ML15163A180

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Energy Northwest Columbia Generating Station Slides for Regulatory Conference June 15 2015-Final
ML15163A180
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 06/15/2015
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Energy Northwest
To:
NRC Region 4
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Download: ML15163A180 (57)
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Opening RemarksGrover Hettel, Vice President OperationsUnderstanding and AcknowledgementEnergy Northwest PerspectiveReview of Agenda 2

AgendaApparent ViolationDon GregoireEmergency Plan CommitmentsDon GregoireNUREG-0654 Supplement 3 (2011)Sean ClizbePPM 13.2.2 Rev 18 ChangesSean ClizbePPM 13.2.2 SIP GuidanceDave BrownLessons LearnedKurt GosneySummary of DifferencesDon GregoireSignificance AssessmentDon GregoireClosingGrover Hettel 3

Apparent Violation "Columbia Generating Station failed to follow and maintain the effectiveness of an emergency plan meeting the requirements of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)."

Inspection Report Finding (Emergency Plan Section 2.1)"Specifically, Columbia Generating Station Procedure 13.2.2, "Determining Protective Action Recommendations," Revision 18, Section 4.5.1, did not implement the requirements of Emergency Plan Section 2.1 because the procedure required the Emergency Director in the control room to delegate the formulation of protective action recommendations to the TSC or EOF. However, protective actions are a non-delegable responsibility of the Emergency Director."

4Don Gregoire (Manager Regulatory Affairs)

Apparent ViolationEnergy Northwest Position (Emergency Plan Section 2.1)(1)Procedure PPM 13.2.2, Revision 18, step 4.5.1 correctly transfers protective action recommendations (PARs) to the Technical Support Center (TSC) or Emergency Operations Facility (EOF) for the expansion of PARs beyond 10 miles because field monitoring, an augmented function, is important to the development of accurate PARs at these distances. (2) Augmented emergency response organization (ERO) functions are under the oversight of either the TSC or EOF in which case the Shift Manager would have transferred responsibilities to the emergency director in one of these locations.(3) Transfer of emergency director responsibilities to the TSC or EOF and the reliance on field team data for PARs beyond 10 miles is consistent with section 2.1 and 5.5.2 of the Columbia Emergency Plan.5 Apparent Violation Inspection Report Finding (Emergency Plan Section 5.5)"Procedure 13.2.2, Revision 18, did not implement the requirements of Emergency Plan Section 5.5 because it did not provide for the development of shelter-in-place as a protective action recommendation and did not provide for protection action recommendations to protect against planned releases of radioactive materials."

6 Apparent ViolationEnergy Northwest Position (Emergency Plan Section 5.5) Shelter-in-Place Protective Action Recommendations(1)Procedure PPM 13.2.2 Revision 18 Attachment 7.1 and 7.2 provide for the development of shelter in place as a protective action recommendation.(2)Shelter and evacuation guidance in Attachment 7.1 and 7.2 is based on guidelines established in NUREG-0654 Supplement 3 (2011). (3)NUREG-0654 Supplement 3 (2011) was provided to licensees as an acceptable method for complying with Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b).(4)Basing shelter and evacuation guidance on NUREG-0654 Supplement 3 is consistent with Section 5.5 and 5.5.2 of Columbia's Emergency Plan 7

Apparent ViolationEnergy Northwest Position (Emergency Plan Section 5.5) Planned Release Protective Action Recommendations(1)Procedure PPM 13.2.2 Revision 18 Attachment 7.1 and 7.2 continue to provide for the development of PARs to protect against planned releases of radioactive material. (2)Use of Attachment 7.1 and 7.2 for developing protective action recommendations during a planned release (controlled, short duration releases) is consistent with Emergency Plan Section 5.5.2.

8 Simplified Finding Statement 9 !""#$%"$&"However, Revision 18 of Procedure 13.2.2 no longer follows the above quoted sections of the station's Emergency Plan."

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Regulatory Compliance11Emergency Plan CommitmentsFederal GuidanceEmergency Plan Implementing ProceduresClassification Notification Form10 CFR 50.47(b)(10)

"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-

..Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place."

