ML20198K018

Informs That on 980828,NRC Granted Exemption to Connecticut Yankee Atomic Power Co from Certain Sections of 10CFR50 Re Emergency Response Planning,Allowing Licensee to Discontinue Offsite Emergency Planning Activities

ML20198K018
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/15/1998
From:	Chris Miller NRC (Affiliation Not Assigned)
To:	Quinn V Federal Emergency Management Agency
References
NUDOCS 9812300322
Download: ML20198K018 (3)

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V:. nessa Quinn, Acting Chief i

Stat) cnd Local Regul: tory Eviluition and AssIssment Br:nch

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, Federal Emergency Management Agency ~d s

500 C Street, S.W. ""

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[ Washington D.C. 20472 g o

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SUBJECT:

EXEMPTION OF HADDAM NECK PLANT FROM OFFSITI@MEjGENCY

] PLANNING REQUIREMENTS , ,.  ?;

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Dear Ms. Quinn:

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This is to notify you that on August 28,1998, the NRC granted an exemption to Connecticut  ;

j Yankee Atomic Power Company (the licensee) from certain sections of 10 CFR 50 concoming i emergency response planning, thereby allowing the licensee to discontinue offsite emergency

. planning activities and reduce the scope of its onsite planning at the Haddam Neck Plant. A  ;

i copy of the exemption is enclosed. The NRC has also approved the Haddam Neck Plant Defueled Emergency Plan which reflects the shutdown and defueled condition of the plant. I J i I The facility, which is beated at the licensee's site in Middlesex County, Connecticut, is a permanently shut down pressurized-water reactor. By letter dated December 5,1996, the

! licensee submitted written certification that the licensee's Board of Directors had decided to i i permanently cease operation of the Haddam Neck Plant and that fuel had been permanently l removed from the reactor.

) In light of the exemption granted to the licensee, the NRC no longer requires FEMA to monitor, j review, or report on offsite radiological emergency planning and preparedness activities at the l Haddam Neck Plant. Emergency planning and preparedness can be limited to onsite activities,  ;

i simple notification to offsite authorities, and training for offsite personnel who rhay need to j respond onsite (e.g., fire, ambulance, and law enforcement personnel).

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Please notify the State and local govemments that the offsite emergency plans and i preparedness will no longer be required for the Haddam Neck Plant. Should you need more

information on this matter please contact Mr. Daniel M. Barss of my staff at 301-415-2922.

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Sincerely, I , hie  !

j Emergency Preparedness and i Radiation Protection Branch Division of Reactor Program Management ,

j Office of Nuclear Reactor Regulation

, Docket No. 50-213 71 l

Enclosures:

As s'ated

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9812300322'NB0915 PDR ADOCK 05000213 F PDR h

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Mr. Russell A. Mellor  !

HNP DEP provides for an acceptable level of emergency preparedness at the HNP in its shutdown and defueled condition and also provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency at the HNP. Therefore, the staff approves the HNP DEP, and the HNP may,in accordance with the provisions of 10 CFR 50.54(q), implement the DEP upon receipt of the enclosed exemption.

Also, enclosed is a copy of the Safety Evaluation of your DEP and the Environmental Assessment and Finding of No Significant Impact related to the axemption from 10 CFR 50.54(q).

Sincerely,

/ H  %

Thomas L. Fredrichs, Project Manager Non Power Reactors and Decommissioning )

Project Directorate j Division of Reactor Program Management j Office of Nuclear Reactor Regulation Docket No. 50-213

Enclosures:

As stated i

cc: w/ enclosures See next page 4

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Connecticut Yankee Atomic Power Co. Haddam Neck Plant

,' Docket No. 50-213 f

cc:

i Lillian M. Cuoco, Esq. Resident inspector Senior Nuclear Counsel Haddam Neck Plant Northeast Utilities Service Company clo U.S. Nuclear Regulatory Commission l 362 injun Hollow Road P. O. Box 270

Hartford, CT 06141 0270 East Hampton, CT 06424-3099 r

Mr. Kevin T. A. McCarthy, Director Mr. James S. Robinson Manager, Nuclear investments and i Monitoring and Radiation Division

, Department of Environmental Administration Protection New England Power Company 79 Elm Street 25 Research Drive Hartford, CT 06106 5127 Westborough, MA 01582 Mr. Allan Johanson Mr. G. P. van Noordennen Assistant Director Manager - Nuclear Licensing Office of Policy and Management Northeast Utilities Service Company ,

Policy Development and Planning 362 injun Hollow Road Division East Hampton, CT 06424-3099 l 450 Capitol Avenue MS#52ENR l l

