3F0814-07, Exemptions to Radiological Emergency Response Plan Requirements Defined by 10 CFR 50.47 and Appendix E to Part 50, Supplement

Exemptions to Radiological Emergency Response Plan Requirements Defined by 10 CFR 50.47 and Appendix E to Part 50, Supplement

ML14251A237
Person / Time
Site:	Crystal River
Issue date:	08/28/2014
From:	Reising R Duke Energy Florida
To:	Document Control Desk, Division of Operating Reactor Licensing
References
3F0814-07, TAC MF2981, TAC MF3415
Download: ML14251A237 (36)

Text

DUiKE Crystal River Nuclear Plant D K 15760 W. Power Line Street ENERGY.

Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.12 August 28, 2014 3F0814-07 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Crystal River Unit 3 - Exemptions to Radiological Emergency Response Plan Requirements Defined by 10 CFR 50.47 and Appendix E to Part 50, Supplement

References:

1. CR-3 to NRC letter, "Crystal River Unit 3 - License Amendment Request

1. 315, Revision 0, Permanently Defueled Emergency Plan and Emergency Action Level Scheme, and Request for Exemption to Certain Radiological Emergency Response Plan Requirements Defined by 10 CFR 50," dated September 26, 2013. (ADAMS Accession No. ML13274A584)

2. CR-3 to NRC letter, "Crystal River Unit 3 -

Exemptions to Radiological Emergency Response Plan Requirements Defined by 10 CFR 50.47 and Appendix E to Part 50, Revision 1, and Response to Request for Additional Information," dated March 28, 2014.

Dear Sir:

In accordance with 10 CFR 50.12, Duke Energy Florida, Inc. hereby submits a supplement to the request for exemption to certain Radiological Emergency Response Plan requirements defined by 10 CFR 50 which were contained in the Crystal River Unit 3 (CR-3) submittal (Reference 1) and revised in the March 28, 2014 submittal (Reference 2). This supplement amends the CR-3 request in order to align with the exemptions proposed by the Nuclear Regulatory Commission staff in SECY 14-0066, "Request by Dominion Energy Kewaunee, Inc.

for Exemptions from Certain Emergency Planning Requirements," which was approved by the Commission in, "Staff Requirements -

SECY 14-0066 -

Request by Dominion Energy Kewaunee, Inc. for Exemptions from Certain Emergency Planning Requirements," dated August 7, 2014 (ADAMS Accession No. ML14219A366).

The Enclosure to this letter provides the revised request for exemption to certain Radiological Emergency Response Plan Requirements defined by 10 CFR 50.47 and Appendix E to Part 50.

The items that require revision are marked with revision bars in the right hand margin.

There are no new regulatory commitments associated with this supplement.

If you have any questions regarding this submittal, please contact Mr. Dan Westcott, Manager, Nuclear Regulatory Affairs, at (352) 563-4796.

U. S. Nuclear Regulatory Commission 3F0814-07 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on August 28, 2014.

Sincerely, Ronald R. Reising, Senior Operations Support RRR/sam

Enclosure:

Request for Exemption to Certain Radiological Emergency Response Plan Requirements Defined by 10 CFR 50, Supplement xc:

NRR Project Manager Regional Administrator, Region 1

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 EXEMPTIONS TO RADIOLOGICAL EMERGENCY RESPONSE PLAN REQUIREMENTS DEFINED BY 10 CFR 50.47 AND APPENDIX E TO PART 50, SUPPLEMENT ENCLOSURE REQUEST FOR EXEMPTION TO CERTAIN RADIOLOGICAL EMERGENCY RESPONSE PLAN REQUIREMENTS DEFINED BY 10 CFR 50, SUPPLEMENT

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 1 of 33 REQUEST FOR EXEMPTION TO CERTAIN RADIOLOGICAL EMERGENCY RESPONSE PLAN REQUIREMENTS DEFINED BY 10 CFR 50, SUPPLEMENT Bold strike out text identifies the extent of the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.

Reference Regulation in 10 CFR 50.47 Basis for Exemption 1

10 CFR 50.47(b): The onsite and, c

.*xpt as prOVided in Crystal River Unit 3 (CR-3) requests an exemption to the paragraph (d) of this...

t.O", ofie"c emergency requirements for offsite emergency response plans.

Offsite response plans for nuclear power reactors must meet the response plans are not necessary because it is no longer following standards:

possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident to result in radioactive releases which exceed the U.S. Environmental Protection Agency's (EPA) Protective Action Guides (PAGs) at the site boundary.

CR-3 requests exemptions from the regulations to the extent that these regulations apply to specific provisions of onsite and offsite emergency planning that are not applicable to CR-3.

Details related to specific exemption requests are provided below.

2 10 CFR 50.47(b)(1): Primary responsibilities for CR-3 requests an exemption from the regulation requiring the emergency response by the nuclear facility licensee and assignment of primary responsibilities for emergency response by State and local organizations within the Emergency to State and local organizations within the existing Plume PIe g ZeRes have been assigned, the emergency Exposure Pathway and Ingestion Exposure Pathway responsibilities of the various supporting organizations Emergency Planning Zones (EPZs). Because it is no longer have been specifically established, and each principal possible for EPA PAGs to be exceeded at the site boundary, response organization has staff to respond and to augment defined Plume Exposure Pathway and Ingestion Exposure its initial response on a continuous basis.

Pathway EPZs are no longer necessary. Letters of Agreement and conduct of operations with various offsite support organizations (hospitals, ambulance, fire-fighting and law enforcement) will be maintained to the extent necessary to support defueled conditions. Response may be to the plant or in support of transport or treatment of contaminated and/or injured individuals.

The normal station operating staff and Emergency Organization will be replaced by a Defueled On-Shift Staff and Emergency Organization with the capability to

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 2 of 33 Reference Regulation in 10 CFR 50.47 Basis for Exemption respond to declared emergencies on a 24-hour basis.

Minimum on-shift positions will be governed by the CR-3 Technical Specifications. Augmented staff will be available to respond to an emergency.

3 10 CFR 50.47(b)(2): On-shift facility licensee No exemption is requested.

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.

4 10 CFR 50.47(b)(3): Arrangements for requesting and CR-3 requests an exemption from the regulation to maintain effectively using assistance resources have been made, arrangements to accommodate State and local emergency a.rrangements to.a...commodate State and local staff at response staff at the Emergency Operations Facility (EOF).

thc licensee's Em*ergenc.Y OperatiiGnS Facility haw Because it is no longer possible for EPA PAGs to be exceeded been-Mader and other organizations capable of at the site boundary, elimination of the EOF is requested since augmenting the planned response have been identified.

there will be no need for a response by offsite agencies to this facility.

The CR-3 emergency plan will continue to maintain arrangements for requesting and using assistance resources from offsite support organizations.

5 10 CFR 50.47(b)(4): A standard emergency classification CR-3 requests an exemption from the regulation requiring the and action level scheme, the bases of which include facility onsite emergency classification and action level scheme system and effluent parameters, is in use by the nuclear information to be provided in support of initial offsite response facility licensee, and State and local response planS call measures.

CR-3 will adopt the Permanently Defueled for. relianc on i mtin proevided by facilip, Emergency Action Levels (EALs) detailed in Nuclear Energy licensees for deter-minations of Minimum initial offeite Institute (NEI) 99-01, "Development of Emergency Action response measures.

Levels for Non-Passive Reactors," Revision 6. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to provide information to State and local response organizations for the development of Protective Action Decisions and offsite emergency planning by State and local organizations, with currently defined emergency

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 3 of 33 Reference Regulation in 10 CFR 50.47 Basis for Exemption response roles, is no longer necessary.

6 10 CFR 50.47(b)(5): Procedures have been established CR-3 requests an exemption from the regulation requiring for notification, by the licensee, of State and local response onsite and State and local offsite emergency plans contain the organizations and for notification of emergency personnel means to provide early notification and clear instruction to the by all organizations; the content of initial and followup populace within the Plume Exposure Pathway EPZ. Because it messages to response organizations aRd-the-publiG has is no longer possible for the radiological consequences of a been established; and means to provide ear4y design basis accident or a postulated beyond design basis no.tifica-,-.tion -and-cear instruction to the p.pulac, accident at CR-3 to result in radioactive releases which exceed within the plume exposure pathway E.mergency the EPA PAGs at the site boundary, the need to provide these Pl.anning Zo-ne haVe been e..tablih-ed.

messages to the public, the need to maintain the Alert and Notification System, the need for the public to take protective actions and offsite emergency planning by State and local organizations, with currently defined emergency response roles, is no longer necessary.

