ML20059L543

Requests Exemptions from Certain Requirements of 10CFR50.47(b) & 50,App E & Proposes New Emergency Plan That Specifically Applies to Long Term Defueled Condition

ML20059L543
Person / Time
Site:	Rancho Seco
Issue date:	09/20/1990
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Weiss S NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20059L544	List: ML20059L543
References
AGM-NUC-90-238, NUDOCS 9009270106
Download: ML20059L543 (11)

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SACAAMENTo MUN6CIPAL UTiurY Disin6CT D 6201 S Street, P.o. Box 15830, Sacramento CA 95P',b1830 (9161452 3211

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AN ELECTRIC SYSTEM SERVING THF htiART OF CALIFORNIA AGN/NUC 90-238 J

i September 20, 1990 l

i U. S. Nuclear Regulatory Commission

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Attn Document Control Desk Hashington, DC 20555 l

f Docket No. 50-312 Rancho Seco Nuclear Generating Station License No DPR-54 l ~

EXEMPTIONS FROM CERTAIN REQUIREMENTS OF 10 CFR 50.47(b) AND 10 CFR 50 APPENDIX E r

References:

1.

D. Keuter (SMUD) to J. Larkins (NRC) letter AGM/NUC 90-130, dated April 30, 1990, " Proposed Amendment No. 182 l

Revision 1" l-2.

D. Keuter (SMUD) to J. Larkins.(NRC) letter AGM/NUC 90-120, dated April 26, 1990, "Long Term Defueled Condition Emergency Plan' l

3.

J. Larkins'(NRC) to D. Keuter (SMUD) letter dated May 16, 1990, " Exemption Related to 10 CFR 55 - Requirements for Simulation Facility and Simulator Training (TAC NO. 7557.0)" -

4.

D. Keuter (SMUD) to J. Larkins (NRC) letter AGM/NUC 90-209, dated July 24, 1990, " Exemption from Performing an Annual Exercise of the Emergency Plan, Activation of Alert

j and Notification System, and Distribution of Public Information Brochures" Attention

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Seymour Weiss The District hereby requests an exemption from certain parts of u

L 10 CFR 50.47(b) and 10 CFR 50, Appendix E, and. proposes a new Emergency Plan l-that specifically applies to the Rancho Seco long term defueled condition.

l' The new Plan has been reviewed by the State of California and Sacramento, San Joaquin, and Amador Counties and their comments have been incorporated.

The new Plan' represents a change in focus from prior versions and is a~ complete rewrite based on the reduced spectrum of applicable postulated accidents, the L

- reduced source terms,.and.the corresponding reduction in potential exposures I

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RANCHO SECO NUCLEAR GENERATING STATION O 14440 Twin Cities Road. Herald, CA 95638 9799;(209) 333 2935

l Seymour Weiss AGM/NUC 90-238

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Rancho Seco shut down in June 1989, as a result of public vote.

Radioactive

.I iodine has tscayed to a level such that thyroid exposure is no longer a significant concern. As indicated in NRC Information Notice 90-08, Krypton-85 is the princional isotope of concern for nuclear plants that have been shut i

down for greate than 180 days.

District calculations summarized in Reference i

1 have determined that offsite exposures from accidental releases would be i

well below the plume exposure Protective Action Guidelines.

The new Plan includes those provisions necessary for the protection of onsite J

personnel and for the protection of the public via communication with offsite agencies. Although 10 CFR 47(b).and 10 CFR 50 Appendix E do not address emergency planning requirements for long term defueled conditions, the new Plan considers all planning functions addressed in the regulations.

The Dist-ict has revised the scope of these functions to correspond with the nature and magnitude of potential hazards associated with the long term defueled condition.

The new Plan has deleted the following:

Emergency News Center, j

i Emergency Operations facility, j

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Emergency Response Organization (ERO) staffing for offsite support, l

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District coordination with Amador and San Joaquin Counties, and-j 1

District maintained systems for alerting members of the public.

