PAR) x

[J.2] Site Evacuation x

[X.3] Security Activities H. Security Lieutenant x

[J.1] Site Assembly and Accountability x

[J.2] Site Evacuation x

[J.3] ERO Radiological Protection x

[X.3] Security Activities I.

Classification Advisor (collateral duty) x

[D.1] Event Classification x

[E.2] State and Local Event Notification (ECL and PAR) x

[J.4] Offsite Protective Action Recommendations J. Dose Assessor (collateral duty) x

[I.2] Effluent Release and Dose Assessment

2. Technical Support Center (TSC)

A. TSC Manager x

[A.2] Continuous Emergency Response Operations x

[B.2] Facility/Group Management and Supervision x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[C.3] Coordination of Principal Organizations (ORO EOCs/ECCs, ICP, etc.)

x

[C.5] NRC Notification and Communications x

[D.1] Event Classification x

[F.1] ERF Communications and Information Display Systems x

[H.1] Facility Activation x

[I.1] Accident Detection and Assessment x

[I.6] Repair Team Priorities, Dispatch and Control x

[J.1] Site Assembly and Accountability x

[J.2] Site Evacuation x

[J.3] ERO Radiological Protection x

[K.1] Emergency Exposure

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Columbia Generating Station Emergency Plan Page 16 of 98 x

[M.2] Recovery x

[X.1] Mitigation of Beyond-Design-Basis Events x

[Z.1] Facility Briefs and Updates B. Plant/NRC Liaison x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[C.5] NRC Notification and Communications C. Radiation Protection Manager x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[C.5] NRC Notification and Communications x

[I.1] Accident Detection and Assessment x

[I.2] Effluent Release and Dose Assessment x

[I.4] Radiological Field Monitoring Activities x

[I.5] Radiation Protection Activities x

[J.2] Site Evacuation x

[J.3] ERO Radiological Protection x

[K.1] Emergency Exposure x

[Z.1] Facility Briefs and Updates D. Core/Thermal Hydraulic Engineer x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[F.1] ERF Communications and Information Display Systems x

[I.1] Accident Detection and Assessment x

[I.3] Core Damage Assessment E. Electrical Engineer x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[F.1] ERF Communications and Information Display Systems x

[I.1] Accident Detection and Assessment F. Mechanical Engineer x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[F.1] ERF Communications and Information Display Systems x

[I.1] Accident Detection and Assessment

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Columbia Generating Station Emergency Plan Page 17 of 98

3. Operations Support Center (OSC)

A. OSC Manager x

[B.2] Facility/Group Management and Supervision x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[F.1] ERF Communications and Information Display Systems x

[H.1] Facility Activation x

[I.1] Accident Detection and Assessment x

[I.6] Repair Team Priorities, Dispatch and Control x

[J.1] Site Assembly and Accountability x

[J.3] ERO Radiological Protection x

[Z.1] Facility Briefs and Updates B. Maintenance Lead x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[I.6] Repair Team Priorities, Dispatch and Control C. Electrical/I&C/Mechanical Maintenance Technician x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[I.6] Repair Team Priorities, Dispatch and Control D. HP Lead x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[J.3] ERO Radiological Protection x

[I.5] Radiation Protection Activities x

[I.6] Repair Team Priorities, Dispatch and Control x

[Z.1] Facility Briefs and Updates E. HP Technician x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[I.5] Radiation Protection Activities x

[J.1] Site Assembly and Accountability x

[J.3] ERO Radiological Protection x

[K.1] Emergency Exposure x

[K.2] Contamination Controls

4. Emergency Operations Facility (EOF)

A. EOF Manager x

[A.1] Federal Assistance x

[A.2] Continuous Emergency Response Operations

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Columbia Generating Station Emergency Plan Page 18 of 98 x

[B.1] Command and Control x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[B.4] External Support Services (management, technical, material, etc.)

x

[C.3] Coordination of Principal Organizations (ORO EOCs/ECCs, ICP, etc.)

x

[C.5] NRC Notification and Communications x

[D.1] Event Classification x

[E.2] State and Local Event Notification (ECL and PAR) x

[F.1] ERF Communications and Information Display Systems x

[G.1] Media Statements x

[H.1] Facility Activation x

[J.2] Site Evacuation x

[J.3] ERO Radiological Protection x

[J.4] Offsite Protective Action Recommendations x

[K.1] Emergency Exposure x

[M.1] Event Termination x

[M.2] Recovery x

[X.1] Mitigation of Beyond-Design-Basis Events x

[Z.1] Facility Briefs and Updates B. Assistant EOF Manager x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[C.1] Integration of Offsite Agency Personnel in the ERF x

[D.1] Event Classification x

[E.2] State and Local Event Notification (ECL and PAR) x

[F.1] ERF Communications and Information Display Systems x

[G.1] Media Statements x

[H.1] Facility Activation x

[H.2] Facility Operation x

[M.2] Recovery x

[Z.1] Facility Briefs and Updates C. State & County Notifier (collateral duty) x

[E.2] State and Local Event Notification (ECL and PAR)

D. Radiological Emergency Manager x

[B.2] Facility/Group Management and Supervision x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[C.5] NRC Notification and Communications x

[G.1] Media Statements x

[I.2] Effluent Release and Dose Assessment x

[I.4] Radiological Field Monitoring Activities

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Columbia Generating Station Emergency Plan Page 19 of 98 x

[J.1] Site Assembly and Accountability x

[J.2] Site Evacuation x

[J.3] ERO Radiological Protection x

[J.4] Offsite Protective Action Recommendations x

[K.1] Emergency Exposure x

[L.2] Transport of Contaminated Injured Personnel x

[M.3] Post-Accident Environmental Sampling x

[Z.1] Facility Briefs and Updates E. Dose Assessor x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[F.1] ERF Communications and Information Display Systems x

[I.2] Effluent Release and Dose Assessment F. Field Team Coordinator x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[I.4] Radiological Field Monitoring Activities G. Field Monitoring Team Technician and Driver x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[H.1] Facility Activation

5. Joint Information System (JIS) / Joint Information Center (JIC)

CGS maintains a process to operate a JIS and support operation of the JIC. Refer to Section G for JIC/JIS details.

A. JIS/JIC Staff x

[A.2] Continuous Emergency Response Operations x

[B.3] ERO Mobilization and Response (persons receiving the notification) x

[F.1] ERF Communications and Information Display Systems x

[G.1] Media Statements x

[G.2] Media Briefings x

[G.3] Accommodation of News Media Personnel x

[G.4] Media Monitoring x

[G.5] Rumor Control x

[H.1] Facility Activation x

[H.2] Facility Operation

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Columbia Generating Station Emergency Plan Page 20 of 98 B.2 An individual is designated as the on-shift emergency coordinator (individual title may vary) who has the authority and responsibility to immediately and unilaterally initiate any emergency response measures, including approving protective action recommendations (PARs) to be disseminated to authorities responsible for implementing offsite emergency response measures.

The Emergency Director has overall command and control during a declared emergency, with the authority and responsibility to immediately and unilaterally initiate any emergency actions, including providing PARs to county and state authorities. Responsibilities also include coordinating the use of outside emergency response resources.

The Shift Manager is on-shift at all times, and assumes the role of Emergency Director upon declaration of an emergency. The Shift Manager is relieved of the role of Emergency Director by the EOF Manager through formal turnover when minimum staffing requirements have been met and the augmenting ERO are capable of performing their functions.

B.2.a The functional responsibilities assigned to the ERO are established and the responsibilities that may not be delegated to other members of the ERO are clearly specified in the emergency plan.

The Shift Manager is responsible for the following non-delegable responsibilities until relieved:

x Event declaration x

Notification of offsite authorities x

PARs for the general public x

Emergency Exposure (Dose limits and KI)

When the Shift Manager is relieved of overall command and control of emergency response, the non-delegable responsibilities of classification, notification and PARs are passed to the Emergency Director in the EOF.

Responsibility for emergency radiation exposure controls initially resides with the Emergency Director, but may be delegated to the TSC and EOF RP manager positions.

Approving departures from license conditions per 10 CFR 50.54(x) is the responsibility of the individual that holds the function of Emergency Director.

B.3 A table is developed depicting the site-specific on-shift staffing plan, as well as the ERO staffing augmentation plan. Table B-1, Emergency Response Organization (ERO) Staffing and Augmentation Plan, provides a model for licensees to consider.

The ERO is composed of on-shift personnel located at the site at all times and augmenting personnel who respond to their assigned emergency facility.

Refer to Table B-1 for the on-shift and augmenting ERO staffing plan.

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Columbia Generating Station Emergency Plan Page 21 of 98 Table B-1: On-Shift and Augmenting ERO Staffing Plan Function On-Shift Minimum Augmenting Staff Alert - 90 min.

Command and Control

Provide overall ERO command and control

Approve ECLs and PARs

Authorize personnel dose extensions (1) Shift Manager (1) EOF Manager - EOF Supervision of On-Site Response Activities

Direct station event response and repair activities Not applicable (1) TSC Manager - TSC Emergency Classifications

Evaluate plant conditions and recommend ECLs (1a) Classification Advisor (1) Asst EOF Manager - EOF Communications

Communicate ECLs and PARs to OROs and the NRC (1) S/C Notifier (1a) S/C Notifier (1) ENS Communicator (1a) S/C Notifier - EOF (1) Plant/NRC Liaison - TSC Supervision of RP Staff and Site Radiation Protection

Evaluate and assess plant and offsite rad data in the development of onsite protective actions and offsite PARs

Recommend onsite protective actions and offsite PARs

Direct all RP activities including FMTs

Provide information to personnel communicating offsite PARs to OROs (1a) Shift Manager (1) Rad Protection Manager - TSC (1) Rad Emergency Manager - EOF Dose Assessments/ Projections

Perform dose assessments and projections and provide input to PAR decision-maker (1a) Dose Assessor(b)

(1) Dose Assessor - EOF Radiation Protection

Provide RP coverage for accessing unknown radiological environments

Control dosimetry and RCA access

Provide in-plant surveys

Perform environmental surveys inside the PA prior to FMT activation (3) HP Technician (5) HP Technician - OSC Field Monitoring Teams(c)

Provide environmental surveys (inside and outside the Protected Area)

Not applicable (1) Field Team Coordinator - EOF (1) Onsite FMT Technician - EOF (2) Offsite FMT Technician - EOF (2) Offsite FMT Driver - EOF Engineering

Provide engineering coverage related to the specific discipline of the assigned engineer (1) STA or 3rd SRO (h)

(1) Core Thermal Engineer - TSC (1) Mechanical Engineer - TSC (1) Electrical Engineer - TSC Supervision of Repair Team Activities

Direct station event response and repair activities Not applicable (1) OSC Manager - OSC (1) Maintenance Lead - OSC (1) HP Lead - OSC

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Columbia Generating Station Emergency Plan Page 22 of 98 Function On-Shift Minimum Augmenting Staff Alert - 90 min.

Repair Team Activities

Provide support for event mitigation and equipment repair (c)

(1) Mechanic - OSC (1) Electrician - OSC (1) I&C Technician - OSC Security

Coordinate security related activities (1) SCC Duty Officer (1) Security Lieutenant Security staff(d)

Security staff(d)

Media Information

Manage and coordinate media information related to the event Not applicable JIS/JIC staff(e, f)

Information Technology (IT)

Provide IT support (g)

(g)

Totals 9

27 (a) Assigned as a collateral duty.

(b) SRO license holders (which include shift managers, control room supervisors and incident advisors) and STAs are available on-shift to perform offsite dose assessment at all times when needed.

(c) The four on-shift Operations Equipment Operators are assigned on-shift maintenance Repair Team roles (mechanical, electrical and I&C) as a collateral duty. One or more of the maintenance roles may be given to an individual from the maintenance organization provided all three maintenance areas (mechanical, electrical and I&C) remain represented by the four personnel assigned to this function.

(d) Per the CGS security plan.

(e) JIS staffed to address media inquiries within 60 minutes of an Alert emergency classification level.

(f) JIS/JIC staffed to perform related tasks. Activation of the JIC is coordinated with County and State representatives (positions and facility have no activation time requirement).

(g) IT personnel can monitor critical digital assets remotely and respond when an issue is identified.

(h) On Shift as required by Technical Specifications in Modes 1, 2, and 3. Available within 90 minutes for call-in for Modes 4 and 5.

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Columbia Generating Station Emergency Plan Page 23 of 98 B.4 The interfaces between and among the licensee functional areas of emergency activity, local services support, and state, local, and tribal government organizations are identified. The information includes all licensee emergency response facilities. A block diagram is preferred for ease of use, but not required.

Figure B-4 illustrates the interface between the ERO, state and county agencies, and local support organizations.

Figure B-4: Interrelationship of Emergency Response Organizations Dependent upon the emergency, a near or on-site Incident Command Post (ICP) is established in coordination with local support organizations. The ICP will interface with site security, and CGS response facilities.

OSC x

Plant Team Operations x

Assembly Area Control Room x

Initial Classification x

Initial Emergency Actions x

Reactor Control JIS/JIC x

Public Information x

Media Monitoring TSC x

Event Assessment x

Direction of Site Activities EOF x

Command & Control x

Offsite Agency Interface x

Radiological Dose Projections x

Field Team Operations x

Logistics Support x

Recovery Operations Private Support x

ANI x

APEL x

Framatone x

General Electric x

INPO x

Landauer Federal Support x

USCG x

USGS x

NWS Local Support x

Benton Co Sheriff x

Hanford FD x

Medical Centers State of Washington DHS FEMA NRC Benton County State of Oregon Franklin County DOE-RL

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Columbia Generating Station Emergency Plan Page 24 of 98 B.5 The external organizations, including contractors, that may be requested to provide technical assistance to and augmentation of the ERO, as applicable, are specified.

Private organizations and contractors are not used to provide additional personnel for positions on the ERO or to perform operational roles. Private organizations and contractors that may be requested to provide technical assistance or logistics support are:

1. American Nuclear Insurers (ANI)

ANI provides insurance coverage for CGS. If an accident occurs which affects the general public, ANI will provide financial assistance and reimbursement of reasonable expenses to persons required to relocate. ANI is notified as soon as possible after the declaration of an Alert, Site Area Emergency, or General Emergency, or if CGS believes that offsite persons may be affected, and financial assistance may be required.

2. Applied Process Engineering Laboratory (APEL)

APEL provides backup radiological analysis for plant and state laboratories.

3. Framatome The Framatome facility, located just outside the southern boundary of the Hanford Site, approximately eight miles south of CGS, maintains 24-hour health physics coverage of operations. Assistance is provided, when requested, to monitor environmental radiological conditions along the southern Hanford Site boundary.

4. General Electric Company The General Electric Company, supplier of the CGS nuclear steam supply system (NSSS),

provides a support program utilizing the resources of their Nuclear Energy Group. A site response team is dispatched to CGS within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of a request to provide technical assistance. The site response team will coordinate with the CGS engineering staff, or be used in the plant as needed. A General Electric technical support group will be staffed at their headquarters to establish communications with the onsite General Electric emergency response team to provide additional event and plant analysis resources.

5. Institute of Nuclear Power Operations (INPO)

INPO provides assistance in identifying and mobilizing the resources of the nuclear industry in the event of an emergency. INPO is notified of any emergency at the Alert or greater emergency classification level.

INPO maintains a dedicated 24-hour emergency notification system to provide the following assistance, when requested:

x Dispatch of INPO representatives to the site.

x Locate personnel with specific technical expertise.

x Obtain industry experience regarding plant equipment.

6. Landauer, Inc.

Landauer, Inc. provides dosimetry and dosimetry analysis services.

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Columbia Generating Station Emergency Plan Page 25 of 98 C:

Emergency Response Support and Resources Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate state and local staff at the licensees EOF have been made, and other organizations capable of augmenting the planned response have been identified.

Regulatory

References:

10 CFR 50.47(b)(3); 44 CFR 350.5(a)(3);

10 CFR Part 50, Appendix E, Sec. IV.E C.1 Emergency response support and resources provided to the licensees EOF, as agreed upon, are described.

The EOF contains dedicated work areas and logistics resources for federal, state and county response personnel. Federal, state and county personnel respond to the EOF in accordance with their emergency response plans and procedures.

C.2 Provisions made for additional emergency response support and resources are described and include the following:

C.2.a The individual(s), by title/position, authorized to request emergency response support and resources from responding organizations.

The Emergency Director is the individual authorized to request assistance and resources from responding organizations.

Refer to Element B.2.a for detail regarding command & control.

C.2.b (1) Each organization from which emergency response support and/or resources may be requested, (2) the circumstance(s) in which the emergency response support and/or resources would be required, (3) the process for requesting needed emergency response support and/or resources, (4) categories of capabilities and/or resources expected to be provided, (5) when the expected emergency response support and/or resources would be available once requested, and (6) how integration would occur.

Refer to Elements A.1.a and A.4 for a description and details of the provisions made for additional assistance and resources.

C.2.c Coordination of NPP site access and support for external organizations that have agreed to provide requested emergency response support and resources.

Site access is controlled at all times by the CGS Security organization in accordance with the site security plan and procedures.

Assistance for support organizations responding to the site is coordinated through the EOF.

C.2.d Agreements between licensees and local agencies for law enforcement, medical and ambulance services, fire, hospital support, and other support.

Assistance with firefighting, medical, and law enforcement activities is provided through the DOE-RL Hanford Fire Department, local hospitals, and Benton County Sheriffs Office.

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Columbia Generating Station Emergency Plan Page 26 of 98 Refer to Element A.1.a for details regarding arrangements for fire & rescue, ambulance service, and law enforcement support.

Refer to Element L.2.b for details regarding arrangements for hospital support.

If an emergency requires establishment of a near site Incident Command Post (ICP), the site will provide liaison(s) to the ICP to assist in coordinating response efforts.

Response agreements with DOE-RL, state and county response organizations have been established through the integrated development of their respective emergency plans. Support agreements with DOE-RL and private organizations have been formally developed and documented through LOAs, MOUs and/or contracts.

Refer to Element A.4 for details on agreements.

C.3 The capability of each principal organization to coordinate with other principal organizations leading the incident response is described.

In addition to response coordination efforts between individuals in command and control of each organization, CGS liaisons may be dispatched to the Washington State EOC, Benton County EOC, and Franklin County EOC. The CGS liaisons clarify information contained in emergency notifications and provide a communications link between the EOF and the offsite centers. CGS liaisons will normally be dispatched to Benton and Franklin County at the Alert or higher emergency classification. The CGS state liaison will normally report to the EOF at the Alert emergency classification level and be dispatched to the Washington State EOC at the Site Area Emergency classification level.

When NRC representatives are present in CGS emergency facilities, additional coordination occurs between those representatives and the CGS ERO. Coordination with these representatives prior to their arrival occurs via phone.

C.4 Radiological laboratories, their general capabilities, and expected availability to provide radiological monitoring analysis services that can be used in an emergency are described. Plans to augment the identified radiological laboratories are described.

CGS has a plant analytical laboratory located on site. The laboratory provides for analyses of plant samples from reactor coolant, process, and secondary systems, and of air and environmental samples obtained by field monitoring personnel.

