ML21076A438
| ML21076A438 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/17/2021 |
| From: | Simpson P Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21076A518 | List: |
| References | |
| RS-21-023 | |
| Download: ML21076A438 (39) | |
Text
4300 Winfield Road Warrenville, IL 60555 Exelon Generation 630 657 2000 Office 10 CFR 50.12 RS-21-023 10 CFR 50.47 10 CFR 50, Appendix E March 17, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington , DC 20555-0001 Dresden Nuclear Power Station, Units 1, 2, and 3 Amended Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRG Docket Nos.50-010. 50-237. 50-249. and 72-037
Subject:
Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E
References:
- 1. Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Dresden Nuclear Power Station, Units 2 and 3," dated September 2, 2020 (ADAMS Accession No. ML20246G627)
- 2. Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request-Proposed Changes to Dresden Emergency Plan for Post-Shutdown and Permanently Defueled Condition," dated November 2, 2020 (ADAMS Accession No. ML20307A434)
In accordance with 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (Exelon) requests exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, for Dresden Nuclear Power Station, Units 1, 2, and 3 (Dresden).
The requested exemptions would allow Dresden to reduce emergency planning requirements and subsequently revise the Dresden Emergency Plan consistent with the anticipated permanently defueled condition of the station.
By letter dated September 2, 2020 (Reference 1), Exelon provided formal notification to the U.S. Nuclear Regulatory Commission (NRG) pursuant to 10 CFR 50.82(a)(1 )(i) and 10 CFR 50.4(b)(8) of the intention to permanently cease operations at Dresden , Units 2 and 3, on or before November 30, 2021.
Once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessels for Dresden , Units 2 and 3 are submitted to the NRG in accordance with 10 CFR 50.82(a)(1 )(i) and (ii), then pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50
March 17, 2021 U.S. Nuclear Regulatory Commission Page 2 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel in the reactor vessels.
By letter November 2, 2020 (Reference 2), Exelon submitted changes to the Dresden emergency plan on-shift and emergency response organization (ERO) staffing to support the planned permanent cessation of operations and permanent defueling of the Dresden reactors. The proposed changes in staffing are commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled nuclear power reactor facility.
Dresden, Unit 1, has an NRC possession-only license and is currently maintained in a SAFSTOR condition (i.e., a method in which a nuclear facility is placed and maintained in a condition that allows it to be safely stored and subsequently decontaminated). All fuel assemblies have been removed from the Dresden, Unit 1, reactor and transferred either to the onsite Independent Spent Fuel Storage Installation (ISFSI) or to the GE Morris facility in Illinois.
The requested exemptions are permissible under 10 CFR 50.12 because they are authorized by law, will not present an undue risk to the public health and safety, are consistent with the common defense and security, and present special circumstances .
Specifically, application of the portions of the regulations from which exemptions are sought is not necessary to ensure adequate emergency response capability for Dresden and to achieve the underlying purpose of the rules. Furthermore, continued application of these portions of the regulations from which exemptions are sought would impose a burden on Exelon and the decommissioning trust fund by requiring implementation of unnecessary emergency response capability. Finally, granting the requested exemptions would result in benefit to the public health and safety and would not result in a decrease in safety, because they would enhance the ability of the emergency response organization to respond to credible scenarios.
The exemption requests are contained in Attachment 1 to this letter. Exelon has performed an analysis to determine the decay time required post-permanent shutdown such that the hottest assembly in the spent fuel pools will not reach the temperature at which zirconium cladding fails within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. The analysis shows that 348 days (i.e., the Zirc-Fire Window) after permanent cessation of power operations of Dresden , Unit 2, and 299 days after permanent cessation of power operations of Dresden, Unit 3, the spent fuel stored in the spent fuel pools will have decayed to the extent that the requested exemptions may be implemented at Dresden. Following the shutdown of Unit 2 (i.e. , the most limiting unit), which is expected on or before the end of November 2021 (Reference 1), expiration of the Zirc-Fire Window for Unit 2 is expected to be approximately October 22, 2022. This analysis is contained in Attachment 2.
Exelon will submit a permanently defueled emergency plan (PDEP) license amendment request (LAR), containing a permanently defueled emergency action level (EAL) scheme, for NRC review and approval pursuant to 10 CFR 50.54(q)(4) and 10 CFR 50, Appendix E, Section IV.B.2. The PDEP LAR and corresponding EALs will be based on the exemptions requested in Attachment 1.
March 17, 2021 U.S. Nuclear Regulatory Commission Page 3 Exelon requests approval of these exemptions by October 7, 2022. Exelon requests that the approved exemptions become effective 348 days following permanent shutdown of Dresden, Unit 2. Exelon will provide the dates once fuel has been permanently removed from the Unit 2 and Unit 3 reactor vessels in the certification required by 10 CFR 50.82(a)(1 )(ii).
Approval of these exemptions by the requested date will allow Exelon adequate time to implement changes to the emergency plan and emergency response organization by the requested effective date.
There are no regulatory commitments contained within this submittal. Should you have any questions concerning this submittal , please contact Ms. Lisa A. Simpson at (630) 657-2815.
Patrick R. Simpson Sr. Manager - Licensing Exelon Generation Company, LLC Attachments:
- 1. Requests for Exemptions from Portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and 10 CFR 50, Appendix E
- 2. Dresden Calculation DRE20-0008, Revision 0, "Zirconium Fire Analysis for Drained Spent Fuel Pool" cc: w/ Attachment NRC Regional Administrator, Region Ill NRC Senior Resident Inspector- Dresden Nuclear Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station Units 2 and 3 NRC Project Manager, NMSS - Dresden Nuclear Power Station Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 1 of 78 10 CFR 50, Appendix E TABLE OF CONTENTS ........................................................................................................ PAGE 1.0 SPECIFIC EXEMPTION REQUEST .................................................................................... 2
2.0 BACKGROUND
................................................................................................................... 2 3.0 BASIS FOR EXEMPTION REQUEST ................................................................................. 3 4.0 EXEMPTIONS TO EMERGENCY RESPONSE PLAN REQUIREMENTS DEFINED BY 10 CFR 50.47 AND 10 CFR 50, APPENDIX E .................................................................... 4
5.0 TECHNICAL EVALUATION
.............................................................................................. 47 5.1 Accident Analysis Overview ...... ...... ... .. ...... ........... .......................... ............. .... ....... .... ..... 47 5.2 Consequences of Design Basis Events .. .. ........................ .. .. .. ....... .... ............ .. ................ 53 5.3 Hottest Fuel Assembly Adiabatic Heat-up (Zirconium Fire) ............................................. 53 5.4 Consequences of Beyond Design Basis Events .............................................................. 54 5.5 Comparison to NUREG-1738 Industry Decommissioning Commitments and Staff Decommissioning Assumptions ............................................... ...... .... .............................. 54 5.6 Consequences of a Beyond-Design Basis Earthquake ......... .. ... .. ......... .......................... 55
6.0 CONCLUSION
................................................................................................................... 57 7.0 JUSTIFICATION FOR EXEMPTIONS AND SPECIAL CIRCUMSTANCES ..................... 69 7 .1 Exemptions ..... ...... ........... .... ....... .... .... ..... ........... .... ....... .... ........... ............... .... ....... .... ..... 69 7.2 Special Circumstances ............................................ ........................ ................................. 70 8.0 PRECEDENT ..................................................................................................................... 72 9.0 ENVIRONMENTAL ASSESSMENT .................................................................................. 72
10.0 REFERENCES
................................................................................................................... 74
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 2 of 78 10 CFR 50, Appendix E 1.0 SPECIFIC EXEMPTION REQUEST In accordance with 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (Exelon) requests the following regulatory exemptions for Dresden Nuclear Power Station (Dresden):
Certain standards in 10 CFR 50.47(b) regarding onsite and offsite emergency response plans for nuclear power reactors; Certain requirements of 10 CFR 50.47(c)(2) to establish plume exposure and ingestion pathway emergency planning zones for nuclear power plants; and Certain requirements of 10 CFR 50, Appendix E, which establish the elements that make up the content of emergency response plans.
The Emergency Response Plan encompasses Dresden , Units 1, 2, and 3. The requested exemptions wou ld allow Exelon to reduce emergency planning requirements and subsequently revise the Dresden Emergency Response Plan to reflect the permanently defueled condition of the station . The current 10 CFR 50 regulatory requirements for emergency planning (developed for operating reactors) ensure safety at Dresden. However, once the station is permanently shutdown and defueled, and a sufficient decay of the spent fuel has occurred ,
some of these requirements exceed what is necessary to protect the health and safety of the public.
The requested exemptions and justification for each are based on and consistent with Interim Staff Guidance NSIR/DPR-ISG-02, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants," issued May 11 , 2015 (Reference 1).
2.0 BACKGROUND
The Dresden site consists of approximately 953 acres located in the northeast quarter of the Morris 15' quadrangle (as designated by the U.S. Geological Survey), Goose Lake Township, Grundy County, Illinois. The site boundaries generally follow the Illinois River to the north, the Kankakee River to the east, and the Elgin, Joliet and Eastern Railway right-of-way on the west.
Unit 1 is located in the northeast quadrant of the site. Unit 1 was shutdown for modification to meet new regulations on October 31, 1978 and has since been placed into SAFSTOR, but its major structures are still present and intact. Unit 2 and Unit 3 are located on the site directly west of and adjacent to Unit 1. The exclusion area boundary (EAB), which is common for all three Dresden units, has a radius of 0.5 miles, and for the purposes of Emergency Planning, the exclusion area and the site boundary are considered the same. No public highways or railroads transverse the EAB.
Section 15.0, "Accident and Transient Analysis," of the Dresden Updated Final Safety Analysis Report (UFSAR) describes the design basis accident (OBA) scenarios that are applicable to Dresden Units 2 and 3. After the Dresden Unit 2 and 3 reactors are defueled, the irradiated fuel will be stored in the spent fuel pools (SFPs) located in the Reactor Building. While spent fuel is stored in the SFPs, the UFSAR Chapter 15 accidents that remain applicable to Dresden in the permanently shutdown and defueled condition are: (1) a postulated liquid release due to liquid tank failure , and (2) a Fuel Handling Accident (FHA) in the SFP (which is a new analysis, since the existing FHA in Chapter 15 addresses an FHA in the reactor core) (Reference 2).
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 3 of 78 10 CFR 50, Appendix E The analyses of the potential radiological impact of accidents while Dresden is in a permanently defueled condition indicate that no design basis accident or reasonably conceivable beyond design basis accident are expected to result in radioactive releases that exceed U.S. Environmental Protection Agency (EPA) Protective Action Guidelines (PAGs)
(Reference 3) beyond the site boundary.
Dresden, Unit 1, was permanently shutdown October 31, 1978, and in Ju ly 1986, the U.S.