Emergency Plan Commitments Inspection Report

"..the licensee failed to follow Sections-5.5 of Emergency Plan-which required that the appropriate protective actions for an airborne release of radioactivity were evacuation and sheltering, that decisions to evacuate or shelter are made based on the dose avoided, that protective action recommendations are based on plant or radiological conditions.."12Emergency Plan Commitments Emergency Plan Commitments Emergency Plan Section 5.5 "Protective Action Guides, discussed in Section 5.5.2,provide pre-planned guidance for making response decisions.When applied with professional judgment, they help to ensure rapid action to protect members of the public."13 Emergency Plan Commitments Emergency Plan Section 5.5.2 "Shelter, evacuationor access control guidelines are based onthe EPA Protective Action Guidelines and NUREG-0654Supplement 3recommendations." 14 NUREG-0654 Supp3 (2011)Abstract "The guidance of Supplement 3 provides an acceptable method to comply with Appendix E to Part 50, Title 10 of the Code of Federal Regulations (10 CFR)Section IV, paragraph 3 in the use of evacuation time estimates in the formulation of protective action recommendations (PARs) for the plume exposure emergency planning zone, and provides guidance for the provisions of 10 CFR 50.47(b)(10) in the development of a range of PARs."15Federal GuidanceSean Clizbe (Manager EmergPreparedness)

NUREG-0654 Supp3 (2011)1.2 Regulatory Basis "Applicants and licensees 2may voluntarily 3use the guidancein this document to demonstrate compliance with Appendix E to Part 50,Section IV, paragraph 3 and the applicable provisions of section 50.47(b)(10)..""Licensees may use the information in this supplement for actions that do not require NRC review and approval such as changes to an emergency plan under 10 CFR 50.54 that do not require prior NRC review and approval."16 NUREG-0654 Supp3 (2011)2.1 Development of Site-Specific Protective Action Recommendation and Decision Logic"The attachmentto this supplement contains a protective action strategy development tool that-licensees should use to develop PAR procedures."Energy Northwest used the attachment of Supplement 3 for development of site specific PARS in procedure PPM 13.2.2 of Revision 1817 18.""

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Attachment Tool NUREG-0654 Supp3 (2011)Protective Action Strategy Development Tool Notes"It is not intended that licensees or offsite response organizations (OROs) have protective action implementing procedures that are exactly the same as provided here. Licensees for each nuclear power plant should develop site-specific strategiesand decision tools/procedures for the site using the guidance provided below in collaboration with OROsresponsible for protective action decision making."Energy Northwest collaborated with Offsite Response Organizations in the development of "appropriate" PARs for Columbia using the attachment in Supplement 3 to arrive at our site-specific procedure19 CGS Max. 90% ETE is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, 15 minutes2 miles5 miles10 milesEPZGeneral Representation of Columbia's EPZ NUREG-0654 Supp3 (2011)2.7 Strategy for Rapidly Progressing Scenarios"For sites at which the 90-percent ETE for the general public of the full EPZ is less than approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, results showed that, for the rapidly progressing scenario, evacuation is the most appropriate protective action."Columbia's evacuation time estimate (ETE) less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for the entireEmergency Planning Zone (EPZ)1.4 Background"ETEs can be used as timing criteria to expand staged evacuation and for SIP versus evacuation decision making for large early release scenarios"Due to effect on ETE of low population in 0-5 miles, staged evacuation was judged to be unnecessary21 NUREG-0654 Supp3 (2011)Note 2: Impediments to Evacuation "Impediments to evacuation include the following: Evacuation support (e.g., traffic control)- In a hostile-action-based GE (armed attack)- In the event of adverse weather-"Energy Northwest evaluated each impediment and collaborated with OROs on PPM 13.2.2 procedure development22 NUREG-0654 Supp3 (2011)Evacuation Support"Many sites have a low population density within 2 miles, and lack of traffic control may not be considered an impediment. The licensee and OROs should discuss this element and reach an agreement- The licensee would base procedures on the agreementand would not confer with OROs before making the initial PAR notification"Due to low population density "evacuation support" not a realistic impediment at Columbia.