Oregon and Washington maintain laboratories under the direction of their respective Departments of Health. These laboratories have the capability to identify, both qualitatively and quantitatively, the constituent elements contained in radiological releases from CGS during an event.

The Applied Process Engineering Laboratory (APEL) provides backup radiological analyses for the plant and state laboratories. If the plant analytical laboratory becomes unusable, plant samples can be transported to the APEL facility for analysis.

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Columbia Generating Station Emergency Plan Page 27 of 98 C.5 Arrangements are described for integrating the licensees response with the NRC Headquarters and regional incident response centers and, when dispatched, the NRCs site response team.

The TSC Manager and the EOF Manager are the initial primary contact positions for the NRC site response team personnel sent to those facilities.

Areas within the EOF and TSC are established for NRC site response teams that including:

x Space for members of an NRC site team x

Additional space for conducting briefings with emergency response personnel x

Communication with other CGS and offsite emergency response facilities x

Access to plant data and radiological information x

Access to copying equipment and office supplies C.5.a The activation process for the NRCs emergency response data system (ERDS) during an emergency is described.

When an emergency occurs, ERO personnel will initiate Emergency Response Data System (ERDS) operation as soon as possible but not later than one hour after an alert or higher emergency classification level is declared, in accordance with 10 CFR 50.72(a)(4).

C.5.b Provisions to continuously maintain open communications lines with the NRC, when requested, are described.

The ERO is capable of maintaining continuous communications with the NRC. When requested, an open communication line is staffed by knowledgeable personnel (i.e., personnel with operations/licensing background for the ENS line, and radiological background for the HPN line) to ensure efficient and effective information flow.

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Columbia Generating Station Emergency Plan Page 28 of 98 D:

Emergency Classification System A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and state and county response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

Regulatory

References:

10 CFR 50.47(b)(4); 44 CFR 350.5(a)(4);

10 CFR Part 50 Appendix E.IV.B and C D.1 A standard emergency classification and action level scheme is established and maintained. The scheme provides detailed EALs for each of the four ECLs in Section IV.C.1 of Appendix E to 10 CFR Part 50.

CGS has established and maintains a standard Emergency Classification Level (ECL) and Emergency Action Level (EAL) scheme. The spectrum of postulated emergency events is categorized into the following four (4) ECLs:

x Unusual Event x

Alert x

Site Area Emergency x

General Emergency The four ECLs are defined as follows:

1. Unusual Event (UE)

An ECL indicating that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

2. Alert An ECL indicating that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of hostile action. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

3. Site Area Emergency (SAE)

An ECL indicating that events are in progress or have occurred which involve an actual or likely major failure of plant functions needed for protection of the public or hostile action that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) prevents effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the site boundary.

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Columbia Generating Station Emergency Plan Page 29 of 98

4. General Emergency (GE)

An ECL indicating that events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile action that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

D.1.a The EALs are developed using guidance provided or endorsed by the NRC that is applicable to the reactor design.

CGS EALs have been developed in accordance with NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. This guidance has been endorsed and the CGS EAL scheme has been approved by the NRC.

The CGS EALs and their technical bases are considered as part of the formal emergency plan by extension. Refer to Introduction Section 2.0.

If the entire EAL scheme is to be changed, then the new EAL scheme will be submitted to the NRC for approval prior to implementation.

D.1.b The initial emergency classification and action level scheme is discussed and agreed to by the licensee and OROs, and approved by the NRC. Thereafter, the scheme is reviewed with OROs on an annual basis.

The NRC approved EAL scheme has been agreed to by DOE-RL, Washington State, Benton County, and Franklin County.

The current EAL scheme is provided to DOE-RL, Washington State, Benton County, and Franklin County for review on an annual (once per calendar year) basis.

D.2 The capability to assess, classify, and declare the emergency condition within 15 minutes after the availability of indications to NPP operators that an EAL has been met or exceeded is described.

CGS maintains the capability to assess, classify, and declare an emergency within 15 minutes after availability of indications to individuals (in the Control Room or EOF) responsible for assessing and classifying events that an EAL threshold has been met or exceeded. Event declaration is complete when the Emergency Director declares the emergency classification level.

The 15 minute criteria is not used to prevent implementation of plant response actions deemed necessary to protect public health and safety provided that any delay in declaration does not deny the state and local authorities the opportunity to implement measures necessary to protect the public health and safety.

After initial emergency declaration, the Emergency Director continually assesses conditions to determine whether the emergency classification level must be upgraded.

Offsite events occurring at nearby Hanford Site facilities or hazardous materials transportation accidents are classified under CGS EALs when onsite conditions meet the criteria in Emergency Plan Implementing Procedure (EPIP) 13.1.1A.

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Columbia Generating Station Emergency Plan Page 30 of 98 D.3 A summary of emergency response measures to be taken for each ECL is provided. The detailed emergency response measures are described in implementing procedures.

CGS maintains procedures that provide response actions to be taken under the four emergency classification levels.

Emergency Operating Procedures (EOPs) provide instruction to Control Room personnel to assist in mitigating the consequences of a broad range of accidents and multiple equipment failures. These procedures are based on guidelines developed by the owners group.

EPIPs provide instructions to ERO personnel for response activities primarily associated with coordination, assessment, classification, notification, and protective actions. Other functions such as augmentation, communications, termination, and recovery are also addressed.

A summary of emergency response measures for each emergency classification level are identified below.

Emergency Response Measure UE Alert SAE GE ERO Augmentation (1)

X X

X State, County and NRC Notification X

X X

X JIS Established X

X X

Site Assembly and Accountability X

X Site Evacuation X

X Offsite Precautionary/Protective Action Recommendations (2)

X (1) Augmentation of the ERO at an Unusual Event emergency classification level is at Shift Managers discretion.

(2) Declaring a Site Area Emergency classification level initiates precautionary actions to evacuate recreational areas and schools in the EPZ.

Additional measures not listed may be taken based on event progression (e.g., emergency exposure controls, effluent release environmental monitoring, local onsite protective actions).

D.4 Emergency response measures based on the ECL declared by the licensee and applicable offsite conditions are described.

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 31 of 98 E:

Notification Methods and Procedures Procedures have been established for notification, by the licensee, of state and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ have been established.

Regulatory

References:

10 CFR 50.47(b)(5); 44 CFR 350.5(a)(5);

10 CFR Part 50 Appendix E.IV.A, C, D and E E.1 The mutually agreeable process for direct and prompt notification of response organizations, aligned with the emergency classification and action level scheme, is described.

1. ERO Notification The Shift Manager will direct or perform ERO notification by use of the in-plant paging system and an automated notification system (Auto-Dialer) at any emergency classification level. The Auto-Dialer is normally initiated by the SCC Duty Officer.

Activation of the ERO is required at the Alert emergency classification level or higher, and discretionary at the Unusual Event emergency classification level. However, the Emergency Director may call upon additional personnel to support event response activities at any level.

ERO personnel report to their assigned emergency response facilities when directed. In the event of a security threat, The ERO may be instructed to report to the alternate facility, or seek cover on-site. Additionally, the ERO is trained to automatically respond to their assigned emergency response facilities or the alternate facility when made aware of an area wide loss or degradation of the electrical grid or phone system (e.g., by direct observation, media report, word of mouth, etc.).

The means for notifying ERO members are described in Element F.1.c.

2. DOE-RL, State, and County Event Notification Initial notification to DOE-RL, Benton County, Franklin County, and Washington State are made from the Control Room or the EOF within 15 minutes of declaration of an emergency classification level.

DOE-RL is responsible for notifying other Hanford Site area facilities of a CGS declared emergency, and notifying CGS of a declared emergency at another Hanford Site area facility.

Washington State is responsible for notifying Oregon State.

Typically, follow-up messages are provided to DOE-RL, Benton County, Franklin County, and Washington State every one hour to two hours. For long duration events with little change in information between messages, the follow-up message time interval can be increased as agreed upon. However, changes in event information that do not meet the requirements for an initial notification may warrant a follow-up message at any time.

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Columbia Generating Station Emergency Plan Page 32 of 98

3. NRC Event Notification CGS will notify the NRC as soon as possible after notification of the state and county agencies, and not later than later than one hour after emergency declaration.

An accelerated call to the NRC will be made after notification of local law enforcement agencies (LLEAs), or within about 15 minutes, following the recognition of a security-based threat (discovery of an imminent threat or attack against the site), to ensure the NRC is notified of safeguards events. The information provided in the accelerated notification will be limited to the following:

x Site name x

ECL if determined prior to the accelerated notification x

Nature of the threat and the attack status E.1.a Provisions for notification of response organizations are established, including the means for verification of messages.

The provisions for notification of response organizations are described in Element E.1.

Initial notification to DOE-RL, state, county, and the NRC includes a means of verification or authentication.

E.1.b The capability to notify responsible OROs within 15 minutes and the NRC within 60 minutes is described.

The capability to notify DOE-RL, state, and county organizations, and the NRC within the required time periods is described above in Element E.1.

E.2 The alert and notification systems (ANSs) used to alert and notify the general public within the plume exposure pathway EPZ and methods of activation are described. This description includes the administrative and physical means, the time required for notifying and providing prompt instructions to the public within the plume exposure pathway EPZ, and the organizations or titles/positions responsible for activating the system.

The Early Warning System (EWS) is designed to alert and provide information to the population in the PEP EPZ.

Sirens are the primary means of alert and prompt notification in the residential, commercial, agricultural, and recreational areas of the CGS 10-mile EPZ (nominally outside the boundaries of the DOE-RL Hanford Site) and within the public recreation areas along the Columbia River.

Details on the design, testing, and maintenance of the sirens are provided in the ANS design report, which is considered part of the CGS Emergency Plan. CGS is responsible for testing, maintenance, and repair of the sirens.

Sirens are supplemented by tone alert radios for a small, special communication needs population (e.g., selected schools and/or residents who identify themselves to their respective county emergency management officials as having hearing impairment-related special communication needs). An Emergency Telephone Notification System (ETNS) serves as the backup ANS.

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Columbia Generating Station Emergency Plan Page 33 of 98 Benton County EOC is responsible for notifying the public in Benton County. Franklin County EOC is responsible for notifying the public in Franklin County.

The DOE-RL maintains a system for notifying and providing information to its employees and contractors on the Hanford Site.

E.3 The licensee and state, local, and tribal government organizations establish the contents of the initial and follow-up emergency notifications to be sent from the NPP.

The content of, and any changes to, initial and follow-up messages are coordinated with DOE-RL, state, and county representatives.

The minimum content of the initial notification contains the following information:

x Site name x

Time of event declaration x

The emergency classification level x

Wind speed and direction x

Whether a release is in progress due to the event x

Protective Action Recommendation (PAR), if applicable Follow-up message content includes additional information regarding event conditions and response actions (such as radiological release details, offsite support, event prognosis, etc.).

E.4 Each organization establishes the contents of the initial and follow-up messages to the public including, as applicable, instructions for protective actions.

This element is not applicable to the licensee emergency plan.

E.5 Provisions are made to provide timely supplemental information periodically throughout the radiological incident to inform the public.

Emergency notification to resident and transient populations is the responsibility of Benton and Franklin County agencies. Notification instructions are based on information received from CGS and, if time permits, consultation with the staffs of the Benton County EOC, Franklin County EOC, and Washington State EOC.

Resident and transient populations are instructed to monitor the Emergency Alert System (EAS) for emergency announcements and protective action instructions in public information material.

The initial instructions will consist of prescribed emergency messages consistent with the emergency classification level. EAS messages broadcast over the siren system are contained in the Benton and Franklin Counties emergency response plans.

CGS will assist with the establishment of appropriate instructions and message content when requested.

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Columbia Generating Station Emergency Plan Page 34 of 98 F:

Emergency Communications Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

Regulatory

References:

10 CFR 50.47(b)(6); 44 CFR 350.5(a)(6);

10 CFR Part 50, Appendix E.IV.E F.1 Each principal response organization establishes redundant means of communication and addresses the following provisions:

F.1.a Continuous capability for notification to, and activation of, the emergency response network, including a minimum of two independent communication links.

CGS maintains communications systems that are designed to facilitate normal and emergency communication. The communications systems are continuously available between CGS, DOE-RL, state, county, and NRC personnel. Suitable normal and backup power supplies are provided. Cellular and satellite telephones provide additional voice communications capability.

Communications systems described in FSAR Section 9.5.2 include:

x Public Telephone Access System x

Private Branch Exchange x

Sound Powered Telephone System x

Public Address and Building-Wide Alarm Systems x

Radio Communications System Additional communications systems used for emergency response include:

1. Energy Northwest Emergency Center Network The Energy Northwest Emergency Center Network is a dedicated circuit that interconnects the plant and emergency centers. The network uses a push button system in which the caller selects the area to be called and pushes the appropriate button which in turn automatically rings into the selected area.

2. CGS Telephone Systems CGS's phone systems are computer based and software controlled, equipped with redundant processor units, and are served by multiple uninterruptible power supplies.

Telephone locations include the Control Room, TSC and OSC, EOF, and Energy Northwest's Office Complex (ENOC).

3. Response Agency Network (Crash Line)

The Response Agency Network is a dedicated circuit that connects the CGS emergency response facilities with state and local emergency centers. Facilities serviced by these dedicated lines are Control Room, TSC, EOF, JIC, Alternate EOF and TSC, DOE-RL, Benton County EOC, Franklin County EOC, Washington State EOC, and SECOMM Dispatch Center. The network has a crash function, which operates by dialing a unique activator number that automatically rings all the phones on the system.

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Columbia Generating Station Emergency Plan Page 35 of 98 F.1.b Communication with applicable organizations to include a description of the methods that may be used when contacting each organization.

1. State and County Communications Initial and follow-up notification messages to DOE-RL, state and county warning points, and/or state and county emergency centers are performed using the Response Agency Network and transmission of the Classification Notification Form (CNF).

2. NRC Communications Links The Federal Telephone System (FTS) is available for establishing contact with the NRC Operations Center in Rockville, Maryland. Telephones have been designated for the following NRC communications:

A. Emergency Notification System (ENS) - The ENS provides a communications link used for initial notifications and continuous communications in a classified emergency.

B. Health Physics Network (HPN) - The HPN provides a communications link used to provide radiological information.

ENS and HPN phones are located in the Control Room, TSC, EOF and the Alternate EOF.

Refer to Element H.7 for Emergency Response Data System (ERDS) information.

3. Local Organization Communications Communications between CGS and the local support agencies (fire, medical, and law enforcement) are by telephone.

F.1.c Systems for alerting or activating emergency personnel in each response organization.

Personnel within the Protected Area are notified of the emergency classification via the public address system. The sounding of an alert tone, announcement of the emergency classification, and other pertinent data relating to the emergency classification are made over the public address system.

Notification of personnel located onsite but outside the Protected Area is accomplished through site-wide public address announcements, wireless communication devices, administrative controls, and by Security personnel.

High noise evacuation devices, composed of a radio-controlled siren and strobe light, are located in selected areas throughout the plant. These devices are activated by the PA alerting tone.

The Auto-Dialer is used to notifying ERO members of a declared emergency and consists of an onsite primary computer system and an offsite backup computer system. The Auto-Dialer is capable of communicating a message, verbally and by text, on ERO member phones.

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Columbia Generating Station Emergency Plan Page 36 of 98 F.2 Systems for coordinated communication methods for applicable fixed and mobile medical support facilities are described.

Communications methods have been coordinated with medical support providers (ambulance and local medical facilities). Radio communications are available with the ambulance service.

Communications to local medical facilities is via telephone.

F.3 The testing method and periodicity for each communication system used for the functions identified in evaluation criteria E.2, F.1, and F.2 are described.

Communications tests are conducted and documented on the following frequency:

x Communications systems with DOE-RL, state, and county warning points within the plume exposure pathway EPZ will be tested monthly.

x Communications systems from the CR, TSC, and EOF to NRC headquarters will be tested monthly.

x The ERDS will be verified to transmit data on a quarterly basis.

x Communications systems between CGS ERFs will be tested annually.

x Communications systems between CGS, Washington State EOC, Benton County EOC, and Franklin County EOC, and field monitoring teams will be tested annually.

x Emergency Alert System testing frequency is described in the ANS Design Report.

NRC and DOE-RL are the federal emergency response organizations CGS communicates directly with, where provisions are maintained for monthly communications tests. There are no federal emergency response organizations applicable to CGS that require annual communications testing.

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Columbia Generating Station Emergency Plan Page 37 of 98 G:

Public Education and Information Emergency planning information is made available to the public on a periodic basis and includes information on how they will be notified and what actions they may be asked to take (e.g.,

listening to a local broadcast station, remaining indoors, etc.). Information will also be provided to the news media to include principal points of contact to receive information (including the physical location(s)) and information about the coordinated dissemination of information from all agencies engaged in the response.

Regulatory

References:

10 CFR 50.47(b)(7); 44 CFR 350.5(a)(7);

10 CFR Part 50, Appendix E.IV.D and F G.1 Provisions are made for a coordinated annual dissemination of information to the public within the plume exposure pathway EPZ, including transient populations and those with access and functional needs, regarding how they will be notified and what actions should be taken. The information is disseminated using multiple methods, to include non-English translations per current Federal guidance.

1. Public Information CGS, in coordination with the DOE-RL, Washington State, and Benton County, and Franklin County updates and distributes site related emergency planning information, in the form of printed or electronic materials, annually (once per calendar year) to resident populations within the PEP EPZ. Such information includes:

x Educational information on radiation.

x Warning methods used in notification of the public.

x Recommended protective measures.

x Selected evacuation routes and assistance centers.

x Personnel or agencies to be contacted for additional information.

Brochures are made available at designated recreational facilities within the PEP EPZ for transient populations.

Information for residents with access and functional needs and non-English translations is incorporated per current federal guidance.

2. Warning Signs Warning signs providing public notice are posted and maintained at selected areas frequented by transient members of the public within the PEP EPZ. The signs inform the transient members of the public that upon hearing a steady siren tone to leave the area immediately and tune to the local EAS frequency.

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Columbia Generating Station Emergency Plan Page 38 of 98 G.2 Methods, consistent with JIS concepts, are established for coordinating and disseminating information to the public and media. Plans include the physical location(s) for interacting with the media.

Energy Northwest communications personnel maintain processes for coordination of information with other organizations, and methods and means to provide public information using JIS concepts. The JIS provides a structure and system for:

x Developing and delivering coordinated messages.

x Developing, recommending, and executing public information plans and strategies.

x Monitoring for and responding to rumors and inaccurate information.

The JIS is functional within 60 minutes of an Alert emergency classification level.

The JIC is located approximately 10 miles south of the plant in the ENOC. Response personnel typically report to the JIC at an Alert emergency classification, and it is activated in coordination with DOE-RL, state, and county representatives.

G.3 Organizations designate news media points of contact and a spokesperson(s) with access to necessary information.

A spokesperson is designated as the primary public information point of contact for CGS and is responsible for the consistency of the information released by the utility. The spokesperson may select individuals to address the public on behalf of CGS as their respective expertise is needed.

