ML20198R618

Requests Exemption to 10CFR50.54(q) to Allow Myap to Discontinue Certain Aspects of Offsite Planning Activities Commensurate W/Reduction in Risk to Public.Defueled Emergency Plan Encl

ML20198R618
Person / Time
Site:	Maine Yankee
Issue date:	11/06/1997
From:	Meisner M Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20198R626	List: ML20198R618 ML20198R637
References
MJM-97-19, MN-97-119, NUDOCS 9711130334
Download: ML20198R618 (21)

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MaineYankee ALLtABLE f LICTRtCJTY FOR MAINE SWCE 197 PO BOX 408. WISCASSET, MAINE 04578 . (207) 882-6321 November 6,1997 MN-97-119 MJM-97-19 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, DC 20555 Reierences:

License (O) Letter:

(b M. B.No. SellmanDPF-36 to USNRC; (Docket Certificat No. 50-309) ions of Perman Cessation of Power Operation and Permanent Removal of Fuel from the Reactor; MN-97-89, dated Augus' 7,1997

Subject:

Defueled Emergency Plan and 10CFR50.54(q)- Exemption Request Gentlemen-Maine Yankee is pleased to submit the Defueled Emergency Plan for Maine Ycakee. W~ have determined, consistent with Maine Yankee's permanently defueled status, that the chsnges to the Emergency Plan, comb.ned with the exemption iequests discussed below, do not decrease the effectiveness of the Plan, in Reference @), Maine Yankee informed the USNRC that the Board of Directors of Maine Yankee had decided to permanently cease operations at the Maine Yankee F. ant and that the fuel had been permanently removed from the reactor.

In accordance with 10CFR50.82(a)(2), the certifications in the letter modified the Meine Yankee license to permanently withdraw Maine Yankee's authority to operate the reactor and to load fuel in the reactor vessel. In this permanently shutdown

- condition, the plant poses a significantly reduced risk to the public health and safety.

M eiew of this reduced risk, certain requirements of 10CFR50.47(b) and Appendix E to 10CFR50 are no longer appro ariate. Therefore, Maine Yankee is requesting an exemption to 10CFR50.54(q) w11ch states:

"A licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in offect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of this part...".

Approval of the exemption request will allow Maine Yankee to discontinue certain aspects of offsite planning activities commensurate with the reduction in risk to the public associated with the permanently shutdown and defueled plant, and reduce the scope of its onsite plan as indicated in Maine Yankee's Defueled Emorgency Plan. Specifically, the major areas of exemption include elimination of emergency

classification above the " alert" level, elimination of off-site emergency response \ -

l provisions and elimination of off site protective measures. /

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UNITED STATES NUCLEAR REGULATORY COMMISSION MN-97-119 Attention: Document Control Desk Page Two Maine Yankee has determined that the emergency planning activities required for compliance with 10 CFR50.54(q) and the referenced portions of 10CFR50.47 and Appendix E to Part 50 would not serve the underlying aurpose of the rule and would present an undue financial and administrative hards 11p. A request for exemption from the requirements of 10 CFRLO.54(q)is enclosed as Attachment I to this letter.

The exceptions being taken to 10CFR50.47 and Appendix E to 10CFR50 are described in Attachment II.

The Defueled Emergency Plan (Attachment Ill) specifically reflects the substantially reduced risk of the remaining design basis accidents associated with the 3ermanently shutdown plant with the raactor permanently defueled. Maira Yankee las discussed the contents of the Defueled Emergency Plan and the rationale for the exemption requests from offsite emergency prept. redness requirements with the appropriate officials from the State of Maine and the Federal Emergency Management Agency, Region I.

Based on the information presented in the Attachments I and 11 to this letter and contained in the enclosed Defueled Emergency Plan, Maine Yankee believes that an exemption from the requirements of 10CFR50.54(q)is justifiec'. The Defueled Emergency Plan has been reviewed by the Plant Operations Review Committee (PORC).

Maine Yankee requests approval of the proposed exemptions by March 1,1998 so that the appropriate actions can be taken to implement the Defueled Emergency Plan by Apiil 30,1998. Piease contact Stephen D. Evans or me should you have any questions or desire additional information.

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l Mi ael . Meisner, Vice President N cle afety & Regulatory Affairs Attachment l- Exemption Request from 10CFR50.54(q)

Il- List of Exceptions to 10CFR50.54(q) and Appendix E addressed by Exemption Request lil- Defueled Emergency Plan c: Mr. Hubert Miller Mr. J. T. Yerokun Mr. Michael Webb Mr. Richard Rasmussen Mr. Patrick J. Dostie Mr. Uldis Vanags Mr. John W. Libby, State Dimctor, Maine Emergency Management Agency l

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ATTACHMENT l .

l REQUEST FOR EXEMPTION FROM TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 50.54(q)

1. REQUEST FOR EXEMPTION:

Maine Yankee hereby reouests exemption from of 10CFR50.54(q), which requires that emergency plans be mainiained to meet the standards of 10CFR50.47(b) and Appendix E to 10CFR50. Maine Yankee has decided to permanently cease operation of the Maine Yankee Plant. " Certification of Permanent Cessation of Operation and Removal of Fuel from the Reactor Vessel" has been docketed in accordance with 10CFR50.82. The requirements in 10CFR50.47 and Appendix E to Part 50 are no longer appropriate in the defueled plant condition. The specific portions of 10CFR50.47 and Appendix E which do not apply to the defueled plant condition are described in Attachment II.