Nuclear Regulatory Commission (NRC) issued a license amendment to alter the Dresden ,
Unit 1, operating license to possession-only status. Dresden, Unit 1, is being maintained in a SAFSTOR condition (i.e., a method in which a nuclear facility is placed and maintained in a condition that allows it to be safely stored and subsequently decontaminated). All fuel assemblies have been removed from the Dresden , Unit 1, reactor and SFP and transferred either to the onsite Independent Spent Fuel Storage Installation (ISFSI) or to the GE Morris facility in Illinois.
By letter dated September 2, 2020 (Reference 4), Exelon provided formal notification to the NRC pursuant to 10 CFR 50.82(a)(1 )(i) and 10 CFR 50.4(b)(8) of its determination to permanently cease operations at Dresden , Units 2 and 3, on or before November 30, 2021.
Once fuel has been permanently removed from the reactor vessels, Exelon will submit a written certification to the NRC , in accordance with 10 CFR 50.82(a)(1 )(ii) that meets the requirements of 10 CFR 50.4(b)(9). Upon submitting the certifications of permanent removal of fuel from the reactor vessels, the 10 CFR 50 licenses for Dresden, Units 2 and 3, will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels, as specified in 10 CFR 50 .82(a)(2).
With the reactors permanently defueled, the reactor vessels and supporting structures and systems will no longer be in operation and will have no function related to the safe storage and management of irradiated fuel in the SFPs. The irradiated fuel will initially be stored in the SFPs and later stored in the ISFSI until it is shipped offsite in accordance with the schedules that will be described in the PSDAR and Spent Fuel Management Plan.
3.0 BASIS FOR EXEMPTION REQUEST In order to allow a reduction in emergency response planning requirements commensurate with the hazards associated with Dresden's permanently defueled condition , exemptions from portions of 10 CFR 50.47(b), 50.47(c)(2), and 10 CFR 50, Appendix E, are needed . Exelon has performed an analysis to determine the decay time required post-permanent shutdown such that the hottest assembly in the SFPs will not reach the temperature at which zirconium cladding fails within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (Reference 5). The analysis shows that 348 days after permanent cessation of power operations of Dresden, Unit 2, and 299 days after permanent cessation of power operations of Dresden, Unit 3, a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available before fuel cladding temperature reaches 900°C with a complete loss of SFP water inventory with no heat loss (adiabatic heat-up). Based on the current planned shutdown dates, after the 348-day period for Dresden , Unit 2 (i.e., the most limiting unit, herein referred to as the Zirc-Fire Window), there is sufficient time within the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> described in the supporting analysis to mitigate events that could lead to a zirconium cladding fire. The analysis is contained in .
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 4 of 78 10 CFR 50, Appendix E Exelon plans to submit a Permanently Defueled Emergency Plan (PDEP) License Amendment Request (LAR), including a Permanently Defueled Emergency Action Level (EAL) scheme, for NRC review and approval pursuant to 10 CFR 50.54(q)(4) and 10 CFR 50, Appendix E, Section IV.B.2. The PDEP and corresponding EALs will be based on the exemptions requested herein.
Based on the analyses detailed in Section 5.0 below, Exelon has concluded that the portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, identified in Table 1 (Exemptions Requested from 10 CFR 50.47(b) and (c)(2)) and Table 2 (Exemptions Requested from 10 CFR 50, Appendix E) will not be necessary to protect the health and safety of the public when Dresden, Units 1, 2 and 3, are in the permanently defueled condition and would be unduly burdensome. Approval of the exemptions requested in Table 1 and Table 2 would not present an undue risk to the public or prevent an appropriate response in the event of an emergency at Dresden.
4.0 EXEMPTIONS TO EMERGENCY RESPONSE PLAN REQUIREMENTS DEFINED BY 10 CFR 50.47 AND 10 CFR 50, APPENDIX E Exelon requests exemptions from portions of 10 CFR 50.47(b) and (c)(2) and Appendix E of 10 CFR 50 to the extent that these regulations apply to specific provisions of onsite and offsite emergency planning that will no longer be applicable once the certifications required by 10 CFR 50.82(a)(1 )(i) and (ii) have been submitted, and sufficient decay of the spent fuel has occurred for Dresden, Units 2 and 3. Dresden, Unit 1, is a possession-only license and no Dresden, Unit 1, spent fuel is stored in an SFP. The Unit 1 reactor vessel contains no irradiated fuel and has been placed into SAFSTOR. The Unit 1 SFP is drained . All fuel assemblies have been removed from the Dresden, Unit 1, reactor and SFP and transferred either to the onsite ISFSI or to the GE Morris facility in Illinois. Therefore, these specific provisions of the requested exemptions are also no longer applicable to Dresden, Unit 1, and are also requested for Dresden, Unit 1.
Once the certifications described in 10 CFR 50.82(a)(1) have been submitted and the conditions of 10 CFR 50.155(a)(2)(ii) are met, the mitigation strategies (e.g ., equipment, procedures) called out in this submittal that are solely needed to support the mitigation strategies for beyond-design basis external event (i.e., FLEX) for the SFPs will be discontinued as allowed in accordance with 10 CFR 50 .155(a)(2)(ii). Dresden will continue to maintain the required extensive damage mitigation guidelines (EDMGs) for the SFPs until the conditions of 10 CFR 50.155(a)(2)(iv) are met.
The specific portions of 10 CFR 50.47 and 10 CFR 50, Appendix E from which exemptions are being requested are identified using bold strikethrough text in Table 1 and Table 2 below.
The portions of regulations that are not identified using bold strikethrough text (i.e., those portions for which an exemption is not being requested), will remain applicable to Dresden.
Details related to specific exemption requests are provided in the Basis for Exemption column.
The requested exemptions and justification for each are based on and are consistent with NSIR/DPR-ISG-02 (Reference 1).
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 5 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption 1 10 CFR 50.47(b) : The onsite and, exGept as pra¥ided in In the Statement of Considerations (SOCs) for the final rule for EP requirements paragraph (d) af this seGtian, affsite emergency for independent spent fuel storage installations (ISFSls) and for monitored response plans for nuclear power reactors must meet the retrievable storage (MRS) facilities (60 FR 32430 ; June 22 , 1995) (Reference 6),
following standards: the Commission responded to comments concerning offsite emergency planning for ISFSls or MRS and concluded : "the offsite consequences of potential accidents at an ISFSI or a MRS would not warrant establishing Emergency Planning Zones (EPZs)."
As discussed in NSIR/DPR-ISG-02 (Reference 1), in a nuclear power reactor's permanently defueled state, the accident risks are more similar to an ISFSI or MRS than an operating nuclear power plant The EP program would be similar to that required for an ISFSI under 10 CFR 72 .32(a) when fuel stored in the SFP has more than five years of decay time and would not change substantially when all the fuel is transferred from the SFP to an onsite ISFSI. Exemptions from offsite EP requirements have previously been approved when the site-specific analyses show that in a partial drain-down event, at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available from the time when cooling of the spent fuel is not effective until the hottest fuel assembly reaches the zirconium ignition temperature of 900°C. The technical basis that underlies the approval of the exemption request is based partly on the analysis of a time period that spent fuel stored in the SFP is unlikely to reach the zirconium ignition temperature in less than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. This time period is based on a heat-up calculation which uses several simplifying assumptions. Some of these assumptions are conservative (adiabatic conditions), while others are non-conservative (no oxidation below 900°C). Weighing the conservatisms and non-conservatisms, the NRG judges that this calculation reasonably represents conditions which may occur in the event of an SFP accident.
The NRG concluded that if 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> were available to initiate mitigative actions, or if needed , offsite protective actions using Comprehensive Emergency Management Plan (CEMP), formal offsite radiological emergency response plans would not be necessary for a permanently defueled nuclear power reactor licensee. As supported by the licensee's SFP analysis , the NRG considers an
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 6 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption exemption from the requirements for formal offsite radiological emergency response plans is justified for a zirconium fire scenario considering the low likelihood of this event together with time available to take mitigative or protective actions between the initiating event and before the onset of a postulated fire .
Dresden has an analysis (Reference 2) that demonstrates that 365 days after permanent shutdown of Dresden, Units 2 and 3, the radiological consequences of the analyzed design basis accident (OBA) will not exceed the limits of the U.S.
Environmental Protection Agency (EPA) Protective Action Guides (PAGs) at the exclusion area boundary (EAB). An additional analysis (Reference 5) shows that 348 days after permanent cessation of power operations of Dresden , Unit 2, and 299 days after permanent cessation of power operations of Dresden , Unit 3, where the hottest fuel assembly adiabatic heat-up occurs, 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> are available to initiate mitigative actions, or if needed , offsite protective actions , using a CEMP from the time the fuel is uncovered until it reaches the auto-ignition temperature of 900°C.
Dresden maintains several strategies implemented by procedures for mitigating the loss of SFP water inventory. These mitigative strategies are maintained in accordance with License Conditions 2.C .(18) and 3.M of the Renewed Facility Operating Licenses for Dresden, Units 2 and 3, respectively. Mitigation strategies are also required to be maintained in accordance with the requirement provided in 10 CFR 50.155. These diverse strategies provide defense-in-depth and can be implemented in ample time to provide makeup water or spray to an SFP prior to the onset of zirconium cladding ignition should a very low probability beyond design basis event affect an SFP. However, in the Statement of Considerations (SOCs) for the final rule for Mitigation of Beyond-Design-Basis Events (80 FR 70610; November 13, 2015) (Reference 7) and in the associated Final Rule (84 FR 39684 ; Aug ust 9, 2019) (Reference 8), once the certifications of permanent removal of fuel from the reactor vessels have been submitted in accordance with 10 CFR 50.82(a)(1 ), the licensee does not need to comply with
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 7 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption the requirement in 10 CFR 50.155(e) to provide reliable means to remotely monitor wide-range SFP levels.
Several means will be available to provide makeup water to the SFPs, such as the Fire Protection (FP) System and the portable equipment maintained in accordance with Extensive Damage Mitigating Guidelines (EDMGs) (in support of License Conditions 2.C.(18) and 3.AA). There are diverse means to provide makeup water to an SFP via the FP system. The FP system provides 500 gpm, and a EDMG portable (B.5.b) pump provides 500 gpm . Water sources are from the Kankakee River and alternate fire service sources.
The on-shift staff has the capability (i.e., training and qualifications) and capacity (i.e., available personnel) to execute the required actions to mitigate a loss of SFP level and can complete those actions in a timely manner. In accordance with 10 CFR 50 .155, Dresden will maintain strategies to provide makeup to the SFPs until such a time that it is determined that the site can support the ability to sustain the SFPs indefinitely without EDMG equipment. Time validation was completed for EDMG strategies demonstrating ability for the station personnel to cope with various losses. Dresden EDMG Validation Plan with integrated review, dated November 9, 2017 , demonstrated that a team of three operators is capable of aligning makeup from the ultimate heat sink and aligning hoses to makeup to the SFPs in 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Two operators should complete the task in 8.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
Additional methods to makeup to the SFPs are bounded by this time. Direction and selection of these tasks will be accomplished by the Certified Fuel Handler and Non-Certified Operator.
