ML20207F676

Summary of 990222 Meeting with NEI Re Decommissioning of Power Reactors.Meeting Also Focused on NEI Views on Appropriate SRP for Staff to Use as Basis for Evaluating Licensee Applications for EP Related Licensing Actions

ML20207F676
Person / Time
Issue date:	03/05/1999
From:	Larry Wheeler NRC (Affiliation Not Assigned)
To:	Weiss S NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9903110298
Download: ML20207F676 (43)

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t NUCLEAR REGULATORY COMMISSION WASHINGTON, D.c. 2066H001 8 March 5, 1999 k . . . . . ,o MEMORANDUM TO: Seymour H. Weiss, Director Non-Power Reactors and Decommissioning Project Directorate Division of Regulatory improvement Programs Office of Nu.: lear Reactor Regulation FROM: Louis L. Wheeler, Senior Project Manager Non-Power Reactors and Decommissioni

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Project Directorate Division of Regulatory improvement Programs Office of Nuclear Reactor Regulation

SUMMARY

OF FEBRUARY 22,1999, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING DECOMMISSIONING OF POWER REACTORS On February 22,1999, representatives of Nuclear Energy institute (NEI) Decommissioning Working Group and the NRC staff met to discuss NEl perspectives on the appropriate priorities for ongoing and planned NRC staff actions for decommissioning power plants. The meeting also focused on NEl views on an appropriate Standard Review Plan (SRP) for the staff to use as a basis for evaluating licensee :2pplications for emergency preparedness related licensing actions. In a meeting between the Working Group and the NRC staff on January 13,1999, it -

had been agreed that such a meeting would be a useful step in the process for developing the regulatory framework for regulating decommissioning power plants. A list of attendees at the February 22,1999, meeting is attached (Attachment 1).

Mr. Collins, Director, NRR, emphasized the importance of this forum, and other opportunities for exchanging information, such as the Regulatory Information Conference, as a me.ans of identifying issues and developing their resolutions in a more timely manner. Mr. Greeves, Director, NMSS/DWM and the NRC Decommissioning Program Manager, briefly discussed the importance of the Decommissioning Management Board and noted some time will be required for the Board to adjust tc changes being made by the pending reorganization of several NRC staff elements involved in the decommissioning process.

Following-up on a discussion during the January 13,1999, meeting, Mr. Meisner, Chairman, NEl Working Group, shared with the NRC staff a Working Group document entitled " Mission .

Statement," noting that it should be useful to the staff in understanding the Group's focus and direction. It was also noted the Group had a meeting scheduled for the next day. A copy of the

• Mission Statement," is attached (Attachment 2).

Mr. Meisner then distributed a document entitled,

• Industry Perspectives on Need for Guidance and Rulemaking in Decommissioning." This document contains current NEl perspectives on CONTACT: Duke Wheeler, DRIP /NRR Ob 415-1444 4+,4 .. y 9903110298 990305 PDR REVGP ERONUMRC pr!eyN 88MBCOPY w

E-e Seymour H. W;iss 1 which actions should be categorized as high, medium and low priority. Referring to substantial

[ financial costs associated with the time it has taken for the staff to complete various licensing actions, Mr. Meisner offered the view that the staff should strive to complete licensing actions in 1 to 2 months, similar to past staff performance during the time when Licensing Project Managers prepared a substantially greater po; tion of safety evaluations than they have prepared in more recent times. Mr. Greeves noted that an appropriate level of caution needs to be taken to ensure plant specific licensing actions are consistent with related ongoing generic activities. Items focused on during the discussion on priorities included License Termination Plans (LTPs), guidance for Project Managers on the disposition of outstanding commitments, the Maintenance Rule, and possible opportunities for risk-basing applicable regulations. A copy of " Industry Perspectives ..." is attached (Attachment 3).

During the discussion on priorities, Mr. Greeves shared with NEl a copy of a January 26,1999, letter from EPA Region I to the NRC Atomic Safety and Licensing Board which discussed EPA Region i views on the NRC process for evaluating the Yankee Rowe LTP. A copy of the letter is attached (Attachment 4).

NEl handed out copies of a document titled " Standard Review Plan, Emergency Plan Exemption Request for Permanently Defueled Facilities" (SRP). NEl noted they plan to develop additional SRPs, for other appropriate areas of interest. Mr. Collins recognized the value of further dialog with NEl documented in the public recorrt on this subject, and further noted the need for the NRC staff to meet as a team to develop an integrated plan. Mr. Richards was identified as the NRC staff point of contact. A copy of the NEl handout is attached (Attachment 5). A related document titled " Attachment 1, Exemptions to 10 CFR 50.54(g),10 CFR 50.54(t),

10 CFR 50.47, and Appendix E to Part 50" was handed out and a copy is attached (Attachment 6).

Attachments: As stated cc w/ attachments:

See next page DISTRIBUTION:

HARD COPY 90entulMes2 PUBLIC SWeiss Stewis, OGC (015-B18)

PDND R/F MMasnik SMagruder (011-F1) DWheeler EHylton CTrottier (T9-C24)

ACRS E-MAIL COPY SCollins/RZimmerman (SJC1/RPZ)) DMatthews (DBM)

BSheron (BWS) JZwolinski(JAZ) i JGreeves (JTG1) SRichards (SAR) l TJohnson(TCJ) RAuluck (RCA)

DWheeler (DXW) AHodgdon (APH)

MWebb (MKW)  !

PD PDRD:(A)SC P. ,

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Seymour H. W:iss which actions should be categorized as high, medium and low priority. Referring to substantial financial costs associated with the time it has taken for the staff to complete various licensing actions, Mr. Meisner offered the view that the staff should strive to complete licensing actions in 1 to 2 months, similar to past staff performance during the time when Licensing Project Managers prepared a substantially greater portion of safety evaluations than they have prepared in more recent times. Mr. Greeves noted that an appropriate level of caution needs to be taken to ensure plant specific licensing actior.s are consistent with related ongoing generic )

activities. Items focused on during the discussion on priorities included License Termination l Plans (LTPs), guidance for Project Managers on the disposition of outstanding commitments, i the Maintenance Rule, and possible opportunities for risk-basing applicable regulations. A copy of " Industry Perspectives . ." is attached (Attachment 3).

During the discussion on priorities, Mr. Greeves shared with NEl a copy of a January 26,1999, ,

letter from EPA Region I to the NRC Atomic Safety and Licensing Board which discussed EPA j Region I views on the NRC process for evaluating the Yankee Rowe LTP. A copy of the letter l I

is attached (Attachment 4).

NEl handed out copies of a document titled " Standard Review Plan, Emergency Plan Exemption Request for Permanently Defueled Facilities" (SRP). NEl noted they plan to develop additional SRPs, for other appropriate areas ofinterest. Mr. Collins recognized the value of further dialog with NEl documented in the public record on this subject, and further noted the i need for the NRC staff to meet as a team to develop an integrated plan. Mr. Richards was  !

identified as the NRC staff point of contact. A copy of the NEl h::ndout is attached (Attachment l 5). A related document titled " Attachment 1, Exemptions to 10 CFR 50.54(g),10 CFR 50.54(t),

10 CFR 50.47, and Appendix E to Part 50" was handed out and a copy is attached (Attachment 6).

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Attachments: As stated cc w/ attachments:  ;

See next page l

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DISTRIBUTION:

HARD COPY Central Files PUBLIC ,

SWeiss Stewis, OGC (015-B18) l PDND R/F MMasnik l SMagruder (011-F1) DWheeler ,

EHylton CTrottier (T9-C24) I

ACRS

E-MAIL COPY SCollins/RZimmerman (SJC1/RPZ)) DMatthews (DBM)

BSheron (BWS) JZwolinski(JAZ)

J JGreeves (JTG1) SRichards (SAR)

TJohnson(TCJ) RAuluck (RCA)

DWheeler (DXW) AHodgdon (APH)

MWebb (MKW) O g1 PD .

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/ l DW eler MM,asnik ton S ei's 3/ f/99 3/$ /99 3/ /99 3/f/99 OFFICIAL RECORD COPY DOCU M E NTNAM E:G SS ECY\MTG_NOTC\2-22 S U M I

e Seymour H. Weiss which actions should be categorized as high, medium and low priority. Referring to substantial financial costs associated with the time it has taken for the staff to complete various licensing actions, Mr. Meisner offered the view that the staff should strive to complete licensing actions in 1 to 2 months, similar to past staff performance during the time when Licensing Project Managers prepared a substantially greater portion of safety evaluations than they have prepared in more recent times. Mr. Gr3 eves noted that an appropriate level of caution needs to be taken to ensure plant specific licensing actions are consistent with related ongoing generic activities. Items focused on during the discussion on priorities included License Termination Plans (LTPs), guidance for Project Managers on the disposition of outstanding commitments, the Maintenance Rule, and possible opportunities for risk-basing applicable regulations. A copy of " Industry Perspectives . ." is attached (Attachment 3).

During the discussion on priorities, Mr. Greeves shared with NEl a copy of a January 26,1999, letter from EPA Region I to the NRC Atomic Safety and Licensing Board which discussed EPA Region i views on the NRC process for evaluating the Yankee Rowe LTP. A copy of the letter is attached (Attachment 4). ,

NEl handed out copies of a document titled Standard Review Plan, Emergency Plan Exemption Request for Permanently Defueled Facilities" (SRP). NEl noted they plan to develop additional SRPs, for other appropriate areas of interest. Mr. Collins recognized the value of further dialog with NEl documented in the public record on this subject, and further noted the need for the NRC staff to meet as a team to develop an integrated plan. Mr. Richards was identified as the NRC staff point of contact. A copy of the NEl handout is attached (Attachment 5). A related document titled " Attachment 1, Exemptions to 10 CFR 50.54(g),10 CFR 50.54(t),

10 CFR 50.47, and Appendix E to Part 50" was handed out and a copy is attached (Attachment 6).

l Attachments: As stated I

cc w/ attachments- i See next page 1

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. Nucle:r Energy Institut)

Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Ni": lear Officer Nuclear Energy Institute Nuclear Energy .nstitute Suite 400 Suite 400 1776 i Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.