P. O. Box 341441 Regional Adrrinistrator l Region 1 Hartford, CT 06134-1441 U.S. Nuclear Regulatory Commission i Mr. F. C. Rothen 475 Allendale Road l Vice President - Work Services King of Prussia, PA 19406 i Northeast Utilities Service Company P. O. Box 128 Board of Selectmen Waterford, CT 06385 Town Office Building Haddam, CT 06438 Mr. D. M. Goebel

! Vice President - Nuclear Oversight Northeast Utilities Service Company f' P. O. Box 128 Waterford, CT 06385 4

Mr. J. K. Thayer Recovery Officer, Nuclear Engineering and Support Northeast Utilities Service Company P. O. Box 128 Waterford, CT 06385 i

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4 UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION i

IN THE MATTER OF )

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CONNECTICUT YANKEE ATOMIC ) DOCKET NO. 50-213

$ POWER COMPANY )

! I i HADDAM NECK PLANT )

l EXEMPTION i.

l l Connecticut Yankee Atomic Power Company (CYAPCO or the licensse) is the holder of Facility Operating License No. DPR-61, which authorizes the licc;.:*e to possess the a

Haddam Neck Plant (HNP). The license states, among other things, that the facility is i

i subject to all the rules, regulations, and orders of the U.S. Nuclear Regulatory Commission i (the Commission or NRC) now or hereafter in effect. The facility consists of a pressurized-1 i water reactor located at the licensee's site in Middlesex County, Connecticut. The facility is permanently shut down and defueled and the licensee is no longer authorized to operate i

or place fuel in the reactor.

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' Section 50.54(q) requires power reactor licensees to follow and maintain in effect i

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. emergency plans that meet the standards of Section 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.

Pursuant to 10 CFR 50.12(a), NRC may grant exemptions from the requirements of

the regulations, which are (1) authorized by law, will not present an undue risk to public health and saf6ty, and are consistent with the common defense and security, and a

, (2) present special circumstances. Special circumstances exist when application of the 3 909060/93-

2 i regulation in the particular circumstance would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule (10 CFR 50.12(a)(2)(ii)).

The underlying purpose of Section 50.54(q) is to ensure that licensees follow and maintain

in effect emergency plans which provide reasonable assurance that adequate protective measures can and will be taken ;n the event of an emergency at a nuclear reactor.

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i l By letter dated May 30,1997, CYAPCO requested an exemption from the provision

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of 10 CFR 50.54(q) that requires emergency plans to meet all of the standards of 10 CFR

! 50.47(b) and all of the requirements of Appendix E of Part 50. The request for exemption was based on the substantially reduced the risk to public health and safety resulting from the permanently shutc':wn and defueled condition of the Haddam Neck Plant (HNP). In l >

addition, the licensee submitted a proposed Defueled Emergency Plan (DEP) for NRC approval. The DEP proposed to discontinue offsite emergt.ncy planning activities and to f reduce the scope of onsite emergency planning, which met only a portion of the standards i

! and requirements. Thus, an exemption is required from the provision of 10 CFR 50.54(q) i j that requires emergency plans to meet all of the standards of 10 CFR 50.47(b) and all of 4

the requirements of Appendix E of Part 50. By & Determined That Revs Do Not Decrease Effectiveness of Plan|letter dated September 19,1997]], the l licensee submitted the Emergency Action Levels that it proposed to use with the DEP. By o

! letter dated September 26,1997, the licensee submitted the results of an assessment of 1

the ability of the HNP spent fuel to heat up in the absence of water in the spent fuel pool i

(SFP). By letter dated October 21,1997, the licensee submitted additionalinformation on certain aspects of the DEP and identified the specific standards and requirements of 10 CFR 50.47(b) and Appendix E of Part 50 which the proposed DEP would no longer meet.

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{ By letters dated December 18,1997, January 22, March 25, June 19, and July 31, I

i 1998, the licensee sent additionalinformation on the proposed DEP. Tables 1 and 2 of Attachment 2 of the licensee's March 25,1998 letter revised and consolidated the list of j standards and requirements of 10 CFR 50.47(b) and Appendix E to Part 50 that woulv k

! remain in effect.

] The licensee stated that special circumstances exist at HNP because of the plant's .

j permanently shutdown and defueled condition. With the plant in this condition, most of j

- the design-basis accidents postulated for operating reactors are no longer possible.

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However, CYAPCO postulated two design-basis accidents that are relevant to the 1 l permanently shutdown condition

(1) a release from combustible radioactive ion exchange  !