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Also, the new Plan reduces the EPZ to the plant Industrial Area (currently the Protected Area).

Included in the Plan are onsite emergency response

-i facilities and an ERO with adequate proceoures and resources to manage the-emergency response for events applicable to the long term defueled condition.

Provisiens are in place to inform $3cramento County and the State of California of emergencies at Rancho Seco.

This change is being proposed in accordance with site pror<sures which govern the Plan.

Ranchd Seco has changed from an operating reactor facility to a permanently defueled facility with all fuel stored in the spent fuel pool. A 10 CFR 50.59 review of the new Plan determined that the changes do not involve an unreviewed safety question; however, they do represent a decrease in the scope of planning as provided by prior versions of the Plan.

A review of the new Plan, conducted in accordance with the requirements of 10 CFR 50.54(q),

determined the new Plan requires exemption from certain requirements of 10 CFR 50.47(b) pursuant to 10 CFR 50.12 " Specific Exemptions," and NRC approval prior to implementation of the new Plan.

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i Seymour Heiss AGM/NUC 90-238 j

Accordingly, the District hereby requests exeinptions from the following Emergency Planning requirements of 10 CFR 50.47(b),10 CFR 50 Appendix E, and i

NUREG 0654:

mobilization of offsite organizations to implement emergency preparedness plans, a reduction to the standard emergency classification and action e

level scheme.

maintenance of meteorological and seismic equipment,

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off-site emergency facilities, and a reduction in the Emergency Planning Zone.

Attachinent 1. " Requested Exemptions and Defueled Condition Compliance,"

provides the District's position for exemption or compliance with the various emergency planning requiren.ents in the defueled conditiou. Attachment 2 is a I

copy of the new Emergency Plan reformatted to the Rancho Seco manual style.

J The only changes from the previously submitted Emergency Plan Change 4 occurs in Section 5, page 3 of 9, subsection 5.4, and Section 7, page 4 of 6 subsections 7.6.3 and 7.6.4., " Basis for Exemption," presents the District's.,ases-for granting this exemption request.

In Emergency Plan Change 4 subsection 5.4, the term "offsite" is removed to indicate that the dose assessments shift personnel perform,may be onsite or offsite, whichever is necessary. Since offsite doses following an accident in the defueled condition will be very small, emphasis on offsite dose assessments is inappropriate.

In subsections 7.6.3 and 7.6.4, the requirement to obtain seismic and meteorological information from onsite instrumentation is changed to reference offsite sources for this information. This information would be obtained during an emergency response to a defueled condition accident or incident, if needed.

I Onsite seismic data was used to provide information for plant shutdown and cooldown following a Safe Shutdown Earthquake or Design Basis Earthquake.

Since the plant is already shut down and seismic data is available from State and Federal agencies, seismic instrumentation is not required to support the new Plan.

Onsite meteorological instrumentation is not needed in the defueled condition because an evaluation of the consequences of accidents considered credible in the defueled condition (Reference 1) resulted in the determination that the plume exposure Protective Action Guidelines will not be exceeded.

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Seymour Weiss.

4-AGM/NUC 90-238

' Alee, e District evaluation v;toblished a direct correlation between spent fuel. pool area radiation monitor readings and the dose consequences at the EPZ boundary (Industrial Area Boundary) following an accident in the spent fuel storage building.

This correlation is used in the defneled condition Emergency Plan to evaluate the con equences of ar accidental airborne release from the spent fuel storage building and preerr*s che need for meteorological data.

If meteorological information is desired dur'.ng a response to an accident, it may be obtained from the National Heather Set vice in Sacramento.

Members of your staff with questions requiring additional information or clarification may contact Jim Reese at (209) 333-2935, extension 4506.