Training of the on-shift staff will be maintained, and they will implement such strategies and plans to mitigate the consequences of an event involving a catastrophic loss-of-water inventory concurrently from an SFP.
2 10 CFR 50.47(b)(1 ): Primary responsibilities for Refer to the basis for 10 CFR 50.47(b).
emergency response by the nuclear facility licensee and by State and local organizations i.*.iithin the Emergency
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 8 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption Planning Zanes have been assigned , the emergency responsibilities of the various supporting organizations have been specifically established , and each principal response organization has staff to respond and to augment its initial response on a continuous basis.
3 10 CFR 50.47(b)(2) No exemption requested.
4 10 CFR 50.47(b)(3): Arrangements for requesting and Discontinuing offsite emergency planning activities and reducing the scope of effectively using assistance resources have been made , onsite emergency planning is acceptable given the significantly reduced offsite arrangements ta assammadate State and lasal staff at consequences when Dresden is in the permanently defueled condition. The the licensee's Emergency Operations Facility have Dresden emergency response plan will continue to maintain arrangements for been made, and other organizations capable of requesting and using assistance resources from offsite support organizations.
augmenting the planned response have been identified . Decommissioning power reactors present a low likelihood of any credible accident resulting in a radiological release together with the time available to take mitigative or, if needed, offsite protective actions using a CEMP between the initiating event and before the onset of a postulated fire . As such , an emergency operations facility (EOF) would not be required. The Control Room or other onsite location can provide for the communication and coordination with offsite organizations for the level of support required .
Also refer to the basis for 10 CFR 50.4 7(b ).
5 10 CFR 50.47(b)(4): A standard emergency classification Decommissioning power reactors present a low likelihood of any credible and action level scheme , the bases of which includes accident resulting in a radiological release together with the time available to take facility system and effluent parameters, is in use by the mitigative or, if needed , offsite protective actions using a CEMP between the nuclear facility licensee, and State and lasal response initiating event and before the onset of a postulated fire . As such , formal offsite plans call for reliance an infarmatian pra~JiEleEI by radiological emergency response plans are not required.
facility licensees far Eleterminatians af minim1;;1m initial Dresden will adopt the Permanently Defueled Emergency Action Levels (EALs) affsite response meas1;;1res. consistent with those detailed in Appendix C of Nuclear Energy Institute (NEI) 99-01 , "Development of Emergency Action Levels for Non-Passive
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 9 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption Reactors," Revision 6 (Reference 9), endorsed by the NRC in a letter dated March 28, 2013 (Reference 10). A site-specific Dresden analysis (Reference 5) shows that after the spent fuel has decayed for 348 days for Dresden, Unit 2, and 299 days for Dresden , Unit 3, for beyond design basis events where an SFP is drained, and air cooling is not possible, 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available to take mitigative or, if needed, offsite protective actions using a comprehensive approach to emergency planning from the time spent fuel cooling is lost until the hottest fuel assembly reaches a temperature of 900°C. No offsite protective actions are anticipated to be necessary. Therefore, classification above the Alert level (e .g., Site Area Emergency or General Emergency) will no longer be required.
Also refer to the basis for 10 CFR 50.4 7(b ).
6 10 CFR 50.47(b)(5): Procedures have been established Per SECY-00-0145 (Reference 11), after approximately 1 year of spent fuel for notification, by the licensee, of State and local response decay time (and as supported by the SFP analysis), the NRC considers an organizations and for notification of emergency personnel exception to the offsite EPA PAG standard is justified for a zirconium fire scenario by all organizations; the content of initial and followup considering the low likelihood of this event together with time available to take messages to response organizations and the p1;;1blic has mitigative or protective actions between the initiating event and before the onset been established; and means ta pra¥ide early of a postulated fire. If 10 CFR 50.155(b)(2)-type mitigation measures are natificatian and clear instrnctian ta the pap1;;1lace successful, releases could only occur during the first several days after the fuel within the pl1;;1me expas1;;1re pathway Emergency was removed from the reactor. As previously indicated, a Dresden analysis Planning Zane ha'le been established . (Reference 5) shows that after the spent fuel has decayed for 348 days for Dresden, Unit 2, and 299 days for Dresden, Unit 3, for beyond design basis events where an SFP is drained, and air cooling is not possible, 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available to take mitigative or, if needed, offsite protective actions using a comprehensive approach to emergency planning from the time spent fuel cooling is lost until the hottest fuel assembly reaches a temperature of 900°C. Therefore, offsite emergency response plans for the populace within the plume exposure pathway Emergency Planning Zone are not necessary for permanently defueled nuclear power plants .
Also refer to the basis for 10 CFR 50.4 7(b ).
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 10 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption 7 10 CFR 50.47(b)(6) : Provisions exist for prompt Refer to the basis for 10 CFR 50.47(b).
communications among principal response organizations to emergency personnel aRd ta the p1;;1eliG.
8 10 CFR 50.47(b)(7) : IRfarmatiaR is made a11ailaele ta Refer to the basis for 10 CFR 50.47(b).
the p1;;1eliG aR a periadiG basis aR haw they will be Ratified aRd i.*1hat their iRitial aGtiaRs sha1;;1ld ee iR aR emergeRGy (e.g., listeRiRg te a leGal ereadGast statieR aRd remaiRiRg iRdaars}, [T]he principal points of contact with the news media for dissemination of information during an emergency (iRsl1;;1diRg the physisal lasatiaR er laGatiaRs) are established in advance, and procedures for coordinated dissemination of information to the public are established.
9 10 CFR 50.47(b)(8) No exemption requested.
10 10 CFR 50.47(b)(9): Adequate methods, systems, and Refer to the basis for 10 CFR 50.47(b).
equipment for assessing and monitoring actual or potential affsite consequences of a radiological emergency condition are in use.
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 11 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption 11 10 CFR 50.4 7(b )(10): A range of protective actions has Dresden has developed an analysis (Reference 5) indicating that 348 days after been developed far the pl1;;1me expas1;;1re pathway EPZ permanent cessation of power operations for Dresden , Unit 2, and 299 days after for emergency workers and the public. IA Ele¥elaping this permanent cessation of power operations for Dresden , Unit 3, no credible or range af astians, sansiEleratiaR has been gi¥eR ta beyond design basis accident at Dresden, Units 2 and 3, will result in radiological e¥aG1;;1atian, sheltering, and, as a s1;;1pplement ta these, releases requiring offsite protective actions. The analysis of the potential the praphylastiG 1;;1se af patassi1;;1m iaEliEle {Kl}, as radiological impact of the postulated accident for Dresden, Units 2 and 3, in a appropriate. E¥as1;;1atian time estimates ha11e been permanently defueled condition indicates that any releases beyond the site Ele11elapeEI by applisants anEI lisensees. bisensees boundary are limited to small fractions of the EPA PAG exposure levels.
shall 1;;1pElate the e11as1;;1atian time estimates an a In the unlikely event of an SFP accident, the iodine isotopes which contribute to periaEliG basis. G1;;1iElelines far the shaise af pratesti11e an offsite dose from an operating reactor accident are not present, so potassium astians El1;;1ring an emergensy, sansistent with Federal iodide (Kl) distribution offsite would no longer serve as an effective or necessary g1;;1iElanse, are ElevelapeEI anEI in plase, anEI pratesti11e supplemental protective action .
astians far the ingestiaR expas1;;1re pathway EPZ apprapriate ta the lasale ha11e been ElevelapeEI. Because it is not possible for PAGs to be exceeded at Dresden , Units 2 and 3, following the Zirc-Fire Window, evacuation planning , including evacuation time estimates, is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.4 7(b ).
12 10 CFR 50.4 7(b )(11) through (b )(16) No exemption requested .
13 10 CFR 50.47(c)(1) No exemption requested .
14 10 CFR 50.47(c)(2) : Generally, the pl1;;1me expas1;;1re Dresden has developed an analysis (Reference 5) indicating that 348 days after path111ay EPZ far n1;;1slear pawer plants shall sansist af permanent cessation of power operations for Dresden , Unit 2, and 299 days after an area aba1;;1t rn miles {~G km) in raEli1;;1s anEI the permanent cessation of power operations for Dresden , Unit 3, no credible or ingestiaR pathi.Yay EPZ shall sansist af an area aba1;;1t beyond design basis accident at Dresden, Units 2 and 3, will result in radiological 50 miles {80 km) in raEli1;;1s. l=he exast size anEI releases requiring offsite protective actions . The analysis of the potential sanfig1;;1ratiaR af the EPZs s1;;1rra1;;1nEling a partis1;;1lar radiological impact of the postulated accident for Dresden, Units 2 and 3, in a
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 12 of 78 10 CFR 50, Appendix E TABLE 1 EXEMPTIONS REQUESTED FROM 10 CFR 50.47{b) AND {c){2)
Bold strikeUua1;;1gh text identifies the proposed exemption with respect to the regulation . The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50.47 Basis for Exemption RllGlear pat1<<er reaGtar shall be determined in relation permanently defueled condition indicates that any releases beyond the site ta laGal emergency response needs and Gapabilities as boundary are limited to small fractions of the EPA PAG exposure levels.
they are affeGted by SllGh GaRditians as demography, In the unlikely event of an SFP accident, the iodine isotopes which contribute to tapagraphy, land characteristics, access ra1;;1tes, and an offsite dose from an operating reactor accident are not present, so Kl j1;;1risdiGtianal ba1;;1ndaries. The size of the EPZs al&G distribution offsite would no longer serve as an effective or necessary may be determined on a case-by-case basis for gas- supplemental protective action .
cooled nuclear reactors and for reactors with an authorized power level less than 250 MW thermal. The plans far the Because it is not possible for PAGs to be exceeded at Dresden , Units 2 and 3 ,
ingestion pathway shall fac1;;1s an SllGh aGtians as are following the Zirc-Fire Window, evacuation planning is not needed since Dresden appropriate ta pretest the feed ingestion pathtNay. will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.4 7(b ).