G.3.a Arrangements are made for the timely exchange of information among the designated spokespersons representing the entities involved in incident response.

Arrangements are made for the timely exchange of information among the designated spokespersons that use various means and technologies (i.e., face-to-face, phone, text, email, conference bridge lines, etc.) as agreed upon by the particular agencies. CGS provides information and updates to address the emergency to include plant conditions and associated response actions. DOE-RL, state, and county representatives will address agency response and public actions.

G.4 Organizations establish coordinated arrangements for identifying and addressing public inquiries and inaccurate information.

Energy Northwest communications personnel monitor media and public sources for misleading or erroneous information and to address inquiries. JIS/JIC personnel coordinate with DOE-RL, state, county, and federal public information officers via the JIS, or in a JIC, to address rumors and correct misinformation.

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Columbia Generating Station Emergency Plan Page 39 of 98 G.5 Organizations conduct programs to acquaint news media with the emergency plans at least annually.

The news media is invited to participate in an annual (once per calendar year) outreach program to acquaint them with CGS emergency preparedness, radiation hazards, and to provide contact information for further media related dialog. Typical information provided to the media during the outreach includes:

x Site information.

x Overview of the JIS.

x The response organization.

x ECLs and PARs.

x JIC operations.

x Emergency educational information for the public.

x Points of contact for release of information to the media during an emergency.

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Columbia Generating Station Emergency Plan Page 40 of 98 H:

Emergency Facilities and Equipment Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

Regulatory

References:

10 CFR 50.47(b)(8); 44 CFR 350.5(a)(8);

10 CFR Part 50, Appendix E.IV.E H.1 A TSC is established, using current Federal guidance, from which NPP conditions are evaluated and mitigative actions are developed.

The Technical Support Center (TSC) is a dedicated facility attached to the Radwaste Building on the west side of the plant. The TSC is sized to accommodate ERO responders and several NRC representatives.

The TSC is activated at an Alert or higher emergency classification level when minimum staffing requirements are met, key systems and equipment are verified operational, and ERO personnel are prepared to perform their functions.

Functions of the TSC are to provide management and technical support to operations personnel, and to relieve the shift staff of emergency response actions and communications not related to plant operations. Specifically, the TSC is used to monitor and assess event and plant conditions, direct onsite protective and response actions, and plan response activities.

TSC primary power is supplied by a plant power circuit, with back-up by diesel generator.

TSC habitability design requirements are the same as the Control Room. The TSC and Control Room share common air intake structures (local and two remote intakes), and the TSC ventilation HEPA filters and charcoal absorbers are the same type as those used for the Control Room. Radiological monitoring equipment is available to continuously monitor dose rates and airborne radioactivity concentrations in the TSC.

The TSC has voice communications with the Control Room, OSC, EOF, ENOC, NRC, and state and county emergency centers.

Protective equipment such as respirators and potassium iodide are maintained in the TSC.

Dedicated workstations with access to the plant LAN are maintained in the TSC to obtain plant parameter Information and meteorological data from the Plant Process Computer (PPC) system, and to utilize response related applications. Displays are used to provide key information in the facility. The TSC has ready access to plant records, drawings and other plant related documentation.

H.2 An OSC is established, using current Federal guidance, from which repair team activities are planned and teams are dispatched to implement actions.

A dedicated portion of the TSC building serves as the OSC for the ERO to provide planning and coordination of in-plant and on-site response activities and for staging emergency personnel and equipment. The OSC is sized to accommodate ERO responders.

The OSC is activated at an Alert or higher emergency classification level when minimum staffing requirements are met, key systems and equipment are verified operational, and ERO personnel are prepared to perform their functions.

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Columbia Generating Station Emergency Plan Page 41 of 98 Functions of the OSC are to plan plant and equipment response activities, coordinate and dispatch repair teams, and to monitor and track in-plant radiation levels and personnel exposure.

The OSC has voice communications with the with the Control Room, TSC, EOF, and to dispatched repair teams using portable radios.

Equipment and supplies are available to the OSC for repair team use.

Dedicated workstations with access to the plant LAN are maintained in the OSC to obtain plant parameter Information and meteorological data from the PPC system, and to utilize response related applications such as the Radiation Protection Dose Tracking and Control System.

Displays are used to provide key information in the facility. The OSC has ready access to plant records, drawings and other plant related documentation.

H.3 An EOF is established, using current Federal guidance, as the primary base of emergency operations for the licensee during a radiological incident. The EOF facilitates the management and coordination of the overall emergency response, including the sharing of information with Federal, state, local, and tribal government authorities.

The EOF is a dedicated facility located 0.75 miles southwest of CGS in the shielded lower level of the Kootenai Building. The EOF is sized to accommodate ERO and ORO responders, and several NRC representatives to coordinate actions. Specific areas in the EOF are designated to be utilized by various offsite response organizations.

The EOF is activated at an Alert or higher emergency classification level when minimum staffing requirements are met, key systems and equipment are verified operational, and ERO personnel are prepared to perform their functions.

Functions of the EOF are to provide a location for overall command and control and coordination of licensee activities, and to relieve the shift staff of emergency response actions and communications not related to plant operations. Specifically, the EOF is used to escalate or terminate the event, perform notifications and external communications, develop PARs, perform field monitoring and dose projections activities, coordinate security and site access activities, provide administrative and logistics support for response personnel, assist public information personnel with technical information, and plan recovery activities.

EOF capabilities include obtaining and displaying plant data and radiological information, analyzing plant technical information, and providing technical briefings on event conditions and prognosis to CGS and offsite response personnel.

An emergency power generator supplies the EOF during power loss.

The EOF is a protected area in the Kootenai Building which has special shielding and ventilation to maintain habitability requirements.

The EOF provides for communications with the Control Room, TSC, OSC, state and county emergency centers, and the NRC via phone systems, and to dispatched field monitoring teams.

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Columbia Generating Station Emergency Plan Page 42 of 98 Dedicated workstations with access to the plant LAN are maintained in the EOF to obtain plant parameter Information and meteorological data from the PPC system, and to utilize response related applications such as URI/RASCAL. Displays are used to provide key information in the facility. The EOF has ready access to plant records, drawings and other plant related documentation.

H.3.a For an EOF that is located more than 25 miles away from the NPP site, provisions are made for locating NRC and offsite responders closer to the NPP site.

This element does not apply as the CGS EOF is not located more than 25 miles from the site.

H.4 An alternative facility (or facilities) is established, using currently provided and/or endorsed guidance, which would be accessible even if the NPP site is under threat of or experiencing hostile action.

1 Alternate EOF The Alternate EOF is located approximately 10 miles south of the plant in the ENOC. This facility may be activated if the primary EOF becomes uninhabitable or inaccessible.

The emergency functions of command and control, classification, notification, protective action recommendations, dose projection and field team dispatch and control may be provided from this facility.

The Alternate EOF has the capability to communicate with the Control Room, TSC, on-site EOF, field teams, and offsite agencies. A crash phone and NRC ENS phone are available to provide event notification to offsite agencies.

Primary and backup emergency power are available to supply the Alternate EOF and its telephone system.

2 Alternate TSC / OSC Staging Facility The alternate TSC / OSC staging facility is located approximately 10 miles south of the plant in the ENOC for the staging of ERO personnel in the event of site access restrictions or a Hostile Action threat against the site. The alternative facility may also serve as an evacuation location for TSC and OSC personnel should the onsite TSC / OSC become uninhabitable.

The alternate TSC / OSC staging facility can communicate with the Control Room, site security, and EOF. Engineering assessment activities, including damage control team planning and preparation, can be performed from the alternate TSC / OSC staging facility.

H.5 A JIC is established, and its location is identified, to coordinate communication from Federal, state, local, and tribal government authorities and licensee personnel with the public and media.

Refer to Section G for details regarding the CGS JIC and JIS.

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Columbia Generating Station Emergency Plan Page 43 of 98 H.6 Each organization establishes an emergency operations center (EOC) for use in directing and controlling response functions, and provides for timely EOC activation. For an EOC located within the plume exposure pathway EPZ, an alternate EOC, or location outside the plume exposure pathway EPZ, is identified to continue response functions in the event of an evacuation.

This element is not applicable to the licensee emergency plan.

H.7 Onsite monitoring systems used to initiate emergency response measures in accordance with the emergency classification scheme, as well as those to be used for conducting assessment, are identified. Monitoring systems consist of geophysical phenomena monitors, including meteorological, hydrologic, and seismic instrumentation; radiation monitors and sampling equipment; plant process monitors; and fire, toxic gas, and combustion products detectors.

CGS has instrumentation for meteorological monitoring, hydrologic monitoring, seismic monitoring, radiation monitoring, and fire/toxic gas/combustion products detectors in accordance with Current Licensing Basis (CLB) documents.

1. Meteorological Instrumentation The 240-foot primary meteorological tower is located approximately 2500 feet west of CGS.

Primary and redundant instruments are located on the meteorological tower that provide near real-time measurements (computer averaged 15-minute data) of wind speed, wind direction, and temperature differential used for emergency response. Meteorological tower data is available in the Control Room, TSC, and EOF.

Refer to FSAR Chapter 2.3 for a description of the CGS meteorological monitoring system.

2. Hydrologic Instrumentation CGS is located approximately three miles west of the Columbia River with reactor floor elevation 68 ft above the water level estimated for the largest historical flood. The results of the FSAR analyses (which considers storm winds wave action, failure of upstream dam surge flooding, and ice flooding) indicate that the site is safe from floods and that no flood protection measures are required.

Refer to FSAR Chapter 2.4 for information regarding site hydrology.

3. Seismic Instrumentation The seismic monitoring system consists of two forms of monitoring instrumentation, the strong motion triaxial accelerometers and the peak recording accelerometers. The strong motion triaxial system is composed of seismic triggers, control panel, recorder, panels, accelerometers, and power supply. The accelerometers for these two systems have been placed in various locations throughout the plant in such positions as to minimize inadvertent system activations.

Refer to FSAR Chapter 3.7.4 for a description of the seismic instrumentation.

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Columbia Generating Station Emergency Plan Page 44 of 98

4. Process and Area Radiation Monitors Process Radiation Monitors (PRMs) measure radioactive noble gas, iodine, and particulate concentrations in gaseous effluent pathways and gross radioactivity in other gaseous and fluid streams, and are used for event recognition and assessment.

Area Radiation Monitors (ARMs) measure local and remote in-plant radiation levels. This information is used to aid in the determination of plant area accessibility, for protective actions, and for event recognition and assessment.

Refer to FSAR Chapters 11 and 12 for the descriptions of the PRM and ARM systems.

5. Portable Radiation Monitoring Equipment Portable radiation monitoring equipment is available for uses such as area monitoring, sampling, personnel surveys, accident assessment, and event recognition and declaration.

6. Sampling Systems Liquid and gaseous sampling systems, consisting of normal sampling systems and panels located throughout the plant may be used to aid in event recognition and declaration.

Refer to FSAR Chapters 11.5 and 11.6 for a description of the sampling systems.

7. Fire Detection Systems The fire detection system, consisting primarily of fire/smoke detectors, control panel units, and annunciator panels located throughout the plant are used for event recognition and declaration.

Refer to FSAR Appendix F and in the CGS Fire Protection Evaluation for a description of the fire detection and protections systems.

8. Data Acquisition and Display Systems The CGS Safety Parameter Display System (SPDS) is made up of hard wired Control Room instrumentation to allow rapid assessment of plant conditions. The SPDS provides information related to assessment of the following plant functions:

x Reactivity control x

Reactor core cooling and heat removal x

Reactor coolant system integrity x

Radioactivity control and x

Containment integrity A plant data center, referred to as the Plant Process Computer (PPC), is installed at CGS to provide data acquisition and analysis needs in support of emergency response facility functions. The PPC collects and multiplexes plant analog and digital data to a central location for storage and emergency response facility functions such as ERDS, and provides graphic display capability in the response facilities.

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Columbia Generating Station Emergency Plan Page 45 of 98 ERDS provides direct electronic data transmission of required plant parameters from the PPC to the NRC Operations Center via a modem.

Refer to FSAR Chapter 7 for a description of the data acquisition and display systems.

H.8 Provisions are made to acquire data from offsite monitoring and analysis equipment, including data on geophysical phenomena (e.g., meteorological, hydrologic, and seismic monitors) and radiological data (e.g., from FMTs, environmental dosimeters, and laboratory analyses).

1. Meteorological Monitoring Offsite meteorological data can be acquired from DOE-RL sources if the CGS meteorological system is unavailable.

As back-up, NOAA Weather Service Forecast broadcasts can be obtained available via the internet, or by phone and weather radios.

2. Hydrologic Monitoring Columbia River hydrologic information is available from Benton or Franklin Counties or the National Weather Service.

3. Seismic Monitoring Seismic information from offsite sources can be obtained from the National Earthquake Information Center. The USGS is the contact agency to obtain information about a seismic event.

4. Radiological Environmental Monitoring Offsite programs and processes are developed within the Radiological Environmental Assessment Program (REMP) as described in the Offsite Dose Calculation Manual (ODCM).

The Radiological Environmental Assessment Program includes:

x Fixed continuous air samplers x

Routine sampling of water, vegetation, consumable products x

A fixed dosimeter monitoring network The locations of the normal onsite and offsite environmental monitoring stations are described in the ODCM.

Site specific details of the radiological environmental assessment program are provided in the ODCM.

5. Laboratory Facilities, Fixed or Mobile Refer to Element C.4 for details on facilities for counting and analyzing samples.

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Columbia Generating Station Emergency Plan Page 46 of 98 H.9 Organizations directly responsible for offsite radiological monitoring provide for radiological monitoring equipment. This includes equipment that is located or stored near the NPP site, as well as additional equipment that may be brought to the site.

CGS maintains a sufficient supply of emergency equipment (such as portable survey, counting, air sampling instrumentation, and other radiological monitoring equipment and supplies) to supply one field monitoring individual operating inside the Protected Area and two Field Monitoring Teams operating outside the Protected Area.

H.10 Instrumentation is provided to obtain current meteorological information. Additional provisions are made to obtain representative meteorological information from other sources as needed by the NPPs radiological assessment models for site-specific characterization of plume dispersion and transport. Meteorological information is provided to the control room, TSC, EOF (or backup EOF), and NRC (via ERDS).

Meteorological inputs for the dose assessment model are acquired from the PPC, which displays meteorological tower data used for dose assessment.

Refer to Element H.7.1 for a description of the onsite meteorological monitoring capabilities.

Refer to Element H.8.1 for a description of the offsite meteorological monitoring capabilities.

Meteorological data is available on PPC workstations in the Control Room, TSC, and EOF.

ERDS provides the NRC with selected meteorological data points on a near real-time basis.

Refer to Element H.7.8 for a description of the ERDS.

H.11 Provisions are made to ensure that emergency equipment and supplies are tested, maintained, and available in sufficient quantities, to include reserves and replacements, when needed. This includes:

H.11.a Identification of the organization(s) responsible for the testing and maintenance of emergency equipment.

EP personnel provide oversight for the maintenance and testing of EP related equipment.

CGS emergency facilities and emergency kits are inventoried by personnel from emergency preparedness and other station organizations to verify adequate supplies and materials, check expiration dates, inspect condition, and operationally check equipment/instruments.

Emergency use equipment and instruments are operationally checked semi-annually during the inventory, and prior to use if needed as specified in procedures.

Sufficient reserves of instruments and equipment are maintained to replace instruments removed from kits for repair or calibration.

H.11.b Calibration and operational checks of emergency equipment per national standards or the manufacturers instructions, whichever is more frequent.

Equipment designated for emergency use is calibrated at the intervals recommended by the manufacturer or as specified in site procedures.

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Columbia Generating Station Emergency Plan Page 47 of 98 H.12 Emergency kits are identified by general category. Contents and quantity of each emergency kit are specified in the emergency plan or other document(s) referenced in the emergency plan.

CGS emergency plan related equipment and supply kits are:

x Decontamination Kits - Two kits are located in the Radwaste Building decontamination area, and one is located in the Yakima Building (GSB) Emergency Equipment Area.

x Protective and Radiological Monitoring Equipment Kit - Kit is located in the TSC.

x Field Monitoring Kits - Kits containing protective gear, radiological monitoring equipment, communications equipment and emergency supplies are located at the EOF and ENOC.

x Hospital Radiological Emergency Kits - Kits containing protective equipment, radiological monitoring equipment and decontamination supplies for use in the care of radiation accident patients are located at the medical facilities described in Element L.2.c.

CGS emergency plan implementing procedures used to inventory and maintain facilities and equipment are listed in Table P.7-1.

H.13 Each organization identifies the location(s) for the receipt and analysis of field monitoring data and coordination of sample media, and identifies the organization(s) responsible for assessing radiological data.

The EOF is the primary location for receipt of field monitoring data and coordination of team sample media. The EOF is responsible for direction and coordination of field monitoring sample analyses, and for assessing the radiological data obtained from the Field Monitoring Teams.

Sampling and analysis equipment are available (see Element C.4) for quantitative activity determination of liquid and air samples, and qualitative activity determination of terrestrial samples.

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Columbia Generating Station Emergency Plan Page 48 of 98 I:

Accident Assessment Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Regulatory

References:

10 CFR 50.47(b)(9); 44 CFR 350.5(a)(9);

10 CFR Part 50, Appendix E.IV.A, B and E I.1 Capabilities for performing radiological assessment for all reactor core and spent fuel pool sources, individually and collectively, including response to events occurring simultaneously at all units on the NPP site, are described. These capabilities include:

I.1.a Methods for determining the magnitude and isotopic composition of an ongoing release of radioactive material through waterborne or airborne release pathways, or estimating these parameters for a potential release.

The magnitude of a release of radioactive material to the environment is primarily identified directly by effluent monitors. Survey and sample analysis may also be used to determine the magnitude of a release. Indirect means such as core damage estimates and release pathway assumptions may be used to estimate the magnitude of a release of radioactive material.

The isotopic composition of a release of radioactive material to the environment may be determined by; (1) effluent gaseous monitors, (2) survey and sample analysis, or (3) source term estimates based on core damage and release pathway assumptions.

Dose assessment model methods are capable of estimating source term and magnitude of gaseous releases from effluent monitors or plant parameter data and release rate projections.

I.1.b A radiological assessment model for airborne releases that provides estimates of offsite radiation exposures and contamination levels using a dispersion model that is representative of the plant release points, topographical features, and meteorological regimes at the NPP site.

CGS uses a site specific version of the Unified RASCAL Interface (URI) off-site dose projection computer model. The underlying dose assessment model in URI is the NRCs RASCAL 4 model, based on the methods and equations documented in NUREG-1940.

The URI model provides off-site radiological dose and dose rate estimates based on near real time or hypothetical inputs. Projected dose is based on EPA-400-R-92-001 dose conversion factors given as; (1) the total effective dose equivalent, or TEDE (the sum of the effective dose equivalent from immersion, 4 days of ground deposition, and the committed effective dose equivalent from inhalation), and (2) the committed dose equivalent to the thyroid (CDE thyroid).

