ML19227A233

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Official Exhibit - NRC-011-MA-CM01 - Clinch River Nuclear Site Early Site Permit Application, Rev. 2 - Part 6, Departures and Exemption Requests (Jan. 18, 2019)
ML19227A233
Person / Time
Site: Clinch River
Issue date: 08/07/2019
From:
NRC/OGC
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
52-047-ESP, ASLBP 17-954-01-ESP-BD02, RAS 55139
Download: ML19227A233 (28)
v • d • e


Text

United States Nuclear Regulatory Commission Official Hearing Exhibit In the Matter of: TENNESSEE VALLEY AUTHORITY (Clinch River Nuclear Site Early Site Permit Application)

Commission Mandatory Hearing Docket #: 05200047 Exhibit #: NRC-011-MA-CM01 Identified: 8/14/2019 Admitted: 8/14/2019 Withdrawn:

Rejected: Stricken:

Other:

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of TENNESSEE VALLEY AUTHORITY Docket No. 52-047-ESP (Clinch River Nuclear Site Early Site Permit Application)

Hearing Exhibit Exhibit Number: NRC-011 Exhibit

Title:

Clinch River Nuclear Site Early Site Permit Application, Rev. 2 -

Part 6, Departures and Exemption Requests (Jan. 18, 2019).

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS ........................................................... iv 1.0 CLINCH RIVER NUCLEAR SITE EXEMPTION REQUESTS......................... 1 1.1

SUMMARY

DESCRIPTION ............................................................................ 1 1.2 DETAILED DESCRIPTION ............................................................................. 2 1.3 JUSTIFICATION ............................................................................................. 2 1.3.1 Exemptions Are Authorized By Law ............................................................ 3 1.3.2 Exemptions Will Not Present Undue Risk to Public Health And Safety ... 3 1.3.3 Exemptions Are Consistent with the Common Defense and Security ..... 4 1.3.4 Special Circumstances ................................................................................. 4

1.4 TECHNICAL EVALUATION

........................................................................... 6 1.4.1 Accident Analysis Overview......................................................................... 6 1.4.2 Consequences of Design Basis Events ...................................................... 6 1.4.3 Consequences of Beyond Design Basis Events ........................................ 6

1.5 CONCLUSION

................................................................................................ 6 2.0 CLINCH RIVER NUCLEAR SITE DEPARTURES ........................................ 22

3.0 REFERENCES

.............................................................................................. 23 ii Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures LIST OF TABLES Table 1-1 Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the Site Boundary EPZ Emergency Plan Table 1-2 Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Table 1-3 Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the 2-Mile EPZ Emergency Plan iii Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures ACRONYMS AND ABBREVIATIONS CEMP Comprehensive Emergency Management Plan CFR Code of Federal Register COLA Combined License Application CRN Clinch River Nuclear DBE Design Basis Event DCD Design Control Document EAL Emergency Action Level EPA Environmental Protection Agency EPZ Emergency Planning Zone ESPA Early Site Permit Application FEMA Federal Emergency Management Agency LWR Light Water Reactor NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission PAG Protective Action Guides PEP Plume Exposure Pathway PPE Plant Parameter Envelope SMR Small Modular Reactor SRM Staff Requirements Memorandum SSAR Site Safety Analysis Report TVA Tennessee Valley Authority iv Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures 1.0 CLINCH RIVER NUCLEAR SITE EXEMPTION REQUESTS 1.1

SUMMARY

DESCRIPTION A review of regulatory requirements was undertaken as part of the Clinch River Nuclear (CRN)

Site Early Site Permit Application (ESPA) to identify potential exemptions from portions of 10 CFR 50.33(g), 50.47(b) and (c)(2), and 10 CFR Part 50, Appendix E, to the extent that these regulations apply to specific provisions of onsite and offsite emergency planning. The regulations, as written, do not take into account (1) the enhanced safety expected to be inherent in the design of Small Modular Reactors (SMRs) or (2) the application of the significant body of risk information available to inform the technical basis for the Plume Exposure Pathway (PEP)

Emergency Planning Zone (EPZ) size. Pursuant to 10 CFR 52.7, Specific Exemptions, which is governed by 10 CFR 50.12, Specific Exemptions, Tennessee Valley Authority (TVA) requests exemptions from the following for the CRN Site ESPA:

  • Certain standards in 10 CFR 50.47(b) regarding onsite and offsite emergency response plans for nuclear power reactors;

The requested exemptions allow for the development and implementation of emergency plans that are commensurate with the significantly reduced risk associated with SMR technology. The current 10 CFR Part 50 regulatory requirements for emergency planning provide an appropriate planning basis for the current operating plants. However, some of these requirements are not necessary to protect the health and safety of the public in the vicinity of an SMR facility due to the decreased potential consequences associated with such a facility. The requested exemptions would require the SMR design selected for the Combined License Application (COLA) to meet the established criteria at the selected EPZ boundary. The criteria are consistent with and based upon the U.S. Environmental Protection Agency (EPA) Protective Action Guides (PAG) 1 rem dose criteria for early phase protective actions in the unlikely event of a severe accident. The intermediate and late phase EPA PAGs are not relevant to sizing of the PEP EPZ, and further references to the EPA PAGs in this document and Site Safety Analysis (SSAR) Section 13.3 are to the early phase EPA PAG.