7 10 CFR 50.47(b)(6): Provisions exist for prompt CR-3 requests an exemption from the regulation requiring communications among principal response organizations maintenance of provisions for prompt notification to the public.

to emergency personnel and to the public.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for prompt notification and supporting systems, the need for the public to take protective actions and offsite emergency planning by State and local organizations, with currently defined emergency response roles, is no longer necessary.

8 10CFR 50.47(b)(7): Information imade available to CR-3 requests an exemption from the regulation requiring the public. on a perio.dic-bagias on how they will be information be made available to the public on a periodic basis notified and what thper i al.ationsg q saho.-d be 'in an on how they will be notified and what their initial actions should emergenc.

,.-g.,

listening.to local brodcast-tat-'--

o be during an emergency. News media contacts for CR-3 will and remaiRiRg indoe-s), the principal points of contact be maintained and upon an event at the CR-3 site, information with the news media for dissemination of information would be disseminated to the public and briefings with pertinent during an emergency (including the physical location or media organizations would be conducted per corporate

'-ee-t"en-- are established in advance, and procedures for communication protocols. Because it is no longer possible for coordinated dissemination of information to the public are the radiological consequences of a design basis accident or a established, postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 4 of 33 Reference Regulation in 10 CFR 50.47 Basis for Exemption boundary, the need to educate the public on what their prompt actions would be in the event of a radiological emergency is not necessary because the need for the public to take protective actions does not exist.

9 10 CFR 50.47(b)(8): Adequate emergency facilities and No exemption is requested.

equipment to support the emergency response are provided and maintained.

10 10 CFR 50.47(b)(9); Adequate methods, systems, and CR-3 requests an exemption from the regulation requiring equipment for assessing and monitoring actual or potential offsite accident assessment capabilities during an emergency effsite consequences of a radiological emergency and for the onsite emergency plan to contain established condition are in use.

procedures for coordinating accident assessment capabilities with offsite organizations. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, there is no need for CR-3 to maintain offsite accident assessment capabilities.

Since a need for monitoring and assessing no longer exists, CR-3 no longer intends to maintain the capability to deploy field teams for assessing and monitoring offsite radiological conditions.

The CR-3 Permanently Defueled Emergency Plan (PDEP) will continue to maintain onsite assessment capabilities.

11 10 CFR 50.47(b)(10): A range of protective actions has CR-3 will rely upon offsite organizations for firefighting, law been developed for the plume cxposu.. pathway EPZ enforcement, ambulance, and medical services in support of fer-emergency workers and the public. in developing this the (onsite) emergency plan described in the PDEP. CR-3 is range of 3ctIO,.,

con.idcr-atien has been given to also responsible for control of activities in the Exclusion Area, eva'cu-ation,.

.elter-.ng, and, as a

_upp"ement to there, including public access.

A range of protective actions have the pro.phy!actic use of p.tas.ium iodide (1411),

as been developed for emergency workers and the public, which app..pr.at.. Evacuation time cetimates have been is described in the PDEP.

developed by appicants and l.icens.ees.. Li.enc..

CR-3 requests an exemption from the regulation requiring shall update the evacu..ation time ect.matec. on a development of protective actions for the Plume Exposure pcodi. basis. Guidelines for the c.hoice of pr-ote.tive Pathway and Ingestion Exposure Pathway EPZs. Because it is a

.t.o..

during an e c.. ci.......

ith Federal no longer possible for EPA PAGs to be exceeded at the site g uae, arc developed and in plare, and pr-otecti.

boundary, the need to provide Protective Action ac.tions for the ingestion exposure pathway E12 Recommendations (PARs) to State and local response

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 5 of 33 Reference Regulation in 10 CFR 50.47 Basis for Exemption appr..pri.at. to the locale hav.e een devop.d..,

organizations for the development of Protective Action Decisions, including consideration to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI) is no longer necessary. Evacuation of the public and the need to develop Evacuation Time Estimates (ETEs) is no longer necessary.

12 10 CFR 50.47(b)(11): Means for controlling radiological No exemption is requested.

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.

13 10 CFR 50.47(b)(12): Arrangements are made for medical No exemption is requested.

services for contaminated injured individuals.

14 10 CFR 50.47(b)(13): General plans for recovery and No exemption is requested.

reentry are developed.

15 10 CFR 50.47(b)(14): Periodic exercises are (will be)

No exemption is requested.

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.

16 10 CFR 50.47(b)(15): Radiological emergency response No exemption is requested.

training is provided to those who may be called on to assist in an emergency.

17 10 CFR 50.47(b)(16): Responsibilities for plan No exemption is requested.

development and review and for distribution of emergency plans are established, and planners are properly trained.

18 10 CFR 50.47(c)(2): Generally, the plume exposure CR-3 requests an exemption from the regulation requiring pathway EPZ fo-- nucl.

I

..a power plants shall consist e defined Plume Exposure Pathway and Ingestion Exposure an area abo-u 1n0 mile (16 kin) -n radius aRd the Pathway EPZs.

The analysis of the potential radiological ingestin pathway EPZ shall consist of. an ar. a abut impact of an accident for CR-3 in a permanently defueled 60 miles (80 kin) in radius. The exact size and condition indicates that any releases beyond the site boundary

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 6 of 33 Reference Regulation in 10 CFR 50.47 Basis for Exemption configuration of the E-P-Zs urondn a particullar nuGecar powcr reactor shall be determined in rellation to local emer-gency response needs and capabilities as they arc affected by sucr-h cona-diations as demogr-aphy, te~aer-aohy. land characteriSticS, a;ccess rouites, and are limited to small fractions of the EPA PAG exposure levels, as detailed in the EPA's "Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment," dated March 2013 (PAG Manual).

According to the PAG Manual, "EPZs are not necessary at those facilities where it is not possible for PAGs to be exceeded off-site."

he size of the EPZs a" urisaicrionai Dounuarles.

may be determined on a case-by-case basis for gas cooled nuclear reactors and for reactors with an authorized power level less than 250 MW thermal. The pl.ans *ar-the ingestion pathway shall focum-s on suc--h actions asare appropriate to proDtect the food ingestion pathway.-

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 7 of 33 Reference Regulation in Appendix E to Part 50 Basis for Exemption 19 10 CFR 50 App E: Ill. The Final Safety Analysis Report; No exemption is requested.

Site Safety Analysis Report The final safety analysis report or the site safety analysis report for an early site permit that includes complete and integrated emergency plans under § 52.17(b)(2)(ii) of this chapter shall contain the plans for coping with emergencies. The plans shall be an expression of the overall concept of operation; they shall describe the essential elements of advance planning that have been considered and the provisions that have been made to cope with emergency situations. The plans shall incorporate information about the emergency response roles of supporting organizations and offsite agencies. That information shall be sufficient to provide assurance of coordination among the supporting groups and with the licensee. The site safety analysis report for an early site permit which proposes major features must address the relevant provisions of 10 CFR 50.47 and 10 CFR part 50, appendix E, within the scope of emergency preparedness matters addressed in the major features. The plans submitted must include a description of the elements set out in Section IV for the emergency planning zones (EPZs) to an extent sufficient to demonstrate that the plans provide reasonable assurance that adequate protective measures can and will be taken in the event of an emergency.

20 10 CFR 50 App E The scope of the PDEP will not include onsite protective IV Content of Emergency Plans actions during hostile action.

In the Emergency 1.The applicant's emergency plans shall contain, but not Preparedness (EP) Final Rule (December 2011), the necessarily be limited to, information needed to NRC defined "hostile action" as, in part, an act directed demonstrate compliance with the elements set forth below, toward a nuclear power plant or its personnel. The NRC i.e., organization for coping with radiological emergencies, excluded non-power reactors (NPRs) from the definition assessment actions, activation of emergency organization, of "hostile action." CR-3 should not be required to plan notification procedures, emergency facilities and for an offsite impact resulting from "hostile action" equipment, training, maintaining emergency preparedness, because: (1) the facility poses a lower radiological risk to the public than does a power reactor, and (2) the facility

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 8 of 33 recovery, and onsite protective action. during hostile has a low likelihood of a credible accident resulting in aerie., In addition, the emergency response plans radiological releases requiring offsite protective submitted by an applicant for a nuclear power reactor measures.

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 § 50.47(b), and they will be evaluated against those standards.

21 IV. 2 Thi-s nucle.,r poewc reactor li"cns. applircant shall CR-3 requests an exemption from the regulation since also proVide an analysis of the timc required to this requirement does not apply to CR-3 (intended for vacu-ate variou--

ecators and distanGcs w.-ithin the nuclear power reactor license applicants).

plume exposure pathway E=PZ for transient anRd perm.anent populations, using the most =onU.S.

v~

Census-Brewau data as of the date the applicant submits its applicatio-n to-t-he NRC.

