ML24324A288
| ML24324A288 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 03/13/2025 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Schuetz R Energy Northwest |
| Chawla M | |
| References | |
| EPID L-2024-LLA-0011 | |
| Download: ML24324A288 (44) | |
Text
March 13, 2025 Robert Schuetz Chief Executive Officer Energy Northwest MD 1023 76 North Power Plant Loop P.O. Box 968 Richland, WA 99352
SUBJECT:
COLUMBIA GENERATING STATION - ISSUANCE OF AMENDMENT NO. 276 FOR REVISION TO THE EMERGENCY PLAN (EPID L-2024-LLA-0011)
Dear Robert Schuetz:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 276 to Renewed Facility Operating License No. NPF-21 for the Columbia Generating Station (Columbia). The amendment consists of changes to the Columbia Emergency Plan in response to your application dated January 30, 2024, as supplemented by letters dated March 20, 2024, September 10, 2024, and September 24, 2024.
The amendment revises the Columbia Emergency Plan pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q). Specifically, Energy Northwest (the licensee) developed a proposed Columbia Emergency Plan utilizing the guidance 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, dated December 2019 (Agencywide Documents Access and Management System Accession No. ML19347D139). The proposed plan establishes an updated licensing basis for Columbia. The licensee stated that an evaluation of the proposed changes pursuant to 10 CFR 50.54(q) determined that the proposed changes result in a potential reduction of effectiveness of the Columbia Emergency Plan and therefore require prior NRC approval.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-397
Enclosures:
- 1. Amendment No. 276 to NPF-21
- 2. Safety Evaluation cc: Listserv
ENERGY NORTHWEST DOCKET NO. 50-397 COLUMBIA GENERATING STATION AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 276 License No. NPF-21
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Energy Northwest (the licensee) dated January 30, 2024, as supplemented by letters dated March 20, 2024, September 10, 2024, and September 24, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, by Amendment No. 276, Renewed Facility Operating License No. NPF-21 is hereby amended to authorize revision to the Emergency Plan for Columbia Generating Station, as set forth in Energy Northwests application dated January 30, 2024, as supplemented by letters dated March 20, 2024, September 10, 2024, and September 24, 2024, and evaluated in the NRC staffs safety evaluation associated with this amendment.
- 3.
The license amendment is effective as of its date of issuance and shall be implemented no later than December 31, 2025.
FOR THE NUCLEAR REGULATORY COMMISSION Laura A. Dudes, Acting Director Office of Nuclear Reactor Regulation Date of Issuance: March 13, 2025 LAURA DUDES Digitally signed by LAURA DUDES Date: 2025.03.13 16:32:21 -04'00'
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 276 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397
1.0 INTRODUCTION
By application dated January 30, 2024 (Reference 1), as supplemented by letters dated March 20, September 10, and September 24, 2024 (References 2, 3, and 4, respectively),
Energy Northwest (the licensee) submitted changes to the Columbia Generating Station (Columbia) Emergency Plan for U.S. Nuclear Regulatory Commission (NRC, the Commission) review and prior approval pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q). The licensees evaluation of the proposed changes pursuant to 10 CFR 50.54(q) determined that the proposed changes result in a potential reduction of effectiveness of the Columbia Emergency Plan and therefore require prior NRC approval. Specifically, the licensee developed a proposed Columbia Emergency Plan utilizing the guidance 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 (NUREG-0654), dated December 2019 (Reference 5). The proposed plan establishes an updated licensing basis for Columbia.
The supplemental letters dated September 10, 2024, and September 24, 2024, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs proposed finding that the amendment involves no significant hazards consideration, as published in the Federal Register (FR) on June 11, 2024 (89 FR 49241). There has been no public comment on this finding.
2.0 REGULATORY EVALUATION
The regulatory requirements and guidance, on which the NRC staff based this review, are provided below.
2.1 Regulations The planning standards, as set forth in 10 CFR 50.47(b), establish the requirements that the onsite and offsite emergency response plans must meet in order for the NRC staff to find that
there is reasonable assurance that the licensee will take adequate protective measures in the event of a radiological emergency.
In addition, Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV.1, states, in part:
[T]he emergency response plans submitted by an applicant for a nuclear power reactor operating license under this part, or for an early site permit (as applicable) or combined license under 10 CFR part 52, shall contain information needed to demonstrate compliance with the standards described in
[10 CFR] 50.47(b), and they will be evaluated against those standards.
The requirements for making changes to emergency plans, as set forth in 10 CFR 50.54(q)(4),
state, in part:
The changes to a licensees emergency plan that reduce the effectiveness of the plan as described in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC.
2.2 Guidance The NRC staff used the following applicable guidance documents to conduct its review:
Regulatory Guide 1.101, Revision 6, Emergency Response Planning and Preparedness for Nuclear Power Reactors, dated June 2021 (Reference 6), endorses NUREG-0654, which provides specific acceptance criteria for complying with the planning standards set forth in 10 CFR 50.47, Emergency plans. These criteria provide a basis for NRC licensees (and applicants), and State and local governments to develop acceptable radiological emergency preparedness plans.
Regulatory Issue Summary 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, dated August 5, 2016 (Reference 7), provides examples of the scope and detail of information that should be provided in license amendment requests (LARs) related to emergency response organization (ERO) staffing and augmentation to facilitate the NRC staffs review. The staff considered these examples as part of its review.
3.0 TECHNICAL EVALUATION
The NRC staff has reviewed the licensees regulatory and technical analyses in support of its proposed Columbia Emergency Plan as described in its LAR, as supplemented. The proposed Columbia Emergency Plan is structured to follow the general format of NUREG-0654. The following NRC staff technical evaluation of the LAR is structured to reflect the 16 planning standards in section II, Planning Standards and Evaluation Criteria, of NUREG-0654, and addresses the requirements in 10 CFR 50.47(b), including any applicable requirements in Appendix E to 10 CFR Part 50.
3.1 Background
The licensee stated, in part, in its LAR:
The proposed Columbia Emergency Plan was developed based upon the updated NRC guidance contained in NUREG-0654/FEMA-REP-1, 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.
The licensee also stated that the proposed Columbia Emergency Plan is aligned and formatted consistent with the new demonstration criteria and level of detail of NUREG-0654.
The LAR includes, as enclosures, the licensees evaluation of the proposed changes, the proposed Columbia Emergency Plan, and letters of concurrence from offsite response organizations (OROs). In the supplemental letter dated March 20, 2024, the licensee provided an analysis that compared the wording of the current emergency plan with the proposed emergency plan. Additionally, the licensee provided responses to the NRC staffs requests for additional information in the supplemental letters dated September 10, 2024, and September 24, 2024.
3.2 Evaluation Section II of NUREG-0654 contains evaluation criteria for each planning standard of 10 CFR 50.47(b). The following discussion provides the results of the NRC staffs review of the proposed Columbia Emergency Plan and the staffs finding that all 16 planning standards and evaluation criteria of NUREG-0654 are met:
A. Assignment of Responsibility B. Emergency Response Organization C. Emergency Response Support and Resources D. Emergency Classification System E. Notification Methods and Procedures F. Emergency Communications G. Public Education and Information H. Emergency Facilities and Equipment I.
Accident Assessment J. Protective Response K. Radiological Exposure Control L. Medical and Public Health Support M. Recovery, Reentry, and Post Accident Operations N. Exercises and Drills O. Radiological Emergency Response Training P. Responsibility for the Planning Effort: Development, Periodic Review, and Distribution of Emergency Plans.
3.2.1 Criterion II.A, Assignment of Responsibility NUREG-0654, Evaluation Criterion II.A, addresses planning standard 10 CFR 50.47(b)(1),
which states:
Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
The requirements of 10 CFR 50.47(b)(1) are addressed in section A, Assignment of Responsibility, of the proposed Columbia Emergency Plan. The proposed Columbia Emergency Plan describes the assignment of responsibility to Energy Northwest and Federal, State, and county organizations within the emergency planning zones (EPZs) for Columbia. For review purposes, there are two EPZs considered for planning purposes. The first is a 10-mile plume exposure pathway planning zone and the second is a 50-mile ingestion pathway planning zone.