OROs agreed.23 NUREG-0654 Supp3 (2011)Hostile Action"OROs may determine that an initial recommendation to shelter in place (SIP) rather than evacuation is the preferred path. The licensee would discuss this element with OROs and reach an agreement during the development process. The licensee would base procedures on the agreementand would not confer with OROs before making the initial PAR notification."Agreement reached with OROs prior to issuance of procedure. PPM 13.2.2 Revision 18 is based on agreement.24 NUREG-0654 Supp3 (2011)Adverse Weather"In the event of adverse weather, licensees are not responsible for soliciting information or for making a determination that weather or other impediments (e.g., an earthquake or wildfire) for safe public evacuation exist at the time of the emergency. However, the licensee will consider an impediment to exist if OROs have previously notified it of such an impediment (e.g., roadways are closed because of deep snow). During the planning process, OROs may determine that the licensee does not need to consider adverse weather in its plant PAR procedures."Agreement reached with OROs that adverse weather need not be considered in procedure. However, procedure still retains consideration for sheltering in adverse weather conditions during a radiological release.25 Supplement 3 (2011) Summary Supplement 3 encourages licensees to use guidance within it for developing procedures to meet 50.47(b)(10)Supplement 3 identifies evacuation as the most appropriate for rapidly progressing scenariosEnergy Northwest collaborated with ORO's in the development of "appropriate" PARs for Revision 18 of PPM 13.2.2Consistent with Emergency Plan section 5.5.2, protective action strategy for shelter and evacuation is based onNUREG-0654 Supplement 3 (2011) 26 PPM 13.2.2 Revision 18 Changes27Emergency Plan Implementing ProceduresInspection Report Cover Letter "Specifically, on June 16, 2014, when Columbia Generating Station implemented Revision 18 of-Procedure 13.2.2-it inappropriately (1) removed shelter-in-place as a protective action that can be recommended to offsite authorities, (2) removed the recommendation of protective actions for planned releases of radioactive material during an accident, and (3) limited the ability of the emergency response organization to recommend protective actions outside of the plume exposure emergency planning zone."

PPM 13.2.2 Revision 18 ChangesImplemented 2011 version of NUREG-0654 Supplement 3Improved strategies for protection of public health and safetyIncorporated results of evaluation of shelter-in-place considerations as described in Supplement 3Formatting improvements28 Revision 17 Revision 18 Initial PAR29 Revision 17 Revision 18 PAR Update30 .1 -Revision 17 Attachment 7.1 -Revision 18 31 .2 -Revision 17 Attachment 7.2 -Revision 18 32 PPM 13.2.2 Revision 18 Changes Inspection Report

"..Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, "Determining Protective Action Recommendations," on June 16, 2014, so that it:

  • Removed the responsibility of the emergency coordinator in the control room (shift manager) to make protective action recommendations for areas outside the plume phase (10-mile) emergency planning zone."33 PPM 13.2.2 Revision 18 ChangesEmergency Plan Section 2.1 "Responsibility for emergency direction and control (i.e., overall direction of the plant's emergency response which must include the non-delegable responsibilities for emergency classification, the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures) is normally transferred from the Shift Manager to the EOF Manager. However, if the situation dictates, the responsibilities may be transferred from the Shift Manager to the TSC Manager and then to the EOF Manager."

Emergency Plan Section 5.5.2 "Plant and offsite officials will continue to assess plant conditions to determine additional protective actions. These protective actions should be based on field monitoring data and dose projectionsthat indicate EPA PAGs may be exceeded inareas beyond those that have been evacuated."34 2.8 Plant and offsite officials should continue assessment actions based on additional plant information, dose projections, and field monitoring results. After performing the initial early evacuation actions near the plant, licensee and offsite officials should modify their protective action recommendations as necessary based on (1) field monitoring to locate areas with high levels of contamination (hot spots) and (2) dose projections which indicate that EPA protective action guide doses may be exceeded in areas beyond those that have been evacuated. On the basis of this information, plant and offsite officials may expand the evacuations to encompass other areas in the plume EPZ and, for the worst case accidents, protective actions may be required beyond the plume EPZ.2.9 Plant and offsite officials should continue assessment actions based on additional plant information, dose projections, and field monitoring results. After performing the initial early evacuation actions near the plant, licensee and offsite officials should modify their protective action recommendations as necessary based on (1) field monitoring to locate areas with high levels of contamination (hot spots) and (2) dose projections which indicate that EPA protective action guide doses may be exceeded in areas beyond those that have been evacuated. On the basis of this information, plant and offsite officials may expand the evacuations to encompass other areas in the plume EPZ and, for the worst case accidents, protective actions may be required beyond the plume EPZ.Expansion of Initial PARs Revision 17 Expansion of Initial PARs Revision 18 35 PPM 13.2.2 Rev 18 SIP Guidance Inspection Report "Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, "Determining Protective Action Recommendations," on June 16, 2014, so that it:

  • No longer provided a mechanism to make a shelter-in-place protective action recommendation;
  • No longer ensured a protective action recommendation in the event of a planned release of radioactive material;"36Emergency Plan Implementing Procedures PPM 13.2.2 Rev 18 SIP Guidance 4.2 Initial Plant Based PARs for General Emergency Classifications4.2.1 REFER to Attachment 7.1, Decision Guide for Offsite Protective Action Recommendations to ensure appropriate PAR is determined

.a. IFa dose projection has been made, THENDETERMINE appropriate downwind section(s) based on the doseprojection program output.b. IF NOdose projection is made

,THENUSEthe "Downwind Sections Table" in attachment to determineappropriate sections.4.2.2 INDICATE the PAR on the Classification Notification Form (CNF), Form 24075,AND MAKE the required offsite notifications in accordance with PPM 13.4.1,Emergency Notifications.37Dave Brown (Emergency Director)

ENTER IF SAE or GE DeclaredAutomatic PAR to evacuate Recreational Areas and EPZ SchoolsENTER IFWhile at GE a change in Release Status or Meteorological Conditions occursEvacuate Sections where EPA PAGs (Attachment 7.2)are projected to be exceeded based on DoseAssessments or actual survey readings. 1 & 2PLUSIFnot previously recommended, THENEvacuateALL Sections 0-2 Miles and 10 Miles downwindAND shelter remaining Sections.

1PLUSAutomatic PAR to evacuate RecreationalAreas and EPZ SchoolsSAEGERecreational Areas:Columbia River Ringold Fishing AreaHorn Rapids RecreationWahluke Hunting AreaArea / ORV ParkEvacuate ALL Sections 0-2 Miles and 10 Miles downwind AND shelter remaining Sections.PLUSAutomatic PAR to evacuate RecreationalAreas and EPZ SchoolsRelease inProgress?YesNoAttachment 7.1 -Initial PAR, General Emergency, Release in Progress or Planned Release38 From EPA 400, Manual of Protective Action Guides and Protective Actions for NuclearIncidents1 Sheltering may be the preferred protective action when it will provide protection equalto or greater than evacuation, based on consideration of factors such as source termcharacteristics, and temporal or other site-specific conditions.Evacuation vs. ShelteringBecause of the higher risk associated with evacuation of some special groups in the population (e.g.those who are not readily mobile),sheltering may be the preferred alternative for such groups as aprotective action at projected doses up to 5 Rem TEDE. In addition, under unusually hazardousenvironmental conditions, use of sheltering at projected doses up to 5 Rem to the general population(and up to 10 Rem to special groups) may be justified. Offsite officials will determine when the use ofsheltering is appropriate.Illustrative examples of situations or groups for which evacuation may not be appropriate at 1 Reminclude: a) the presence of severe weather, b) competing disasters, c) institutionalized persons whoare not readily mobile, and local physical factors which impede evacuation.PROTECTIVEACTIONPAG(projected dose)COMMENTSEvacuation(or sheltering 1)1 -5 Rem TEDE OR 5 -25 Rem CDE thyroid OR 50 -500 Rem skinEvacuation (or, for somesituations, sheltering

1) should normally be initiated at the lowest level of the range.Attachment 7.2 -PAGs for the Early Phase of a Nuclear Incident39 ENTER IF SAE or GE DeclaredAutomatic PAR to evacuate Recreational Areas and EPZ SchoolsENTER IFWhile at GE a change in Release Status or Meteorological Conditions occursEvacuate Sections where EPA PAGs (Attachment 7.2)are projected to be exceeded based on DoseAssessments or actual survey readings. 1 & 2PLUSIFnot previously recommended, THENEvacuateALL Sections 0-2 Miles and 10 Miles downwindAND shelter remaining Sections.