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resin and (2) fuel handCog accidents. With the exception of Kr 85, the noble gas and i iodine nuclides that contribute to the dose consequences of releases from operating i

reactors have decayed to a negligible amount. CYAPCO calculated doses due to resin

! handling and fuel handling accidents and concluded that doses at the residence nearest to 1-HNP would not exceed the Environmental Protection Agency (EPA) Protective Action 1

i i i Guides (PAGs) for activation of the offsite emergency response organization. I

! In addition, the licensee has evaluated the potential consequences of a beyond-j.

{ design basis event that would completely remove the spent fuel pool water inventory. The j

analysis demonstrated that, even with no cooling by water, the decay heat load has J decreased to the point that air cooling would maintain fuel cladding temperatures low l

1 l enough to ensure the integrity of the cladding material. l j

in the permanently shutdown and defueled condition, the source term of nuclides that )

are readily dispersible in air and the energy available to propel radioactive materials off site

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are significantly reduced in comparison to an operatmg plant. The staff has evaluated the 1

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potential for a permanently shutdown plant with spent fuel stored in the spent fuel pool to

! generate a release of radioactive material that would result in offsite dose consequences, f l l The two source terms of primary concern are low level radioactive waste generated by j decommissioning activities and the spent fuel.

i i The first source term, from low-level radioactive waste at the site, is much lower than ,

the one from the spent fuel. However, the potential dose consequences of a release from i'

a low level waste container have been evaluated. An event that would provide a motive i

- force for the release and transport of airborne activity offsite is a fire in low level radioactive waste. The bounding accident for low-level radioactive wastes present on site is a fire in ion exchange resins used to process wastes from a reactor coolant system a chemical decontamination. While they are in use, the resins are immersed in water. Upon depletion, used ion exchange rc.zins are placed in containers called liners for dewatering I

{' prior to shipment to a disposal site. The licensee calculated that a fire in a resin liner, j loaded with wastes having the maximum activity allowed by procedure, would result in a offsite dose which does not exceed the EPA PAGs. The staff reviewed the calculational methods and assumptions used by the licensee to determine the consequences of a resin

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fire and found them to be acceptable. The staff concludes that the consequences of a l resin liner fire at HNP would not exceed the EPA PAGs.

The second source term considered is spent fuel. However, wet storage of spent fuel possesses inherently large safety margins due to the simplicity and robustness of the SFP design. The design basis includes the ability to withstand an earthquake and retain the ability to hold sufficient water to adequately cool and shield the spent fuel. Thus, the loss of all the water from the Haddam Neck SFP is a beyond-design-basis event, with a very l low probability of occurring.

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5 i However, there are two potential consequences from a beyond-design-basis event -

that postulates the complete remov31 of water from the SFP. In the absence of water i

cooling, during the period that decay heat generation is relatively high the fuel could heat '

i up to such a degree that a release could occur in the absence of water shielding, the radiation from the fuel could cause radiation exposure to individuals offsite from the scatter of gamma rays streaming up from the pool.

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j in order for a release that would result in offsite dose consequences to occur, a r

motive force must exist to cause radioactive material to move into an unrestricted area. At l; .

j I a permanently shutdown and defueled plant, decay heat in the spent fuel could provide this 2 i force. However, decay heat decreases over time, and at some point it can no longer

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overcome the ability of the fuel cladding to retain fission products. When decay heat can no longer cause the fuel to heat to the point where fission products could be relear ed, l

a significant release off the site is no longer possible by this means, i

The licensee analyzed the heatup characteristics of the spent fuelin the absence of

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SFP water, when cooling depends on the natural circulation of air through the spent fuel racks. By letter dated September 26,1997, the licensee presented the results of an analysis showing that as of October 1,1997, decay heat could not heat the spent fuel i

i cladding above 538'C, in the event all water was drained from the SFP. The licensee's i

4 heat up analysis was based on a particular configuration of the spent fuelin the SFP. By letter dated December 18,1997, the licensee stated, that as of October 23,1997, the spent fuel had been moved into a configuration consistent with the analysis. The staff i

evaluated the licensee's analysis by performing heat up calculations using computer codes

validated to be accurate to within 15'C of actual peak fuel cladding temperatures. The licensee's value for_ peak fuel cladding temperature was found to be acceptable. On the basis of a previous staff determination that fuel cladding will remain intact if its i

i 6 temperature remains below 565'C, the staff concluded that it is no longer possible for a

complete loss of water from the Haddam Neck SFP to result in a release offsite that exceeds the early phase EPA PAGs.