Suite 400 12300 Twinbrook Parkway, Suite 330 1776 i S eet, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. Michael Meisner, President Mr. David Modeen, Director Maine Yankee Atomic Power Company Engineering 321 Ferry Road l Nuclear Energy Institute Wiscasset, ME 04578 Suite 400 1776 l Street, NW Arthur Rone Washington, DC 20006-3708 GPU Nuclear, Inc.

P.O. Box 480 Mr. Anthony Pietrangelo, Director Middletown, PA 17057 Licensing I' Nuclear Energy Institute A. Edward Scherer Suite 400 S uthern California Edison Company 1776 i Street, NW p . x$2 Washington, DC 20006-3708 San Clemente, CA 92674-0128 Mr. Nicholas J. Liparulo, Manager Alan Nelson Nuclear Safety and Regulatory Activities Nuclear Energy Institute Nuclear and Advanced Technology Division Suite 400 Westinghouse Electric Corporation 1776 I Street, NW P.O. Box 355 Washington, DC 20006-3708 Pittsburgh, Pennsylvania 15230 1 N. Chapman Mr. Jim Davis, Director Bechtel Operations 9801 Washingtonain Blvd.

Nuclear Energy Institute Gaithersburg, MD 20878 Suite 400 l 1776 I Street, NW C. Amoruso I

Washington, DC 20006-3708 th g, 20878 l

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NRCINEl MEETING ON NEl PRIORITIES LIST OF ATTENDEES February 22,1999 t NRC Samuel Collins NRR (301)415-1270- l John Zwolinski NRR,DLPM (301)415-1453 l David Matthews NRR, DRIP (301) 415-1199 John Greeves NMSS, DWM (301) 415-7437  :

Stuart Richards NRR/DLPM/PDill-2 (301) 415-1395 Timothy Johnson NMSS/DWM/LLDP (301) 415-7299 I Raj Auluck NRR/ DRIP /PGEB (301)415-1025 Louis Wheeler NRR/ DRIP /PDND . (301)415-1444 '

Ann Hodgdon OGC (301) 415-1587 Stephen Lewis OGC (301)415-1934 Michael Webb NRR/ DRIP /PDND (301)415-1347 i

NEl Michael Meisner MYAPC (207) 882-5700 Arthur Rone GPUN (973) 316-7500 A. Edward Scherer SCE (949) 368-7501 Lynnette Hendricks NEl (202)739-8109 Alan Nelson NEl (202) 739-8110 PUBLIC '

N. Chapman SERCH/Bechte! (301) 417-3771 C. Amoruso NUS Information Services (301) 258-2548 i

i ATTACHMENT 1 l l

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a MISSION STATEMENT Decommissioning Working Group Mission:

Provide executive oversight for strategic aspects of decommissioning including risk informed regulations for decommissioning and site clcanup/ license termination, dry cask storage, and low level waste. Executive oversight is required to provide strategic direction and to interface with hTC Commissioners and senior level management and members of Congress, where appropriate, to ensure industry's strategic objectives are met.

Strategic Objectives:

1. Work with hTC to ensure safe, timely decommissioning by:

. Devoting resources to process critical reviews in a timely manner. )

. Developing decommissioning requirements that accurately reflect the reduced risk posed by shutdown plants. A Commission determination j that the backfit rule applies to decommissioning issues is essential to this j process.  ;

. Supporting alternatives to traditional decommissioning approaches, e.g.,

entombment.

. Correcting NRC's funding formula to reflect accurate low-level waste disposal costs and expedite revision of NRC rules to permit use of site '

specific funding methodology in lieu of NRC's formula to set minimum funding levels.

. Ensuring timely completion of NRC rulemakings to reduce or eliminate operating requirements that are not applicable to permanently shutdown plants. e.g., emergency prepa.*dness, fire protection, safeguards.

2. Site Cleanup and License Termination

. Work through Congress to prevent EPA from listing decommissioned sites on Superfund and, ultimately, to resolve overlap in regulatory authority by removing EPA from radiation issues. EPA's challenge to NRC's recently promulgated dose based standard undermines industry's efforts to ensure adequate funding for decommissioning by adding uncertainty and lack of finality to site cleanup standards.

. Work with NRC to ensure timely decisionmaking on survey methodology and dose assessment issues related to license termination.

3. ' Deployment of dry cask storage in time to meet industry's decommissioning needs:

. Work with NRC to ensure approaches and resources for licensing dry cask storage systems are appropriate to meet industry's needs for plant ATTACliMEfr 2

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a operability and decommissioning. Executive oversight will help ensure  !

NRC meets its ambitious goals ofissuing SERs for casks in one year and  !

that their " rules of engagement" for the licensing process are appropriately applied to meet industry needs.

. Provide executive oversight to help ensure that industry is working to ensure excellence in licensing, fabrication and deployment of dry cask .

storage. The public is - ery interested in dry cask storage. Mistakes in implementation will severely impact industry's ability to deploy dry cask storage in a timely manner.

4. Safe,~ reliable, economical low level waste disposal for decommissioning. 3

. Provide the decommissioning perspective to the NEI LLW Working i Group for retaining access to existing national facilities, i.e., Barnwell  :

and Envirocare.

. Provide the decommissioning perspective to the LLW Working Group  :

to re-assess the value of regional siting efforts.

. Provide the decommissioning perspective to the NEl LLW Working Group on developing a contingency plan fo'r industry driven disposal  ;

solutions. (Alternatives to evaluate include gaining wider access to i Hanford, gaining access to DOR disposal facilities, and private disposal l

/ storage projects.)  ;

e Work with NRC and industry to get site specific approvals and rulemaking for clearance of materials.

. Support rulemaking to address storage of greater than Class C low- i level waste at decommissioned sites.

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c-I Industry Perspective on Need for Guidance and Rulemaking in  ;

- Decommissioning '  !

HIGH PRIORITY FOR INDUSTRY I

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1. Final Standard Review Plan on Doeommmiomne Power Reactors i

. NRC Status: On hold.' l 1

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. INDUSTRY PERSPECTIVE: We will provide industry's input by Slarch.

Providing review and acceptance criteria will streamline process for approval of critical approvals for EP. Safeguards. financial protection and Tech. Specs. j Streamlimne should permit NRC to grant approvals within 12 months of a  ;

submittal m lieu of the G-months to one year today. The cost savings for I these avoided delays are on the order of 5-6 million dollars per plant per year of delay.

2. Draft Guide on Free Releare of.ilaterial from Nuclear Power Reactors During -;

Decommissioning. j

. ' Status: NRC plans to ioue m 2001.

. INDUSTRY PERSPECTIVE: Industry needs workable guidance much l sooner than this. We plan to propose Tech. Spec. changes that will provide l relief on a site specific pilot plant basis this year that is comparable to what will ultimately be accomplished on a generic basis through rulemaking. I Estimates m cost savmes rance from S500.000 S2 million. Since NAISS is doing the rule shouldn't the cuidance come from them also?

3. Emergency Preparedness Rule

. Status: NRC want- to have;a proposed rule in early 1999.

L . INDUSTRY PERSPECTIVE: . Use input from interactions with industry on SRPs. Cost savings to avoid delays could be SDI per plant per year. _

4. Physical Security /Safecuards Rule L

• Status: NRC 13 developing technicalhasis and rulem king plan.

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. INDUSTRY PERSPECTIVE: NRC should use SRPs to inform rulemaking.  ;

Cost savinus will exceed SDI per plant per year.  !

5. Financial Protr etion Rul- i

. Status: NRC may hold off and revise to be consistent with EP and security I rules.

ATTAONENT 3 e

. INDUSTRY PERSPECTIVE: Agree that NRC should wait. Potential cost savings are S2.\1 per plant per year for single umt plants. Sites with other operating plants would save the portion resulting from being released from participation in the industry pool providine secondary offsite coverage for the plant and some proportion of cite premiums for primary on site and off site coverace.

6. Final Reculatory Guide 1078. " Standard Format and Content of License Termination Plan + for Nuclear Power Reactor-

• Status: Industry requested cuidance +o that acreement can be reached up front prior to large mvstments in surveys.

. INDUSTRY PERSPECTIVE: Co-t -avine- t ould ea.-ily exceed S1 milhon if

-urvey- do not neod in be repeated T. Draft Standard Review Plan for Licen* Termination Plans for Nucb>ar Power Reactor <

. $1.i t u 3. G uidanet ir int. n h ! t. -.irt thi< tich r ams of cuidance on surveying and dose modehne and het what i+ appheable for reactors. The guidance should recocmre that there is a balance between the amount ofinformation availahle e:irlV in and th. n "i t. hav. .tn alipr,ived ;lan I to proceed with activitie-

. INDUSTRY PERSPECTIVE: Industry requested this cuidance. It needs to be mformed with experience oflead plants. Cnet savings would be significant in industry preparation and NRC review time. Industry savines could easily exceed S1 milhon p.er plant

.TIEDIU.TI PRIORITY FOR INDUSTRY

}. NEW ITE.Tl Reipir-te.1 by indu-t ry: Information Notice to industry rtating that fitnes8 for duty, station blackout. heensed operator requirements (50.54 i-m).and the trainine rule do not apply to decominissionine plants.

