ML20034G981
| ML20034G981 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/09/1993 |
| From: | Cross J, Robinson W PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9303150010 | |
| Download: ML20034G981 (16) | |
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Portland General Electric Company r
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James E. Cross Vice President and Chief Nuclear Officer Afarch 9,1993 Trojan Nuclear Plant Docket 50-344 License NPF-1 I
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear Sirs:
Request for Exemptions from 10 CFR 50 Reauirements for Emercency Plannine Portland General Electric (PGE) is requesting exemption to certain sections ofTitle 10 of the -
Code of Federal Regulations, Part 50.47 " Emergency Plans", and 10 CFR 50, Appendix E, Paragraph IV, " Content ofEmergency Plans". These exemptions will allow PGE to allocate available resources more appropriately in maintaining the Trojan Permanently Defueled l'
Emergency Plan and training the appropriate emergency response personnel on the defueled plan. The basis for the requested exemptions is submitted as an attachment to this letter. The Trojan Permanently Defueled Emergency Plan is being submitted to the Nuclear Regulatory j
Commission Staff, concurrent with this exemption request, under separate cover letter.
Upon NRC approval of the Trojan Permanently Defueled Emergency Plan and associated
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exemptions from 10 CFR 50.47(b) and Appendix E, the Trojan Nuclear Quality Assurance Program will be correspondingly amended in accordance with the provisions of 10 CFR 50.54(a)(3). These changes will be processed as non-reductions in commitments, as NRC approval for these changes will have been received via NRC approval of the Trojan -
Permanently Defueled Emergency Plan.
Sincerely, L4 g
W..R. Robinson for J. E. Cross l
Attachment y7 i)t h
9303150010 930309 PDR
.ADOCK 05000344 121 SW Salmon Street, Portland, OR 97204 503/464-8897
4 Document Control Desk March 9,1993 i
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Mr. John B. Martit Regional Administratur, Region V U. S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon-q Department ofEnergy Mr. -Kenneth Johnston NRC Resident Inspector t
Trojan Nuclear Plant i
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License NPF-1 Attachment Page1 of14 Request for Exemptions from 10 CFR 50 Requirements for Emergency Planning -
Summan> of Exemption Reauest By letter dated January 27,1993, Portland General Electric (PGE) informed the Nuclear Regulatory Commission of PGE's decision to cease operations at the Trojan Nuclear Plant on a permanent basis. Further, by letter dated February 2,1993, PGE informed the Commission that the Trojan reactor had been permanently shutdown and defueled, with the nuclear fuel placed in the spent fuel pool. Additionally, by letter dated February 17, 1993, PGE cenified that fuel will not be moved back into the containment building at Trojan without prior NRC approval.
PGE has concluded that the degree of emergency planning and preparedness necessary to provide idequate protection of the public health and safety in a permanently shutdown and defueled condition is significantly less than that required for an operating facility.
Pursuant to Title 10 of the Code of Federal Regulations, Part 50.12, PGE is requesting exemption from certain sections of 10 CFR 50.47, " Emergency Plans", and 10 CFR 50, Appendix E, Paragraph IV, " Content of Emergency Plans" The requested exemptions address two areas: (1) the discontinuance of the need for offsite planning, and (2) the reduced onsite planning needs of the Trojan Permanently Defueled Emergency Plan.
These exemptions will be referred to as "offsite" and "onsite" exemptions, respectively.
Description of Reauested Exemr,tions 10 CFR 50.47(b) states,' "The onsite anL.offsite emergency response plansfor nuclearpower reactors must meet thefollmeing standardsi" Exemptions from the requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E_ are requested as described in the attached Tables 1 and 2. (Stricken text shown in Tables I and 2 is indicative of 10 CFR requir_ements from which PGE is requesting an exemption.)