22 IV. 3 Nuclear power rcact,.

li.ensees shall use NRC CR-3 requests an exemption from the regulation requiring approved eva.uatio.n tim-

.es timates (ET=s) and the use of NRC-approved ETEs and updates to the ETEs updates to the ETEs in the formulation Of protective in the formulation of PARs and the requirement to provide action recommendations and shall provide the ET-Es ETE updates to State and local government authorities and ET-updates to. State and local government for use in developing offsite protective action strategies.

a u""thoe..s.... r is in e v elp.Ig oG

1. 6*i"te pt Fecti"e Because it is no longer possible for EPA PAGs to be a"tion atrategie exceeded at the site boundary, EPZs and the associated protective actions developed with consideration to ETEs are no longer required.

23 IV. 4 1!8thn 326A days of the later of the d-ate of the CR-3 requests an exemption from the regulation requiring avai of t.he most recent decennial census data the use of NRC-approved ETEs and updates to the ETEs from the U.S. Census Bureau or De..ember 23, 204,4 in the formulation of PARs and the requirement to provide nuclear p.wer reactor li.ensees shall develop an ETE ETE updates to State and local government authorities analysi using this deennial d.ata and s-*

it-It und*e*

for use in developing offsite protective action strategies.

§ 60.4 to the NRC. These licensees shal sm.--.t this Because it is no longer possible for EPA PAGs to be ETE analysis to the NRC-at least 18.0 days before using exceeded at the site boundary, EPZs and the associated it to fo.m protective action recommendations and protective actions developed with consideration to ETEs proig it to State.and local goverm.n..

authorities are no longer required.

for use in developing offit1 protective ac-tion

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 9 of 33 24 IV 5 Durin~g the years bct::ccn decennial censuses-,

nuclear power reactor licensees shall estimtEP permanent resident population changes on~e-a "earm, but noG later than 366 days from the date ofte previous estimate, Using the Most recent U..Cnu Bureau annual resident population estlimate n State/local government population data, if aalbe These licensees shall maintain these estimates so that they are ailbefor NRC Inspection duFrig the period between de-cennial censuses and shall submi hs estimates to the NRC with any updated ETE-analysis-.

CR-3 requests an exemption from the regulation requiring the estimation of EPZ permanent resident population changes once per year using recent U.S. Census Bureau annual resident population estimate and State/local government population data.

CR-3 also requests an exemption to the requirement to maintain estimates for NRC inspection and the requirement to submit estimates and updated ETE analysis. ETEs will no longer be used in the formulation of PARs or to provide ETE updates to State and local government authorities for use in developing offsite protective action strategies. Because it is no longer possible for EPA PAGs to be exceeded at the site boundary, EPZs and the associated protective actions developed with consideration to ETEs are no longer required.

25 I\\I S If -,

~

+;~

~

4kg dn~n..~j'd n~rnd tI'r FPZ r~

~,

permanent resident population increases suchthat it causes the longest ETE value for-the 2-mile oeo mili zone, Inuduaing al auci*ca cmclglncy RespoInse Planning Areas, or for the entire 1 0-mile EPZt Sincrease by 26 percent Or 30 minutes, whihvrs less, from the nnuclear power FreaGtG l.cense's currently NRC approved Or updated ETE, the licensee shall update the ETE analysils to reflect the impacto that population hincease. The lcensee shall submit the updated ETE ana~lysis to the NRC under §601nlae than 366 days after the licensee's determinainta the criteria for updating the ETE have been met and at least 180 days before Using it to form protective action recommendations and providing it to State-and local governmental aulthorities for use in developing offsite Drotoctive action sttrategiesm.

CR-3 requests an exemption from the regulation requiring the continuous monitoring of EPZ permanent resident population changes using recent U.S. Census Bureau annual resident population estimate and State/local government population data and the requirement to submit estimates and updated ETE analysis. ETEs will no longer be used in the formulation of PARs or to provide ETE updates to State and local government authorities for use in developing offsite protective action strategies.

Because it is no longer possible for EPA PAGs to be exceeded at the site boundary, EPZs and the associated protective actions developed with consideration to ETEs are no longer required.

26 IV 7 After an applicant for a combined license under part 52 No exemption is requested. CR-3 is not an applicant for of this chapter receives its license, the licensee shall a combined license, and therefore, this regulation is not conduct at least one review of any changes in the applicable to CR-3.

population of its EPZ at least 365 days prior to its scheduled fuel load. The licensee shall estimate EPZ

U. S. Nuclear Regulatory Commission Enclosure 3F0814-07 Page 10 of 33 permanent resident population changes using the most recent U.S. Census Bureau annual resident population estimate and State/local government population data, if available. If the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ, to increase by 25 percent or 30 minutes, whichever is less, from the licensee's currently approved ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase. The licensee shall submit the updated ETE analysis to the NRC for review under § 50.4 of this chapter no later than 365 days before the licensee's scheduled fuel load.

27 A Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

28 A.1. A description of the normal plant Gper-athng CR-3 requests an exemption to the term "operating" as it organization.

no longer applies to CR-3. The station will be maintained by a defueled on-shift staff.

29 A 2. A description of the onsite emergency response No exemption is requested.

organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

30 A 3. A dcScription, by

-p..-ti"n and. f.U.nctio.n to be CR-3 requests an exemption to the requirement to

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 11 of 33 per.Fomed, of the -".e...e's headuar*..

per-.....l describe headquarters personnel who will be sent to the who-will be-sent to the plant site to augment-t.he.n..t-'e plant to augment the onsite emergency organization.

emergency or-ganization.

The level of emergency response required by the CR-3 PDEP does not require response by headquarters personnel.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for headquarters response is no longer necessary.

31 A 4. Identification, by position and function to be performed, CR-3 requests an exemption to the requirement to make of persons within the licensee organization who will be offsite dose projections. The responsibility and process responsible for making-effseite dose projections and a for completing onsite dose projections and the description of how these projections will be made and the communication of results to State and local authorities, results transmitted to State and local authorities, NRC, and NRC, and appropriate governmental entities will be other appropriate governmental entities.

maintained by the PDEP. Offsite emergency response capability is no longer appropriate as no design basis accident or postulated beyond design basis accident can result in radioactive releases which exceed EPA PAGs at the site boundary. The postulated dose to the general public from any credible event would not exceed EPA PAGs.

32 A 5. Identification, by position and function to be CR-3 requests an exemption to the requirement to pefor*med, Of othcr

.mployee.

of the,l....ee with identify employees, other persons or consultants with

• -ual*f*atG.sn for r.oping with emergency special qualifications who may be called upon for

,,.nd.it.-io.n, that May ar. e. Other per...n. with.pe'ial assistance. Individuals with special qualifications are no

.ualification., uch 215 coA6ultantc, who are not longer needed to assist emergency response personnel

,mplnyeec of the lic-en"ee -and-who may be called upon because no design basis accident or postulated beyond for. ac.ic.anc. fre.

mergencies shall also be identified.

design basis accident can result in radioactive releases The special qualific.ation, of thse persons shall be which exceed EPA PAGs at the site boundary.

33 A 6. A description of the local offsite services to be No exemption is requested.

provided in support of the licensee's emergency organization.

34 A 7. By June 23, 20144, identification of, and a-desr.IptieGR CR-3 requests an exemption to the requirement for

_f-the assistance expected from, appropriate State, local, describing assistance expected from State, local, and

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 12 of 33 and Federal agencies with responsibilities for coping with emergencies, including hostile action at the site. For I. MU e

of this "h

stl arI"R de..

as-an act directed toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.

Federal agencies with responsibilities for coping with emergencies, including hostile action. Since protective actions are no longer needed for the public, the responding agencies would not have conflicting duties that may prevent offsite resources from responding to the site during a hostile action. Offsite emergency response capability is no longer appropriate as no design basis accident or postulated beyond design basis accident can result in radioactive releases which exceed EPA PAGs at the site boundary.

In the EP Final Rule (December 2011), the NRC defined "hostile action" as, in part, an act directed toward a nuclear power plant or its personnel.

The NRC excluded NPRs from the definition of "hostile action." CR-3 should not be required to plan for an offsite impact resulting from hostile action because: (1) the facility poses a lower radiological risk to the public than does a power reactor, and (2) the facility has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures.

35 A 8. identification ef the State and,.,or locnal offic-al, CR-3 requests an exemption to the requirement to re.pon.ible for-planning for, ordering, and controlling identify State or local officials responsible for protective appro.priate pr..tectiv.-e actin.,

including evacuation.

actions.

Offsite protective actions are no longer when ne-,*.

e. ar..

appropriate as no design basis accident or postulated beyond design basis accident can result in radioactive releases which exceed EPA PAGs at the site boundary.