II. BACKGROUND:

On August 7,1997, Maine Yankee submitted " Certifications for Permanent Cessation of Power Operation and Permanent Removal of Fuel from the Reactor" pursuant to l 10CFR50.82(a)(1)(i) and (ii). With the docketing of this submittal, Maine Yankee was no l

!onger authorized to operate the reactor or to place fuel in the reactor vessel in i accordance with 10CFR50.82.

In the defue!ad condition, there are no longer any credible design basis accidents associated with an operating plant from startup tMough full power operatioa. The design basis accidents relative to a defueled facility are a small subset of those considered for an operating facility. This subset of design basis accidents would include the following:

l Fuel Handling inadent, Spent Fuel Cask Drop, and Radioactive Liquid Waste System i Leaks and Failures. The Radioactive Liquid Waste System leaks and failures is the most limiting design basis accident. The pos'ulated off-site whole body dose from the maximum assumed release from the radioactive ll quid waste system is much less than the U.S EPA Protective Action Guides (PAGs). With over ten months of decay since the plant was shut down (December 6,1996), the potential source term associated with the remaining design basis accidents is decreasing. The likelihood of a beyond design basis accident which would warrant an offsite response is also decreasing. Maine Yankee estimates that by March 1998, a beyond design basis event which would exceed EPA protective action guides at the site boundary and warrant an offsite response (the so-callec' zirconium fire scenario) would be impossible. This estimate will be confirmed prior to impamenting the Defueled Emergency Plan.

Tha Defueled Emergency Plan establishes the onsite emergency response capability which is appropriate once a radiological release warranting offsite response is no longer credible. At this time, offsite response capability, including offsite emergency plans, will no longer be warranted. The proposed exemptions to the emergency planning criteria contained in 10CFR50.47 and Appendix E to 10CFR50 would eliminete requirements for offsite response capability and would eliminate requirements associated with the onsite plans which are no longer appropriate. The proposed exemptions are consistent with the j defuelec emergency plan.

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lil. JUSTIFICATION FOR GRANTING THE EXEMPTION REQUEST The specific requirements for granting exemptions from Part 50 regulations are set forth in 10CFR50.12. Under Section 50.12 (a)(1), the Commission is authorized to grant an exemption upon demonstration that the exemption: (A)is authorized by law; (B) will not present an undue risk to the public health and safety, and (C) is consistent with the common defense and security. Under Section 50.12 (a)(2), special circumstances must exist for the NRC to consider the exemption request. Special circumstances include: (A) particular circuinstances where the application of the regulation would not serve the undedying purpose of the rule or is not necessary to achieve the underlying purpose of the rule and (B) undue hardship or costs that are significantly in excess of those incurred by others similarly situated and (C) circumstances exist that were not considered when the regulation was adopted for which it would be in the public interest to grant an exemption. The following justification addresses each of these requirements and demonstrates that the Commission should grant the requested exemption.

As indicated above, the underlying purpose of 10CFR50.54(q) is to provide reasonable assurance that adequate protective measures can be taken in the event of a radiological emergency. In the permanently defueled plant condition, the risk associated with the plant has been significantly reduced. Radiological releases from design basis accidents will not result in the EPA's protective action guides being exceeded at the site boundary.

Maine Yankee expects to complete, by December 1997, a site specific analysis of the susceptibility of its spent fuel to an accidental radiological release in the event that the spent fuel poo!is drained. Once this zirconium fire scenario is assessed, we expect that offsite response capability can be eliminated and the scope of the onsite response cm be reduced. The onsite response is described in the Defueled Emergency Plan. The Defueled Emergency Plari provides reasonable assurance that adequate pretective measures will be taken for the defueled plant condition. Therefore, requiring Maine Yankee to comply with the requirements of 10 CFR50.54'q) would not serve the underlying purpose of the rule.

In addition, the significant costs involved with emergency planning activities associated with compliance with 10CFR50.54(q) outweigh the potential benefits. Because Maine Yankce is a permanently shutdown facility and no longer possesses a license authorizing reactor operation or placement or retention of fuel in the reactor, the limited resources at the site are dedicated to the safe storage of fuel and the preparations for decommissioning of the facility. The costs involved in complying with 10CFR50.54(q) would result in inefficient use of Maine Yankee resources. Therefore, Maine Yankee's compliance with the requirements of 10CFR50.54(q) would result in undue financial and administrative hardship to Maine Yankee, its owners and their ratepayers.

' Mindful of the effects on other plants yet to be decommissioned, it is important to note that Maine Yankee has undertaken the zircon'um fire analysis as a matter of expediency rather than a matter of regulatory compliance. Maine Yankee believes that a zirconium fire is outside the plant's licensing basis, is of sufficiently low probability as to fail the Backfit Rule test, and is an inappropriate basis for emergency planning. Nonetheless. it is clearly an extreme case that, if inapplicable to a facility, serves to bound any other emergency planning scenarios. Since Maine Yankee has been shut down since December,1996 the period of applicability of a zirconium fire is near completo. In order to avoid regulatory delays in processing the emergency planning exemption requests, whicn can be implemented early in 1998, the zirconium firo analysis is presently underway.

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Over a dozen power reactors have been permanently shut down and entered the decommissioning process. When the NRC promulgated the emergency planning requirements (10CFR50.47 and Appendix E), it was not envisioned that nuclear power plants would shut down and enter decommissioning prematurely before the end of their operating license.

NRC has acknowledged that the provisions of the current regulations do not provide clear guidance relative to the reduction of emergency planning requirements for permanently shut down plants. In fact, the interpretation that the emergency planning requirements of $50.47 and Appendix E no longer apply to a facility that has provided the certifications under 10CFR50.82(a), as Maine Yankee has done, was never contemplated by the NRC.