1 j Although a significant release of radioactive material from the spent fuelis no longer i possible, in the absence of water cooling, a potential exists for radiation exposure to an offsite individual in the event that shielding of the fuelis lost. Water and the concrete pool structure serve as radiation shielding on the sides of the pool. However, water alone i 4 j provides most of the shielding above the spent fuel. A loss of shielding above the fuel i j -

j could increase the radiation levels offsite because of the gamma rays streaming up out of the pool being scattered back to a receptor at the site boundary. The licensee calculated l

I the offsite radiologicalimpact of a postulated complete loss of SFP water and determined l that the dose rate at the residence nearest to HNP would be 0.016 rem per hour. At that i-

[ rate, it would take 2.6 days for the event to exceed the EPA early phase PAG of 1 rem.

The PAGs were develooed to respond to a mobile airborne plume that could transport and deposit radioactive material over a large area. In contre st, the radiation field formed by scatter from a drained SFP would be stationary, rather than moving, and would not cause transport or deposition of radioactive materials. The 2.6 days available for action allows sufficient time to develop and implement mitigative actions and provides confidence that additional offsite measures could be taken without planning, if efforts to reestablish i shielding over the fuel are delayed.

n The staff has evaluated the radiological consequences,'onsite emergency organization,

facilities, equipment, procedures, and support resources of the licensee's proposed DEP.

The staff reviewed the licensee's proposed DEP against the planning standards in 10 CFR 50.47(b) and (d), the requirements of Appendix E to 10 CFR Part 50, the acceptance

7 criteria in NUREG 0654/ FEMA REP-1, Revision 1, and the guidance contained in NUMARC/NESP-OO7, Revision 2. The staff review took into consideration the permanently shutdown and defueled status of the facility, the configuration of the stored fuel, and the length of time since power operation.

IV.

The NRC steff has completed its review of the licensee's request for an exemption i from the requirement of 10 CFR 50.54(q) that emergency plans must meet all of the standards of 50.47(b) and all of the requirements of Appendix E of 10 CFR Part 50.

Standards and requirements that remain in effect are listed in Tables 1 and 2 of Attachment 2 to the licensee's letter dated March 25,1998 (Docket No. 50 213, Accession No. 9804020370). On the basis of this review, the NRC staff finds that the radiological consequences of accidents possible at HNP are substantially lower than those at an operating plant. The analyses submitted by the licensee are consistent with the commitment made in their Post Shutdown Decommissioning Activities Report, which stated that any radiation exposure to an offsite individual will be bounded by the EPA PAGs. The upper bound of offsite dose consequences limits the highest attaineble

emergency class to the alert level. In addition, due to the reduced consequences of i . .

i radiological events still possible at the site, the scope of the onsite emergency i

preparedness organization may be reduced. Thus, the underlying purpose of the

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! regulations will not be adversely affected by eliminating offsite emergency planning activities or reducing the scope of onsite emergency planning.

1 1 For these reasons, the Commission has determined that, pursuant to

- 10 CFR 50.12, elimination of the offsite emergency planning activities and implementation i

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of the DEP will not present an undue risk to public health and safety and is consistent with ,

I the common defense and security. Further, special circumstances are present as stated in i 1

10 CFR 50.12(a)(2)(ii).

Pursuant to 10 CFR 51.32, the Commission has determined that granting this i exemption will have no significant impact on the environment (63 FR 43967, dated August 17,1998).

This exemption is effective upon issuance.

FOR THE NUCLEAR REGULATORY COMMISSION  ;

a . b or Office of Nuclear Reactor Regulation

• 4 Dated at Rockville, Maryland this 28th day of August 1998.

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f t UNITED STATES' j

NUCLEAR REGULATORY COMMISSION WAgHINGToN, D.C. 2- m1 SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLE .R REACTOR REGULATION OF THE DEFUELED EMERGENCY PLAN FOR EMERGENCY PLANNING FOR CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT DOCKET NO. 50-213

1.0 INTRODUCTION

1 By letter dated December 5,1996, Connecticut Yankee Atomic Power Company (CYAPCO) submitted written certifications that the Board of Directors of CYAPCO (or the licensee) had decided to permanently cease operation at the Haddam Neck Plant (HNP) and that fuel 4

had been permanently removed from the reactor.

By. letter dated May 30,1997, CYAPCO requested an exemption from the provision of 10 CFR 50.54(q) that requires emergency plans to meet all of the standards of 10 CFR 50.47(b) and all of the requirements of Appendix E to Part 50, on the basis that the permanently shutdown and defueled condition of the HNP had substantially reduced the risk to public health and safety. Bacause the licensee's proposed Defueled Emergency Plan would not meet some of the standards and requirements noted in 10 CFR 50.47(b) and Appendix E to Part 50, the exemption was required in order for the DEP to maintain compliance with the regulation.