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1 SECY to Cammt-smn on Entombment

. Statu- Due to Commi-ston June 19m Will probably recommend rulemakmc tolake On-year hmitation out of the current rule and to provide Criteria for entoiiibment

. INDUSTRY PERSPECTIVE: Indu.,try -upports it if entombment criteria are reasonable. We succe-i NRC work with the industry to develop these criteria.

3. Draft Guidance on Incremental Site Release at Facilities Undergoing Decommissioning

. Status: NRC intends to publish in the year 2000. Anticipating problems with piecemeal site release obviating opportunity for public meeting on site termination. Alco harmg problems defmme site for older plants.

INDUSTRY PERSPECTIVE: Support need for cuidance. Should N3ISS be domg thie?

4. New Item: Develop Guidance for P.W to dispostion outstanding commitments.

e.e.. license conditions. outstandme orders, confirmatory action letters etc.

5. New Item: Update GEIS with recent expenence.

LOW OR NO PRIORITY FOR INDUSTRY

1. Rtile on staffine.

. Statu- N1!C i- ready t.i .come iiut with thi- even though they acknowledee it is a low priorny.

. INDUSTRY 2 ' RSPECTIVE Indu-try *ee no value in this rule. Tech.

Spec- Indicate required -talTing. It is not necessary or meaningful to thy and decide overall staffine requirements on a generic basis. Tech. Spec.

chances are needed anyway -o the rule would not buy anything.

2. Draft Standard Review Plan on Decommiss2onine of Nuclear Power Reactors

. Statu-: NRR i- coordmatme with N31SS. NRC will take a wait and see attit ude. .

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. INDUSTRY PERSPECTIVE: We hope this will be superseded by the SRP muiative We aeree with SRC's wait and see apuroach.

3. Information Notice on Alaintenance Rule Compliance for Decommissioning Power Reactors

. Status: D&D staff 1.- workine with maintenance staff. Supposed to be risk informed-

. INDUSTRY PERSPECTIVE: If a risk informed approach is taken the maintenance rule would not apply to deccmmusioning. Industry questions the need for ths cuidance.

4. Revision to Rec. Guide 1.160 to melude maintenance rule compliance for

! decommissionine plant .

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. Status: D&D folks are workmg with maintenance folks to take risk informed approach to D&D plants.

INDUSTRY PERSPECTIVE: Should revise guide to clarify that based on a risk mformed approach. maintenance rule does not apply to decommissionine

3. Final Reculatory Guide 1067. "Decommiesionmg of Nuclear Power Reactors

. Status: Thic guide is eventially done. Industry has always questioned the need for this cuide. We believe it wa.s superseded by industry guidance on the decommissionine process. NRC believes it will be useful with the pubhe. Industry objected to the -tatement m the guide that spent fuel co-ts could not be included m decommissionme funding. NRC may have addrewed this.  !

. INDUSTRY PERSPECTIVE. I-sue ifite done. fix reference to spent fuel cost,

6. Final Reculatory Gtude DG lot 1. "Siandard Format and Conten for a Post-Shutdown Decommissionine Activuies Report" l

. Statu-: NRC ha- incorporat-d comment, Its basically done. Believes its usefu} II)r inter.letirin.- Wit h t he public.

. INDUSTRY PERSPECTIVE: Don't need it. ifits done. don't oppose it.

7. Fmal NUREC '628 "Decommisionine Questions and Answers

. St a t us: They are -till incorporatine comments as they use it with the public. Ihn to issue [iii:ll in the sprme

. INDUSTRY PERSF"CTIVE. No obwetmns. more for NRC's use than indust ry' .

S. Nevi-e Decommi41oning Inspection Program (I. TIC 2501) Issue for Comment

. INDUSTRY PERSPECTIVE No views.

9. Revise inspection procedures fbr Occupational Radiation Exposure and Nadioactive W3-te handlinM i . Status. Intend to tailor ext-tine procedures for shutdown plants.

. INDUSTRY PERSPECTIVE. Don t -ee need for.

10. Evaluatmn of De.-tun Bass, Accident- for Decommiscionine Power Reactors

. Status: Final draft out next month.

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. INDUSTRY PERSPECTIVE: Issue will be dealt with in developing SRPs.

don't believe a separate document is needed.

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11. Decommissioning Inspector Training Course l

. Status: Develop self study programs for resident inspectors regarding j decommissiomne process and issues. Prepares inspector to deal with the I pubhc m case of a protrncted shutdown where no decision has been made l as to whether the plant will decommiesion.  ;

. INDI~STRY PERSPECTIVE. Is it needed?

i 12.Information Notice on Release of Licen3ed .Tlaterial During Decommissioning j

. Status: Plannine to deceribe events where beensees released materials in an  !

unauthorned manner. No mention intended of referencing release limits in tech. Si me,. iir throuch 20.2in12. Activity in clearance issue may slow dorn issuance.

. INDUSTRY PERSPECTIVE: Additional cuidance of the "not one atom" vernacular is very unhelpful at this time when the agency is trying to move away from this pocition Industry oppose ,

13.Fmal Stan<iard Permanently Ikfueled Techmeal Specification for PWRS I

. Status. On hold l

. INDUSTRY PERSPECTIVE: NEI will coordinate through D&D working l croup and owners eroups as appropriate.

I 1. Final Revison: DIC 2.wl. "Decommis.sionme Inspection Program. l

. St a t us: Uncertain. un t out m draft yet.

. INDUSTRY PERSPECTIVE: NRC needs to do. Low priority for industry. i 1.ilssue Inspection Precedure on Dwommissioning Safeguards and Physical i Security.

. Status: Uncertain. scheduled for end of 1999.

! . INDUSTRY PERSPECTIVE NRC neede to do? Low priority for Industry.

Should be mformed by SRPs.

10. Draft Regulatory Guide and SRP for Cost Estunate P.eports required under 50.82

. Status: NRC miend, to pubh .h this cuidance next year. Industry sent our cuidance for the .\ larch 1999 reporting requirement in late January.

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. INDUSTRY PERSPECTIVE: Guidance industry recently issued may be all that is needed.

17. Draft Guidance on FSAR Conversion After Permanently Ceasing Power Operations.

. Status: NRC intends to publish m the year 2000.

. INDUSTRY PERSPECTIVE: Industry will develop guidance on declassification of SSCs.

18. Guidance on Evaluation of Safety Reviews -imilar to 50.59 at permanently shutdown reactors

. St at us: NRC plans to pubh.-h m the year 2000

. INDUSTRY PERSPECTIVE. Not needed Once accidents are defined no

<hfferent than for operatmc plants.

IR Draft Regulatory Guide and Inspection .Tlanual chapter on 3035(ci spills and records related to decommu.+ .mc

. Statu-: NRC plan- to pubh-h in the year 2000.

. INDUSTRY PERSPECTIVE: Guidance i.- aimed at operating plants.

Industry reque-f ed to 395141 m documentmp old cpills.

20. Final Regulatory Guide 1069. " Fire Protection Program for Permanently Shutdown and Do ,mmie-mnine Nuclear Power Plants"

. St at us: In proure-3

. INDUSTRY PERSPECTIVE: Guidance should clarify that Appendix R does not apply to permanently .-hutdown plants NRC is inappropriately proposing to use Part 20 and ALARA as a basi- for application of fire pn tectwn reqmrement . In addition. NRC is referencing NFPA standards.

State- already apply various ver.-ionn of NFPA standards. NRC should not be in thi, area.

21. Draft Standard Permaneir defueled Techn: cal Specifications for BWRs

. NRC is not happy with the product their contractor delivered.

They miend to work with..\lill: tone to devolop tech specs.

INDUSTRY PERSPECTIVE: NRC -hould not go beyond ITS by adding new Tech. Spec. requirement s. NEI offered to develop through the owners groups.

NRC should not spend anymore time on thi .

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, y awa y O i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY I I REGION 1 ONE CONGRESS STREET, BOSTON, MA 02114 January 26,1999 Charles Bechhoefer, Chainnan Atomic Safety and Licensing Board

[ Mail Stop T-3 F23]

U.S. Nuclear Regulatory Commission '

2 White Flint North 11545 Rockville Pike Rockville, MD 20852-2738 OfEce of the Secretary Rulema&g= and Adjudications Staff U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Ian Yankee Atomic Electric Company (Yanke: Nuclear Power Station) License Termination Plan, Docket No. 50-029-LA, ASLBP No. 99-754-01-LA-R To the Atomic Safety and Licensing Board:

In accordanc6 with 10 C.F.R. Q 2.1211(a)(1998) and 63 Fed. Reg. 67494 (December 7,1998),

the United Rates Environmental Protection Agency (EP A) - New England, Region I submits the following reon-party statement, which expresses our view on the Nuclear Regulatory Commission's (NRC) approval of the Yankee Rowe License Termination Plan (LTP). 'lhe stated purpose of the January 26,1999, prehearing conference is to determine whether the petitioners have submitted admissible contentions. We believe that the parties have raised legitimate health and safety concems, which if substantiated at a later hearing, would bear directly on the question of whether the Atomic Yankee Electric Company will be able to satisfactorily clean-up the site. We therefore encourage the Atomic Safety and Licensing Board to fully consider the petitioners' contentions. We further invite the Board to use its adjudicatory process to provide the public with adequate responses to the numerous unanswered and longstanding health and safety questions, which should properly have been addressed in the LTP, or earlier through the National Environmental Policy Act (NEPA) process.