URI dose projection results are given for various locations from the site boundary to 10 miles.

URI is capable of providing dose assessment results for multiple release points from the site.

URI dose projection results and field monitoring readings are used in assessing radiological EALs and PARs.

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Columbia Generating Station Emergency Plan Page 49 of 98 I.1.c A capability to coordinate and implement in-field radiological assessments by FMTs and provisions to assess the data obtained.

Onsite out of plant (inside the protected area) and offsite (outside the protected area) environmental monitoring is performed by qualified field monitoring personnel under the direction of the Field Team Coordinator and Radiological Emergency Manager in the EOF.

Field monitoring personnel initially report to the EOF. Field team deployment is performed as needed and can be done in less than 30 minutes based on the time necessary to brief, load equipment, and depart.

Field monitoring personnel use dedicated equipment, and for offsite field monitoring, dedicated vehicles. Field monitoring personnel are directed to track and evaluate a radioactive plume by monitoring radiation levels and by obtaining and analyzing air samples. Field monitoring surveys and sampling are performed at pre-identified locations or other geographic locations within the EPZ determined during the event.

Laboratory facilities described in Element C.4 are available for detailed analysis of onsite and offsite environmental samples.

I.2 A methodology for assessing contamination of drinking water by waterborne releases for sites located on bodies of water from which public drinking water is drawn.

This element is not applicable to the licensee emergency plan.

I.3 The capability and responsibility for monitoring the following parameters, which provide input to radiological assessments during an emergency, are described:

1. Status of reactor fuel (e.g., no fuel damage, technical specification activity, clad failure, core melt).

2. Status of containment integrity.

3. Leakage of radioactive material from plant systems, structures, and components.

4. Status of engineered safety features used to mitigate the release of radioactive material to the environment (e.g., filters, containment spray, etc.).

5. Onset and duration of an actual release of radioactive material to the environment, or estimating these parameters for a potential release.

The ERO monitors plant parameters using information provided by the PPC to assess the status of reactor fuel using core damage assessment procedures.

The ERO monitors PPC data to evaluate the status of containment integrity, systems used to mitigate the release of radioactive material to the environment and to identify leakage of radioactive material from plant systems, structures, and components.

Effluent and process monitors are used to determine the onset and duration of an actual or potential release of radioactive material to the environment.

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Columbia Generating Station Emergency Plan Page 50 of 98 I.4 The methods and responsibility for determining the source term present in reactor coolant, containment atmosphere, and spent fuel pool area atmosphere are described.

Source term present in reactor coolant, containment atmosphere, and spent fuel pool area atmosphere are estimated using effluent, process and area radiation monitor readings, comparison of plant conditions against design basis event scenarios, sample analysis and environmental survey results, and plant parameter indications as inputs into the dose assessment and core damage assessment processes.

I.4.a The contingency arrangements to obtain and analyze highly radioactive samples from the reactor coolant system, containment atmosphere and sump, and spent fuel pool storage area are described.

The NRC issued Amendment No. 184 (to Facility Operating License No. NPF-21) on 01/27/03.

This amendment deleted Technical Specification Section 5.5.2, and thereby eliminated the licensing requirement to have and maintain Post Accident Sampling Systems.

Consistent with the requirements of the NRC safety evaluation, contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere are maintained in plant procedures.

I.5 The organizations responsible for FMT activities, and necessary resources, are identified.

CGS is responsible for CGS field monitoring team activities and resources. DOE-RL and Washington and Oregon Departments of Health are responsible for ORO field monitoring team activities and resources.

I.6 Each organization, where appropriate, provides methods, equipment, and expertise to make timely assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways, including development of post-plume PARs for comparison to current Federal guidance.

CGS uses the site-specific URI dose assessment program to make timely assessments of the actual or potential magnitude and locations of any radiological hazards through gaseous release pathways. Personnel qualified in dose assessment are available on shift and as augmenting minimum ERO staff in the EOF. Dose assessment results and field monitoring readings assist in evaluating ECLs based on radiological EALs, and for developing any related PARs.

The actual or potential magnitude of liquid radiological releases with regard to event classification are determined by liquid effluent monitors, direct area surveys, or sample analyses.

Post-plume PARs (i.e., ingestion pathway) are developed by OROs and described in state and county radiological emergency plans in accordance with Element I.2.

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Columbia Generating Station Emergency Plan Page 51 of 98 I.7 The capability to detect and measure radioiodine concentrations in air in the plume exposure pathway EPZ as low as 10-7 Ci/cc under field conditions is described.

The sample collection process takes into account the sample flow rate, collection efficiency of the sample media used to collect the sample, duration of the sample, counter efficiency, and background radiation, including interference from the presence of noble gases.

CGS field monitoring equipment has the capability to detect and measure airborne radioiodine concentrations as low as 1E-7 Ci/cc in the presence of noble gases. Air samples are taken with portable air sampling devices equipped with a Silver Zeolite or equivalent cartridge and particulate filter. Interference from the presence of noble gas and background radiation is minimized by ensuring that monitoring teams move to areas of low background prior to analyzing the sample cartridge.

Air sample results are estimated in the field through the use of a portable count rate meter. The samples can be subsequently analyzed for greater precision by one of the available laboratory facilities described in Element C.4.

I.8 A means is established for relating the various measured parameters (e.g.,

exposure rates, contamination levels, and air activity levels) to dose or dose rates.

Provisions are made for estimating integrated dose from the projected and actual dose rates and for comparing these estimates with current Federal guidance. In addition, provisions are established to validate dose projections with field data and compare projections with other organizations also calculating dose projections.

The detailed provisions are described in implementing procedures.

CGS field monitoring teams track the plume from a radiological release by monitoring radiation levels and by obtaining and analyzing air samples. Field monitoring team environmental survey and air sample results are compared with dose assessment results to validate or adjust projections. Additionally, field monitoring results can be input into the dose assessment model to develop projections at different locations.

I.9 Arrangements to locate and track the airborne radioactive plume are made using available resources, which includes Federal, state, local, and tribal governments, and/or licensee resources. Provisions are made to characterize the plume including taking peak plume measurements. Identification of the plume, includes determining a measurement that is high enough to be reasonably above background radiation readings and sufficient enough to indicate submersion within the plume.

CGS provides dedicated vehicles and equipment for the field monitoring teams. Methods to monitor a radioactive plume include establishing peak centerline values and edges. Monitoring strategies may include the traversing of plumes when road networks and exposure rate permit.

Additionally, local field sampling and monitoring points are specified to support prepositioning of teams or use in comparison with dose projection results.

Data from CGS field monitoring teams is compared to data provided by ORO field monitoring teams that may be dispatched within the EPZ. Data collected before ORO field monitoring teams are deployed is made available to ORO dose assessment personnel, upon arrival.

Refer to Element I.1.c for detail regarding field monitoring resources.

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Columbia Generating Station Emergency Plan Page 52 of 98 I.10 Organizations directly responsible for radiological monitoring, analysis, and dose projections describe the capability for coordinating monitoring efforts, tracking and trending data, and sharing analytical results with other organizations performing radiological assessment functions.

CGS personnel coordinate environmental radiological monitoring and assessment efforts with state field monitoring teams via MUDAC and telecommunications to facilitate field monitoring coordinate and to compare dose projection results.

Accommodations are provided for NRC site team representatives to co-locate in the EOF in order to compare dose projection results.

!"

Columbia Generating Station Emergency Plan Page 53 of 98 J:

Protective Response A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate. ETEs have been developed by applicants and licensees.

Licensees shall update the ETEs on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

Regulatory

References:

10 CFR 50.47(b)(10); 44 CFR 350.5(a)(10);

10 CFR Part 50, Appendix E.IV.2-6, E and I J.1 The means and time required to alert, notify, and provide a range of protective actions for onsite individuals and individuals who may be in areas controlled by the licensee (including members of the public) during a radiological incident are described.

CGS maintains procedures to provide for a range of protective actions for all areas controlled by the station. Protective actions have been developed for radiological incidents and to protect personnel during hostile actions directed at the site.

Site wide notifications and announcements are routinely made using the public address system.

Personnel on site are notified of a declared emergency through the public address system.

Visitors within the Protected Area are escorted by badged individuals. The escort is responsible for controlling and directing their assigned visitors regarding actions required by any announcement.

Security personnel may be used, as available, to augment public address announcements and to check site locations outside the Protected Area for remaining individuals.

J.1.a Provisions are made for evacuation of onsite non-essential personnel at an SAE or General Emergency (GE).

A site evacuation of non-essential personnel is performed following a Site Area Emergency or General Emergency classification level, or sooner as determined by the Emergency Director.

Site evacuees are sent to the ENOC for monitoring or decontamination as necessary.

A Protected Area evacuation of non-essential personnel may be performed for security threats or at Emergency Director discretion when a site evacuation is not warranted. This type of evacuation may occur independent of the emergency classification level.

The decision to evacuate to the ENOC, or to direct personnel to an alternate location, or to direct personnel to shelter in place will be made depending on conditions at the time of the event (such as; severe weather, security threats, radiological conditions, etc.).

!"

Columbia Generating Station Emergency Plan Page 54 of 98 J.2 Provisions are made and coordinated with appropriate offsite entities for evacuation routes and transportation for onsite individuals to a suitable offsite location. Selection of location considers the potential for inclement weather, high traffic density, and potential radiological conditions. Alternate location(s) and route(s) are identified.

Site evacuees are sent to the ENOC, which is owned and operated by Energy Northwest.

Several evacuation routes are available from the site to the ENOC. The site evacuation process has been developed in coordination with DOE-RL and Benton County and takes into consideration meteorological and radiological conditions, weather, and other travel hazards, in determining the appropriate evacuation route.

On-site personnel will evacuate the site when directed using transportation that was employed to arrive at the site. Personnel without transportation will be identified and have transportation arranged for.

J.3 Provisions for radiological monitoring and decontamination, if necessary, of personnel evacuated from the NPP site are described.

Personnel evacuating from outside the Protected Area are monitored, and decontaminated if necessary, at the Kootenai Building or the ENOC, as required by radiological conditions.

Personnel decontamination facilities in the plant include showers, sinks and cleaning agents.

Decontamination capabilities for emergency purposes are also available at the Kootenai Building and the ENOC.

Personnel evacuating from within the Protected Area are monitored for contamination, and typically decontaminated in the plant or the Kootenai Building before leaving the site. If conditions do not allow for decontamination of personnel on site, they will report to the ENOC for radiological monitoring, and decontamination if required.

J.4 The capability to account for all individuals inside the NPP Protected Area following declaration of an SAE or GE is described. The names of missing individuals are ascertained within 30 minutes following the emergency declaration and accountability is maintained for the duration of the incident. This capability includes provisions for prompt accountability following events that may preclude completion within 30 minutes (e.g., hostile action).

Accountability is performed following declaration of a Site Area Emergency or General Emergency classification level, or earlier as determined by the Emergency Director.

Personnel accountability is conducted at predetermined locations for ERO and essential personnel remaining inside the Protected Area. Non-essential personnel are accounted for when logged out of the Protected Area utilizing the electronic access control system or personnel logs as part of the evacuation process.

Personnel inside the Protected Area are accounted for within 30 minutes of event declaration using the security computer system. Backup means of accountability is available if the primary system fails. Accountability may be delayed if the movement of personnel creates safety or security concerns. If delayed for safety or security concerns, then accountability will be performed as soon as conditions permit.

!"

Columbia Generating Station Emergency Plan Page 55 of 98 The last known location of unaccounted for (missing) individuals will be obtained, and search and rescue actions initiated to locate the missing individuals.

After initially completed, accountability will be maintained continuously throughout the emergency for personnel inside the Protected Area.

J.5 Provisions are made for personal radiological protection for individuals arriving or remaining onsite during the incident.

Protective equipment and supplies are available to personnel remaining on site or arriving on site during the emergency to minimize the effects of radiological exposures or contamination in accordance with radiation protection procedures. Personal radiological protection provisions include the following:

1. Individual Respiratory Protection Selected personnel assigned in-plant emergency response duties are trained and qualified in the use of respiratory protection equipment. Respiratory protection equipment is maintained at various locations in the plant in accordance with operations, health physics, and fire protection procedures.

2. Individual Thyroid Protection Potassium Iodide (KI) is maintained in various locations at the site. In the event of a release involving radioiodine, the TSC Manager, in consultation with the Radiation Protection Manager, will evaluate conditions and issue instructions for the use of KI to personnel inside the Protected Area. The EOF Manager, in consultation with the Radiological Emergency Manager, will evaluate conditions and issue instructions for the use of KI to CGS field team and other response personnel outside the Protected Area.

3. Protective Clothing Protective clothing will be issued when needed to limit personal contamination and minimize the spread of contamination. The process for use of protective clothing is provided in radiation protection procedures.

J.6 The basis and methodology are established for the development of PARs for the responsible OROs, including evacuation, sheltering, and, if appropriate, radioprotective drug use, for the plume exposure pathway EPZ. Current Federal guidance is used.

CGS has developed PARs, in accordance with agreements made with DOE-RL, state and county agencies, for the plume exposure pathway EPZ that include evacuation and sheltering.

In conjunction with the PARs, a precautionary recommendation of monitor and prepare is given in unaffected areas of the EPZ to maintain readiness. PARs were developed using the following:

x NUREG-0654/FEMA-REP-1, Supplement 3, Guidance for Protective Action Strategies, November 2011 x

EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, May 1992

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Columbia Generating Station Emergency Plan Page 56 of 98 It is the position of the State of Washington, Benton County, and Franklin County that they are responsible for determining if and when to use potassium iodide. The CGS Emergency Director is responsible for notifying the offsite agencies when the State of Washington criteria for consideration of KI use has been met. CGS is not responsible for the acquisition or stockpile of KI for offsite use.

PARs for the general public will be based on plant conditions and/or offsite dose assessment results. Plant conditions, offsite projected dose, and field monitoring team data are used in PAR decision making. Site-specific ETEs were used in in the development of PARs for rapidly progressing severe accidents.

PARs beyond the 10-mile EPZ will be developed on an "ad hoc basis" from projected or measured dose in excess of EPA PAGs. Because dose projection accuracy is limited by distance, actual field measurements are used to corroborate projections before issuing PARs in areas outside the 10-mile EPZ.

J.7 A site-specific protective action strategy or decision-making process, informed by the ETE study, is coordinated between the licensee and OROs. Current Federal guidance is used.

CGS offsite protective action recommendation strategies, based upon information in the latest NRC reviewed ETE report, have been developed, in coordination with DOE-RL and the state and county agencies, using guidance provided in NUREG-0654/FEMA-REP-1, Supplement 3, Guidance for Protective Action Strategies.

J.8 The latest ETEs are:

J.8.a Incorporated either by reference or in their entirety into the emergency plan.

The most recent ETE report is incorporated by reference into this emergency plan. Refer Introduction Section 2.

1. Annual Population Estimates CGS will estimate EPZ permanent resident population changes once a year during the years between decennial censuses, but no later than 365 days from the date of the previous estimate, using the most recent U.S. Census Bureau annual resident population estimate and state/county government population data, if available.

CGS maintains annual population estimates available for NRC inspection during the period between decennial censuses.

2. ETE Report Updates The ETE report will be updated:

A. Whenever the most recent decennial census data from the U.S. Census Bureau becomes available.

OR B. If at any time during the decennial period, the EPZ permanent resident population increases such that it causes the longest ETE value for;

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Columbia Generating Station Emergency Plan Page 57 of 98 x

the 2-mile zone (Section CGS)

OR x

the entire 10-mile EPZ (Sections 1 - 4 collectively) to increase by 25 percent or 30 minutes, whichever is less, from the currently NRC approved or updated ETE.

Updated ETE reports, and any applicable annual population estimates, will be submitted to the NRC under §50.4 no later than 365 days after CGS determines that the criteria for updating the ETE have been met and at least 180 days before; (1) using it to form protective action recommendations, and (2) providing it to DOE-RL, and state and county authorities for use in developing offsite protective action strategies.

J.8.b Incorporated either by reference or as a summary of the latest ETE analysis into the emergency plan.

This element is not applicable to the licensee emergency plan.

J.9 PARs are provided, in a timely manner, directly to the designated ORO(s) responsible for making protective action decisions (PADs) within the plume exposure pathway EPZ.

Applicable PEP EPZ PARs of evacuate and shelter are developed at the General Emergency classification level and provided to the ORO personnel responsible for making protective action decisions.

PARs are communicated using the initial notification form and process. See Section E for a discussion of emergency notification.

J.10 Plans include maps, charts, or other information that demonstrate the following for the plume exposure pathway EPZ:

J.10.a Evacuation routes, evacuation areas, reception centers in host areas, and shelter areas.

Details on evacuation routes, evacuation areas, assistance centers in host areas, and shelter areas are provided in the ETE report, which is considered part of the CGS Emergency Plan.

J.10.b Population distribution around the NPP site by evacuation areas.

Details on population distribution around the CGS site, by evacuation areas, are provided in the ETE report, which is considered part of the CGS Emergency Plan.

J.11 A capability for implementing protective actions based on current Federal guidance is established. The process ensures coordinated implementation of PADs with all appropriate jurisdictions. The process for implementing protective actions for the plume exposure pathway EPZ is described and includes the following:

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 58 of 98 J.11.a Means for identifying and protecting residents who would have difficulty in implementing protective actions without assistance. This includes those with access and functional needs, transportation-dependent residents, those in special facilities, and those in correctional facilities. These means include notification, support, and assistance in implementing protective actions where appropriate.

This element is not applicable to the licensee emergency plan.

J.11.b The decision-making methodologies for use of radioprotective drugs and the provisions for administration to the general public, emergency workers, and institutionalized persons within the plume exposure pathway EPZ. This includes the means of determining quantities, maintaining and managing supplies, communicating recommendations, and distributing.

This element is not applicable to the licensee emergency plan.

J.11.c Means of evacuation informed by the updated ETEs. The evacuation routes and transportation resources to be utilized are described and include projected traffic capacities of evacuation routes and implementation of traffic control schemes during evacuation.

This element is not applicable to the licensee emergency plan.

J.11.d The locations of pre-identified reception centers beyond the boundaries of the plume exposure pathway EPZ, organizations responsible for managing reception centers, arrangements for handling service animals and pets, and provisions for radiological monitoring/decontamination.

This element is not applicable to the licensee emergency plan.

J.11.e Means for the initial and ongoing control of access to evacuated areas and organizational responsibilities for such control, including identifying pre-selected control points.

This element is not applicable to the licensee emergency plan.

J.11.f Identification of and means for dealing with potential impediments to the use of evacuation routes (e.g., seasonal impassability of roads) and contingency measures. The resources available to clear impediments and responsibility for rerouting traffic, as necessary, are described.

This element is not applicable to the licensee emergency plan.

J.11.g Identification of and means to implement precautionary protective actions (e.g.,

actions taken at an SAE).

This element is not applicable to the licensee emergency plan.

J.12 Protective actions to be used for the ingestion exposure pathway EPZ are specified, including the methods for protecting the public from consumption of contaminated foodstuffs, and are based on current Federal guidance.