- As explained herein, the Maine Yankee plant, in its permanently shut down and defueled condition, poses a significantly reduced risk to the public health and safety. Certain requirements of 10CFR50.47(b) and Appendix E are no longer appropriate for which these exemption requests are submitted. Clearly, this is an exam)le of a special circumstance, pursuant to 10CFR50.12(a)(2), that was not consicered when the (emergency planning) regulations were adopted for which it would be in the public interest to grant an exemption. Reducing emergency planning requirements for permanently shutdown nuclear plants would result in a significant cost savings to licensees. Since the cost for emergency planning requirem3nts are ultimately bome by the public rate payers, it would be in public interest for the NRC to grant the requested exemption.

IV. CONCLUSION Maine Yankee has concluded that the requested exemption from 10CFR54(q)is justified, it is authorized by law, will not present undue risk to the public health and safety, and is consistent with the common defence and security. Such an exemption meets the requirements of 10CFR50.12(a)(2)(ii)in that maintaining emergency plans meeting the standards of 10CFR50.47 and Appendix E in the defueled plant condition does not serve the underlying purpose of the rula. Such an exemption also meets the requirements of 10CFR50.12(a)(2)(iii) in that compliance with the requirements to maintain emergency plans meeting the standards of 10CFR50.47 and Appendix E would result in undue costs for a facility in the decommissioning process.

V. ENVIRONMENTAL IMPACT Pursuant to the provisions of 10CFR50.12, Maine Yankee is mouesting exemption to the requirements of 10 CFR54(q) which requires the maintenance of emergency plans meeting the standards of 10CFR50.47 and Appendix E. The proposed exemption does not affect the type or quantity of radioactive or non-radioactive effluents and does not have a significant impact on the environment.

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ATTACHMENT 11 DEFUELED EMERGENCY PLAN EXCEPTIONS TO 10CFR50,47 AND APPENDIX E TO PART 50 Maine Yankee has decided to permanently cease operation of the Maine Yankee Plant.

" Certification of Permanent Cessation of Operation and Removal of Fuel from the Reactor Vessel" has been docketed in accordance with-10CFR50.82. The requirements in 10CFR50.47 and Appendix E to Part 50 are no longer appropriate in the defueled plant condition. Exceptions to 10CFR50.47 and Appendix E to Part 50 which are inherent in the Maine Yankee Defueled Emergency Plan and the requested exemption to 10CFR50.54(q) are described below.

REQUIREMENT PLAN BASIS 950.47 Emergency plans. 10CFR50.47(b)- Offsite emergency response plans are no longer appropriate as no design basis (b) The onsite end, cacep; a; provided in accident or credible beyond design basis accident peregraph (d) of 05l: ecc .en, .5 c emergency can result in radioactive releases which exceed response plans for nuclear power reactors must EPA's protective action guides E! the site boundary, meet the following standards:

(1) Primary responsibilities for emergency response 10CFR50.47(b)(1) thrrmgh (16) - The Defueled by the nuclear facility licensee and by Cic;c and Emergency Plan takes dxception to these standards l00;l ergon lc;;;en; vJ h;n th; Emcrgency I'!anning to the extent that they apply to offsite planning.

Eenes have been assigned, the m.~,r,m, Offsite emergency response capability is r.o longer rc; pen;;blF lc; cf the var;eu; eupport;ng appropriate as no design basis accident or credible orgn:ca;;en; hcvc bcca ;pecifica"i c;;;b;;;hed, beyond design basis accident can result in and eac61 principal response organization has staff radioactive releases which exceed EPA's protective to respond and to augment its action guides at the site boundary.

Initial response on a continuous basis.

(2) On-dift facility licensee responsibilities for 10CFR50.47(b)(2) - Exception is taken to the emergency response are unambiguously defined, requirement to specify interfaces with offsite support adequate staffing to provide initial facility accident and response activities in the onsite plan. Offsite response ir- key functiont I areas is maintained at emergency response capability is no longer j all times, timely augmentation of response appropriate as no design basis accident or credible

capabilities is availab!a and the interfaces among beyond design basis accident can result in l_ various onsite response activities and ch;c radioaclive releases which exceed EPA's protective supper;and action guides at the site boundary.

l rc; pen;c ac:L. :c; are specified.

l (3) Arrangements for requesting and effectively 10CFR50.47(b)(3) - Exception is taken to the l using assistance resources have been made, requirements to identify arrangements for requesting i arrangemca ; s accommedc:c C:c;c and lcca: and using offsite assistance in the onsite plan and to

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c Emcrgency making arrangements to accommodate State and E Opera;;en; fac;;;;y havc beca made, and local staff. Offsite emergency response capability is other organizations capable of augmenting the no longer appropriate as no design basis accident or i_

planned response have been identified. credible beyond design basis accident can result in I

radioactive releases which exceed EPA's protective action guides at the site boundary.

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(4) A standard emergency classification and action 10CFR50.47(b)(4) - Exception is taken to the level scheme, the bases of which include facility requirement that onsite plans identify information to system and effluent parameters, is in use by the be provided in support of offsite response measures.

nuclear facility licensee, er.d Obb and b;;l Offsita en,ergency response capability ,s no longer ieef~nec pba; ce" for appropriate as no design basis accident or credible idbase on infermeGen provldcd by fec5;y beyond - design basis accident can result in

!benn;; for d;brm'neSen; cf mb; mum NS;l radioactive releases which exceed EPA's protective e";;% se;pene;ine;;urce: action guides at the site boundary.