The exemptions specified in Table 1, containing the requested offsite exemptions, are requested as a result of the elimination of those credible accidents that could result in -
significant offsite dose consequences.' PGE has calculated the offsite doses for fuel handling accidents, the limiting accidents for the current shutdown and defueled condition,-
and has determined that the resulting offsite doses at the exclusion area boundary are well below the Environmental Protection Agency's (EPA's) Protective Action Guides. The onsite exemptions are requested, in pan, on the basis that the Trojan Permanently Defueled Emergency Plan 6es indeed reflect the substantially reduced risk associated -
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Trojan Nuclear Plant.
Document Control Desk
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Docket 50-344 March 9,1993
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License NPF-1 Attachment
'l Page 2 of14 with the plant's permanently shutdown and defueled condition and provides for the f
organization and actions necessary to respond to an emergency.-
l Regulatory Bases for Reauested Esemptions j
The provisions of 10 CFR 50.12 allow specific exemptions from the requirements of 10
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CFR 50 provided the exemptions are authorized by law, are consistent with the common ;
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defense and security, are accompanied by special circumstances, and do not present an.
undue risk to the public health and safety. PGE concludes that the activities sought to be conducted under this exemption request are clearly authorized by law, are consistent with the common defense and security, and do not present r.n undue risk to the public health 1
and safety. PGE believes special circumstances exist with regard to offsite and onsite l
emergency planning requirements as described below.
10 CFR 50.12 (a)(2)(ii) states, " Application ofthe regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achiere the underlying purpose of the rule;... "
i The degree of emergency planning and preparedness necessary to provide adequate l
protection of the public health and safety in a permanently shutdown and defueled j
condition is significantly less than provided for in the existing Radiological Emergency l
Response Plan that was prepared to meet the requirements of 10 CFR 50.47. PGE has -
j conducted a hazards analysis in support of the Trojan Permanently Defueled Emergency :
l Plan and has concluded that there are no design basis or other credible events that would-result in doses beyond the exclusion area boundary that would exceed the Emironmental Protection Agency Protective Action Guides. Therefore, requiring PGE to comply with the full range of emergency preparedness requirements specified in 10 CFR-50.47(b) and 10 CFR 50, Appendix E, is not necessary to achieve the underlying purpose of the mle.
These regulations were established for power operation conditions, as such conditions could result in the potential for an accident with offsite radiological dose consequences.
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The permanently shutdown and defueled condition of the Trojan facility renders the -
1 possibility ofsuch accidents no longer credible. Therefore, the elimination of offsite j
emergency response capabilities, planning activities, and a reduction in the scope of onsite d
responses is warranted; j
j In view of the fact that power operations at Trojan have permanently ceased, and thus the
. potential risk associated with activities at Trojan have been significantly reduced,-
1 maintenance of offsite emergency response capabilities (e.g., facilities, public notification system), offsite planning activities and the current level ofonsite response would represent a misallocation oflimited human and monetary resources. Such resources would be better allocated to maintaining the Trojan Per nanently Defueled Emergency Plan and training j
the appropriate emergency response personnel on the defueled plan.
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Trojan Nuclear Plant Document Control Desk
' Docket 50-344 March 9,1993 License NPF-1 Attachment Page 3 of14 Conciusion On the basis of the information presented in this letter, and the concurrent submittal of the Trojan Permanently Defueled Emergency Plan, it is PGE's position that exemption from certain requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, as specified in l
attached Tables 1 and 2, isjustified.
Potential Environmental Impact f
Pursuant to the requirements of 10 CFR 50.12, PGE is requesting an exemption from certain requirements of 10 CFR 50.47, and 10 CFR 50, Appendix E, for the Trojan Nucicar Plant.
i The requested exemptions do not involve any measurable environmental impacts, as the -
plant configuration and operation are not changed. In addition, the likelihood of a radiological accident is not affected as a result of the requested exemptions.
The proposed change does not affect non-radiological plant effluents. Therefore, there are no significant non-radie',3ical environmental impacts associated with the requested exemptions.