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 13 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption 1 IV Content of Emergency Plans Following submittal of the "Certification of Permanent Removal of Fuel from the IV.1 . The applicant's emergency plans shall contain, but Reactor Vessel," in accordance with 10 CFR 50.82(a)(1 )(i) and (ii), Dresden, not necessarily be limited to, information needed to Units 2 and 3, will be permanently shutdown units with irradiated fuel stored in the demonstrate compliance with the elements set forth below, SFPs and ISFSI. In the EP Final Rule (76 FR 72560, November 23, 2011) i.e., organization for coping with radiological emergencies, (Reference 12), the NRC defined "hostile action" as, in part, an act directed assessment actions, activation of emergency organization, toward a nuclear power plant or its personnel. This definition is based on the notification procedures, emergency facilities and definition of "hostile action" provided in NRC Bulletin 2005-02, "Emergency equipment, training, maintaining emergency preparedness, Preparedness and Response Actions for Security-Based Events," dated
[and] recovery, amt ensite pretestive astiens during July 18, 2005 (Reference 13). NRC Bulletin 2005-02 was not applicable to hostile astieA. In addition, the emergency response plans nuclear power reactors that have permanently ceased operations and have submitted by an applicant for a nuclear power reactor certified that fuel has been removed from the reactor vessels .
operating license under this Part, or for an early site permit The NRC excluded non-power reactors from the definition of "hostile action" at the (as applicable) or combined license under 10 CFR Part 52, time of the rulemaking because , as defined in 10 CFR 50.2 , a non-power reactor shall contain information needed to demonstrate is not considered a nuclear power reactor and a regulatory basis had not been compliance with the standards described in§ 50.47(b), and developed to support the inclusion of non-power reactors (NPR) in the definition of they will be evaluated against those standards. "hostile action." Similarly, a decommissioning power reactor or ISFSI is not a "nuclear reactor" as defined in the NRC's regulations. A decommissioning power reactor also has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures. For all of these reasons, the NRC has concluded that a decommissioning power reactor is not a facility that falls within the definition of "hostile action."
Similarly, for security, risk insights can be used to determine which targets are important to protect against sabotage. A level of security commensurate with the consequences of a sabotage event is required and is evaluated on a site-specific basis. The severity of the consequences declines as fuel ages and, thereby, removes over time the underlying concern that a sabotage attack, under the current definition, could cause offsite radiological consequences.
Although, this analysis provides a justification for an exemption to include the definition for a "hostile action" and its related requirements, elements for security-based events would be maintained. The classification of security-based events, notification of offsite authorities and coordination with offsite agencies under a
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 14 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption CEMP would still be required. Other security-related requirements in the EP Final Rule would be exempted such as, on-shift staffing analysis, emergency response organization (ERO) augmentation and alternative facilities, protection of onsite personnel, and challenging drills and exercises due to the reduced radiological risk for a decommissioning power reactor.
The following similarities between Dresden and NPRs show that the Dresden facility should be treated in a similar fashion as an NPR. Similar to NPRs, Dresden will pose lower radiological risks to the public from accidents than do power reactors because: 1) Dresden will be a permanently shutdown facility (with fuel stored in the SFPs and ISFSI) and will no longer generate fission products;
- 2) fuel stored in the Dresden, Units 2 and 3, SFPs will have lower decay heat resulting in lower risk of fission product release in the event of a beyond design basis boil off or drain down event; and 3) no credible or beyond design basis accident at Dresden will result in radiological releases requiring offsite protective actions.
2 IV.2. t:his nuslear po11.ter reastor lisense applisant Dresden has developed an analysis (Reference 5) indicating that 348 days after shall also provide an analysis of the time required to permanent cessation of power operations for Dresden, Unit 2, and 299 days after evasuate various sestors and distanses within the permanent cessation of power operations for Dresden, Unit 3, no credible or plume exposure pathway EPZ for transient and beyond design basis accident at Dresden, Units 2 and 3, will result in radiological permanent populations, using the most resent IJ.S. releases requiring offsite protective actions. The analysis of the potential Census Bureau data as of the date the applisant radiological impact of the postulated accident for Dresden, Units 2 and 3, in a submits its applisation to the NRC. permanently defueled condition indicates that any releases beyond the site boundary are limited to small fractions of the EPA PAG exposure levels.
In the unlikely event of an SFP accident, the iodine isotopes which contribute to an offsite dose from an operating reactor accident are not present, so Kl distribution offsite would no longer serve as an effective or necessary supplemental protective action.
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning, including evacuation time estimates, is not needed since Dresden will meet the criteria for an exemption
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 15 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.47(b).
3 IV.3. NuGlear pe*.ver reaGter liGensees shall use NRG Dresden has developed an analysis (Reference 5) indicating that 348 days after appreved evaGuatien time estimates {e+es} and permanent cessation of power operations for Dresden, Unit 2, and 299 days after updates te the eleS in the fermulatien ef preteGti¥e permanent cessation of power operations for Dresden, Unit 3, no credible or aGtien reGemmendatiens and shall pre*1ide the e+es beyond design basis accident at Dresden, Units 2 and 3, will result in radiological and e+e updates te State and leGal ge11ernmental releases requiring offsite protective actions. The analysis of the potential autherities fer use in develeping effsite proteGtive radiological impact of the postulated accident for Dresden , Units 2 and 3, in a aGtien strategies. permanently defueled condition indicates that any releases beyond the site boundary are limited to small fractions of the EPA PAG exposure levels.
In the unlikely event of an SFP accident, the iodine isotopes which contribute to an offsite dose from an operating reactor accident are not present, so Kl distribution offsite would no longer serve as an effective or necessary supplemental protective action .
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning, including evacuation time estimates, is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.47(b).
4 IV.4. Within 365 days ef the later ef the date ef the Dresden has developed an analysis (Reference 5) indicating that 348 days after a11ailability ef the mest reGent deGennial Gensus data permanent cessation of power operations for Dresden , Unit 2, and 299 days after from the Y.S. Census Bureau er CeGember 23, 20~ ~, permanent cessation of power operations for Dresden, Unit 3, no credible or nuGlear pewer reaGter liGensees shall de11elep an e+e beyond design basis accident at Dresden , Units 2 and 3, will result in radiological analysis using this deGennial data and submit it under releases requiring offsite protective actions. The analysis of the potential
§ 50.4 te the NRG. +hese liGensees shall submit this radiological impact of the postulated accident for Dresden, Units 2 and 3, in a e+e analysis te the NRG at least ~ 80 days befere using permanently defueled condition indicates that any releases beyond the site it te ferm proteGti*1e aGtien reGemmendatiens and boundary are limited to small fractions of the EPA PAG exposure levels.
previding it te State and leGal gevernmental
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 16 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption authorities for use in developing offsite protestive In the unlikely event of an SFP accident, the iodine isotopes which contribute to astion strategies. an offsite dose from an operating reactor accident are not present, so Kl distribution offsite would no longer serve as an effective or necessary supplemental protective action.
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning, including evacuation time estimates, is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50 .4 7 (b ).
5 IV.5. During the years between desennial sensuses, Dresden has developed an analysis (Reference 5) indicating that 348 days after nuslear po11i.1er reastor lisensees shall estimate EP.l permanent cessation of power operations for Dresden, Unit 2, and 299 days after permanent resident population shanges onse a year, permanent cessation of power operations for Dresden, Unit 3, no credible or but no later than 365 days from the date of the beyond design basis accident at Dresden, Units 2 and 3, will result in radiological pre11ious estimate, using the most resent IJ.S. Census releases requiring offsite protective actions. The analysis of the potential Bureau annual resident population estimate and radiological impact of the postulated accident for Dresden, Units 2 and 3, in a State,llosal go11ernment population data, if a¥ailable. permanently defueled condition indicates that any releases beyond the site
+hese lisensees shall maintain these estimates so that boundary are limited to small fractions of the EPA PAG exposure levels.
they are a11ailable for NRG inspestion during the period In the unlikely event of an SFP accident, the iodine isotopes which contribute to bet1.veen desennial sensuses and shall submit these an offsite dose from an operating reactor accident are not present, so Kl estimates to the NRG with any updated E+E analysis. distribution offsite would no longer serve as an effective or necessary supplemental protective action.
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning, including evacuation time estimates, is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.47(b).
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 17 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception .
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption 6 IV.6. If at any time during the desennial period, the Dresden has developed an analysis (Reference 5) indicating that 348 days after EP~ permanent resident population insreases sush permanent cessation of power operations for Dresden , Unit 2, and 299 days after that it sauses the longest E+E ¥alue fer the 2 mile i!!:ene permanent cessation of power operations for Dresden , Unit 3, no credible or er 5 mile i!!:ene, insluding all affested Emergensy beyond design basis accident at Dresden , Units 2 and 3, will result in radiological Response Planning Areas, er fer the entire rn mile releases requiring offsite protective actions. The analysis of the potential EP~ te insrease by 25 persent er 30 minutes, radiological impact of the postulated accident for Dresden , Units 2 and 3, in a 11..ihishe¥er is less, from the nuslear power reaster permanently defueled condition indicates that any releases beyond the site lisensee's surrently NRG appre11ed er updated E+E, boundary are limited to small fractions of the EPA PAG exposure levels.
the lisensee shall update the E+E analysis te reflest In the unlikely event of an SFP accident, the iodine isotopes which contribute to the impast ef that population insrease. +he lisensee an offsite dose from an operating reactor accident are not present, so Kl shall submit the updated E+E analysis te the NRG distribution offsite would no longer serve as an effective or necessary under§ 50.4 ne later than 365 days after the lisensee's supplemental protective action.
determination that the sriteria fer updating the E+E ha¥e been met and at least ~ 80 days before using it te Because it is not possible for PAGs to be exceeded at Dresden , Units 2 and 3, form pretesfr1e astien resemmendatiens and following the Zirc-Fire Window, evacuation planning , including evacuation time pre¥iding it te State and lesal ge11ernmental estimates, is not needed since Dresden will meet the criteria for an exemption authorities fer use in de¥eleping effsite pretesti11e from offsite emergency preparedness requirements as discussed in the exemption astien strategies. from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.47(b).
7 IV.7. After an applicant for a combined license No exemption requested.
8 A. Organization No exemption requested.
The organization for coping< ... >
9 A.1. A description of the normal plant operating Once Dresden, Units 2 and 3, are permanently shutdown and defueled, and the organization. certifications submitted in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) per 10 CFR 50 .82(a)(2), they will no longer be authorized to operate . Because Dresden cannot operate the reactors, a plant "operating" organization will no longer be required. Rather, the facility will be maintained by a defueled on-shift staff.
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 18 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception .
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption 10 A.2. No exemption requested.
11 A.3. A desGriptien, by position and funGtien te be The number of staff at Dresden during decommissioning will be small but peFfermed, ef the liGensee's headquarters personnel commensurate with the need to safely store spent fuel at the facility in a manner who will be sent te the plant site te augment the ensite that is protective of public health and safety. Dresden will have a level of emergenGy ergani2'atien. emergency response that does not require response by headquarters personnel.
The on-shift and emergency response positions will be defined in the Permanently Defueled Emergency Plan (PDEP).