SECY-15-0077, Options for Emergency Preparedness for Small Modular Reactors and Other New Technologies (Reference 3-1), describes an option for SMR applicants to request exemptions from the current regulations when proposing the use of different emergency planning requirements or standards within the current NRC emergency planning regulatory framework. In this application, TVA is proposing a dose-based, consequence-oriented approach to establish an appropriate EPZ size consistent with PAG criteria. The requested exemptions, and justification for each, are based on and consistent with the Nuclear Energy Institute (NEI)

White Paper, Proposed Emergency Preparedness Regulations and Guidance for Small Modular Reactor Facilities (Reference 3-2).

1 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures 1.2 DETAILED DESCRIPTION Part 5 of the CRN Site ESPA includes two Emergency Plans (Part 5A and Part 5B) for review by the NRC. The two distinct Emergency Plans are based upon a PEP EPZ border that encompasses the areas in which the plume exposure doses could exceed the EPA PAG and where there is a substantial reduction in risk of significant early health effects. Part 5A addresses a PEP EPZ established at the Site Boundary and Part 5B addresses a PEP EPZ approximately two miles from the site center point.

Based on the Site Safety Analysis Report (SSAR) Section 13.3 criteria applied to the selected SMR technology, two sets of exemptions have been developed for the CRN Site ESPA to address the Emergency Plans included in Part 5:

  • Exemptions for an approximate 2-mile PEP EPZ (hereafter referred to as the 2-mile EPZ).
  • Exemptions for a PEP EPZ established at the Site Boundary (hereafter referred to as the Site Boundary EPZ).

The two distinct Emergency Plans and the two sets of exemptions are based on the distance at which the selected SMR reactor technology is able to demonstrate that it meets the criteria set forth in Site Safety Analysis Report (SSAR) Section 13.3. The applicability of any exemption would be based on the SMR design selected for the COLA falling within the parameters set forth in SSAR Section 13.3. The specific portions of 10 CFR 50.33(g), 50.47, and 10 CFR Part 50, Appendix E from which TVA is requesting exemptions for each of the Emergency Plans are identified using strikethrough text in Table 1-1, Exemptions Requested from 10 CFR 50.33(g),

50.47(b), and (c)(2) for the Site Boundary EPZ Emergency Plan, Table 1-2, Exemptions Requested from 10 CFR Part 50, Appendix E, and Table 1-3, Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the 2-Mile EPZ Emergency Plan. No exemption is sought with respect to the portions of these regulations that are not identified using strikethrough text.

As appropriate, each Emergency Plan included in Part 5 of the ESPA considers the requested exemptions presented in Tables 1-1, 1-2 and 1-3. Specifically, the Emergency Plan in Part 5A considers the requested exemptions in Tables 1-1 and 1-2, and the Emergency Plan in Part 5B considers the requested exemptions in Table 1-3. The selected EPZ size will be determined based upon the SMR design selected in the preparation of the COLA. The criteria for determining the appropriate EPZ size, the appropriate regulatory exemptions, and the Emergency Plan that TVA intends to incorporate into a future COLA, are addressed in SSAR Section 13.3.

1.3 JUSTIFICATION The Commission, in SRM-SECY-15-0077, recognized that current emergency planning regulations are not necessarily appropriate for SMR designs and that [f]or any small modular reactor reviews conducted prior to the establishment of a [new] rule, the staff should be prepared to adapt an approach to emergency planning zones for SMRs under existing exemption processes, in parallel with its rulemaking efforts. In order to establish an emergency planning program commensurate with the hazards associated with SMR technology, exemptions from portions of 10 CFR 50.33(g), 10 CFR 50.47(b), 50.47(c)(2), and 10 CFR 50, 2 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Appendix E, are needed to account for the reduced risks and reduced consequences expected to be associated with new SMR technology. The criteria established in SSAR Section 13.3 employs a consequence based approach consistent with EPA PAG to determine appropriate EPZ size for the commensurate risks associated with SMR technology. During preparation of a COLA, when TVA has selected a reactor design, the appropriate EPZ will be selected based on the SMR design that conforms to the criteria established in SSAR Section 13.3.

10 CFR 50.12 states that the Commission may grant exemptions from the regulatory requirements in 10 CFR Part 50 if the exemption is authorized by law, will not present an undue risk to public health and safety, and is consistent with the common defense and security. 10 CFR 50.12 also states that the Commission will not consider granting an exemption unless special circumstances are present. As discussed below, this exemption request satisfies the provisions of 10 CFR 50.12.

1.3.1 Exemptions Are Authorized By Law Under 10 CFR 52.7, which is governed by 10 CFR 50.12, the NRC is authorized to grant exemptions that do not violate the Atomic Energy Act of 1954, as amended, or the Commission's regulations. Granting these exemptions would not violate the Atomic Energy Act or any other statute or regulation and is therefore authorized by law.

1.3.2 Exemptions Will Not Present Undue Risk to Public Health And Safety SSAR Section 13.3 sets forth criteria that the SMR design will be required to meet in order for an exemption to apply. SSAR Section 13.3 demonstrates that due to the calculated consequences of radiological events for the surrogate plant presented in this ESPA:

  • For the Site Boundary EPZ, formal offsite emergency response plans will not be needed for protection of the public beyond the Site Boundary because no credible event will result in offsite consequences in excess of EPA PAG. Offsite response organizations are capable of implementing protective actions in accordance with each agencys Comprehensive Emergency Management Plan (CEMP), commensurate with the hazard posed by the SMR designs under consideration.