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Trojan NuclearPlant Document Control Desk Docket 50-344 March 9,1993 License NPF-1 Attachment Page 4 of14 Table 1 Requested Offsite Exemptions Regulation Requirement Plan Basis for Exemption 10 CFR 50.47(b)(4)
" Stat: andlocakespanstplans As there are no design basis call-forweliance on ::zkrmation or other credible events provid:d byfacilitylicenutsfor that would result in doses determination; cfmimmum beyond the exclusion area initialofAire+esfymse boundary that would measures "
exceed the EPA PAGs, no offsite response measures
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are required.
"...the content ofinitialand As there are no design basis follouwp messages to response or other credible events organi:ations and th:publie has that would result in doses been established; wufmeans4e beyond the exclusion area prcvid: carlynotifi~ "~ ~'
boundasy that would clear-instmetic : tc th:;w+1mlaee exceed the EPA PAGs, no
=lthi,: th:;;!ume+xposure
'offsite notification of the pathwayE= rge:::y?!an,:ing general public is required.
Zone have b:en estab!!r.hed."
" Provisions existforprompt As there are no design basis communications amongprincipal or other credible events response organi:ations to that would result in doses emergencypersonnelaml4e4he beyond the exclusion area l
publie. "
boundary that would.
communications with the public will now be via news releases. No' capability for prompt communication to
.l the public is required.
Trojan Nuclear Plant Document Control Desk f
Docket 50-344 March 9,1993 License NPF-1 Attachment Page 5 of14 f
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Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption
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"Informatie:is =de cra!!ab!c As there are no design basis i
te-the-p;&!!c c:: aperiodidasis or ather credible events on hc= they ' 'ill-bemotifiedend that would result in doses whaHheir-initialaelions-shtmid beyond the exclusion area
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be-irsuamergemWeg-boundary that would j
listening 4eadocalbraukast exceed the EPA PAGs, the station +ndremaining.ndoors),
periodic mailings to theprincipalpoints ofcontact residents are no longer i
with the news mediafor necessary as they will have dissemination ofinformation no response actions.
during an emergency (inelmiing the-physical-locatieru>r locations) are establishedin i
admnce, andproceduresfor coordinateddissemination of l
information to thepublic are l
established. "
" Adequate methods, systems, and As there are no design basis equipmentfor assessing and or other credible events monitoring actualorpotential that would result in doses offWie consequences ofa beyond the exclusion area radiologicalemergency boundary that would l
condition are in use."
methods, systems and j
i equipment will be maintained for i
1 determination of offsite dose consequences.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License NPF-1 Attachment Page 6 of14 Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50.47(b)(10)
"A+ange-offvotectiveactions As there are no design basis h<we bee::developedfonthe or other credible events plume-exposurepathway EPZfor that would result in doses emerge::eyworkers1md4he beyond the exclusion area puidie-Guidelinesf<n=4he-choice boundaty that would ofynotective-oetimis1/uring4m exceed the EPA PAGs, the emergeneyrconsistent-with EPZs and associated Federal-guidance,-1ere41evekyvd protective actions are no and4nplace <md nntective longer required.
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actionsfor4he-ingestkm exposurejwthwyEPZ approte-iate te4hedocalehave beendeveloped. "
"..Jhe-nuclear-power-reactor As there are no design basis Appendix E, Section operating 4/ cense 4yyVieant-shall or other credible events IV alsoyvovidevm1malysis+f4he that would result in doses time-requiredto-emenate1uulfor beyond the exclusion area taking11ther-invieetive1retions boundary 1 hat would for-wrious-sectors 1mddistances exceed the EPA PAGs, within4heplume+xposure evacuation times and pathwyE14?-forgrensien/4nal protective actions within permanentyvym/atimes. "
the EPZ are no longer required.