EPA - is particularly interested in the decommissioning of Yankee Rowe. Because it is the first commercial plant in New England to be decommissioned, it is especially important that the process affords t he public appropriate opportunities for review and comment, and assures that the clean-up is done correctly from the outset. NRC's and Atomic Yankee's tre ament of the site will both set a precedent for a number of upcoming decommissionings in New England, and continue to impact the health and welfare of the people, and the enviromnent, in the vicinity of ATTAGMENT 4

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the site. EPA - New England is equally concemed about releasing the site for unrestricted

^ residential or commercial use and allowing the public, including children, free access to the site, l

particularly.when so many questions about on- and off-site radiation contamination remain at this  !

' late stage in the decommissioning process.

' We note at the outset that EPA - New England is pleased that Yankee Atomic has committed to a  !

Total Effective Dose Equivalent from residual radiation contamination not to exceed 15 i

mrem / year above background. EPA cc tsiders 15 mrem / year to be a minimally acceptable dose

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! -- limit, consistent with both the risk range for other carcinogens, and our mandate under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA),

that clean-up levels "at a minimum . . .- assure protection of human health and the environment."

l CERCLA { 121(d)(1). . This is the same level of clean-up that EPA requires of all other

• radioactively contaminated CERCLA sites. We also commend Yankee Atomic for assuring that upon license termination, the plant-related contamination in groundwater and surface water will j not exceed the EPA's National Pdmary Drmking Water Standards (Maximum Contaminant i Level) for radioactivity.

Notwithstanding our approval of the chosen clean-up standards at Yankee Rowe, we believe the I

petitioners have raised a number of health and safety concems that directly challenge how and I whether Yankee Atomic will meet these standards under the LTP and Final Status Survey Plan.

l. - For instance, the petitioners challenge the LTP's site characterization, arguing that Yankee Atomic has not yet: determined background radiation' levels; fully examined the extent of contamination on-site below a depth of 15 cm; adequately surveyed for contamination off-site; j or, accounted for all possible radionuclides (e.g. plutonium and americium). Petitioners further  !

ellege that site inspections revealed that Yankee Atomic's scan survey results are biased toward l low readings, and that sampling methodologies have been adjusted to de-emphasize existing hot-spots on-site. We do not address the validity of these contentions, as that is the proper function l of the Board. But if the petitioners' concems are legitimate, and to the extent that the Yankee Rowe decommissioning might subsequently fail to meet the stated clean-up standards, we note j that NRC's own publications propose that such sites could be assigned to the EPA for listing on l the National Priorities List under CERCLA, l

We comment last on decommissioning as a public process, and our hope that the future need for l prehearing conferences, such as this one, might be lessened by allowing the public to participate more substantively in the early stages of decommissioning, accompanied by meaningful -

environmental review. EPA - New England believes that the public has cause for concem and its l ' questions should be addressed.The NRC has recognized that the Yankee Rowe decommissioning i

is in many ways expenmental and that some of the clean-up technologies and methodologies are untested.Recent incidents occurring during the decommissioning of Connecticut Yankee at Haddam Neck demonstrate that decommissioning is not necessarily environmentally benign, and i

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s also indicate that greater NRC oversight is required.' Radiation can pose serious health and environmental risks. It should be treated in the same manner as other regulated pollutants, not more leniently. Its clean-up should be addressed openly. As evidenced by the First Circuit's recent decision,' the Yankee Rowe decommissioning process precluded public participation and environmental review for a number ofyears while nearly 90% of the site was dismantled. This should not be allowed to happen in the upcoming decommissionings of the Maine and Connecticut nuclear power plants.

. Many of the contentions presently before the Board conid have been addressed earlier in the decommissioning process or through NEPA. Although NRC's new regulations do not require o NEPA. compliance during the earliest stages of decommissioning, EPA - New England' suggests that an Environmental Impact Statement (EIS) is the appropriate vehicle for environmental i

review of decommissioning activities because it would allow for comprehensive site characterization and consideration of altemative clean-up scenarios and mitigation, as well as full public review and comment. NEPA also encourages public participation in the scoping process early in a federal agency's decisionmaking process. Especially in the case of Yankee Rowe, l

which was the first commercial plant to come off-line and be decommissioned, we are surprised i i that without much current environmental information, NRC issued an Environmental

' Assessment / Finding of No Significant hnpact and relied to a great degree upon an outdated,1988 Generic EIS, which contains no site-specific information, in approving the decommissioning t plan. We also agree with the petitioners that it appears that NRC has segmented the  ;

l decommissioning process by allowing the temporary storage of spent fuel to be considered under i

! a separate licensing scheme, the environmental review ofwhich typically occurs after an LTP has L been approved. By doing so, the impacts associated with Independent Spent Fuel Storage Installation (ISFST) -- earth-moving, alterations to orainage and surface and groundwater flows, radiation releases - which also affect the decommissioning of the site, remain unaddressed until the closing stages oflicense termination.

In short order, New England will see the decommissioning of a number of nuclear power plants, such as Maine Yankee, Connecticut Yankee, and Millstone Unit 1. EPA - New England will monitor the NRC proceedings in these other cases to ensure that the plant operators demonstrate at least the same level of comminnent to radiological clean-up levels, and the protection of our region's human and ecological health. With respect to Yankee Rowe, we are concemed that so many health and safety questions persist at this stage of the decommissioning process. We are equally troubled by the parties' allegations that site remediation, as described in the LTP, may not satisfy the chosen radiological clean-up standards. EPA - New England believes that the petitioners' numerous contentions deserve the Board's further attention. We request that the F

' San Director's Decision, Office of Nuclear Reactor Regulation, Docket No 50-

! 213, DD-99-01 at 3-5 (Jan.12,1999).

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Sa Cithens' Awareness Network. Inc. v. United States Nuclear Rerulatory i

Commission,59 F.3d 284,293,295 (1st Cir.1995).

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. Board fully respond to those contentions as well as the concerns raised in this letter, in order to ensure that the decommissioning of Yankee is done right on the first try. And we look forward to -

l working with NRC on the upcoming decommissionings in New England. .

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' Sincerely, I l

1 John P. DeVillars 1

Regional Administrator j

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l STANDARD REVIEW PLAN j

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EMERGENCY PLAN EXEMPTION REQUEST FOR PERMANENTLY DEFI'ELED FACILITIES REVIFW RESPONSIBil ITIES )

Primary -- Applicant's Project Managt Secondary - None '

L AREAS OF REVIEW A facility which is in a permanently shutdow n and defueled condition poses a significantly reduced risk to the public health and safety. After a " Certification of Permanent Cessation of Operation and Removal of l~uel from the Reactor Vessel" has been docketed in accordance with 10 CFR 50.82 and, in siew of the 4

reduced risk. it is anticipated that the licensee of such a facihty will seek exemption from certain requiremems of 10 CFR 50.544q).10 CFR 50 54(ti.10 CFR 50 47tb) and tch and Appendix E to 10 CFR Part 50 w hich are no longer appropriate. This resiew is expected to provide the basis for exempting the appheant licensee from the requirement of 10 CFR 50.54 q) that the licensee "shall follow and maintain in effect emergency plans u hich meet the standards in .10 CFR .J47(b) and the requirements in appendix E N thiipart." tref.1) The speci5c elements of 10 CFR 50 47 and Appendix E to 10 CFR Part 50 which are espected to be sublect to exemption and those elements w hich are expected to trmain in effect are detailed

m Anachment I of this SRP. A licensee has the option of either adopting the content of Attachment i by reference m an esemption request or proposing .n alternatise plant-speci6c exemption

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l l' The resiew is performed by the licensee's Project Manager. The resiew insolves evaluation of the beensee's Defueled Safety An 13 sis Report (DSAR). and any other relesant information prosided in the esemption request agamst the acceptance criteria of Section 11 of this SRP. In the defueled condition. there are no longer any credible design basis accidents associated with an operating plant from startup through full pow er operation. The design basis accidents relatise to a defueled facility are a small subset of those considered for an operating facility and are lunited to the following:

(l I a fuel handling incident.

C i a spent fuel cask drop. and ,

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(.4 accidents associated w tth radioactis e waste storage or processing.

l The onh possible addition to this hst would be any design basis accident which was included in the  !

heensee's original licensing basis for the operating facility and w hich is still valid for the facility in the

- defueled condition. As discussed in detail in Section lit of this SRP. REVIEW PROCEDURES. there are l

no releunt bey ond design basis accidents which could require offsite response capabilities and v. Web uvuld therefore need to be esaluated in order to grant the exemption request.

(. The subject review will be performed consistent with the requirements of the Commission's back5tting i~ . rule.10 CFR 50109. The policy under lying the ru le. i.e to ensure t at h new requirements are properiy tastified from a safety and cost-benefit standpoint, continues to apply during the decommissioning process  !

- so long as a facihty's 10 CFR Part 50 license remams in effect. Decommissioning facilities are entitled to the same predictabihty. stabihty and protection from arbitrary actions as operating facilities.

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ATTACHMENT 5 i

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!!. ACCEPTANCE CRITERI A Pursuant to 10 CFR 5012ta), the Commi sion may. upon application by any interested person or upon its own initiatis e. grant exemptions from the requirements of the regulations which are:

(1) authorized by law will not present an undue risk to public health and safety. and are consistent with the common defense and security, and (2) present special circumstances.

Special circumstances exist u hen-(I) application of the regulation in the particular circumstance would not serve the underlying purpose of the rule or is not necessary to achiese the underlying purpose of the rule (10 CFR $0.12(a)(2)(ii)); or (2) compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted. or that are significantly in excess of those incurred by others similarly situated (10 CFR 50.ths)C Wiii)); or (3) there is present other material circumstances not considered w hen the regulation wat adopted for which it would be in the public interest to grant an esemption (10 CFR 50.12(a)(2)oi)).