The need to provide PARs to State and local response organizations for the development of Protective Action Decisions and the need to plan for, order and control protective actions, including evacuations, is no longer necessary.

36 A 9. By December 24, 2012, for u.c!ear power-reactcr CR-3 requests an exemption to the requirement to

,.-nsees, a detailed anal...i. demontating that

,o complete a detailed analysis demonstrating that on shift ohift per.....el assigned.m.rgenr..placn personnel assigned emergency plan implementation implementation fnc.*tRio ar" not assigned functions are not assigned responsibilities that would re.pon.

that wou-Id p.eve.t the timely' prevent the timely performance of their assigned peo*.man... of their ae-.igned fUn.tion. as pe.ified in functions as specified in the emergency plan. In the EP the em..geR..

plan.

Final Rule (December 2011), the NRC acknowledged

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 13 of 33 that the staffing analysis requirement was not necessary for non-power reactor licensees because staffing at non-power reactors is generally small which is commensurate with operating the facility in a manner that is protective of the public health and safety. Because of the slow rate of the event scenarios postulated in the design basis accident and postulated beyond design basis accident analyses, significant time is available to complete actions necessary to mitigate an emergency without impeding timely performance of emergency plan functions.

+

I 37 B. Assessment Actions B.1. 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. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offaite-monitoring. By Junc 20, 2012, for nuclear powe Vrcctmm licensees, these aGcIto levels must include hocstile action that may advercely affect the nuclear poweF-ptaat-The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.

CR-3 requests an exemption to the requirement to use EALs for consideration of protective measures outside the site boundary because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary.

CR-3 will adopt the Permanently Defueled EALs detailed in NEI 99-01, Revision 6. CR-3 also requests an exemption from the requirement to include "hostile action".

In the EP Final Rule (December 2011), the NRC defined "hostile action" as, in part, an act directed toward a nuclear power plant or its personnel.

The NRC excluded NPRs from the definition of "hostile action." CR-3 should not be required to plan for an offsite impact resulting from hostile action because: (1) the facility poses a lower radiological risk to the public than does a power reactor, and (2) the facility has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures.

CR-3 proposes to continue to review EALs with the State of Florida and local governmental authorities on an annual basis. However, based upon the reduced scope of EALs for the permanently defueled facility, the scope of the annual review of EALs is expected to be reduced (informal mailings, etc.).

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 14 of 33 38 B.2. A licensee desiring to change its entire emergency No exemption is requested.

action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Licensees shall follow the change process in § 50.54(q) for all other emergency action level changes.

39 C. Activation of Emergency Organization CR-3 requests an exemption from the requirement to C.1. The entire spectrum of emergency conditions that describe information from containment pressure sensors involve the alerting or activating of progressively larger and the Emergency Core Cooling System (ECCS) segments of the total emergency organization shall be System for notification of offsite agencies. Because it is described. The communication steps to be taken to alert or no longer possible for the radiological consequences of a activate emergency personnel under each class of design basis accident or a postulated beyond design emergency shall be described. Emergency action levels basis accident to result in radioactive releases which (based not only on onsite and-effsite-radiation monitoring exceed the EPA PAGs at the site boundary, the information but also on readings from a number of sensors Permanently Defueled EALs, detailed in NEI 99-01, that indicate a potential emergency,

-Uch as the pre.cure Revision 6, will be adopted. This scheme eliminates the i -cotainment and the r.e.p.ne of the E*mr*gencY Site Area Emergency and General Emergency event Cor-e. Co-,,,og Sy-tem) for notification of offsite agencies classifications. Additionally, the need to base EALs on shall be described. The existence, but not the details, of a containment pressure and the response of the ECCS is message authentication scheme shall be noted for such no longer appropriate for notification of offsite agencies.

agencies. The emergency classes defined shall include: (1)

Notification of unusual events, (2) alert, (3)-0te ar-ea emergeny, and (4) general emergency. These classes are further discussed in NUREG-0654/FEMA-REP-1.

40 C.2. By June 20, 2012, nu'clear poc' rea:ctor licensees CR-3 requests an exemption from the regulation requiring shall establish and maintain the capability to assess, it maintain the capability to assess, classify and declare classify, and declare an emergency condition W-thn ! A an emergency condition within 15 minutes after the miMUIs after the availability of indications to plant availability of indications to plant operators that an EAL operators that an emergency action level has been has been exceeded and promptly declare the emergency.

exceeded and shall promptly declare the emergency CR-3 will maintain the capability to assess, classify, and condition as soon as possible following identification of the declare an emergency condition.

In the permanently appropriate emergency classification level. Licensees shall defueled condition, the rapidly developing scenarios not construe these criteria as a grace period to attempt to associated with events initiated during reactor power restore plant conditions to avoid declaring an emergency operations are no longer credible.

The consequences action due to an emergency action level that has been resulting from the only remaining events (e.g., fuel exceeded. Licensees shall not construe these criteria as handling accident) develop over a significantly longer

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 15 of 33 preventing implementation of response actions deemed by the licensee to be necessary to protect public health and safety provided that any delay in declaration does not deny the State and local authorities the opportunity to implement measures necessary to protect the public health and safety.

period. As such, the 15 minute requirement to classify and declare an emergency is unnecessarily restrictive.

The 10 CFR 50.72(a)(3) requirement to complete an Emergency Notification System notification of the declaration of an Emergency Class within one hour after the time the licensee declares one of the Emergency Classes is not impacted by this exemption. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to identify an emergency within 15 minutes and to promptly provide information to the State and local response organizations is no longer necessary.

41 D. Notification Procedures D.1. Administrative and physical means for notifying local, State, and Federal officials and agencies and-ag-eeme-.s marchcd with these offiials and agenGiew for.-th roempt notification of the public and for-public.

=

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L!.

I-

--. I I.L cn'lcultmnn or amen nroIccnule men*IMnen, enomln nn beco...me nece..a.., shall be described. This description shall include identification of the appropriate officiall-,

by title-and-agency, of the State and local government agencies within the EPZ&.

CR-3 requests an exemption from the regulation requiring emergency plans contain the means to provide early notification to local, State and Federal officials and agencies for the prompt notification of the public and for public evacuation or other protective measures. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to provide these messages to the public, the need to maintain the Alert and Notification System, and the need to implement protective action strategies are no longer necessary. CR-3 requests an exemption from the regulation requiring the description of State and local government officials within the EPZs. Because it is no longer possible for EPA PAGs to be exceeded at the site boundary, the description of EPZs is no longer necessary.

42 D.2. Provi.iong Shall he deca..ibed f'or year"y CR-3 requests an exemption from the regulation to As.amt..he.I n

• A

• k blaG.... withintheplum.........

provide information to the public on a periodic basis for

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 16 of 33 nathwav FPZ of basic emeraenmr planning infor~mation7 suc.h as the methods and times required for public notification and the protective actions planned if an accGident occGurs, general information as to the natureP w..3 and CHCCI3s OT rapipuon, ana a listing of IoCJIl 0arUJU-andrt stations that will be uscd for dlissemination ot infrmaiondurngan emnergency. Signs or other measuresq Shall also-be used-toe disseminate to an" trmansienRt population withi mn t h. plm epsure pathway EPZ appropriate information that would be heloful i an accidcnt occurs how they will be notified, what their initial actions should be during an emergency, and for the onsite emergency plan to contain established procedures for the coordinated dissemination of information to the public.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for the public to take protective actions and the need to educate the public on what their prompt actions would be in the event of a radiological emergency is no longer necessary.

43 D.3. A licensee shall have the capability to notify responsible State and local governmental agencies within 46 minutes after declaring an emergency. The license snal aemonsdrate latinn appropriate Goverinme*nt authorii*es. have the capability to make a public. alertin an~d ntfcto decision prom~ptly On being infor-med by the IcenRsee of an emergency condition. Prior to inkitiai operation greater Iman ecn 0i rtea Itner-mai power of the firs-t reac-toar at-a site, each nuclear power-repactor incensee shall demonstr-ate that administrative and physical Means have been established for-alerting and providing prompt instructions to the public wiFthin the plume exposure pathway EPZ. The design objective of the promnpt public alert anRd notificatio system shall be to-h-ave the capability to essentially coemplete the initial alerting and initiate notification ot the public within the plume exposure pathwayEP within about 15a minutes. The use of this alertingan notfific--ation c~apability will rnefo meit alerting and noti-fic-ation of the public. (within 15 minuites of the time that State and local officials are notified that a situation existS requiring urgent action) to the more likely events where there issutail time available for the anronrpiate governmental CR-3 requests an exemption from the regulation requiring the capability to notify responsible State and local governmental agencies within 15 minutes after declaring an emergency. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for the public to take protective actions in the event of a radiological emergency is not necessary. CR-3 proposes to complete emergency notification through the State Watch Office Tallahassee (SWOT) within 60 minutes after an emergency declaration or a change in classification. This timeframe is consistent with the 10 CFR 50.72 notification to the NRC and is appropriate because there is no need for State or local response organizations to implement any protective actions.