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Columbia Generating Station Emergency Plan Page 59 of 98 This element is not applicable to the licensee emergency plan.

J.13 The means for registering, monitoring, and decontaminating evacuees, service animals, pets, vehicles, and possessions at reception centers in host areas are described. The personnel and equipment available are capable of monitoring 20 percent of the plume exposure pathway EPZ population, including transients, assigned to each facility within a 12-hour period.

This element is not applicable to the licensee emergency plan.

J.14 General plans for the removal or continued exclusion of individuals from restricted areas are developed. Relocation plans include:

This element is not applicable to the licensee emergency plan.

J.14.a Process for implementing current Federal guidance for relocation.

This element is not applicable to the licensee emergency plan.

J.14.b Means to identify and determine the boundaries of relocation areas, including a buffer zone.

This element is not applicable to the licensee emergency plan.

J.14.c Prioritization of relocation based on projected dose to an individual and the timeframe for relocation.

This element is not applicable to the licensee emergency plan.

J.14.d Control of access to and egress from relocation areas and security provisions for evacuated areas.

This element is not applicable to the licensee emergency plan.

J.14.e Contamination control during relocation.

This element is not applicable to the licensee emergency plan.

J.14.f Means for coordinating and providing assistance during relocation.

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 60 of 98 K:

Radiological Exposure Control Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Regulatory

References:

10 CFR 50.47(b)(11); 44 CFR 350.5(a)(11);

10 CFR Part 50, Appendix E.IV.E K.1 The radiation protection controls for emergency workers to be implemented during emergencies are described. These controls address the following aspects:

Radiation exposure limits and guidelines have been established for the control of radiation exposure to workers during an emergency. Approval is required if emergency workers are expected to receive dose in excess of 10 CFR 20 occupational dose limits. ALARA practices are utilized during emergencies as much as practical.

K.1.a Onsite emergency exposure guidelines for emergency workers consistent with their assigned duties and current Federal guidance and the conditions under which the guidelines apply.

Onsite exposure guidelines for emergency workers, consistent with EPA 400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, U.S. Environmental Protection Agency, May 1992, Table 2-2, "Guidance on Dose Limits for Workers Performing Emergency Services," have been established as follows:

TEDE Limit (Rem) Activity 5

All activities during the emergency.

10 Protecting valuable property when lower dose is not practicable.

25 Lifesaving or protection of large populations when lower dose is not practical per EPA-400-R-92-001.

Greater Than 25 Lifesaving or protection of large populations, only if individual receiving exposure is a volunteer, and fully aware of risks involved.

Emergency exposure limits are exclusive of current occupational exposure.

Only one emergency exposure is allowed per lifetime.

Dose to lens of the eye is limited to 3X listed value.

Dose to other organs, including skin and body extremities, is limited to 10X listed value.

K.1.b The capability to evaluate emergency worker dose (i.e., the sum of the effective dose equivalent and the committed effective dose equivalent) at the time of exposure when direct measurement is not feasible.

CGS ERO personnel who respond to the site during an emergency are considered emergency workers. Emergency worker exposure is obtained at the time of exposure by the use of dosimeters that can be read in real time, and sampling for airborne radioactivity for potential internal exposure. Issuance of dosimeters is performed in accordance with established Health Physics procedures.

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Columbia Generating Station Emergency Plan Page 61 of 98 If direct measurement of airborne concentrations is not available at time of exposure, qualified emergency workers are provided respiratory protection when feasible. In the absence of direct measurements, total dose exposures will be verified or calculated after the fact using follow up survey data and whole body counting equipment.

K.1.c The capability to monitor and assess the radiation doses received by emergency workers for the duration of the incident.

Radiation protection personnel in the TSC, OSC and EOF, have the responsibility to continuously monitor and assess the radiation dose exposure received by ERO personnel throughout a declared emergency.

CGS maintains a twenty-four hour per day capability to analyze dosimeters and monitoring for airborne radioactivity. Provisions are established to increase the frequency of dosimeter processing, as necessary, during emergencies. Dosimeters of legal record are analyzed by a contracted dosimetry laboratory.

Whole body counting and in-vitro bioassay will be available during and after an emergency to aid in determining the extent of an individual's internal exposure to radioactive materials.

Personnel dose records are documented and managed using an electronic dose tracking system. Should this system not be readily accessible or available, dose tracking and records will be maintained manually.

K.1.d The capability to implement onsite contamination control measures.

Normal contamination limits apply to personnel and equipment during routine and emergency operations. Personnel and equipment are monitored when leaving the Radiologically Controlled Area (RCA) to ensure contamination limits in uncontrolled areas are not exceeded. However, normal in-plant contamination limits may be suspended during an emergency to allow for prompt emergency response and to minimize personnel exposure to other hazards.

Contamination control limits and contamination control measures are contained in radiation protection procedures.

K.1.e The capability to decontaminate emergency workers, equipment, and vehicles.

A decontamination facility, equipment and supplies are located on the 487' elevation of the Radwaste Building. The facility consists of a large shower area with drains connected to the radwaste effluent treatment system. A decontamination shower and supplies are maintained at the Kootenai Building and the ENOC, where personnel decontaminations can also be performed as warranted. Personnel decontamination is performed using normal radiation protection procedures.

All equipment and material are checked for contamination before removal from a known contaminated area. Equipment and material are released for use outside of contaminated areas when radioactive contamination is within acceptable limits. If contaminated above limits, equipment and material are either decontaminated using radiation protection procedures, or maintained in controlled areas as radioactive.

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Columbia Generating Station Emergency Plan Page 62 of 98 K.1.f Appropriate radiation protection briefings for repair teams that are being dispatched into the plant and FMTs being sent onsite and offsite, the scope of which is consistent with the expected risk to the team.

Emergency teams that must enter areas where they might be expected to receive higher than normal doses will be briefed on the task assigned, the planned route to destination, allowed dose and dose rates, stay time, protective clothing/equipment, and actions to take for unanticipated conditions, hazards, or other conditions as applicable.

During dispatch, if the monitored dose or dose rates, or stay times exceed the limits set for the task, the team will communicate with the OSC for further direction or will return to the area from where they were dispatched. Once their task has been completed, team personnel will follow monitoring and personnel decontamination as specified by radiation protection procedures.

Field Monitoring personnel are briefed regarding their duties, actions, and what they are to do while in the field. They will also be briefed as to potential dose rates and protective clothing requirements.

K.1.g The process for NPP site access and dosimetry issuance to personnel from OROs arriving to assist with the onsite response.

Offsite emergency personnel who respond onsite for events that could result in exposure or entry into a radiologically controlled area, and do not arrive with dosimetry issued by their organization, will be issued the dosimetry at the site.

CGS will also provide KI, and personnel monitoring & decontamination services to offsite emergency workers when needed and requested by their organization.

The site access process into the Protected Area for local support organizations responding on site during an emergency is controlled by site security personnel. Non-CGS emergency workers supporting on-site activities will be monitored by radiation protection personnel when responding to areas where a radiation dose may be received.

K.2 Individual(s) who can authorize personnel to receive radiation doses in excess of the occupational dose limits in accordance with the minimum standards set forth in 10 CFR Part 20 or 29 CFR 1910.1096, as applicable to the organization, are identified by title/position. Such authorizations are documented.

Element B.2.a describes the responsibility for authorization of exposures to radiation in excess of 10 CFR 20 limits. Such authorizations are documented as part of the emergency exposure controls process provided in Element K.1.c.

K.2.a The process for allowing onsite volunteers to receive radiation exposures in the course of carrying out lifesaving and other emergency activities is described.

All personnel dispatched into radiation areas or areas of unknown radiation levels are briefed on the task and environmental conditions and are provided appropriate monitoring and personnel protective equipment.

Refer to Element K.1.a for the description of activities and their exposure thresholds and considerations.

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Columbia Generating Station Emergency Plan Page 63 of 98 K.2.b The process for authorizing emergency workers to incur exposures that may result in doses in excess of the current Federal guidance is described.

This element is not applicable to the licensee emergency plan.

K.3 The capability to determine the doses received by emergency workers involved in any commercial NPP radiological incident is described. Each organization makes provisions for distribution of direct-reading dosimeters (DRDs) and permanent record dosimeters (PRDs).

This element is not applicable to the licensee emergency plan.

K.3.a Provisions to ensure that DRDs are read at designated intervals and dose records are maintained for emergency workers are described.

This element is not applicable to the licensee emergency plan.

K.4 Action levels for determining the need for decontamination are specified and the means for radiological decontamination are established for emergency workers and the general public, as well as equipment, vehicles, and personal possessions.

The means for disposal of contaminated waste created by decontamination efforts are also established.

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 64 of 98 L:

Medical and Public Health Support Arrangements are made for medical services for contaminated injured individuals.

Regulatory

Reference:

10 CFR 50.47(b)(12); 44 CFR 350.5(a)(12);

10 CFR Part 50, Appendix E.IV.E L.1 Arrangements are established with primary and backup hospitals (one hospital is located outside the plume exposure pathway EPZ) and medical services. These facilities have the capability for evaluation of radiation exposure and uptake. The persons providing these services are adequately trained and prepared to handle contaminated, injured emergency workers and members of the general public.

This element is not applicable to the licensee emergency plan.

L.2 Arrangements for the medical treatment of contaminated, injured onsite personnel and those onsite personnel who have received significant radiation exposures and/or significant uptakes of radioactive material are described. These arrangements include the following components:

L.2.a An onsite first aid capability with adequate medical equipment and supplies.

First aid supplies and equipment are maintained for the treatment of injured persons.

Initial first aid for personnel who are injured and potentially contaminated is provided by the on-shift Fire Brigade Team, which is composed of first aid and health physics trained personnel.

Emergency treatment of injured personnel will normally be performed on the scene.

Medical equipment and supplies are maintained by Occupational Health Services.

L.2.b Primary and backup offsite medical facilities.

Trios Health Southridge Hospital in Kennewick, Washington; Lourdes Medical Center in Pasco, Washington; and Kadlec Regional Medical Center in Richland, Washington, provide hospital and medical services. Any combinations of these three hospitals serves as the primary and backup medical facility. These hospitals have emergency room coverage 24-hours per day.

The State of Washington maintains agreements for handling contaminated patients with other hospitals in the State of Washington.

CGS assists each hospital in developing training and procedures for the care of radiation accident patients as requested. Copies of the appropriate instructions are available to the physicians and staff at the medical facilities.

L.2.c Radiological controls capability, including the isolation of contamination, assessment of contamination levels, radiation exposure monitoring for medical facility staff, collection of contaminated waste, and decontamination of treatment areas.

CGS health physics personnel are available to assist medical personnel with decontamination, radiation exposure monitoring, and contamination control.

!"

Columbia Generating Station Emergency Plan Page 65 of 98 Radiological controls capability, including the isolation of contamination, assessment of contamination levels, radiation exposure monitoring for medical facility staff, collection of contaminated waste, and decontamination of treatment areas are described in CGS radiation protection department and hospital procedures.

Hospitals are equipped and hospital personnel trained to address contaminated injured individuals.

L.2.d Provisions to evaluate for radiological contamination either prior to transport to a medical facility or after arrival.

Injured personnel are evaluated for radiological contamination prior to transport to a medical facility per radiation protection department procedures. If contamination monitoring is not possible due to the medical condition of the individual, contamination monitoring is performed as soon as possible following treatment at the medical facility.

L.2.e Contact information for facilities capable of treating overexposure to radioactive material.

DOE-RL provides assistance in treatment of radiologically contaminated or exposed injured patients when requested. Assistance is provided by DOE Hanford contractors specializing in medical treatment and exposure/uptake evaluation. The DOE Hanford contract personnel are available for response and consultation services to CGS and agreement medical facilities.

The Radiation Emergency Assistance Center Training Site (REAC/TS) located at Oak Ridge, Tennessee, is capable of responding to and/or provide advice and assistance to offsite medical facilities in the event of a severe radiation accident.

L.3 Supplemental lists are developed that indicate the location of the closest public, private, and military hospitals and other emergency medical facilities within the state or contiguous states considered capable of providing medical support for any contaminated, injured individual.

This element is not applicable to the licensee emergency plan.

L.4 Each organization arranges for the transportation of contaminated, injured individuals and the means to control contamination while transporting victims of radiological incidents to medical support facilities and the decontamination of transport vehicle following use.

Injured personnel are evaluated for radiological contamination and if needed packaged to control contamination prior to transport to a medical facility.

Medical emergency transportation is provided by the Hanford Fire Department. If additional assistance is required, local ambulance services may be used. Hanford Fire Department personnel are trained to and perform decontamination of their transport vehicles.

CGS personnel knowledgeable in health physics will accompany contaminated patients to the hospital or meet the ambulance at the hospital to assist in the emergency.

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Columbia Generating Station Emergency Plan Page 66 of 98 M:

Recovery, Reentry, and Post-Accident Operations General plans for recovery and reentry are developed.

Regulatory

Reference:

10 CFR 50.47(b)(13); 44 CFR 350.5(a)(13);

10 CFR Part 50, Appendix E.IV.H M.1 General recovery, reentry, and return plans for radiological incidents are developed, as appropriate. These plans address reoccupancy, as appropriate. The plans should include:

M.1.a Provisions for allowing reentry into areas controlled by the licensee. Reentry planning includes evaluation of the controls necessary for reentry under post-incident conditions.

Reentry can occur during the plume or post-plume phase and refers to the temporary movement of people into an area of actual or potential hazard. Personnel who have been evacuated or relocated from a restricted area may be allowed to reenter under controlled conditions to perform additional emergency response activities when hazards are reduced to permissible levels. During or following a hostile action based incident, reentry criteria take into consideration site security and threat conditions.

M.1.b Provisions for reentry into restricted areas, including exposure and contamination control, as appropriate. A method for coordinating and implementing decisions regarding temporary reentry into restricted areas is addressed.

This element is not applicable to the licensee emergency plan.

M.2 Individuals who will comprise the licensees recovery organization are identified by title/position. The recovery organization includes technical personnel with responsibilities to develop, evaluate, and direct recovery and reentry operations.

Recovery activities are managed much like a normal outage, except that certain activities unique to the post-accident situation may be controlled by the recovery organization. The recovery organization is matrixed to and coordinated with the normal CGS organization. The recovery organization may be located at the EOF or elsewhere, as appropriate.

The primary positions in the recovery organization are described as follows:

x Recovery Manager - Overall management of recovery activities. High level coordination with offsite agencies.

x Onsite Recovery Coordinator - Directs the onsite recovery activities.

x Offsite Recovery Coordinator - Directs interface with offsite agencies during the recovery.

x Radiological Assessment Coordinator (if needed) - Coordinates radiological and environmental assessment with offsite agencies. Coordinates offsite radwaste management and decontamination activities.

x Spokesperson - Directs the public information program during the recovery phase.

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Columbia Generating Station Emergency Plan Page 67 of 98 M.3 The process for initiating recovery actions is described and includes the criteria for terminating the emergency.

Steps will be taken to terminate from the event, either directly from the emergency or following a transition period (prior to entering a state of recovery operations). Usually, the Unusual Event and Alert classification levels will be directly terminated (no entry into recovery).

Items that must be considered before terminating the emergency condition to either a normal or a recovery organization are as follows:

x Emergency Action Level criteria x

Releases of radioactive materials to the environment x

In-plant radiation levels x

Plant stability and long term core cooling availability x

Containment integrity x

Functionality and integrity of plant systems, facilities, power supplies, equipment, and instrumentation x

Fire, flood, earthquake or similar hazardous emergency conditions x

Site security x

Site access limitations for personnel and support services x

Discussion with ORO Decisions to relax protective actions for the public will be made by the appropriate offsite authorities.

When transition from an emergency to a recovery phase is necessary, a Recovery Manager will be identified to assist the ERO in the development of a recovery organization.

Specific recovery procedures will be developed following the incident. Recovery procedures will include the following: (1) damage evaluation; (2) decontamination measures; (3) repair procedures; (4) disposal procedures; and (5) test and startup procedures, as applicable.

The Emergency Director will inform the ERO, OROs, and NRC upon termination of the emergency when either returning to normal organizational control or entering recovery.

M.4 The process for initiating recovery actions is described and includes provisions to ensure continuity during transfer of responsibility between phases. The chain of command is established.

This element is not applicable to the licensee emergency plan.

M.5 The framework for relaxing protective actions and allowing for return are described.

Prioritization is given to restoring access to vital services and facilities.

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 68 of 98 M.6 The organization(s) responsible for developing and implementing cleanup operations offsite is identified.

This element is not applicable to the licensee emergency plan.

M.7 Provisions for developing and modifying sampling plans are established.

Provisions for laboratory analysis of samples are included in the plan.

The recovery organization will coordinate CGS environmental sampling activities with the state agency. Refer to Element C.4 for a description of laboratory capabilities.

M.8 A method for periodically conducting radiological assessments of public exposure is established.

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 69 of 98 N:

Exercises and Drills Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

Regulatory

References:

10 CFR 50.47(b)(14); 44 CFR 350.5(a)(14);

10 CFR Part 50, Appendix E.IV.F N.1 Exercises and drills are conducted, observed, and critiqued/evaluated as set forth in NRC and FEMA regulations and guidance.

1. Exercise An exercise is an event that tests the integrated capability and a major portion of the elements of the emergency plans and organizations. Exercises test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public alert and notification system, and ensure that the ERO are familiar with their duties.

x Exercises must provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to implement the principal functional areas of emergency response.

x State and county agencies within the plume exposure pathway EPZ are provided the opportunity to participate by invitation as described in Element N.2.a.

2. Drill Drills are conducted during the interval between biennial exercises, including at least one drill involving a combination of some of the principal functional areas of the onsite emergency response capabilities. The principal functional areas of emergency response include activities such as:

x Management and coordination of emergency response x

Accident assessment x

Event classification x

Notification of offsite authorities x

Assessment of the onsite and offsite impact of radiological releases x

Protective action recommendation development x

Protective action decision making x

Plant system repair and mitigative action implementation A drill is aimed at testing, developing and maintaining skills in one or more of the emergency plan functions.

x During drills, activation of all of the ERFs is not required. Focus may be primarily on onsite training objectives and supervised instruction is permitted.

x Drill types may be operational or discussion-based events (e.g., single ERF or tabletop drills). Drills may be a component of an exercise.

x Drills may include evaluation of specific performance objectives or be conducted for non-evaluated training only.

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Columbia Generating Station Emergency Plan Page 70 of 98 CGS will support requests from the State of Washington, and Benton and Franklin Counties to participate in station drills.

Topical drills or exercises, as described in the elements below, may be conducted singularly or combination with others. Verification that all drills and exercises are conducted and documented within the required intervals is performed through maintenance of cycle and annual drill and exercise schedules.

Drill and exercise requirements may be satisfied by an actual event provided it meets the specified criteria and the objectives are evaluated and documented in an event report that meets the requirements of the critique report.

The ERO (not necessarily each ERO member) is provided the opportunity to develop and maintain key emergency response skills within the scope of their duties in drills and exercises during each exercise cycle.