The underlying purpose of 10 CFR 50,54(qiis to ensure licensees follow and maintain in effect emergency plans that pros ide reasonable assurance that adequate protectise measures can and will be taken in the event of an emergency at a nuclear reactor. Sections 50.47(b) and (c) outline the planning standards and size of Emergency Planning Zenes. respectivel). that are to be considered in emergency plans and Appendis E to 10 CFR Pan 50 identifies the information that must be included in emergency plans.

In the permanently defueled condition. the risk associated with the plant has been significantly reduced.

Under the prosisions of 10 CFR 50.544qi. when a change to an emergenc> plan is made. the change is evaluated agamst tN bases for commitments made in the plan to determine whether there is a decrease in

, effectis eness. It is not a decrease in effectis eness if the reduction in the commitment is commensurate with a reduction m the bases for that commitment. Therefore. if the licensee satisfactorily demonstrates that the l

! calculated maximum offsite dose for the postulated releases evaluated in the facility's DSAR is less than L

the U.S. Ensironmental Protection Agency (EPA) Protectis e Action Guides (PAGs), it is to be concluded I that there has been a reduction in the bases that require offsite emergency planning. This conclusion, in turn. satisfies the special circumstance critena of 10 CFR 50.12(a)(2Xii) i.e., requiring the licensee to

'compl> with the requirements of 10 CFR 50 54(q) would not serve the underlying purpose of the rule.

With respect to the other "special circumstances" noted abos e, nothing in the docu- entation of the emergency planning rulemakings discussed the applicabihty or appropriateness of these regulations for facilities in the permanently shutdown and defueled condition: the subject regulations were established for power operations because such condntions create the potential for an accident with offsite consequences.

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2 Because esperience has shown that there are signi6 cant costs incurred in complying with the offsite emergency planning sequirements of 10 CFR 50 54tq) and because such costs are ultimately bome by the  ;

general public as ratepayers, a demonstration by the licensee that the basis for the offsite emergency planning requirement no longer exists will be suf6cient grounds for concludmg.primafxte. that compliance would result in " costs that are signi6cantly in excess of those contemplated u hen the regulation was adopted". i e.,10 CFR 50.12(a)(2)(iii) is satis 3ed; furthermore, with such a demonstration, there is present "other material circumstance not considered w hen the regulation was adopted for u+ich it wculd be in the public interest to grant an exemption", i e.,10 CFR 5012(aK2)(vi)is satisfied.

1. REVIEW PROCEDl'RES The review consists of the Project Manager's es aluation of the plant specific information submitted by the applicant licensee using the foregoing Acceptance Craeria. The bulk of this information should be found in the applicant's Defueled Safety Analysis Report. This information may be supplemented by a personal sisit to the site by the reuener and meetings with tue applicant.

The design basis accidents requiring esaluation for a defueled facility are a small subset of those considered for an operatmg facility and are limited to the following:

(I) a fuel handling incident (2) a spent fuel cask drop t3t accidents associated with radioactive waste storage or processing As noted in Section I of this SRP. the only possible addition to this list would be a design basis accident in the licensee's licensing basis for the operating facility w hich remains salid for the facility in the defueled condition.

If a speci6c accident anal) sis. w hich is containeo m the FSAR for the operatmg plant. has been presious!)

found to be acceptable to the Commission and there has been no meaningful change in the key parameters and assumptions which served as the basis for the originaljudgment, the original conclusion of acceptability will remain salid.

There are no relevant beyond design basis es ents u bich could require offsite response capabilities and which would therefore need to be evaluated in order to grant the exemption request. NUPlG-0396 (Ref.2) prosided recommendations on emergency planning zones and a range of time values in which emergency l response of6cials should be prepared to implement protectise actions. The NUREO also presented the chemical and phy sical characteristics of those radionuclides w hich contribute most significantly to human esposure. Th.se radionuclides primarily consist of short-lis ed isotopes in the form of noble gases and solatiles such as iodine.

In a policy statement (Ref.3) concerning the planning basis for emergency response, the Commission stated

! in reference to NUPIG-03%:"In endorsing this guidance, the Commission recognizes that it is l

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. j appropriate and prudent for emergency planning guidance to take into consideration the principal characteristic (such as 3

nuclides released and distance likely to be inscheds of a spectrum of design basis and core melt accidents.

Thus. one of the prmeipal considerations w hich formed the underlying basis of the emergency planning rule was the radionuclide distribution associated uith the design oasis and core melt (beyond design basis) accidents.

After a permanently shutdown plant has undergone a modest es el of decay (60 to 90 day s), the nuclide distribution is significantly different than that upon which the emergency planning rule was based. Many of the requirements of the emergency planning rule were based upon a spectrum of accidents which may result in early fatahties and early injury due to the presence of shorte -lised isotopes. The consequences of besond design basis es ents far perm'anently shutdown plants are de .iinated by long lised isotopes. Thus, the health consequences are dominated by the risk oflatent cancer fatalities due to long term exposures; there are no early fatalities and the risk of early injury is negligible (Ref.-1) As such many of the requirements of the emergency planning rule no longer apply to permanent!) shutdown plants which have undergone a modest lesel of decay. These requirements include the ten mile radius emergency planning zone and protecth e action recommendations.

In addition to the reasons ated abos e. aPfrosal for an exemption from the emergency planning rule requirements isjustified based upon the inherently large safety margins associated with the storage of spent fuel. The simplicity and robustness of spent fuel pool and dry cask storage designs make the occurrence of a beyond design basis esent of such low probability that they can be eliminated from consideration on the basis of risk alone. These design characteristic include seismic capability. s ersatile structural capability.

_ passise cooling capability and passive shielding capability.

Therefore, for the reasons cited abos e. there are no bey ond design basis es ents w hich need to be considered for approsal of an exemption consistent with Attachment I of this Standard Resiew Plan The resiewer must determine w hether or not the acceptance criteria identined in Section 11 of this SRP hase been satisGed Any de0ciencies should be clearly identined and should form the basis for a request for additional information to the applicant. If any deDciencies remain at the conclusion of the review. they must be identiGed in the Safety Esaluation Report and subsequently resobed with participation of higher les el NRC management.

It should be recogmzed that the detailed application of the acceptance criteria willin some instances require the exercise ofjudgement on the part of the reuewer. The resiewer is expected to achieve a safety Onding based on a traditional risk-informed reasonableness threshold which treats the acceptance criteria as akin to an " adequate protection" standard rather than seekmg to impose a standard of absolute safety.

l L The reviewer should conGrm that the applicant licensee has informed the appropriate ofGcials of the State.

l' local posernment and the Federal Emergene) Management Agency of tne exemption request.

1. . EV Atl' ATION FINDINGS The desired evaluation findings should be substantially equivalent to the following statement:

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.. l The Commission has completed its review of the licensee's request for an exemption from certain requirements of 10 CFR 50.54(q),10 CFR 50.54t).10 CFR 50.47(b) and (c), and Appendix E to 10 CFR Part 50 and concludes that the request is acceptable in view of the greatly reduced offsite radiological consequences from any reasonably conceivable accident which could occur with the plant in a permanently shutdown status. The specine elements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50 which are to be e.sempted and those w hich will remain in effect are listed in Attachment 1.

4 The Commission Gnds that the potential dose to the general public from any reasonably l conceis able accident would not exceed EPA PAG 3 and for the bounding accident. the length of .

time asailable proudes confidence that offsite measures for the public could be taken without i preplannin e ,

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The Commission. based on its independent es aluation. agrees with the licensee's analy ses and concludes that suf0cient bases base been presented for approval of the exemption request. The '

Commission has determined that pursuant to 10 CFR 50.12(a)(1). this exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. Furthermore, the Commission finds that there are special

circumstances presemed that satisfy the requirements of 10 CFR 50.12ta)(2)tii). (iii). and tsi).

l The Commission hereby grants the requested exemption.

, 11. 1%f PL F\1FNTATION i 1 The following is intended to proude guidance to licensees regarding the Commission's plan for using this j SRP. i l

Except in those cases in w hich a licensee proposes an acceptable alternatise method. the methods described herein aill be used by the Commission in its esalation of requests by licensees of facilities that are planning to, or are already pennanently shutdown and defueled, for exemption from certain offsite emergency planning requirements and reductions in the scope of onsite emergency plans.  ;

I It is important to note that those pros isions of 10 CFR 50.54 (q) which pennit a licensee to make changes to the Emergency Plan without prior Commission appros al. remain in effect. The licensee must simply ,

ascertain that the changes do not decrease the effectiseness of the Plan and that the Plan meets the  ;

requirements of Appendix E to 10 CFR Part 50 as modiGed by appros al of the exemption request.

111. REFERENCES (1) 10 CFR 50.54(q)

(2) NUREG.0396," Planning 13 asis for Des elopment of State and Local Gosernment Radiological Emergency Response Plans in Support of Light Water Nuclear Powei Plants." December 1978

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f (3) 44 FR 61123. -Planning Basis for Emergency Responses to Nuclear Power Reactor Accidents.