For the 2-mile EPZ, offsite emergency plans will be developed consistent with the guidance presented in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654/FEMA-REP-1) considering any approved regulatory exemptions. Formal offsite emergency response plans will not be needed for protection of the public beyond two miles because no credible event will result in offsite consequences in excess of EPA PAG beyond the EPZ. The criteria have been established using a dose-based, consequence-oriented approach in accordance with the EPA PAG. Use of the criteria in the ESPA demonstrates that public health and safety are protected. The use of EPA PAG as performance criteria requires that the SMR design selected demonstrate that the hazards associated with the SMR design are not greater than those present in standard industrial activities. For the Site Boundary EPZ, this level of hazard does not require advance offsite emergency planning to protect public health and safety because any consequences are limited to the site. If the SMR design selected does not meet those criteria at the Site Boundary, the Site Boundary EPZ will not be used. Alternatively, if the selected SMR design meets the established criteria within two miles then TVA could elect to establish the EPZ 3 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures at an approximate 2-mile radius. Consideration will be given to local emergency response needs and capabilities, including considerations of demography, topography, land characteristics, access routes, and jurisdictional boundaries.

If the dose consequences can not be met at a 2-mile radius, then neither set of exemptions would be applicable. Accordingly, for either EPZ size, the scope of the onsite emergency management organization and corresponding requirements in the Emergency Plans included in Part 5 do not present an undue risk to the public health and safety. The technical basis for demonstrating that the SMR design meets the criteria in SSAR Section 13.3 will be in the COLA.

The proposed criteria for determining the appropriate EPZ size, and thus the appropriate regulatory exemptions and the Emergency Plan, take into account the enhanced safety features of the SMR designs under consideration. The proposed technical criteria for determining the EPZ size consider the utilization of the existing emergency preparedness regulatory framework and dose saving criteria established in NUREG-0396. Therefore, the underlying purpose of the regulations (protecting public health and safety) will continue to be met and as a result, the exemptions will not present an undue risk to the public health and safety.

The requested exemptions otherwise do not result in any other change. Because the requested exemptions will not alter the operation of any plant equipment or systems, they do not present an undue risk. The proposed exemptions do not introduce any new industrial, chemical, or radiological hazards that would represent a public health or safety risk, nor would they modify or remove design or operational controls or safeguards that are intended to mitigate any on-site hazards. Furthermore, the proposed exemptions would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in fuel cladding failures. Accordingly, these proposed exemptions do not present an undue risk from any equipment or systems.

The exemptions, if approved by the Commission, would not affect the authority that the Federal Emergency Management Agency (FEMA) has under its regulations in 44 CFR Chapter I for overall emergency management and assistance to State and local response organizations, nor would the exemptions affect the responsibilities of State and local governments to establish and maintain a CEMP.

1.3.3 Exemptions Are Consistent with the Common Defense and Security The scope of the emergency preparedness organization and associated Emergency Plan requirements will not adversely affect the ability of TVA to physically secure the CRN Site or protect special nuclear material. Physical security measures at the CRN Site are not affected by the requested exemptions. Therefore, the proposed exemptions are consistent with the common defense and security.

1.3.4 Special Circumstances 10 CFR 50.12(a)(2) lists six special circumstances for which an exemption may be granted.

Pursuant to the regulation, it is necessary for one of these special circumstances to be present in order for the NRC to consider granting an exemption request. The requested exemptions meet the special circumstances of 10 CFR 50.12(a)(2)(ii). That subsection identifies a special 4 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures circumstance as when, Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

The regulations under consideration in this request for exemption require that licensees develop, and maintain in effect, emergency plans that comply with specific standards. The underlying purpose of 10 CFR 50.33(g), 10 CFR 50.47(b) and (c)(2), and 10 CFR 50, Appendix E, is to establish PEP and ingestion pathway EPZs for nuclear power plants, to provide reasonable assurance that adequate protective measures will be taken in the event of a radiological emergency, and to ensure that licensees maintain effective offsite and onsite emergency plans.

Special circumstances exist at the CRN Site due to the anticipated enhanced safety features of the SMR designs under consideration. Specifically, the SMR designs are expected to have smaller radionuclide inventory and source terms; the projected rate of progression of postulated accidents is anticipated to be slower; various design features are expected to eliminate several historically considered design-basis events (DBEs); and the occurrence of severe accidents are projected to be significantly less likely. Additionally, each of the SMR designs under consideration for the CRN Site has advanced design features that minimize accident consequences. The criteria established in the ESPA require the SMR design to demonstrate in the COLA that any accident consequences are less than the EPA PAG criteria and meet specific risk reduction criteria (see SSAR Subsection 13.3.3.1.1) for the Emergency Plan and the size of the PEP EPZ in the ESPA to be used. If the SMR design selected does not meet those criteria, the smaller EPZ will not be used.

Therefore, special circumstances are present, because of the enhanced safety features inherent in the design of SMRs provide for significant additional confidence in the protection of public health and safety. Application of the current regulations as required by 10 CFR 50.33(g),

50.47(b) and (c)(2), and 10 CFR Part 50, Appendix E, in the particular circumstances discussed in this request, is not necessary to achieve the underlying purpose of the rules due to the significant enhancements in nuclear safety.

The appropriateness of the requested exemptions, including the size of the CRN Site EPZ, were established using risk-informed considerations and the understanding that the SMR designs evaluated under the CRN Site Plant Parameter Envelope (PPE) reflect enhanced safety features. The selected SMR design will conform to the criteria described in SSAR Section 13.3.

Therefore, the underlying purpose of the regulations will continue to be met. Because the underlying purpose of the rules will continue to be met, the exemptions will not present an undue risk to the public health and safety.