N.1.a The process to critique/evaluate exercises and drills is described.

A formal critique is conducted to identify weak or deficient areas that need correction following all drills and exercises that are used to evaluate performance objectives or to demonstrate key skills. The critique is performed using preselected performance objectives that are evaluated against demonstration criteria. In addition to performance, critiques include evaluation of response procedure processes, and facility and equipment adequacy.

Provisions are made for federal, state, and county representatives to observe and participate in drill and exercise critiques when present.

A report is prepared following the critique to document whether the objectives were successfully demonstrated and other observations.

Critique reports are approved by the Emergency Preparedness Manager. Critique reports are maintained as documentation for the completion of performance objectives throughout an eight-year exercise cycle.

N.1.b The process used to track findings and associated corrective actions identified by drill and exercise critiques/evaluations, including their assignment and completion, is described.

Any weakness or deficiency identified in a critique report must be corrected.

Critique report objectives and demonstration criteria that are not adequately performed, and other programmatic weaknesses and deficiencies are entered into the Corrective Action Program (CAP) for corrective action and/or tracking & trending. Improvement items and recommendations contained in the report may be documented and tracked, at the discretion of the Emergency Preparedness Manager.

The significance of any issue, the action(s) taken to resolve it, and the schedule for its closure are determined through the CAP process. The Emergency Preparedness Manager coordinates the assignment of corrective actions and due dates of issues affecting departments other than EP, as appropriate.

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Columbia Generating Station Emergency Plan Page 71 of 98 N.1.c A drill or exercise starts between 6:00 p.m. and 4:00 a.m. at least once every eight-year exercise cycle.

CGS will conduct an off-hours drill or exercise within an eight-year exercise cycle.

Off-hours is established as between the hours of 6:00 p.m. and 4:00 a.m. on a normal workday, any time of day on a weekend day, or any time of day on a weekday holiday.

Any drill or exercise listed in Elements N.2, N.3 and N.4 may be performed as an off-hours drill or exercise to satisfy this item.

N.1.d A drill or exercise is unannounced at least once every eight-year exercise cycle.

CGS will conduct an unannounced drill or exercise within an eight-year cycle.

Any drill or exercise listed in Elements N.2, N.3 and N.4 may be performed as an unannounced drill or exercise to satisfy this item.

N.2 Exercises are designed to enable the response organizations demonstration of the key skills and capabilities necessary to implement the emergency plan. The following two types of exercises are conducted at the frequency noted:

N.2.a Plume Exposure Pathway Exercises Plume exposure pathway exercises are conducted biennially. These exercises include mobilization of licensee and state, local, and tribal government personnel and resources and implementation of emergency plans to demonstrate response capabilities within the plume exposure pathway EPZ.

CGS will conduct a plume exposure pathway exercise biennially.

The plume exposure pathway exercise is developed to provide the ERO with the opportunity to demonstrate proficiency in key skills necessary to implement the principal functional areas of emergency response in the Control Room, TSC, OSC, EOF, and JIS/JIC.

As a minimum, each plume exposure pathway exercise contains objectives to demonstrate the following key skills as appropriate to the scenario:

x Event classification x

Notification of offsite emergency authorities x

PAR development (required only in exercises that include a GE) x Radiological assessment x

Shift staff event response while implementing emergency plan actions x

ERO augmentation and ERF activation x

Integration of response with OROs (such as; briefings, coordination of worker protection, coordination of public protective actions, radiological release monitoring, and offsite response to the site) x Response communications between onsite and offsite ERFs x

Dissemination of information to the public via media channels and press briefings

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Columbia Generating Station Emergency Plan Page 72 of 98 x

Development and implementation of onsite protective actions x

Accident assessment x

Accident mitigation (such as; planning and execution activities with and without radiological controls)

All ERO teams (not necessarily each individual) are scheduled to participate in a plume exposure pathway exercise within each eight-year exercise cycle.

The State of Washington, and Benton and Franklin Counties are invited to participate in plume exposure pathway exercises. If an organization chooses not to participate, their participation is not required to conduct the exercise for the station.

Biennial plume exposure pathway exercise scenarios are submitted to the NRC under §50.4 at least 60 days before they are held.

A remedial exercise is required if the emergency plan is not satisfactorily tested during the biennial exercise such that NRC, in consultation with FEMA, cannot (1) find reasonable assurance that adequate protective measures would be taken during a radiological emergency, or (2) determine that the ERO has maintained key skills specific to emergency response.

N.2.b Ingestion Exposure Pathway Exercises Ingestion exposure pathway exercises are conducted at least once every eight years. These exercises include mobilization of state, local, and tribal government personnel and resources and implementation of emergency plans to demonstrate response capabilities to a release of radioactive materials requiring post-plume phase protective actions within the ingestion exposure pathway EPZ.

This element is not applicable to the licensee emergency plan.

N.3 Exercise Scenario Elements During each eight-year exercise cycle, biennial, evaluated exercise scenario content is varied to provide the opportunity to demonstrate the key skills and capabilities necessary to respond to the following scenario elements:

Scenarios, prepared in advance, govern the conduct of exercises and drills, and include the following information and data as applicable to the type and scope of the event:

x Scope - A list of facilities and agencies, and their extent of participation, in the scenario.

x Objectives - A table of performance objectives expected to be demonstrated during the scenario.

x Controller/Evaluator Instructions - List of assignments and instructions for scenario specific actions.

x Participant/Observer Instructions - Instructions for scenario specific extent of play and safety considerations.

x Summary - A narrative description of the scenario identifying major events and their timing.

x Timeline - A section containing the time schedule of expected events.

x Messages - A section for messages, injects, plant data, equipment operation, and media used to control the flow of events.

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Columbia Generating Station Emergency Plan Page 73 of 98 x

In-Plant Radiological Data - A section for area radiation maps and data information.

x Environmental Radiological and Meteorological Data - A section for onsite and offsite maps and data information.

In each eight-calendar year exercise cycle, the contents of scenarios (i.e., event type, sequencing, and timing) are varied to provide the opportunity for the ERO to demonstrate proficiency in the key skills and prevent anticipatory responses through the preconditioning of participants. Scenario details are kept confidential from participants whenever performance objectives are selected for evaluation.

A record of exercises conducted during each 8-year exercise cycle that documents the contents of scenarios is maintained. A record of performance objective demonstration is maintained for the full eight-year exercise cycle to document successful completion of all required scenario elements.

N.3.a Hostile Action-Based (HAB) Hostile action directed at the NPP site. This scenario element may be combined with either a radiological release scenario or a no/minimal radiological release scenario, but a no/minimal radiological release scenario should not be included in consecutive HAB exercises at an NPP site.

CGS will conduct a HAB scenario in an exercise within an eight-year cycle.

The HAB scenario will include either a radiological release scenario or no/minimal radiological release scenario, but HAB scenarios combined with a no/minimal radiological release scenario will not be used in consecutive HAB exercises.

N.3.b Rapid Escalation An initial classification of, or rapid escalation to, an SAE or GE.

CGS will conduct one rapid escalation scenario in an exercise within an eight-year cycle.

The rapid escalation scenario will begin with an initial declaration of, or rapid escalation to the Site Area Emergency or General Emergency classification level while event response is performed from the Control Room.

N.3.c No/Minimal Release of Radioactive Materials No release or an unplanned minimal release of radioactive material which does not require public protective actions. This scenario element is used only once during each eight-year exercise cycle.

CGS will conduct a no/minimal radiological release scenario in an exercise within an eight-year cycle.

The no/minimal radiological release scenario may escalate to an Alert or Site Area Emergency classification level, but does not reach a General Emergency with issuance of PARs for Sections 1 through 4. The automatic location specific PARs required for CGS by the OROs at the Site Area Emergency classification level may be included.

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Columbia Generating Station Emergency Plan Page 74 of 98 N.3.c.1 The licensee is required to demonstrate the ability to respond to a no/minimal radiological release scenario. State, local, and tribal government response organizations have the option, and are encouraged, to participate jointly in this demonstration. If the offsite organizations elect not to participate in the licensees required minimal or no release exercise, the OROs will still be obligated to meet the exercise requirements as specified in 44 CFR 350.9.

The State of Washington and Benton and Franklin Counties are invited to participate in no/minimal radiological release exercises.

CGS will support offsite agencies in meeting FEMA demonstration requirements when they elect to not participate in a required no/minimal release scenario that is included in an exercise.

N.3.c.2 When planning for a joint no/minimal radiological release exercise, affected state, local, and tribal government jurisdictions, the licensee, and FEMA will identify offsite capabilities that may still need to be evaluated and agree upon appropriate alternative evaluation methods to satisfy FEMAs biennial criteria requirements.

Alternative evaluation methods that could be considered during the extent of play negotiations include expansion of the exercise scenario, out of sequence activities, plan reviews, staff assistance visits, or other means as described in FEMA guidance.

FEMA will determine whether a no/minimal radiological release scenario is acceptable for use in a full or partial participation biennial exercise.

N.3.d Resource Integration Integration of offsite resources with onsite response.

CGS will conduct a resource integration scenario (such as with offsite agency fire, medical, or law enforcement) in an exercise within an eight-year cycle.

The resource integration scenario includes offsite response to the site, briefings, and coordination of worker protection.

N.3.e 10 CFR 50.155(b)(2) Strategies Demonstration of the use of equipment, procedures, and strategies developed in compliance with 10 CFR 50.155(b)(2).

CGS will conduct a mitigation of beyond design basis event (MBDBE) scenario in an exercise within an eight-year cycle.

The MBDBE scenario will be based in one of the site specific strategies used to mitigate spent fuel pool damage scenarios, or one of the 10 strategies for BWRs used to mitigate reactor accidents and maintain containment. The scenario will require demonstration of the ability to transition between procedures and select the strategy(ies) for preventing or mitigating fuel damage and limiting radiological releases.

The MBDBE scenario may be conducted separately from a main exercise timeline and sequence of events. This includes the (simulated) deployment and use of equipment associated with these strategies. At a minimum, TSC and OSC ERO staff will participate. Participation of Control Room, EOF, JIS, and offsite officials may be simulated.

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Columbia Generating Station Emergency Plan Page 75 of 98 Methods to accomplish this demonstration are dependent upon the nature of the postulated initiating event, the plant response/accident sequence, and the ability of responders to select and implement mitigation/management strategies. These methods involve a demonstration of the transition from a controlling AOP or EOP into the Extensive Damage Mitigation Guidelines (EDMGs), FLEX support guidelines (FSGs), or Severe Accident Management Guidelines (SAMGs), and conducting any of the following:

x A demonstration of the use of EDMGs.

x A demonstration of the use of FSGs.

x A demonstration of the use of SAMGs.

N.4 Drills are designed to enable an organizations demonstration and maintenance of key skills and capabilities necessary to fulfill functional roles. Drills include, but are not limited to, the following at their noted frequencies:

N.4.a Emergency Medical Drills Emergency medical drills are conducted annually.

These drills involve a simulated, contaminated individual and contain provisions for participation by support services agencies (i.e., ambulance and offsite medical treatment facility).

CGS will conduct an emergency medical drill once per calendar year.

The emergency medical drill will include a simulated injured and contaminated individual, and provisions for participation by ambulance and offsite medical facilities.

N.4.b Medical Services Drills Medical services drills are conducted annually at each medical facility designated in the emergency plan. These drills involve a simulated, contaminated emergency worker and/or member of the general public and contain provisions for participation by support services agencies (i.e., ambulance and offsite medical treatment facility).

This element is not applicable to the licensee emergency plan.

N.4.c Laboratory Drills Laboratory drills are conducted biennially at each laboratory designated in the emergency plan. These drills involve demonstration of handling, documenting, provisions for record keeping, and analyzing air, soil, and food samples, as well as quality control and quality assurance processes. These drills also involve an assessment of the laboratorys capacity to handle daily and weekly samples and the volume of samples that can be processed daily or weekly.

This element is not applicable to the licensee emergency plan.

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Columbia Generating Station Emergency Plan Page 76 of 98 N.4.d Environmental Monitoring Drills Environmental monitoring drills are conducted annually. These drills include direct radiation measurements in the environment, collection and analysis of all sample media (e.g., water, vegetation, soil, and air),

and provisions for record keeping.

CGS will conduct an environmental monitoring drill once per calendar year.

The environmental monitoring drill will include performance objectives for direct radiation measurements in the environment, collection and analysis of sample media (e.g., water, vegetation, soil, and air), communications, and record keeping.

N.4.e Ingestion Pathway and Post-Plume Phase Drills Ingestion pathway and post-plume phase drills are conducted biennially. These drills involve sample plan development, analysis of lab results from samples, assessment of the impact on food and agricultural products, protective decisions for relocation, and food/crop embargos.

This element is not applicable to the licensee emergency plan.

N.4.f Communications Drills Communications amongst and between emergency response organizations, including those at the state, local, and Federal level, the FMTs, and nuclear facility within both the plume and ingestion exposure pathway EPZs, are tested at the frequencies determined in evaluation criterion F.3.

Communications drills include the aspect of understanding the content of messages and can be done in conjunction with the testing described in evaluation criterion F.3.

CGS will conduct a communications drill once per calendar year.

Communications tests described in Element F.3 can be performed as drills provided they include the aspect of understanding the content of messages.

N.4.g Post-Accident Sampling Drills Post-accident sampling drills are conducted annually. These drills address capabilities including analysis of liquid and containment atmosphere samples with simulated elevated radiation levels. This criterion is not applicable if the NPP unit(s) does (do) not have licensing basis requirements for post-accident sampling.

This element is not applicable to the CGS emergency plan.

CGS has received NRC approval for the elimination of post-accident sample system requirements from technical specifications. In accordance with the NRC safety evaluation, contingency plans have been developed for obtaining and analyzing highly radioactive samples; however, these contingency plans are not required to be carried out in emergency plan drills or exercises.

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Columbia Generating Station Emergency Plan Page 77 of 98 N.4.h Off-Hours Report-In Drills Off-hours report-in drills are conducted biennially and are unannounced.

CGS will conduct an off-hours unannounced ERO report-in drill at least once within an eight-year cycle.

The off-hours unannounced ERO report-in drill will require actual response to the assigned facility and the ability to perform turnover of responsibilities from the on-shift ERO.

N.4.i Off-Hours Call-In Drills Off-hours call-in drills are conducted quarterly, such that each ERO members normally expected response time is assessed at least biennially based on call-in drill responses or an alternate means for determining response time. Some drills are unannounced.

CGS will conduct an off-hours unannounced ERO call-in drill biennially to validate each ERO members response time.

The off-hours unannounced ERO call-in drill will require collection of the estimated response times to the applicable facility.

Completion of an Element N.4.h off-hours unannounced ERO report-in drill satisfies the requirements of the off-hours unannounced ERO call-in drill in this element.

N.4.j Onsite Personnel Protective Action Drills Onsite personnel protective action drills are conducted during every eight-year exercise cycle. These drills demonstrate the NPP sites ability to implement and coordinate protective actions for onsite personnel during hostile action.

CGS will conduct an onsite protective action drill within an eight-year cycle.

The onsite protective actions drill will demonstrate the ability to implement and coordinate protective actions for onsite personnel during a hostile action using one or more of the following:

x Warning personnel in the OCA outside the protected area x

Evacuation of personnel from target buildings, including security personnel x

Site evacuation by opening (while continuing to defend) security gates (demonstrated through discussion/table top) x Dispersal of licensed operators x

Sheltering of personnel in structures away from potential site targets x

Arrangements for accounting for personnel after the attack N.4.k Aircraft Threat/Attack Response Drills Aircraft threat/attack response drills are conducted during every eight-year exercise cycle. These drills demonstrate the use of procedures and protective measures developed for responding to hostile action involving an aircraft threat or attack.

CGS will conduct an aircraft threat/attack response drill at least once within an eight-year cycle.

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Columbia Generating Station Emergency Plan Page 78 of 98 N.4.l Minimum Staffing An ERO minimum staffing (no participation of non-minimum augmenting ERO personnel) drill is conducted at least once during every eight-year exercise cycle CGS will conduct a minimum staffing drill at least once within an eight-year cycle.

A minimum staffing response drill requires demonstration of facility activation, transfer of command and control, event assessment and classification, and offsite notification.

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Columbia Generating Station Emergency Plan Page 79 of 98 O:

Radiological Emergency Response Training Radiological emergency response training is provided to those who may be called on to assist in an emergency.

Regulatory

References:

10 CFR 50.47(b)(15); 44 CFR 350.5(a)(15);

10 CFR Part 50, Appendix E.IV.F O.1 Each organization ensures the training of emergency responders and other appropriate individuals with an operational role described in the emergency plan.

Initial training and at least annual retraining are provided.

The Emergency Preparedness Manager is responsible for oversight of ERO training and qualification. Responsibility for the conduct of ERO training resides with EP or site departments, depending on the position or type of training needed. Training is conducted by qualified training personnel or Subject Matter Experts (SMEs).

Initial training is provided to all new CGS ERO candidates. Refresher training is provided to the ERO as specified by the Systems Approach to Training (SAT) process. Categories of personnel requiring training include:

1. Shift Managers and Emergency Directors

2. Accident Assessment Personnel

3. Radiological Field Monitoring Team Personnel

4. Dose Assessment Personnel

5. ORO and NRC Communicators

6. Security Personnel x

Individuals assigned to site security receive required emergency plan training as part of their normal job specific training program.

x Security management/supervisory personnel assigned to an ERO position receive additional training on EP related tasks as part of the ERO training program.

7. Fire Brigade Personnel x

Individuals assigned to fire brigade maintain fire brigade qualifications by receiving initial and requalification training periodically as defined by the site fire protection program.

8. Repair and Damage Control Team Personnel x

Operations, maintenance, chemistry and radiation protection personnel who would be assigned to repair and damage control teams receive required emergency plan training as part of their normal job specific training program.

9. Site First Aid Personnel x

Individuals assigned as first aid responders maintain minimum qualifications equivalent to Red Cross Standard First Aid techniques.

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Columbia Generating Station Emergency Plan Page 80 of 98

10. Non-ERO Site Personnel x

General employee (site access) training provides initial orientation and recurring training on general aspects of the emergency plan and non-ERO response. Personnel are familiarized with site emergency announcements, and assembly and evacuation processes.

O.1.a Site-specific emergency response training is developed and conducted for those offsite organizations that may be called upon to provide onsite assistance in the event of an emergency.

State and county emergency management agencies who have a response role during an emergency are invited to participate in site specific training annually (once per calendar year).

Training includes CGS radiation protection practices, the notification process for their organization, and their organizations expected role. The invitation will provide a schedule of drills and exercises to enable offsite agencies to request participation.

CGS offers emergency response training annually (once per calendar year) to the Hanford Fire Department, who can be contacted to provide on-site fire & rescue and first aid support during an emergency. The training includes the general site layout, an overview of EP, site access procedures, and the identity (by position and title) of the onsite individual who will control their support activities.

CGS Security coordinates any site specific familiarization training with local law enforcement in accordance with the Security Plan.