October 23.1979  ;

(4) NUREG-1353. " Regulatory Analysis for Resolution of Generic issue 82. Beyond Design Basis Accidents in Spent Fuel Pools." April 1989 ]

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s ATTACHMENT I EXEMPTIONS TO 10 CFR 50.54(q).10 CFR 50.54(t).10CFR50.47. AND APPENDIX E TO PART 50 The hcensee seeks exemption to the prosisions of 10 CFR 50.54(qi which require the licensee 'to follow and maintain in etTect emergency plans w hich meet the standards in j 50 4'(b) and the requirements in appendix E of this part" in their entirety. Those requirements in 10CFR50.47(b) and (c) and Appendix E to  ;

Part 50 which will continue to apply in the defueled plant condition are shown below in the unshaded text:

those requirements from which exemption is to be granted are indicated as shaded text. The licensee also l

seeks exemption to the provisions of 10 CFR 50.54(t). 1 i

f 50.4' Emeipacy plans. 1 tb) The onsite and. except as prosided m paragraph id) of this section. offsite emergency response plans for nuclear power reactors must meet the follow mg standards-(1) Primary responsibilities for emergency response by the nuclear facility licensee and

- by State and local organizations withm the Emergency Planning Zones have been assigned.

rhe emergency responsibilities of the sarious supporting organizauons hase been specifically  !

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

Q On-shift facility licensee responsibilities for emergency response are unambiguously denned adequate staffing to proside mitial facihty accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is asailable and the interfaces among various onsite response activities and offsite support and response activities l are specified.

G) Arrangements for requesting and effectively using assistance resources hase been i made. arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility base been made, and other organizations capable of augmenting the planned response base been identified

1. 4) A standard emergency classification and action lesel scheme. the bases of which l include facility sy stem and effluent parameters. is in use by the nuclear facility licensee, and ,

State and local response plans call for reliance on information provided by the facility licensees for detennination of minimum initial offsite response measures.

15> Procedures have been estabbshed for notification. by the licensee. of State and local response organizations and for notification of emergency personnel by all organizations; the content ofinitial and follow-up messages to response organizations and the public has been established: and means to proside early notification and clear instruction to the populace within the plume exposure pathw a) Emergency Planning Zone have been established.

(6) Prosisions exist for prompt communications among principal response organizations to emergency personnel and to the public.

A information is made asailable to the public on a periodic basis on how they uill be i . notified and w hat their initial actions should be in an emergency (e.g.. listening to a local broadcast station and remaining indocrs), the principal points of contact uith the news media for dissemination of information during an emergency nneluding the physical location or locations) are established in adunce, and procedures for coordinated dissemination of information to the public are established

(8). Adequate emergency facilties and equipment to support the emergency response are I_ prosided and maintained.

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l (9) ~ Adequate methods, systems and equipment for assessing and montoring actual or i potential offsite consequences of a radiological emergency condition are in use. l l

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(10) A range of protective actions hase been developed for the plume exposure pathway  ;

. EPZ for emergency workers and the public Guidelines for the choice of protective actions l during an emergency. consistent with Federal guidance. are deseloped and in place, and protectise actions for the ingestion exposure pathway EPZ appropriate to the locale have been des eloped. ,

t!I! Means for controlling radiological aposures. in an emergency, are established for j emergency workers The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protectise Action Guides.

t12i Arrangements are made for medical services for contaminated injured individuals.

t 1.4 General plans for recos ery and reentry are developed.

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

il5 Radiolopeal emergency response training is prosided to those who may be called i on to assist in an emergency.

(los Responsibilities for plan deselopment and review and for distribution of emergency l plans are established. and planners are properly trained.

(c)(2) Generally, the plume exposure pathway EPZ for nuclear power plants shall consist of an area about 10 miles f 16 km)in radius and the ingestion pathway EPZ shall consist of an area j about 50 miles (80 km)in radius. The exact size and configuration of the EPZs surrounding a j particular nuclear pow er reactor shall be determined in relation to local emergency response needs i and capabilities as they are affected by such conditions as demography. topography, land l

characteristics, access routes. and jurisdictional boundaries. The size of the EPZs also may be determined on a case by-case basis for gas-cooled nuclear reactors and for reactors with an j authorized power lesel less than 250 MW thermal The plans for the ingestion pathway shall '

focus on such actions as are appropriate to protect the food ingestion pathway.

Appendis E to Part 50 - Emergency Planning and Preparedness for Production and l L'tilization Freilities  !

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111. The Final Safety Analysis Report  ;

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( The Final Safety Analysis Report shall contain the plans for coping with emergencies. i The plans shall be an espression of the overall concept of operation, they shall describe the essential elements of advance planning that have been considered and the provisions that have ,

been made to cope with emergency situations. The plans shall incorporate information about the j i emergency response roles of supporting organizations and offsite agencies. That information shall j be sufficient to pros ide assurance of coordination among the supporting groups and with the licensee.

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l-l The plans submitted must include a description of the elements set out in Section IV for the Emergency Planning Zones (EPZs) to an extent sufficient to demonstrate that the plans provide reasonable assurance that adequate protective measures can and will be taken in the event of an emergency.

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IV. Content of Emergency Plans  ;

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The applicant's emergency plans shall contam, but not necessarily be limited to.

i infonnation needed to demonstrate compliance with the elements set fonh below i.e..

organization for coping u ith radiation emergencies. assessment action. activation of emergency organization. not:0 cation procedures. emergency facilities and equipment, training maintaining emergency preparedness. and recosery. In additions the emergency response plans submitted by an apphcant for a nuclear pow er reactor operating license shall com in ir ' rmation needed to i

demonstrate compliance uith the standards described in }50.47(b). ats ~ c will be evaluated against those standards. The nuclear power reactor operating license applicant shall also provide l

an analy sis of the time required to es acuate and for taking other protectis e actions for various sectors and distances uithm the plume esposure pathway EPZ for transient and permanent populations. i j

1 A. Organization The organization for copmg w ith radiological emergencies shall be described, including ,

definition of authorities responsibilities. and duties ofindisiduals assigned to the licensee's j

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emergency organization and the means for notification of such individuals in the event of an emergency. Speci0cally. the following shall be included.  ;

l. A description of the normal plant operating organization.

1 A description of the onsite emergency response organization with a detailed dscussion of.

a. Authorities. responsibilities, and duties of the mdn idaak si w ho u ill take charge during an emergenc);

b. Plant staff emergency assignments: i

c. Authorities. responsibilities. and duties on an onsite  ;

emergency coordinator who shall be in charge of the exchange ofinformation j with offsite authorities responsible for coordinating and implementing offsite emergency measures.

A description by position and function to be performed. of the licensee's headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

4 .- Identi0 cation , by position and function to be performed. of persons within the beensee orgamzation w ho will be responsible for for making offsite dose projections. and a description of how these projections will be made and the results  !

transmitted to State and local authorities. NRC. and other app apriate governmental agencies.

5. Identification. by position and function to be performed, of other

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employ ces of the licensee uith special quah0 cations for coping with emeryncy f

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conditions that may arise. Other persons with special qualifications, such as consultants. who are not employees of the licensee and who may be called upon for l

assistance for emergencies shall also be identi6ed. The special quali6 cations of these persons shall be described.

6. A description of the local offsite services to be provided in suppon of the licensee's emergency organization.

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7. Identincation of, and assistance expected from. appropriate State.

l local. and Federal agencies u ith responsibilities for coping with emergencies.

S. Identification of the State and or local officials responsible for planning for. ordering. and controlling appropriate protectis e actions, including es acuations u hen necessarv.

Page 4 of 8 A. Assessment Actiors The means to be used for determining the magnitude of and for continually assessing the impact of the release of radioactn e materials shall be described. including emergency action lesels that are to be used as criteria for determming the need for notification and participation of local and State agencies, the Commission and other Federal agencies, and the emergency action les els that are to be used for determining n hen and s. hat t)pe of protectis e measures should be considered within and outside the site boundary to protect health and safety. The emergency action les els shall be based on m. plant conditions and instrumentation in addition to onsite and offsite monitoring. These emergency action les els shall be discussed and agreed on by the applicant and State and local gosernmental authorities and approved by the NRC. They shall also be resiewed w ith the State and local governmental authorities on an annual basis.

B Activation of Emergency Orgamzation The entire spectrum of emergency conditions that ins oise the alerting or activating of progressnely larger segments of the total emergency orgamzation shall be described. The communication steps to be taken to alen or actis ate emergency personnel under each class of emergency shall be described Emergency action lesels (based not only on ensite and offsite radiation monitoring mformation but also on readmgs from a number of sensors that indicate a potential emergency. such as the pressure in containment and the response of the Emergency Core Cooling System i for notiGcation of of fsite agencies shall be described. The existence, but not the details. of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include. (1 ) notincation of unusual es ents. C) alert,0) site area emergency.

and (4) general emergency. These classes are further discussed in NUREG-0654: FEMA REP-1.

D NotiGeation Procedures D

1. AJministratis e and phy sical means for notifying local. State. and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for pubhc es acuation or other protectise measures, should they become

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necessary shall be described. This description shall include identification of the appropriate ,

officials. by title and agency. of the State and local gos ernment agencies within the EPZs. (1)

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2. Provisions shall be described for yearly dissemination to the public within the plume exposure pathway EPZ of basic emergency planning infonnation, such as the methods and l times required for public notification and the protectise actions planned if an accident occurs. j genera 1 information as to the nature and effects of radiation. and a listing of local broadcast i stations that will be used for dissemination ofi.mformation during an emergency. Signs or other measures shall also be used to disseminate to any transient population within the plume

. esposure pathwa: EPZ appropriate information that would be helpful if an accident occurs.