Sincerely.

n Dan R. Keuter 1

Assistant General Manager Nuclear Attachment cc w/atch:

J. B. Martin, NRC, Walnut Creek C. Myers, NRC, Rancho Seco S. Reynolds, NRC, Rockville

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ATTACHMENT 1 n

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! i' Requested Exemptions and J

Defueled Condition Compliance i

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PART 50-DOMESTIC UCENSING AND UTb17ATION FACluTIES: SUBPART 47-EMERGENCY PLANS 50.47(b)

SECTION REQUESTED EXEMPTION (1)

Primary responsibilities for emergency Defueled Condition Compliance: The response by the nuclear facility licensec number of positions in the ERO has been and by State and local organ!zations reduced to conform with accidents within the Emergency Planning Zones applicable in the Long Term Defueled have been assigned, the emergency Condition (LTD C).

Specific responsibilitics of the various supporting responsibilities are assigned to each organ 17ations have been specifically position in the LTDC ERO.

established, and cach principal response organization has staff to respond and to augment its initial response on a continuous basis.

Related Reculatory Guidance NUREO 0654, llA, Assignment of Responsibility (Organtration Control) and 10 CFR $0 App. E, IV.A. Orgr.nization (2)

On. shift facility licensee responsibilities Defuelc<l Condition Compliance: Onshift for emergency response are personnel are designated to perform unambiguously defined, adequate staffing initial response to postulated emergencies.

to provide initial facility accident response The number of personnel assigned to in key functional areas is maintained at shifts has been reduced consistent with all times, timely augmentation of response the LTDC. Personnel filling headquarters capabilitics is available and the interfaus support functions are not defined since among various onsite response activitics the spectrum of accidents in the LTDC and offsite support ano cespcase activitics has been significantly reduced, Pertinent are specified.

agreements are appended in the Plan.

Appropriate interfaces and augmentation Related Reculatoly Guidance of capabilities is provided in the Plan.

NUREO 0654, llD, Onsite. Emergency Organization and 10 CFR 50 App. E, IV.A. Organization 1

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SECTION REQUESTED EXEMPTION I

(3)

Arrangements for requesting 'and Partial Exemption:The plan provides for cffectively using assistance resources have requesting assistance from outside been made, arrangements to accommodate organizations to augment the response to State and local staff at the licensce's near-an emergency at Rancho Seco.' Due to site E m t incy Operations Facility have the substantially reduced spectrum of beca made, and other organizations accidents in the ' LTDC, the offsite capable of augmenting the planned facilitics are no longer necessary and response have been identified.

participation of San Joaquin and Amador Countics are longer, necessary.

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Relate <1Reculatory Guidance participation of Sacramento county and State of California is ' reduced to

. NUREO 0654, llc, Emergency Response notification for purposes of information.

I Support and Resources and 10 CFR 50 Ar 1. E, IV.A, Organization l

I (4).

A standard emergency classiletion and Partial Exemption:The reduced spectrum action level scheme, the bases et which of accidents appilcable in the LTDC do include facility. system and effluent not meet the conditions required for Site j

parameters, is 'n. use by the nuclear Arca or Ocncral Emergency. As a result facility licenace, and State and local the Plan defines only the levels of response plans call for reliance on Notification of Unusual Event (NOUE) information provided by facility licensees and Alert, for determinations of minimum initial offsite rt,,ponse measures.

Related Reculatory Guidance NUREO

0654, ilD, Emergency Classification System and 10 CFR 50 App. E, IV.B, Assessment Actions, IV.C, Activation of Emergency Organization, Ii t

l-SECTION REQUESTED EXEMPTION (5)

Procedures have been estahished for Partial Exemption: The plan provides for notification, by the licensee of State and notification of Sacramento County and local response organiza'aons and for the State of California. Notification of notification of emergency personnel by all the public was addressed in a separate organizations; the content of initial and request dated July 24,

1990, followup messages to response (ref.AOM/NUC 90-209). Due to the organizations and the public has been reduced spectrum of accidents in the est. 1shed; and means to previde early LTDC and the associated potential not. ation and clear instruction to the radiological exposure, the distribution of populace within the plume exposure information to the public and news media pathway Emergency Planning Zone have as described in NUREO 0654,110, is not been established.

necessary.