In the proposed Columbia Emergency Plan, the licensee states that it 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.
The proposed Columbia Emergency Plan relies on Federal, State, and local organizations to provide emergency response assistance. This assistance will be provided by Federal, State, and county agencies that are mandated by charter, regulation, or law to protect public health and safety. Energy Northwest and other entities that are expected to provide emergency response support have developed memoranda of understanding (MOUs) and/or letters of agreement (LOAs). A contract/purchase order with a private contractor is also considered acceptable in lieu of an MOU or LOA for the specified duration of the contract. Energy Northwest states that the current copies of applicable MOUs/LOAs and contracts are kept in the Columbia records management system.
The proposed Columbia Emergency Plan states that Columbia is integrated with response plans maintained by Washington State, Oregon State, Benton County, Franklin County, Department of Energy - Richland Operations (DOE-RL), and the NRC.
The proposed Columbia Emergency Plan states that Columbia maintains an ERO that is capable of providing continuous 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).
Because the proposed Columbia Emergency Plan provides information that describes the primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the EPZs, the NRC staff finds that the information related to Evaluation Criterion II.A is acceptable in its identification of key responsibilities during a response.
3.2.1.1 Criterion II.A Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has identified (1) the primary responsibilities for emergency response by the licensee and Federal, State, and local organizations within the EPZs; (2) that the emergency responsibilities of the various supporting organizations have been specifically established; and (3) that each principal response organization has staff to respond and to augment its initial response on a continuous basis. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(1) has been adequately addressed.
3.2.2 Criterion II.B, Emergency Response Organization NUREG-0654, Evaluation Criterion II.B, addresses planning standard 10 CFR 50.47(b)(2),
which states:
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.
As noted above,Section IV.A of Appendix E to 10 CFR Part 50 states, in part:
The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization and the means for notification of such individuals in the event of an emergency.
The requirements of 10 CFR 50.47(b)(2) and applicable requirements of Section IV.A of Appendix E to 10 CFR Part 50 are addressed in portions of section B, Emergency Response Organization, of the proposed Columbia Emergency Plan.
In April 2004, the licensee submitted a request to revise the augmentation time goal for Columbias emergency response facilities (ERFs) from 60 minutes to 90 minutes. The NRC staff reviewed the licensees request and approved it by letter dated August 31, 2004 (Reference 8).
The current Columbia Emergency Plan states that ERFs are staffed and activated within 90 minutes of the Alert emergency classification level.
The proposed Columbia Emergency Plan describes the primary responsibilities of the ERO. The NRC staff verified that the proposed Columbia Emergency Plan describes ERO staffing based on the guidance in NUREG-0654. This description includes ERO facility staffing and primary emergency planning and preparedness (EP) responsibilities. The licensee stated that changes in the proposed Emergency Plan that could be considered a reduction in effectiveness from the updated NUREG-0654 guidance or from the current Columbia Emergency Plan have been identified in the LAR as deviations.
In conjunction with the LAR, the licensee performed and documented an on-shift staffing analysis per 10 CFR Part 50, Appendix E, Section IV.A.9 to verify that the initial on-shift response members do not have conflicting responsibilities.
The proposed Columbia Emergency Plan states that a Shift Manager is on-shift at all times and assumes the role of the Emergency Director upon declaration of an emergency. 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 protective action recommendations (PARs) to county and State authorities. Emergency Director responsibilities also include coordinating the use of outside emergency response resources.
The proposed Columbia Emergency Plan defines non-delegable responsibilities as: event declaration, PARs for the general public, notification of offsite authorities, and emergency exposure (dose limits and potassium iodide). The responsibility for event classification, notification of State and county offsite authorities and the NRC, and PARs for the general public is transferred to the emergency operating facility (EOF) Emergency Director when the Shift Manager is relieved of overall command and control of emergency response. Responsibility for emergency exposure controls initially resides with the Emergency Director but may be delegated to the technical support center (TSC) and EOF Radiation Protection Manager positions.
The proposed Columbia Emergency Plan includes a block diagram that illustrates the interfaces between and among Energy Northwest, Federal, State, and county OROs, and local services support.
The proposed Columbia Emergency Plan states that dependent upon the emergency, a near or onsite Incident Command Post is established in coordination with local support organizations.
The Incident Command Post will interface with the Columbia site security and the Columbia ERFs.
3.2.2.1 Deviations The licensee states that the ERO key function analysis identified 10 deviations as a result of the proposed changes to the on-shift and augmenting ERO positions based on a difference between the proposed Columbia Emergency Plan and the current Columbia Emergency Plan.
The licensee also evaluates this as compared to NUREG-0654 guidance and the proposed Columbia Emergency Plan where applicable. The NRC staff is using the numbering assigned to the deviations by the licensee in its LAR.
[Deviation 1-1] No Minimum Staff Technical Support Center Emergency Coordinator Position The licensee states:
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.
Both the current and proposed Emergency Plans require simultaneous activation of the TSC and EOF at an Alert emergency classification level. The current
[Columbia] Emergency Plan anticipates relief of command and control [function]
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
[Columbia] Emergency Plan does not provide for the relief of command and
control [function] 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.
Although different from the guidance of NUREG-0654 (which specifies assigning a minimum staff Emergency Coordinator ERO position in the TSC to the Command-and-Control function) and the current Columbia Emergency Plan as discussed above, the proposed Columbia Emergency Plan will retain a Shift Manager/Emergency Director until relieved by the EOF Manager within 90 minutes of an Alert or higher emergency classification level. With both the current and proposed Columbia Emergency Plans requiring simultaneous activation of the TSC and EOF at an Alert emergency classification level, the relief of the Command-and-Control function by a TSC Manager would be a duplication of the function and therefore is not needed.
Therefore, the NRC staff finds that the proposed change to not assign a minimum staff Emergency Coordinator ERO position in the TSC to the Command-and-Control function is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-2] No Minimum Staff Technical Support Center Offsite Response Organization Communicator Position The licensee states:
The proposed [Columbia] 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 [Columbia] Emergency Plan requirements and NUREG-0654, Revision 2 guidance for minimum staff ERO positions.
The licensee states that the current Columbia Emergency Plan assigns the ORO Communications function as a collateral duty to the minimum staff TSC Operations Manager and the non-minimum staff Assistant EOF Manager positions at the Alert emergency classification level. The process of two functions being assigned to a single position is not being altered in the proposed Columbia Emergency Plan.
The licensee further states:
Both the current and proposed Columbia Emergency Plans require simultaneous activation of the TSC and EOF at an Alert emergency classification level. The current [Columbia] Emergency Plan anticipates relief of ORO Communication
[function] 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 [function]
cannot be performed in the EOF. The proposed [Columbia] Emergency Plan transfers the ORO aspect of the Communications function from the dedicated on-shift State/County Notifier to the non-minimum staff Assistant EOF Manager, making it unnecessary to staff a TSC ORO Communicator ERO position.
Although different from the guidance of NUREG-0654 (which specifies assigning a minimum staff ORO Communicator position in the TSC) and the current Columbia Emergency Plan as discussed above, the proposed Columbia Emergency Plan will retain on-shift ORO communications function until relieved by the Assistant EOF Manager within 90 minutes of an Alert or higher emergency classification level. With both the current and proposed Columbia Emergency Plans requiring simultaneous activation of the TSC and EOF at an Alert emergency classification level, the relief of ORO communications by the TSC ERO staff, currently the Operations Manager, would be a duplication of the function and therefore not needed.