(5) Procedures have been established for 10CFR50.47(b)(5) - Exception is taken to the notification, by the licensee, of State and local requirements that onsite procedures be established response organizations and for notification of to notify offsite organizations and that the means be emorgency personnel by all organizations; the established for the notification of the public. Offsite content of initial and followup emergency response capability is no longer messages to response organizations and the pubnc appropriate as no design basis accident or credible has been established ,~ ,,,- ~ prov;de car!y beyond design basis accident can result in l netic Gen e ,d cb;r betrucGon to the popubcc radioactive releases which exceed EPA's protective withh the plum; ;;po;urc pathviay Emergency action guides at the site boundary.

' Ib .n'ng 20,0 h;V; b;;7 St:bnehad.

(6) Provisions exist for prompt communications 10CFR50.47(b)(6) - Exception is taken to the among principal response organizations to requirement that onsite plans provide for prompt emergency personnel and to the pub lb. communication with offsite response organizations and the public. Offsite emergency response capability is no longer necessary as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary.

(7) Micrmatbn i; madc av;;bblc te4hc pub lb on a 10CFR50.47(b)(7) - Exception is taken to the perbd;c ba;b on how they will bc noticd and what requirements to provide information to the public on thclr i,Uabeeber,; ;hould bc ln an cmcrgency (c.g., a periodic basis and to the requirement for lbbnbg to a bca; broadca;t ;bSon and icmabbg procedures for the coordinated dissemination of bdecre), the principal point: of contact with the information to the public. Offsite emergency news media for response capability is no longer appropriate as no dissemination of infon%"on during an emergency design basis accident or credible beyond design (bcludhg the phy;;ccl bcanon or lccatbn;) are basis accident can result in radioactive releases established in advance, and proccdurc; for which exceed EPA's protective action guides at the coordb;bd db;cmb;Uan of bbimaton to the site boundary, pubMc arc a;;abH;hcd.

(8) Adequate emergency facilities and equipment to No exception is being taken to this requirement.

support the emergency response are provided and maintained.

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(9) Adequate methods, systems, and equipment for 10CFR50.47(b){9) - Exception is taken to the i

assessing and monitoring actual or potential offsite requirement to have the capability to assess and consequences of a radiological emergency monitor offsite consequences. Offsite emergency conoition are in use, response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary.

(W) A rango of protectivo actions havc bccn 10CFR50.47(b)(10) - Exception is taken to t%*

developed for the plurnc exposuretethwey-Eb2-for requirement to develop protective actions for tne emergency v;orhers and the pub lic. Ouidclincs for plume exposure and ingestion pathway EPZ's.

the choice of protect lvc actions during on Offsite emergency response capability is no longer cracrgcncy, consistent-with appropriate as no design basis accident or credible Icdcic! guidance, arc devcl sped and in placo, and beyond design basis accident can result in protectivo acticas for the ingestien cxposure radioactive releases which exceed EPA's protective pethvecy E"2 approprietc to the !ccc!c haveteen action guides at the site boundary.

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(11) Means for controlling radiological exposures, No exception is being taken to this requirement.

In an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

(12) Arrangements are made for medical services No exception is being taken to this requirement.

for contaminated injured individuals.

(13) General plans for recove y and reentry are No exception is being taken to this requirement.

developed.

(14) Jeriodic exercises are (will be) conducted to No exception is being taken to this requirement.

evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.

(15) Radiological emergency response training is No exception is being taken to this requirement.

provided to those who may be called on to assist in an emergency.

(16) Responsibilities for plan development and No exception is being taken to this requirement.

review and for distribution of emergency plans are established, and planners are properly trained.

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(c)(2) Genera"y, the Numet=posufepettwerEPZ 10CFR50.47(c)(2) Exception is being taken to the foe +oolee+pouct p!cnts$hehottetstof to+ fee roouirement to establish plume exposure and about40+ni6esi464tm)intedeus+,nd4heingesteen ingestion pathway EPZ's. Offsite emergency pathwayW2-$helhoroistelen1c eetbout-60 response capability is no longer appropriate as no mi;asiB04tm)4niedtus. Theexactsireend design basis accident or credible beyond design conf.guretiert+f 4h6 EP2s+utroundtngeportveuter basis accident can result in radioactive releases nueleerpoweHeeetoNheltbe-detefmtnedin WhiCh exceed EPA's protective action guides at the reletett4e40ccl cmergener+esponseieedsend site boundary, eepobe'tt+ eses they-ete+ffectedby+uchtortdttens es demogeophy, tapsgrephy;4endtheteetemtees; eeeest+outes,-end jured+ettonefboundetes-TIM sire +f 4he EP2telsomey4>e<ietermined twe ee;c-by-casebesit4teges-cooled +tueleef 4eeetors emdfotiesetorswethen eutho+1redpoweN aveHess4hert?60 MW4hermeh Utoplane4eHhe-engem.nn pathwershelHoeusen suchtelions eseteeppf opfete toproteeHhe400d ingestion pathwety-Appendix E to Pprt 50 10CFR50 Appendix E.Ill Exception is being taken to the requirement to include in the FSAR information 111. The Final Eafety Analysis Report pertaining to offsite agencies and organizations, The Fhal Safety Analysis Report shall contain the Emergency Planning Zones, and protective plans for coping with emergencies. The plans shall measures. Offsite emergency response canability is be ar expression of Dc overall concept of no longer appropriate as no design basis accident or oporation; they shall describe the essential credible beyond design basis accident can result in elements of advanco planning radioactive releases which exceed EPA's protective tW hevo been considered and the provisions that action guidos at the site boundaty.