Each of the SMR designs under consideration for the CRN Site has advanced design features that minimize accident consequences. The criteria established in the ESPA require the SMR design to demonstrate that any accident consequences conform to EPA PAG criteria and meet specific risk reduction criteria for the use of one of the Part 5 emergency plans and the corresponding size of the EPZ. Based on the selection of a SMR design that satisfies the criteria presented in SSAR Section 13.3, TVA has concluded that the portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, requested for exemption as identified in the Tables 1-1, 1-2, and 1-3, will not be necessary to protect the health and safety of the public, and 5 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures would be unduly burdensome. Approval of the exemptions, as requested, will not present an undue risk to the public or prevent appropriate response in the event of an emergency at the CRN Site.

1.4 TECHNICAL EVALUATION

1.4.1 Accident Analysis Overview SSAR Chapter 15, Accident Analysis, addresses the postulated DBEs associated with the SMR technologies under consideration for the CRN Site.

The criteria for determining the appropriate EPZ size, and thus the appropriate regulatory exemptions and the Emergency Plan that TVA intends to ultimately incorporate into a future COLA, are addressed in SSAR Section 13.3. The selected design will be required to demonstrate conformance with the criteria established in SSAR Section 13.3.

1.4.2 Consequences of Design Basis Events The criteria for a DBE are addressed in SSAR Section 13.3.

1.4.3 Consequences of Beyond Design Basis Events The criteria for a Beyond Design Basis Event are addressed in SSAR Section 13.3.

1.5 CONCLUSION

In the COLA, the selected SMR design will be required to demonstrate conformance with the criteria established in SSAR Section 13.3. TVA has concluded that if the selected SMR technology meets the criteria established in SSAR Section 13.3, then the protection of public health and safety will be ensured and the regulatory exemptions described herein are appropriate.

If the selected SMR design is unable to conform to the criteria established, appropriate revisions to the CRN Site Emergency Plan will be described in the COLA.

6 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-1 (Sheet 1 of 4)

Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the Site Boundary EPZ Emergency Plan Item Regulation in 10 CFR 50.33(g), 50.47(b) or 50.47 (c)(2) Basis for Exemption 1 10 CFR 50.33(g): If the application is for an operating license or combined license for a The criteria established in SSAR Section 13.3, nuclear power reactor, or if the application is for an early site permit and contains plans for provide for adequate protection of public health coping with emergencies under § 52.17(b)(2)(ii) of this chapter, the applicant shall submit and safety by providing an EPZ that encompass radiological emergency response plans of State and local governmental entities in the the areas in which the plume exposure doses United States that are wholly or partially within the plume exposure pathway emergency could exceed the EPA PAG, and for where there planning zone (EPZ), as well as the plans of State governments wholly or partially within is a substantial reduction in risk of significant the ingestion pathway EPZ. If the application is for an early site permit that, under 10 CFR early health effects. Because there are no offsite 52.17(b)(2)(i), proposes major features of the emergency plans describing the EPZs, then consequences from any credible event in excess the descriptions of the EPZs must meet the requirements of this paragraph. Generally, the of the criteria provided in SSAR Section 13.3, plume exposure pathway EPZ for nuclear power reactors shall consist of an area about 10 defined EPZs and formal offsite radiological miles (16 km) in radius and the ingestion pathway EPZ shall consist of an area about 50 emergency response plans are not necessary.

miles (80 km) in radius. The exact size and configuration of the EPZs surrounding a particular nuclear power reactor shall be determined in relation to the local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries. The size of the EPZs also may be determined on a case-by-case basis for gas-cooled reactors and for reactors with an authorized power level less than 250 MW thermal. The plans for the ingestion pathway shall focus on such actions as are appropriate to protect the food ingestion pathway.

7 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-1 (Sheet 2 of 4)

Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the Site Boundary EPZ Emergency Plan Item Regulation in 10 CFR 50.33(g), 50.47(b) or 50.47 (c)(2) Basis for Exemption 2 10 CFR 50.47(b): The onsite and, except as provided in paragraph (d) of this section, Because there are no offsite consequences from offsite emergency response plans for nuclear power reactors must meet the following any credible event in excess of the criteria standards: provided in SSAR Section 13.3, formal offsite radiological emergency response plans are not necessary.

3 10 CFR 50.47(b)(4): A standard emergency classification and action level scheme, the Because there are no offsite consequences from bases of which include facility system and effluent parameters, is in use by the nuclear any credible event in excess of the criteria facility licensee, and State and local response plans call for reliance on information provided in SSAR Section 13.3, formal offsite provided by facility licensees for determinations of minimum initial offsite response radiological emergency response plans are not measures.

necessary.

Although the likelihood of an accident or event resulting in offsite doses exceeding the EPA PAGs beyond the site boundary is extremely remote, TVAs Emergency Plan will describe the capabilities to determine if a radiological release is occurring and promptly communicate that information to Offsite Response Organizations (OROs) for their consideration. Each ORO is responsible for deciding what, if any, protective actions should be taken utilizing its Comprehensive Emergency Management Plan (CEMP).

Also refer to basis for 10 CFR 50.47(b).

Note: TVA will adopt an Emergency Action Level (EAL) scheme developed in accordance with industry standards.