12 A.4 . Identification , by position and function to be Dresden has developed an analysis (Reference 5) indicating that 348 days after performed , of persons within the licensee organization who permanent cessation of power operations of Dresden , Unit 2, and 299 days after will be responsible for making effsite dose projections, and permanent cessation of power operations of Dresden , Unit 3, no credible or a description of how these projections will be made and the beyond design basis accident at Dresden , Units 2 and 3, will result in radiological results transmitted to State and local authorities, NRG, and releases requiring offsite protective actions. Dresden will maintain the capability other appropriate governmental entities. to determine if a radiological release is occurring. If a release is occurring ,
Dresden will promptly communicate that information to offsite authorities for their consideration . The offsite organizations are responsible for deciding what, if any, protective actions should be taken based on a CEMP.
13 A.5. ldentifiGatien, by position and funGtien te be As indicated by the Dresden , Units 2 and 3, adiabatic heat-up analysis peFfermed, ef ether employees ef the liGensee with (Reference 5), the time available to initiate compensatory actions in the event of a speGial qualifiGatiens fer Geping with emergenGy loss of SFP cooling or inventory precludes the need to identify and describe the Genditiens that may arise. Other persons 1,vith speGial special qualifications of these individuals in the emergency response plan. The qualifiGatiens, SUGh as G9nsultants, 1,yh9 are net number of staff at Dresden during decommissioning will be small but employees ef the liGensee and who may be Galled commensurate with the need to maintain the facility in a manner that is protective upon fer assistanGe fer emergenGies shall also be of public health and safety.
identified. The speGial qualifiGatiens ef these persons Also refer to the basis for 10 CFR 50.47(b).
shall be desGribed.
14 A.6. No exemption requested.
15 A.7. By June 23, 2014, [l]dentification of, and a A decommissioning power reactor has a low likelihood of a credible accident desGriptien ef the assistance expected from , appropriate resulting in radiological releases requiring offsite protective measures. For this State, local , and Federal agencies with responsibilities for reason and those described in the basis for 10 CFR 50, Appendix E, Section IV.1,
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 19 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception .
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption coping with emergencies, including hostile aGtion at the a decommissioning power reactor is not a facility that falls within the definitions of site. For purposes of this appendix, "hostile aGtion" is "hostile action ."
defined as an act directed toward a nuclear power plant or Similarly, for security, risk insights can be used to determine which targets are its personnel that includes the use of violent force to important to protect against sabotage. A level of security commensurate with the destroy equipment, take hostages, and/or intimidate the consequences of a sabotage event is required and is evaluated on a site-specific licensee to achieve an end . This includes attack by air, basis. The severity of the consequences declines as fuel ages, and over time, the land , or water using guns, explosives , projectiles, vehicles, underlying concern that a sabotage attack could cause offsite radiological or other devices used to deliver destructive force . consequences is removed.
Although the analysis described above and in the basis for 10 CFR 50 ,
Appendix E,Section IV.1 provides a justification for exempting Dresden from "hostile action" related requirements, some EP requirements for security-based events will be maintained. Protective actions are maintained for onsite personnel through the classification of security-based events, notification of offsite authorities, and coordination of offsite response organizations (i.e., local law enforcement, firefighting , medical assistance) onsite under a CEMP concept.
Following submittal of the "Certification of Permanent Removal of Fuel from the Reactor Vessel ," in accordance with 10 CFR 50.82(a)(1 )(i) and (ii), Dresden ,
Units 2 and 3, will be permanently shutdown units with irradiated fuel stored in the SFPs and ISFSI. In the EP Final Rule (76 FR 72560, November 23 , 2011)
(Reference 12), the NRG defined "hostile action" as, in part, an act directed toward a nuclear power plant or its personnel. This definition is based on the definition of "hostile action" provided in NRG Bulletin 2005-02 , "Emergency Preparedness and Response Actions for Security-Based Events," dated July 18, 2005 (Reference 13). NRG Bulletin 2005-02 was not applicable to nuclear power reactors that have permanently ceased operations and have certified that fuel has been removed from the reactor vessels.
The NRG excluded non-power reactors from the definition of "hostile action" at the time of the rulemaking because, as defined in 10 CFR 50.2 , a non-power reactor is not considered a nuclear power reactor and a regulatory basis had not been developed to support the inclusion of NPR in the definition of "hostile action. "
Similarly, a decommissioning power reactor or ISFSI is not a "nuclear reactor" as
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 20 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption defined in the NRC's regulations. A decommissioning power reactor also has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures . For all of these reasons, the NRC has concluded that a decommissioning power reactor is not a facility that falls within the definition of "hostile action."
Similarly, for security, risk insights can be used to determine which targets are important to protect against sabotage. A level of security commensurate with the consequences of a sabotage event is required and is evaluated on a site-specific basis. The severity of the consequences declines as fuel ages and , thereby, removes over time the underlying concern that a sabotage attack, under the current definition, could cause offsite radiological consequences .
Although, this analysis provides a justification for an exemption to include the definition for a "hostile action" and its related requirements, elements for security-based events would be maintained. The classification of security-based events, notification of offsite authorities and coordination with offsite agencies under a CEMP would still be required. Other security-related requirements in the EP Final Rule would be exempted such as, on-shift staffing analysis, ERO augmentation and alternative facilities, protection of onsite personnel, and challenging drills and exercises due to the reduced radiological risk for a decommissioning power reactor.
The following similarities between Dresden and NPRs show that the Dresden facility should be treated in a similar fashion as an NPR. Similar to NPRs, Dresden will pose lower radiological risks to the public from accidents than do power reactors because: 1) Dresden will be a permanently shutdown facility (with fuel stored in the SFPs and ISFSI) and will no longer generate fission products;
- 2) fuel stored in the Dresden, Units 2 and 3, SFPs will have lower decay heat resulting in lower risk of fission product release in the event of a beyond design basis boil off or drain down event; and 3) no credible or beyond design basis accident at Dresden will result in radiological releases requiring offsite protective actions.
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 21 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption 16 A.8. ldentifisatien of the State andJer lesal effisials Offsite emergency measures are limited to support provided by local police, fire responsible fer planning fer, ordering and sentrelling departments, and ambulance and hospital services, as appropriate. Because an appropriate pratestive astians, insluding evasuatians analysis has been developed (Reference 5) indicating that 348 days after when nesessary. permanent cessation of power operations of Dresden, Unit 2, and 299 days after permanent cessation of power operations of Dresden, Unit 3, and due to the low probability of design basis accidents or other credible events to exceed the EPA PAGs, protective actions such as evacuation should not be required , but could be implemented at the discretion of offsite authorities using a CEMP.
Dresden has developed an analysis (Reference 5) indicating that 348 days after permanent cessation of power operations for Dresden , Unit 2, and 299 days after permanent cessation of power operations for Dresden, Unit 3, no credible or beyond design basis accident at Dresden, Units 2 and 3, will result in radiological releases requiring offsite protective actions. The analysis of the potential radiological impact of the postulated accident for Dresden, Units 2 and 3, in a permanently defueled condition indicates that any releases beyond the site boundary are limited to small fractions of the EPA PAG exposure levels.
In the unlikely event of an SFP accident, the iodine isotopes which contribute to an offsite dose from an operating reactor accident are not present, so Kl distribution offsite would no longer serve as an effective or necessary supplemental protective action .
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.47(b).
17 A.9. 8y Cesember 24, 20~2, fer nuslear pai.ver reastar Responsibilities of the on-shift and emergency response personnel will be detailed lisensees, a detailed analysis demonstrating that en in the Permanently Defueled Emergency Plan and implementing procedures, shift persannel assigned emergensy plan regularly tested through drills and exercises, and audited and inspected by Exelon implementatian funstians are nat assigned and the NRC. The duties of the on-shift personnel at a decommissioning reactor respansibilities that wauld prei.ient the timely
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 22 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption perfarmanse of their assigned funstians as spesified facility are not as complicated and diverse as those for an operating power in the emergensy plan. reactor.
In the EP Final Rule (Reference 12), the NRC acknowledged that the staffing analysis requirement was not necessary for non-power reactor licensees because staffing at non-power reactors is generally small, which is commensurate with operating the facility in a manner that is protective of the public health and safety.
The minimal systems and equipment needed to maintain the spent nuclear fuel in the SFP or in a dry cask storage system in a safe condition requires minimal personnel and is governed by Technical Specifications. Because of the slow rate of the event scenarios postulated in the design basis accident and postulated beyond design basis accident analyses and because the duties of the on-shift personnel at a decommissioning reactor facility are not as complicated and diverse as those for an operating reactor, significant time is available to complete actions necessary to mitigate an emergency without impeding timely performance of emergency response plan functions . For all these reasons , it can be concluded that a decommissioning nuclear power plant is exempt from the requirement of 10 CFR 50, Appendix E, Section IV.A.9.
18 B. Assessment Actions B.1. The means to be used for determining the magnitude Dresden EALs will be developed consistent with the Permanently Defueled EALs of, and for continually assessing the impact of, the release detailed in Appendix C of NEI 99-01 , Revision 6 (Reference 9), which the NRC of radioactive materials shall be described , including found to be an acceptable method for development of EALs. Dresden will emergency action levels that are to be used as criteria for continue to review EALs with the State of Illinois on an annual basis. However, determining the need for notification and participation of based upon the reduced scope of EALs for the permanently defueled facility, the local and State agencies, the Commission, and other scope of the annual review of EALs is expected to be limited (i.e., informal Federal agencies, and the emergency action levels that mailings, etc.).
are to be used for determining when and what type of Following submittal of the "Certification of Permanent Removal of Fuel from the protective measures should be considered within amt Reactor Vessel," in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) , Dresden, outside the site boundary to protect health and safety. Units 2 and 3, will be permanently shutdown units with irradiated fuel stored in the The emergency action levels shall be based on in-plant SFPs and ISFSI. In the EP Final Rule (76 FR 72560, November 23 , 2011) conditions and instrumentation in addition to onsite amt (Reference 12), the NRC defined "hostile action" as, in part, an act directed Gffsite monitoring. By June 20, 20~2. far nuslear pa1...ier toward a nuclear power plant or its personnel. This definition is based on the
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 23 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption reastor lisensees, these astion levels must inslude definition of "hostile action" provided in NRG Bulletin 2005-02, "Emergency hostile astion that may adversely affest the nuslear Preparedness and Response Actions for Security-Based Events," dated power plant. The initial emergency action levels shall be July 18, 2005 (Reference 13). NRG Bulletin 2005-02 was not applicable to discussed and agreed on by the applicant or licensee and nuclear power reactors that have permanently ceased operations and have State and local governmental authorities, and approved by certified that fuel has been removed from the reactor vessels.
the NRG. Thereafter, emergency action levels shall be The NRG excluded non-power reactors from the definition of "hostile action" at the reviewed with the State and local governmental authorities time of the rulemaking because, as defined in 10 GFR 50 .2, a non-power reactor on an annual basis . is not considered a nuclear power reactor and a regulatory basis had not been developed to support the inclusion of NPR in the definition of "hostile action."