Therefore, the NRC staff finds that the proposed change to not assign a minimum staff TSC ORO Communicator ERO position for the communications function is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-3] No Minimum Staff Technical Support Center Dose Assessor Position The licensee states:
The current [Columbia] 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 [Columbia] Emergency Plan does not assign an ERO position in the TSC to the Dose Assessments/Projections function. The proposed [Columbia] Emergency Plan assigns a minimum staff EOF Dose Assessor ERO position to the Dose Assessments/Projections function at the Alert emergency classification level.
Both the current and proposed Columbia Emergency Plans require simultaneous activation of the TSC and EOF at an Alert emergency classification level. The current [Columbia] 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 [Columbia]
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.
Although different from the guidance of NUREG-0654 (which specifies assigning a minimum staff Dose Assessor ERO position in the TSC to the dose assessment function) and the current Columbia Emergency Plan as discussed above, the proposed Columbia Emergency Plan will retain Dose Assessment/Projections function with the on-shift Dose Assessor until relieved by the EOF Dose Assessor within 90 minutes of an Alert or higher emergency classification level. With both the current and proposed Emergency Plans requiring simultaneous activation of the TSC and EOF at an Alert emergency classification level, the Dose Assessment/Projection by a TSC ERO staff, currently the RP Manager, is a duplication of the function and therefore not needed.
Therefore, the NRC staff finds that the proposed change to not assign an ERO position in the TSC to the Dose Assessments/Projections function is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-4] On-Shift Chemistry Technician Position Removed The licensee states:
The proposed [Columbia] Emergency Plan removes the on-shift Chemistry Technician.
This change deviates from current [Columbia] Emergency Plan requirements for on-shift ERO positions.
The licensee states that the basis for maintaining an on-shift Chemistry Technician was conformance to the guidance in NUREG-0654, Revision 1, which included the major task of Chemistry/Radiochemistry under the Radiological Accident Assessment and Support of Operational Accident Assessment function. NUREG-0654, Revision 2, no longer requires the Chemistry/Radiochemistry task in support of the assessment function as part of the ERO response activities.
The licensee concluded that the removal of the on-shift Chemistry Technician is justified because the proposed Columbia Emergency Plan does not contain emergency plan-related response tasks or functions for an on-shift Chemistry Technician. Two of the three tasks assigned to the Chemistry Technician have been eliminated and the remaining task of activating the Emergency Response Data System (ERDS) is performed by the Shift Technical Advisor/Incident Advisor.
Because the Chemistry function is not included in NUREG-0654, Revision 2, and because the Chemistry Technician position is not assigned any emergency plan implementation functions, the NRC staff finds that the proposed removal of the on-shift Chemistry Technician is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-5] No Minimum Staff On-site Field Monitoring Team Driver Position The licensee states:
The current [Columbia] Emergency Plan assigns two minimum staff FMT [Field Monitoring Team] 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 [Columbia] Emergency Plan does not assign an on-site FMT Driver ERO position. On-site field monitoring activities in the proposed [Columbia] Emergency Plan are performed by the FMT Technician on foot.
The proposed Columbia 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 [and] 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.
Although different from the guidance of NUREG-0654 (which specifies assigning a minimum staff driver ERO position to the onsite field monitoring team function) and the current Columbia Emergency Plan as discussed above, the NRC staff reviewed the licensees proposed changes for the removal of the driver position from the onsite FMT function from ERO minimum staff.
Given the size of the Columbia Protected Area, and the ability for the remaining member to traverse on foot, the NRC staff finds this removal acceptable. Therefore, the staff finds that the proposed change to not assign an onsite FMT driver position is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-6] Minimum Staff Technical and Operations Manager Positions Removed The licensee states that the current Columbia Emergency Plan assigns minimum staff Operations Manager and Technical Manager ERO positions at the Alert emergency classification level to the Engineering function. The proposed Columbia Emergency Plan retains a non-minimum staff Operations Manager ERO position and eliminates the Technical Manager ERO position.
The licensee states that 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.
The licensee further states that there is no site-specific basis that requires the Technical Manager as a minimum staff ERO position. The proposed Columbia Emergency Plan retains the minimum staff Core/Thermal Hydraulics Engineer, Electrical/Instrumentation and Control (I&C) Engineer, and Mechanical Engineer, which meets the guidance of NUREG-0654 for the Engineering function.
Additionally, the licensee states that the TSC Manager is the ERO position responsible for supervising the engineering and operations staff in the analysis of plant parameters and event indications for accident detection and assessment activities. The TSC Manager ERO position will no longer be used to take interim command and control as the Emergency Director, allowing the focus to remain primarily on response activities inside the protected area. Specifically, the Technical Manager is assigned seven tasks within the current emergency plan implementing procedures. The TSC Manager, as discussed earlier in this paragraph, performs the supervision of engineering and operations staff. Another three of the seven tasks are performed by other ERO positions and the TSC Manager (response support and resources, accident assessment, and coordinating outside engineering support). Finally, three of the tasks were administrative in nature and applicable to ERO positions in general.
The licensee further states that 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 remain 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.
The NRC staff reviewed the licensees proposed changes to retain a non-minimum staff Operations Manager position and eliminate the Technical Manager position. Because the proposed Columbia Emergency Plan provides for Command-and-Control to be transferred directly from the Shift Manager to the EOF Manager, reduced burden on the TSC Manager to be able to perform supervision duties, and the assignment of the other ERO functions to remaining ERO positions, the NRC staff finds that the proposed change to retain a non-minimum staff Operations Manager position and eliminate the Technical Manager ERO position is acceptable. The proposed Columbia Emergency Plan retains the minimum staff Core/Thermal Hydraulics Engineer, Electrical/I&C Engineer, and Mechanical Engineer, which meets the guidance of NUREG-0654 for the Engineering function.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-7] Single Minimum Staff Maintenance Lead Position The licensee states:
The current [Columbia] Emergency Plan assigns non-minimum staff Mechanical, Electrical and I&C Lead ERO positions in the OSC [Operations Support Center].
The proposed [Columbia] Emergency Plan assigns a single minimum staff Maintenance Lead ERO position in the OSC.
The normal Maintenance organization [at Columbia] 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.
Although different from the guidance of NUREG-0654 (which specifies Mechanical, Electrical and I&C Supervisor Positions) and the current Columbia Emergency Plan as discussed above, the Maintenance Lead is filled by management and supervisory personnel with common qualifications from the maintenance department who provide direction to multiple craft disciplines. Therefore, the NRC staff finds that the Supervision of Repair Team Activities function is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-8] Fewer Minimum Staff Craft Personnel The licensee states that the proposed [Columbia] Emergency Plan reduces the number of minimum staff positions assigned to the Repair Team Activities function. Specifically:
Electricians reduced from two to one Radiological Waste (Radwaste) Operator removed Chemistry Technician removed The licensee proposes to have one electrician, one mechanic, and one I&C technician in the OSC within 90 minutes of an Alert or greater emergency classification level, respectively.
The licensee states that this change aligns the proposed Columbia Emergency Plan with the NUREG-0654 staffing plan guidance.
The licensee states:
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 [the Nuclear Energy Institute (NEI) document]
NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, [dated May 2012 (Reference 9),]
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.
The licensee states that the NRC previously found the 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.
The licensee further states that a comparison of the training requirements from the 2004 timeframe associated with the referenced NRC safety evaluation (Reference 8), and the requirements from the current Equipment Operator Qualification Directory shows that the EOs receive the same cross-training based on the requirements of Columbias Final Safety Analysis Report, and that the basis for the NRC staffs 2004 approval remains valid for the cross-training of the on-shift EOs.
Because the proposed Columbia Emergency Plan aligns with NUREG-0654 for the number of minimum augmenting positions assigned to the Repair Team Activities function and the cross-training of on-shift EOs in mechanical, electrical, and I&C maintenance activities to support essential repair and corrective actions within 90 minutes of event classification prior to staff
augmentation, the NRC staff finds that the proposed staffing of the Repair Team Activities function is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-9] No Minimum Staff Technical Support Center Security Liaison Position The licensee states:
Both the current and proposed [Columbia] 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 proposed Columbia Emergency Plan deviates from guidance in NUREG-0654 by not assigning a TSC Security Liaison Position as a minimum staff position.
