ZS-2012-0307, Request for Exemption to Revised Emergency Planning Rule

Request for Exemption to Revised Emergency Planning Rule

ML12173A316
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	06/20/2012
From:	Thurman P ZionSolutions
To:	Document Control Desk, NRC/FSME, Office of Nuclear Material Safety and Safeguards
References
ZS-2012-0307
Download: ML12173A316 (73)

Text

ZIONSOLUTIONSLLC An EnargySolutions Company 10 CFR 50.4 10 CFR 50.47 10 CFR 50 Appendix E June 20, 2012 ZS-2012-0307 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295, 50-304 and 72-1037

Subject:

Request for Exemption to Revised Emergency Planning Rule Pursuant to 10 CFR 50.12, ZionSolutions, LLC (ZionSolutions) requests NRC approval of an exemption from specific requirements of 10 CFR Part 50.47, Emergency Plans and 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities.

The NRC issued a Final Rule promulgating Enhancements to Emergency Preparedness Regulations in the Federal Register on November 23, 2011 (Reference 1). Pursuant to the Final Rule, licensees are permitted to defer implementation of the final rule until June 20, 2012 with some exceptions. The final rule was described in the Federal Register in terms of six security related Emergency Planning (EP) issues and six non-security related EP issues. These are identified below:

A. Security-Related EP Issues

1. On-Shift Staffing Analysis

2. Emergency. Action Levels for Hostile Action

3. Emergency Response Organization Augmentation and Alternative Facilities

4. Licensee Coordination with Offsite Response Organizations During Hostile Actions

5. Protection for Onsite Personnel

6. Challenging Drills and Exercises B. Non-Security Related EP Issues

1. Backup Means for Alert and Notification Systems

2. Emergency Declaration Timeliness

3. Emergency Operations Facility - Performance Based Approach

4. Evacuation Time Estimate Updating

5. Amended Emergency Plan Change Process

6. Removal of Completed One-Time Requirements 101 Shiloh Boulevard, Zion - IL 60099 (224) 789-4016 - Fax: (224) 789-4008 www.zionsolutionscoripany.com *'

4 ZionSolutions, LLC ZS-2012-0307 Page 2 of 3 This discussion in the Federal Register refers to some of these new or changed requirements as applicable to "nuclear power reactor licensees." Other aspects of the rule are discussed with regard to applicability to "non-power reactor licensees." The issues identified above which apply only to "nuclear power reactor licensees" are: A. l through A.5, portions of A.6, and B. 1 through B.4. 10CFR 50.4 define the terms: "nuclear reactor" and "non-power reactor." Neither of these definitions characterize licensees that have submitted certifications to permanently cease operations and permanently remove fuel from the reactor, pursuant to 10 CFR 50.82(a), such as ZionSolutions. Therefore, while ZionSolutions holds operating licenses, these licenses no longer authorize operation of the reactors and thus it could be argued that the new or changed rules described in the subject are not applicable to the Zion Nuclear Power Station (ZNPS) site, because of its 50.82 certification submission.

Furthermore, the Federal Register notice references a completed backfit analysis for the final rule. This Backfit Analysis, dated September 1, 2010 (Reference 2), is based upon the assumption that 65 power reactor sites and 32 non-power reactor sites are affected by this rule.

According to Section 3.2.4 of this analysis, the information used in the analysis was taken from NUREG-1350, Vol. 21, NRC Information Digest, 2009-2010 Edition (Reference 3). A review of this Digest Edition reveals that the analysis did not consider decommissioning or decommissioned sites, i.e., such as the Zion Nuclear Power Station.

Nonetheless, a review of the revised rule was conducted against the current license basis and NRC approved exemptions on Emergency Planning. The review determined that additional exemptions from portions of 10CFR Part 50 may be appropriate. While ZionSolutions believes that the existing Emergency Planning exemptions continue to apply to the regulations as modified and augmented, ZionSolutions is requesting an explicit exemption for some of the aspects of the new rule to clarify the license basis.

Pursuant to 10 CFR 50.12, "Specific Exemptions," ZionSolutions is requesting NRC approval of an exemption from certain requirements of 10 CFR 50.47 and 10 CFR 50, Appendix E.

Enclosure 1, "Exemption Request," identifies the specific requirements in the regulations that are the subject of the exemption request and contains the associated justifications. The regulations are grouped together according to the six security related emergency planning (EP) issues and six non-security related EP issues described above.

Enclosure 2, "Zion Compliance Matrix for Emergency Plan" identifies the regulations in order, compares the previous version of the regulation to the new rule and identifies the previous regulation as previously exempted with references to the relevant correspondence and license controlled documents.

ZionSolutions has determined that this exemption request and its impact on the corresponding emergency plan is authorized by law, will not present an undue risk to the public health and safety and is consistent with the common defense and security in accordance with 10CFR50.12.

Thus ZionSolutions' intent in submitting this exemption request is to maintain the current regulatory structure prior to the Enhancements to Emergency Preparedness Regulations and, therefore, does not propose any changes tothe Emergency Plan or implementing procedures other than simple regulatory reference changes that can be implemented under 10 CFR 50.54(q).

ZionSolutions, LLC ZS-2012-0307 Page 3 of 3 While this exemption request is pending with the NRC Staff, ZionSolutions requests enforcement discretion as to any potential noncompliance issues that would arise if it is determined that the new regulations apply to the ZNPS.

This submittal contains no new regulatory commitments or revisions to existing commitments.

We are requesting approval of the exemption at your earliest convenience. If you should have any questions regarding this submittal, please contact Chris Baker at (224) 789-4012.

Respectfully,

/Z Patrick S. Thurman, Esq.

///Vice President Regulatory Affairs ZionSolutions, LLC

References:

1) Enhancements to Emergency Preparedness Regulations (76 Federal Register (FR) 72560) dated November 23, 2011, effective December 23, 2011 for implementation June 20, 2012 with exceptions.

-2) Regulatory Analysis and Backfit Analysis, Final Rulemaking: Enhancements to Emergency Preparedness Regulations (10 CFR Parts 50 and 52), U.S. NRC, dated August 4, 2011.

3) NUREG-1350, Volume 21, NRC Information Digest 2009-2010 Edition, U.S. NRC, August 2009.

Enclosures:

(1) Exemption Request (2) Zion Compliance Matrix for Emergency Plan cc: John Hickman, U.S. NRC Senior Project Manager L. Raynard Wharton, U.S. NRC Senior Project Manager Regional Administrator, U.S. NRC Region III Service List (w/o Enclosures 1 and 2)

Zion Nuclear Power Station, Unit 1 and 2 License Transfer Service List cc:

Mr. Patrick T. Daly Mr. Kent McKenzie Senior VP and General Manager Emergency Management Coordinator ZionSolutions, LLC Lake County Emergency Management Agency 101 Shiloh Boulevard 1303 N. Milwaukee Avenue Zion, IL 60099 Libertyville, IL 60048-1308 Patrick Thurman, Esq. Regional Administrator VP Regulatory Affairs, Licensing and U.S. NRC, Region III Document Control 2443 Warrenville Road ZionSolutions, LLC Lisle, IL 60532-4352 101 Shiloh Boulevard Zion, IL 60099 John E. Matthews Morgan, Lewis & Bockius LLP Gary Bouchard 1111 Pennsylvania Avenue, NW VP Engineering, Ops & Nuclear Security Washington, DC 20004 and Decommissioning Plant Manager ZionSolutions, LLC 101 Shiloh Boulevard Zion, IL 60099 Alan Parker President Government Group EnergySolutions 800 Oak Ridge Turnpike, Ste. A-402 Oak Ridge, TN 37830 Thomas Magette Senior VP Nuclear Regulatory Strategy EnergySolutions 6350 Stevens Forest Road, Ste. 2000 Columbia, MD 21046 Russ Workman Deputy General Counsel EnergySolutions 423 West 300 South, Ste. 200 Salt Lake City, UT 84101 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, IL 62704

ZionSolutions, LLC ZS-2012-0307 Exemption Request

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 1 of 15 Introduction ZionSolutions, LLC (ZionSolutions) is the holder of Facility Operating License Nos. DPR-39 and DPR-48 which authorize the licensee to possess and store spent nuclear fuel and Greater-than-Class C (GTCC) radioactive waste at the Zion Nuclear Power'Station (ZNPS) Unit Nos. 1 and 2.

On November 23, 2011, the NRC issued a Final Rule promulgating Enhancements to Emergency Preparedness Regulations in the Federal Register (Ref. 1). Pursuant to the Final Rule, licensees are permitted to defer implementation of the final rule until June 20, 2012 with some exceptions.

The final rule was described in the Federal Register in terms of six security related emergency planning (EP) issues and six non-security related EP issues.

On August 31, 1999, the NRC issued an exemption (Ref. 2) from certain requirements of 10 CFR 50.47 and Appendix E to 10 CFR Part 50 for the ZNPS based upon requests submitted on April 13, 1999 (Ref. 3) and supplemented on July 8, 1999 (Ref. 7). This exemption was issued to discontinue offsite emergency planning activities and to reduce the scope of onsite emergency planning as a result of the permanently shutdown and defueled status of the facility. The staff concluded that the licensee's request for an exemption was acceptable in view of the greatly reduced offsite radiological consequences associated with the permanently shutdown facility status. The staff found that the postulated dose to the general public from any reasonably conceivable accident would not exceed the Environmental Protection Agency Protective Action Guides (EPA PAGs) and, for the bounding accident, the length of time available to respond to a loss of spent fuel cooling or reduction in water level gives confidence that offsite measures for the public could be taken without preparation.

As part of completing decommissioning, all spent fuel and GTCC waste will be transferred to an onsite Independent Spent Fuel Storage Installation (ISFSI), further minimizing the potential for offsite radiological consequences.

ZionSolutions requests that the NRC transfer the previously approved exemption and compliance basis to the new rule or grant new exemptions, as appropriate.

Discussion ZionSolutions has reviewed each relevant section of 10 CFR 50.47 and 10 CFR 50, Appendix E and created a compliance matrix for the facility in Enclosure 2. This matrix provides a detailed compliance discussion for each section and subsection of 10 CFR 50.47(b), and Part 50 Appendix E in order to determine whether that portion of the regulation is applicable to the ZNPS and, if so, whether an exemption is needed. In the portions of the regulation where an exemption is needed, the compliance matrix notes if an existing exemption is present.

Based upon the compliance matrix review, the following exemptions are requested in order to provide clarity for ZionSolutions and to ensure an unambiguous license basis. The exemption requests are grouped together according to the order of appearance in the matrix and multiple

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 2 of 15 sections requiring an exemption for the same item are grouped together according to the six security related emergency planning (EP) issues and six non-security related EP issues discussed in the Federal Register notice (Ref. 1). The previous exemptions for portions of the regulation are indicated by a line out with normal print. The new regulation language and the proposed exemptions are also indicated by a line out with bold print.

A. Security Related EP Issues A.1 On-Shift Staffing Analysis ZionSolutions requests an exemption from the NRC requirements to perform a detailed analysis to show that on-shift personnel assigned emergency plan implementation functions were not assigned any responsibilities that would prevent them from performing their assigned emergency plan functions. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR Part 50, Appendix E, Section. IV.A.9 exempt in its entirety.