Similarly, a decommissioning power reactor or ISFSI is not a "nuclear reactor" as defined in the NRG's regulations. A decommissioning power reactor also has a low likelihood of a credible accident resulting in radiological releases requiring offsite protective measures. For all of these reasons, the NRG has concluded that a decommissioning power reactor is not a facility that falls within the definition of "hostile action."
Although, this analysis provides a justification for an exemption to include the definition for a "hostile action" and its related requirements, elements for security-based events would be maintained. The classification of security-based events, notification of offsite authorities and coordination with offsite agencies under a GEMP would still be required. Other security-related requirements in the EP Final Rule would be exempted such as, on-shift staffing analysis, ERO augmentation and alternative facilities, protection of onsite personnel, and challenging drills and exercises due to the reduced radiological risk for a decommissioning power reactor.
19 B.2. No exemption requested.
20 C. Activation of Emergency Organization The Permanently Defueled EALs, developed consistent with Appendix G of C.1. The entire spectrum of emergency conditions that NEI 99-01, Revision 6 (Reference 9) , will be adopted , as previously described.
involve the alerting or activating of progressively larger This scheme eliminates the Site Area Emergency and General Emergency event segments of the total emergency organization shall be classifications.
described. The communication steps to be taken to alert
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 24 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption or activate emergency personnel under each class of Additionally, the need to base EALs on containment parameters is no longer emergency shall be described. Emergency action levels appropriate since these parameters do not provide indication of the conditions at a (based not only on onsite amt affsite radiation monitoring defueled facility and emergency core cooling systems are no longer required.
information but also on readings from a number of sensors Other indications, such as SFP level or temperature, can be used at sites where that indicate a potential emergency, sush as the pressure there is spent fuel in the SFPs. The EAL scheme presented in NEI 99-01, in santainment and the response af the Emergensy Revision 6, was endorsed by the NRC in a letter dated March 28, 2013 Care Coaling System) for notification of offsite agencies (Reference 10). No offsite protective actions are anticipated to be necessary, shall be described. The existence, but not the details, of a since classification above the Alert (e.g., Site Area Emergency or General message authentication scheme shall be noted for such Emergency) level is no longer required . In the event of an accident at a defueled agencies. The emergency classes defined shall include: facility that meets the conditions for relaxation of emergency planning (1) notification of unusual events, (2) alert, {3) site area requirements, there will be available time for event mitigation, and if necessary, emergensy, and {4) general emergensy. These classes implementation of offsite protective actions using a comprehensive approach to are further discussed in NUREG-0654/FEMA-REP-1 . emergency planning . See the basis for 10 CFR 50.47(b) detailing the low likelihood of any credible accident resulting in radiological releases requiring offsite protective measures.
In the Statement of Considerations for the Final Rule for EP requirements for ISFSls and for MRS facilities (60 FR 32430; June 22, 1995) (Reference 6), the Commission responded to comments concerning a general emergency at an ISFSI and MRS, and concluded that," ... an essential element of a General Emergency is that a release can be reasonably expected to exceed EPA Protective Action Guidelines exposure levels off site for more than the immediate site area."
The probability of a condition reaching the level above an emergency classification of Alert is very low. In the event of an accident at Dresden that meets the criteria for an exemption from the NRC's offsite EP requirements, there will be time available to initiate mitigative actions consistent with plant conditions, and if necessary, for offsite authorities to employ their CEMP to take protective actions.
As stated in NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants" (February 2001) (Reference 14) for instances of small SFP leaks or loss of cooling scenarios, these events evolve very slowly and generally leave many days for recovery efforts. Offsite radiation
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 25 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception .
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption monitoring will be performed as the need arises. Due to the decreased risks associated with defueled plants, offsite radiation monitoring systems are not required.
Dresden EALs will be developed consistent with the Permanently Defueled EALs detailed in Appendix C of NEI 99-01 , Revision 6 (Reference 9), which the NRC found to be an acceptable method for development of EALs. Dresden will continue to review EALs with the State of Illinois on an annual basis. However, based upon the reduced scope of EALs for the permanently defueled facility, the scope of the annual review of EALs is expected to be limited (i .e., informal mailings, etc.).
21 C.2. By June 20, 2012, nuGlear pewer reaGter In the Statement of Consideration for the EP Final Rule published in the Federal Licensees shall establish and maintain the capability to Register (76 FR 72560) (Reference 12), non-power reactor licensees were not assess, classify, and declare an emergency condition required to assess, classify, and declare an emergency condition within 15 within 15 minutes after the availability of indications to minutes. An SFP and an ISFSI are also not nuclear power reactors as defined in plant operators that an emergency action level has been the NRC's regulations. A decommissioning power reactor has a low likelihood of exceeded and shall promptly declare the emergency a credible accident resulting in radiological releases requiring offsite protective condition as soon as possible following identification of the measures. For these reasons , the staff concludes that a decommissioning power appropriate emergency classification level. Licensees reactor should not be required to assess , classify, and declare an emergency shall not construe these criteria as a grace period to condition within 15 minutes.
attempt to restore plant conditions to avoid declaring an Dresden will maintain the capability to assess, classify, and declare an emergency emergency action due to an emergency action level that condition. Emergency declaration is required to be made as soon as conditions has been exceeded. Licensees shall not construe these warranting classification are present and recognizable , but within 30 minutes after criteria as preventing implementation of response actions the availability of indications to operators that an EAL threshold has been deemed by the licensee to be necessary to protect public reached. In the permanently defueled condition , the rapidly developing scenarios health and safety provided that any delay in declaration associated with events initiated during reactor power operation are no longer does not deny the State and local authorities the credible. The consequences resulting from the only remaining events (e.g ., fuel opportunity to implement measures necessary to protect handling accident) develop over a significantly longer period. As such, the 15-the public health and safety. minute requirement to assess, classify and declare an emergency is unnecessarily restrictive.
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 26 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption Also refer to the basis provided for 10 CFR 50.4 7(b) detailing the low likelihood of any credible accident resulting in radiological releases requiring offsite protective measures.
22 D. Notification Procedures D.1. Administrative and physical means for notifying local, Dresden has developed an analysis (Reference 5) indicating that 348 days after State, and Federal officials and agencies aRel agreemeRts permanent cessation of power operations for Dresden, Unit 2, and 299 days after reasheel 1,vith these affisials aRel ageRsies far the permanent cessation of power operations for Dresden, Unit 3, no credible or prompt RatifisatiaR af the publis aRel far publis beyond design basis accident at Dresden, Units 2 and 3, will result in radiological evasuatiaR er ether pratestive measures, shaulel they releases requiring offsite protective actions. The analysis of the potential besame Resessary, shall be described . This description radiological impact of the postulated accident for Dresden, Units 2 and 3, in a shall include identification af the appropriate affisials, by permanently defueled condition indicates that any releases beyond the site title aRel ageRsy, of the State and local government boundary are limited to small fractions of the EPA PAG exposure levels.
agencies withiR the EPZs. In the unlikely event of an SFP accident, the iodine isotopes which contribute to an offsite dose from an operating reactor accident are not present, so Kl distribution offsite would no longer serve as an effective or necessary supplemental protective action.
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.47(b).
23 D.2. Pra\<isiaRs shall be elessribeel far yearly Dresden has developed an analysis (Reference 5) indicating that 348 days after elissemiRatiaR ta the publiG withiR the plume e*pasure permanent cessation of power operations for Dresden , Unit 2, and 299 days after pathi,vay EPZ af basis emergeRGy plaRRiRg permanent cessation of power operations for Dresden, Unit 3, no credible or iRfarmatiaR, sush as the methaels aRel times required beyond design basis accident at Dresden , Units 2 and 3, will result in radiological far publis RatifisatiaR aRel the pratestive astiaRs releases requiring offsite protective actions. The analysis of the potential plaRReel if aR assieleRt assurs, geReral iRfarmatiaR as radiological impact of the postulated accident for Dresden, Units 2 and 3, in a ta the Rature aRel effests af raeliatiaR, aRel a listiRg af permanently defueled condition indicates that any releases beyond the site IGGal braaelsast statiaRs that will be useel far boundary are limited to small fractions of the EPA PAG exposure levels.
elissemiRatiaR af iRfarmatiaR eluriRg aR emergeRsy.
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 27 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption SigRs ar ether measures shall also be used ta In the unlikely event of an SFP accident, the iodine isotopes which contribute to dissemiRate ta aRy traRsieRt papulatiaR withiR the an offsite dose from an operating reactor accident are not present, so Kl plume exposure pathi.*i1ay EP.Z appropriate iRfarmatiaR distribution offsite would no longer serve as an effective or necessary that wauld be helpful if aR aGGideRt aGGurs. supplemental protective action.
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50 .4 7 (b ).
24 D.3. A licensee shall have the capability to notify Dresden proposes to complete emergency notifications within 30 minutes after the responsible State and local governmental agencies withifl event classification has been made. This timeframe is consistent with the 10 CFR Hi miRutes after declaring an emergency. l=he liGeRsee 50 .72(a)(3) notification to the NRC and is appropriate because in the permanently shall demaRstrate that the appropriate gavernmeRtal defueled condition, the rapidly developing scenarios associated with events authorities have the Gapability ta make a publiG initiated during reactor power operation are no longer credible and there is no alertiRg aRd RatifiGatiaR deGisiaR promptly aR beiRg need for State or local response organ izations to implement any protective iRfarmed by the liGeRsee af aR emergeRGy GaRditiaR. actions.
Prier ta iRitial aperatiaR greater thaR 5 perGeRt af rated Because of the geographic location of Dresden , emergency planning and thermal pa*.ver af the first reaGtar at a site, eaGh responsibilities have historically involved coordination with the State of Illinois.
RuGlear pa11i1er reaGtar liGeRsee shall demaRstrate that Decommissioning-related emergency plan submittals for Dresden have been admiRistrative aRd physiGal meaRs have beeR discussed with offsite response organizations since Exelon provided notification established far alertiRg aRd pra¥idiRg prompt that it would permanently cease power operations at Dresden, Units 2 and 3.
iRstruGtiaRs ta the publiG withiR the plume exposure These discussions have addressed changes to onsite and offsite emergency path1.*i1ay EP.Z. l=he desigR abjeGtive af the prompt preparedness throughout the decommissioning process, including the proposed publiG alert aRd RatifiGatiaR system shall be ta ha¥e time of 30 minutes to notify the state after the event classification has been made.
the Gapability ta esseRtially Gamplete the iRitial Illinois Emergency Management officials have been able to review and concur alertiRg aRd iRitiate RatifiGatiaR af the publiG withiR the with this proposal. The State's acknowledgement of their review will be provided plume exposure pathway EP.Z 111ithiR abaut ~ 5 miRutes. within the Dresden PDEP.