2.0 BACKGROUNQ l

By letter dated May 30,1997, the licensee submitted its proposed Defueled Emergency Plan (DEP) for NRC approval. The DEP proposed to discontinue offsite emergency planning activities and reduce the scope of onsite emergency planning, which reflected the shut-down and defueled status of the plant, and took into account the requested exemption. On September 19,1997, the licensee submitted the Emergency Action Levels it proposed to use with the DEP. By letter dated September 26,1997, the licensee submitted the results of an assessment of *.he HNP with respect to a beyond-design basis event of a loss of all water in the spent fuel pool. As the result of a meeting with the NRC held on October 1, 1997, the licensee submitted additional information by letter dated October 21,1997, on certain aspects of the DEP and identified those specific standards and requirements that the proposed DEP would no longer meet. CYAPCO submitted a letter dated December 18, 1997, which gave additionalinformaticn with respect to the proposed DEP for the HNP.

Following conference calls on December 23,1997, and January 8,1998, the licensee submitted additional information in letters dated January 22, March 25, June 19, and k8D903C/W

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) . July 31,1998. Tables 1 and 2 of Attachment 2 to the licensee's March 25,1998, letter

j. revised and consolidated the standards and requirements of 10 CFR 50.47(b) and Appendix  :

[ 1 E to Part 50 that still apply to the DEP.

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!- With the plant in a permanently shutdown and defueled condition, the two postulated l i

i events that could occur are resin handling and fuel handling accidents. With the exception j of Kr 85, the noble gas nuclides that contribute to a whole body dose have decayed to a '

negligible amount. CYAPCO calculated resin handling and fuel handling accident doses and j concluded that doses at the Exclusion Area Boundary and the Low Population Zone are a i 4 small fraction of the 10 CFR 100 dose limits and, therefore, would not pose any threat to  ;

} the health and safety of the public. The calculated doses would not exceed the r Environmental Protection Agency (EPA) Protective Action Guides (PAGs). Since the resin handling and fuel handling events cannet lead to the release of radioactive materials i

. beyond the current Exclusion Area Boundary in quantities that would require any offsite l Federal, State, or local plume exposure protective actions, an Alert is the highest attainable j l emergency classification level appropriate to the HNP in the permanently shutdown and i defueled condition. The present HNP Emergency Plan contains requirements in excess of l those necessary to support emergency preparedness at the plant in a permanently l l

shutdown and defueled condition and does not address changes that would be allowed on j the basis of the proposed exemption.

I i The staff used the same acceptance criteria for in review of the DEP as are used to j evaluate the adequacy of onsite emergency plans for operating nuclear power reactors, ,

j taking into consideration the current shutdown status of the HNP and reflecting ]

l incorporation of the proposed exemption. The acceptance criteria include the planning standards of 10 CFR 50.47(b), the requirements of Appendix E to 10 CFR Part 50, the j

. guidance criteria of NUREG 0654/ FEMA REP-1, " Criteria for the Preparation and Evaluation ]

l of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power  !

Plants," Revision 1, dated November 1980, and the guidance contained in NUMARC/NESP-l

! 007, " Methodology for Development of Emergency Action Levels," Revision 2, dated l I

! January 1992.

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For any potential offsite impacts, the staff reviewed the DEP using the standards of L 10 CFR 50.47(d), which state the requirements for a license authorizing fuel loading and l low power testing only, in 10 CFR 50.47(d), the staff recognizes the smaller risk l j associated with low power operation and the staff considers the standards to be generally i l

appropriate for reviewing the offsite aspects of the DEP.

I I I 3.0 DISCUSSION AND STAFF EVALUATION OF THE DEP l i

3.1 Radioloaical Conneauences The staff reviewed the licensee's analysis, including calculations CYRESiN-01578 RY, "Haddam Neck - Radiological Consequences From a Resin Accident" and RAB98-01620- i

- RY, " Scatter Dose Rates Due to CY Spent Fuel Pool Draindown," Revision 2, to verify that

[ the licensee demonstrated the acceptability of changes to its emergency plan (EP) using i

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i appropriate methods with sufficiently conservative assumptions and input parameters.

These two postulated accidents bound the possible accidents that could have an impact on ,

j an individual off site through the airborne release of radioactive materials or from direct L radiation, respectively.

I 3.1.1 Resin Fire i

Decontamination of systems during decommissioning and dismantlement operations is j expected to generate significant radioactive waste in the form of contaminated domineralizer resins. A fire in a fully loaded resin liner could serve as a motive force for the release and transport of alrborne radioactivity off site. Resins are collected and de watered  ;

on site in containers called liners before being transported off site for disposal. Using a

! release fraction of 1 percent, the licensee calculated that a fire in a resin liner loaded with i the maximum activity allowed would result in a maximum offsite dose of 0.96 rem. The s release fraction is consistent with the release fractions listed in Schedule C to 10 CFR j 30.72, for mixed fission and corrosion products. The calculational methods and

assumptions used in this analysis are acceptable to the staff.