8 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-1 (Sheet 3 of 4)

Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the Site Boundary EPZ Emergency Plan Item Regulation in 10 CFR 50.33(g), 50.47(b) or 50.47 (c)(2) Basis for Exemption 4 10 CFR 50.47(b)(5): Procedures have been established for notification, by the licensee, of Because there are no offsite consequences from State and local response organizations and for notification of emergency personnel by all any credible event in excess of the criteria organizations; the content of initial and followup messages to response organizations and provided in SSAR Section 13.3, defined EPZs the public has been established; and means to provide early notification and clear and formal offsite radiological emergency instruction to the populace within the plume exposure pathway Emergency Planning Zone response plans are not necessary. The PEP EPZ have been established. would be within the Site Boundary, so there is no populace within the plume exposure pathway that would require early notification or instructions.

Refer to basis for 10 CFR 50.47(b).

Notification and instructions to members of the public that may be onsite is addressed in 10 CFR 50.47(b)(10).

5 10 CFR 50.47(b)(6): Provisions exist for prompt communications among principal Because there are no offsite consequences from response organizations to emergency personnel and to the public. any credible event in excess of the criteria provided in SSAR Section 13.3, formal offsite radiological emergency response plans are not necessary. Therefore, there is no need to require prompt communications to the public beyond the Site Boundary. Refer to basis for Appendix E to 10 CFR 50, IV.D.3.

6 10 CFR 50.47(b)(9): Adequate methods, systems, and equipment for assessing and Because there are no offsite consequences from monitoring actual or potential offsite consequences of a radiological emergency condition any credible event in excess of the criteria are in use. provided in SSAR Section 13.3, formal offsite radiological emergency response plans are not necessary. Refer to basis for 10 CFR 50.47(b).

TVA will maintain the capability to assess the impact of radiological releases and communicate the results to the OROs.

9 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-1 (Sheet 4 of 4)

Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the Site Boundary EPZ Emergency Plan Item Regulation in 10 CFR 50.33(g), 50.47(b) or 50.47 (c)(2) Basis for Exemption 7 10 CFR 50.47(b)(10): A range of protective actions has been developed for the plume Because there are no offsite consequences from exposure pathway EPZ for emergency workers and the public. In developing this range of any credible event in excess of the criteria actions, consideration has been given to evacuation, sheltering, and, as a supplement to provided in SSAR Section 13.3, formal offsite these, the prophylactic use of potassium iodide (KI), as appropriate. Evacuation time radiological emergency response plans are not estimates have been developed by applicants and licensees. Licensees shall update the necessary. Therefore, the language regarding the evacuation time estimates on a periodic basis. Guidelines for the choice of protective range of actions to be considered with respect to actions during an emergency, consistent with Federal guidance, are developed and in the public beyond the Site Boundary is not place, and protective actions for the ingestion exposure pathway EPZ appropriate to the applicable. Refer to basis for 10 CFR 50.47(b).

locale have been developed.

8 10 CFR 50.47(c)(2): Generally, the plume exposure pathway EPZ for nuclear power The criteria established in SSAR Section 13.3, plants shall consist of an area about 10 miles (16 km) in radius and the ingestion pathway provide for adequate protection of public health EPZ shall consist of an area about 50 miles (80 km) in radius. The exact size and and safety by providing an EPZ that encompass configuration of the EPZs surrounding a particular nuclear power reactor shall be the areas in which the plume exposure doses determined in relation to local emergency response needs and capabilities as they are could exceed the EPA PAG, and for where there affected by such conditions as demography, topography, land characteristics, access is a substantial reduction in risk of significant routes, and jurisdictional boundaries. The size of the EPZs also may be determined on a early health effects. Because there are no offsite case-by-case basis for gas cooled nuclear reactors and for reactors with an authorized consequences from any credible event in excess power level less than 250 MW thermal. The plans for the ingestion pathway shall focus on of the criteria provided in SSAR Section 13.3, such actions as are appropriate to protect the food ingestion pathway. formal offsite radiological emergency response plans are not necessary.

10 Revision 2

Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 1 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 1 10 CFR 50 App E. IV. Content of Emergency Plans See following analysis for each paragraph.

The applicant's emergency plans shall contain, but not necessarily be limited to, information needed to demonstrate compliance with the elements set forth below, i.e.,

organization for coping with radiological emergencies, assessment actions, activation of emergency organization, notification procedures, emergency facilities and equipment, training, maintaining emergency preparedness, and recovery, and onsite protective actions during hostile action. In addition, the emergency response plans submitted by an applicant for a nuclear power reactor 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.

2 IV. 2 This nuclear power reactor license applicant shall also provide an analysis of the Because there are no offsite consequences from time required to evacuate various sectors and distances within the plume exposure any credible event in excess of the criteria pathway EPZ for transient and permanent populations, using the most recent U.S. Census provided in SSAR Section 13.3, formal offsite Bureau data as of the date the applicant submits its application to the NRC.

radiological emergency response plans are not necessary. Therefore, there is no need for evacuation time estimates.

Although the likelihood of an accident or event resulting in offsite doses exceeding the EPA PAGs beyond the Site Boundary is extremely remote, TVAs Emergency Plan will describe the capabilities to determine if a radiological release is occurring and promptly communicate that information to OROs for their consideration. Each ORO is responsible for deciding what, if any, protective actions should be taken utilizing its CEMP.

Also refer to basis for 10 CFR 50.47(b) in Table 1-1.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 2 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 3 IV. 3 Nuclear power reactor licensees shall use NRC approved evacuation time estimates Refer to basis for 10 CFR 50, Appendix E, (ETEs) and updates to the ETEs in the formulation of protective action recommendations Section IV.2.

and shall provide the ETEs and ETE updates to State and local governmental authorities for use in developing offsite protective action strategies.