The plan provid(s for notification of ERO personnel.

Related Reculatory Guidance NUREO 0654,llE, Notification Methods and Procedures,llo,Public Education and Information, and 10 CFR 50 App. E, IV.D, Notification Procedures,and FEMA REP.10.

(6)

Provisions exist for prompt Partial Exemption: The plan provides for communications among principal tesponse notification of Sacramento County and organizations to emergency personnel and the State of California for information to the public, only and for requesting assistance from outside organizations to augment the response to an emergency at Rancho Related Reculatory Guidance Seco. Due to the substantially reduced spectrum of credible accidents in the NUREO

0654, llF, Emergency LTDC, participation of San Joaquin and Communications, and 10 CFR 50 App.

Amador Counties is no longer necessary.

- E, IV.D. Notification Procedures 2

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L SECTION REQUESTED EXEMPTION (7)

Information is made available to the Total Exemption: An exemption request public on a periodic basis cn how they was submitted on July 24, 1990, will be notified and what their initial conceraing the distribution of public actions should be i sn cmergency (eg.

Information brochures (ref. AGM/NUC listening to a k>cali x! cast station.and 90 209). Duc to the reduced spectrum of remaining indoors), he principal points accidents in the LTDC and the associated of ' contact with. the news media for potential radiological exposure, the dissemination of information during an distribution of information to the public emergency (including the physical location and news media as described in NUREO or locations) are established in advance.

0654,110, is not necessary, and. procedures for coordinated dissemination ofinformation to the public arc established, j

Related Reculatorv Guidance:

NUREO 0654,110, Public Education and

-Information, and 10 CFR 50 App.E, IV.D, Notification Procedures j

E (8)

Adequate emergency facilitics and Partial Exemption: The plan provides for equipment to support emergency response onsite facilities and equipment adequate are provided and maintained.

te respond to cmcrgencies applicabl9 in the LTDC. Offsite facilitics are no longer necessary due to the reduced offslie

- Related Reculatory Guidance:

radiological consequences of accidents credible for the LTDC. The capability for NUREO 0654, llH, Emergency Facilities onsite and offsite medical services have and Equipment, and 10 CFR 50 App. E, been maintained.

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IV.E.

Emergency Facilities and l

Equipment Due to the reduced spectrum of accidents and the associated potential offsite radiological exposure applicable in the LTDC, not all equipment as described in NUREO 0654, IIH, is necessary.

In i

l-particular, meteorological and seismic equipment will not be maint_ained.

Meteorological data may be obtained.

from the National Weather Service and seismic information may be obtained from State and Federal agencies as necessary, 1.

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L SECTION REQUESTED EXEMPTION h

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(9)

Adequate

methods, systems and Partial Exenantion: Due to the reduced

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equipment for assessing and monitoring spectrum of accidents and the associated l

K actual or potential offue consequences of potential offsite radiological exposure a radiological emergency condition are in applicable in the LTDC, r? - Wt E

use, equipment zis described in NURE-

!!H, is necessary.-

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Egjged Reculatory Guidance:

meteorological and scismic equipment a

will not be maintained. Meteorologictd NUREO 0654, ll.H. Emergency Facilitics data may be obtained from the National.

i; and Equipment II.I, Accident Assessment,

. Weather Service and scismic information and 10 CFR 50 App E.,IV.B Assessment may be obtained from State and Federal l

Actions, and IV.E. Emergency Facilities agencies as necessary.

and Equipment Since Rancho Seco shutdown on June 7, 1989, the primary nuclide contributing to.

j thyroid dose, lodine 131 (1131), has decayed by more than 25 half lives and is therefore below limits where offsite or onsite thyroid dose would be significant.