The SWOT will assume the responsibility to provide notification to Citrus County. An exemption to maintain a backup alerting and notification capability is being taken because this is an offsite emergency planning requirement.

Offsite emergency response capability is no longer appropriate as no design basis accident or postulated beyond design basis accident can result in radioactive releases which exceed

.o.

_______I autnoriiucs to mnane a juagment wetne Or nOt to I_______________________

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 17 of 33 di i iN m

d i

activate the pUbIIC aeien and notmc-ration system. fl alcrting and notification capability shall additionall inluead-ministrative and physical mc-anss for. a backup mcethod of public alerting and notification capable of being used in the event thc primar-y method of alerting and-notificatiMon is unavailable duFrig an emergency toe -alert or notify all Or portios of the plume exposure pathway EPZ population. The backup method Shall have-t-he capability to aleirt and notify the public within the plume exposure pathway EPZ, but does not EPA's protective action guides at the site boundary.

prmay prompt public aleirt and notfificaition system.

Whnthere is a dec-isionen to activate the alert and nnotific-ation System, the appropriate goverRnmental alpe-rt ainid Inotification system simultaneously Or in a; graduated Or staged manner-. The rpesponsibility for activating such a Dublic alert and-notification system w

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t sna~ii premalInl wliinr inlcl anllcroponare~~t**

governmp+lenl*tal*ll.-li author-Otes l+g+

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• tl 44 D.4. If FE.*.A has approved a nuclear power reactor site's ale-hrt and notification design report, including the backup alert-and-no-tification capability, as of Dec~embeir 23, 2011, then the backup alert and notification capability r-equiremnents in Section IVD3 must be implemented by December 24, 2012. If the aler anFd-no-tifica-tion design report does not inc-luide a backup alert-and-no-tification capability orF need revision to ensure adequate backup aleirtan notification capability, then a revisionG of the alert and nottifircation design report mi.ust be submitted to FEMRA for review by June 24, 2013, and the FEMA approved backu alert and,,notificationm',.

A (4

mens.,

must[*RA hes,,,,,,*u' CR-3 requests an exemption from the regulation requiring onsite and State and local offsite emergency plans contain the means to provide early notification and clear instruction to the populace within the Plume Exposure Pathway EPZ. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for the public to take protective actions in the event of a radiological emergency is not necessary.

Therefore, the need to provide these messages to the public, the need to maintain the Alert and Notification System and backup capability is no longer necessary.

implemented withn 36.5. days after FEMA approval Howeveir, the total time period to implement a FEMIA n~n,,,,,,,,,

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ex-ceed *Ju a,,m,.,n e 2 2, 2 0'146.

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U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 18 of 33 45 E. Emergency Facilities and Equipment No exemption is requested.

Adequate provisions shall be made and described for emergency facilities and equipment, including:

E.1. Equipment at the site for personnel monitoring; 46 E.2. Equipment for determining the magnitude of and for No exemption is requested.

continuously assessing the impact of the release of radioactive materials to the environment; 47 E.3. Facilities and supplies at the site for decontamination No exemption is requested.

of onsite individuals; 48 E.4. Facilities and medical supplies at the site for No exemption is requested.

appropriate emergency first aid treatment; 49 E.5. Arrangements for medical service providers qualified No exemption is requested.

to handle radiological emergencies onsite; 50 E.6. Arrangements for transportation of contaminated No exemption is requested.

injured individuals from the site to specifically identified treatment facilities outside the site boundary; 51 E.7. Arrangements for treatment of individuals injured in No exemption is requested.

support of licensed activities on the site at treatment facilities outside the site boundary; 52 E.8.a. (i) A licensee -nsitc t*ch*n*al support c,,tc, and CR-3 requests an exemption from the regulation that an

.m.r.gency op.. ati"ns facility from which effective requires arrangements are maintained to accommodate direction can be given and effective control can be State and local emergency response staff at the EOF.

exercised during an emergency Because it is no longer possible for EPA PAGs to be exceeded at the site boundary, the EOF will no longer exist and there will be no need for a response by offsite agencies or company employees to the EOF. CR-3 also requests an exemption from the requirement to maintain a Technical Support Center (TSC). An onsite facility will continue to be maintained, from which effective direction can be given and effective control may be exercised during an emergency. The CR-3 PDEP will continue to maintain arrangements for requesting assistance and using resources from appropriate offsite support

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 19 of 33 organizations.

53 E.8.a (ii) or. nuclear power reacto, licensees,,a CR-3 requests an exemption from the requirements for li.ensee.

'onsite operational suppor center; the onsite Operational Support Center (OSC).

In the permanently defueled condition, the rapidly developing scenarios associated with events initiated during reactor power operation are no longer credible.

As such, an onsite OSC is no longer needed.

An onsite facility will continue to be maintained, from which control room support, emergency mitigation, radiation monitoring, and effective control may be exercised during an emergency.

54 E.8.b. For a nu-c!ea power reactor lic.esee's CR-3 requests an exemption from the requirements for emer.gency operations facility reqUired by pa.agraph the EOF. Because it is no longer possible for EPA PAGs 8.a of this section, either a facility loc--ated betw-e:en 10 to be exceeded at the site boundary, offsite emergency mils, -and 26 mles of the nuclear poer r..acto..

r. site(s),

response plans are no longer necessary and there will be or-a pr.ima fa.il.ty loc.at-ed+ less. than 10 miles. from the no response by offsite agencies to an EOF and Joint nuclear power. react-or i(s) and a backup facility Information Center (JIC). An EOF and JIC will no longer lcoated between 10 miles and 26 moles of the nuclear be maintained. The CR-3 PDEP will continue to maintain power-reactor site(s). An emergency operatios facilit-Y arrangements for requesting assistance and using may se.. e mo.re. t-han -one nuclear power reactor site. A resources from offsite support organizations. The CR-3 licensee0,0^

de-si'ring to loca.te an e.mergency operation, EOF is between 10 and 25 miles from the nuclear power facility more than 25 mile.,s fro.m a-nuclear poWer reactor site, and therefore the requirements for locating reactor site shall request prior Commission apprl.

NRC responders closer to a nuclear power reactor site by submitting an applicatio-n far* an amendment to that is more than 25 miles from the emergency lic.nse. For an emergency operations facility loca.te operations facility are not applicable to CR-3.

more, than 26 mmia.e from a nuclear power reactor#s*it, proVIsIons must be made for. loc*I atling NRC and olsIte responderts closer to the nuclear power reactor site SO that NRC and offikte r;esponders can inte.ract face-to-faewit-h emergencay response personnel entering and leaVIng the nuclear powerF reactor site Provisionsa for locating NRC and offsite responders closer to a nuclear poear. re-actor site that is more than 26 miles from the emergency operations facility mustinld the ofelewin

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 20 of 33 55 E.8=b. (1) Space for members of an NRC site team and Refer to the 10 CFR Appendix E, IV. E.8.b., basis for Federal, State, and local r-esponders exemption description, which identifies the elimination of the EOF.

56 E.8.b. (2) Additional spa.. for conducting briefings Refer to the 10 CFR Appendix E, IV. E.8.b., basis for with emcrgencY response personnel; exemption description, which identifies the elimination of the EOF.

57 E.8.b.(3) Comm.*.un.icatio."n Wit-h othcr licensee and offt-ite Refer to the 10 CFR Appendix E, IV. E.8.b., basis for em;ergency response facilities; exemption description, which identifies the elimination of the EOF.

58 E.8.b.(4) Access to plant data and radiolog"ial Refer to the 10 CFR Appendix E, IV. E.8.b., basis for info.mation; and exemption description, which identifies the elimination of the EOF.

59 E.8.b.(6) Ac.cess to copying equipmc..t and offie*

Refer to the 10 CFR Appendix E, IV. E.8.b., basis for suppliest exemption description, which identifies the elimination of the EOF.

60 E.8.c. By June 20, 2012, for a nu.. aF. power reactor CR-3 requests an exemption from the requirements for icens.e's

.e..gcncY operationS facility required by the EOF. Because it is no longer possible for EPA PAGs paragr.aph O.a of this section, a facility having the to be exceeded at the site boundary, offsite emergency fol lowin capabilitie:

response plans are no longer necessary and there will be (14) The apability for-obtaiRiRg and displaying plan no response by offsite agencies to an EOF and JIC. An data and radiological info.mation for each reactGo at a EOF and JIC will no longer be maintained. The CR-3 nuclear power reactor site and forF each nuclear power PIDEP will continue to maintain arrangements for reactor site that the facility se.....

requesting assistance and using resources from offsite support organizations.