The licensee states:
The current Security organization staffing at Columbia is such that the requirements of the Physical Security Plan and the proposed [Columbia]
Emergency Plan can be performed simultaneously for any event, and does not require direct relief from a minimum staff ERO position.
The guidance in NUREG-0654 assigns one minimum staff TSC Security Liaison ERO position at the Alert emergency classification level to the Security function. However, the intent of NUREG-0654 is still met by the proposed Columbia Emergency Plan by providing sufficient on-shift personnel resources and a dedicated non-minimum staff EOF Security Manager at the Alert emergency classification level.
Because the proposed Columbia Emergency Plan assigns two on-shift Security positions that coordinate security-related activities with augmentation of a non-minimum staff Security Manager ERO position at the Alert emergency classification level, the NRC staff finds that the proposal to not assign a TSC Security Liaison Position as a minimum staff position in the Columbia Emergency Plan is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
[Deviation 1-10] No Minimum Staff Information Technology Lead Positions The licensee states:
The proposed [Columbia] 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 Columbia Emergency Plan requirements and NUREG- 0654/FEMA-REP-1, Revision 2 guidance for collateral duties assigned to minimum staff ERO positions.
The current [Columbia] Emergency Plan assigns a dedicated minimum staff EOF Telecommunications (Telecomm) Manager ERO position at the Alert emergency classification level. The proposed [Columbia] Emergency Plan assigns a dedicated non-minimum staff EOF Telecomm Manager ERO position at the Alert emergency classification level.
NUREG-0654 guidance states that information technology (IT) staff ERO positions be provided in the emergency plan if Critical Digital Assets are identified in the ERFs per 10 CFR 73.54, Protection of digital computer and communication systems and networks.
The licensee states that it conducted an evaluation of the EP-related digital assets in accordance with the NRCs Cyber Security Rule (i.e., 10 CFR 73.54(b)) and NEI 13-10, Cyber Security Control Assessments, Revision 6, dated August 2017 (Reference 10), and controls have been put in place to protect the EP critical digital assets from cyber-attacks. Along with the controls, the licensee states that Columbia has alternate administrative, non-digital, or adequately independent means that are in place for performing each EP function, should the digital component or program fail, continuous remote coverage of the IT department (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s/day, 7 days/week (24/7)), and built-in redundancy for communication systems and digital EP assets.
The licensee states that it reviews the performance of digital equipment used by EP during drills and exercises and through routine surveillance checks, and it has performed acceptably.
Additionally, this 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.
The licensee concludes that with the evaluation of assets, backup capabilities, and remote coverage for IT support, along with the non-minimum staff EOF Telecomm Manager ERO position, it has identified that there is no need to maintain the IT function as a collateral duty for a minimum staff ERO position in the TSC or EOF.
Because the licensee maintains an IT department process for 24/7 coverage and built-in redundancy for communication systems and digital EP assets, the NRC staff finds that the IT function is acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
3.2.2.2 Non-Minimum Augmenting ERO NUREG-0654, Table B-1, Note iii states:
The minimum ERO staffing plan is that which is required to effectively implement the site-specific emergency plan (i.e., the emergency plan cannot be effectively implemented without this staff). The emergency plan should only describe the minimum ERO staffing plan, while supporting implementing procedures can
describe any additional staff response desired by the licensee, as this additional staff is not critical to effective emergency plan implementation. The augmentation times listed are intended to provide a model for applicants and licensees to consider in the development of their site-specific emergency plan.
The licensee states that all non-minimum staff ERO positions have been removed from the proposed Columbia Emergency Plan, but several will be retained in the emergency plan implementing procedures. 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.
The licensee states that additional non-ERO personnel can be called as needed to support ERO response activities. These personnel will perform activities related to their normal jobs (e.g.,
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 Operations Manager1 TSC Information Coordinator Plant Administrative Manager TSC Manager Secretary OSC Repair Team Coordinator Team Tracker (from 2 to 1)
EOF Telecommunications Manager2 EOF Information Coordinator Site Support Manager Security Manager EOF Manager Secretary Manpower Scheduler Public Information Officer State/County Technical Liaison Energy Northwest County Emergency Operations Center (EOC) Representative Energy Northwest State EOC Representative 1 Changed from Minimum to Non-Minimum Staff between the current and proposed Columbia Emergency Plans.
2 Changed from Minimum to Non-Minimum Staff between the current and proposed Columbia Emergency Plans.
Joint Information Center (JIC)
JIC Manager3 Social Media Coordinator4 Energy Northwest Spokesperson Technical Spokesperson Assistant JIC Manager - Press Conferences Assistant JIC Manager - News Release Coordinator Media Coordinator Support Manager Information Manager Phone Team Supervisor (from 2 to 1)
News Release Editor Media Phone Team (from 4 to 3)
Public Phone Team (from 4 to 2)
Distribution Team (from 2 to 1)
Audio/Visual JIC Secretary Non-minimum staff ERO positions removed from the proposed Columbia Emergency Plan and not retained in the implementing procedures are shown below. All tasks previously assigned to the eliminated ERO positions that involve response actions for key functions continue to be performed by the remaining ERO positions in the proposed Columbia Emergency Plan.
TSC Chemistry/Effluent Manager Maintenance Manager Computer Engineer Administrative Support Staff EOF Engineering Manager Radiation Detection Systems Engineer Field Team Dispatcher Plant Display and Information System Analyst Administrative Support Staff PIO Technical Support Industrial Development Authority JIC Health Physics Spokesperson Distribution Team Supervisor Receptionist Because Energy Northwest identified the response tasks previously completed by those positions being removed and stated that these tasks will be retained and completed by the 3 Changed from Minimum to Non-Minimum Staff between the current and proposed Columbia Emergency Plans.
4 Added to emergency plan implementing procedures per proposed Columbia Emergency Plan.
remaining ERO responders, the NRC staff finds that the proposed changes to the non-minimum staff ERO positions are acceptable.
Based on the above, the NRC staff concludes that the proposed Columbia Emergency Plan will continue to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Appendix E to 10 CFR Part 50, Section IV.A.
3.2.2.3 Criterion II.B Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has defined on-shift responsibilities, provided adequate staffing to always maintain initial accident response in key functional areas, included timely augmentation of response capabilities, and specified the interfaces among various onsite and offsite response activities and support.
Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(2) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.
3.2.3 Criterion II.C, Emergency Response Support and Resources NUREG-0654, Evaluation Criterion II.C, addresses planning standard 10 CFR 50.47(b)(3),
which states:
Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified.
Section IV.A.7 of Appendix E to 10 CFR Part 50 requires the identification of, and a description of the assistance expected from, appropriate Federal, State, and local agencies with responsibilities for coping with emergencies, including hostile action at the site.
Section IV.E.8.b.1 of Appendix E to 10 CFR Part 50 requires space for members of an NRC site team and Federal, State, and local responders.
The requirements of 10 CFR 50.47(b)(3) and the applicable requirements of Section IV.A.7 and Section E of Appendix E to 10 CFR Part 50 are addressed in portions of section C, Emergency Response Support and Resources, of the proposed Columbia Emergency Plan.
The proposed Columbia 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. Specifically for the NRC, the proposed Columbia Emergency Plan states that there are dedicated work areas and resources for NRC response personnel that provide access to plant data and radiological information.
The proposed Columbia Emergency Plan states that 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 Columbia and have developed radiological emergency plans and procedures in an integrated manner. Additionally, LOAs/MOUs have been developed between Columbia and several entities to provide emergency response support and services consistent with this plan. The Emergency
Director is the individual authorized to request assistance and resources from responding organizations.
The proposed Columbia Emergency Plan states that site access is controlled at all times by the Columbia security organization in accordance with the site security plan and procedures.
Assistance for support organizations responding to the site is coordinated through the EOF.