I i' 3.1.2 Fuel Pool Draindown l Although the fuel on site has decayed for a minimum of 2 years, a significant amount of radioactivity remains in the spent fuel pool in the form of spent fuel assemblies. Water and the concrete pool structure provide radiation shielding on the sides of the pool. However, water alone provides most of the shielding above the spent fuel. A loss of shielding above the fuel could increase the, radiation levels off site from the gamma rays streaming up out of the pool being scattered back to a receptor at the site boundary. The licensee calculated i the offsite radiologicalimpact of a postulated complete loss of spent fuel pool water. The i-radioactive inventory in the spent fuel was calculated with the computer code ORIGEN2.

! The computer code QAD was used to adjust this source term for self shielding by the mass

, of the fuel. Finally, the licensee used the GGG F code to calculate that the dose to the nearest residence is 0.016 rem per hour. ORIGEN2, QAD, and GGG F are widely used in i

the radiation shielding industry and are acceptable to the staff.

! The licensee's calculated dose rate indicates it would take 2.6 days for this event to 4 exceed the EPA early phase PAG of 1 rem. The PAGs were developed to respond to a mobile airborne plume that could transport and deposit radioactive material over a large

! area. In contrast, the radiation field formed by the scatter from a drained spent fuel pool (SFP) would be stationary, rather than moving, and would not cause the transport or

! deposition of radioactive materials. The 2.6-day period available for action allows sufficient time to develop and implement mitigative actions and provides confidence that additional offsite measures could be taken without preplanning if efforts to reestablish shielding over the fuel are delayed, i

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4 3.1.3 EMal Heatuo l

The licensee analyzed the heatup characteristics of the spent fuelin the absence of SFP )

water, when cooling depends on the natural circulation of air through the spent fuel racks. l By letter dated September 26,1997, the licenses presented the results of an analysis j showing that as of October 1,1997, decay heat could not heat the spent fuel cladding )

above 538 *C, in the event that all water was drained from the SFP. The licensee's heat up analysis was based on a particular configuration of the spent fuelin the SrP. By letter dated December 18,1997, the licenses stated, that as of October 23,1997, the spent fuel had been moved into a configuration consistent with the analysis. The staff evaluated the j licensee's analysis by performing heat up calculations using computer codes validated to be accurate to within 15 *C of ac*ual peak fuel cladding temperatures. The licensee's value for peak fuel cladding temperature was found to be acceptable. On the basis of an earlier l staff determination that fuel cladding will remain intact if its temperature remains below i 565 *C, the staff concludes that it is no longer possible for a complete loss of water from  !

the Haddam Neck SFP to result in a release off site that exceeds the early phase EPA PAGs.

3.2 Assianment of Resoonsibility (Oraanizational Controll The DEP describes the on shift and augmented organizations that are intended to be part of the overall response organization in the event of an emergency at the HNP. The plan identifies by title a specific individual who is in charge of emergency response and contains 24-hour a-day coverage. In support of the normal shift organization, CYAPCO maintains the capability to provide corporate tupport, including senior personnel, facilities, equipment, and financial resources. Local agency and support services are identified, and cop!:s of letters of agreement list support organization responsibilities and arrangements.

i 3.3 Onsite Emeroenev Oraanization The DEP describes the normal plant organization, the Defueled Emergency Response Organization (DERO), and the augmented organization covering the Technical Support Center (TSC) and the control room. The licensee has described each of the emergency I response positions. The plan identifies the Emergency Director's (ED's) responsibilities, I including emergency classification, offsite notifications, command and control, and

! authorization of onsite protective actions. The augmentation ED has a response goal of 60 minutes from notification of an event. The four additional DERO positions have a 120-j minute response goal from the time of an Alert classification.

3.4 Emeroenev Resoonse Sunoort and Resources CYAPCO has arrangements in place with local support agencies for ambulance services, i hospital facilities, fire fighting assistance, and radiological laboratories. Letters of agreement are found in Appendix B to the DEP.

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3.5 Emercenev Classification System

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! Appendix F to the DEP contains an emergency classification and emergency action level

! (EAL) scheme, including initiating conditions associated with possible events at the HNP j which would result in the declaration of a Notification of Unusual Event (NOUE) or an Alert.

Specific instruments, parameters, and equipment conditions are detailed in plant procedure DEPlP 1.51, " Emergency Assessment Using Defueled EAL Tables." CYAPCO has reached

' agreement with appropriate State and local governmental authorities on the EALs. The staff has reviewed the EALs and determined that they are acceptab!e when compared to the applicable standards considering the defueled condition and shutdown status of the i facility.

