ML25149A226
| ML25149A226 | |
| Person / Time | |
|---|---|
| Site: | Columbia  (NPF-021) |
| Issue date: | 06/24/2025 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Schuetz R Energy Northwest |
| Chawla M | |
| References | |
| EPID L-2024-LLA-0011 | |
| Download: ML25149A226 (7) | |
Text
June 24, 2025 Mr. Robert Schuetz Chief Executive Officer Energy Northwest 76 North Power Plant Loop P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968
SUBJECT:
COLUMBIA GENERATING STATION - CORRECTION TO ISSUANCE OF AMENDMENT NO. 276 FOR REVISION TO THE EMERGENCY PLAN (EPID L-2024-LLA-0011)
Dear Mr. Schuetz:
By letter dated March 13, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24324A288), the U.S. Nuclear Regulatory Commission (NRC) issued Amendment No. 276 to Renewed Facility Operating License No. NPF-21 for the Columbia Generating Station (Columbia). The amendment revised the Columbia Emergency Plan pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q) based on the guidance in NUREG-0654/FEMA [Federal Emergency Management Agency]-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 (ML19347D139).
After issuance of the amendment, Energy Northwest (the licensee) notified the NRC of the following errors on pages 7, 26, and 27 of the safety evaluation (SE) issued with the amendment.
page 7: the Assistant EOF Manager is a minimum staff position.
page 26: the correct Evaluation Criterion is II.H.
page 27: the correct Evaluation Criterion is II.I.
The corrected revised pages 7, 26, and 27 of the NRC staffs safety evaluation contain marginal lines indicating the areas of change.
The changes do not change any of the conclusions associated with the issuance of Amendment No. 276 and do not affect the associated notice to the public.
The enclosure to this letter contains the correct SE pages. Please replace SE pages 7, 26, and 27 issued to Amendment No. 276 for Columbia with the enclosed revised pages.
R. Schuetz The NRC staff regrets any inconvenience this may have caused. If you have any questions regarding this matter, please contact me at (301) 415-8371 or via email at Mahesh.Chawla@nrc.gov.
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
Enclosure:
Corrected SE pages 7, 26, and 27 to Amendment No. 276 cc: Listserv
ENCLOSURE CORRECTED SAFETY EVALUATION PAGES 7, 26, AND 27 RELATED TO AMENDMENT NO. 276 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-21 ENERGY NORTHWEST COLUMBIA GENERATING STATION DOCKET NO. 50-397 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 minimum staff Assistant EOF Manager, making it unnecessary to staff a TSC ORO Communicator ERO position.
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.H 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.I 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.
ML25149A226 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NSIR/DPR/RLB/BC NAME MChawla PBlechman JQuichocho DATE 5/29/2025 6/3/2025 6/3/2025 OFFICE NRR/DORL/LPL/BC NRR/DORL/LPL4/PM NAME TNakanishi MChawla DATE 6/24/2025 6/24/2025