The proposed Columbia Emergency Plan states that, in addition to response coordination efforts between individuals in command and control of each organization, Columbia liaisons may be dispatched to the Washington State EOC, Benton County EOC, and Franklin County EOC. The Columbia liaisons clarify information contained in emergency notifications and provide a communications link between the EOF and the offsite centers.
Columbia 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 Columbia during an event.
The proposed Columbia Emergency Plan states that if an emergency occurs, ERO personnel will initiate 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).
The proposed Columbia Emergency Plan states that 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 NRC Emergency Notification System (ENS) line and radiological background for the NRC Health Physics Network (HPN) line) to ensure efficient and effective information flow.
Because the proposed Columbia Emergency Plan provides information for an integrated response and the process to request additional resources along with laboratory availability during a response, the NRC staff finds that the information related to Evaluation Criterion II.C is acceptable in its identification of resourcing and augmenting support during a response.
3.2.3.1 Criterion II.C Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has identified the arrangements for requesting and effectively using assistance resources, provided arrangements to accommodate State and local staff at the licensees EOF, and identified other organizations capable of augmenting the planned response. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(3) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.
3.2.4 Criterion II.D, Emergency Classification System NUREG-0654, Evaluation Criterion II.D, addresses planning standard 10 CFR 50.47(b)(4),
which states:
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 local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.
Section IV.B.1 of Appendix E to 10 CFR Part 50 requires, in part:
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.
Section IV.C.2 of Appendix E to 10 CFR Part 50 requires, in part:
[N]uclear 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.
The requirements of 10 CFR 50.47(b)(4) and the applicable requirements of Sections IV.B.1 and IV.C.2 of Appendix E to 10 CFR Part 50 are addressed in section D, Emergency Classification System, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan provides an overall discussion regarding classification of emergencies and the basis for emergency classification. The Columbia emergency action levels (EALs) were developed in accordance with the NEI document, NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (Reference 11), which was endorsed by the NRC by letter dated March 28, 2013 (Reference 12), as acceptable generic EAL scheme development guidance. The EAL scheme includes plant systems and radiological effluent parameters to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The licensee states that the EAL scheme has been agreed to by DOE-RL, Washington State, Benton County, and Franklin County and is reviewed on an annual basis.
The proposed Columbia Emergency Plan states that it 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.
A summary of emergency response measures for each emergency classification level is provided in section D, Emergency Classification System, of the proposed Columbia Emergency Plan. The proposed Columbia Emergency Plan states that Columbia maintains procedures that provide response actions to be taken under the four emergency classification levels.
Because the proposed Columbia Emergency Plan provides information that describes Columbias ability to provide timely declarations based on an NRC-approved EALs and provided a summary of general actions taken at each emergency classification level, the NRC staff finds that the information related to Evaluation Criterion II.D is acceptable in its identification of information that Columbia can timely classify the emergency during a response.
3.2.4.1 Criterion II.D Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has identified a standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(4) and applicable requirements of Appendix E to 10 CFR Part 50 have been adequately addressed.
3.2.5 Criterion II.E, Notification Methods and Procedures NUREG-0654, Evaluation Criterion II.E, addresses planning standard 10 CFR 50.47(b)(5),
which states:
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 followup 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 Emergency Planning Zone have been established.
The requirements of 10 CFR 50.47(b)(5) are addressed in section E, Notification Methods and Procedures, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan describes the notification methods and procedures to ensure prompt notification to State and local response organizations and all identified emergency personnel. 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 Columbia declared emergency and notifying Columbia of a declared emergency at another Hanford Site area facility. Washington State is responsible for notifying Oregon State. Initial notification to DOE-RL, State and county agencies, and the NRC includes a means of verification or authentication. Energy Northwest will notify the NRC as soon as possible after notification of the State and county agencies, and not later than one hour after emergency declaration. An accelerated call to the NRC will be made after notification of local law enforcement agencies, 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 that the NRC is notified of safeguards events.
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:
Site name Time of event declaration The emergency classification level Wind speed and direction Whether a release is in progress due to the event PAR, if applicable.
Follow-up message content includes additional information regarding event conditions and response actions (e.g., radiological release details, offsite support, event prognosis, etc.).
The proposed Columbia Emergency Plan states that sirens are the primary means of alert and prompt notification in the residential, commercial, agricultural, and recreational areas of the Columbia 10-mile EPZ (nominally outside the boundaries of the DOE-RL Hanford Site) and within the public recreation areas along the Columbia River. 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.
Sirens are supplemented by tone alert radios for a small, special communication needs population (i.e., 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 serves as the backup Alert Notification System.
Emergency notification to resident and transient populations is the responsibility of Benton County and Franklin County agencies. The DOE-RL maintains a system for notifying and providing information to its employees and contractors on the Hanford Site.
Notification instructions are based on information received from Columbia 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.
Because the proposed Columbia Emergency Plan provides information that describes methods and messages for alerting licensee personnel, OROs, and the public during a response to a declared emergency, the NRC staff finds that the information related to Evaluation Criterion II.E is acceptable in its identification of timely communication during a response to a declared emergency.
3.2.5.1 Criterion II.E Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established provisions for notification of State and local response organizations and of licensee emergency personnel, the content of initial and follow-up messages to response organizations, and means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ at each site. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(5) has been adequately addressed.
3.2.6 Criterion II.F, Emergency Communications NUREG-0654, Evaluation Criterion II.F, addresses planning standard 10 CFR 50.47(b)(6),
which states:
Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public.
The requirements of 10 CFR 50.47(b)(6) are addressed in Section F, Emergency Communications, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that Columbia maintains communications systems that are designed to facilitate normal and emergency communication. The communications systems are continuously available between Columbia, DOE-RL, State, county, and NRC personnel. Suitable normal and backup power supplies are provided. Cellular and satellite telephones provide additional voice communications capability.
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:
NRC ENS NRC HPN The proposed Columbia Emergency Plan states that communications systems with DOE-RL, State, and county warning points within the plume exposure pathway EPZ will be tested monthly. Systems used to communicate from the control room, TSC, and EOF to NRC Headquarters will be tested monthly. Communications systems between Columbia, Washington State EOC, Benton County EOC, and Franklin County EOC, and field monitoring teams will be tested annually. Communications systems between the Columbia ERFs will be tested annually.
The proposed Columbia ERDS will be verified to transmit data on a quarterly basis.
The proposed Columbia Emergency Plan states that the Auto-Dialer is used to notify ERO members of a declared emergency and consists of an onsite primary computer system and an offsite backup computer system.
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. The initial notification to the NRC is made using the ENS. Communications between Columbia and the local support agencies (fire, medical, and law enforcement) are made by the telephone.
Because the proposed Columbia Emergency Plan provides information that describes communication circuits used for communication with the NRC, State, and local organizations, the NRC staff finds that the information related to Evaluation Criterion II.F is acceptable in its identification of continuous and redundant communication capabilities.
3.2.6.1 Criterion II.F Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established provisions for prompt communications among principal response organizations to emergency personnel and to the public. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(6) has been adequately addressed.
3.2.7 Criterion II.G, Public Education and Information NUREG-0654, Evaluation Criterion II.G, addresses planning standard 10 CFR 50.47(b)(7),
which states:
Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of information during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established.
The requirements of 10 CFR 50.47(b)(7) are addressed in section G, Public Education and Information, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that Columbia, in coordination with DOE-RL, Washington State, 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 plume exposure pathway EPZ. The information contains educational information on radiation, warning methods used in notification of the public, recommended protective measures, selected evacuation routes and assistance centers, and personnel or agencies to be contacted for additional information. Brochures are made available at designated recreational facilities within the plume exposure pathway EPZ for transient populations. Information for residents with access and functional needs and non-English translations is incorporated per current federal guidance. The news media is invited to participate in an annual (once per calendar year) outreach program to acquaint them with Columbia emergency preparedness, radiation hazards, and to provide contact information for further media-related dialogue.