O.2 The ERO training program consists of learning objectives that are used to develop and maintain key skills. This includes a systematic analysis of jobs and tasks to be performed from which learning objectives are derived.

The ERO training program is developed based on position-specific responsibilities/tasks using SAT principals. Lesson plans and position specific guides are developed based on task assignments. Requalification training consists of ERO refresher training, and/or drill participation for designated positions.

O.2.a The ERO training program is reviewed at least annually and revised as necessary.

Revisions to the training program are identified during EP assessments, drill and exercise critiques, and from training feedback. Appropriate revisions to the training program are made using the principles of the SAT process.

O.2.b Training sessions that provide performance opportunities to develop, maintain, or demonstrate key skills are critiqued in order to identify weak or deficient areas that need correction.

Individuals participating in the ERO Training Program are given the opportunity to provide feedback critiques of training sessions. Any weak or deficient areas identified are evaluated for correction or tracking.

Refer to Element N.1.a for details regarding the critique process.

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Columbia Generating Station Emergency Plan Page 81 of 98 P:

Responsibility for the Planning Effort Development, Periodic Review, and Distribution of Emergency Plan Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

Regulatory

References:

10 CFR 50.47(b)(16); 44 CFR 350.5(a)(16);

10 CFR Part 50, Appendix E.IV.B and G P.1 The training program, including initial training and periodic retraining, of individuals responsible for the planning effort is described.

Position descriptions specify minimum qualifications for emergency planning personnel.

Qualifications are maintained through related training, workshops, information exchange meetings with other licensees, conferences held by industry and government agencies, observing exercises at other sites or attending courses, such as CGS technical training, that will enhance working knowledge of plant operations performed at least annually (once per calendar year).

P.2 The individual with the overall authority and responsibility for radiological emergency planning is identified by title/position.

The Site Vice President has overall authority and responsibility for the CGS Emergency Plan.

P.3 The individual(s) with the responsibility for the development, maintenance, review, updating, and distribution of emergency plans, as well as the coordination of these plans with other response organizations, is identified by title/position.

The Emergency Preparedness Manager is responsible for the development, maintenance, review, and updating of the emergency plan, as well as the coordination of the plan with other response organizations.

P.4 The process for reviewing annually, and updating as necessary, the emergency plan, implementing procedures, maps, charts, and agreements is described. The process includes a method for recording changes made to the documents and, when appropriate, how those changes are retained.

The formal emergency plan (as defined in Introduction Section 2) are reviewed on an annual (once per calendar year) basis, and updated if necessary. Any changes to regulations or guidance, organizational structures, drill and exercise items, assessment and audit observations, or other desired updates will be evaluated and incorporated into the emergency plan and emergency plan implementing procedures as warranted.

Letters of Agreement/Memorandum of Understanding are reviewed and verified on an annual (once per calendar year) basis, and updated as warranted.

Emergency plan implementing procedures (listed in Element P.7) and other EP related textual and graphic materials (i.e., checklists, forms, user aids, training materials, posted items, electronic applications, etc.) do not require periodic review and are updated as necessary.

Changes to the emergency plan and activities that may affect the emergency plan are evaluated in accordance with 10 CFR 50.54(q) requirements.

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Columbia Generating Station Emergency Plan Page 82 of 98 P.5 Provisions for distributing the emergency plan and implementing procedures to all organizations and appropriate individuals with responsibility for implementation of the plan/procedures are described.

Revised copies of the emergency plan are distributed in accordance with the CGS Document Control Program.

Changes to the emergency plan are submitted to the NRC in accordance with 10 CFR 50.4.

Revisions to response related implementing procedures are communicated to appropriate members of the CGS ERO prior to or upon implementation.

P.6 A listing of annexes, appendices, and supporting plans and their originating agency is included in the emergency plan.

Introduction Section 2 provides a list and description of the documents defined as the formal emergency plan (includes bases documents that are considered part of the emergency plan but are maintained separately).

Emergency plans developed by other agencies that support the CGS Emergency Plan include:

x DOE Order 151.1D - Comprehensive Emergency Management System x

Benton County Columbia Generating Station Emergency Preparedness Plan x

Franklin County Columbia Generating Station Emergency Preparedness Plan x

Oregon Department of Energy CGS/Hanford Emergency Response Plan x

Washington State Fixed Nuclear Facility Protection Plan Theses emergency plans are reviewed when updated to maintain an effective interface with the CGS Emergency Plan.

P.7 An appendix containing a listing by title of the procedures required to maintain and implement the emergency plan is included. The listing includes the section(s) of the emergency plan to be implemented by each procedure.

Table P.7-1 provides a listing, by title, of the response and maintenance procedures required to implement the emergency plan, and the section(s) of the emergency plan to be implemented by each procedure.

Table P.7-1: Emergency Plan Implementing Procedures Document ID Document title Plan Sections Implemented

[To be updated upon E-Plan approval]

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Columbia Generating Station Emergency Plan Page 83 of 98 P.8 A table of contents and a cross-reference index to each of the NUREG-0654/FEMA-REP-1, Rev. 2 evaluation criteria are included. The evaluation criteria that do not apply are identified.

The CGS Emergency Plan contains a table of contents.

The CGS Emergency Plan content corresponds to the NUREG-0654 R2 evaluation criteria.

NUREG-0654 R2 evaluation criteria that do not apply to utilities are listed and identified as such.

P.9 Provisions for addressing the requirements of 10 CFR 50.54(t) are described.

Emergency preparedness program elements are reviewed by persons that have no direct responsibility for the implementation of the emergency preparedness program, in accordance with 10 CFR 50.54(t) and the Operational Quality Assurance Program Description (OQAPD) once every 24 months1. Specifically, the review will include an evaluation for adequacy of:

x Emergency plan and emergency plan implementing procedures x

Training of ERO and Non-CGS support groups that may be called to response to the site x

Drills and exercises x

Facilities and equipment x

Interfaces with state, county, and DOE-RL emergency management agencies Additionally, a review is conducted as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that potentially could adversely affect emergency preparedness program, but no longer than 12 months after the change.

The review findings will be submitted to appropriate CGS management personnel. The portion of the review involving the evaluation of the adequacy of interface with associated governmental organizations will be reported to those agencies. The results of the review, along with recommendations for improvements, will be documented, and retained for a period of five (5) years.

P.10 The administrative process for the periodic review and updating of contact information identified in the emergency plan and implementing procedures is described.

The CGS Emergency Phone Directory contains contact numbers for CGS and ORO response facilities, select ORO response personnel, offsite support groups and ERO positions that are identified in the emergency plan and implementing procedures.

The non-ERO portion of the Emergency Phone Directory is verified annually (once per calendar year) and updated as needed.

ERO contact information is verified quarterly and updated as needed.

1 Per RG 1.101 R6, the requirement for all elements of the emergency preparedness program to be reviewed at least once every 24 months should not exceed 730 days from the end of the prior review to the completion of the next program review, which includes issuance of the review report.

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Columbia Generating Station Emergency Plan Page 84 of 98 P.11 The process for entering EP program-related issues that could reduce the effectiveness of the emergency plan into the site-wide corrective action program is described.

The CGS Corrective Action Program is used to capture issues that do not meet program regulations, requirements, standards, or are otherwise conditions adverse to quality.

P.12 The process to evaluate changes in plant configuration for their impact on the effectiveness of the emergency plan is described.

Changes in plant configuration are evaluated for their impact on the effectiveness of the emergency plan through the plant modification or license compliance review processes specified in change procedures and, if required, the 10 CFR 50.54(q) process specified in emergency plan implementing procedures.

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Columbia Generating Station Emergency Plan Appendix 1 NRC Approval Listing and EP Commitment Cross-Reference Page 85 of 98 NRC Change Approvals and Safety Evaluations Related to the CGS Emergency Plan

1. NEI 99-01 Rev 6 Based EAL Scheme (ML17188A230)

2. NUREG-0654 R2 Based Emergency Plan ([ML# to be added upon NRC approval])

Site Specific EP Commitment E-Plan 1

GI2-03-020 (01/27/03) GO2-02-174 TS Amendment 184 - Maintain the capability for classifying fuel damage events at the Alert Level threshold. This capability may utilize the normal sampling system and/or correlations of radiation readings to radioisotope concentrations in the reactor coolant.

This commitment is met through the NRC approved CGS NEI 99-01 EAL scheme that includes fuel clad fission product barrier threshold indications based on fuel damage at the Alert emergency classification level.

D.1.a 2

GI2-03-020 (01/27/03) GO2-02-174 TS Amendment 184 - Maintain I-131 site survey detection capability, including the ability to assess radioactive iodine released to offsite environs, by using effluent monitoring systems or portable sampling equipment.

This commitment is met directly in Elements I.1.a and I.7.

I.1.a I.7

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 86 of 98

1. The applicant's emergency plans shall contain, but not necessarily be limited to, information needed to demonstrate compliance with the elements set forth below, i.e., organization for coping with radiological emergencies, assessment actions, activation of emergency organization, notification procedures, emergency facilities and equipment, training, maintaining emergency preparedness, recovery, and onsite protective actions during hostile action.

Regulatory Criteria E-Plan

2. This nuclear power reactor license applicant shall also provide an analysis of the time required to evacuate various sectors and distances within the plume exposure pathway EPZ for transient and permanent populations, using the most recent U.S. Census Bureau data as of the date the applicant submits its application to the NRC.

N/A

3. Nuclear power reactor licensees shall use NRC approved evacuation time estimates (ETEs) and updates to the ETEs in the formulation of protective action recommendations and shall provide the ETEs and ETE updates to State and local governmental authorities for use in developing offsite protective action strategies.

J.7

4. Within 365 days of the later of the date of the availability of the most recent decennial census data from the U.S. Census Bureau or December 23, 2011, nuclear power reactor licensees shall develop an ETE analysis using this decennial data and submit it under §50.4 to the NRC. These licensees shall submit this ETE analysis to the NRC at least 180 days before using it to form protective action recommendations and providing it to state and local governmental authorities for use in developing offsite protective action strategies.

J.8.a

5. During the years between decennial censuses, nuclear power reactor licensees shall estimate EPZ permanent resident population changes once a year, but no later than 365 days from the date of the previous estimate, using the most recent U.S. Census Bureau annual resident population estimate and state/local government population data, if available. These licensees shall maintain these estimates so that they are available for NRC inspection during the period between decennial censuses and shall submit these estimates to the NRC with any updated ETE analysis.

J.8.a.1

6. If at any time during the decennial period, the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less, from the nuclear power reactor licensee's currently NRC approved or updated ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase.

J.8.a.2 The licensee shall submit the updated ETE analysis to the NRC under §50.4 no later than 365 days after the licensee's determination that the criteria for updating the ETE have been met and at least 180 days before using it to form protective action recommendations and providing it to state and local governmental authorities for use in developing offsite protective action strategies.

J.8.a

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 87 of 98 Regulatory Criteria E-Plan

7. After an applicant for a combined license under part 52 of this chapter receives its license, the licensee shall conduct at least one review of any changes in the population of its EPZ at least 365 days prior to its scheduled fuel load. The licensee shall estimate EPZ permanent resident population changes using the most recent U.S. Census Bureau annual resident population estimate and state/local government population data, if available. If the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ, to increase by 25 percent or 30 minutes, whichever is less, from the licensee's currently approved ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase. The licensee shall submit the updated ETE analysis to the NRC for review under §50.4 of this chapter no later than 365 days before the licensee's scheduled fuel load.

N/A 10 CFR 50 Appendix E.IV.A - Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

Regulatory Criteria E-Plan

1. A description of the normal plant operating organization.

B.1.a

2. A description of the onsite ERO with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency; B.1.a B.2 B.2.a

b. Plant staff emergency assignments; B.1.a

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

B.1.a B.2 B.2.a

3. A description, by position and function to be performed, of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

N/A

4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, B.1.a and a description of how these projections will be made I.1.b I.6 and the results transmitted to state and local authorities, NRC, and other appropriate governmental entities.

E.1 I.10

5. Identification, by position and function to be performed, of other employees of the licensee with special qualifications for coping with emergency conditions that may arise.

B.1.a

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 88 of 98 Regulatory Criteria E-Plan Other persons with special qualifications, such as consultants, who are not employees of the licensee and who may be called upon for assistance for emergencies shall also be identified. The special qualifications of these persons shall be described.

B.5

6. A description of the local offsite services to be provided in support of the licensee's emergency organization.

C.2.d

7. By June 23, 2014, identification of, and a description of the assistance expected from, appropriate state, local, and federal agencies with responsibilities for coping with emergencies, including hostile action at the site.

For purposes of this appendix, "hostile action" is defined as an act directed toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.

A.4

8. Identification of the state and/or local officials responsible for planning for, ordering, and controlling appropriate protective actions, including evacuations when necessary.

A.1.a.3 A.1.a.4

9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

B.1.a 10 CFR 50 Appendix E.IV.B - Assessment Actions Regulatory Criteria E-Plan

1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and state agencies, the Commission, and other federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety.

I.1.a D.1.a The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant.

D.1.a The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

D.1.b Thereafter, emergency action levels shall be reviewed with the state and local governmental authorities on an annual basis.

D.1.b

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 89 of 98 Regulatory Criteria E-Plan

2. A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change.

D.1.a Licensees shall follow the change process in §50.54(q) for all other emergency action level changes.

P.4 10 CFR 50, Appendix E.IV.C - Activation of Emergency Organization Regulatory Criteria E-Plan

1. The entire spectrum of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described.

D.1 D.3 The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described.

E.1 Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described.

D.1.a The existence, but not the details, of a message authentication scheme shall be noted for such agencies.

E.1.a The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.

D.1

2. By June 20, 2012, nuclear power reactor licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

D.2 Licensees shall not construe these criteria as a grace period to attempt to restore plant conditions to avoid declaring an emergency action due to an emergency action level that has been exceeded.

13.1.1A Step 4.2.6.c Licensees shall not construe these criteria as preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the state and local authorities the opportunity to implement measures necessary to protect the public health and safety.

D.2 10 CFR 50, Appendix E.IV.D - Notification Procedures Regulatory Criteria E-Plan

1. Administrative and physical means for notifying local, state, and federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described. This description shall include identification of the appropriate officials, by title and agency, of the state and local government agencies within the EPZs.

E.1.2 F.1.a.3

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 90 of 98 Regulatory Criteria E-Plan

2. Provisions shall be described for yearly dissemination to the public within the plume exposure pathway EPZ of basic emergency planning information, such as the methods and times required for public notification and the protective actions planned if an accident occurs, general information as to the nature and effects of radiation, and a listing of local broadcast stations that will be used for dissemination of information during an emergency.

G.1.1 Signs or other measures shall also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that would be helpful if an accident occurs.

G.1.2

3. A licensee shall have the capability to notify responsible state and local governmental agencies within 15 minutes after declaring an emergency.

E.1.b The licensee shall demonstrate that the appropriate governmental authorities have the capability to make a public alerting and notification decision promptly on being informed by the licensee of an emergency condition.

E.2 Prior to initial operation greater than 5 percent of rated thermal power of the first reactor at a site, each nuclear power reactor licensee shall demonstrate that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ.

N/A The design objective of the prompt public alert and notification system shall be to have the capability to essentially complete the initial alerting and initiate notification of the public within the plume exposure pathway EPZ within about 15 minutes. The use of this alerting and notification capability will range from immediate alerting and notification of the public (within 15 minutes of the time that state and local officials are notified that a situation exists requiring urgent action) to the more likely events where there is substantial time available for the appropriate governmental authorities to make a judgment whether or not to activate the public alert and notification system.

E.2 The alerting and notification capability shall additionally include administrative and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting and notification is unavailable during an emergency to alert or notify all or portions of the plume exposure pathway EPZ population. The backup method shall have the capability to alert and notify the public within the plume exposure pathway EPZ, but does not need to meet the 15-minute design objective for the primary prompt public alert and notification system.

E.2 When there is a decision to activate the alert and notification system, the appropriate governmental authorities will determine whether to activate the entire alert and notification system simultaneously or in a graduated or staged manner. The responsibility for activating such a public alert and notification system shall remain with the appropriate governmental authorities.

E.2

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 91 of 98 10 CFR 50, Appendix E.IV.E - Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and equipment, including:

Regulatory Criteria E-Plan

1. Equipment at the site for personnel monitoring; K.1.b K.1.c

2. Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment; H.7.4 I.6

3. Facilities and supplies at the site for decontamination of onsite individuals; J.3 K.1.e

4. Facilities and medical supplies at the site for appropriate emergency first aid treatment; L.2.a

5. Arrangements for medical service providers qualified to handle radiological emergencies onsite; A.1.a.2.C

6. Arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary; L.4

7. Arrangements for treatment of individuals injured in support of licensed activities on the site at treatment facilities outside the site boundary; L.2.b 8.a (i) A licensee onsite technical support center and an emergency operations facility from which effective direction can be given and effective control can be exercised during an emergency; H.1 H.3 8.a (ii) For nuclear power reactor licensees, a licensee onsite operational support center; H.2 8.b For a nuclear power reactor licensee's EOF required by paragraph 8.a of this section, either a facility located between 10 miles and 25 miles of the nuclear power reactor site(s), or a primary facility located less than 10 miles from the nuclear power reactor site(s) and a backup facility located between 10 miles and 25 miles of the nuclear power reactor site(s). An EOF may serve more than one nuclear power reactor site. A licensee desiring to locate an EOF more than 25 miles from a nuclear power reactor site shall request prior Commission approval by submitting an application for an amendment to its license.

H.4.1 For an EOF located more than 25 miles from a nuclear power reactor site, provisions must be made for locating NRC and offsite responders closer to the nuclear power reactor site so that NRC and offsite responders can interact face-to-face with emergency response personnel entering and leaving the nuclear power reactor site. Provisions for locating NRC and offsite responders closer to a nuclear power reactor site that is more than 25 miles from the EOF must include the following:

N/A (1) Space for members of an NRC site team and federal, state, and local responders; C.5 (2) Additional space for conducting briefings with emergency response personnel; C.5

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 92 of 98 Regulatory Criteria E-Plan (3) Communication with other licensee and offsite emergency response facilities; C.5 (4) Access to plant data and radiological information; and C.5 (5) Access to copying equipment and office supplies; C.5 8.c By June 20, 2012, for a nuclear power reactor licensee's EOF required by paragraph 8.a of this section, a facility having the following capabilities:

(1) The capability for obtaining and displaying plant data and radiological information for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves; H.3 (2) The capability to analyze plant technical information and provide technical briefings on event conditions and prognosis to licensee and offsite response organizations for each reactor at a nuclear power reactor site and for each nuclear power reactor site that the facility serves; and H.3 (3) The capability to support response to events occurring simultaneously at more than one nuclear power reactor site if the emergency operations facility serves more than one site; and N/A 8.d For nuclear power reactor licensees, an alternative facility (or facilities) that would be accessible even if the site is under threat of or experiencing hostile action, to function as a staging area for augmentation of emergency response staff and collectively having the following characteristics:

x the capability for communication with the EOF, Control Room, and plant security; H.4.2 x

the capability to perform offsite notifications; H.4.1 x

and the capability for engineering assessment activities, including damage control team planning and preparation, for use when onsite emergency facilities cannot be safely accessed during hostile action.

