ML25141A024

Second Quarter 2025 Emergency Plan Changes In-Office Inspection - Closure Basis

ML25141A024
Person / Time
Site:	Columbia
Issue date:	05/20/2025
From:	English S Energy Northwest
To:	Cook D, Sean Hedger, Oakes R NRC Region 4
References
Download: ML25141A024 (1)

Text

From:

English, Steven R.

To:

Sean Hedger; Oakes, Ryan M.; Cook, Daniel D.

Cc:

Wolfgramm, Desiree M.

Subject:

[External_Sender] RE: RE: RE: Emergency Plan Revisions - Initial Review - Requests Date:

Tuesday, May 20, 2025 12:52:43 PM Mr. Hedger, Thank you for the follow up. We understand and do not need anything additional, the team and I will work to ensure that this issue is resolved. This communication is acceptable to credit as an exit. Please reach out if there is anything else needed form my team or myself.

Thank you, Steve English l Emergency Preparedness Manager Energy Northwest l 509.377.8317 From: Sean Hedger <Sean.Hedger@nrc.gov>

Sent: Tuesday, May 20, 2025 10:24 To: Oakes, Ryan M. <rmoakes@energy-northwest.com>; Cook, Daniel D. <ddcook@energy-northwest.com>; English, Steven R. <srenglish@energy-northwest.com>

Subject:

RE: RE: RE: Emergency Plan Revisions - Initial Review - Requests Thank you for the feedback, and the AR corrective action document!

Based on what is known, this looks like a failure to provide a summary of emergency plan changes made by your site within 30 days of the documents effective date [10 CFR 50.54(q)

(5)]. It is similar to the self-identified issue your site addressed in 2024-2025 (ARs 463495, 466491). Consistent with that, it appears minor in significance.

Your site has the issue documented in your corrective action program, and we understand what corrective actions have been taken, and will be planned in the future.

I am open to discussing the issue if we need to have a conversation. Let me know if that is something that is needed from your perspective.

I am finished with the inspection activity, and this is the one regulatory issue coming from it. I can credit this communication with you as the exit meeting. If, from your process, you would like me to provide an oral exit discussion of the inspection activity, and the issue, I can do so.

Let me know your perspectives on this.

Thank you, Sean D. Hedger ADAMS Accession # ML25141A024

Senior Emergency Preparedness Inspector US Nuclear Regulatory Commission, Region IV (817)200-1556 From: Oakes, Ryan M. <rmoakes@energy-northwest.com>

Sent: Monday, May 19, 2025 3:21 PM To: Sean Hedger <Sean.Hedger@nrc.gov>; Cook, Daniel D. <ddcook@energy-northwest.com>;

English, Steven R. <srenglish@energy-northwest.com>

Subject:

[External_Sender] RE: RE: Emergency Plan Revisions - Initial Review - Requests

Sean, Our review identified your assessment and perspective were correct and a 30-day notification should have been sent. We initiated CR 470162 (attached) and the letter was sent on 5/8/25. A revision to PPM 13.1.1A is also planned to address the conflicting information from the EPlan.

Let me know if you have any additional questions or would like to discuss further.

Thanks.

-Ryan Oakes rmoakes@energy-northwest.com 509-377-4079 From: Sean Hedger <Sean.Hedger@nrc.gov>

Sent: Monday, May 19, 2025 7:32 AM To: Cook, Daniel D. <ddcook@energy-northwest.com>; Kuklinski, Jennifer L. <jlkuklinski@energy-northwest.com>

Cc: Oakes, Ryan M. <rmoakes@energy-northwest.com>

Subject:

RE: RE: Emergency Plan Revisions - Initial Review - Requests I wanted to check in again regarding the issue I brought up some time ago to see what you found based on your review.

If you are available for communications this week, let me know. Thank you, Sean D. Hedger Senior Emergency Preparedness Inspector US Nuclear Regulatory Commission, Region IV (817)200-1556 From: Sean Hedger Sent: Thursday, May 8, 2025 4:16 PM

To: Cook, Daniel D. <ddcook@energy-northwest.com>; Kuklinski, Jennifer L. <jlkuklinski@energy-northwest.com>

Subject:

RE: RE: Emergency Plan Revisions - Initial Review - Requests Afternoon!