The proposed Columbia Emergency Plan states that the Joint Information System (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 Energy Northwest Office Complex (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. 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.
Because the proposed Columbia Emergency Plan provides information that describes the annual dissemination of information to the public, engagement with news media, and the ability to respond to public inquiries during the response to a declared emergency, the NRC staff finds that the information related to Evaluation Criterion II.G is acceptable in its identification of public education and information.
3.2.7.1 Criterion II.G Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established provisions for adequate public education and information to support the emergency response. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(7) has been adequately addressed.
3.2.8 Criterion II.H, Emergency Facilities and Equipment NUREG-0654, Evaluation Criterion II.H, addresses planning standard 10 CFR 50.47(b)(8),
which states:
Adequate emergency facilities and equipment to support the emergency response are provided and maintained.
The requirements of 10 CFR 50.47(b)(8) are addressed in section H, Emergency Facilities and Equipment, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan describes the emergency facilities, including the TSC, OSC, EOF, alternative EOF, and Alternate TSC/OSC Staging Facility, supporting emergency response. The JIC and JIS concept is described previously in this safety evaluation, which addresses public education and information associated with emergency response.
The proposed Columbia Emergency plan states that the 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. 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.
The proposed Columbia Emergency plan states that the 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 the control room share common air intake structures (local and two remote intakes), and the TSC ventilation high efficiency particulate air 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. Protective equipment such as respirators and potassium iodide are maintained in the TSC. Dedicated workstations with access to the plant local area network (LAN) are maintained in the TSC to obtain plant parameter information and
meteorological data from the Plant Process Computer 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.
The proposed Columbia Emergency Plan states that a dedicated portion of the TSC building serves as the OSC for the ERO to provide planning and coordination of in-plant and onsite response activities and for staging emergency personnel and equipment. The OSC is sized to accommodate ERO responders. 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 control room, TSC, EOF, and to dispatched repair teams using portable radios. Equipment and supplies are available to the OSC for repair team use.
The proposed Columbia Emergency Plan states that the EOF is a dedicated facility located 0.75 miles southwest of Columbia 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 OROs.
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 Columbia 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 proposed Columbia Emergency Plan states that 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, PARs, 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.
The proposed Columbia Emergency Plan states that 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.
The proposed Columbia Emergency Plan describes various instrumentation for meteorological monitoring, hydrologic monitoring, seismic monitoring, radiation monitoring, and fire/toxic gas/combustion products detectors that are available to support emergency response.
The proposed Columbia Emergency Plan states that Columbia 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 FMTs operating outside the Protected Area.
Because the proposed Columbia Emergency Plan provides information that describes the licensees primary and alternate ERFs, their locations, and their purposes, as well as equipment and instrumentation for evaluating a release of radioactive materials, the NRC staff finds that the information related to Evaluation Criterion II.F is acceptable in its identification of these facilities.
3.2.8.1 Criterion II.H Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established provisions for adequate emergency facilities and equipment to support the emergency response. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(8) has been adequately addressed.
3.2.9 Criterion II.I, Accident Assessment NUREG-0654, Evaluation Criterion II.I, addresses planning standard 10 CFR 50.47(b)(9), which states:
Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.
The requirements of 10 CFR 50.47(b)(9) are addressed in section I, Accident Assessment, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that 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. The magnitude of a release of radioactive material to the environment is primarily identified directly by effluent monitors. Dose assessment modeling methods are capable of estimating source term and magnitude of gaseous releases from effluent monitors or plant parameter data and release rate projections.
The licensee states that Columbia uses a site-specific version of the Unified RASCAL Interface (URI) offsite dose projection computer model. The underlying dose assessment model in the URI is the NRCs RASCAL 4 model, based on the methods and equations documented in NUREG-1940, RASCAL 4: Description of Models and Methods, dated December 2012 (Reference 13). The URI dose projection results are given for various locations from the site boundary out to 10 miles, and the model is capable of providing dose assessment results for multiple release points from the site. The URI model is able to provide offsite radiological dose and dose rate estimates based on near real time or hypothetical inputs. Projected dose is based on the U.S. Environmental Protection Agency (EPA) document, EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, dated May 1992 (referred to as the EPA PAG [Protective Action Guide] Manual) (Reference 14), dose
conversion factors given as: (1) the total effective dose equivalent (the sum of the effective dose equivalent from immersion, four days of ground deposition, and the committed effective dose equivalent from inhalation), and (2) the committed dose equivalent to the thyroid.
The FMTs use dedicated equipment, and for offsite field monitoring, dedicated vehicles. FMTs 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 may be performed at pre-identified locations or at other geographic locations within the EPZ as determined during the event.
The NRC issued Amendment No. 184 to Facility Operating License No. NPF-21 on January 27, 2003 (Reference 15). This amendment deleted Technical Specification section 5.5.3 and thereby eliminated the licensing requirement to have and maintain a Post Accident Sampling System. The proposed Columbia Emergency Plan states that contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere are maintained in plant procedures.
Because the proposed Columbia Emergency Plan provides information that describes methods for evaluating the magnitude of a release of radioactive materials, modeling of a release for dose assessment, and the use of FMTs for verification, the NRC staff finds that the information related to Evaluation Criterion II.F is acceptable in its identification of key attributes for accident assessment.
3.2.9.1 Criterion II.I Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established provisions for adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition.
Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(9) has been adequately addressed.
3.2.10 Criterion II.J, Protective Response NUREG-0654,Section II.J, addresses planning standard 10 CFR 50.47(b)(10), which states:
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. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates 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.
The requirements of 10 CFR 50.47(b)(10) are addressed in section J, Protective Response, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan maintains procedures to provide for a range of protective actions for all areas controlled by the licensee. Protective actions have been developed for radiological incidents and to protect personnel during hostile actions directed at the site. The public address system will be used to notify onsite personnel of a declared emergency. 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. 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. Personnel inside the Protected Area are accounted for within 30 minutes of event declaration. The last known location of unaccounted for (missing) individuals will be obtained and search and rescue actions initiated to locate the missing individuals. Accountability may be delayed if the movement of personnel creates safety or security concerns.
The proposed Columbia Emergency Plan states that 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:
Individual respiratory protection; Individual thyroid protection; and Protective clothing.
The proposed Columbia Emergency Plan states that Columbia has developed PARs, in accordance with agreements made with DOE-RL and 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 for the general public will be based on plant conditions and/or offsite dose assessment results. Plant conditions, offsite projected dose, and FMT data are used in PAR decision making. Site-specific ETEs were used 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 doses in excess of the 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.
Because the proposed Columbia Emergency Plan provides information that describes the notification of onsite staff and visitors and the potential response actions for onsite personnel for a declared emergency; incorporates the ETE into the plan while identifying the requirements to conduct an update to the ETE study; and describes the requirement for developing PARs in conjunction with OROs, the NRC staff finds that the information related to Evaluation Criterion II.J is acceptable in its identification of key protective response actions and plans.
3.2.10.1 Criterion II.J Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has
developed a range of protective actions for the plume exposure pathway EPZ for emergency workers and the public. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(10) has been adequately addressed.
3.2.11 Criterion II.K, Radiological Exposure Control NUREG-0654, Evaluation Criterion II.K, addresses planning standard 10 CFR 50.47(b)(11),
which states:
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.
The requirements of 10 CFR 50.47(b)(11) are addressed in section K, Radiological Exposure Control, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that the onsite exposure guidelines for emergency workers are consistent with the EPA PAG Manual Table 2-2, Guidance on Dose Limits for Workers Performing Emergency Services.
The proposed Columbia Emergency Plan states that 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 plant Health Physics procedures. If direct measurement of airborne concentrations is not available at time of exposure, qualified emergency workers are provided respirator protection when feasible. Radiation doses received by emergency workers for the duration of the incident are monitored by RP personnel in the TSC, OSC, and EOF. 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 will be documented and managed using an electronic dose tracking system. If the electronic dose tracking system is not available, dose tracking and records will be maintained manually.