c a boon made to cope with emugency wiations. The plans shal' 'ncorporate information about the emergency response roles of supporting organizations endoffeite egenotes: That information shall be sufficient to provide assurance of coordination among the supportint, groups ard with tM licensee. Heplans subm red f"tusHneludetedesertpttontf-Ute element e-settut4nfeetto64V4oHhe-Ernor g c ncy PlanningfonesiEP2s}4eeft+wlent-stWeeeent totietMonstrete4hu theplent provide +eesoneble essutence4het-edequetepoteettve meesuresten tmd wi4He4ekefarv4he+ vent +f+,tenwwgetu y

IV. Content of Emergency Plans 10CFR50 Appendix E.IV Exception is being taken The applicant's emergency plans shac. contain, but to the requirements of this section to the extent they not necessanly be kmned ;. , information needed to apoly to offsite plans. Exception is also being taken demonstrate comphance with the elements set to the requirement to provide an analysia of the time forth below, i.e., organization for coping with required to evacuate and take othcr protective radiation emergencies, assessment action, actions. Offsite emergency response capabihty is no activation of emergency organization, notification longer appropriate as no design basis accident or procedures, emergency facihties and equipment, credible t,eyond design basis accident can result in training, maintaining emergency preparedness, and radioactive releases which exceed EPA's protective recovery. In oddition, the emergency response action guides nt the site boundary.

plans submitted by an applicant for a nuclear power reactor operating hcense shall contain information needed to demonstrate comphance with the standards described in $50.47(b), and they will be evaluated against those standards -The4meleef power +sactc4 cperettfv4,oenseepphoent+henelse provideenene'y2 of the4ime+equttedioeveeuete end forlekingetheftreteebyeeettons4of-vefious sectoteendtestyteeswethen4hc plumc exposutecethway@Mor4fensteniend permanent populehefe A. Organization 10CFR50 Appendix E.IV.A.2.c Exception is being The or0anization for coping with radiological taken to the requirement for an onsite coordinator emergencies shall be desenbed, including definition responsible for the exchange of information with of authonties, responsibilities, and duties of offsite authorities. Offsite emergency response individuals assigned to the licensco's emergency capabikty is no longer appropnate as no design basis organization and the means for notification of such accident or credible beyond design basis accident individuals in the event of an emergency. can result in radioactive releases which exceed Specifically, the following shall be includer' EPA's protective action guides at the site boundary.

1. A description of the normal plant opefettng or0anization.

2. A description of the onsite emergency response organization with a detailed discussion of:

a. Authorities, responsibilitics, and duties of the individual (s) who will take charge duriro an emergency;

b. Plant staff emer0ency assignments;

c. Authorities, responsibilities, and duties on an onsite emergency coordinatorwheshe%e4n chugeef 4he+wetmageef-infeemnbonwetheffsde eutherettesiesponsetde foetootth+mbngetwf implemenhngeffstle ef;ugancy .n asures-5

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3: A dn-.,,;M, by p:n-, ud fure:1. is k - 10CFR50 Appendix E.IV.A.3 Exception is being f F.;' c d. c' t'e ! en'; hnf , % e take1 to the requirement to describe licensee i p ;er.re: 2.; wil M e n;te *e p b';% to headquarters personnel that will be sent to the plant l

s v.e ntthe ecc:': ca e. g e y e: s i. b b . in an emergency. Response capability from headquarters is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which r exceed EPA's protective action guides at the site  ;

boundary. l

4. lic,;1 : n, by p;.:en e-4 'unc'.e to M 10CFR50 Appendix E.IV.A.4. Exception is being pd.;;ad, Of p;;en; ..?n th; lba;n taken to the requirements related to offsite dose aga; ..a. de wi" h ing ,;;bb 's n eUng projections. Offsite emergency response capability is

.~. 1.; p;.,.,/,en;, and a due..r:en c' Mv, no longer appropriate as no design basis accident or

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4 u,..,,n; wi" h ; ed; u d ; M i n u t credible beycnd design basis accident can result in ,

Wennt;/ td to 0:;t gi ;,, ' au;h .:.x, T,0, and radioactive releases which exceed EPA's protective e#mr app..y, M: ;;;..ncne. A e., te;. action guides at the site boundary.

5. OC..:J~.:.en, by pd:en and fune en 0; h 10CFR50 Appendix E.IV.A.5. Exception is being pde;-ed, c' e'Mr e..rk,,,s of tM %;;.x; wnh taken to the requirement to identify individuals with

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."a;a.; fc eeph; wnh e; e g ey special qualifications, Individuals with special eu.d1xe ;M n ey aree O'her pereen; wnh qualifications are no longer necessary as no desiga

p eblqu.!f.atbne,;uch a; consu% nt, d e ar; basis accident or credible beyond design basis nci ecc.rk,;;; c' th; ; n;3e accident can result in radioactive releases which endwM ;ei M sid spen for exibne;4ef exceed EPA's protective action guides at the site emergenesee ehe" 25 h ;de .

Odc The ege%l boundary.

qu;. On; c' th;x p;;en; eha" be de; . ,;d.

6. A description of the locel offsite services to be No exception is being taken to this requirement, provided in support of the licensee's emergency organization.

7. Identification of, and assistance expected from, No exception is being taken to this requirement.

appropriate State, local, and Federal agencias with responsibilities for coping with emergencies,

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• o 10CFR50 Appendix E.IV.A.8 - Exception is being

spn;;bb for pbaning for, cid;;;ng, and taken to the requirement to identify state or local a .

.e::b; apprep;bb pre:c;W; a;;h;, NLd.ng officials responsible for protective actions. Offsite

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e e wMn nen;nry, emergency response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary.