3.6 Notification Methods and Procedures i

! The DEP specifies that the State of Connecticut and the NRC will be notified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ,

of an emergency classification. Simultaneous notification of State and site augmentation personnelis outlined. The content of notification messages is specified, and provisions are made for verification of notifications, i 3.7 Emeroenev Commun'ications

! The DEP specifies that a radio pager is used for prompt notification of the DERO and offsite l

- authorities. . Backup communications are available using commercial telephone lines, company tie-line telephones, and radios. Two-way radios are available in the plant l I

between the control room and in plant teams. A public address system is also available in l the plant to link the TSC, control room, and in-plant teams. The NRC will be notified via

? the emergency notification system. Communication with fixed and mobile medical support i facilities is described. J l 3.8 Public Education and Information

{

i Under th? DEP, the Public Information Coordinator is responsible for preparing and transmitting news releases. A media information program is provided for annually.

3.9 Emeroenev Facilities and Eauloment

)

The DEP identifies the control room and Technical Support Center (TSC) as the onsite ,

emergency response f acilities. Arrangements have been made to accommodate offsite officials at the TSC. The HNP has various appropriate monitoring systems as needed for l

~

evaluating the condition of plant systems, meteorological conditions, seismic activity, and radioactive materials. The provisions for, and the maintenance of, emergency equipment ,

and supplies are established. ,

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j 3.10 Accident Assessment The DEP calls for onsite systems and equipment to allow for radiological accident monitoring and assessment of radiological conditions, and the performance of dose projections.

3.11 Protective Resoonse The DEP outlines protective actions to be taken on site to warn personnel of hazard

conditions, call for the relocation of onsite staff when necessary, maintain accountability of ,

ernergency responders, and limit site access when needed. The DEP has a goal to

! complete accountability of onsite personnel within 60 minutes.

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3.12 Radioloaical Exoosure Control j in the DEP, the Radiation Assessment Coordinator {RAC) is responsible for onsite j

! emergency radiological protection activities for plant staff and support personnel. Exposure l limits and authorization authority for exceeding limits are defined. Contamination control measures and provision for decontamination are established. ,

, i 3.13 Medcat and First Aid Sumoort First aid and other medical supplies are provided for at the plant. Shift personnel trained in ,

first aid are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The DEP contains arrangements for transportation to j l offsite medical facilities; two hospitals are identified'for the trettment of potentially

contaminated injured individuals.

3,14 Recoverv and Reentrv Plannino i l The DEP contains general criteria for determining when to establish recovery operations. J The plan identifies the appropriate authority by position and title for initiating recovery 1 actions.

l 3.15 Exercises and Drills l

The DEP specifies that en annual exercise of the DEP will be conducted. The DEP also calls i

for an annual medical drill and an annual health physics drill. Tha plan allows for testing of l i the site relocation alarm weekly. Communication links to the State of Connecticut and the NRC are tested monthly. Quarterly tests of onsite radios and telephones are specified and j include keeping phone numbers current.

3.16 Radioloolcal Emerasnev Resoonse Trainina

. The DEP maintains a training program to ensure that personnel sesigned to the emergency.

response organizations are trained prior to assuming any emergency plan responsibilities and retrained annually. The program covers basic as well as specialized training for those emergency response personnel with specific assignments. Training for participating offsite agency personnel involved in emergency response is made available annually. HNP first aid responders receive first aid training equivalent to the Red Cross Multimedia first aid prograrn.

i

7 I 3.17 Plan Develooment and Review The requirement for an annual review of the DEP, procedures, practices, training, ]

equipment, readiness testing, drills and exercises, letters of agreement, and adequacy of interface with offsite officials, is specified in the plan. An annualindependent audit of the DEP is also to be conducted. Responsibilities for maintaining the emergency response '

facilities, plans and procedures, staffing the emergency response organization, and training of responders are specified in the DEP.

4.0 CONCLUSION

S The staff concludes that the licensee's proposal to discontinue offsite emergency planning activities and reduce the scope of onsite emergency planning is acceptable in view of the greatly reduced offsite radiological consequences associated with the current state of the plant, and consistent with CYAPCO's requested exemption. The staff found acceptable the licensee's findings that, in its defueled condition, a radiological accident would not result in a dose in excess of the EPA early phase PAG (1 rem) to any individuallocated off site.