The use af this alertiRg aRd RatifiGatiaR Gapability will raRge fram immediate alertiRg aRd RatifiGatiaR af the Dresden has developed an analysis (Reference 5) indicating that 348 days after publiG {11i1ithiR ~ 5 miRutes af the time that State aRd permanent cessation of power operations for Dresden, Unit 2, and 299 days after laGal affiGials are Ratified that a situatiaR exists permanent cessation of power operations for Dresden, Unit 3, no credible or beyond design basis accident at Dresden, Units 2 and 3, will result in radiological
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 28 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption requiring urgent astien} ta the mere likely e 1ents 1 releases requiring offsite protective actions. The analysis of the potential
- 11here there is substantial time a*1ailable fer the radiological impact of the postulated accident for Dresden, Units 2 and 3, in a appropriate ge11ernmental authorities ta make a permanently defueled condition indicates that any releases beyond the site judgment whether er net ta asti11ate the publiG alert boundary are limited to small fractions of the EPA PAG exposure levels.
and netifisatian system. +he alerting and netifisatian In the unlikely event of an SFP accident, the iodine isotopes which contribute to sapability shall additionally inslude administrati11e and an offsite dose from an operating reactor accident are not present, so Kl physisal means fer a baskup method ef publis alerting distribution offsite would no longer serve as an effective or necessary and netifisatien sapable ef being used in the e11ent the supplemental protective action.
primary method ef alerting and netifisatien is una11ailable during an emergensy ta alert er notify all Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, er portions ef the plume exposure path*.vay EP~ following the Zirc-Fire Window, evacuation planning is not needed since Dresden population. +he baskup method shall ha11e the will meet the criteria for an exemption from offsite emergency preparedness sapability ta alert and notify the publis 1.vithin the requirements as discussed in the exemption from 10 CFR 50.47(b).
plume exposure pathway EP~, but does net need ta Also refer to the basis for 10 CFR 50.47(b).
meet the ~ 5 minute design ebjesti*1e fer the primary prompt publis alert and netifisatien system. ).llJheR there is a desisien ta aGti\<ate the alert and netifisatien system, the appropriate ga11ernmental authorities *1i1ill determine \*1hether ta asti11ate the entire alert and netifisatien system simultaneously er in a graduated er staged manner. +he responsibility fer asti11ating sush a publis alert and netifisatian system shall remain with the appropriate ge11ernmental authorities.
25 D.4. If FEM,O, has appre11ed a nuslear pe>,Yer reaster Dresden proposes to complete emergency notifications within 30 minutes after site's alert and netifisatien design report, insluding the the event classification has been made. This timeframe is consistent with the baskup alert and netifisatien sapability, as ef 10 CFR 50 .72(a)(3) notification to the NRC and is appropriate because in the IJesember 23, 20~ ~, then the baskup alert and permanently defueled condition, the rapidly developing scenarios associated with netifisatien sapability requirements in Sestien IV.IJ.3 events initiated during reactor power operation are no longer credible and there is must be implemented by IJesember 24, 20~2. If the no need for State or local response organizations to implement any protective alert and netifisatien design report does net inslude a actions.
baskup alert and natifisatien sapability er needs Because of the geographic location of Dresden , emergency planning and revision ta ensure adequate baskup alert and responsibilities have historically involved coordination with the State of Illinois.
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 29 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception .
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption natifiGatiaR Gapability, then a re*.iisiaR af the alert and Decommissioning-related emergency plan submittals for Dresden have been natifiGatiaR design report must be submitted ta FEMA discussed with offsite response organizations since Exelon provided notification far re*.iiei.*1 by June 24, 2013, and the FEMA approved that it would permanently cease power operations at Dresden, Units 2 and 3.
baGkup alert and natifiGatiaR means must be These discussions have addressed changes to onsite and offsite emergency implemented within 365 days after FEM,6, appraval. preparedness throughout the decommissioning process, including the proposed Ma*.vever, the total time period ta implement a FEMA time of 30 minutes to notify the state after the event classification has been made.
appraved baGkup alert and natifiGatiaR means must Illinois Emergency Management officials have been able to review and concur net exGeed June 22, 2015. with this proposal. The State's acknowledgement of their review will be provided within the PDEP.
26 E. Emergency Facilities and Equipment E.1 thru E.7 No exemption requested.
27 E.8.a.(i) A licensee ansite teGhRiGal suppart Genter and The Dresden , Units 2 and 3, analysis (Reference 5) indicates that within 348 days an emergeRGY aperatians facility from which effective after permanent cessation of power operations of Dresden , Unit 2, and 299 days direction can be given and effective control can be after permanent cessation of power operations of Dresden , Unit 3, no design exercised during an emergency; basis accidents or other credible event at Dresden , Units 2 and 3, will exceed the EPA PAGs. Due to the low probability of design basis accidents or other credible events to exceed the EPA PAGs at the site boundary, the available time for event mitigation at a decommissioning power reactor and , if needed , to implement offsite protective actions using a CEMP , an EOF would not be required to support offsite agency response. Onsite actions may be directed from the Control Room or other location , without the requirements imposed on a technical support center (TSC).
An onsite facility will continue to be maintained , from which effective direction can be given and effective control may be exercised during an emergency. The Dresden emergency response plan will continue to maintain arrangements for requesting assistance and using resources from appropriate offsite support organizations.
Discontinuing offsite emergency planning activities and reducing the scope of onsite emergency planning is acceptable given the significantly reduced offsite consequences when Dresden is in the permanently defueled condition. The
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 30 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption Dresden emergency response plan will continue to maintain arrangements for requesting and using assistance resources from offsite support organizations.
Decommissioning power reactors present a low likelihood of any credible accident resulting in a radiological release together with the time available to take mitigative or, if needed, offsite protective actions using a CEMP between the initiating event and before the onset of a postulated fire . As such, an EOF would not be required .
The Control Room or other onsite location can provide for the communication and coordination with offsite organizations for the level of support required.
Also refer to the basis for 10 CFR 50 .4 7 (b ).
28 E.8.a.(ii) Far Ruslear pa111er reaster liseRsees, a NUREG-0696, "Functional Criteria for Emergency Response Facilities,"
liseRsee aRsite eperatieRal suppert seRter; (Reference 15) provides that the operational support center (OSC) is an onsite area separate from the Control Room and the TSC where licensee operations support personnel will assemble in an emergency. For a permanently shutdown and defueled power plant, an OSC is no longer required to meet its original purpose of an assembly area for plant logistical support during an emergency.
The Control Room is the single onsite facility that provides support, emergency mitigation, radiation monitoring, and effective control that will be exercised during an emergency.
29 E.8.b. Far a Ruslear pawer reaster liGeRsee's In accordance with paragraph E.8.e., the requirements of paragraph 8.b do not emergeRsy aperatiaRs fasility required by paragraph apply to the Dresden EOF because it was an approved facility prior to 8.a af this sestiaR, either a fasility lasated bet1,1i1eeR December 23, 2011. However, the exemption is requested to clearly reflect that rn miles aRd 25 miles af the Ruslear pa1.-1er reastar the requirement no longer applies to Dresden in a permanently shutdown and site{s}, er a primaFy fasility lasated less thaR ~ O defueled condition.
miles fram the RuGlear pa1.ver reastar site{s} aRd a Discontinuing offsite emergency planning activities and reducing the scope of baskup fasility lesated betweeR rn miles aRd 25 onsite emergency planning is acceptable given the significantly reduced offsite miles ef the Ruslear pawer reaster site{s}. AR consequences when Dresden is in the permanently defueled condition. The emergeRGy aperatiaRs faGility may serve mare thaR Dresden emergency response plan will continue to maintain arrangements for eRe RUGlear pe1.ver reaster site. ,fl, liseRsee desiriRg requesting and using assistance resources from offsite support organizations.
te lasate aR emergeRGY aperatieRs fasility mare thaR 25 miles fram a Ruelear pawer reaetar site shall Decommissioning power reactors present a low likelihood of any credible accident resulting in a radiological release together with the time available to take mitigative
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 31 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption request prior Gommission appro\<al by submitting an or, if needed, offsite protective actions using a CEMP between the initiating event appliGation for an amendment to its liGense. and before the onset of a postulated fire . As such, an EOF would not be required.
For an emergenGy operations fasility loGated more The Control Room or other onsite location can provide for the communication and than 25 miles from a nuGlear pot,\!er reaGtor site, coordination with offsite organizations for the level of support required.
pra¥isians must be made far laGating NRG and Also refer to the basis for 10 CFR 50 .4 7 (b ).
affsite respanders slaser ta the nuGlear pawer reastar site sa that NRG and affsite respanders Gan interaGt faGe ta faGe with emergensy respanse persannel entering and lea¥ing the nuGlear pawer reaGtar site. Prat.<isians for laGating NRG and affsite respanders Glaser ta a nuGlear power reaGtor site that is mare than 25 miles fram the emergenGy aperations faGility must inGlude the fallawing:
(1) SpaGe far members of an NRG site team and Federal, State, and loGal responders; (2) Additianal spaGe far sandusting briefings with emergenGy respanse persannel; (3) GammuniGatian t,\!ith ether liGensee and offsite emergenGy response faGilities; (4) AGGess ta plant data and radialagiGal infarmatian; and (5) AGGess ta sapying equipment and affiGe supplies; 30 E.8 .c. By June 20, 20~2, far a nuGlear power reaGtar The Dresden , Units 2 and 3, analysis (Reference 5) indicates that within 348 days liGensee's emergenGy operatians faGility required by after permanent cessation of power operations of Dresden, Unit 2, and 299 days paragraph 8.a af this seGtion, a faGility ha¥ing the after permanent cessation of power operations of Dresden , Unit 3, no design fallawing sapabilities: basis accidents or other credible event at Dresden, Units 2 and 3, will exceed the (1) +he Gapability far abtaining and displaying plaRt EPA PAGs. Due to the low probability of design basis accidents or other credible data and radiologiGal information for eaGh reaGtar at a events to exceed the EPA PAGs at the site boundary, the available time for event nuGlear pat1i1er reastar site and far eash nuslear mitigation at a decommissioning power reactor and, if needed, to implement offsite protective actions using a CEMP, an EOF would not be required to support
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 32 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption pawer reastar site that the fasility serves; offsite agency response. Onsite actions may be directed from the Control Room (2) +he sapability ta aRalyi!!:e plaRt testmisal or other location , without the requirements imposed on a TSC.
iRfarmatiaR aRd pra¥ide teshRisal briefiRgs aR event An onsite facility will continue to be maintained, from which effective direction can saRditiaRs aRd pragRasis ta liseRsee aRd affsite be given and effective control may be exercised during an emergency. The respaRse argaRii!!:atiaRs far eash reastar at a Ruslear Dresden emergency response plan will continue to maintain arrangements for pawer reastar site aRd far eash Ruslear pawer reastar requesting assistance and using resources from appropriate offsite support site that the fasility serves; aRd organizations.