Page5ofS

1. A heensee shall has e the capabihty to notify responsible State and local gos emment agencies u ithm 15 mmutes after declaring an emergency The licensee shall demonstrate that the State local officials base the capability to make a public notification decision promptly on bein; informed by the licensee of an emergency condition. By Februarv 1. -1982 each nuclear power reactor licensee shall demonstrate that administratise and ph)sical means has e been established for alerting and providing prompt inst. actions to the public within the plume exposure pathua) EPZ. The four month period in 10 CFR 50.9 s W D 'or the correction of emergency plan de6ciencies shall not apply to the initial mstallation of this public notification system that is required by February 1.1982. The four-month period uill appl . to the correction of deficiencies identified during the initial msnllation and testing of the prompt public notification s) stems as well as those deficiencies discosered thereafter. The design objectise of the prompt public notification system shall be to base the capability to essentially complete the initial nori6 cation of the public within the plume exposure pathw ay EPZ within about 15 minutes. The use of this notification capability will range from immediate notification of the public twithin 15 minutes of the time that State and local officials are notitled that a situation exists requiring urgent action) to the more likely esents uhere there is substantial time available for the State and local governmental of0cials to make a judgment u hether or not to activate the public notification system. Where there is a decision to actis ate the notification system. the State and local officials will determine whether to activate the entire notification system simultaneously or in a graduated or staged manner. The responsibility for activating such a public notification system shall remain u ith the appropriate gosernmental authorities.

E. Emergency Facilities and Equipnient Adequate prosisions shall be made and described for emergency facilities ard equipment. including:

1. Equipment at the site for personnel monitoring:

1 Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the ensironment:

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3. Facilities and supplies at the site for decontamination of onsite indisiduals:

4 . Facilities and medical supplies at the site for appropriate emergency first aid treatment:

- 5. Arrangements for the sers ices of physicians and other medical personnel qualified to handle radiation emergencies on-site;

6. .

Arrangements for transportation of contaminated injured

. indisiduals from the site to specifically identified treatment facilities outside the site boundary:

7 Arrangements for treatment ofindividuals injured in the support of licensed activities on the site at treatment facilities outside the site boundary; 8.- A licensee onsite techaical support center and a licensee near-site emergency operations f acility from w hich effective direction can be gisen and effective control can be exercised during an emergency:

9. At least one onsite and one offsite communications system; each sy < tem shall has e a backup pou er source.

Page 6 of 8 All commumcation plans shall hase arrangements for emergencies, including titles and alternates for those in charge at both ends of the communication links and the primary and backup means of communication. Where consistent uith the function of the governmental agency, these arrangements u ill include:

a Pros isions for communications w ith contiguous Statellocal gos ernments uithin the plume esposure pathway EPZ. Such communications shall be tested monthly.

b. Prosision for communications uith Federal emergency response organizations. Such communications systems shall be tested annually.

c. Prosisions for communications among the nuclear power reactor control room. the onsite techmcal support center, and the near-site emergency operations facility: and among the nuclear facility, the principal State and local emergency operations centers, and the field assessment teams. Such communications sy stems shall be teste. annually.

d Pros isions for communications by the licensee wi:h NRC Headquarters and the appropriate NRC Regional Office Operations Center from the nuclear pow er reactor control room, the onsite technical support center, and the near-site emergency operations facility Such communications shall be tested monthly.

F. Training

1. The program to provide for: (a) The training of employees and exercising. by periodic drills, of radiation emergency plans to ensure that employees of the licensee are familiar w ith their specific emergency response duties, and (b) The participation in the training and drills by other persons whose assistance may be needed in the event of a radiation emergency shall be described. This shall include a description of specialized initial

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training and periodic retraining programs to be prosided to each of the following categories of emergency personnel:

i. Directors and or coordinators of the plant emergency organization:

ii. Personnel responsible for accident assessment, including control room shttt pc.sonnel:

iii.- Radiological monitoring teams: l is. Fire control teams (fire brigades);

s. Repair and damage control teams:  ;

Si First aid and rescue teams; i sii Medical support personnel: ,

siii Licensee's headquarters support personnel:

it Security personnel In addition. a radiological orientation train:ng program shall be made as ailable to local sersices personach e.g.. local emergency sersices Cisil Defense. local law enforcement personnel, local new s media persons. )

1. The plan shall describe prosisions for the conduct of emergency preparedness esercises as follow s: Esercises shall test the adequacy of timing and content ofimplementing j procedures and methods test emergency equipment and communications networks. test the pubhc notification s> stem. and ensure that emergency organization personnel are familiar with their duties 4.4 Page 7 of 8

b. Each licensee at each site shall conduct an esercise ofits onsite emergency plan es ery 2 y ears. The exercise may be included in the full participation bienmal exercise required i by parsgraph 2 c. of this section. In addnion. the licensee shall take actions necessary to ensure that adequate emergency response capabilities are maintained during the intersal between biennial ciercises by conducting drills, including at least one drill insolving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilities. The principal functional areas of emergency response include actisities such as management and coordmation of emergency response. accident assessment. protective action decision-making, and plant system repair and correctise actions During these drills. activation of all of the licensee's emergency response facilities (Technical Support Center (TSCL Operations Support Center (OSC), and the  ;

Emergency Operations Facihty (EOFH wceld not be necessary, licensees would have I

!- the opportunity to consider accident management strategies, supervised instruction l l

w ould be pennitted. operating staff w ould has e the opportunity to resolve problems I j (success paths) rather than has e controllers intervene, and the drills could focus on onsite traming objectn es.

c. Offsite plans for each sue shall be esercised biennially with full participation by each offsite authority hasing a role under ;he plan. Where the offsite authority has a role i under a radiological response plan for more than one site. it shall fu" ,articipate in one )

exercise esery two years and shall. at least partially participated)in 1er offsite plan esercises in this period.

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d. A State should fully participate in the ingestion pathway portion of exercises at least once every six years. In States with more than one site. the State should rotate this l~ participation from site to site.

c. Licensees shall enable any State or local Government located within the plume exposure ,

l pathway EPZ to participate in the licensee's drills when requested by such State or local l Gos ernment.

f. Remedial exercises will be required if the emergency plan is not satisfactorily tested dunng the biennial exercise. such that NRC. m consultation with FEM A. cannot find reasonable assurance that adequat: protec'ive measures can be taken in the event of a radiological emergency. The extent of State and local participation in remedial exercises must be sufficient to show that appropriate corrective measures base been  !

taken regarding the elements of the plan not properly tested in the previous exercise.

g. All training. including exercises. shall be pros ided for formal critiques in order to identify weak or deficient area that need correction. Any weaknesses or deficiencies that are identified shall be corrected. l

h. The participation of State and local gos emments in =n emergency exercise is not required to the extent that the applicant has identified those governments as refusing to i participate further m emergency planning actiuries, pursuant to 10 CFR 50.Qc 41). In such cases. an exercise shall be held uith the applicant or licensee and such gosemmental entities as elect to participate in the emergency planning process.

G. Maintaining Emergency Preparedness l

.Preusions to be emplo)ed to ensure that the emergency plan. its implementing procedures, i and emergency equipment and supplies are maintained up to date shall be described.

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l H. Recosery j Criteria to be used to determine when. following an accident. reentry of the facility would be I appropriate or when operation could be resumed shall be described.

V. Implementing Procedures I'

No less than 180 day s 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 Co nmission as specified in (50.4.

Licensees a ho are authorized to operate a nuclear pow er facihty shall submit any changes to the  :

emergency plan or procedures to the Commission. as specified in !$0.4, within 30 days of such changes. i l

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l Page 1 of 8 ATTACHMENTI >

1 EXEMPTIONS TO 10 CFR 50.54(q),10 CFR 50.54(t).10CFR50.47, AND APPENDIX E TO PART 50 i; The licensee seeks exemption to the provisions of 10 CFR 50 54(q) w hich require the licensee "to follow l and maintain in effect emergency plans which meet the standards in f 50.47(b) and the requirements in 'I appendix E of this part" in their entirety. Those requirements ia 10CFR50.47(b) and (c) and Appendix E i to Part 50 which will continue to apply in the defueled plant condition are shown below !1 the unshaded  ;

text; those requirements from which exemption is to be granted are indicated as shaded ' :xt. The licensee also sccks exemption to the provisions of 10 CFR 50.54(t). .

s50.47 Emergency plans. '

(b) The onsite did'~a~c@II@hyldedjiiMiiirspli(d) c of 6jiiddiii~$1DiiWis emergency I response plans for nuclear power reactors must meet the fc' Jewing standards: 1 (1) Primary resp ~onsibilities for emerpener~ response by the nucicar facility licensee iIrid  ;

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the aiid have been assi ned.  :

eM; Iliici M M elpds TI M ~ W t established, and each prmcipal response organization has staff to respond and to augment its initial response on a continuous basis.  ;

(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined. adequate staffing to provide initial facility accident response in key functional areas i is maintained at all times, timely augmentation of response ca abilities is available and the interfaces among various onsite response activities ind . iiiSMidL7 " 7' _

are specified.

(3) Arrange, men, t_s fo._r requesting and effectively using a.ssistance resources have been 1

Emsrgency .

f iaciSt[havetisen Snade] and other organizations capable of augmenting the planned response have been identified.

(4) A standard emergency classification and action level scheme, the bases of which  :

include facility ss stem and efliuent parameters. is in use by tbc nuclear facility licensec[5nd I State and local'riiiiiiinifepliiiftiallMisiginos"onjinfodnNion"pirigided.siEll$)ti$1@ l licensees for 6~-- *briintaiNuniinitN!ofTsitefrgspor% rnessupis (5) Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content ofinitial and follow-up messages to response organizations Mi$'@ has been i 5 I (6) Provisions exist for prompt communications among principal response orgamzations to emergency personnel andio tishisblic.

-(7) _ _InfM@u$dc[@$hejiublihMggo(Id. "M ,

notified and whatWairiaitial acelons should bein'an ,,..@n(c 4e} l broadcast statkmal4M indoors), the principal points of contact with the news

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media for dissemination ofinformation during an emergenc) (Midfr@iliiiin@iilsid l location ei lociations) are established in advance, and pro 6Bilures forjwd... sed l- disseminad6nl0f irifdhisiti6hlinlic hublic'arcjstablistied.