The licensee's proposed Defueled Emergency Plan has been reviewed by the staff against the planning standards in 10 CFR 50.47(b), as described in Tables 1 and 2 of Attachment 2 to the licensee's letter' dated March 25,1998, the planning standards in 10 CFR 50.47(d),

the requirements of Appendix E to 10 CFR 50, as described in Tables 1 and 2 of Attachment 2 to the licensee's letter dated March 25,1998, the acceptance criteria in NUREG 0654/ FEMA REP 1, Revision 1, and the guidance contained in NUMARC/NESP-007, Revision 2. The staff review took into consideration the shutdown and defueled status of the facility, the configuration of the stored fuel, and the length of time since power

operation, s

The staff concludes that the HNP Defueled Emergency Plan provides for an acceptable level l

of emergency preparedness at the HNP in its shutdown and defueled condition, and also

{ provides reasonable assurance that adequate protective measures can and will be taken in

! the event of a radiological emergency at HNP.

. Principal Contributors: Daniel M. Barss ,

Roger L. Pedersen

j. Diane T. Jackson 1 Date: August 28, 1998 t

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7590-01-P UNITED STATES NUCLEAR REGULATORY COMMISSION CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT DOCKET NO. 50-213 ENVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT The U.S. Nuclear Regulatory Commission (the Commission or NRC) is considering issuance of an exemption from certain requirements of its regulations to Facility Operating License No. DPR 61, a license held by the Connecticut Yankee Atomic Power Company (CYAPCO or the licensee). The exemption would apply to the Haddam Neck Plant (HNP), a permanently shutdown and defueled plant located at the CYAPCO site in Middlesex County, Connecticut.

ENVIRONMENTAL ASSESSMENT j

Identification of the Proposed Action: i The proposed exemption would modify emergency response plan requirements, in response to the permanentiv shutdown and defueled status of the Haddam Neck facility.

The proposed action is in accordance with the licensee's application dated May 30, ;

1997, as supplemented or modified by letters of September 19, September 26, )

i October 21, and December 18,1997, and January 22, March 25, June 19, and July 31, 1998. The requested action would grant an exemption from certain requirements of 10 CFR 50.54(q) to discontinue offsite emergency planning activities and reduce the scope of 4

onsite emergency planning.

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2 The Need for the Proposed Action: )i l

j By letter dated December 5,1996, the licensee submitted certifications that it had ,

permanently ceased operations at HNP and that all fuel had been permanently removed i

from the reactor. In accordance with 10 CFR 50.82(a)(2), upon docketing of the  ;

i. i certifications, CYAPCO was no longer authorized to operate the reactor or to retain fuel in l

. the reactor vessel. In this permanently shutdown and defueled condition, the facility poses I a reduced risk to public health and safety. Because of this reduced risk, certain provisions l

i

of 10 CFR 50.54(q) are no longer required. An exemption is required from portions of 10 t 1

i CFR 50.54(q) to allow the licensee to implement a revised Defueled Emergency Plan (DEP)  ;

that is appropriate for the permanently shutdown and defueled reactor facility.

Environmental Impact of the Proposed Action:

The Commission has completed its evaluation of the proposed action. The Commission concludes that exemptions from certain portions of 10 CFR 50.54(q) are i acceptable given the reduced risk and reduced consequences of an accident occurring at a i

permanently defueled reactor site with a substantially reduced decay heat load produced by

! the spent fuel held in storage.

1 The proposed change will not increase the probability or consequences of  ;

accidents, no changes are being made in the types of effluents that may be released off-i >

site, and there is no significant increase in the allowable individual or cumulative

. occupational exposure. Accordingly, the Commission concludes that there are no significant radiological environmental impacts associated with the proposed action.

With regard to potential non-radiologicalimpacts, the proposed action does not affect l

- l 3 r non radiological plant effluents and has no other environmentalimpact. Therefore, the Commission concludes that there are no significant non radiological impacts associated with the proposed action.

Alternatives to the Proposed Action:

Since the Comru!ssion has concluded that there is no measurable environmental -

impact associated with the proposed action, any alternative with equal or greater environmental impact need not be evaluated. The principal alternative to the action would l

be to deny the request (no action alternative). Denial of tne exemption request would not change any current environmentalimpacts. The environmentalimpacts of the proposed action and the alternative action are similar.

Afternative Use of Resources:

1 This action does not involve the use of resources not previously considered in the final environmental statement related to operatien of HNP issued in October 1973.

i Agencies and Persons Consulted:

In accordance with its stated policy, on August 5,1998, the NRC staff consulted with Mr. D. Galloway of the State of Connecticut, Department of Environmental Protection, regarding the environmentalimpact of the proposed action. The NRC staff and the State official discussed the proposed issuance of the exemption. The State officist did not object to issuance of the exemption.

FINDING OF NO SIGNIFICANT IMPACT On the basis of the environmental assessment, the Commission concludes that the proposed action will not have a significant effect on the quality of the human environment.

Accordingly, the Commission has determined not to prepare an environmental impact

' statement for the proposed action.

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