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B. Assessment Actions 10CFR50 Appendix E.IV.B Exception is being taken The means to be used for determining the to the requirements to identify the means used to magnitude of and for continually assessing the assess offsite releases of rcdioactivity, the i impact of the release of radioactive materials shall emergency action levels to be used in determining l be described, including emergency action levels the need for notification of and participation of offsite that are to be used as criteria for determining the agencies, the emergency action levels to be used in need for notification end pe%peSen of determining protective measures ouulde the site j looekwwl State agencies, the Commissionrand boundary, to confer and obtain concurrance on EALs ,

ethe; T;de e' er ~~; and the emergency action by state and local govemment author, ties, and the l levels that are to be used for determining when and approval and periodic review of emergency action {

~

what type of protective measures should be levels by offsite agencies. Exception is also being considered within and at;!d; the site boundary to taken to requirement for notification of local and protect health and safety The emergency action certain Federal agencies and for the participation of levels shall be based on in-plant conditions and offsite agencies. Offsite emergency response instrumentation in addition to onsite eMcNede capability is no longer appropriate as no design basis monitoring. These emergency action levels shall be accident or credible beyond design basis accident deoevooed and esteed ;- by 05s appOe.t e .d can result in radioactive releases which exceed 64eleend be p.;; ...~ . ! n;he..e; end EPA's protective action guides at the site boundary. ,

approved by NRC. They ehe";b be r:d;.;d ' nh the44ete-and LeJ g; san. Tent! atheriesen-en R. nee!'.:_ i ~

C. Activation of Emergency Organization 10CFR50 Appendix E.IV.C Exception is being taken .

The entire spectrum of emergency conditions that to the requirements related to the activation of the involve the alerting or activating of progressively emergency organization over a spectruns of larger segments of the total emergency accidents from unusual event through general ,

organization shall be described. The emergency, offsite notification and response, and communication steps to be taken to alert or offsite radiation munitoring. Offsite emergency ,

activate emergency personnet under each class of response capability is no longer appropriate as no emergency shall design basis accident or credible beyond design [

be described. Emergency action levels (based not basis accident can result in radioactive releases only on onsite endeHede radiation monitoring whicl, exceed EPA's protective action guides at the l' information but also on readings from a number of site boundary.

sensors that indicate a potential emergency, euch i et the prawra in ae:en-Tent and the ;c ;pene; ef th E.Tergency Oe ; Ose'ing Eye';;r.) for .

notification of offsite agencies shall be described. '

The existence, but not the details, of a message auther' ,ation scheme shall be noted for such agencies. The emergency classes defined shall include: (1) notification of unusual events, (2) alert, (B) ;n; aree eTe:gency, and (4) gene el eTe.pacy, These classes are further discussed in NUREG 0654; FEMA - RFP.1.

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- =. - . ~ - - - - - --.._ .- -._ -. - - - - . - . - . - . -

D. Notification Procedures 10CFR50 Appendix E.lV.D 1 Exception is being

1. Administrative and physical means for notifying taken to the requirements related to the notification ,

leeel, State, and Federal officials and agencies end of offsite agencies. Offsite emergency responsu l

eement;icached';;;nihc;ccEcie

tend capability is no longer appropriate as no design basis egene;;; for the prempt not;f; cat.cn of the pub lic accident or credible beyond design basis accident and for pub lb ccacuatbn or other pistectFic can result in radioactive releases which exceed meesureer-should thcy bceeme necc;;ary, EPA's protective action guides at the site boundary, shall be described. This dc;;;ipten ;hall include

?de .; f.eatbn of4he approprbic off;cbb, by itb cad agency, c! thc C cto and le-dgcicmment agencic; . in'a the EPZe(4) 2-Pfevtsions shall bc dc; cried 4et-yeerly .10CFR50 Appendix E.IV.D.2 - Exception is being db;cm'netbn to the public witMo4heplume taken to the requirements for yearly dissemination of e*pesure peu ;ccy EPZ cf bc;ic cmergency basic emergency planning information and for plenning infermetba, ach+s4he-fr.ethed; sad measures to be used to disseminate information to (tmes re ,u: red for pub lic not;f.catten transient populations. Offsite emergency response sad the protectric act;en; planned 4 an ace; dent capability is no longer appropriate as no design basis occurs, genera l ;nformetterres4e4hetetureend accident or credible beyond design basis accident effeefsef isdbtbn, and*4istingef lecs; broadce;t can result in radioactive releases which exceed station; 0.s.: wi" be u;cd for dissemenettonel EPA's protective action guides at the site boundary, interfnat;sa during an cmcrgency. Cigas er other measuretshs!! to be used4e dessemir.ato to any trensientpopulettertwethin4he plume-exposurepethivay EPZ approprtote informanca t%t wcv!d be he:pfahfen accidern eeettre-8

- _ . . . _ . . - . . - _ - - . . - - _-. -. - - ._ - .. - - - ~ . - . . - - -

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3. A licensee shall have the capability to notify 10CFR50 Appendix E.IV.D.3 Exception is being l responsible State and local governmental agencies taken to the requirement to notify offsite agencies l wWwt-Wmmdee after declaring an emergency, within fifteen minutes. Offsite ernergency response '

T've Mr.;;;SN" de.-TeV Y.u v. ;; t'T;fdste4eeel T capability is no longer appropriate as no design basis deele+eveee accident or credible beyond design basis accident

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, E. Emergency Facilities and Equipment 10CFR50 Appendix E.lV.E.8 Exception is being i Adequate provisions shall be made and described taken to the requirement for a near site emergency i for emergency facilities and equipment, including: operations facility. Offsite emergency response l

1. Equipment at the site for personnel monitoring; capability and the technical support center are no l

2. Equipment for determining the magnitude of and longer appropriate as no design basis accident or ,

for continuously assessing the impact of the credible beyond design basis accident can result in l release of radioactive materials to the environment; radioactive releases which exceed EPA's protective  !

