ML19308A877

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Proposed Commission Paper Language for the Three Mile Island Nuclear Station Emergency Plan Decommissioning Exemption Request
ML19308A877
Person / Time
Issue date: 11/14/2019
From: Kathryn Brock
NRC/NSIR/DPR
To: Casey M
Federal Emergency Management Agency
Joseph Anderson
References
Download: ML19308A877 (3)


Text

November 14, 2019 Michael S. Casey, PhD, Director Technological Hazards Division Federal Emergency Management Agency, Area 8 400 C Street, South West Washington, DC 20024

SUBJECT:

PROPOSED COMMISSION PAPER LANGUAGE FOR THE THREE MILE ISLAND NUCLEAR STATION EMERGENCY PLAN DECOMMISSIONING EXEMPTION REQUEST

Dear Dr. Casey:

By letter dated July 1, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19182A104), Exelon Generation Company, LLC (Exelon) requested exemptions from certain emergency planning (EP) requirements of Part 50, "Domestic Licensing of Production and Utilization Facilities," to Title 10, "Energy," of the Code of Federal Regulations (10 CFR). Exelons proposed exemptions would reduce the EP requirements placed by the NRC on the licensee following the permanent cessation of operations and permanent removal of spent fuel from the reactor vessel to the spent fuel pool (SFP) at the Three Mile Island Nuclear Station (TMI) site. The proposed exemptions, if approved, would eliminate the requirement for the licensee to maintain formal offsite radiological emergency preparedness plans, but would still require the licensee to maintain certain onsite capabilities to communicate and coordinate with offsite response authorities.

The exemptions would not be effective until heat generation of spent fuel in the SFP is reduced to a point that formal offsite radiological emergency preparedness plans are no longer needed.

This letter documents the transmittal to you earlier by electronic mail a copy of the initial draft Commission (SECY) paper, entitled "Request By Exelon Generation Company, LLC for Exemptions from Certain Emergency Planning Requirements for the Three Mile Island Nuclear Station," for FEMA's review and comment. The SECY paper provides the NRC staff's evaluation of Exelons request for exemption from certain EP requirements in 10 CFR 50.47 and Appendix E to 10 CFR Part 50, and the NRC staff's proposed recommendation to the Commission. Please note that the NRC has not completed its internal concurrence review of the draft SECY paper, so the paper is subject to revision. As such, the Office of the Secretary of the Commission will not make the SECY paper publicly available in ADAMS until the paper is formally provided to the Commission.

The NRC performed its evaluation, as documented in the draft SECY paper, in accordance with NRC Interim Staff Guidance (ISG) document NSIR/DPR-ISG-02, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants," dated May 11, 2015

Dr. Casey 2

(ADAMS Accession No. ML14106A057), which is consistent with recent reviews for EP exemption requests from the Kewaunee Power Station (ADAMS Accession No. ML14072A257), Crystal River Unit 3 (ADAMS Accession No. ML14219A444), Vermont Yankee Nuclear Power Station (ADAMS Accession No. ML14227A711), San Onofre Nuclear Generating Station (ADAMS Accession No. ML14251A554), Fort Calhoun Station (ADAMS Accession No. ML17116A430), Oyster Creek Nuclear Generating Station (ADAMS Accession No. ML18030B340), and the Pilgrim Nuclear Power Station (ML18347A717). The NRC views the circumstances regarding the TMI decommissioning as substantially the same as for these plants.

In order to support the NRC staffs timeline for providing the SECY paper to the Commission, we request that FEMA provide us with any input no later than December 20, 2019. As has been the case for recent decommissioning plants, the NRC staff will revise the section to Enclosure 1, entitled Offsite Radiological Emergency Preparedness Considerations, as appropriate to include and address specific FEMA comments received on the draft TMI SECY paper.

Please do not hesitate to contact me to discuss this matter further. As always, my staff stands ready to support any discussions with FEMA staff on the TMI EP exemption request, as well as the criteria and process being used to evaluate this action.

Sincerely,

/RA/

Kathryn M. Brock, Director Division of Preparedness and Response Office of Nuclear Security and Incident Response cc: Alex Amparo, FEMA Assistant Administrator for National Preparedness Hampton H. Hart, FEMA Deputy Director Technological Hazards Division

Dr. Casey 3

SUBJECT:

PROPOSED COMMISSION PAPER LANGUAGE FOR THE THREE MILE ISLAND NUCLEAR EMERGENCY PLAN DECOMMISSIONING EXEMPTION REQUEST DATED:

November 14, 2019 DISTRIBUTION:

J. Danna, NRR J. Poole, NRR K. Brock, NSIR R.C. Johnson, NSIR J.D. Anderson, NSIR H. Benowitz, OGC M. Norris, NSIR R. Kinard, NSIR ADAMS Accession No: ML19308A877 OFFICE NSIR/DPR:BC OGC NSIR/DPR:D NAME J.D. Anderson H. Benowitz K. Brock DATE 10/30/19 11/07/19 11/14/19 OFFICIAL AGENCY RECORD