(3) +he sapability ta suppart respaRse ta e¥eRts Discontinuing offsite emergency planning activities and reducing the scope of assurriRg simultaneausly at mare thaR one RUGlear onsite emergency planning is acceptable given the significantly reduced offsite pawer reastar site if the emergeRsy aperatiaRs fasility consequences when Dresden is in the permanently defueled condition . The serves mare thaR aRe site; aRd Dresden emergency response plan will continue to maintain arrangements for requesting and using assistance resources from offsite support organizations.
Decommissioning power reactors present a low likelihood of any credible accident resulting in a radiological release together with the time available to take mitigative or, if needed, offsite protective actions using a CEMP between the initiating event and before the onset of a postulated fire . As such, an EOF would not be required.
The Control Room or other onsite location can provide for the communication and coordination with offsite organizations for the level of support required.
Also refer to the basis for 10 CFR 50.47(b).
31 E.8.d. Far Ruslear pat.ver reastar liseRsees, aR Following submittal of the "Certification of Permanent Removal of Fuel from the altematit1e fasility {or fasilities) that tivauld be Reactor Vessel ," in accordance with 10 CFR 50.82(a)(1 )(i) and (ii), Dresden ,
assessible eveR if the site is uRder threat of or Units 2 and 3, will be permanently shutdown units with irradiated fuel stored in the experieRGiRg hostile astiaR, ta fuRstiaR as a stagiRg SFPs and ISFSI. In the EP Final Rule (76 FR 72560, November 23, 2011) area far augmeRtatiaR of emergensy respaRse staff (Reference 12), the NRC defined "hostile action" as, in part, an act directed aRd sallestively haviRg the fallawiRg sharasteristiss: toward a nuclear power plant or its personnel. This definition is based on the the sapability far sammuRisatiaR t1i.1ith the emergeRsy definition of "hostile action" provided in NRC Bulletin 2005-02, "Emergency aperatiaRs fasility, saRtral roam, aRd plaRt sesurity; Preparedness and Response Actions for Security-Based Events," dated the sapability ta perform affsite RatifisatiaRs; aRd the July 18, 2005 (Reference 13). NRC Bulletin 2005-02 was not applicable to sapability far eRgiReeriRg assessmeRt astivities, nuclear power reactors that have permanently ceased operations and have iRsludiRg damage saRtral team plaRRiRg aRd certified that fuel has been removed from the reactor vessels.
preparatiaR, far use wheR aRsite emergeRsy fasilities
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 33 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption Gannet be safely aGGessed during hostile aGtien. l'.he The NRC excluded non-power reactors from the definition of "hostile action" at the requirements in this paragraph 8.d must be time of the rulemaking because, as defined in 10 CFR 50.2, a non-power reactor implemented no later than DeGember 23, 2014, 1,11ith the is not considered a nuclear power reactor and a regulatory basis had not been exGeptien af the Gapability far staging emergenGy developed to support the inclusion of NPR in the definition of "hostile action."
response argani;z;atian personnel at the alternati1._1e Similarly, a decommissioning power reactor or ISFSI is not a "nuclear reactor" as faGility {er faGilities} and the Gapability far defined in the NRC's regulations. A decommissioning power reactor also has a GammuniGatians '*'Jith the emergenGy aperatians low likelihood of a credible accident resulting in radiological releases requiring faGility, Gentral raem, and plant seGurity, whiGh must offsite protective measures. For all of these reasons, the NRC has concluded that be implemented na later than June 20, 2012. a decommissioning power reactor is not a facility that falls within the definition of "hostile action."
Although, this analysis provides a justification for an exemption to include the definition for a "hostile action" and its related requirements, elements for security-based events would be maintained. The classification of security-based events, notification of offsite authorities and coordination with offsite agencies under a CEMP would still be required. Other security-related requirements in the EP Final Rule would be exempted such as, on-shift staffing analysis, ERO augmentation and alternative facilities, protection of onsite personnel, and challenging drills and exercises due to the reduced radiological risk for a decommissioning power reactor.
32 E.8.e. A liGensee shall net be subjeGt ta the In accordance with paragraph E.8.e., the requirements of paragraph 8.b do not requirements af paragraph 8.b af this seGtian feF..a.R apply to the Dresden EOF because it was an approved facility prior to existing emergenGy eperatians faGility approved as of December 23, 2011. However, the exemption is requested to clearly reflect that DeGember 23, 2011; the requirement no longer applies to Dresden in a permanently shutdown and defueled condition.
Discontinuing offsite emergency planning activities and reducing the scope of onsite emergency planning is acceptable given the significantly reduced offsite consequences when Dresden is in the permanently defueled condition. The Dresden emergency response plan will continue to maintain arrangements for requesting and using assistance resources from offsite support organizations.
Decommissioning power reactors present a low likelihood of any credible accident resulting in a radiological release together with the time available to take mitigative
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 34 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception .
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption or, if needed, offsite protective actions using a CEMP between the initiating event and before the onset of a postulated fire . As such, an EOF would not be required .
The Control Room or other onsite location can provide for the communication and coordination with offsite organizations for the level of support required.
Also refer to the basis for 10 CFR 50 .4 7 (b ).
33 E.9.a. Provisions for communications with contiguous Dresden will maintain communications with the State of Illinois. Existing State/local governments within the plume exposure commercial phone lines will to be used to communicate EP notifications to the pathway EPZ. Such communications shall be tested State of Illinois and will continue to be functionally tested monthly.
monthly. Dresden has developed an analysis (Reference 5) indicating that 348 days after permanent cessation of power operations for Dresden , Unit 2, and 299 days after permanent cessation of power operations for Dresden, Unit 3, no credible or beyond design basis accident at Dresden, Units 2 and 3, will result in radiological releases requiring offsite protective actions. The analysis of the potential radiological impact of the postulated accident for Dresden, Units 2 and 3, in a permanently defueled condition indicates that any releases beyond the site boundary are limited to small fractions of the EPA PAG exposure levels.
In the unlikely event of an SFP accident, the iodine isotopes which contribute to an offsite dose from an operating reactor accident are not present, so Kl distribution offsite would no longer serve as an effective or necessary supplemental protective action.
Because it is not possible for PAGs to be exceeded at Dresden, Units 2 and 3, following the Zirc-Fire Window, evacuation planning is not needed since Dresden will meet the criteria for an exemption from offsite emergency preparedness requirements as discussed in the exemption from 10 CFR 50.47(b).
Also refer to the basis for 10 CFR 50.47(b).
34 E.9 .b No exemption requested 35 E.9 .c. Pra*1isian far GammuniGatians amang the Dresden has developed an analysis (Reference 5) indicating that 348 days after nuGlear pa*11er reaGtar Gantral ream, the ansite permanent cessation of power operations, no credible accident at Dresden, Units teGhniGal support Genter, and the emergenGy 2 and 3, will result in radiological releases requiring offsite protective actions; or in
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 35 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption operations fasility; and among the nuslear fasility, the the event of beyond design basis accidents, 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available to take prinsipal State and losal emergensy operations mitigative actions, and if needed, implement offsite protective actions using CEMP senters, and the field assessment teams. Sush concept.
sammunisatians systems shall be tested annually. Therefore, there is no need for the TSC, EOF, or field assessment teams.
Additionally, there is no need to maintain and test committed provisions for communications with State and local emergency operations centers (EOCs) with these facilities .
An onsite facility will continue to be maintained , from which effective command and control can be maintained during an emergency. Communication with State and local EOCs is maintained to coord inate assistance on site if required . Testing will be as described in justification for 10 CFR 50, Appendix E, Section IV.E.9.a The Dresden, Units 2 and 3, analysis (Reference 5) indicates that within 348 days after permanent cessation of power operations of Dresden, Unit 2, and 299 days after permanent cessation of power operations of Dresden, Unit 3, no design basis accidents or other credible event at Dresden , Units 2 and 3, will exceed the EPA PAGs. Due to the low probability of design basis accidents or other credible events to exceed the EPA PAGs at the site boundary, the available time for event mitigation at a decommissioning power reactor and , if needed, to implement offsite protective actions using a CEMP, an EOF would not be required to support offsite agency response. Onsite actions may be directed from the Control Room or other location, without the requirements imposed on a TSC .
An onsite facility will continue to be maintained, from which effective direction can be given and effective control may be exercised during an emergency. The Dresden emergency response plan will continue to maintain arrangements for requesting assistance and using resources from appropriate offsite support organizations.
Discontinuing offsite emergency planning activities and reducing the scope of onsite emergency planning is acceptable given the significantly reduced offsite consequences when Dresden is in the permanently defueled condition. The Dresden emergency response plan will continue to maintain arrangements for requesting and using assistance resources from offsite support organizations.
Request for Exemptions from Portions of Attachment 1 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and Page 36 of 78 10 CFR 50, Appendix E TABLE 2 EXEMPTIONS REQUESTED FROM 10 CFR 50, APPENDIX E Bold strikethrough text identifies the proposed exemption with respect to the regulation. The basis for the exemption explains the scope of the exception.
Item Regulation in 10 CFR 50, APPENDIX E, SECTION IV Basis for Exemption Decommissioning power reactors present a low likelihood of any credible accident resulting in a radiological release together with the time available to take mitigative or, if needed, offsite protective actions using a CEMP between the initiating event and before the onset of a postulated fire. As such, an EOF would not be required.
The Control Room or other onsite location can provide for the communication and coordination with offsite organizations for the level of support required.
Also refer to the basis for 10 CFR 50 .4 7 (b ).
36 E.9.d. Provisions for communications by the licensee with The functions of the Control Room, EOF, TSC and OSC are intended to be NRG Headquarters and the appropriate NRG Regional combined into an onsite facility due to the smaller facility staff and the greatly Office Operations Center from the nuclear power reactor reduced required interaction with State and local emergency response facilities.
control room, the onsite teshnisal support center, and An onsite facility will continue to be maintained, from which effective direction can the emergency operations facility. Such communications be given and effective control can be exercised during an emergency. Dresden shall be tested monthly. will maintain communication with the NRG.
Also refer to the basis for 10 CFR 50.47(b).
37 F. Training F.1. The program to provide for: (a) The training of employees and exercising, by periodic drills, of emergency plans to ensure that employees of the licensee are familiar with 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 radiological 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;