" Authorities, responsibilities, and As there are no design basis j
Appendix E, duties ofan onsite emergency or other credible events l
i (IV)(A)(2)(c) coordinator who+hal/4e4n that would result in doses ehmge+/4he+relumge<>f beyond the exclusion area informatmnethofAire boundary that would aufhorities+esponsiblefor exceed the EPA PAGs, the coordinating 1mdimplementing coordination and o[fvite+mergenermeasures. "
implementation of offsite emergency measures are no longer required.
i Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License hTF-1 Attachment Page 7 of 14 Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50,
"/dentifcalic:. bypositionond As there are no design basis Appendix E, functiv : to beperformedsf or other credible events (IV)(A)(4) perens*ithin4heJieensee that would result in doses organizatic:: uho will be beyond the exclusion area respo:::lb!:prr-making +ffsite boundary that would dow-projections;-ando exceed the EPA PAGs, deser#>tionef4:cu these offsite dose projections are projections-will-be ::ade and4he no longer required.
results4ransmitted4o-State-and locala::thorities;-NRC-and+ther apjnywiate-governmenkd entities. "
10 CFR 50, "Identi#eati(m+f4he-Stateand As there are no design basis Appendix E, sir-local +fficials+esponsiblefer or other credible events (IV)(A)(8) planningfor orderingrand that would result in doses r
contr-ollingwppropriate beyond the exclusion area pr<nectiveseriens irreluding boundaty that would r
emenations-whernreeessary "
exceed the EPA PAGs, identification of State and local authorities responsible for protective actions is no longer required.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License hTF-1 Attachment Page 8 of14 Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50,
"...what type ofprotective As there are no design basis Appendix E, (IV)(B) measures shorddbe considered or other credible events within ami<miside the site that would result in doses boundary toprotect health and beyond the exclusion area safety. The emergency actions boundasy that would levels shallbe based on in-plant exceed the EPA PAGs, conditions andinstrumentation ofTsite protective measures in addition to onsite arul+ffsite and monitoring are no monitoring. 7hese emergency longer required. As no action levels shall be discussed significant afTsite dose andagreedon by the applicant consequences result from andState andlocal remaining credible accident governmentalauthorities and scenarios, review af EALs approved by the NRC. They by State and local officials shallaisM>newenedMth4he is no longer beneficial.
StatennJ40ealpe:::=::tal authoritiesanim1mnualhasis. "
" Emergency action levels (based As there are no design basis Appendix E, (IV)(C) not only on onsite and+ faire or other credible events j
radiation monitoring information that would result in doses i
but also on readingsfrom a beyond the exclusion area number ofsensors that indicate a boundany that would potential emergency, suchss4he exceed the EPA PAGs, pressure-iuontainmentend4he oITsite radiation monitoring responswf4hedhnergeneyEere shall not be conducted.
1 GudingEystem)for notification Containment pressure ofof/ site agencies shallbe sensors and Emergency i
described." "...(3Jsitenrea Core Cooling System are emergeneygmdMyneral no longer required in the emergeney. "
permanently shutdown and defueled condition. Site area and general emergency are no longer credible emergency classifications.
Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License NPF-1 Attachment Page 9 of14 Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50,
" Administrative andphysical As there are no design basis Appendix E, meansfor notifyinglocal, State, or other credible events (IV)(D)(1) andFederaloffcials and that would result in doses agencies andagreements beyond the exclusion arca reachedwith these officials and boundasy that would agenciesfor9heprompt exceed the EPA PAGs, the notificati<nu+f4hejmblicmmipw prompt notification of the fmblinvaenation+r+/her public shall no longer be fvnteetive4neaswe+;-dum/d4 hey required. Notification of bec<nneweecssmy, shallbe Federal, State, and local described. Ihis11escription-shall authorities should occur inelm/e-identifeationof4he within one hour. As the opfv opriate-efpeials;-by4itlennd EPZ is no longer applicable ageneyof/he-Stateandlocal to Trojan, the list of State governmentmgencies+ithirHhe and local government EFZs. "
agencies within the EPZ is no longer required.