Justification It is not necessary for ZionSolutions to perform this analysis, since the shift staffing at the ZNPS is small, commensurate with the need to operate the facility in a manner protective of public health and safety. Similar to a non-power reactor, the responsibilities are well outlined in the emergency plan and procedures, tested through drills and exercises regularly and audited/inspected by the licensee and the NRC. These measures ensure that on-shift personnel assigned emergency plan implementation functions are not assigned any responsibilities that would prevent them from performing their assigned functions without performing a detailed analysis.

A.2 Emergency Action Levels for Hostile Action ZionSolutions requests an exemption from the NRC requirements to include, in emergency action levels, hostile actions that may adversely affect the nuclear power plant. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR 50.47(b)(4) A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and leeal response plans call for-reliance on information provided by facility' licensees-for determinations of minimuminitial Off.ite response m.easu.es. (Previously issued by NRC on August 31, 1999)

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units I and 2 Exemption Request ZS-2012-0307 Page 3 of 15 10 CFR Part 50 Appendix E, Section. IV.B. 1 exempt as indicated below:

1. The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and ,et6tide(Previously issued by NRC on August 31, 1999) the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite a-Rd ,ffsite (Previously issued by NRC on August 31, 1999) monitoring. By June 20, 2012, for nu.lear, power reat*Or ntuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis.

Justification On August 31, 1999, the NRC issued an exemption from portions of 10 CFR 50.47(b)(4) as indicated above, regarding the need for State and local plans to rely on information provided by the licensee for offsite response measures. In the same letter, the NRC also issued an exemption from portions of 10 CFR Part 50, Appendix E, Section IV.B, as indicated above, from the requirement to base emergency action levels on offsite monitoring results and considerations of protective measures outside the site boundary. These exemptions continue to apply to ZionSolutions in the new rule.

ZionSolutions is further requesting an exemption from the new rule requiring action levels to include hostile action that may adversely affect the nuclear power plant as indicated in the markup above. This request is justified, in part, because the regulatory documents that form the basis of the new requirement do not apply to ZionSolutions. This requirement is based upon Order EA-02-026 (Ref. 4) and NRC Bulletin 2005-02 "Emergency Preparedness and Response Actions for Security-Based Events" (Ref. 5), neither of which apply to ZionSolutions. NRC Bulletin 2005-02 applies to all holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been removed from the reactor vessel.

Alternatively, ZionSolutions currently includes a security related event in the Emergency Classification Initiating Conditions to declare an Unusual Event for a "HUI - Confirmed Security Event with Potential Loss of Level of Safety of the Plant" or an Alert for a "HAI -

Confirmed Security Event in the Fuel Building." This exemption is justified in view of this alternative and based upon the greatly reduced offsite consequences associated with the current plant status.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 4 of 15 A.3 Emergency Response Organization Augmentation and Alternate Facilities ZionSolutions requests an exemption from the NRC requirements to provide alternate facilities that meet hostile action accessibility criteria. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR Part 50, Appendix E, Section IV.E.8.d exempt in its entirety.

Justification On August 31, 1999, the NRC issued an exemption from portions of 10 CFR Part 50, Appendix E, Section IV.E, as indicated above, from the requirement to provide for a near-site emergency operations facility. In support of this exemption request via letter dated April 13, 1999 (Ref. 3),

ZNPS stated that offsite emergency response capability and the technical support center are no longer appropriate as no design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary. This exemption continues to apply to the ZNPS in the new rule (Ref. 1) and, thereby, also renders ZionSolutions exempt from 10 CFR Part 50, Appendix E, Section IV.E.8.d, in its entirety. However, ZionSolutions requests that the NRC issue an exemption from these requirements to explicitly clarify the licensing basis. This exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status.

In addition, an exemption from 10 CFR Part 50, Appendix E, Section IV.E.8.d is justified, in part, because the regulatory documents that form the basis of the new requirement do not apply to ZionSolutions. This requirement is based upon Order EA-02-026 and NRC Bulletin 2005-02 "Emergency Preparedness and Response Actions for Security-Based Events", neither of which apply to ZionSolutions. NRC Bulletin 2005-02 applies to all holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been removed from the reactor vessel.

A.4 Licensee Coordination with Offsite Response Organizations During Hostile Action ZionSolutions requests an exemption from the NRC requirements to include in the licensee's emergency plan a description of the assistance expected from State, local and Federal agencies with responsibilities for coping with emergencies, including hostile action at the site. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR Part 50, Appendix E, Section. IV.A.7

7. By-Ji.. 23,42044-4 identification of, and a d.sc-iptiOn of the assistance expected from, appropriate State, local, and Federal agencies with responsibilities for coping with emergencies, including hostile action -atthe site. For purposes of this appendix, "hostile action" is defined as an nct dircctcd toward a nucicar powcr- Plant or its personnel that includcs the use of violent forcc to destroy equipment, take hostages, and/or intimidate the liccnscc to

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 5 of 15 aehicyc an end. This includes attack by air-, land, or water using guns, explosives, projectiles, vehicles, or other dcviccs used to deliver destr-tctivc forcce.

Justification An exemption from 10 CFR Part 50, Appendix E, Section IV.A.7 is justified, in part, because the regulatory documents that form the basis of the new requirement do not apply to ZionSolutions.

This requirement is based upon Order EA-02-026 and NRC Bulletin 2005-02 "Emergency Preparedness and Response Actions for Security-Based Events", neither of which apply to ZionSolutions. NRC Bulletin 2005-02 applies to all holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been removed from the reactor vessel.

Similar to non-power reactor licensees, ZionSolutions still identifies in its emergency plan the offsite response organizations that would respond to an emergency and the assistance expected from these resources, including those for hostile actions. This exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status and the existing provisions of the emergency plan.

A.5 Protection for Onsite Personnel ZionSolutions requests an exemption from the NRC requirements to provide a range of protective actions to protect onsite personnel, during hostile action to ensure the continued ability to safely shutdown the reactor and perform the functions of the emergency plan. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR 50.47(b)(10) exempt in its entirety (Previously issued by NRC on August 31, 1999) 10 CFR Part 50, Appendix E.Section IV. I The applicant's emergency plans shall contain, but not necessarily be limited to, information needed to demonstrate compliance with the elements set forth below, i.e., organization for coping with radiological emergencies, assessment actions, activation of emergency organization, notification procedures, emergency facilities and equipment, training, maintaining emergency preparedness, recovery, and onsite protective actions during hostile action. In addition, the emergency response plans submitted by an applicant for a nuclear power reactor operating license under this part, or for an early site permit (as applicable) or combined license under 10 CFR part 52, shall contain information needed to demonstrate compliance with the standards described in § 50.47(b), and they will be evaluated against those standards.

10 CFR Part 50, Appendix E, Section IV.I Onsite Protective Actions During Hostile Action By Juine 20, 2012, for nuclear power reactor licensees, a range of protective acetions to pr-otect onsite personnel during hostile action must be deveod toesure the continued ability of the licensee to safely shut down the reactor and performn the functions of the licensee's emergency plan-.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 6 of 15 Justification On August 31, 1999, the NRC issued an exemption from 10 CFR 50.47(b)(10) in its entirety, as indicated above, from the requirement to develop protective actions for the plume exposure and ingestion pathway EPZs. This exemption was based upon the ZNPS letter dated April 13, 1999 which stated that offsite emergency response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective actions guides at the site boundary. On January, 19, 2001 (66FR5440)

(Ref. 6), the NRC added a requirement to add considerations on the prophylactic use of potassium iodide (KI) to the possible protective action. ZNPS considered the previously issued exemption to apply to that added requirement.

ZionSolutions considers this exemption to continue to apply to the new requirement in the new rule, namely 10 CFR Part 50, Appendix E, Section IV. 1 and, thereby, also renders ZionSolutions exempt from 10 CFR Part 50, Appendix E, Section. IV.I in its entirety. However, ZionSolutions requests that the NRC issue an exemption from these requirements to explicitly clarify the licensing basis. This exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status.

An exemption from 10 CFR Part 50, Appendix E, Section IV. 1 is justified, in part, because the regulatory documents that form the basis of the new requirement do not apply to ZionSolutions.

This requirement is based upon Order EA-02-026 and NRC Bulletin 2005-02 "Emergency Preparedness and Response Actions for Security-Based Events", neither of which apply to ZionSolutions. NRC Bulletin 2005-02 applies to all holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been removed from the reactor vessel. Furthermore, because the Zion reactors are permanently shut down and defueled, there is no need to ensure the continued ability to safely shutdown the reactor: The current plans and procedures provide sufficient assurance of the capability to perform the functions of the emergency plan.

A.6. Challenging Drills and Exercises ZionSolutions requests an exemption from the NRC requirements to 1) submit exercise scenarios under I OCFR50.4 at least 60 days before use, 2) include in exercise and drill scenarios a spectrum of radiological releases and events, including hostile action, 3) emphasize in exercise and drill scenarios coordination among onsite and offsite response organizations, 4) demonstrate ERO proficiency in all of the key skills necessary to implement the principal functional areas of emergency response and 5) conduct exercises in accordance with an eight-year exercise cycle.

These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units I and 2 Exemption Request ZS-2012-0307 Page 7 of 15 Specific regulations subject to this request for exemption 10 CFR Appendix E,Section IV.F.2.a A full participation 4 exercise which tests as much of the licensee, State, and local emergency plans as is reasonably achievable without mandatory public participation shall be conducted for each site at which a power reactor is located. N-uelear powe-r reactor-licensees shall submit excie scnros tinder-§ 50.4 at least 60 days before use in a full par-ticipation excis rIquirced by this paragraph 2.a.

10 CFR Appendix E,Section IV.F.2.b Each licensee at each site shall conduct a subsequent exercise of its onsite emergency plan every 2 years. Nuccar-power- ra.tor.li,.ns..s shll submit exrcs sdarios under § 50.4 at least 60 days before use in an excrcise -requiredby this paragraph 2.b. The exerceise may be incluided in the full participation biennial eecs required by paragraph 2.e. of this seetfin. In addition, the licensee shalltake actions necessary to ensure that adequate emergency response capabilities are maintained during the interval between biennial exercises by conducting drills, including at least one drill involving a combination of some. of the principal functional areas of the licensee's onsite emergency response capabilities.

The principal functional areas of emergency response include activities such as management and coordination of emergency response, accident assessment, event classification, notification of offsite authorities, assessment of the onsite and offsite impact of radiological releases, protective action recommendation development, protective action decision making, plant system repair and mitigative action implementation. During these drills, activation of all of the licensee's emergency response facilities (Techniel ,*vveft Center- (TSC,, O'-a'---s u<e-Center- (O , and the* Ee.........erati.+*ons F:*aei., (EO* would not be necessary, licensees would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in all participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills may focus on the onsite exercise training objectives.

10 CFR Appendix E,Section IV.F.2.c & d exempt in its entirety (Previously issued by NRC on August 31, 1999) 10 CFR Appendix E,Section IV.F.2.i Licensees shall use drill and exercise scenarios that provide reasonable assurance that anticipatory responses will not result from preconditioning of participants. Such sc.nar.ios for-nu.l.ar power .rcactor lieens,.s must includc a 'wide spcctrum of r-adiological releases and events, including hostile acetion.

Exercise and drill scenarios as appropriate must emphasize coordination among onsite and offsite response organizations.