The proposed Columbia Emergency Plan states that personnel and equipment are monitored when leaving a radiologically controlled area, 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. Columbias decontamination 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 for personnel decontamination.
The proposed Columbia Emergency Plan states that 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.
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. Responsibility for authorization of
exposures to radiation in excess of 10 CFR Part 20 limits resides with the Emergency Director and may be delegated to the TSC and EOF RP managers.
Because the proposed Columbia Emergency Plan provides information that describes the methods used to monitor and minimize exposure for ERO or ORO personnel, the NRC staff finds that the information related to Evaluation Criterion II.K is acceptable in its identification of those key characteristics for exposure control.
3.2.11.1 Criterion II.K Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established appropriate means for controlling radiological exposures for emergency workers in an emergency. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(11) has been adequately addressed.
3.2.12 Criterion II.L, Medical and Public Health Support NUREG-0654, Evaluation Criterion II.L, addresses planning standard 10 CFR 50.47(b)(12),
which states:
Arrangements are made for medical services for contaminated injured individuals.
The requirements of 10 CFR 50.47(b)(12) are addressed in portions of Section L, Medical and Public Health Support, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan describes medical and public health support. The licensee maintains at Columbia first aid supplies and equipment 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. 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 combination of these three hospitals serves as the primary and backup medical facility.
Energy Northwest Health Physics personnel are available to assist medical personnel with decontamination, radiation exposure monitoring, and contamination control. Hospitals are equipped, and hospital personnel are trained, to address contaminated injured individuals.
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 licensee radiation protection department and hospital procedures. 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, monitoring is performed as soon as possible following medical treatment.
DOE-RL provides assistance in treatment of contaminated or exposed injured patients when requested. The Radiation Emergency Assistance Center Training Site, located at Oak Ridge, Tennessee, is capable of responding to and/or providing advice and assistance to offsite medical facilities in the event of a severe radiation accident.
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. Columbia personnel knowledgeable in health physics will accompany contaminated patients to the hospital or meet the ambulance at the hospital to assist in the emergency.
Because the proposed Columbia Emergency Plan provides information that describes onsite care and transportation and identifies the primary and backup hospitals ready to receive contaminated injured personnel, the NRC staff finds that the information related to Evaluation Criterion II.L is acceptable in its identification of key information needed for medical support during a response or incident.
3.2.12.1 Criterion II.L Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established arrangements for medical services for contaminated injured individuals. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(12) has been adequately addressed.
3.2.13 Criterion II.M, Recovery, Reentry, and Post-Accident Operations NUREG-0654, Evaluation Criterion II.M, addresses planning standard 10 CFR 50.47(b)(13),
which states:
General plans for recovery and reentry are developed.
The requirements of 10 CFR 50.47(b)(13) are addressed in portions of section M, Recovery, Reentry, and Post-Accident Operations, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan addresses general principles that serve as guides for developing a recovery plan. 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.
The proposed Columbia Emergency Plan states that 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 Columbia 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: Recovery Manager, Onsite Recovery Coordinator, Offsite Recovery Coordinator, Radiological Assessment Coordinator (if needed), and Spokesperson.
Additionally, the proposed Columbia Emergency Plan states that 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:
Emergency Action Level criteria; Releases of radioactive materials to the environment; In-plant radiation levels; Plant stability and long term core cooling availability; Containment integrity; Functionality and integrity of plant systems, facilities, power supplies, equipment, and Instrumentation; Fire, flood, earthquake, or similar hazardous emergency conditions; Site security; Site access limitations for personnel and support services; and Discussion with ORO.
The proposed Columbia Emergency Plan further states that 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. Finally, the recovery organization will coordinate Columbia environmental sampling activities with the state agency.
Because the proposed Columbia Emergency Plan provides general information for recovery operations and the expected coordination with offsite authorities, the NRC staff finds that the information related to Evaluation Criterion II.M is acceptable in its identification of recovery, reentry, and post-accident operations.
3.2.13.1 Criterion II.M Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has developed general plans for recovery and reentry for Columbia. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(13) has been adequately addressed.
3.2.14 Criterion II.N, Exercises and Drills NUREG-0654, Evaluation Criterion II.N, addresses planning standard 10 CFR 50.47(b)(14),
which states:
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.
The requirements of 10 CFR 50.47(b)(14) are addressed in portions of section N, Exercises and Drills, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that 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 members are familiar with their duties.
Additionally, 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 Columbia Emergency Plan identifies the activities that constitute principal functional areas of emergency response and describes the emergency plan functions that drills aim at testing, developing, and maintaining.
The proposed Columbia Emergency Plan further states that 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. Any weakness or deficiency identified in a critique report must be corrected. Provisions are made for Federal, State, and county representatives to observe and participate in drill and exercise critiques.
The proposed Columbia Emergency Plan states that the licensee will conduct a plume exposure pathway exercise biennially. Specifically, the plume exposure pathway exercise is developed to provide the ERO members 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. Each plume exposure pathway exercise contains objectives to demonstrate key skills appropriate to each scenario. State and local authorities are invited to participate in plume exposure pathway exercises.
Additionally, the proposed Columbia Emergency Plan provides a description of the types of exercises and drills, as well as a description of the various required scenario elements to be conducted within the 8-year exercise cycle.
3.2.14.1 Deviations The licensee identified a deviation between the current and the proposed Columbia Emergency Plan that could be considered a potential reduction in effectiveness.
Biennial Call-In Drills The licensee states:
The current Columbia Emergency Plan requires quarterly ERO notification drills.
NUREG-0654, Element N.4.i 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 [Columbia] Emergency Plan specifies that off-hours call-in drills be performed biennially.
The licensee further states:
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.
The licensee concludes that 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.
The NRC and the Federal Emergency Management Agencys adjudication of public comments for the draft version of NUREG-0654 (Reference 16) states, in part:
An additional provision that response times for all ERO members be validated biennially is retained to address the potential that quarterly drills may not capture the response of all emergency response organization (ERO) members due to absence, rotation, etc. The NRC acknowledges that the use of a time window when conducting unannounced drills or exercises has become a common industry practice. Licensees have flexibility in scheduling and conducting these activities as long as they are done in a manner such that the date and time are not known to participants in advance.
Since the licensee uses an all-call process, it meets the testing intent of the guidance in NUREG-0654, Revision 2. Therefore, the NRC staff finds that the proposed change to the frequency of off-hours call-in drills from quarterly to biennially is acceptable.
Because the proposed Columbia Emergency Plan identifies the differences between drills and exercises, the requirements for formal critiques to develop corrective actions, the requirement for the different exercise types to include a plume exposure pathway exercise, and the justification for the deviation related to the call-in drill, the NRC staff finds that the information related to Evaluation Criterion II.N is acceptable in its implementation of exercise and drills.
3.2.14.2 Criterion II.N Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee will conduct periodic exercises to evaluate major portions of emergency response capabilities, conduct periodic drills to develop and maintain key skills, and adequately correct deficiencies identified as a result of exercises or drills. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(14) has been adequately addressed.
3.2.15 Criterion II.O, Radiological Emergency Response Training NUREG-0654, Evaluation Criterion II.O, addresses planning standard 10 CFR 50.47(b)(15),
which states:
Radiological emergency response training is provided to those who may be called on to assist in an emergency.
The requirements of 10 CFR 50.47(b)(15) are addressed in portions of section O, Radiological Emergency Response Training, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that the Emergency Preparedness Manager is responsible for the 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. Initial training is provided to all new Columbia ERO candidates. The ERO training program is developed based on position-specific responsibilities/tasks using Systems Approach to Training (SAT) principles. 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 at least annually.