10 CFR 50, "14evisionswha//4e-described As there are no design basii Appendix E, for-yearlydissemination4o4he or other credible events (IV)(D)(2) publie-within4heplume-crfvisure that would result in doses parkwayEPZ1+ hasinmergency beyond the exclusion area f
planning 4nformationanddhe boundary that would helpfulaf1mnecident+eents. "
exceed the EPA PAGs, no annual mailing will be conducted. Similarly, no signs or other measures for notification of transient populations shall be required.
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Trojan Nuclear Plant Document Control Desk J
Docket 50-344 March 9,1993 License NPF-1 Attachment Page 10 of14 Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50, "A licensee shallhave the As there are no design basis Appendix E, capability to notify responsible or other credible events (IV)(P)(3)
State andloca/ governmental that would result in doses agencies wnhin-14-mimnes after beyond the exclusion area declaring an emergency. The boundany that would licens&di-demonstmte4 hat exceed the EPA PAGs, the-StateJoeal-offei<ds4 ave 4he notifications to State and capability 4einake-apublie local agencies will take notipcatiwnleeision.=with4he place within one hour.
appropriate-governmental Similarly, no alest ornhorities. "
notification system shall be required.
10 CFR 50, "Provisionfor communications As offsite participation by Appendix E, with contiguous Statedocal State and local authorities (IV)(E)(9)(a) govenunents within4hepheme is no longer required exposure-pathwy-EPZ. Such (including the State of communications shall be tested Washington),
monthly. "
communications will only be conducted with the State and local agencies in the state ofOregon. Such equipment will be tested quarterly.
10 CFR 50, "Provisionfmwnnmunications The Trojan Permanently Appendix E, withfeder<d-emergeneyeesponse Defbeled Emergency Plan (IV)(E)(9)(b) aganizatirms--Such contains no Federal emnmunications-systems-shallhe emergency response other tested-annually. "
than the NRC.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License NPF-1 Attachment Page11 of14 Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50, "Inoddition -a+adio!agimi As there are no design basis r
Appendix E, (IV)(F) orientation 4rainingyvogram or other credible events sha!! bc made-availah!c to local that would result in doses service &persom:e!; e.g., local beyond the exclusion area emergeney-wrvices-Givil boundasy that would Defeme 4oca/Ja++nforcement exceed the EPA PAGs, the r
per*<nme/ 4oca/4;ews+nedia training oflocal services 7
persons. "
personnel is not required.
10 CFR 50, "The plan shalldescribe As there are no design basis Appendix E, (IV)(F) provisionsfor...tesHhe-publie or other credible events nonfication+ystem, and ensure that would result in doses that emergency organi:ation beyond the exclusion area personnelarefamiliar with their boundary that would duties. "
exceed the EPA PAGs, the public notification system
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will no longer be required.
10 CFR 50, "Afulfparticipation+rereise As there are no design basis Appendix E, whie/Hes/sasvnuchof4he or other credik events (IV)(F)(1) licensee -Statewndlocal that would result in doses r
emergeneyplans State orlocal beyond the exclusion area governmentparticipatwn. "
boundary that would exceed the EPA PAGs, the offsite full participation exercise will no longer be required.