10 CFR Appendix E,Section IV.F.2.j exempt in its entirety

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 8 of 15 Justification On August 31, 1999, the NRC issued an exemption from 10 CFR Appendix E, Section. IV.F.

from the following exercise and drill scenario requirements:

F. 1.viii - Delete Headquarters support personnel and local news media persons from the list of categories of emergency personnel who will be provided training.

F.2 - Eliminate the requirementto test the public notification system as part of emergency preparedness exercises.

F.2.b - Eliminate the reference to specific emergency response facilities, Technical Support Center, Operations Support Center and the Emergency Operations Facility.

F.2.c - Remove, the requirement for a biennial exercise with full participation of offsite authorities.

F.2.d - Remove the requirement for an ingestion pathway exercise.

F.2.e - Replace the phrase "located within the plume exposure pathway EPZ" with "support services" to modify and clarify the governmental entities who would be permitted to participate in emergency preparedness drills.

F.2.f- Eliminate reference to the Federal Emergency Management Agency (FEMA) and State and local participation in remedial exercises.

This exemption was based upon ZNPS's letter dated April 13, 1999 which stated that offsite emergency response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary. ZionSolutions considers that this exemption continues to apply to the ZNPS in many aspects of the new rule and, thereby, also renders ZionSolutions exempt from 10 CFR Appendix E, Section. IV.F.2.c, d and j (as modified by the new rule) exempt in its entirety and other portions of Section IV.F as indicated above. However, ZionSolutions requests that the NRC issue an exemption from these requirements to explicitly clarify the licensing basis. This exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status.

The request for exemption from the requirement for nuclear power reactor licensees to submit exercise scenarios under § 50.4 at least 60 days before use in a full participation exercise required by this paragraph 2.a is justified, in part, because ZionSolutions is already exempt from the requirement to hold a full participation exercise. In addition, this requirement applies to

nuclear power reactor licensees." This term does not address licensees that have submitted certifications to permanently cease operations and permanently remove fuel from the reactor, pursuant to 10 CFR 50.82(a), such as ZionSolutions. While ZionSolutions holds operating licenses, those licenses no longer authorize operation of the reactor and thus this requirement should be subject to the previously authorized exemption for the previously accepted basis.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 9 of 15 Accordingly, ZionSolutions requests that the NRC issue an exemption from this requirement to explicitly clarify the licensing basis.

The request for exemption from the requirement that scenarios for nuclear power reactor licensees must include a wide spectrum of radiological releases and events, including hostile action" is justified, in part, because the term nuclear power reactor licensee does not sufficiently address the status of ZNPS, as described above. Furthermore, this requirement is based, in part, on NRC Bulletin 2005-02 "Emergency Preparedness and Response Actions for Security-Based Events," which does not apply to ZionSolutions. NRC Bulletin 2005-02 applies to all holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been removed from the reactor vessel. Accordingly, ZionSolutions requests that the NRC issue an exemption from this requirement to explicitly clarify the licensing basis.

B. Non-Security Related EP Issues B.1 Backup Means for Alert and Notification Systems ZionSolutions requests an exemption from the NRC requirements to require backup power for sirens or other backup ANS alerting capabilities. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR Part 50 Appendix E, Section IV.D.3 (Previously issued by NRC on August 31, 1999)

A licensee shall have the capability to notify responsible State and local governmental agencies within 60 5 minutes after declaring an emergency. The licensee shall demonstrate that the apprnopiate governmental au.thorities have the capability to m.ae a public alerting an notification decision promiptly on being info, ed by the licensee of an emfier.gency condition.

Prior-to initial opcration grcater-than 5 pcrccent of ratcd thcrmal powcr of thc first r-eacto~r at a site, each nuclear powef feactor licensee shall demonstrate that administrative and physical means have been4 e-st-ablished for alerting and proeviding prompt instructions to the public within the plume exposurfe pathway EPZ. The design objective of the promfipt public alert an notification system shall be to. have the capability to essentially cmplete the initial alerting and initiate notificationt of the public 'within the plume exposuire pathway 'EPZ 'within about 15 minut~es. The use of this alerting and notification capability will range from imfmediate alerting

-Andno-tificeation of the public ('within 15 minuites of the time that State and local officials are notified that a situation exists r-equir-ing urgent action) to the more likely events 'where there is substantial time available for the appropriate goenetal authorities to make a 'judgment

'whether-or-not to activate the public _alert. -anldnoi~tification systemf. The alerting and notification capability shall additionally include adiitaieadphysical means for-a backup method of public alerting and notificain cpal of being used in the event the pr.Imr mtethod of alerting and notification is unavailable during an emer-gency shl hav the ea ItIt toaetadIIiyte ulewtiftepufl ~o~ept- to aler-t or-notify, all or portions of the plume exposure pathway EPZ population. The backutp method

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 10 of 15 EPZ, but does not need to meet thc 15 minute design objeetivc for the primary prompt notification system, the approp.iate g.vernmental authr*,ities will determine whether- to a.tivate.

thentre.alert anld notification system simultan-eously orf in a tgra-du-ated or staged manner. The r-esponsibility fer activating suceh a public alert, and notification sy~tem shall r-emfain with the approepr-iate gover-nmental authorities.

Justification On August 31, 1999, the NRC issued an exemption from 10 CFR Part 50 Appendix E, Section IV.D.3, as indicated above, from the requirement to demonstrate that State/local officials have the capability to make public notification promptly, and changed the time for notification of State and local, agencies to within 30 minutes and the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after declaring an emergency. This exemption was based upon ZNPS's letter dated April 13, 1999 which stated that offsite emergency response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary. ZionSolutions considers that this exemption continues to apply to the ZNPS as modified by the new rule and, thereby, also automatically renders ZionSolutions exempt from the portions of 10 CFR Appendix E, Section. IV.D.3 indicated above. However, ZionSolutions requests that the NRC issue an exemption from these requirements to explicitly clarify the licensing basis. This exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status.

B.2 Emergency Declaration Timeliness ZionSolutions requests an exemption from the NRC requirements to establish and maintain the capability to assess, classify and declare an emergency condition within 15 minutes... These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR Part 50, Appendix E, Section IV.C.2 exemption in its entirety.

Justification The request for exemption from the requirement for nuclear power reactor licensees to establish and maintain the capability to assess, classify and declare an emergency condition within 15 minutes is justified, in part, because this requirement applies to "nuclear power reactor licensees." This term does not sufficiently address licensees that have submitted certifications to permnanently cease operations and permanently remove fuel from the reactor, pursuant to 10 CFR 50.82(a), such as ZionSolutions. While ZionSolutions holds operating licenses, those licenses no longer authorizes operation of the reactor and thus this requirement should not apply.

Nonetheless, ZionSolutions requests that the NRC issue an exemption from this requirement to explicitly clarify the licensing basis.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 11 of 15 Furthermore, on August 31, 1999, the NRC issued an exemption from 10 CFR Part 50 Appendix E, Section IV.D.3, to increase the time for notification of State and local agencies to within 30 minutes and the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after declaring an emergency. In the accompanying, safety evaluation report, the NRC noted that the length of time involved in the bounding accident provides confidence that offsite protective measures for the public could be taken, if necessary, without the need for preplanning. Therefore, this exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status.

B.3. Emergency Operations Facility - Performance Based Approach ZionSolutions requests an exemption from the NRC requirements to have an operational support center and emergency operational facility. Specifically, the newly promulgated distance criteria, performance based criteria and hostile action accessibility criteria are not applicable. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

Specific regulations subject to this request for exemption 10 CFR Part 50, Appendix E, Section IV.E.8.

8.a. (i) A licensee onsite technical support center and an emer.gency operations faility from which effective direction can be given and effective control can be exercised during an emergency; (Previously issued by NRC on August 31, 1999) 8.a (ii), b, and c, exempt in its entirety.

Justification On August 31, 1999, the NRC issued an exemption from portions of 10 CFR Part 50, Appendix E, Section IV.E from the requirement to provide for a near-site emergency operations facility.

Offsite emergency response capability and the technical support center are no longer appropriate as no design basis accident can result in radioactive releases which exceed EPA's protective action guides at the site boundary. This exemption continues to apply to the ZNPS in the new rule and, thereby, also renders ZionSolutions exempt from 10 CFR Part 50, Appendix E, Section IV.E.8. a (ii), b, c, and d, in its entirety. However, ZionSolutions requests that the NRC issue an exemption from these requirements to explicitly clarify the licensing basis. This exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status.

B.4 Evacuation Time Estimates (ETE) Updating ZionSolutions requests an exemption from the NRC requirements to develop and update evacuation time estimates. These requirements are found in the following references of Title 10 of the Code of Federal Regulations.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 12 of 15 Specific regulations subject to this request for exemption 50.47(b)(10) & App E, Sec. IV.3-6 10 CFR 50.47(b)(1 0) exempt in its entirety (Previously issued by NRC on August 31, 1999) 10 CFR Part 50, Appendix E, Section IV.2 (Previously issued by NRC on August 31, 1999) 10 CFR Part 50, Appendix E.Section IV.3 through 6 exempt in its entirety Justification On August 31, 1999, the NRC issued an exemption from 10 CFR 50.47(b)(10) in its entirety, as indicated above, from the requirement to develop protective actions for the plume exposure and ingestion pathway EPZs. Offsite emergency response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective actions guides at the site boundary. On January, 19, 2001 (66FR5440), the NRC added a requirement to add considerations of the prophylactic use of potassium iodide (KI) to the possible protective action. ZNPS considered the previously issued exemption to apply to that added requirement.

In the same letter, the NRC also issued an exemption from 10 CFR Part 50, Appendix E, Section IV to provide an analysis of the time required to evacuate and for taking other protective actions for various sectors and distances within the plume exposure pathway EPZ for transient and permanent populations. This requirement has been renumbered as 10 CFR Part 50, Appendix E, Section IV.2 and augmented in the new rule.

ZionSolutions considers this exemption to apply to the new requirement in the new rule, namely 10 CFR 50.47(b)(10) and 10 CFR Part 50, Appendix E, Section. IV.2 and thereby also renders ZionSolutions exempt from 10 CFR Part 50, Appendix E, Section. IV.3-6 in its entirety.

However, ZionSolutions requests that the NRC issue an exemption from these requirements to explicitly clarify the licensing basis. This exemption is justified based upon the greatly reduced offsite consequences associated with the current plant status.

Summary of Exemptions Requested Based on the above discussion, application of all of the requirements in 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50 is not necessary to achieve the underlying purpose of those rules in view of the greatly reduced offsite radiological consequences associated with the current plant status. The requested exemptions are justified, in part because offsite emergency response capability is no longer appropriate as no design basis accident or credible beyond design basis accident can result in radioactive releases which exceed EPA's protective actions guides at the site boundary.

The Requested Exemption is Authorized By Law The NRC has the authority under the Atomic Energy Act to grant exemptions from its regulations if doing so would not violate the requirements of law. The exemption is authorized by law as is required by 10 CFR 50.12. No law exists that precludes the activities covered by this exemption request. The provisions of 10 CFR 50.47 and 10 CFR 50, Appendix E were adopted

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units 1 and 2 Exemption Request ZS-2012-0307 Page 13 of 15 at the discretion of the Commission consistent with its statutory authority. No statute required the NRC to adopt the specific provisions from which ZionSolutions seeks an exemption. Rather, the NRC may determine that alternative means are adequate to provide reasonable assurance of safety.