4 IV. 4 Within 365 days of the later of the date of the availability of the most recent Refer to basis for 10 CFR 50, Appendix E, decennial census data from the U.S. Census Bureau or December 23, 2011, nuclear Section IV.2.

power reactor licensees shall develop an ETE analysis using this decennial data and submit it under § 50.4 to the NRC. These licensees shall submit this ETE analysis to the NRC at least 180 days before using it to form protective action recommendations and providing it to State and local governmental authorities for use in developing offsite protective action strategies.

5 IV 5 During the years between decennial censuses, nuclear power reactor licensees shall Refer to basis for 10 CFR 50, Appendix E, estimate EPZ permanent resident population changes once a year, but no later than 365 Section IV.2.

days from the date of the previous estimate, using the most recent U.S. Census Bureau annual resident population estimate and State/local government population data, if available. These licensees shall maintain these estimates so that they are available for NRC inspection during the period between decennial censuses and shall submit these estimates to the NRC with any updated ETE analysis.

6 IV 6 If at any time during the decennial period, the EPZ permanent resident population Refer to basis for 10 CFR 50, Appendix E, increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, Section IV.2.

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 nuclear power reactor licensee's currently NRC approved or updated 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 under § 50.4 no later than 365 days after the licensee's determination that 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 authorities for use in developing offsite protective action strategies.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 3 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 7 IV 7 After an applicant for a combined license under part 52 of this chapter receives its Refer to basis for 10 CFR 50, Appendix E, license, the licensee shall conduct at least one review of any changes in the population of Section IV.2 its EPZ at least 365 days prior to its scheduled fuel load. The licensee shall estimate EPZ 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.

8 D. Notification Procedures Refer to basis for 10 CFR 50, Appendix E, Section IV.2.

D.1. Administrative and physical means for notifying local, State, and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described. This description shall include identification of the appropriate officials, by title and agency, of the State and local government agencies within the EPZs.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 4 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 9 D.3. A licensee shall have the capability to notify responsible State and local Because there are no offsite consequences from governmental agencies within 15 minutes after declaring an emergency. The licensee any credible event in excess of the criteria shall demonstrate that the appropriate governmental authorities have the capability to provided in SSAR Section 13.3, formal offsite make a public alerting and notification decision promptly on being informed by the radiological emergency response plans are not licensee of an emergency condition. Prior to initial operation greater than 5 percent of necessary. Therefore, there would be no rated thermal power of the first reactor at a site, each nuclear power reactor licensee shall members of the public within the PEP EPZ to demonstrate that administrative and physical means have been established for alerting alert and inform, and no need for action by and providing prompt instructions to the public within the plume exposure pathway EPZ. governmental authorities beyond the Site The design objective of the prompt public alert and notification system shall be to have the Boundary.

capability to essentially complete the initial alerting and initiate notification of the public TVA will maintain the capability to assess, within the plume exposure pathway EPZ within about 15 minutes. The use of this alerting classify, and declare an emergency condition and and notification capability will range from immediate alerting and notification of the public notify offsite governmental organizations within (within 15 minutes of the time that State and local officials are notified that a situation times specified in the Emergency Plan. Offsite exists requiring urgent action) to the more likely events where there is substantial time governmental agencies will maintain the available for the appropriate governmental authorities to make a judgment whether or not capability to alert and notify the public utilizing a to activate the public alert and notification system. The alerting and notification capability CEMP.

shall additionally include administrative and physical means for a backup method of public alerting and notification capable of being used in the event the primary method of alerting The elimination of the regulatory required time to and notification is unavailable during an emergency to alert or notify all or portions of the alert and notify the public is acceptable because plume exposure pathway EPZ population. The backup method shall have the capability to there is no need for State or local response alert and notify the public within the plume exposure pathway EPZ, but does not need to organizations to implement immediate protective meet the 15-minute design objective for the primary prompt public alert and notification actions.

system. When there is a decision to activate the alert and notification system, the appropriate governmental authorities will determine whether to activate the entire alert The 10 CFR 50.72(a)(3) requirement to complete and notification system simultaneously or in a graduated or staged manner. The an Emergency Notification System notification of the declaration of an Emergency Class within one responsibility for activating such a public alert and notification system shall remain with the hour after the time TVA declares one of the appropriate governmental authorities.

Emergency Classes is not impacted by this exemption. Also, Refer to basis for 10 CFR 50, Appendix E, Section IV.2.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 5 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 10 D.4. If FEMA has approved a nuclear power reactor site's alert and notification design Refer to basis for 10 CFR Part 50, Appendix E, report, including the backup alert and notification capability, as of December 23, 2011, Section IV.D.3 regarding the alert and notification then the backup alert and notification capability requirements in Section IV.D.3 must be system requirements.

implemented by December 24, 2012. If the alert and notification design report does not include a backup alert and notification capability or needs revision to ensure adequate backup alert and notification capability, then a revision of the alert and notification design report must be submitted to FEMA for review by June 24, 2013, and the FEMA-approved backup alert and notification means must be implemented within 365 days after FEMA approval. However, the total time period to implement a FEMA-approved backup alert and notification means must not exceed June 22, 2015.