10 CFR 50, "Eachlicenseewsweh-site-shall As there are no design basis Appendix E, exercise *ith+ffsitewu/horities or other credible events (IV)(F)(3) such4haHhe4'tatewm/-local that would result in doses j
government-emergencyplansfor beyond the exclusion area eachoperating-reactor-siteore boundary that would exereised-biennially-by-such exceed the EPA PAGs, Stateor4ocatgevernment. "
biennial offsite participation exercises will no longer be conducted.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License NPF-1 Attachment Page 12 of14 i
Table 1 Requested Offsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50,
" Remedial +rercit.:::.!!! he As there are no design basis Appendix E, requiredif:he e,=:rge::cypfwns or other credible events (IV)(F)(4)
- ct.arisfactorilyvested</uring that would result in doses j
tht4ienmal+rercise-wor beyond the exclusion area properly 4estedin4heprevious boundary that would exercises. "
exceed the EPA PAGs, biennial offsite panicipation exercises will no longer be conducted. Hence, remedial exercises for improperly conducted biennial exercises will similarly no longer be required.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 March 9,1993 License NPF-1 Attachment Page 13 of14 Table 2 Requested Onsite Exemptions Regulation Requirement Plan Basis for Exemption 10 CFR 50.47(b)(3)
"Arrangementsfor requesting As offsite emergency andeffectively using assistance respanse is no longer resources have been made, required, the Trojan arrange:rt:its4eneannmodate Emergency Operations State-an(Ilocal-efaHhe Facility shall no longer be license:'s :::ar-sitefunergency retained.
OperationsFacility have been made, andother organi:ations capable ofaugmenting the plannedresponse have been identified. "
"Responsibilitiesforplan PGE will not maintain a j
development and review andfor specific training program i
distribution ofemergencyplans for the individual are established, andplannersere responsible for the properly 4 rained. "
emergency plan, but will continue to ensure that the individual responsible for emergency planning is adequately trained.
10 CFR 50, "A*/eseriptimi;-byfesitimmnd The level of emergency Appendix E, femetion to be performed,-ef4he response required by the (IV)(A)(3) licensee'sJieadquarters Trojan Permanently j
personnelsh<nWil-be-senHethe Defueled Emergency Plan plan /Wievewugmensheonsite does not currently require emergeneyeganization. "
response to the plant by headquarters personnel.
10 CFR 50, "Identifcation,4ppositimmnd The Trojan Permanently Appendix E, funerion to beperformed,-of Defueled Emergency Plan (IV)(A)(5) other+mp/cyces of the-licensee does not specify individuals Wih+pecialvp#ahfeationsfor with "special qualifications" coping-with+mergenc9 for emergency response.
conditions =+pecial quahfcetionsef4hesepersons shallkieseribed. "
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Trojan Nuclear Plant Document Control Desk Docket 50-344 Msrch 9,1993 License NPF-1 Attachment Page 14 of14 Table 2 Requested Onsite Exemptions (Cont'd)
Regulation Requirement Plan Basis for Exemption 10 CFR 50, "A4ieensce a::-!!c teclinical The Trojan Permanently Appendix E, support +enterend*4/censee Defueled Emergency Plan (IV)(E)(8) near-site emerger:cy ofrrations does not require the use of faedityfrom nhich+ffeetive the EOF and TSC.
direction +an4e-givenwnd Effective direction and effectiw-conin#wm4ewereised control during an duringen+ merge ::y:
emergency shall emanate from the Trojan Control Room.
10 CFR 50, "Pmvisic::for commmileations Communication with the Appendix E, among4he4melear-powcr reaclor TSC, EOF, and State and (IV)(E)(9)(c) contmAnem,-the-onsite local emergency operations feelmic,d-suppor+eenter-and4he centers are no longer
- car-siteemergeney+perations required as these facilities facility;-andimumg4hemuclear shall no longer be faeilitydheprincipal-State-and maintained.
local-emergencforemtions Communications under the centers aml4hefieldsssessment requested plan are tested in r
teams-Suchennmunications accordance with 10 CFR systems-shallbe4estedannually."
50, Appendix E, (IV)(E)(9)(a).
10 CFR 50, "Provisionsfor communications As the requested Appendix E, by the licensee with NRC emergency plan does not (IV)(E)(9)(d)
Headquarters and the employ the EOF and TSC, appropriate NRCRegional such communication Office Operations Centerfro:n capability is no 1onger the nuclearpower reactor required. The requested controlroom, the-onsite emergency plan requires tecimieal-suppor+eenternmd4he quarterly testing of such near-site +mergencyopemtions communications.
facility. Such communications shall be tested monthiv."
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