The Requested Exemption Will Not Present an Undue Risk to the Public Health and Safety, and is Consistent with the Common Defense and Security The exemption request would permit ZionSolutions to continue to implement emergency planning requirements commensurate with the reduced risk associated with a plant undergoing decommissioning including the planned, near-term movement of the spent fuel from the fuel pool to a stand-alone Independent Spent Fuel Storage Installation. Thus the requested exemption will not present an undue risk to the public health and safety and is consistent with the common defense and security.

The Requested Exemption is in the Public Interest The requested exemption is in the public interest, because it will allow ZionSolutions to implement a safe approach to maintaining onsite emergency planning without the need by ZionSolutions for new systems, equipment, and training programs at a substantial cost without any added safety benefit. Therefore, granting the exemption is in the public interest.

Environmental Assessment In accordance with 10 CFR 51.30 and 51.32, the following information is provided in support of an environmental assessment and finding of no significant impact for the proposed action.

The proposed action would grant an exemption from certain requirements of 10 CFR 50.47 and 10 CFR Part 50 Appendix E, which contain requirements for emergency planning. Specifically, the exemption will eliminate unnecessary requirements associated with offsite consequences, protective actions, hostile action and emergency facilities in light of the current status of the ZNPS.

Pursuant to 10 CFR 50.82, the ZNPS poses a significantly reduced risk to public health and safety from design basis accidents or credible beyond design basis accidents since these cannot result in radioactive releases which exceed EPA's protective actions guides at the site boundary.

Because of this reduced risk, compliance with all the requirements in 10 CFR 50.47 and 10 CFR Part 50 Appendix E is not appropriate. The requested exemption from portions of 10 CFR 50.47 and 10 CFR Part 50 Appendix E is needed to continue decommissioning of the ZNPS and implementing the ZNPS Emergency Plan that is appropriate for a permanently shutdown facility and is commensurate with the reduced risk posed by the facility. The requested exemption will allow safe storage of spent fuel storage to continue without imposing burdensome and costly new requirements that provide no increased safety benefit.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units I and 2 Exemption Request ZS-2012-0307 Page 14 of 15 The principle alternative to the proposed action would be to deny the requested exemption.

Denial of the exemption request would result in no change in environmental impacts. Concerning alternative use of resources, granting the requested exemption will'not involve the use of resources not previously considered in the Final Environmental Statement for the new Emergency Planning Rule. The proposed action (i.e., granting the exemption) will not increase the probability or consequences of accidents, no changes are being made in the types or quantities of effluents that may be released offsite, and there is no significant increase in occupational or public radiation exposure. Therefore, there are no significant radiological environmental impacts associated with the proposed action.

The proposed action does not affect non-radiological plant effluents and has no other environmental impact. Therefore, there are no significant non-radiological impacts associated with the proposed action. Based on the assessment above, the proposed action will not have a significant effect on the quality of the human environment.

Conclusion ZionSolutions considers that this exemption request is in accordance with the criteria of 10 CFR 50.12. Maintaining emergency planning requirements at the ZNPS commensurate with an operating reactor facility is not necessary to achieve the underlying basis of 10 CFR 50.47 and 10 CFR Part 50 Appendix E. The radiological risk to the public has been significantly reduced because the ZNPS is a facility that has its spent nuclear fuel stored in a spent fuel pool and is transferring the spent fuel to dry cask storage. There are no adverse environmental impacts associated with this specific exemption.

References

1. Enhancements to Emergency Preparedness Regulations (76 Federal Register (FR) 72560) dated November 23, 2011, effective December 23, 2011 for implementation June 20, 2012 with exceptions.

2. U.S. NRC letter to Commonwealth Edison Company dated August 31, 1999, "Request for Approval of Defueled Station Emergency Plan and Exemption from Certain Requirements of 10 CFR 50.47, Emergency Plan," Zion Nuclear Power Station, Unit Nos. l and 2, August 31, 1999.

3. Commonwealth Edison Company letter to the U.S. NRC, "Request for Approval of Defueled Station Emergency Plan and Exemption from Certain Requirements of 10 CFR 50.47, Emergency Plan," dated April 13, 1999.

4. U.S. NRC Letter to All Operating Reactors, "Issuance of Order EA-02-026 for Interim Safeguards and Security Compensatory Measures," February 25, 2002

5. U. S. NRC Bulletin 2005-02: Emergency Preparedness and Response Actions for Security-Based Events, dated July 18, 2005.

ZionSolutions, LLC Enclosure 1 Zion Nuclear Power Station, Units I and 2 Exemption Request ZS-2012-0307 Page 15 of 15

6. Consideration of Potassium Iodide in Emergency Plans (66 Federal Register (FR) 5427) dated January 19, 2001, effective date April 19, 2001 for implementation appropriate to the site specific circumstances.

7. Commonwealth Edison Company letter to the U.S. NRC, "Supplemental Information for Request for Approval of Defueled Station Emergency Plan and Exemption from Certain Requirements of 10 CFR 50.47, Emergency Plan," dated July 8, 1999.

ZionSolutions, LLC ZS-2012-0307 Zion Compliance Matrix for Emergency Plan

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 1 of 52 Applicable Regulatory Requirements Section Requirement Status of Exemptions 1 10 CFR 50.47 Emergency Plans Exemptions Noted 2 10 CFR Part 50 Appendix E to Part 50--Emergency Planning and Preparedness for Exemptions Noted Production and Utilization Facilities Hr En t New Emergency Planning Rule Compliance Discussion, Historical Rule Language Curent:Exemptions to HistoricalI and Requested Exemptions Applicability and Implementing (Prior to D~cember 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures Notes

1. Language with normal font and lines through represents current exemptions approved on August 31, 1999 and ZionSolutions believes carries forward.

2. Language with bold and italic font represents new rule language.

3. Language with bold and italic ,font and lines through represents new rule language and requested exemptions.

Section 1 - 10 CFR 50.47 Emergency Plans (b) The onsite and, except as (b) The onsite ande&eeptas- (b) The onsite and, e*eepta-s On August 31, 1999, the NRC provided in paragraph (d) of this pr.vided in paragraph (d) of this pr-,vided in parag;.aph (d) of this approved Zion's exemption section, offsite emergency response seetoienffsie emergency response seetinoff-site emergency response request submitted on April 13, plans for nuclear power reactors plans for nuclear power reactors plans for nuclear power reactors 1999.

must meet the following standards: must meet the following standards: must meet the following standards:

ZionSolutions complies with this requirement as exempted. See the Zion Defueled Station Emergency Plan (DSEP) and Implementing Procedures (1) Primary responsibilities for (1) Primary responsibilities for (1) Primary responsibilities for On August 31, 1999, the NRC emergency response by the nuclear emergency response by the nuclear emergency response by the nuclear approved Zion's exemption facility licensee and by State and facility licensee and by State and facility licensee and by State and request submitted on April 13, local organizations within the local organizations within the local organizations within the 1999.

Emergency Planning Zones have Emer.gen* y Planning Zones have Emer.geney Planning Zones have been assigned, the emergency been assigned, the emergency been assigned, the emergency ZionSolutions complies with this responsibilities of the various responsibilities of the various responsibilities of the various requirement as exempted.

supporting organizations have been supporting organizations have been supporting organizations have been This is the general program

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 2 of 52 Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, Historical Rule Language and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures specifically established, and each specifically established, and each specifically established, and each requirement and ZionSolutions principal response organization has principal response organization has principal response organization has meets this requirement for a staff to respond and to augment its staff to respond and to augment its staff to respond and to augment its permanently shutdown plant.

initial response on a continuous initial response on a continuous initial response on a continuous Although we no longer have an basis. basis basis. EPZ, onsite and offsite organizations have the staff and resources to respond to an onsite emergency, if requested.

Chapter 4 of the Emergency Plan describes the responsibilities for the onsite organization. DSEP Section 4.6 also describes the support activities provided by offsite organizations should the need be requested.

(2) On-shift facility licensee None (2) On-shift facility licensee This is the general program responsibilities for emergency responsibilities for emergency requirement and ZionSolutions response are unambiguously defined, response are unambiguously meets this requirement for a adequate staffing to provide initial defined, adequate staffing to provide permanently shutdown plant facility accident response in key initial facility accident response in except as noted by the 1999 functional areas is maintained at all key functional areas is maintained at exemption.

times, timely augmentation of all times, timely augmentation of response capabilities is available and response capabilities is available and Based on the 1999 exemption and the interfaces among various onsite the interfaces among various onsite the initial DSEP approved by the response activities and offsite response activities and offsite NRC, no off-site response support and response activities are support and response activities are measures are required.

specified. specified.

Chapter 4 of the Emergency Plan describes the responsibilities for the onsite organization. DSEP

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 3 of 52

"New Emergency Planning Rule Compliance Discussion, Historical Rule Language Curent Exemptions to Historical emergen Planning RuleiComplianc une Iscussin, (Prior to December(Pror o Dcemer23,201) 23, 2011). Rleand Requested Exemptions Applicability and Implementing Rule (76 FR 72596, Nov. 23, 2011) Procedures Section 4.6 also describes the support activities provided by offsite organizations should the need be requested.

(3) Arrangements for requesting and (3) Arrangements for requesting (3) Arrangements for requesting and ZionSolutions meets this effectively using assistance resources and effectively using assistance effectively using assistance requirement to describe the use of have been made, arrangements to resources have been made, resources have been made, support resources, how support is accommodate State and local staff at arrangements to accommodate State arrangements to a.ccommodate State requested and ensuring that they the licensee's near-site Emergency and loeal staff at the licensee's near and local staff at the licensee's are used effectively, as needed, Operations Facility have been made, Site Emergeny Operations Facility Emer.gency Oper.ations Faility have except as noted by the 1999 and other organizations capable of have been made, and other been-made, and other organizations exemption.

augmenting the planned response organizations capable of capable of augmenting the planned have been identified. augmenting the planned response response have been identified. Based on the 1999 exemption, the have been identified. need for response by State and Local organizations has been eliminated and the Emergency Operations Facility shall no longer be retained. There is no need to accommodate State or Local staff onsite.

DSEP Sections 4.4 and 4.6 describe the use of support resources.

(4) A standard emergency (4) A standard emergency (4) A standard emergency ZionSolttions complies with this classification and action level classification and action level classification and action level requirement as exempted.

scheme, the bases of which include scheme, the bases of which include scheme, the bases of which include facility system and effluent facility system and effluent facility system and effluent The DSEP includes an emergency parameters, is in use by the nuclear parameters, is in use by the nuclear parameters, is in use by the nuclear classification and action level facility licensee, and State and local facility licensee, and State and loeal facility licensee, and State and lecal scheme that is based on NEI 99-response plans call for reliance on response p all for-r.eliance-e n r nall for-reliance ont 0.1, Revision 4 and Regulatory

ZionSolutions, LLC 11 Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 4 of 52 Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, Historical Rule Language (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures information provided by facility information previded by faility inf...mation provided by faility Guide 1.101 guidance for a licensees for determinations of licensees for determinations of licensees for deternminations of permanently shutdown plant. This minimum initial offsite response minimum.ffsite initial r"espnse minimum iitial off-site response includes natural phenomena measures. e s events and accident conditions that could potentially affect the confinement boundary of the spent fuel in the spent fuel pool.

Based on the 1999 exemption, no offsite response measures are required. Facility systems and effluents parameters that are related to potential radiological releases are included in the basis for EALs.

DSEP Chapter 5 shows the classification and action level scheme.