11 F.2. The plan shall describe provisions for the conduct of emergency preparedness Because there are no offsite consequences from exercises as follows: any credible event in excess of the criteria provided in SSAR Section 13.3, formal offsite Exercises shall test the adequacy of timing and content of implementing procedures and radiological emergency response plans are not methods, test emergency equipment and communications networks, test the public alert necessary. Therefore, a dedicated public alert and notification system, and ensure that emergency organization personnel are familiar and notification system would not be used and no with their duties.

testing is required.

Refer to basis for 10 CFR 50, Appendix E, Section IV.2.

12 F.2.a. An full participation exercise which tests as much of the licensee, State, and local Because there are no offsite consequences from emergency plans as is reasonably achievable without mandatory public participation shall any credible event in excess of the criteria be conducted for each site at which a power reactor is located. Nuclear power reactor provided in SSAR Section 13.3, formal offsite licensees shall submit exercise scenarios under § 50.4 at least 60 days before use in a full radiological emergency response plans are not participation exercise required by this paragraph 2.a. necessary. Therefore, a full participation exercise is not required.

TVA would continue to invite State and local support organizations to participate in the periodic drills and exercises conducted to assess each participating organizations ability to perform responsibilities related to an emergency at the facility. Refer to basis for 10 CFR 50, Appendix E, Section IV.2.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 6 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 13 F.2.a(i) For an operating license issued under this part, this exercise must be conducted TVA would be exempt from those portions of 10 within two years before the issuance of the first operating license for full power (one CFR Part 50, Appendix E,Section IV.F.2.a.(i)-(iii) authorizing operation above 5 percent of rated power) of the first reactor and shall include related to offsite participation in exercises participation by each State and local government within the plume exposure pathway EPZ because TVA would be exempt from the umbrella and each state within the ingestion exposure pathway EPZ. If the full participation provisions of 10 CFR Part 50, Appendix E, exercise is conducted more than 1 year prior to issuance of an operating licensee for full Section IV.F.2.a.

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.

14 F 2.a.(ii) For a combined license issued under part 52 of this chapter, this exercise must TVA would be exempt from those portions of 10 be conducted within two years of the scheduled date for initial loading of fuel. If the first CFR Part 50, Appendix E,Section IV.F.2.a.(i)-(iii) full participation exercise is conducted more than one year before the scheduled date for related to offsite participation in exercises initial loading of fuel, an exercise which tests the licensee's onsite emergency plans must because TVA would be exempt from the umbrella be conducted within one year before the scheduled date for initial loading of fuel. This provisions of 10 CFR Part 50, Appendix E, exercise need not have State or local government participation. If FEMA identifies one or Section IV.F.2.a.

more deficiencies in the state of offsite emergency preparedness as the result of the first full participation exercise, or i[I]f 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.

15 F 2.a (iii) For a combined license issued under part 52 of this chapter, if the applicant TVA would be exempt from those portions of 10 currently has an operating reactor at the site, an exercise, either full or partial CFR Part 50, Appendix E,Section IV.F.2.a.(i)-(iii) participation, shall be conducted for each subsequent reactor constructed on the site. This related to offsite participation in exercises exercise may be incorporated in the exercise requirements of Sections IV.F.2.b. and c. in because TVA would be exempt from the umbrella this appendix. If FEMA identifies one or more deficiencies in the state of offsite emergency provisions of 10 CFR Part 50, Appendix E, preparedness as the result of this exercise for the new reactor, or i[I]f the Commission Section IV.F.2.a.

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.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 7 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 16 F 2.b. Each licensee at each site shall conduct a subsequent exercise of its onsite TVA would be exempt from those portions of 10 emergency plan every 2 years. Nuclear power reactor licensees shall submit exercise CFR Part 50, Appendix E,Section IV.F.2.a.(i)-(iii) scenarios under § 50.4 at least 60 days before use in an exercise required by this related to offsite participation in exercises paragraph 2.b. The exercise may be included in the full participation biennial exercise because TVA would be exempt from the umbrella required by paragraph 2.c. of this section. In addition, the licensee shall take actions provisions of 10 CFR Part 50, Appendix E, necessary to ensure that adequate emergency response capabilities are maintained Section IV.F.2.a.

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 offsite impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation. During these drills, activation of all of the licensee's emergency response facilities (Technical Support Center (TSC), Operations Support Center (OSC), and the Emergency Operations Facility (EOF)) 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.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 8 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 17 F 2.c. Offsite plans for each site shall be exercised biennially with full participation by each Because there are no offsite consequences from offsite authority having a role under the radiological response plan. Where the offsite any credible event in excess of the criteria authority has a role under a radiological response plan for more than one site, it shall fully provided in SSAR Section 13.3, formal offsite participate in one exercise every two years and shall, at least, partially participate in other radiological emergency response plans are not offsite plan exercises in this period. If two different licensees each have licensed facilities necessary. Therefore, there is no need for OROs located either on the same site or on adjacent, contiguous sites, and share most of the to participate in biennial exercises.

elements defining co-located licensees, then each licensee shall:

Although the likelihood of an accident or event (1) Conduct an exercise biennially of its onsite emergency plan; resulting in offsite doses exceeding the EPA PAG beyond the Site Boundary is extremely remote, (2) Participate quadrennially in an offsite biennial full or partial participation exercise; TVAs Emergency Plan will describe the (3) Conduct emergency preparedness activities and interactions in the years between its capabilities to determine if a radiological release participation in the offsite full or partial participation exercise with offsite authorities, to test is occurring and promptly communicate that and maintain interface among the affected State and local authorities and the licensee. information to OROs for their consideration.