(8) Adequate emergency facilties and equipment to support the emergency response are provided and maintained.

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ATTACHMENT 6 I i

W (9) Adequate methods, systems, and equipment for assessing and montoring actual or potential Elfsdc consequences of a radiological emergency condition are in use.

Page 2 of 8

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t&iiGilifest (11) Means for controlling radiological exposures. 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 Poicctive Action Guides.

(12) Arrangements are made for medical services for contaminated injured individuals.

(13) General plans for recovery and reentry are developed.

(14) Periodic exercises are (will be) conducted to evaluate major portions of emergency recponse capabilities. periodic drills are (will be) conducted to develop and maintain key l

skills. and deficiencies identified as a result of exercises 01 drills are (will be) corrected.

(15) Radiological emergency response training is provided to those who may be called on to assist in an e.r.ergency.

(16) Responsibilities for plan development and resiew and for distribution of emergency plans are established. and planners are properly trained.

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rocus on such acuens assic appropmse hipressateelood Appendix E to Part 50 - Emergency Planning and Preparedness for Production and Utilization Facilities 111. The Final Safety Analysis Report l

The Final Safety Anal 3sis Report shall contain the plans for coping with emergencies.

The plans shall be an expression of the overall concept of operation; they shall describe the essential elements of advance planning that have been considered and the provisions that have been made to cope with emergency situations. The plans shall incorporate information about the emergency response roles of supporting organizations'addSfsiFijieiiins That information shall be sufricient to pros ide assurance of coordination among the supporting groups and with the licensee.

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e Page 3 of 8 IV. Content of Emergency Plans The apph^caht's emergency plans shall contain, but not necessarily be limited to, information needed to demonstrate compliance with the elements set forth below, i.e.,

organization for coping with radiation emergencies, assessment action, activation of emergency organization. notification procedures. emergency facilities and equipment, training, maintainin >

cmergency preparedness. and recovery. In addition. the e.nergency response plans ~ , E daippNUiht kaE3C7 GMgs@s shall contain information needed to demonstrate compliance with the standards described in s50.47(b). and they will be eval,uat,cd_

against those standards.

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populations A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities. responsibilitics, and duties ofindividuals assigned to the licensce's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically. the following shall be included:

1. A description of the normal plant 5M~" organization.

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

a Authorities responsibilities, and duties of the individual (s) w ho will take charge during an emergency;

b. Plant staff emergency assigmnents;

c. Authorities, res isibilities and duties on an onsite

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6. ' A description of the local offsite services to be provided in suppo:1 l

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l 7. Identification of, and assistance expected from, appropriate State, local and Federal agencies with responsibilities for coping wis.h emergencies. i l

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Page 4 of M A. Assessment Actions 'i The means to be used for detennining the magnitude of and for continually assessing the impact of the release of radioactive materials shall be desenbed. including emergency action levels that are to be used as criteria for determining the need for notification ini$rlli(Ndii of local and State agencies the Conunission ma44derW and the emergency action levels that are to be used for determining u hen and what type of protective measures should be considered uithin siiAKEsidi the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite iMf, ~ ~

offsite monitoring. These emergency action levels shall bc _

g ggm yme-w~'5: rowd by the NRC.

alsoIMUPUwed withNMMtal. get B. Activation of Emergency Organization The entire spectnnu of emergency conditions that involve the alerting or activating of progressively larger segments of the total emergency organization shall be described. The communication steps to be taken to alert or activate emergency personnel under each class of emergency shall be described. Emergency action levels (based not only on onsite M radiation monitoring information but also on readings from a number of sensors that indicate a potential emergenc)[sichT(MM'ITn rinimisnisisMMMMM Coiff'ipihidSysEsiekfor notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) notification of unusual events. (2) alert [M7inii ,

cise'ageicyiand (4) gencial clineig'eidy. These classes are further discussed in NUREG 0654;

- FEMA-REP-1.

D. Notification Procedures l D-l

1. Administrative and physical means for notifying lodall State, and Federal officials and hedWittiilisiii u agencies nonfl5insiiMilliaTnGsna W"""syg&Wnifs.E nonC _ _smissessoisiildlii@

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1. A licensee~

shall have the capability to notify responsible State and local gos_ernm_ent agencies in 5 ? " after declarmg an emer ency.

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E. Emergency Facilities and Equipment Adequate provisions shall be made and described for emergency facilities and l equipment, including: 1

1. Equipment at the site for personnel monitoring. I

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2. Equipment for determining the magnitude of and for continuously assessing the impact of the release of radioactive materials to the environment;

3. Facilities and supplies at the site for decontamination of onsite individuals;

4. Facilities and medical supplies at the site for appropriate emergency first aid treatment;

5. Arrangements for the services of physicians and 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 ontside the site botmdary; i

7. '

Arrangements for treatment of individuals injured in the support oflicensed activitics on the site at treatment facilities outside the site boundary;

8. A licensee onsite iiditicallalpped center aMM M M from which efTective direction can be given and efTective control can be exercised during an emergency;

9. At least one onsite M[6Ghli6 communications sy stem [Ech t

sys'~ein shall have a backup power source.

Page 6 of 8 l

All communication plans shall have arrangements for emergencies, including titles and alternates for those in charge at both ends of the communication links and the primary and '

backup means of communication. Where consistent with the ftmetion of the governmental agency, these arrangements will include:

a. Provisions for communications with foritissin State /losid governments withitittid ElsinfEfosurd%thsay EPZ. Such communications shall be tested monthly. ~

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c. Provisions for communications amon the I control room, the onsite 180lusalM center, M *

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cmergencyoperahonscentetsrandtlIefield:menanstn[a*M Such nand, communications systems shall be tested annually.

d. Provisions for communications by the licensee with NRC Headquaners and the appropriate NRC Regional Office Operations Center from the nucl5ar pisirindtor control roomftlioitsitijdclinicinniujigisitermteq and the neap @c7 cmcrgencp spiiriiitidits facility. Such conununications shall be tested monthly, F. Training

1. The program to provide for: (a) The training of employ ees and exercising, by perioclic drills. of radiation emergency plans to ensure that employees of the licensee are f:uniliar with their specific emergency response dutics, and (b) The participation in the i

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o training and drills by other persons whose assistance may be needed in the event of a radiation emergency shall be described. This shall include a description of specialized initial training and periodic retraining programs to be provided to each of the following categories of emergency personnel:

i. Directors and/or coordinators of the plant emergency organization; ii. Personnel responsible for accident assessment. including

control room shift personnel; iii. Radiological monitoring teams; iv. Fire control teams (fire brigades);

v. Repair and damage control teams;

' vi. First aid and rescue teams;  ;

vii. Medical supgrt personnel; j viii. $65Ei~eihendiisiiiiis~sRpifet5ifi%

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ix. Scenrity personnel.

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l. The plan shall describe prosisions for the conduct of emergency preparedness l exercises as follow - Exerciscs shall test the adequacy of timing and content of {'

l implementing procedures and methods, test emergency equipment and conununications

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netuorks. tcstihcpublic 50tificailotilsysNm, and ensure that emergency organization i

personnel are familiar with their dutics. (3) l l

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Page 7 of 8

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b. Each licensee at cach site shall conduct an exe cisc of its onsite emergency plan every 2 '

> cars. ThebergiscEy.jsiiIcidilidiritisfulfparncepsitiosd@iliUSNiisiiiiiisgisbul tipalidpiskhdfc0thhfssillonTIn addition, the licensee shall take actions necessary to ensure that adequate emergency response capabilitics are maintained during the inten al between biennial exercises by conducting drills, including at least one drill im olving a combination of some of the principal functional areas of the licensee's onsite emergency response capabilitics. The principal functional areas of emergency  !

response include activities such as management and coordination of cmergency *

' response, accident assessinent, Foi66kaciisiffsiBLig5 Mand plant system repair and corrective actions. During these drills, activation of all of the licensce's i emergency response facilitics. $diclidiiisil%ss7" ~l$csIIE6iis[W l )

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_ Mould not be necessary.

j licensecs would hase the opportunity to consider accident management strategies.

supcivised instruction would be permitted operating staff would hase the opponunity to resch e problems (success paths) rather than have controllers intenene, and the drills could focus on onsite training objectives.

c. milliful OfTshe'piaiiildiTichiite 'stiall tid texercised bicinaisti[h{pqnjicspa offsitclauthorityhiviaj AzolEisnidEfthipliii.(Wlidic 2gsNild under a indiatosidliesisiiserpts rWmoiefthan onsWWanamedlyliii$jgKsd M__.f."

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e. Licensees shall enable any State R$IisthdsiEiiiill$isiiG($@$i(M )

o participate in the licensee's drills when requested by such

f. Reinedial exercises will be required if the emergency plan is not satisfactorily tested i during the biennial exercise, such that NRC,IIsiM. M+ cannot find I reasonable assurance that ade uate protective incasures can be taken in the event of a radiological emercency. "tstilRStats

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All training, including exercises, shall be provided for fornial critiques in order to I 1 identify weak or deficient area that need correction. Any weaknesses or deficiencies that are id y .gg.entified shall be corrected 3 --- -

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[oMM8"tilidt$es$eleotkhesticipiteMtfiecedrganiy'MI Nisees,' p G. . Maintaining Ernergency Preparedness Prosisions to be employed to ensure that the emergency plan, its implementing procedures, and emergenes equipment and supplies are maintained up to date shall be described.

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H. Recovery Criteria to be used to deterinine when, following an accident, reentry of the flicility would be appropriate or when operation could be resumed shall be described.

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