(5) Procedures have been established (5) Procedures have been (5) Procedures have been ZionSolutions complies with this for notification, by the licensee, of established for notification, by the established for notification, by the requirement as exempted.

State and local response licensee, of State and local response licensee, of State and local response organizations and for notification of organizations and for notification of organizations and for notification of Based on the 1999 exemption; emergency personnel by all emergency personnel by all emergency personnel by all there are no State and local organizations; the content of initial organizations; the content of initial organizations; the content of initial responses required and no need and follow up messages to response and followup messages to response and followup messages to response for notification of emergency organizations and the public has organizations ant-he publie has organizations andthepubli-e has personnel by State and local been established; and means to been established; and means to been established; and means to organizations. There is no need provide early notification and clear provide early notification and clear provide early) notification and clear for a means to provide early instruction to the populace within the instruction to the populace.within instruction to the populace within notification and clear instructions plume exposure pathway Emergency the plume exposure pathway the plume exposure pathway to the public within the plume

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 5 of 52 Historical Rule Language Curent Exemptions to Historical

' ' '*::  :: ew andEmergency Requested Planning ExemptionsRule Compliance Applicability andDiscussion, Implementing (Prior to December 23, 2011) _Rule (76 FR 72596, Nov. 23, 2011) Procedures Planning Zone have been Emer.gen. y Plaming Zone hv. Emergency Planning Zone have exposure pathway EPZ.

established, been est-ablshed. been established.

(6) Provisions exist for prompt (6) Provisions exist for prompt (6) Provisions exist for prompt ZionSolutions complies with this communications among principal communications among principal communications among principal requirement as exempted.

response organizations to emergency response organizations to response organizations to emergency personnel and to the public. emergency personnel and to the personnel and te the pub4e. Based on the 1999 exemption, no publie. offsite response measures and no offsite notification of the general public are required.

Communications with the public will be via news releases. No capability for prompt communication or telephone calls to the public is required.

DSEP Section 6.1, "Notification and Activation" and Section 7.2, "Communications Capabilities" provide direction on communications within the ERO and to outside agencies and the public.

(7) Information is made available to (7) Information is made available to (7) Information is made available to ZionSolhtions complies with this the public on a periodic basis on how the pu.blic on a per.iodi; basion the public on a pe-iodic basis on requirement as exempted.

they will be notified and what their how they. will be notified andwhat ho,,,

.ill they*w be...no-tifieNd And wh;At*

initial actions should be in an their initial actions should be in an their initial action:; should be in an Based on the 1999 exemption, emergency (e.g., listening to a local emergency (e.g., listening to a lecal emer-gency (e.g., listening to a l1oal periodic mailings to the residents broadcast station and remaining broadcast station and remaining broadcast station and r*em*ai are no longer necessary as they indoors), the principal points of i.dee.s) the principal points of indeefs), the principal points of will have no response actions.

contact with the news media for contact with the news media for contact with the news media for Contact information for the local dissemination of information during

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 6 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing

_ _(76 FR 72596, Nov.23, 2011) Procedures dissemination of information during an emergency (4ineiding the dissemination of information during news media is provided as an emergency (including the physical physi'al l..ation or-leatifots) are an emergency (inchuding the modified by the 1999 exemption.

location or locations) are established established in advance, and physical location or locations) are in advance, and procedures for procedures for coordinated established in advance, and coordinated dissemination of dissemination of information to the procedures for coordinated information to the public are public are established, dissemination of information to the established. public are established.

(8) Adequate emergency facilities None (8) Adequate emergency facilities ZionSolutions complies with this and equipment to support the and equipment to support the requirement.

emergency response are provided emergency response are provided and maintained, and maintained. Overall, administrative controls are provided in DSEP Section 4.

Emergency facilities and equipment are described in DSEP Section 7 and provide guidance on maintaining equipment and facilities.

(9) Adequate methods, systems, and (9) Adequate methods, systems, (9) Adequate methods, systems, and ZionSolutions complies with this equipment for assessing and and equipment for assessing and equipment for assessing and requirement as exempted.

monitoring actual or potential offsite monitoring actual or potential monitoring actual or potential offsi4te consequences of a radiological offsite consequences of a consequences of a radiological Based on the 1999 exemption, no emergency condition are in use. radiological emergency condition emergency condition are in use. offsite response measures are are in use. required and no methods, systems, and equipment will be maintained for the determination of actual offsite dose consequences.

DSEP Section 6.2 describes actions taken to assess and monitor potential radiological

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 7 of 52 Historical

' " Rule Language Curent Exemptions (Pror "o Dcemer23,201) .ew to Historical

. Rleand ne EmergencyPlanning emergen Planning RuleiComplianc Requested Exemptions Rule *Compliance Applicability Iscussin, andDiscussion, Implementing (Prior to December 23, 20 1) _(76 Rule FR 72596, Nov. 23, 2011) Procedures emergency conditions.

(10) A range of protective actions (10) A range of protective actions (10) A range of protective actions ZionSolutions is exempt from this has been developed for the plume have been developed for-4he-p-tfie has been developed for44he-phne requirement for offsite actions.

exposure pathway EPZ for exEpeosure pathway EPZ for..xp ..sre pathway EPZ for.

emergency workers and the public, emergency workers-and4he-publie. emergency workers and-the publi-e. Based on the 1999 exemption, the In developing this range of actions, Guidelines for the choice of M developing this range of ac-ions*, EPZs and associated protective consideration has been given to protective actions during an eonsidetion has been g.v.n to actions are no longer required evacuation, sheltering, and, as a emergeny* , consistent with Feder.al evaatiod.n, she.tring-,, and--,as a offsite.

supplement to these, the guidance, are developed and.in.... .... to....

these .

prophylactic use of potassium place, and pretective expsur.pthwy.E.

actions for the ropylat-..t.o..

pop s..thseofpit..as...

t...

o........, Exemption Request needed for iodide (KI), as appropriate. .......... .. p 6W), as..... r. - ,gsi new requirement to perform Guidelines for the choice of the loale have been ........ ito

- est.iateshave evacuation time estimates. See protective actions during an developed..been developed by appia*. . ts an Enclosure 1, Items A.5 and B.4.

emergency, consistent with Federal icensees.. Licensees shall t.pdat guidance, are developed and in the evacuatien tidme estimates on a DSEP Sections 6.3 and 6.4 of the place, and protective actions for the periodicbasis-. Guidelines for the- Emergency Plan and the ingestion exposure pathway EPZ choice of protective actiones during implementing procedures provide appropriate to the locale have been an emergency, consistent wi guidance on protective actions for developed. Feder*a* guidance, are developed and- emergency workers onsite.

in place, and proetective actions for the ingestion eEposurfe pathway EPZ appropriate to **the4ale have been (11) Means for controlling None (11) Means for controlling ZionSolutions complies with this radiological exposures, in an radiological exposures, in an requirement.

emergency, are established for emergency, are established for emergency workers. The means for emergency workers. The means for DSEP Section 6.4.3 and the controlling radiological exposures controlling radiological exposures implementing procedures are shall include exposure guidelines shall include exposure guidelines based on EPA 400-R-92-00 1,

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 8 of 52 New Emergency Planning Rule Compliance Discussion, Historical Rule Language Curent Exemptions to Historical and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures consistent with EPA Emergency consistent with EPA Emergency Revised 10/91.

Worker and Lifesaving Activity Worker and Lifesaving Activity Protective Action Guides. Protective Action Guides.

(12) Arrangements are made for None (12) Arrangements are made for ZionSolutions complies with this medical services for contaminated medical services for contaminated requirement.

injured individuals. injured individuals.

DSEP Section 6.4.7 provides the guidance for this requirement.

The letters of Agreement for medical services are in place.

(13) General plans for recovery and None (13) General plans for recovery and ZionSolutions complies with this reentry are developed, reentry are developed, requirement.

DSEP Section 5 provides information on reentry and recovery actions.

(14) Periodic exercises are (will be) None (14) Periodic exercises are (will be) ZionSolutions complies with this conducted to evaluate major portions conducted to evaluate major requirement.

of emergency response capabilities, portions of emergency response periodic drills are (will be) capabilities, periodic drills are (will DSEP Section 8.3 discusses this conducted to develop and maintain be) conducted to develop and requirement.

key skills, and deficiencies identified maintain key skills, and deficiencies as a result of exercises or drills are identified as a result of exercises or (will be) corrected. drills are (will be) corrected.

(15) Radiological emergency None (15) Radiological emergency ZionSolutions complies with this response training is provided to those response training is provided to requirement.

who may be called on to assist in an those who may be called on to assist emergency. in an emergency. DSEP Section 8.2 provides I guidance on this requirement.

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 9 of 52

• ] New Emergency, Planning Rule iCompliance Discussion, Historical Rule Language Curent Exemptions to Historical and Requested Exemptions Applicability and Implementing

((76 FR 72596, Nov. 23, 2011) Procedures (16) Responsibilities for plan None (16) Responsibilities for plan ZionSolutions complies with this development and review and for development and review and for requirement.

distribution of emergency plans are distribution of emergency plans are established, and planners are established, and planners are DSEP Sections 8.2 and 8.4 properly trained, properly trained, describe these requirements.

50.47 (c), (d), and (e) None 50.47 (c), (d), (e) These sections are not applicable to ZionSolutions.

Section 2 - 10 CFR Part 50 Appendix E to Part 50--Emergency Planning and Preparedness for Production and Utilization Facilities IV. Content of Emergency Plans IV. Content of Emergency Plans IV. Content of Emergency Plans ZionSolutions complies with this The applicant's emergency plans The applicant's emergency plans 1. The applicant's emergency plans requirement as exempted.

shall contain, but not necessarily be shall contain, but not necessarily be shall contain, but not necessarily be limited to, information needed to limited to, information needed to limited to, information needed to ZionSolutions maintains a NRC demonstrate compliance with the demonstrate compliance with the demonstrate compliance with the approved Emergency Plan.

elements set forth below, i.e., elements set forth below, i.e., elements set forth below, i.e., Revision 13 of the Zion Defueled organization for coping with organization for coping with organization for coping with Station Emergency Plan was radiation emergencies, assessment radiation emergencies, assessment radiological emergencies, submitted to the NRC on action, activation of emergency action, activation of emergency assessment actions, activation of organization, notification emergency organization, notification September 21,2010. Revision 13 organization, notification procedures, f procedures, emergency facilities procedures, emergency facilities and decommissio emergency facilities and equipment, training, maintaining emergency and equipment, training, equipment, training, maintaining preparedness, and recovery. In maintaining emergency emergency preparedness, recovery- Previous exemptions were issued addition, the emergency response preparedness, and recovery. In nd Ons...protetive a... ns dur.-. by the NRC on August 31, 1999 padditions thebemeryan espplicansefor addition, the emergency response hed-.... f. In addition, the to reflect the defueled condition plans submitted by an applicant for a plans submitted by an applicant for ....... . I d ,o e e d i nuclear power reactor operating a nuclear power reactor operating emergencyresponse plans submitted of the reactor with spent fuel in license shall contain information license shall contain information by an applicant for a nuclear power the spent fuel pool.

needed to demonstrate compliance needed to demonstrate compliance reactor operating license under this DSAR Section 6.5.1 continues to with the standards described in § with the standards described in part,orfor an early sitepermit (as reference the current applicable 50.47(b), and they will be evaluated 50.47(b), and they will be evaluated applicable)or combined license Emergency Plan for the site. This against those standards. The nuclear against those standards.-The- i-telea under 10 CFR part 52, shall contain discussion and reference is

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 10 of 52 T[

..... New Emergency Planning Rule Compliance Discussion, (Prior to December Historical 23, 2011)

Rule Language Rule to Historical Curent Exemptions (76 andFR 72596, Nov.