1PLUSAutomatic PAR to evacuate RecreationalAreas and EPZ SchoolsSAEGERecreational Areas:Columbia River Ringold Fishing AreaHorn Rapids RecreationWahluke Hunting AreaArea / ORV ParkEvacuate ALL Sections 0-2 Miles and 10 Miles downwind AND shelter remaining Sections.PLUSAutomatic PAR to evacuate RecreationalAreas and EPZ SchoolsRelease inProgress?YesNoAttachment 7.1 -Initial PAR, General Emergency, No Release in Progress40 Updating PARs Inspection Report "Revision 18, Step 4.4.4, states, in part, "IF there is to be a planned release (containment venting) THEN discuss the proposed activity with offsite authorities to assist them with protective action implementation.""Revision 18, Step 4.4.5, states, in part, "WHEN circumstances such as weather, distance, or concurrent emergencies may impact specific areas for which PARs are being proposed, THEN inform the Benton and Franklin County EOFs-" The inspectors determined that Revision 17 required the licensee make a protective action recommendation to offsite authorities for planned releases of radioactive material into the environment, while Revision 18 requires the licensee to discuss a planned release with offsite authorities. The inspectors concluded that a discussion intended to assist offsite authorities is not equivalent to a protective action recommendation from the licensee to offsite authorities."41 Updating PARs4.4 Updating Offsite PARs Based on Projected Doses or Offsite Survey ResultsNOTE:Do not delay recommending offsite protective actions while waiting for field monitoring results to verify the accuracy of the dose projection results.4.4.1 OBTAIN ANDREVIEW applicable offsite dose projection and/or survey data.4.4.2 DETERMINE the appropriate offsite PAR by comparing the plume projected dose and/or Field Monitoring Team data with the Protective Action Guidelines (PAGs) and guidance provided in Attachment 7.2, PAGs for the Early Phase of a Nuclear Incident.

a. IFreview of dose projections or survey results indicate a PAG has been exceeded in any Sections not already evacuated, THENISSUE a new PAR for additional affected Sectionsb. IFdose projections or survey results indicate a PAG may be exceeded beyond

,10 miles, THENREFER to step 4.5. 42 Updating PARs 4.4.3Updating Offsite PARs Based on Change of Wind Direction with NO PAG exceeded.

a. ISSUE a new PAR ONLY if the following conditions are met:* The change in wind direction affects a downwind Section (see Attachment 7.1 for downwind Sections) for which an Evacuation PAR has NOT been issued.

AND* Containment Radiation Monitor reading GT 14,000 R/hr.AND* LOSS OR POTENTIAL LOSS of Primary Containment as indicated by the Fission Product Barrier Degradation Table in PPM 13.1.1, Classifying the Emergency.4.4.4 IF there is to be a planned Release (containment venting), THEN DISCUSS proposed activity with offsite authorities to assist them with Protective Action implementation.43 Updating PARs444.4.5 WHENcircumstances such as weather, distance or concurrent emergencies may impact specific areas for which PARs are being proposed, THENINFORM the Benton and Franklin County EOCs which sections are most affected so that routes to be taken or avoided may be identified, or other special considerations in the notification to offsite agencies. 4.4.6 IFany of the above actions result in a change to established PARs, THENCOMPLETE the appropriate parts of the CNF, and make the required notifications in accordance with PPM 13.4.1, Emergency Notifications.

Columbia Electronic Classification Notification Form45Class/NotifForm 46Lessons LearnedEngagement with NEI EPWGEngagement with NSIRInspection InterfaceKurt Gosney (Acting General Manager Emergency Services)

Don Gregoire (Manager Regulatory Affairs)Summary of DifferencesInspection Report"Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, "Determining Protective Action Recommendations," on June 16, 2014, so that it:

  • No longer provided a mechanism to make a shelter-in-place protective action recommendation"Energy NorthwestA mechanism for making a shelter-in-place protective action recommendation is provided via Attachment 7.1 and 7.2 of PPM 13.2.2 Revision 18.47Emergency Plan CommitmentsFederal GuidanceEmergency Plan Implementing ProceduresClassification Notification Form Summary of DifferencesInspection Report"Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, "Determining Protective Action Recommendations," on June 16, 2014, so that it:
  • No longer ensured a protective action recommendation in the event of a planned release of radioactive material"Energy NorthwestA protective action for planned releases of radioactive materials is developed using Attachment 7.1 and 7.2 of PPM 13.2.2 Revision 18. In addition steps 4.2.2 (initial PAR) and 4.4.6 (updated PAR) ensure that notifications for a planned release of radioactive material are made.48 Summary of DifferencesInspection Report"Specifically, Columbia Generating Station revised emergency plan implementing Procedure 13.2.2, "Determining Protective Action Recommendations," on June 16, 2014, so that it:
  • Removed the responsibility of the emergency coordinator in the control room(shift manager) to make protective action recommendations for areas outside the plume phase (10-mile) emergency planning zone."Energy NorthwestNo responsibility was removed from the shift manager. Step 4.5.1 of PPM 13.2.2 Revision 18 correctly transfers responsibilities to the TSC or EOF for the expansion of PARs beyond the EPZ which requires field monitoring (an augmented function) to support conclusions. This is consistent with section 5.5.2 of the Columbia Emergency Plan.49 Summary of DifferencesInspection Report"Specifically, the licensee failed to follow Sections 2.1-of Emergency Plan, Revisions 59 through 61-"Energy NorthwestEnergy Northwest complies with Emergency Plan section 2.1 based on taking into considerationthe additional text of Section 5.5.2. Specifically,Section 5.5.2 states that subsequent protective action for areas beyond those evacuated should be based on both dose monitoring and dose projections. Consistent with federal guidance.Dose monitoring is conducted by field teams which is an augmented ERO function. Augmented EROs are led by an Emergency Director in either the TSC or EOF.Step 4.5.1 of PPM 13.2.2 Revision 18 requires field team data for PAR determination.50 Summary of DifferencesInspection Report"Specifically, the licensee failed to follow Sections-5.5 of Emergency Plan, Revisions 59 through 61-"Energy NorthwestEnergy Northwest complies with Emergency Plan section 5.5 based on taking into consideration the entire text of Sections 5.5 and 5.5.2. Specifically: Section 5.5 states that protective action guides discussed in section 5.5.2 provide pre-planned guidance for making response decisionsSection 5.5.2 states that shelter and evacuation guidelines are based on EPA and NUREG-0654 Supplement 3 guidelinesProtective action recommendation guidance in Attachment 7.1 and 7.2 of PPM 13.2.2 Revision 18 are based on EPA and NUREG-0654 Supplement 3 (2011) recommendations.51 Significance Assessment Stated Basis for Significance "The planning standard function was degraded because, although the licensee could make appropriate recommendations for evacuation of the public, the licensee could no longer make recommendations for the public to shelter-in-place when appropriate, and limitations could result in delaysin making appropriate protective action recommendations for areas outside the emergency planning zone."52 Significance Assessment Very Low Safety Significance 1.(2015) -Region I PlantFailure to maintain effectiveness of Emergency PlanProcedure changes made to PAR flowchart that would result in "inappropriately recommending evacuation of downwind areas and many more emergency response planning areas (ERPAs) than intended"Both downwind and many other areas affected with inappropriate evacuation53 Significance Assessment2.(2012/2011) -2 Region IV Plants Failure to develop and have in place guidelines for the choice of protective actions consistent with federal guidance (procedure did not implement EPA-400-R 001)Automatic process extended protective action for evacuation based on plant conditions and changes in wind direction without considering radiation dose 54 Significance Assessment Low to Moderate Safety Significance 1.(2015) -Region IV PlantChanged PAR procedure to eliminate PARs over the ocean within 10 mile EPZ2.(2012) -Region III PlantChanged PAR procedure to eliminate decision-making process for PARs beyond EPZUpdated evacuation PAR during drill to Shelter55 Summary of SignificanceColumbia continues to meet Emergency Plan CommitmentsAll considerations for shelter-in-place found in applicable federal guidance are addressed in PPM 13.2.2 Rev 18Compliance with NUREG-0654 Supplement 3 results in 10 CFR 50.47(b)(10) compliancePublic health and safety appropriately protected56 ClosingGrover HettelVice President Operations57
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