3. Facilities and supplies at the site for action guides at the site boundary. I decontamination of onsite Individuals; i

4. Facilities and medical supplies at the site fer  !

appropriate emergency first aid treatment; l S. Arrangements for the services of physicians and i other medical personnel

, qualified to handle radiation emergencies on-site;

6. Arrangements for transportation of contaminated  :

injured individuals from the site to specifically identified treatment facilities outside the site boundary; _ _

7. Arrangements for treatment of individuals injured in support of licensed activities on the site at treatment facilities outside the site boundary; .

8. A licensee onsite technical support center-ende .

lhn;x r ,;n ;n; e.T.e.pacy eperet.vne LL y from which effective direction can be given and 4 effective control can be exercised during an +

emergency;

9. At least one onsite and one offsite 10CFR50 Appendix E.IV.9.a Exception is being communications system; each system shall have a taken to the requirement for communications with backup power source. contiguous state and local governments within the i All communication plans shall have arrangements plume exposure EPZ. Offsite emergency response for emergencies, including titles and attemates for capability is no longer appropriate as no design basis i those in charge at both ends of the communication accident or credible beyond design basis accidcnt links and the primary and backup means of can result in radioactive releases which exceed communication. Where consistent with the function EPA's protective action guides at the site boundary.

of the governmental agency, these arrangements will include:

a. Provision for communications with ee Qucus StatelleceFgovemments wn.nn :h; pb.; capeaur; pel e;y EPZ. Such communications shall be tested monthly.

b. Prcah for ee.T.rc.und h; wnh feder;l 10CFR50 Appendix E.IV.9.b Exception is being e.T.;;,ency;npen;;ergn hid e, Ouch taken to the requirement for communications with es.T T.u .h;M; sy;;;.T.; ;he:: b; tc;;;d annu;"y. Federal emergency response organizations. Offsite emergency response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary.

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l c Provision for communications a,nong the nuclear 10CFR50 Appendix E.IV.9.c Exception is being l power reactor control room, the onsite technical taken to the requirement for communications among j support conter, and the as: ;% en.e:gency the control room, the technical support center, and  ;

ep .. .; fee. , i; end e.T.W.; th; nu;:n: fee;nti, the emergency operations facility; and J the p ;ne:pe 00.:; end l.ee! :,.T;:gency oper.;!en; communications among the nu'9r facility, offsite eeMe ., u.d the 'e:d ;;;;;r.;nt txT.;. Such agencies and field teams. Onsite emergency communications systems shall be tested annually. response capability and the onsite technical support center are no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releasas which exceed ,

EPA's protective action guides at the site boundary.

d. Provisions for communications by the licensee with NRC Headquarters and the appropriate NRC 10CFR50 Appendix E.IV.9.d Exception is being Regional Office Operations Center from the nuclear taken to the requirement for communications power reactor control room, th; en;t techn se; between the NRC and the technical support center eupport eer.;er, and the and the emergency operations facility and the neef ;t e.T.;;;eney opere;;en; fe;sti. Such requirement for monthly testing of communications communications shall be tested tmmthly, between the licensee and the NRC. Offsite emergency response capability and the onsite  ;

technical support center are no longer appropriate as i no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary.

I1

F. Training. 10CFR50 Appendix E.IV.F.1 - Exception is being

1. The program to provide for: (a) The training of taken to the requirements for the training of licensee }

employees and exercising, by periodic drills, of headquarters' support personnel and a radiological j radiation emergency plans to ensure that orientation training program for local services ,

employees of the licensee are familiar with their personnel. Offsite emergency response capability i specific emergency response duties, and (b) The and headquarters response capability are no longer  !

participation in the training and drills by appropriate as no design basis accident or credible i other persons whose assistance may be needed in beyond design basis accident can result in .

the event of a radiation emergency shall be radioactive releases which exceed EPA's protective described. This shall include a description of action gulden at the site boundary, specialized initial training and periodic retraining  ;

programs to be provided to each of the following categories of emergency personnel:

1. Directors and/or coordinators of the plant emergency organization; .

11. Personnel responsible for accident assessment, including control room shift personnel; l Ill Radiological monitoring teams; .

iv. Fire control teams (fire brigades);

v. Repair and damage control teams; vi. First aid and rescue teams; l} Medical support personnel, v;;;. Lbenx;'; tedweite,; ;upport p;;;enic ;

ix. Security personnel.

b add;;ba, a redt'e,ee ment:ba tre;n;ng progeom;te" b; .Ted; ;;;:bMe to bee wrsbe; pe ;ennel; :.g., bee l emer,er.;i ;; reb;;/Oivil C;fonn, bee: b.; enbreement perserrc!, be;l n:;c: :nedt per;en;.