Requested 23, 2011)

Exemptions ApplicabilityProcedures and Implementing power reactor operating license power- r operating weat*-r li.ense information needed to demonstrate contained within DSEP Section applicant shall also provide an applicant shall also pr..videan compliance with the standards 1.1.

analysis of the time required to analysis of the timd" eqied to described in 50.47(b), and they will evacuate and for taking other evacuate and t be evaluated against those standards.

protective actions for various sectors .lear. for-vanou protective aetions 2. This power-reactor license and distances within the plume sectors and distances within the onsite protective actions during exposure pathway EPZ for transient plume e.posure pathway EPZ fo applicant shall also provide hostile action. See Enclosure 1, and permanent populations. transient and pe..anent*.

.. analysis of the time required to Item A.5,a ppe..lations. evacuate various secters and distances within the plume exposure Exemption Request needed for pathway EPZ for-transien*t , evacuation time estimates. See permanent populations, usin.-g the Enclosure 1, Item B.4 moest recent C4S. Gensuis Btreaui data as of the date the appliant subits its applieatioen to the NR.

3.........

N Er .p..rovedt e........ Exemption Request needed for sha......s..... arv.............. evacuation time estimates. See time esti.ates (ET..s) and updat. Enclosure 1, Item B.4 to the EM~ hi the formutlation proteetive aetion reeommtendations and shallprovde the E-TE-s and ETE updates to State and loeal govervnmental authoitifesfor uise i developing offsite proteetive action A. Within 365 days of,the later Exemption Request needed for the

.... date t .. of the een" of the availabiliey

................ .... eauto ieetmts evacuation time e estim ates. See m treent dee nnialenst us dat Enclosure 1, Item B.4 December 23-, 2041, nuelearpower reactorlicensees shall develop-an

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 11 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, Rule and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011)

(Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures ETE analy-sis ushig this deeennia data and submoit istinder § 50.r4 to the NBC These licensees shall suibmit this E-TE analysis to th-e NRC at least 180 days before using it toformn proteetive a"tio" recommendations andproT iiengsi to State ndloecal governmentan athoriies.for :se i developing

___________________________ __________________________offsite protective ae&#in stratge. __________________

5. Dring the yeas be.een Exemption Request needed for de.ennial censuses, nu'lear.power evacuation time estimates. See reator licensees shall estimate Enlsr1,IeB.

EPZ permanent residentpopulation Enlsr1,IeB4 changes once a year, but no late, than 365 days from the date of th-e previouis estiate-,using the most rveeen L4. Census Bureau ofnnual residentpopulation estimtate and State/Theal governiment popuvlatin data-,if available. These licensee shall maintain these estimtates so that they are availablefor NRC inpection during the period between decennial censuise-s and shall submit th-eswe emsitimates to th-e NRCG with any updated ETE

6. If at any time dufring teEepinRqetnee o decennialperiod- thepio Reuetnedd o

______________________________ peranentresie,:tpplto evacuation time estimates. See

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 12 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule I Compliance Discussion, (risoricalRulemb 2, gaer 2 ) Ruem n tand Requested Exemptions Applicability and Implementing (Priorto December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures increases suceh that it causes the Enclosure 1, Item B.4 longest ETE alue for the 2 mile zone or 5 neile zone, including al affcceted Emerlgeney Response Planninfg.lreas,erfor the entire0 10 mile EPAZ to inreiaseby45 percent$or 30 mnintites, wphichever is les-s-,fromn the nuclearpower raeatorlicensee's currently NR' approved or-updated ETEI, the licensee shall update the EITE analysi to r-eflect the impact of that population hincease. The license-e I- 'j- .1 171rV

.IflhAL&

.- YU~.rrr.pn t~l -AA analysis to the NBJC unider § 50.4 no later than 365 days after the licensee's determiination that the criteriafor updatingthe ETE hae been met and at least 180 days9 befor uising it to formi protective providingit to State and local g.over.nmental authoritiesforuse in.

developing off-site proective action 7-.After-an applieantfor a cobined leicese uinderpart52--of this chapter reeeives its license, the licensee shall contduct at least one rwevie of any ehanges in thme

______________________________ ~ ~ ~ ~ ~ - Ipouato J its EAZ at least 35 1 of Op I_____________ ______________

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 13 of 52 Historical Rule Language Curent Exemptions to Historical Ne Emergency Planning Rule Compliance (Prior to December 23, 2011 Rule and Requested Exemptions Applicability andDiscussion, Implementing (76 FR 72596, Nov. 23, 2011) Procedures days prior to its scheduledfue-l load. The lienfsee shal estimate EP~pernianentresidentpopulation ehanges uising the maost r-eentst US4.

Cenfsus Bureau annmal resident popuflation estimate and Statelocal goverwnmentpopulation data, i available If the EPZ permaonent residentpopulation increasessuceh that it causes thep longest KME value for the 2 mile zone or S mile eone,-

including all affected Emer-genc Response PlanniigAreas, orfor the entire 10 mile EP-Z, to increase by 25 percent or 30 minutes,-

whichever is less-,.from the licensee ýs currently approved E-TE-,

the licensee shall update the Eh analysis to rvefet the imtpact of that populatin increase-.The licensee shall sufbmit the updated E-TE analysis to the NRC-for eve under § 50.4 of this chapterno later than 365 days,before thlTe A. Organization None A. Organization ZionSolutions complies with this The organization for coping with requirement.

The organization for coping with radiological emergencies shall be DSEP Section 4 describes the radiological emergencies shall be described, including definition of noma plationization. Dhe described, including definition of authorities, responsibilities, and Secion6.tdecrbesth authorities, responsibilities, and Section 6.1 describes the

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 14 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23,2011) Procedures duties of individuals assigned to the duties of individuals assigned to the notification and activation steps licensee's emergency organization licensee's emergency organization for the emergency organization.

and the means for notification of and the means for notification of such individuals in the event of an such individuals in the event of an emergency. Specifically, the emergency. Specifically, the following shall be included: following shall be included:

1. A description of the normal plant 1. A description of the normal plant 1. A description o Cthe normal plant Based on the 1999 exemption, operating organization. ope.ating organization. operat*ng organization. ZionSolutions complies with this requirement as exempted.

DSEP Section 4 describes the normal plant organization. DSEP Section 6.1 describes the notification and activation steps for the emergency organization.

2. A description of the onsite None 2. A description of the onsite emergency response organization emergency response organization requirement as clarified in the with a detailed discussion of:. (ERO) with a detailed discussion of: 1999 exemption.

a. Authorities, responsibilities, and

a. Authorities, responsibilities, and duties of the individual(s) who will The 1999 exemption clarified that duties of the individual(s) who Will take charge during an emergency; offsite emergency measures is take charge during an emergency; b. Plant staff emergency limited to providing support from assignments; local police and fire departments,-

b. Plant staff emergency c. Authorities, responsibilities, and ambulance services and hospitals, assignments; duties of an onsite emergency as appropriate.

coordinator who shall be in charge DSEP Section 4 implements this

c. Authorities, responsibilities, and of the exchange of information with requirement.

duties on an onsite emergency offsite authorities responsible for coordinator who shall be in charge of coordinating and implementing the exchange of information with

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 15 of 52 itl New Emergency Planning Rule Compliance Discussion, (Pisorca RulDeLanguber C20n En tl and Requested Exemptions Applicability and Implementing (Prior to December 23,'2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures offsite authorities responsible for offsite emergency measures.

coordinating and implementing offsite emergency measures.

3. A description, by position and 3. A description, by position and 3. A desr-iption, by position and ZionSolutions is exempted from function to be performed, of the funetion to be perfo.rmed, of futnction to be perfr-med, Ef he this requirement in its entirety.

licensee's headquarters personnel lieensee's headqua..ers per.sonnel licens*.e' h*'adqua.t.es per..nnel who will be sent to the plant site to who will be sent to the plant site to who will be sent to the plant site to Based on the 1999 exemption, no augment the onsite emergency augment theonsite emergen*;y augment. the nsite emergency offsite or headquarters personnel organization. efg.. eH- efga...at;e, are required to augment the onsite emergency organization.

DSEP Sections 4 and 6.1 describe the notifications and actions taken by onsite personnel.

4. Identification, by position and 4. Identification, by position and 4. Identification, by positfion*an ZionSolutions is exempted from function to be performed, of persons function to be performed, of fiunction to be perfbrmed, of persons this requirement in its entirety.

within the licensee organization who persons within. the license.e within the licensee or... ation who will be responsible for making or.ganization who will be will be respo.nsib.le fo..ma Based on the 1999 exemption, no offsite dose projections, and a responsible for-making offsite dose eff.it. dose projections, and offsite response measures are description of how these projections projections, and a deser-iption of description of how these pro.jectieas required and no methods, will be made and the results how these pro-jec*tions will be made will be made and the results systems, and equipment will be transmitted to State and local and the results transmitted to State transmitted to State and loal maintained for the determination authorities, NRC, and other and local authorities, NRC, an*,d auithor*ities, NRC,, and other of actual offsite dose appropriate governmental entities. other- appr.opriate gove.mental appropriate governmental entities. consequences.

entities.

DSEP Section 6.2 describes actions taken to assess and monitor potential radiological emergency conditions.

5. Identification, by position and 5. Identification, by position. and 5. Identification, by positioni an ZionSolutions is exempted from function to be performed, of other function to be per-frm.ed, oefot func.tioni to be performed, of-Othý this requirement in its entirety.

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 16 of 52 New Emergency Planning Rule Compliance Discussion, Historical Rule Language Curent Exemptions to Historical and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures employees of the licensee with emf.plo.... of the licnsee 't employees of the licensee 'wt special qualifications for coping with special qualifications for coping special qualifications fcr coping Based on the 1999 exemption, the emergency conditions that may arise. with emergency conditions that with emergency conditions that may need for response by offsite Other persons with special may arise. Other persons ' arise. Other- per.sons with speial employees or specialist qualifications, such as consultants, special q .ualifications, suc aqualifications, such as consu.ltants, contractors is no longer needed.

who are not employees of the con.su.ltants, who are not employees who are not employees of t DSEP Sections 4.4 and 4.6 licensee and who may be called upon of.the liensee and'who may.be licensee an.d who may be calledei called upon for-assistancefor upon for assistance for emergencies resour ho teus, support.is for assistance for emergencies shall also be identified. The special hall also be shall also be identified. The speialis qualifications of these persons shall i . Th special qalifications of these per shall requested and ensuring that they be described. qualifications of these persons shall be*4..... b.. 4 are used effectively, as needed, be-deseribe4, except as noted by the 1999 exemption.

6. A description of the local offsite None 6. A description of the local offsite ZionSolutions complies with this services to be provided in support of services to be provided in support of requirement as clarified in the the licensee's emergency the licensee's emergency 1999 exemption.

organization. organization. The 1999 exemption clarified that offsite emergency measures are limited to providing support from local police and fire departments, ambulance services and hospitals, as appropriate.

DSEP Section 4.6 implements this requirement.