H.4.2 The requirements in this paragraph 8.d must be implemented no later than December 23, 2014, with the exception of the capability for staging emergency response organization personnel at the alternative facility (or facilities) and the capability for communications with the emergency operations facility, Control Room, and plant security, which must be implemented no later than June 20, 2012.

N/A 8.e A licensee shall not be subject to the requirements of paragraph 8.b of this section for an existing EOF approved as of December 23, 2011.

N/A

9. At least one onsite and one offsite communications system; each system shall have a backup power source.

F.1.a All communication plans shall have arrangements for emergencies, including titles and alternates for those in charge at both ends of the communication links and the primary and backup means of communication. Where consistent with the function of the governmental agency, these arrangements will include:

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 93 of 98 Regulatory Criteria E-Plan

a. Provision for communications with contiguous state/local governments within the plume exposure pathway EPZ.

E.1.2 F.1.a F.1.b.1 Such communications shall be tested monthly.

F.3

b. Provision for communications with federal emergency response organizations.

F.1.a Such communications systems shall be tested annually.

F.3

c. Provision for communications among the nuclear power reactor control room, the onsite TSC, and the EOF; and among the nuclear facility, the principal state and local emergency operations centers, and the field assessment teams.

F.1.a Such communications systems shall be tested annually.

F.3

d. Provisions for communications by the licensee with NRC Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear power reactor control room, the onsite TSC, and the EOF.

E.1.3 F.1.a F.1.b.2 Such communications shall be tested monthly.

F.3 10 CFR 50, Appendix E.IV.F - Training Regulatory Criteria E-Plan

1. The program to provide for:

(a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and N.1 N.2 (all)

N.3.a-e N.4 (all)

O.1 (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiological emergency shall be described.

N.2.a N.3.d O.1.a This shall include a description of specialized initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel:

i.

Directors and/or coordinators of the plant emergency organization; O.1.1 ii. Personnel responsible for accident assessment, including control room shift personnel; O.1.2 iii. Radiological monitoring teams; O.1.3 O.1.4 iv. Fire control teams (fire brigades);

O.1.7

v. Repair and damage control teams; O.1.8 vi. First aid and rescue teams; O.1.9 vii. Medical support personnel; O.1.a viii. Licensee's headquarters support personnel; N/A

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 94 of 98 Regulatory Criteria E-Plan ix. Security personnel.

O.1.6 In addition, a radiological orientation training program shall be made available to local services personnel; e.g., local emergency services/Civil Defense, local law enforcement personnel, local news media persons.

O.1.a G.5

2. The plan shall describe provisions for the conduct of emergency preparedness exercises as follows: Exercises shall test the adequacy of timing and content of implementing procedures and methods, test emergency equipment and communications networks, test the public alert and notification system, and ensure that emergency organization personnel are familiar with their duties.

N.1.1 2.a A full participation exercise which tests as much of the licensee, state, and local emergency plans as is reasonably achievable without mandatory public participation shall be conducted for each site at which a power reactor is located.

N/A Nuclear power reactor licensees shall submit exercise scenarios under §50.4 at least 60 days before use in a full participation exercise required by this paragraph 2.a.

N/A (i) For an operating license issued under this part, this exercise must be conducted within 2 years before the issuance of the first operating license for full power (one authorizing operation above 5 percent of rated thermal power) of the first reactor and shall include participation by each state and local government within the plume exposure pathway EPZ and each state within the ingestion exposure pathway EPZ. If the full participation exercise is conducted more than 1 year prior to issuance of an operating licensee for full power, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before issuance of an operating license for full power. This exercise need not have state or local government participation.

N/A (ii) For a combined license issued under part 52 of this chapter, this exercise must be conducted within two years of the scheduled date for initial loading of fuel. If the first full participation exercise is conducted more than one year before the scheduled date for initial loading of fuel, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before the scheduled date for initial loading of fuel. This exercise need not have state or local government participation. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of the first full participation exercise, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of §50.54(gg) apply.

N/A

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 95 of 98 Regulatory Criteria E-Plan (iii) For a combined license issued under part 52 of this chapter, if the applicant currently has an operating reactor at the site, an exercise, either full or partial participation, shall be conducted for each subsequent reactor constructed on the site. This exercise may be incorporated in the exercise requirements of Sections IV.F.2.b. and c. in this appendix. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of this exercise for the new reactor, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of

§50.54(gg) apply.

N/A 2.b Each licensee at each site shall conduct a subsequent exercise of its onsite emergency plan every 2 years.

N.2.a Nuclear power reactor licensees shall submit exercise scenarios under §50.4 at least 60 days before use in an exercise required by this paragraph 2.b.

N.2.a The exercise may be included in the full participation biennial exercise required by paragraph 2.c. of this section.

N.2.a In addition, the licensee shall take actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill involving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilities. The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, event classification, notification of offsite authorities, assessment of the onsite and offsite impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation.

N.4 During these drills, activation of all of the licensee's emergency response facilities (TSC, OSC, and the EOF) would not be necessary, licensees would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in all participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives.

N.1.2 2.c Offsite plans for each site shall be exercised biennially with full participation by each offsite authority having a role under the radiological response plan. Where the offsite authority has a role under a radiological response plan for more than one site, it shall fully participate in one exercise every two years and shall, at least, partially participate in other offsite plan exercises in this period.

N.2.a If two different licensees each have licensed facilities located either on the same site or on adjacent, contiguous sites, and share most of the elements defining co-located licensees, then each licensee shall:

N/A (1) Conduct an exercise biennially of its onsite emergency plan; N/A (2) Participate quadrennially in an offsite biennial full or partial participation exercise; N/A

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 96 of 98 Regulatory Criteria E-Plan (3) Conduct emergency preparedness activities and interactions in the years between its participation in the offsite full or partial participation exercise with offsite authorities, to test and maintain interface among the affected state and local authorities and the licensee. Co-located licensees shall also participate in emergency preparedness activities and interaction with offsite authorities for the period between exercises; N/A (4) Conduct a hostile action exercise of its onsite emergency plan in each exercise cycle; and N/A (5) Participate in an offsite biennial full or partial participation hostile action exercise in alternating exercise cycles.

N/A 2.d Each state with responsibility for nuclear power reactor emergency preparedness should fully participate in the ingestion pathway portion of exercises at least once every exercise cycle. In states with more than one nuclear power reactor plume exposure pathway EPZ, the state should rotate this participation from site to site.

N/A Each state with responsibility for nuclear power reactor emergency preparedness should fully participate in a hostile action exercise at least once every cycle and should fully participate in one hostile action exercise by December 31, 2015. States with more than one nuclear power reactor plume exposure pathway EPZ should rotate this participation from site to site.

N/A 2.e Licensees shall enable any state or local government located within the plume exposure pathway EPZ to participate in the licensee's drills when requested by such State or local government.

N.1.2 2.f Remedial exercises will be required if the emergency plan is not satisfactorily tested during the biennial exercise, such that NRC, in consultation with FEMA, cannot (1) find reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency or (2) determine that the Emergency Response Organization (ERO) has maintained key skills specific to emergency response. The extent of state and local participation in remedial exercises must be sufficient to show that appropriate corrective measures have been taken regarding the elements of the plan not properly tested in the previous exercises.

N.2.a 2.g All exercises, drills, and training that provide performance opportunities to develop, maintain, or demonstrate key skills must provide for formal critiques in order to identify weak or deficient areas that need correction.

N.1.a O.2.b Any weaknesses or deficiencies that are identified in a critique of exercises, drills, or training must be corrected.

N.1.b O.2.b 2.h The participation of state and local governments in an emergency exercise is not required to the extent that the applicant has identified those governments as refusing to participate further in emergency planning activities, pursuant to

§50.47(c)(1). In such cases, an exercise shall be held with the applicant or licensee and such governmental entities as elect to participate in the emergency planning process.

N.2.a

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 97 of 98 Regulatory Criteria E-Plan 2.i Licensees shall use drill and exercise scenarios that provide reasonable assurance that anticipatory responses will not result from preconditioning of participants.

N.3 Such scenarios for nuclear power reactor licensees must include a wide spectrum of radiological releases and events, including hostile action.

N.3.a-e N.4.a-k Exercise and drill scenarios as appropriate must emphasize coordination among onsite and offsite response organizations.

N.1.2 N.2.a 2.j(i) The exercises conducted under paragraph 2 of this section by nuclear power reactor licensees must provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to implement the principal functional areas of emergency response identified in paragraph 2.b of this section.

N.2.a j(ii) Each exercise must provide the opportunity for the ERO to demonstrate key skills specific to emergency response duties in the control room, TSC, OSC, EOF, and JIC.

N.2.a j(iii) In each 8-calendar-year exercise cycle, nuclear power reactor licensees shall vary the content of scenarios during exercises conducted under paragraph 2 of this section to provide the opportunity for the ERO to demonstrate proficiency in the key skills necessary to respond to the following scenario elements:

(1) Hostile action directed at the plant site, N.3.a (2) No radiological release or an unplanned minimal radiological release that does not require public protective actions; N.3.c (3) An initial classification of or rapid escalation to a Site Area Emergency or General Emergency; N.3.b (4) Implementation of strategies, procedures, and guidance developed under

§50.155(b)(2); and N.3.e (5) Integration of offsite resources with onsite response.

N.3.d j(iv) The licensee shall maintain a record of exercises conducted during each 8-year exercise cycle that documents the content of scenarios used to comply with the requirements of section IV.F.2.j of this appendix.

N.3 j(v) Each licensee shall conduct a hostile action exercise for each of its sites no later than December 31, 2015.

N/A j(vi) The first 8-year exercise cycle for a site will begin in the calendar year in which the first hostile action exercise is conducted. For a site licensed under 10 CFR part 52, the first 8-year exercise cycle begins in the calendar year of the initial exercise required by section IV.F.2.a of this appendix.

N/A 10 CFR 50, Appendix E.IV.G - Maintaining Emergency Preparedness Regulatory Criteria E-Plan Provisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.

H.11 P.4 P.10

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Columbia Generating Station Emergency Plan Appendix 2 10 CFR 50 Appendix E.IV (Content of Emergency Plans) Cross Reference Page 98 of 98 10 CFR 50, Appendix E Section IV.H - Recovery Regulatory Criteria E-Plan Criteria to be used to determine when, following an accident, reentry of the facility would be appropriate or when operation could be resumed shall be described.

M.3 10 CFR 50, Appendix E.IV.I - Onsite Protective Actions During Hostile Action Regulatory Criteria E-Plan By June 20, 2012, for nuclear power reactor licensees, a range of protective actions to protect onsite personnel during hostile action must be developed to ensure the continued ability of the licensee to safely shut down the reactor and perform the functions of the licensee's emergency plan.

J.1

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GO2-24-004 CONCURRENCE LETTERS FROM OFF-SITE RESPONSE ORGANIZATIONS (6 pages follow)

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ENERGY NORTHWEST October 26, 2023 Steve Williams Radiological Preparedness Program Manager Jennifer L. Kuklinski Emergency Preparedness P.O. Box 968, PE 30 Richland, WA 99352-0968 Ph. 509-377-4133 jlkuklinski@energy-northwest.com Operations Unit/Preparedness Section, Washington State Emergency Management Division 127 W. Clark St Pasco, WA 993001 Mr. Williams, To enhance emergency preparedness, Energy Northwest is revising our Emergency Plan for Columbia Generating Station. This letter is seeking your agency's written concurrence regarding the proposed revision to the Energy Northwest Columbia Generating Station Emergency Plan.

The revised Emergency Plan is written based off NUREG 0654 FEMA REP 1 Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. There are many efficiencies that will be realized through this revision for both Energy Northwest and our offsite partners. Utilizing revision 2 of NU REG 0654 allows Energy Northwest to take advantage of lessons learned and technologies available since NUREG 0654 Revision 1 was written and approved in 1980.

An implementation date will be scheduled after approval of the proposed revision to the Energy Northwest Columbia Generating Station Emergency Plan is received from the NRC (expected 2024). By signing this concurrence letter, you are stating that you have reviewed and concur with Energy Northwest's plan to revise the Columbia Generating Station Emergency Plan, which may result in needed changes to the State's REP documents.

If you have any questions regarding the proposed revision, please feel free to contact Jennifer Kuklinski, Manager, Emergency Preparedness at 509-377-4133 or Scott Metzger, Emergency Planner, at 509-377-2320. Otherwise, please return an original signed copy of this letter to me by November 6th, 2023.

As always, your continued support of Energy Northwest Columbia Generating Station Emergency Preparedness program and partnership is greatly appreciated.

Sincerely,

~

L. /t,.,._;(i:.rr,'b.,

Jennifer Kuklinski Manager, Emergency Preparedness

!"

Steve Williams Radiological Preparedness Program Manager Operations Unit/Preparedness Section, Washington State Emergency Management Division Page 2 of 2 October 26, 2023 Concurrence with Energy Northwest Columbia Generating Station Emergency Plan Change Proposal ACKNOWLEDGED AND AGREED I, Steve Williams, Radiological Preparedness Program Manager, Operations Unit/Preparedness Section, Washington State Emergency Management Division, acknowledge that I have received the proposed Energy Northwest Emergency Plan and attest that I did have the opportunity to provide feedback. I concur with the Energy Northwest plan to revise the Columbia Generating Station Emergency Plan and will update the required REP documents as necessary.

Signature Digitally signed by Steven Williams Date: 2023.10.26 16:36:32 -07'00' 10/26/23 Date

!"

ENERGY NORTHWEST October 26, 2023 Deanna Davis Manager, Benton County Emergency Management 625 Swift Blvd., MS-36 Richland, WA 99352 Mrs. Davis, Jennifer L. Kuklinski Emergency Preparedness P.O. Box 968, PE 30 Richland, WA 99352-0968 Ph. 509-377-4133 jlkuklinski@energy-northwest.com To enhance emergency preparedness, Energy Northwest is revising our Emergency Plan for Columbia Generating Station. This letter is seeking your agency's written concurrence regarding the proposed revision to the Energy Northwest Columbia Generating Station Emergency Plan.

The revised Emergency Plan is written based off NUREG 0654/ FEMA-REP-1 Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Supporl of Nuclear Power Plants. There are many efficiencies that will be realized through this revision for both Energy Northwest and our offsite partners. Utilizing revision 2 of NUREG 0654 allows Energy Northwest to take advantage of lessons learned and technologies available since NUREG 0654 Revision 1 was written and approved in 1980.

An implementation date will be scheduled after approval of the proposed revision to the Energy Northwest Columbia Generating Station Emergency Plan is received from the NRC (expected 2024). By signing this concurrence letter, you are stating that you have reviewed and concur with Energy Northwest's plan to revise the Columbia Generating Station Emergency Plan, which may result in needed changes to the State's REP documents.

If you have any questions regarding the proposed revision, please feel free to contact Jennifer Kuklinski, Manager, Emergency Preparedness at 509-377-4133 or Scott Metzger, Emergency Planner, at 509-377-2320. Otherwise, please return an original signed copy of this letter to me by November 6th, 2023.

As always, your continued support of Energy Northwest Columbia Generating Station Emergency Preparedness program and partnership is greatly appreciated.

Sincerely,

~L.IC..,...dU'1sb,.,

Jennifer Kuklinski Manager, Emergency Preparedness

!"

Deanna Davis Manager, Benton County Emergency Management Page2 of2 October 26, 2023 Concurrence with Energy Northwest Columbia Generating Station Emergency Plan Change Proposal ACKNOWLEDGED AND AGREED I, Deanna Davis, Manager, Benton County Emergency Management, acknowledge that I have received the proposed Energy Northwest Emergency Plan and attest that I did have the opportunity to provide feedback. I concur with the Energy Northwest plan to revise the Columbia Generating Station Emergency Plan and will update the required REP documents as necessary.

~Rarvv:naQi<;td<)

Signature 10/30/2023 Date

!"

ENERGY NORTHWEST October 26, 2023 Sean Davis Director, Franklin County Emergency Management 1011 E. Ainsworth St.

Pasco, WA 99301 Mr. Davis, Jennifer L. Kuklinski Emergency Preparedness P.O. Box 968, PE 30 Richland, WA 99352-0968 Ph. 509-377-4133 jlkuklinski@energy-northwest.com To enhance emergency preparedness, Energy Northwest is revising our Emergency Plan for Columbia Generating Station. This letter is seeking your agency's written concurrence regarding the proposed revision to the Energy Northwest Columbia Generating Station Emergency Plan.

The revised Emergency Plan is written based off NUREG 0654/ FEMA-REP-1 Revision 2, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. There are many efficiencies that will be realized through this revision for both Energy Northwest and our offsite partners. Utilizing revision 2 of NUREG 0654 allows Energy Northwest to take advantage of lessons learned and technologies available since NUREG 0654 Revision 1 was written and approved in 1980.

An implementation date will be scheduled after approval of the proposed revision to the Energy Northwest Columbia Generating Station Emergency Plan is received from the NRC (expected 2024). By signing this concurrence letter, you are stating that you have reviewed and concur with Energy Northwest's plan to revise the Columbia Generating Station Emergency Plan, which may result in needed changes to the State's REP documents.

If you have any questions regarding the proposed revision, please feel free to contact Jennifer Kuklinski, Manager, Emergency Preparedness at 509-377-4133 or Scott Metzger, Emergency Planner, at 509-377-2320. Otherwise, please return an original signed copy of this letter to me by November 6th, 2023.

As always, your continued support of Energy Northwest Columbia Generating Station Emergency Preparedness program and partnership is greatly appreciated.

Sincerely,

~L.~~

Jennifer Kuklinski Manager, Emergency Preparedness

!"

Sean Davis Director, Franklin County Emergency Management Page2 of2 October 26, 2023 Concurrence with Energy Northwest Columbia Generating Station Emergency Plan Change Proposal ACKNOWLEDGED AND AGREED I, Sean Davis, Director, Franklin County Emergency Management, acknowledge that I have received the proposed Energy Northwest Emergency Plan and attest that I did have the opportunity to provide feedback. I concur with the Energy Northwest plan to revise the Columbia Generating Station Emergency Plan and will update the required REP documents as necessary.

10/30/2023 Signature Date

v t e Letter Sequence Request
EPID:L-2024-LLA-0011, TSTF-359, TSTF-529, Clarify Use and Application Rules, TSTF-359 (Approved, Closed)
Initiation Request, Request, Request Acceptance, Acceptance Supplement, Supplement Administration Questions 1 August 2024 Answers 10 September 2024 Results Approval, Approval, Approval, Approval Other: ML24234A029, ML24234A030
MONTHYEAR2024-08-01 [Table View]

GO2-24-004, License Amendment Request to Revise Emergency Plan

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Subject:

Dear Sir or Madam:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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GO2-24-004, License Amendment Request to Revise Emergency Plan

Text

Subject:

Dear Sir or Madam:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Response

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