The proposed Columbia Emergency Plan further states that State and county emergency management agencies that have a response role during an emergency are invited to participate in site-specific training annually (once per calendar year). Training includes the Columbia radiation protection practices, the notification process for their respective organization, and their respective organizations expected role. The invitation will provide a schedule of drills and exercises to enable offsite agencies to request participation. Energy Northwest offers emergency response training annually (once per calendar year) to the Hanford Fire Department, which can be contacted to provide onsite fire and 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 offsite response support activities. Columbia Security coordinates any site-specific familiarization training with local law enforcement in accordance with the Security Plan.
The proposed Columbia Emergency Plan further states that 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.
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.
Because the proposed Columbia Emergency Plan provides information on responsibility for the Columbia ERO training program, coordination with OROs to provide training, and annual requalification and review of the training programs, the NRC staff finds that the information related to Evaluation Criterion II.O is acceptable in its identification of emergency response training.
3.2.15.1 Criterion II.O Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has established radiological emergency response training for those who may be called on to assist
in an emergency at Columbia. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(15) has been adequately addressed.
3.2.16 Criterion II.P, Responsibility for the Planning Effort Development, Periodic Review, and Distribution of Emergency Plans NUREG-0654, Evaluation Criterion II.P, addresses planning standard 10 CFR 50.47(b)(16),
which states:
Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.
The requirements of 10 CFR 50.47(b)(16) are addressed in section P, Responsibility for the Planning Effort Development, Periodic Review, and Distribution of Emergency Plan, of the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that 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 Energy Northwest technical training, that will enhance working knowledge of plant operations performed at least annually (once per calendar year). The Site Vice President has overall authority and responsibility for the Columbia Emergency Plan. 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.
The proposed Columbia Emergency Plan is 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. LOAs/MOUs are reviewed and verified on an annual (once per calendar year) basis and updated as warranted.
The proposed Columbia Emergency Plan states that the emergency plans developed by other agencies that support it include:
DOE Order 151.1D - Comprehensive Emergency Management System; Benton County Columbia Generating Station Emergency Preparedness Plan; Franklin County Columbia Generating Station Emergency Preparedness Plan; Oregon Department of Energy Columbia/Hanford Emergency Response Plan; and Washington State Fixed Nuclear Facility Protection Plan.
These emergency plans are reviewed when updated to maintain an effective interface with the proposed Columbia Emergency Plan.
The proposed Columbia Emergency Plan states that 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 once every 24 months. Specifically, the review will include an evaluation for adequacy of:
Emergency plan and emergency plan implementing procedures; Training of ERO and non-Columbia support groups that may be called to respond to the site; Drills and exercises; Facilities and equipment; and 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 could adversely affect the emergency preparedness program, but no longer than 12 months after the change. The review findings will be submitted to the appropriate Columbia 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 5 years.
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.
Because the proposed Columbia Emergency Plan provides information on the responsibility for updating and reviewing emergency plans, including coordination with OROs, the NRC staff finds that the information related to Evaluation Criterion II.P is acceptable in its ability to maintain and update the emergency plan.
3.2.16.1 Criterion II.P Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff concludes that the licensee has identified the responsibilities for plan development, review, and distribution and that planners are properly trained. Therefore, the NRC staff has determined that the planning standard of 10 CFR 50.47(b)(16) has been adequately addressed.
3.3 Conclusion Based on the NRC staffs review and evaluation of the information in Energy Northwests LAR and supplemental letters as described above, the NRC staff finds that the proposed changes in the Columbia Emergency Plan continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50 and that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at Columbia. Therefore, the NRC staff concludes that the proposed Columbia Emergency Plan contained in the LAR dated January 30, 2024, as supplemented by letters dated March 20, 2024, September 10, 2024, and September 24, 2024, is acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Washington State official was notified of the proposed issuance of the amendment on November 18, 2024. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
Pursuant to 10 CFR 51.21, 51.32, and 51.35, an environmental assessment and finding of no significant impact was published in the Federal Register on November 12, 2024 (89 FR 89049).
Accordingly, based upon the environmental assessment, the Commission has determined that issuance of this amendment will not have a significant effect on the quality of the human environment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions 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.
7.0 REFERENCES
- 1.
Brown, D. P., Energy Northwest, letter to U.S. Nuclear Regulatory Commission, Columbia Generating Station, Docket No. 50-397 License Amendment Request to Revise Columbia Generating Station Emergency Plan, dated January 30, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24030A844).
- 2.
Brown, D. P., Energy Northwest, letter to U.S. Nuclear Regulatory Commission, Columbia Generating Station, Docket No. 50-397 Supplement to License Amendment Request to Revise Columbia Generating Station Emergency Plan, dated March 20, 2024 (ML24081A193).
- 3.
Brown, D. P., Energy Northwest, letter to U.S. Nuclear Regulatory Commission, Columbia Generating Station, Docket No. 50-397 Response to Request for Additional Information Regarding License Amendment Request to Revise Columbia Emergency Plan, dated September 10, 2024 (ML24254A366).
- 4.
Brown, D. P., Energy Northwest, letter to U.S. Nuclear Regulatory Commission, Columbia Generating Station, Docket No. 50-397 Supplement to Response to Request for Additional Information Regarding License Amendment Request to Revise Columbia Emergency Plan, dated September 24, 2024 (ML24269A254).
- 5.
U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654/FEMA-REP-1, Revision 2, dated December 2019 (ML19347D139).
- 6.
U.S. Nuclear Regulatory Commission, Emergency Response Planning and Preparedness for Nuclear Power Reactors, Regulatory Guide 1.101, Revision 6, dated June 2021 (ML21111A090).
- 7.
U.S. Nuclear Regulatory Commission, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, Regulatory Issue Summary 2016-10, dated August 5, 2016 (ML16124A002).
- 8.
Macon, W. A., U.S. Nuclear Regulatory Commission, letter to J. V. Parrish, Energy Northwest, Columbia Generating Station - Emergency Plan Changes (TAC No.
MC3048), dated August 31, 2004 (ML042440479).
- 9.
Nuclear Energy Institute, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, NEI 12-01, Revision 0, dated May 2012 (ML12125A412).
- 10.
Nuclear Energy Institute, Cyber Security Control Assessments, NEI 13-10, Revision 6, dated August 2017 (ML17234A615).
- 11.
Nuclear Energy Institute, Development of Emergency Action Levels for Non-Passive Reactors, NEI 99-01, Revision 6, dated November 2012 (ML12326A805).
- 12.
Thaggard, M., U.S. Nuclear Regulatory Commission, letter to S. Perkins-Grew, Nuclear Energy Institute, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, dated November, 2012 (TAC No. D92368), dated March 28, 2013 (ML12346A463).
- 13.
U.S. Nuclear Regulatory Commission, RASCAL 4: Description of Models and Methods, NUREG-1940, dated December 2012 (ML13031A448).
- 14.
U.S. Environmental Protection Agency (EPA), EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, dated May 1992 https://www.epa.gov/sites/default/files/2016-03/documents/pags.pdf.
- 15.
Dembek, S. for Benney, B., U.S. Nuclear Regulatory Commission, letter to J. V. Parrish, Energy Northwest, Columbia Generating Station - Issuance of Amendment Re:
Elimination of Requirements for Post Accident Sampling System (TAC No. MB6683),
dated January 27, 2003 (ML030280681).
- 16.
U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, Adjudication Report for NUREG-0654/FEMA-REP-1, Rev. 2, dated December 2019 (ML19350A378).
Principal Contributors: M. Norris, NSIR K. Miller, NSIR D. Bradshaw, NSIR Date: March 13, 2025
- via - email NRR-106 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NSIR/DPR/RLB/BC*
OGC - NLO*
NAME MChawla PBlechman JQuichocho CRyan DATE 01/29/2025 12/13/2024 12/16/2024 01/28/2025 OFFICE NRR/DORL/LPL4/BC*
NRR/DORL/D(A)*
NRR/D(A)*
NRR/DORL/LPL4/PM*
NAME TNakanishi JPelton LDudes MChawla DATE 2/4/2025 2/13/2025 2/28/2025 3/13/2025