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Thus no provisions for sampling will be included in the plan.

(10)

A range of protective actions have been Total Exemption: Based upon the reduced developed for the plume c.posure spectrum of acci<lents and associated pathway EPZ for emergency workers and potential radiological exposure applicable 3

the public. Ouldelines for the cholec of in the LTDC, the Plan defines the EPZ.

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'ive actions during an emergency, as the site boundary (ic,, perimeter fence consistent with Federal guidance, are or Industrial Area boundry). The 50 mile developed and in place, and protective -

ingestion pathway is not applicable in the actions for the ingestion exposure pathway LTDC, and no PA's are required beyond e

EP7 appropriate to the locale have been the site boundry. The Plan defines PA'S l

developed.

for onsite use only.

Related Reculatory Guidance:

NUREG 0654,11.J, Protective Response 1

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SECrlONS REQUESTED EXEMPTIONS a

(11) ' Means for controlling radiological No Exemption Recuested exposures, in. an emergency, are e

established for emergency workers. The --

speans. ' for-controlling radiological exposures-shall include - exposurc guidelines consistent with EPA En.crgency j

Worker and Lifesaving Activity Protective

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Action Ouldes.

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Related Regulatory Ouldano;

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Exposure Ccmtral

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(12)

. Arrangements - arc _ made for : medical No Exemption Recyested

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services _ for contaminated injured individuals. -

a Related Ret.latory Guidance:

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i NUREO 0654, II.L Medical and Public

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_ Health Support, and 10 CFR 50 App.E, r

IV.E.

Emergency. Facilitics and i

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(13). General plans for recovery and reentry No Exemption Reauested i

arc developed.

Related Reculatory Guidance:

NUREO 0654, - II.M,' _ Recovery and i

Reentry - Planning and Postaccident t*

Operations, and to CFR 50 App.E, l

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IV.H. Recovery i

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[b SECTION REQUESTED EXEMPTION m

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Periodic exercises arc (will be) amducted Dctueled Conditlon Compliance: An ll.,

' : to evaluate major portions of emergency exemption regarding the - 1990 An.tual h1

. resp (mse capabilitics, periodic drills arc Exercise was requested in letter (will be) ctmducted to develop and AOM/NUC 90 209 dated July 24, 1990, I

maintain key _ skills, and deficiencies.

The Plan provides for, periodis drills,

Identified as a result of exercises or drills including one comprehen:1ve drill are (will bc) corrected, annually, to adequately evaluate the

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capabilitics to manage accidents applicable :

i Related Reculatory Guidance

in the LTDC.

l NUREO 0654, ll.N Exercises and Drills, Communication drills have been reduced and 10 CFR 50 App.E. IV.F, Training.

from monthly to quarterly. The annual l

cxercise has been replaced by an annual j

comprehensive drill. The llcalth Physks -

drill will be ecmducted annually. Due to j

the red uced - offsite radiological consequences of accidents credible for the LTDC, annual sampling of (L environs surrounding Rancho Seco will not bc perforrned.

Onsite sampling - will.

a c(mtinue.

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Radiological emergency resp (mse training Defueled Condition Compliance:The Plan.

is provided to those who may be called provides for training for those assigned to on to assist in an cmergency.

ERO positions to adequately manage e

accidents applicable in the LTDC.

'i Related Reculatorv Guidance:

j NUREO

0654, 11.0, Radiological Emergency Response Training, and 10 CFR 50 App.E, IV.F, Training Responsibilitics for plan development and Defueled Condition Compliancefl he Plan (16) ~ review and for distribution of emergency provides for an independent review of the

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plans are established, and planners arc Emergency Planning. program _ ~and properly trained, implementing Procedures every two years

'in place of previous review cycles.

Related Reculatory Guidance:

t NUREO 0654, ll.P. Responsibility for the Planning Effort: Development, Periodic Review -and Distribution of Emergency Plans.

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