2. The plan shall describe provisions for the 10CFR50 Appendix E.IV.F.2 - Exception is being conduct of emergency preparedness exercises as taken to the requirement to test the public notification follows: Exercises shall test the adequacy of timing network.

and content of implementing procedures and Offsite emergency response capability is no longer methods, test emergency appropriate as no design basis accident or credible equipment and communications networksdeeHhe beyond design basis accident can result in puMb re;;fbe ba ey;;;T, and ensure that radioactive releases which exceed EPA's protective emergency organization personnel are familiar with action guides at the site boundary.

their duties.(3)

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_. i . _ - _ ______i _ __ _ , _ _ _ . , _

_ _ . _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ~ _ _ _ _

I

b. Each licensee at each site shall conduct an 10CFR50 Appendix E.IV.F.2.b - Exception is being exercise of its onsite emergency plan every 2 taken to the requirement for exercises and drills to  :

years. The as. x, ; ai b; b;/uded in t'a fu!! include protective action decision making, the f w;1,ir, th .nb: e,em.,e ;;uced by Technical Support Center and the Emergency p;.;egeph 2.0 e' '.b eee:en. In addition, the Operations Facility. Offsite emergency response l licensee shall take actions necessary to ensure that capability is no longer appropriate as no design basis i adequate emergency response capabilities are accident or credible beyond design basis accident l maintained during the interval between biennial can result in radioa':tive releases which exceed exercises by conducting drills, including at least EPA's protective action guides at tf'e site boundary, ,

one drillinvolving a combination of some of the l principal functional areas of >

the licensee's onsite emergency response capabilities. The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, p;eb;0c; ec ba desbba 7 ekb;; and plant system repair and corrective actions. During these drills, activation of all of the licensee's emergency response facilities (Ted.nbe! Supped Oen;e; (T6GkOperetiens '

Supped Cent; (OSC), and th; En.e gency Op.re:.e a reduti (EOF)) would not be necessary, licensees would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills could focus on onsite training objectives, erO";;b pbn; for ;;;h ::b ;ha" b; cx;;; bed 10CFR50 Appendix E.IV.F.2.c - Exception is being b'ennblly adh fu!! pads p;'bn by coch e";;% taken to the requirement for a biennial exercbe with

uthe;4i husb; a reb under the pbn "!h;;; th; full participation of offsite authorities. Offsite e";

0 aub. i e;ha rob under ; radb'esbe emergency response capability is no longer

pen;; pba for er; then eie ; 2, it ;he" funy appropriate as no design basis accident or credible pedt

p;b b enc cxereb; ;very two y;;;; and beyond design basis accident can result in *

he", at be;;, podt"i padb;p;.Z(5) in other e"; 2 radioactive releases which exceed EPA's protective pbn ;;;;;ac ; it thb perbd. action guides at the site boundary.

d. A Ott ;heu!d is"y penkip;2 i.. th; bs;;;b . 10CFR50 Appendix E.IV.F.2.d - Exception is being peJ.;;;y pedbn of ;xc;;b;; at k;~;; ence recri sb taken to the requirement for an ingestion pathway yee ;. b 00%; w;;h cer; : hen en; ;;2, :h; State exercise. Offsite emergency response capability is feu!d i;LZ thb pad;dpetan frem ;l2 te ;;t. no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the : Le boundary.

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. - - - - . - - - ~.

e. Licensees shall enable any Stat; e- !;ee' 10CFR50 Appendix E.IV.F.2.e Exception is being Govemmerd l-:-::::d ;.".h the ph.n.e 0,+;; ;; taken to the requirement that licensees allow local i-.;; ;;;; CZ to participate in the licensee's drills authorities within the plume exposure EPZ to when requested by such State eHeeni participate in drills. Offsite emergency response Government. capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site'ooundary.

1

f. Remedial exercises will be required if the 10CFR50 Appendix E$1V.F.2.f Exception is being emergency plan is not satisfactorily tested during taken to the requirement for remadial exercises the biennial exercise, such that NRC, in related to biennial exercises. Orfsite emergency e .a.:.. :.x, wnh IC'."., cannot find reasonable response capability is no longer appropriate as no -

assurance that adequate design basis accident or cradible beyond design prctective measures can be taken in the event of a bcsis accident can result in iadioactive releases radiological emergency. The sca:ef C:::; and which exceed EPA's protective action guides at the looedi ,.c:Mp :.-, h seinedd ;x;;eiseemueWe site boundary. ,

sufficeerd4e ;h;w ;he: app:;p;b:; ;e. . e;;;c; n,; ; ;e. h;; b;;;. ;;h;n rese dbg the i..en;;

of th; pic, act p;eps;lit emd b the p;;2u; ewereewee-

g. All training, including exercises, shall provide for No exception is being taken to this requirement.

formal critiques in order to identify weak or deficient areas that need correc9on. Any weaknesses or deficiencies that are identified shall be corrected.

h. The participation of State and local governments No exception is being taken to this requirement.

In an emergency exercise is not required to the extent that the applicant has identified those governments as refusing to participate further in emergency planning activities, pursuant to 10 CFR 50.47(c)(1). In such cases, an exercise shall be held with the applicant or licensee and such governmental entities as elect to participate in the emergency planning process.

G. Maintaining Emergency Preparedness No exception is being taken to this requirement.

Provisions to be employed to ensure that tho emergency plan, its implementing procedures, and emergency equipment and supplies are maintained up to date shall be described.

H. Recovery No exception is being taken to this requirement.

Criteria to be used to determine when, following an accident, reentry of the facility would be appropriate or when operation could be resumed shall be described.

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V. Implementing Procedures No exception is being taken to this requirement.

No less than 180 days prior to the scheduled issuance of an operating license for a nuclear power reactor or a license to possess nuclear material the applicant's detailed implementing procedures for its emergency plan shall be submitted to the Commission as specified in $50.4.

Licensees who are authorized to operate a nuclear power facility shall submit any changes to the emergency plan or procedures to the Commission, as specified in $50.4, within 30 days of such changes.

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f ATTACHMENT lil DEFUELED EMERGENCY PLAN 1