Co-located licensees shall also participate in emergency preparedness activities and OROs are responsible for deciding what, if any, interaction with offsite authorities for the period between exercises; protective actions should be taken utilizing its CEMP. Formal offsite radiological emergency (4) Conduct a hostile action exercise of its onsite emergency plan in each exercise cycle; response plans would not be required. Therefore, and a full participation exercise is not required. Also (5) Participate in an offsite biennial full or partial participation hostile action exercise in refer to basis for 10 CFR 50.47(b) and 10 CFR alternating exercise cycles. 50.47(b)(4) in Table 1-1 and 10 CFR Part 50, Appendix E, Section IV.F.2.a.

TVA would continue to invite State and local support organizations to participate in the periodic drills and exercises conducted to assess its ability to perform responsibilities related to an emergency at the facility.

Those portions of F.2.c relating to co-located facilities are not applicable to the CRN Site ESPA. However, if in the future, the CRN Site became a co-located facility, those portions of F.2.c applicable to the CRN Site are addressed elsewhere in F.2.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-2 (Sheet 9 of 9)

Exemptions Requested from 10 CFR 50, Appendix E for the Site Boundary EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 18 F 2.d. Each State with responsibility for nuclear power reactor emergency preparedness should fully participate in the ingestion pathway portion of exercises at least once every Because there are no offsite consequences from exercise cycle. In States with more than one nuclear power reactor plume exposure any credible event in excess of the criteria pathway EPZ, the State should rotate this participation from site to site. Each State with provided in SSAR 13.3, formal offsite radiological responsibility for nuclear power reactor emergency preparedness should fully participate emergency response plans are not necessary.

in a hostile action exercise at least once every cycle and should fully participate in one Therefore, there is no need for OROs to hostile action exercise by December 31, 2015. States with more than one nuclear power participate in hostile action exercises.

reactor plume exposure pathway EPZ should rotate this participation from site to site.

Although the likelihood of an accident or event resulting in offsite doses exceeding the EPA PAG beyond the Site Boundary is extremely remote, TVAs Emergency Plan will describe the capabilities to determine if a radiological release is occurring and promptly communicate that information to OROs for their consideration.

OROs are responsible for deciding what, if any, protective actions should be taken utilizing its CEMP. Formal offsite radiological emergency response plans would not be required. Therefore, offsite participation in a hostile action exercise is not required.

TVA would continue to invite State and local support organizations to participate in the periodic drills and exercises conducted to assess its ability to perform responsibilities related to an emergency at the facility.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-3 (Sheet 1 of 2)

Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the 2-Mile EPZ Emergency Plan Item Regulation in 10 CFR 50.33(g), 50.47(b) or 50.47 (c)(2) Basis for Exemption 1 10 CFR 50.33(g): If the application is for an operating license or combined license for a The criteria established in SSAR Section 13.3, nuclear power reactor, or if the application is for an early site permit and contains plans for provide for adequate protection of public health coping with emergencies under § 52.17(b)(2)(ii) of this chapter, the applicant shall submit and safety in accordance with the EPA PAG.

radiological emergency response plans of State and local governmental entities in the United States that are wholly or partially within the plume exposure pathway emergency planning zone (EPZ), as well as the plans of State governments wholly or partially within the ingestion pathway EPZ. If the application is for an early site permit that, under 10 CFR 52.17(b)(2)(i), proposes major features of the emergency plans describing the EPZs, then the descriptions of the EPZs must meet the requirements of this paragraph. Generally, the plume exposure pathway EPZ for nuclear power reactors shall consist of an area about 10 miles (16 km) in radius and the ingestion pathway EPZ shall consist of an area about 50 miles (80 km) in radius. The exact size and configuration of the EPZs surrounding a particular nuclear power reactor shall be determined in relation to the local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries. The size of the EPZs also may be determined on a case-by-case basis for gas-cooled reactors and for reactors with an authorized power level less than 250 MW thermal. The plans for the ingestion pathway shall focus on such actions as are appropriate to protect the food ingestion pathway.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures Table 1-3 (Sheet 2 of 2)

Exemptions Requested from 10 CFR 50.33(g), 50.47(b), and (c)(2) for the 2-Mile EPZ Emergency Plan Item Regulation in Appendix E to 10 CFR Part 50 Basis for Exemption 2 10 CFR 50.47(c)(2): Generally, the plume exposure pathway EPZ for nuclear power Refer to basis for 10 CFR 50.33(g).

plants shall consist of an area about 10 miles (16 km) in radius and the ingestion pathway EPZ shall consist of an area about 50 miles (80 km) in radius. The exact size and configuration of the EPZs surrounding a particular nuclear power reactor shall be determined in relation to local emergency response needs and capabilities as they are affected by such conditions as demography, topography, land characteristics, access routes, and jurisdictional boundaries. The size of the EPZs also 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 plans for the ingestion pathway shall focus on such actions as are appropriate to protect the food ingestion pathway.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures 2.0 CLINCH RIVER NUCLEAR SITE DEPARTURES A departure is a plant-specific deviation from design information in a standard design certification rule. Because TVA has not selected a reactor design, departures from the reference Design Control Document (DCD) have not been identified.

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Clinch River Nuclear Site Early Site Permit Application Part 6, Exemptions and Departures

3.0 REFERENCES

3-1 SECY-15-0077, Options for Emergency Preparedness for Small Modular Reactors and Other New Technologies, dated May 29, 2015.

3-2 Nuclear Energy Institute, White Paper, Proposed Emergency Preparedness Regulations and Guidance for Small Modular Reactor Facilities, July 2015.

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