ML20205Q997

Requests NRC Approval of Plant Defueled Station Emergency Plan in Accordance with 10CFR50.54(q).Ltrs of Agreement Between Util & Offsite Agencies Who Have Agreed to Provide Assistance to Plant Encl.Calculations Also Encl

ML20205Q997
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/13/1999
From:	Krich R COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205Q999	List: ML20205Q997 ML20205R024 ML20205R050
References
NUDOCS 9904220148
Download: ML20205Q997 (5)

Text

Commonwealth lidiwn Company 1400 Opus Place Downers Grove, 11. 60515-5701 l

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l April 13,1999 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304 l

Subject:

Request for Approval of Defueled Station Emergency Plan and Exemption from 10 CFR 50.47(b) and 10 CFR 50.47(c)(2) l

Reference:

NRC letter, " Certification of Permanent Cessation of Operation and I Permanent Removal of Fuel from the Zion Nuclear Power Station, .

Units 1 and 2," dated May 4,1998  !

! l In accordance with 10 CFR 50.54(q), we are requesting Nuclear Regulatory /

Commission (NRC) approval of the Zion Nuclear Power Station (ZNPS) Defueled Station Emergency Plan. In the referenced letter, the NRC acknowledged that, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licent.cs for ZNPS, Units 1 h ,

and 2 no longer authorize operation of the reantors or emplacement or retention of fuel in the reactor vessels. ZNPS poses a significantly reduced risk to public health and safety in this condition. As shown in Attachment 5, " Radiological Consequences of Postulated Events at ZNPS," it is no longer possible for the radiological consequences of accidents at ZNPS to exceed the limits of the Environmental Protection Agency (EPA) Protective Action Guides at the exclusion area boundary. Commensurate with this reduction in risk, we are proposing to replace our current emergency plan for ZNPS with the Defueled Station Emergency Plan.

The enclosed Defueled Station Emergency Plan discontinues offsite emergency l planning activities and reduces the scope of onsite emergency planning in light of

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m A Unicom Company L

April 13,1999 '

U. S. Nuclear Regulatory Commission Page 2 l the substantially lower offsite radiological consequences of accidents possible at i ZNPS. Although the proposed plan will not meet all the standards of 10 CFR 50.47(b) and the requirements in appendix E of 10 CFR 50, since the licenses for )

ZNPS no longer authorize operaticn of the reactors, the requirement of 10 CFR {

50.54(q) to follow and maintain in effect emergency plans which meet the '

standards in 10 CFR 50.47(b) and the requirements in appendix E of 10 CFR 50 l no longer applies. Nevertheless,10 CFR 50.54(q) requires prior NRC approval of proposed changes to emergency plans that do not continue to meet the standards of 10 CFR 50.47(b) and the requirements in appendix E of 10 CFR 50. , " Requested Exemption from 10 CFR 50.47(b) and 10 CFR 50.47(c)(2)," identifies the standards of 10 CFR 50.47(b) that would continue to be met. Attachment 2, "Defueled Station Emergency Plan Compliance with Section IV of Appendix E to Part 50," identifies the requirements of Section IV of appendix E to 10 CFR 50 that would continue to be met.

1 In accordance with 10 CFR 50.12(a), we are requesting an exemption from I certain standards in 10 CFR 50.47(b) that apply to nuclear power reactors regarding onsite and offsite emergency response plans. We are also requesting an exemption from 10 CFR 50.47(c)(2) which requires plume exposure and ingestion pathway emergency planning zones to be established for nuclear power plants. Since appendix E of 10 CFR 50 only applies to applicants for an operating license, an exemption is not being requested from the requirements of Section IV of appendix E that will no longer be met. Attachment 1, " Requested Exemption from 10 CFR 50.47(b) and 10 CFR 50.47(c)(2)," identifies the specific requirements in these regulations that are the subject of the exemption request.

As explained in Attachment 3,

• Exemption Request," the NRC may grant this requested exemption since it would be authorized by law, would not present an undue risk to the public health and safety, and would be consistent with the common defense and security. Additionally, special circumstances as defined in 10 CFR 50.12(a)(2) are present and explained in Attachment 3, " Exemption Request."

We have discussed the proposed Defueled Station Emergency Plan with the state agencies in Illinois and Wisconsin who are responsible for implementation of the current emergency plan for ZNPS. Their review and concurrence with the proposed plan are documented in letters contained in Attachment 4, " Letters of Concurrence from State Agencies."

Letters of agreement between Commonwealth Edison (Comed) Company and offsite agencies who have agreed to provide assistance to ZNPS during an emergency are enclosed with the proposed Defueled Station Emergency Plan.

April 13,1999 U. S. Nuclear Regulatory Commission  !

Page 3 The proposed Defueled Station Emergency Plan has been reviewed and approved in accordance with the Comed Quality Assurance Program.

We are requesting NRC approval of the proposed Defueled Station Emergency I Plan and related exemption request by June 1999. If not approved in this timeframe, we will need to begin planning for a ZNPS Generating Station Emergency Plan exercise of the offsite emergency plan in 1999.

If you have any questions about this letter, please contact K. A. Ainger at (630) 663-7350.

Respectfully, R. M. Krich Vice President - Regulatory Services Enclosure Attachments cc: Regional Administrator- NRC Region til (two copies) l l

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bec: NRC Project Manager, NRR - Zion Nuclear Power Station Decommissioning Branch Chief- NRC Region lli l

Office of Nuclear Facility Safety, IDNS Vice President - Renulatory Services Licensing Director, Zion /Dresden Unit 1 Decommissioning Emergency Preparedness Manager Regulatory Assurance Manager-Zion Nuclear Power Station l N. J. Reynolds -Winston and Strawn Document Control Desk - Licensing (hard copy) l l

Document Control Desk - Licensing (electronic copy) '

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Enclosure 1

l Zion Nuclear Power Station I 1

Defueled Station Emergency Plan and 4 Letters of Agreement with Offsite Agencies

1. City of Zion - ambulance, fire and police services Comed letter, " Biennial Letter of Agreement," dated February 18,1999

2. Teledyne Brown Engineering - environmental monitoring Comed memo to file, "Non-Comed Support Organization Letter-of-Agreement," dated May 28,1996

3. Victory Memorial Hospital- treatment of contaminated, injured person Comed letter, " Biennial Letter of Agreement," dated February 18,1999