7. Identification of, and assistance None 7. By June 23, 2414,-identification ZionSolutions complies with this expected from, appropriate State, of, and a description of t!e requirement as clarified in the local, and Federal agencies with assistance expected from, 1999 exemption.

responsibilities for coping with appropriate State, local, and Federal emergencies. agencies with repniiiisfor The 1999 exemption clarified that resposibiltiesoffsite emergency measures are

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 17 of 52 Histrical Rule Language ]Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) u Rule and Requested Exemptions Applicability and Implementing

___________,, ______ _ _ _.....__ (76 FR 72596, Nov. 23, 2011) Procedures coping with emergencies, inelkudi:g limited to providing support from hstile action at the site. Ft local police and fire departments, p..rposes of this appendix-, ",esti ambulance services and hospitals, a.tion." is defied as an a.t dire.ted as appropriate.

t...rd a.nu.learpowerp.n. . or t.S DSEP Section 4.6 implements personnel that includes the.s. of violetfo.r.e to dsty ip..ent, this requirement.

take hostages, an/r inti-ida the Exemption Request needed for licensee to achieve an end. This hostile action. See Enclosure 1, inclides.a.ak by air-,land, oi Item A.4.

water using guns explosives, projetils-,vehicles-,or-othet devices used to deliver destrtied

8. Identification of the State and/or 8. Identification of the State and/,r 8. Identificeatin of the State *and*or ZionSolutions is exempted from local officials responsible for local officeials respotnsible flocal .ffi.ials responsible this requirement in its entirety.

planning for, ordering, and planning fr, or.dering, and planning for-, ordeing, and controlling appropriate protective controlling appropriate pretective controllng appropriate protective The 1999 exemption clarified that offsite emergency measures are actions, including evacuations when actions, including evac.atins actions, including eva.uatios e limited to providing support from necessary. hen-neeessaf neeesa.-y. local police and fire departments, ambulance services and hospitals, as appropriate. No offsite protective actions and evacuations are required.

DSEP Section 4.6 implements this requirement.

9. By Decemb e 21.....

er 1, f a, Exemption Request needed for nulerpoe re....t..... licensees... a this requirement. See Enclosure 1, detailed analysis demonstrating

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 18 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (risorical toDeeer 23,gg 2 ) Rem s tand Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures that on sh.ft.personnel assig-ed Item A. 1.

emrgency plan implemnwtationf functions ~r not assigned responsib~iiis" that jwould prevent the timely peirfomance of their signed funetionfs as speeified in the emtergeney-plan.

B. Assessment Actions B. Assessment Actions B. Assessment Actions ZionSolutions complies with this The means to be used for The means to be used for 1. The means to be used for requirement as exempted.

determining the magnitude of, and determining the magnitude of and determining the magnitude of, and Based on the 1999 exemption, no for continually assessing the impact for continually assessing the impact for continually assessing the impact offsite response measures are of, the release of radioactive of the release of radioactive of, the release of radioactive required. Facility systems and materials shall be described, materials shall be described, materials shall be described, effluents parameters that are including emergency action levels including emergency action levels including emergency action levels related to potential radiological that are to be used as criteria for that are to be used as criteria for that are to be used as criteria for releasestareoincludedrinithegbasi determining the need for notification determining the need for determining the need for notification releases are included in the basis and participation of local and State notification and participation of and participation of local and State for EALs.

agencies, the Commission, and other local and State agencies, the agencies, the Commission, and other The Emergency Plan includes an Federal agencies, and the emergency Commission, and other Federal Federal agencies, and the emergency emergency classification and action levels that are to wat be used tyefor agencies, levels that and deteriningwhenand the emergency action action levels that are to be used for action level scheme that is based of are to be used for dt determining when and what type of determining when and what type of on NEI 99-01, Revision 4 and protective measures should be protective measures should be protective measures should be Regulatory Guide 1.101 guidance considered within and outecdeatha considered within anduesatsh de the considered within an-doutside the for a permanently shutdown plant.

site boundary to protect health and site boundary to protect health and site boundary to protect health and This includes natural phenomena safety. The emergency action levels safety. The emergency action levels safety. The emergency action levels events and accident conditions shall be based on in- plant conditions shall be based on in-plant shall be based on in-plant conditions that could potentially affect the and instrumentation in addition to conditions and instrumentation in and instrumentation in addition to confinement boundary of a spent onsite and offsite monitoring. These addition to onsite and effsite onsite and -ffsit monitoring. By fuel pool.

initial emergency action levels shall monitoring. These emergency June 20, 20.2,fo.. n*ucler.. powe. The EALs are reviewed with the be discussed and agreed on by the action levels shall be discussed and reactor lcensees., these action le...s i S applicant or licensee and state and agreed onby the applicant and mu'.st inelude hestile aecti&on, tLoat

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 19 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (risorical tDe er 23,guag 2 ) Rem s tand Requested Exemptions Applicability and Implementing (Prior to December 23, 2011 _(76 Rule FR 72596, Nov. 23, 2011) Procedures local governmental authorities, and State and local governmental may adv.rm!ey affe.t the nu.lear an annual basis.

approved by the NRC. Thereafter, authorities and approved by NRC. p".we"pla. The initial emergency DSEP Section 5 shows the emergency action levels shall be They shall also be reviewed with action levels shall be discussed and classification and action level reviewed with the State and local the State and local governmental agreed on by the applicant or scheme.

governmental authorities on an authorities on an annual basis. licensee and state and local annual basis. governmental authorities, and DSEP Section 8.2.2.2 discusses approved by the NRC. Thereafter, the requirement to review the emergency action levels shall be EALs with the State and Local reviewed with the State and local governments on an annual basis.

governmental authorities on an Exemption Request needed for annual basis. hostile action. See Enclosure 1, Item A.2 A revision to an emergency action 2. A licensee desiringto change its ZionSolutions complies with this level must be approved by the NRC entire emergency action level requirement.

before implementation if: scheme shall submit an application (1) The licensee is changing from for an amendment to its license and The NRC approved the change to one emergency action level scheme receive NRC approvalbefore EALs based on NEI 99-01 on to another emergency action level implementing the change. August 31, 1999.

scheme (e.g., a change from an Licensees shallfollow the change The Emergency Plan includes an emergency action level scheme process in § 50.54(q) for all other emergency classification and based on NUREG-0654 to a scheme emergency action level changes. action level scheme that is based based upon NUMARC/NESP-007 or on NEI 99-01, Revision 4 and NEI-99-01); Regulatory Guide 1.101 guidance (2) The licensee is proposing an for a permanently shutdown plant.

This includes natural phenomena alternate method for complying with regulations; the)The orThsicuenarlpeoma emergetncy aio n events and accident conditions (3) The emergency action level that could potentially affect the revision decreases the effectiveness confinement boundary of a spent of the emergency plan. fuel pool.

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 20 of 52 isrc Rue Es INew Emergency Planning Rule Compliance Discussion,,

(Priotorical D uleemb guager, 2lep n t Historical "and Requested Exemptions Applicability and Implementing (Prio r to December 23, 2011) _ _ Rule (76 FR 72596, Nov. 23, 2011) Procedures DSEP Section 5 shows the A licensee shall submit each request classification and action level for NRC approval of the proposed scheme.

emergency action level change as DSEP Section 8.4 and Procedure specified in § 50.4. If a licensee EPIP-12 provide the guidance for makes a change to an EAL that does making changes to the not require NRC approval, the Emergency Plan and submitting licensee shall submit, as specified in those changes to the NRC, based

§ 50.4, a report of each change made on the type of change being within 30 days after the change is proposed.

made.

C. Activation of Emergency C. Activation of Emergency C. Activation of Emergency ZionSolutions complies with this Organization Organization Organization requirement as exempted.

The entire spectrum of emergency The entire spectrum of emergency 1. The entire spectrum of emergency Based on the 1999 exemption, no conditions that involve the alerting conditions that involve the alerting conditions that involve the alerting offsite response measures are or activating of progressively larger or activating of progressively larger or activating of progressively larger required and no offsite segments of the total emergency segments of the total emergency segments of the total emergency notification of the general public organization shall be described. The organization shall be described. The organization shall be described. The is required.

communication steps to be taken to communication steps to be taken to communication steps to be taken to alert or activate emergency personnel alert or activate emergency alert or activate emergency There are no State and local under each class of emergency shall personnel under each class of personnel under each class of responses required and no need be described. Emergency action emergency shall be described. emergency shall be described. for notification of emergency levels (based not only on onsite and Emergency action levels (based not Emergency action levels (based not personnel by State and local offsite radiation monitoring only on onsite and efsite radiation only on onsite and effsite radiation organizations. There is no need information but also on readings monitoring information but also on monitoring information but also on for a means to provide early from a number of sensors that readings from a number of sensors readings from a number of sensors notification and clear instructions fromcatea poenu ler rensrsutha that indicate a potential emergency, that indicate a potential emergency, to the public within the plume indicate a potential emergency, such such as the pressure in contaimrent ... o ...... .. *...

as the pressure in containment and and the presp*one if he. eh as the pressuEge

. . in ntaip...e.t exposure pathway EPZ.

the response of the Emergency Core Core Cooling System) for .ndth.r.pn. of the. Emerge .. DSEP Section 6.1 provides Cooling System) for notification of notification of offsite agencies shall Cor,,,e Coeing System) for offsite agencies shall be described, be described. The existence, but not notification of offsite agencies shall

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 21 of 52 Historical Rule Language ICurent Exemptions to Historica II New Emergency Planning Rule Compliance Discussion, HPrisrtoricalmRulerLangue C t Es tand Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures The existence, but not the details, of the details, of a message be described. The existence, but not notification including the content a message authentication scheme authentication scheme shall be the details, of a message of messages.

shall be noted for such agencies. The noted for such agencies. The authentication scheme shall be noted emergency classes defined shall emergency classes defined shall for such agencies. The emergency include: (1) notification of unusual include: (1) notification of unusual classes defined shall include:' (1) events, (2) alert, (3) site area events, (2) alert, (3)-site-area Notification of unusual events, (2) emergency, and (4) general emer.geney, and (4) general alert, (3) site area emergency, and emergency. These classes are further emergeney. These classes are (4) gener.al emergency. These discussed in NUREG-0654; FEMA- further discussed in NUREG - classes are further discussed in REP- 1. 0654; FEMA - REP- 1. NUREG-0654/FEMA-REP-1.

