View source for GO2-24-034, Supplement to License Amendment Request to Revise Columbia Generating Station Emergency Plan

{{Adams
| number = ML24081A193
| issue date = 03/20/2024
| title = Supplement to License Amendment Request to Revise Columbia Generating Station Emergency Plan
| author name = Brown D
| author affiliation = Energy Northwest
| addressee name = 
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000397
| license number = 
| contact person = 
| case reference number = GO2-24-034
| document type = Emergency Preparedness-Emergency Plan, Letter type:GO
| page count = 1
| project = 
| stage = Supplement
}}

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David P. Brown ENERGY                                                                                        Columbia Generating Station P.O. Box 968, PE23 Richland, WA 99352-0968 NORTHWEST                                                                                                   509.377.8385 dpbrown@energy-northwest.com

March 20, 2024                                                                                             10 CFR 50.90 GO2-24-034                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       10 CFR 50, Appendix E

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 SUPPLEM     ENT TO LICENSE AMENDMENT REQUEST TO REVISE COLUMBIA GENERATING STATION EMERGENCY PLAN

==Reference:==
: 1. Letter from D.P. Brown (Energy Northwest) to U.S. Nuclear Regulatory Commission, License Amendment Request to Revise Columbia Generating Station Emergency Plan, dated January 30, 2024 (ADAMS Accession No. ML24030A844)
: 2.           Letter from U.S. Nuclear Regulatory Commission to Mr. Robert Schuetz (Energy Northwest), Columbia Generating Station -
Supplemental Information Needed for Acceptance of Requested Licensing Action RE: License Amendment Request to Revise Emergency Plan (EPID L-2024-LLA-0011), dated March 14, 2024 (ADAMS Accession No. ML24058A069)

==Dear Sir or Madam:==

In Reference 1, Energy Northwest requested a revision to the Columbia Generating Station Emergency Plan. The proposed revision would adopt updated guidance contained in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 2.

In Reference 2, the Nuclear Regulatory Commission requested supplemental information to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment request. The enclosure to this letter provides the requested information.
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GO2-24-034 Page 2 of 2

The information contained in this supplement does not affect the Technical Analysis or No Significant Hazards Consideration conclusions contained in the license amendment request. Additionally, the information provided in this supplement does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, Energy Northwest is notifying the State of Washington of this amendment supplement by transmitting a copy of this letter and enclosure to the designated State Official.

This letter and its enclosure contain no new commitments.

If there are any questions or if additional information is needed, please contact Mr. R.M. Garcia, Licensing Supervisor, at 509-377-8463.

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

Executed this ______ day of March, 2024.  

Respectfully,

David P. Brown Site Vice President

==Enclosure:==
Current to Proposed Emergency Plan Comparison Analysis

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

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GO2-24-034 Enclosure

CURRENT TO PROPOSED EMERGENCY PLAN COMPARISON ANALYSIS (211 pages to follow)

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ENERGY
                                         -             ~-NORTHWEST

Columbia Generating Station                          (CGS)

Analysis Report #5 Current to Proposed Emergency Plan Comparison Analysis

10/24/23
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: 1.                                                                                              INTRODUCTION

This analysis compares          the current emergency plan          (Revision 68)          to          the          proposed emergency plan.
: 2.                                                                                                  REVIEW METHODOLOGY

The comparison between the current emergency plan and the proposed emergency plan was made as follows:
: 1.                               The first step compares the content of the current emergency plan to the proposed emergency plan to identify changes. Comparisons where the wording is the same are identified as No Change.
: 2.                               Where a change          does exist between the wording of the two documents, it is evaluated as Editorial, Difference           or a Deviation. The definitions for the terms           are as follows:

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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         Editorial           -           Changes          that include typographical, formatting, paragraph numbering, spelling, grammar, punctuation, or title; or wording that do not alter intent of the original content or level of commitment.

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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            Di              fference           -          Changes           in intent,          method, or          commitment that sustain or improve the licensee's capability to perform an emergency planning function in the event of a radiological emergency.

x                                                  Deviation          -           Changes           in intent,           method, or           commitment that may result in reducing the licensee's capability to perform an emergency planning function in the event of a radiological emergency.

Deviations           are          further evaluated to determine if a          reduction in capability results in a loss or degradation in the ability to perform a function, which would then meet the definition of a Reduction in Effectiveness (RIE).
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: 3.                                                                                                

==SUMMARY==

This analysis compares the current emergency plan (Revision 68) to the proposed emergency plan.

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

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

3.1                                                                         [Deviation          5-1]           ERO Staffing Changes

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

Deviation Evaluation and Justification See submittal enclosure 1 (Change Evaluation) Sections          3.1          and 3.2 for ERO position and augmentation deviation evaluation and justification documentation.
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3.2                                                                         [Deviation          5-2]           Biennial Call-In           Drills

Current          Emergency Plan                      Proposed          Emergency Plan 6.7.3 Notification Systems                           N.4.i  Off-Hours Call-In Drills          Off-hours call-in
: d. Automatic Dialer                                 drills are conducted quarterly, such that each
: 1)                                Perform pager activationERO members normally expected response test/notification drill -          quarterly.time is assessed at least biennially based on call-in drill responses or an alternate means for determining response time. Some drills are unannounced.
CGS will conduct an off   -hours unannounced ERO call-in drill biennially to validate each ERO members response time.
The off-hours unannounced ERO call-in drill will require collection of the estimated response times to the applicable facility.
Completion of an Element N.4.h off-hours unannounced ERO report-in drill satisfies the requirements of the off-hours unannounced ERO call-in drill in this element.

Deviation Evaluation and Justification The current CGS Emergency Plan requires quarterly ERO notification drills. NUREG-0654, Revision 2, Element N.4.h requires that off-hours call-in drills be conducted at least quarterly, such that each ERO members response time is validated at least biennially (with some drills being unannounced).
The proposed CGS Emergency Plan specifies that off-hours call-in drill be performed biennially.
CGS ERO notification is an all-call process, which for call-in drills will collect response time estimates from the entire ERO. This process validates all ERO members response time each time it is used.
Removing the quarterly test          of a          portion of the ERO response and retaining the biennial  testfor the full         complete ERO meets the intent of the NUREG-0654 element.

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