61 E.8.c (2) The capability to analyze plant technical CR-3 requests an exemption from the requirement to ainfo-mation and provide tech.Incal bri1.efingS On n

brief offsite response organizations on event conditions at condfiti*on and progno.Sis-to licensee and off"ite CR-3. Because it is no longer possible for EPA PAGs to resp.nse organizations for each reactor* at a nuclear be exceeded at the site boundary, offsite emergency power reacer 6ite and far. each nu.lear power reactor response plans are no longer necessary and there will be cite that the facility serves; and no response by offsite agencies to an EOF and JIC. An EOF and JIC will no longer be maintained. The CR-3 PDEP will continue to maintain arrangements for requesting assistance and using resources from offsite support organizations.

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 21 of 33 62 E.8.c (3) The capability to SUppO.t response to evvSnt CR-3 requests an exemption from the regulation since occurring simut--aneo,.U.s.ly at more than on nUcG this requirement does not apply to CR-3.

power reactor site if the emergency operations facility serves more than one site;, and 63 E.8.d. Fo. nu.lear power reMtOr licensees,- an CR-3 will maintain an alternative facility for augmentation alt-ern.ati.."e facili-ty (Or facilities) that would be of the ERO capable of: communicating with the control accessible en if the cite is under threat of or room and plant Security, performing notifications to the exper.cn,..g hostile action*

, to functio as a staging SWOT, enabling emergency repair and damage control area for augmentation of emergenRcY esponse staff teams to begin planning actions to mitigate the aRd collectively haVing the fGollWing hara-t..i.tics-consequences of an event, and supporting a rapid the capability forc

• mmunication with the emergencY response as soon as the site is deemed accessible, in operations facility, control room, and plant security; the event that the site is not accessible. CR-3 requests the capability to pe.form of..ite notificationS; and the an exemption from the requirement to maintain capability fr

.e..

nrg assessment activities, communications with the EOF.

The scope of an Mincluding damage controI team p'lannig and emergency response will be appropriate for the defueled pr.eparation, for use when onsito emergenc.y facilities plant status (not be the same as actions necessary for c.annt be safely accessed during hostile actio.-

The "hostile actions" at operating power plants).

In the EP requirements in this paragraph 8.d must be Final Rule (December 2011), the NRC defined "hostile i.mplemented no later than December 23, 2014, with the action" as, in part, an act directed toward a nuclear power e.ception of the capability for staging em.ergenc plant or its personnel. The NRC excluded NPRs from the response organization per.sonnell at the al.ternative definition of "hostile action." CR-3 should not be required facility (OF facilities) and the capability for to plan for an offsite impact resulting from hostile action communicatin

.with the em.ergency operations because: (1) the facility poses a lower radiological risk to fac.i.ity, control rOo,. an pat security,.'which must the public than does a power reactor, and (2) the facility be implemented no later than June 20, 2012.

has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures.

64 E.8.e. A licensee shall not be subject to the CR-3 requests an exemption from the requirements requirements of paragraph 8.b of this section for an established for an EOF. Because it is no longer possible existing emergencY operations facility apprved as of for EPA PAGs to be exceeded at the site boundary, the December 23, 2014; EOF will no longer exist and there will be no need for a response by offsite agencies to the EOF.

The CR-3 PDEP will continue to maintain arrangements for requesting assistance and using resources from offsite support organizations.

65 E.9. At least one onsite and one offsite communications CR-3 requests an exemption from the regulation requiring

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 22 of 33 system; each system shall have a backup power source.

All communication plans shall have arrangements for emergencies, including titles and alternates for those in charge at both ends of the communication links and the primary and backup means of communication. Where consistent with the function of the governmental agency, these arrangements will include:

E.9.a. Provision for communications with contiguous State/local governments within the plume exposure pathway-EPZ Such communications shall be tested monthly.

communications with contiguous State and local governments within the Plume Exposure Pathway EPZ.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to provide prompt notification to the local governments to implement protective actions is no longer necessary. CR-3 will maintain the capability to communicate with the SWOT.

SWOT will assume the responsibility to provide notification to Citrus' County.

CR-3 will maintain communications with the SWOT and the NRC. The onsite response facilities will be combined into a single facility.

66 E.9.b. Provision for communications with Federal No exemption is requested.

emergency response organizations. Such communications systems shall be tested annually.

67 E.9.c. PoV.ision for ommuni".tion among thc CR-3 requests an exemption from the requirement for nUclear po reactor control room, the onsite communications among the control room, the TSC, and technic*al SUPPOrt center, and the emergency the EOF; and communication with field assessment operations facility; and among the n clearfac'li'.

the teams for assessing and monitoring offsite radiological principal State and le-al emergency operationS conditions.

Because it is no longer possible for the centers, and the field assessment teams. Such radiological consequences of a design basis accident or com munIcations system..

s sh.all be tested annually.-

a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to provide prompt notification to the local governments to implement protective actions is no longer necessary. CR-3 will maintain the capability to communicate with the SWOT from the control room.

The SWOT will assume the responsibility to provide notification to Citrus County.

Since a need for monitoring and assessing no longer exists, CR-3 no longer intends to maintain the capability to deploy field teams for assessing and monitoring offsite radiological conditions. The CR-3 PDEP will continue to maintain communication between onsite assessment

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 23 of 33 teams and the onsite response facility.

68 E.9.d. Provisions for communications by the licensee with CR-3 requests an exemption from the requirement for NRC Headquarters and the appropriate NRC Regional communications between the NRC and the TSC and Office Operations Center from the,u.-clar pow-r ;eactor EOF. CR-3 will maintain communications with the NRC control room, the onsitc tcchnocal support ccntcr, and from the Control Room.

the.me.genc..

ep..atie-facility. Such communications shall be tested monthly.

69 F. Training No exemption is requested.

F.1. The program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiological emergency shall be described. This shall include a description of specialized initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel 70 F.1. i. Directors and/or coordinators of the plant emergency No exemption is requested.

organization; 71 F.1. ii. Personnel responsible for accident assessment, No exemption is requested.

including control room shift personnel; 72 F.1. iii Radiological monitoring teams; No exemption is requested.

73 F.1. iv. Fire control teams (fire brigades);

No exemption is requested.

74 F.1. v. Repair and damage control teams; No exemption is requested.

75 F.1. vi. First aid and rescue teams; No exemption is requested.

76 F.1. vii. Medical support personnel; No exemption is requested.

77 F.1. viii. Lc.en.ee's headquga.tero suppo.t pe.ro.e...l; CR-3 requests an exemption from the requirement to provide training to headquarters personnel because the

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 24 of 33 level of emergency response required by the CR-3 PDEP does not require response by headquarters personnel.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for headquarters response is no longer necessary.

78 F.1. ix. Security personnel.

No exemption is requested.

79 F.1 In addition, a radiological orientation training program CR-3 requests an exemption from the requirement to shall be made available to local services personnel; e.g.,

maintain a radiological orientation training program for local emergency services/Cviei-Defense, local law Civil Defense and local news media persons. Training enforcement personnel, l*ocal news media persons.

will be provided to prepare local services (firefighting, local law enforcement, and ambulance) personnel for their response to an event at the CR-3 site. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to educate the public on what their prompt actions would be in the event of a radiological emergency is no longer necessary.

80 F.2. The plan shall describe provisions for the conduct of CR-3 requests an exemption from the requirement to emergency preparedness exercises as follows:

conduct full participation biennial exercises.

CR-3 will Exercises shall test the adequacy of timing and content of continue to test the adequacy of timing and content of implementing procedures and methods, test emergency implementing procedures and methods, test emergency equipment and communications networks, test-the-publs equipment and communications networks, and ensure al..t and notification system, and ensure that emergency that ERO personnel are familiar with their duties, through organization personnel are familiar with their duties.

periodic exercise, drill and training activities. CR-3 also requests an exemption from the requirement to test the public notification network as part of emergency preparedness exercises. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to provide

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 25 of 33 emergency messages to the public and the need to maintain the Alert and Notification System are no longer necessary.