I wanted to check in with you and see if you have had a chance to look at this item.

If you wish to discuss it, let me know. I am at a site on inspection next week but can make time in my schedule for conversation.

Thank you, Sean D. Hedger Senior Emergency Preparedness Inspector US Nuclear Regulatory Commission, Region IV (817)200-1556 From: Sean Hedger Sent: Thursday, May 1, 2025 3:03 PM To: Cook, Daniel D. <ddcook@energy-northwest.com>; Kuklinski, Jennifer L. <jlkuklinski@energy-northwest.com>

Subject:

RE: RE: Emergency Plan Revisions - Initial Review - Requests Thank you for your responses!

The one question I am left with is why a change to the EAL bases document, although minor in nature, did not result in a notification with a summary of analysis provided to the NRC within 30 days of implementation. It is, after all, a change in the emergency plan that your site completed without prior NRC approval.

In looking at your 50.54(q) process procedure (EPI-16, R. 18), it echoes similar text to the regulation [10 CFR 50.54(q)(5)] in Steps 4.2.9 and 4.3.6. With this being an emergency plan change that was evaluated with a screen only, action should have been completed to submit the 30 notification/summary via Step 4.2.9.

In the IMS Certrec response yesterday, it said that a 30 day submittal was not provided because the change involved a 50.54(q) screen only. I suspect that a user of your procedure came to that conclusion by using only the 50.54(q) screening flowchart (Figure 4.2) vice reading the procedural steps. If one would do that, they could miss implementing procedure step 4.2.9.

Please take a look at this, and let me know your perspectives on this. We can discuss it next

week if desired.

Let me know if you have any questions. Thank you, Sean D. Hedger Senior Emergency Preparedness Inspector US Nuclear Regulatory Commission, Region IV (817)200-1556 From: Cook, Daniel D. <ddcook@energy-northwest.com>

Sent: Wednesday, April 30, 2025 1:50 PM To: Sean Hedger <Sean.Hedger@nrc.gov>; Kuklinski, Jennifer L. <jlkuklinski@energy-northwest.com>

Subject:

[External_Sender] RE: Emergency Plan Revisions - Initial Review - Requests

Sean, Requested information has been uploaded to CERTREC. I created an In-Office review for 71114.04 inspection. Answers should be contained in the only request SH-001.

Respectfully, Daniel Cook Regulatory Affairs Columbia Generating Station 509.377.4745 From: Sean Hedger <Sean.Hedger@nrc.gov>

Sent: Wednesday, April 30, 2025 8:22 AM To: Kuklinski, Jennifer L. <jlkuklinski@energy-northwest.com>

Cc: Cook, Daniel D. <ddcook@energy-northwest.com>

Subject:

Emergency Plan Revisions - Initial Review - Requests

Jennifer, Ive performed a preliminary review of three emergency plan revision changes.

EP-01 (CGS Emergency Plan), Revision 69 PPM 13.4.1 (Emergency Notifications), Revision 46 PPM 13.1.1A (Classifying the Event - Technical Bases), Revision 35

Based on that, I have some additional requests. They are detailed in the attached document.

Any response could be provided either via email or IMS Certrec. However, I can work with whatever means you all decide to use.

After you get a chance to look this over, please let me know what would be a reasonable timeline for your response. Were early in the quarter, but we should address this to allow any discussion needed/additional information sharing prior to the quarters end.

Let me know if you have any questions. Thank you, Sean D. Hedger Senior Emergency Preparedness Inspector US Nuclear Regulatory Commission, Region IV (817)200-1556 TRUSTED EXTERNAL: Nuclear Regulatory Commission TRUSTED EXTERNAL: Nuclear Regulatory Commission TRUSTED EXTERNAL: Nuclear Regulatory Commission