-I-81 F.2.a. A full pa*"t-ipation x..i-;e wflicf tests as mucn of the ienscc, Statc'

.n lo.

c mergcncay plans as i rcasonabll; achiewable Wit-hAout mandatory public piipFtion hall Ibe, riniductcd fo-I eac-h*l c-iffitP *t

%MiaAh a powerf re-ntactr 6qs loc-at-ed-.Nuclear power reactor lien~esees shall submit exercnise scenarios under § 50.4 Mf Inp an CM S

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CR-3 will continue to include the State of Florida, the Citrus County Sheriffs Office, and local support organizations in the periodic drills and exercises to assess its ability to perform responsibilities related to an emergency at CR-3 to the extent defined by the CR-3 PDEP and State emergency plans. Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for State and local response organizations to participate in drills and exercises is no longer necessary. CR-3 also requests an exemption from the requirement to submit the exercise scenario at least 60 days in advance since relief is being requested from the requirement to perform a full participation exercise.

+/-

82 F.2.a(i) For an operating license issued under this part, this exercise must be conducted within two years before the issuance of the first operating license for full power (one authorizing operation above 5 percent of rated power) of the first reactor and shall include participation by each State and local government within the plume exposure pathway EPZ and each state within the ingestion exposure pathway EPZ. If the full participation exercise is conducted more than 1 year prior to issuance of an operating licensee for full power, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before issuance of an operating license for full power. This exercise need not have State or local government participation.

No exemption is requested.

83

[F 2.a.(ii) For a combined license issued under part 52 of No exemption is requested.

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 26 of 33 this chapter, this exercise must be conducted within two years of the scheduled date for initial loading of fuel. If the first full participation exercise is conducted more than one year before the scheduled date for initial loading of fuel, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before the scheduled date for initial loading of fuel. This exercise need not have State or local government participation. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of the first full participation exercise, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of § 50.54(gg) apply.

84 F 2.a (iii) For a combined license issued under part 52 of this chapter, if the applicant currently has an operating reactor at the site, an exercise, either full or partial participation, shall be conducted for each subsequent reactor constructed on the site. This exercise may be incorporated in the exercise requirements of Sections IV.F.2.b. and c. in this appendix. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of this exercise for the new reactor, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of § 50.54(gg) apply.

No exemption is requested.

85 F 2.b. Each licensee at each site shall conduct a CR-3 requests an exemption from the requirement to subsequent exercise of its onsite emergency plan every 2 conduct full participation biennial exercises. Because it is years. Nuclear. po.er ra.t.r-li.ensees.hl submit no longer possible for the radiological consequences of a exec ise s-. na.i. S undc. § 60.41 at least 60 day's b,. for-e design basis accident or a postulated beyond design u.e in an...e..se required by this paragraph 2.b. The basis accident at CR-3 to result in radioactive releases exe.i.e may be included in thc full participation which exceed the EPA PAGs at the site boundary, the biennial e..r.ie re.q.ud by paragraph 2.r.. of thi" need for State and local response organizations to

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_._In addition, the licensee shall take actions participate in drills and exercises is no longer necessary.

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 27 of 33 necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including-at least one drill involving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilities. The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, event classification, notification of offsite authorities, assessment of the onsite and eff-ite impact of radiological releases, p-otect"v. action r-vco=mmendlation development, protecvvt--

-=ive action decis.ion imaking, plant system repair and mitigative action implementation. During these drills, activation of all of the licensee's emergency response facilities (Teehnical Support Ccntcr (TSC), Opcr-ationRS Support Centcr (OSC), and the E~mergency Operations Facility (EOFI) would not be necessary, licensees would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in all participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives.

CR-3 will continue to include the State of Florida, the Citrus County Sheriffs

Office, and local support organizations for firefighting, ambulance and medical services for events at the CR-3 site in the periodic drills and exercises to assess its ability to perform responsibilities related to an emergency at CR-3 to the extent defined by the CR-3 PDEP and State emergency plans.

CR-3 also requests an exemption from the requirement to submit the exercise scenario at least 60 days in advance since relief is being requested from the requirement to perform a full participation exercise. The public will no longer have any response actions in the event of an emergency at CR-3. The need to coordinate with State and local response organizations for the development of Protective Action Decisions is no longer necessary.

Activation of the EOF, TSC, and OSC is no longer necessary.

The onsite response facilities will be combined into a single facility.

+

86 F 2.c. Off.ite pla.n for each site shall be exerc.ised biennially with full particlpation by each offeite authority having a ro~le u-nder-t-he r-adiological r-esponse plan. WheFe the offaite authority has a role underF a radiologic.al response plan for more than one site,; i shall fully participate in one exercise every two years and shall, at least, pairtially particsipate in other. offaite plan exercises in this period. if two differenRt iceGPnseesP eac-h have lic-ensed-fac-ilitie located either. on the same site orF on adffacent, contigUOUS sites, and share mo-st CR-3 requests an exemption from the requirement to conduct full participation biennial exercises.

Periodic exercises and drills will be completed to demonstrate ERO proficiency and evaluate performance. Training will be provided to ERO personnel.

CR-3 will continue to include the State of Florida, the Citrus County Sheriffs Office, and local support organizations in the periodic drills and exercises to assess its ability to perform responsibilities related to an emergency at CR-3 to the extent defined by the CR-3 PDEP and State emergency plans.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to t

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U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 28 of 33 result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for State and local response organizations to fully participate in drills and exercises is no longer necessary.

CR-3 is not a co-located licensee, and therefore co-licensee provisions do not apply to CR-3.

87 F ""

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it.e CR-3 requests an exemption from the regulation since e....ger..-plai'-

this requirement does not apply to CR-3.

88 F 2.c.(2) Part""patc quad'.ennially "a Oft.it..e bhi-c.-ialn CR-3 requests an exemption from the regulation since full OF partial pa-'icipation exerci; this requirement does not apply to CR-3.

89 F 2-G.(3) Conduct em"rgeny preparedness.. activitiest CR-3 requests an exemption from the regulation since and "-er....

in-the years between its participatin*

this requirement does not apply to CR-3.

in the off-t full OF partia.l par-ltcipation exercise with offeite aulthoritmes, to-test- -and-maint-2aiinrfc among the affected Stat and l*oca authoritiesm and the licensee-. Coc-c-ated licensees shall also participate in emeFgency preparedness activities and interaction with.ffs.te autho-rities for the period betmeefp 90 F

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Conductp a.hostie ation exercise of" i"-"....

CR-3 requests an exemption from the regulation since emergencY plan in each.e....ise cycl*e; and this requirement does not apply to CR-3.

91 F 2.G.(6) Particiipate inan offaite biennial full Or partial CR-3 requests an exemption from the regulation since partic Iipation hostile -action exorciise in alternating this requirement does not apply to CR-3.

92 F 2.d. Each State with responsibility for nuc*lear power CR-3 requests an exemption to conduct the ingestion reacto. emergencY preparedness should fully pathway exercise and the State participation in this par-ticipate in the ingestion pathway portIon o exercise.

Because it is no longer possible for the exercises at le.a.st onGe eve.y exerise cyce. In States radiological consequences of a design basis accident or With mo.re. than o.ne nuclear power reactor plume a postulated beyond design basis accident at CR-3 to exposure pathway EPZ, the State should rotate this result in radioactive releases which exceed the EPA cpation from site t site. Each State PAGs at the site boundary, the need to conduct an responsibility forF nuclear power reactor emergency ingestion pathway exercise is no longer necessary. CR-3 preparedness should fully parti*ipate in a ho-stile also requests an exemption from the requirement to

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require "hostile action" drills and exercises.

In the EP

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 29 of 33 fully par.ticipate in one hostile action

.xercise by Final Rule (December 2011), the NRC defined "hostile De.ember. 31, 2054.

States with Moro than one nucle.arW action" as, in part, an act directed toward a nuclear power power reactor plume exposure pathway EPZ shod--.

plant or its personnel. The NRC excluded NPRs from the rotate this partc*ip-at.ion frm site to site.

definition of "hostile action." CR-3 should not be required to plan for an offsite impact resulting from hostile action because: (1) the facility poses a lower radiological risk to the public than does a power reactor, and (2) the facility has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures.

93 F 2.e. Licensees shall enable any State or local CR-3 requests an exemption from this regulation that government located within the plume exposure pathway requires participation of offsite response organizations EPZ to participate in the licensee's drills when requested by within the plume exposure pathway EPZ in drills. CR-3 such State or local government, will enable any State or local government to participate in drills when requested by State of Florida or local government.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need to provide information to State and local response organizations for the development of Protective Action Decisions and offsite emergency planning by State and local organizations is no longer necessary.

94 F 2.f. Remedial exercises will be required if the emergency CR-3 requests an exemption from the requirement for the plan is not satisfactorily tested during the biennial exercise, NRC to consult FEMA if the emergency plan is not such that NRC, n-consul-tati.

w.th F-.A, cannot satisfactorily tested during the biennial exercise.

(1) find reasonable assurance that adequate protective Remedial exercises will be conducted commensurate measures can and will be taken in the event of a with the reduced exercise scenario scope when radiological emergency or necessary.

Because it is no longer possible for the radiological consequences of a design basis accident or (2) determine that the Emergency Response Organization a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA (ERO) has maintained key skills specific to emergency response. The extent of State and local partic'ipa-tio i PAGs at the site boundary, the need for State and local r.emedial ex.eries mut be sufficient to show. that response organizations to participate in drills and appropriat correcti......e m-a.........

he bn tn exercises in the same manner as full participation ap'"

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exercise is no longer necessary.

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 30 of 33 regarding the clc-ment-s of the plan not proper-ly tested in the previous exercises.g 95 F 2.g. All exercises, drills, and training that provide No exemption is requested.

performance opportunities to develop, maintain, or demonstrate key skills must provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified in a critique of exercises, drills, or training must be corrected.

96 F 2.h. The participation of State and local governments in No exemption is requested.

an emergency exercise is not required to the extent that the applicant has identified those governments as refusing to participate further in emergency planning activities, pursuant to § 50.47(c)(1). In such cases, an exercise shall be held with the applicant or licensee and such governmental entities as elect to participate in the emergency planning process.

97 F 2.i. Licensees shall use drill and exercise scenarios that CR-3 requests an exemption from the requirement to provide reasonable assurance that anticipatory responses conduct full participation biennial exercises.

Periodic will not result from preconditioning of participants. Such drills and exercises will be completed to demonstrate s.enarios for nuclear po'er P... r-eactor licens.e

.mus ERO proficiency and evaluate performance. Because it include a wade spectrUM f radiological releases and is no longer possible for the radiological consequences of eventS, including hostile actin,.

a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases Exercise and drill scenarios as appropriate must which exceed the EPA PAGs at the site boundary, the emphasize coordination among onsite and offsite response need for State and local response organizations to organizations.

participate in drills and exercises is no longer necessary.

CR-3 will continue to include the State of Florida, the Citrus County Sheriffs

Office, and local support organizations in the periodic drills and exercises to assess its ability to perform responsibilities related to an emergency at CR-3 to the extent defined by the CR-3 PDEP and State emergency plans. CR-3 also requests an exemption from the requirement to include "hostile action" drills and exercises.

In the EP Final Rule (December 2011), the NRC defined

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 31 of 33 "hostile action" as, in part, an act directed toward a nuclear power plant or its personnel. The NRC excluded NPRs from the definition of "hostile action." CR-3 should not be required to plan for an offsite impact resulting from hostile action because: (1) the facility poses a lower radiological risk to the public than does a power reactor, and (2) the facility has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures.

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t-his-sec-tion by nuclear power reactor licensecs must pOvde the oppoArtuiy for. thc ERO to demntrt profic~iency in the key skills necessar-toimlen the pFrinipal functional areas of em~ergency responsc idetiicdinparagraph 2b o f this%

section. Each e~xePrci~se must provide the opportunity for the ERG to demonstrate kcy skills specific to emergency responsc dutiwest in the-coant~roal roo-m, T-SC, OSC, EOF, and joint informatioRncenter. Additionally, in each eight calendar year exercise cycle, nuclear power reactor licensees shall var; the-conntePnt nof sceanarioes during exercASise condchted u nder paragrtaph 2 of this section to provide the oppoArtuity for the ERO to demonstrate proeficiency in the key skills necessary to respond to the following scenario elements:!

hostile actioen dir-ectAed -at the plant site, no radilogical__

relas oranunplanned mninimal radiological release that does not require puli proective actions, an initia clasiicaio ofR or r-apid escalation to a Site Area Emergency or. General Emegny implementation of strategies, pFroedures, and guidance developed un'der-

§ 50.51(hh)(2), and integration of offSite resouercs With onsite response. The licensee shall maintain a recr.Gd of exercises conducted duFrig each eight year exercise c.ycle that docau-ments-the content of scenarios used to CR-3 requests an exemption from the requirement to conduct full participation biennial exercises.

Periodic drills and exercises will be completed to demonstrate ERO proficiency in key skills necessary to implement the principal functional areas of emergency response as applicable for the permanently defueled plant status.

Critiques will follow each drill or exercise activity.

The CR-3 PDEP discusses exercise and drill types and frequencies of occurrence. Scenarios will be developed to test all major elements of the PDEP within an eight (8) year period.

These elements include management and coordination of emergency response, accident assessment, and system repair and corrective action.

CR-3 will continue to include the State of Florida, the Citrus County Sheriffs

Office, and local support organizations in the periodic drills and exercises to assess its ability to perform responsibilities related to an emergency at CR-3 to the extent defined by the CR-3 PDEP and State emergency plans.

Because it is no longer possible for the radiological consequences of a design basis accident or a postulated beyond design basis accident at CR-3 to result in radioactive releases which exceed the EPA PAGs at the site boundary, the need for State and local response organizations to participate in drills and exercises is no longer necessary.

CR-3 also requests an exemption to require "hostile action" drills and exercises.

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U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 32 of 33 icensec shall conduct a hostile action exer;cse for In the EP Final Rule (December 2011), the NRC defined each of its sites no. later. than De.ember 3-1, 2015. The "hostile action" as, in part, an act directed toward a fir-st eight year exercise cycl.e for- -a cite wi.ll begin in the nuclear power plant or its personnel. The NRC excluded c-alendar "car-in which the first hostile action exe.-rcse NPRs from the definition of "hostile action." CR-3 should iS conducted. For-a site licensed under Part 52, the first not be required to plan for an offsite impact resulting from eightyea* r e c

c.ycle begins in the calendlar ycarf*

hostile action because: (1) the facility poses a lower the inii-al..exercise required by Section F*2*a radiological risk to the public than does a power reactor, and (2) the facility has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures.

99 G. Maintaining Emergency Preparedness No exemption is requested.

Provisions to be employed to ensure that the emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.

100 H. Recovery No exemption is requested.

Criteria to be used to determine when, following an accident, reentry of the facility would be appropriate or when operation could be resumed shall be described.

101 I. Onsite Protective Actions During Hostile Action CR-3 requests an exemption from the requirement to By June 20, 2012, for-nuclea power r.eactor.,liensees, establish protective actions to protect onsite personnel a range of,pFrtective actions to protect onsit during hostile action to ensure reactor shut down. In the personnel during hostile ac.tion must be developed to EP Final Rule (December 2011), the NRC defined ensure the continued ability of the li.ensee to safely "hostile action" as, in part, an act directed toward a shud~own t*he. rc*- to and pe,-r-m the fun.tions of the nuclear power plant or its personnel. The NRC excluded li.ensee.s emergency plan-.

NPRs for an offsite impact resulting from hostile action because: (1) the facility poses a lower radiological risk to the public than does a power reactor, and (2) the facility has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures.

102 10CFR 50 App E No exemption is requested.

V. Implementing Procedures No less than 180 days before the scheduled issuance of an operating license for a nuclear power reactor

U. S. Nuclear Regulatory Commission 3F0814-07 Enclosure Page 33 of 33 or a license to possess nuclear material, or the scheduled date for initial loading of fuel for a combined license under part 52 of this chapter, the applicant's or licensee's detailed implementing procedures for its emergency plan shall be submitted to the Commission as specified in § 50.4.

Licensees who are authorized to operate a nuclear power facility shall submit any changes to the emergency plan or procedures to the Commission, as specified in § 50.4, within 30 days of such changes.

.4 103 10CFR 50 App E VI. Emergency Response Data System

1. The Emergency Response Data System (ERDS) is a direct near real-time electronic data link between the licensee's onsite computer system and the NRC Operations Center that provides for the automated transmission of a limited data set of selected parameters.

The ERDS supplements the existing voice transmission over the Emergency Notification System (ENS) by providing the NRC Operations Center with timely and accurate updates of a limited set of parameters from the licensee's installed onsite computer system in the event of an emergency. When selected plant data are not available on the licensee's onsite computer system, retrofitting of data points is not required. The licensee shall test the ERDS periodically to verify system availability and operability. The frequency of ERDS testing will be quarterly unless otherwise set by NRC based on demonstrated system performance.

2. Except for Big Rock Point and all nuclear power facilities that are shut down permanently or indefinitely, onsite hardware shall be provided at each unit by the licensee to interface with the NRC receiving system. Software, which will be made available by the NRC, will assemble the data to be transmitted and transmit data from each unit via an output port on the appropriate data system.

The regulation that identifies the requirement to maintain the Emergency Response Data System (ERDS) is not applicable to nuclear power facilities that are permanently shutdown.

Based upon the permanently defueled status of CR-3, this system is no longer necessary to transmit safety system parameter data. No exemption is requested since this change in ERDS data requirement is identified in 10 CFR 50 Appendix E, VI. 2.

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