2. By June 20, 2042-, nu. .ar powe. Exemption Request needed for reactorlicensees .shaYl establish and emergency declaration timeliness.

wainain

- the.a xbi.ity to assess-, See Enclosure 1, Item B.2.

classify-,and deelare an emergency cronfditionl 1i1 in 15 minutes after the availab*i*ty oj indiat*ions to S

plants operator-s that an emtergencey action level has bee ex-eded and

• shallpromptly declare the emergen cndition as seen as possibe wh~fgidentifod*on the aipprpiateezmergency classificationlevel. Licensees shal not construe these criteria. as -

graceperiod to attempt to restre.

plantcon ditions to avoid declariing aemergency action due to anf emter-gency action levewl that has been eeded-.Licensees shall not construe these criteriaas preventing implementation-01

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 22 of 52 New NdEmergency Requeste Planning ExempinsRule Compliance Discussion, Historical Rule Language Curent Exemptions to Historical (andFR (76 Requested 72596, Nov¢. 223, 2011)

Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule Rule Procedures reýsponse actions deemed by th-e licensee to be neeessary to protect publicbhealth and safef" pro'ided that anty delay in deelaratin does 1.

mphysical y Administrative f land Sme nsfrntife Statneonth lndopyscal, 1 exemptiond 1L.Administrative and physical means for notifying local, State, means for notifying local, State,' and Based on the 1999 exemption, no means for notifying local, State, and and Federal officials and agencies Federal officials and agencies and offsite response measures and no and agreements reached with these agreements reached with these offsite notification of the general Federal officials and agencies and officials and agencies f he m pompt public is required.

agreements reached with-these officials and agencies ferthe n.tifiation of the public and fcr p is.......

officials and agencies for the prompt Prompt n. tifi.ation of the pui notification of the public and for and for-publi evacuation or-othe public evauatin or ether-pr.tective. There are no State and local public evacuation or other protective pro.te.tive m.ea.ur.e. , should they measure s, should they become responses required and no need measures, should they become become necessay, shall be neeeai:y, shall be described. This for notification of emergency necessary, shall be described. This described. This description shall description shall include personnel by State and local description shall include include identification of the identification of the appropriate organizations. There is no need identification of the appropriate appropriate officials, by title and officials, by title and agency, of the for a means to provide early officials, by title and agency, of the agency, of the State and local State and local government agencies notification and clear instructions State and local government agencies goernmet a. within the EPZ. to the public within the plume within the EPZs. I . exposure pathway EPZ.

DSEP Section 6.1 provides guidance for onsite and offsite notification including the content of messages.

2. Provisions shall be described for 2. Provisions shall be described fer 2. Pro-oisions shall be described fer ZionSolhtions is exempted from yearly dissemination to the public yearly dissemination to the pu.bli yearly dissemination to the public

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 23 of 52 Historical Rule Language Curent Exemptions to Historical' New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 20'1) Rule and Requested Exemptions Applicability and Implementing (76 FR 72596, Nov. 23, 2011) Procedures within the plume exposure pathway within the plume exposur.e pathway within the pluml . .. po ur...pathway this requirement in its entirety.

EPZ of basic emergency planning EPZ of basi emer.gency planning EPZ of basic emergency planning Based on the 1999 exemption, no information, such as the methods and infr.mation, such as the metd infoation, such as the methods offsite response measures and no times required for public notification and times required for public and times required for public and the protective actions planned if notification and the prtecte notifiation and the pr.otecet offsite notification of the general actions planned if an accid action;s planned if an accid el isnti an accident occurs, general information as to the nature and ocur.s, general information asto occ.r.s, gener.al infomation as to the The effects of radiation, and a listinga of the nature and effects of radiation, nature and effects of radiation, and a and a listing of local broeadcastg l broadcast station responses required and no need local broadcast stations that will be used for be usedthat.wl for- distino.seatio for notification of emergency inedformationduringan emerey dissemination of information dunng oh atibe d an .........

information during an emergency............. Ofnisai ft emergncy.

.. : ppersonnel by State and local b anemergency. s othet S- lse organizations. There is no need.

Signs or other measures shall also be ......... used to Signs

....... or.other- m t;_ for a means to provide early used to disseminate to any transient disseminate to any transient used to disseminate to any transient notification and clear instructions population within the plume populatio within te p_____

exosrepth ayEP ppopiae population within the plu e to the public within the plume exposure pathway EPZ appropriate ex.posu.r.e pathway EPZ appropriate tothe.public.withinthe.plume information that would be helpful if inforationpthwat would be hepfl it, information that, wo.uld behelu11 it exposure pathway EPZ.

an accident occurs. an accident occurs, a accident occurs. DSEP Section 6.1 provides guidance for onsite and offsite notification including the content of messages.

3. A licensee shall have the 3. A licensee shall have the 3. A licensee shall have the ZionSolutions complies with this capability to notify responsible State capability to notify responsible capability to notify responsible State requirement as exempted.

and local governmental agencies State and local governmental and local governmental agencies within 15 minutes after declaring an agencies within 60 4-5 minutes after within 60 4-5 minutes after declaring Based on the 1999 exemption, no emergency. The licensee shall declaring an emergency. The an emergency. The licensee offsite response measures and no demonstrate that the State/local li;.... shall demonr*. .ate that the demonstrate that the appropriate offsite notification of the general officials have the capability to make State/local officials have the governmental autherities have'the public is required.

a public notification decision capability to make a public capability to make a public aeing There are no State and local promptly on being informed by the notification being. ;nfe *deision

,ieby. theprom.ptlyon

.. .. and notification decision pro-mptly rs responsesee required and no need licensee of an emergency condition. beig.informedy the liene. of on being informed by the license of0 for notification of emergency

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 24 of 52 New Emergency Planning Rule Compliance Discussion, Historical Rule Language Curent Exemptions to Historical and Requested Exemptions AppC liity and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures By February 1, 1982, each nuclear Februarfy 1, 1982, each nucea an emnergency condition. PrPiorto personnel by State and local power reactor licensee shall power-reactor- licensee shall in itia! operatingreater-than S organizations. There is no need demonstrate that administrative and demonstr-ate tha _admVAinis~trative and percentof rated therma power of for a means to provide early physical means have been physical means have been the fir-st reactorat a site, eac notification and clear instructions established for alerting and providing establishedfo- al-einig an nuclear power reactor licensee shall to the public within the plume prompt instructions to the public pro-viding prompt instruetions to the demonstrate that administrative and exposure pathway EPZ.

within the plume exposure pathway public within the plume .expsure phsical maeans have bee-n pathway EPZ. The four- mo DSEP Section 6.1 provides EPZ. The four-month period in 10 est-ablished foraenad period in 10 CFR 5 0.5..(s).(2 fo guidance for onsite and offsite CFR 50.54(s)(2) for the correction of proeviding promt instrctios toAthLe the correction of emergency plan notification including the content emergency plan deficiencies shall pulic withinl the plumfe exposure deficienceies shall not apply to the of messages.

not apply to the initial installation of p~hwa,. EPAThe design objeetive this public notification system that is initial installation of this p~ublic-- of the prompt publie alert and

• *1 *

• nohtti'~teat-"- '+tm +',a is! r-e i'ire required by February 1, 1982. The t.. rT? ... -1 1flO'~ T'L £ notification system shall be to have four-month period will apply to u3y retufuury 1 , tIY e). m1fe tbuur F J mionth period will apply to i 11  : * , I i ý* A correction of deficiencies identified during the initial installation and correction of deficiencies identified initiate notification of the public testing of the prompt public testing of the pro.mpt public withint the plumfe expo surfe pathway notification systems as well as those notification systems as we,, as EPZ within about 15 mninutes. The deficiencies discovered thereafter. these defieiencieg dicovered use of this alerting anid notification*

The design objective of the prompt thiereafter- capability will r-ange from public notification system shall be to immediate alerting and notificatioin have the capability to essentially .The es C2w aev o th Ofl1t- of the public (within 15 minutes ot complete the initial notification of to hav. the capability to essentially the time that State and local officials the public within the plume exposure complete the initial notification ot are notified that a situation exists pathway EPZ within about 15 the public withinf the Plume requringurgnt action) to the more minutes. The use of this notification exposur-e pathway EPZAwithin likely events where there is-capability will range from immediate abouit 15 minutes. The use of this substantial time available for- the notification of the public (within 15 notification capability will range ap~propriategovernmenta minutes of the time that State and from immediate noetification of the local officials are notified that a public (within 15 mninu; 1thee f whether-or not to activate the public Exemption Request needed for situation exists requiring urgent time that Utate and lal A fficiaL alert and noatification system. The backup means to alert and

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 25 of 52 i RNew Emergency Planning Rule Compliance Discussion, HistoricalRule Language Curent Exemptions to Historical and Requested Exemptions Applicability and Implementing (Prior to Deember 23, 2011) .Rule (76 FR 72596, Nov. 23, 2011), Procedures action) to the more likely events are no0tified that a Situlation exiSts- 'in', n'rr,'~qrrgn '~gng,.r'rn' notification system. See where there is substantial time VI V shagl additionally include Enclosure 1, Item B.1 available for the State and local likely events wher-e there is governmental officials to make a substantial time avatlable ior-ine for a backffp mfethod of pfbli judgment whether or not to activate State and loeal governmenta alertin and nes~feation eapable the public notification system. afficials to make a judgment behig uised in tMe event the 'p*Ial Where there is a decision to activate whether- o~r not to activate the public method of alerting-and notification the notification system, the State and notification system. Where there is is unavailable during an entergen e local officials will determine whether a decision to aetivate the tM alert or notify anI Or pe~ortos to activate the entire notification notification svstem, the State and- the plunte exposuie pathway EPK system simultaneously or in a local officials will detefrmine population. The backufp method graduated or staged manner. The Whether- to activate the entir-e I shall have the capabilty to aleri responsibility for activating such a nouncftation system sifmulaneoutsly ana nott the plpluli twlin tue or-in a gr-aduated or-staged flalmatner public notification system shall plIue exposure pathway E. ZK,bu The r-espefn~ibility for- activtng remain with the appropriate does not need to meet the 15 suchk a public notification syste governmental authorities. minute design objecti* for the shall r-emain with the appropr-iate governmental auithor-ities. pI .aIy popt piub& alert and notification system, the appropr-iate governmenta author-ities will determine wvhether- to activate the enitir-e alei4 and notification system simultaneouisly o~r in a graduiated of staged maner. The r-esponsibility for-activating suceh a public alert and notification systemi shall r~emai-n with the appropriate governmfenital au~lefi~tie-s-

-- 7 4-. If FEMA4 has approved a nuvelear Exemption Request needed for

___________________________ _________________________power reactrsite'ýs alert and I backup means to alert and

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 26 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing

..... __- .... - (76 FR 72596, Nov. 23, 2011) Procedures noti-fictin design r.port, notification system. See inel.*ding the backup ale.. an Enclosure 1, Item B. 1 notflewation capability, as of December 23, 2011, then the backuip alert and notificeation capabilityrequir-ements in S-ection 11D.3 imust be intplemtented-by December 24, 2012. If the alc&and notifeation designreport does not incelude a backup alert and notification capabilityor needs revision to ensure adequate bac!kup alr mn otificaton capabilit, twheareiino the W&er and notification design report must beo subi.*ied to FEM4for revie, by Jume 24, 2013, and the FEWM approved backup alert and notifiEeraignmeansn bediss Eupneniented w in 365 days after AuMp n approvalsifowever, the total time period to impl"ement a FEA*L apprvedi backup alderu and notificationmeansmust not w-exe June 22-, 2015 E. Emergency Facilitiesand E. Emergency Facilities and E. Emergency Facilitiesand ZionSoluttions complies with this Equipment Equipment Equipment requirement.

Adequate provisions shall be made Adequate provisions shall be made DSEP Section 7 provides the Adequate provisions shall be made and described for emergency and described for emergency guidance for Equipment and and described for emergency facilities and equipment, including: facilities and equipment, including: Facilities.

facilities and equipment, including:

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 27 of 52 Historical Rule Language Curent Exemptions to Historical (Prior toDecember 23;2011)* *Rule NewEmergency and Requested Planning Exemptions Rul Compliance Applicability andDiscussion, Implementing

- (76 FR 72596, Nov. 23, 2011) Procedures

1. Equipment at the site for None 1. Equipment at the site for ZionSolutions complies with this personnel monitoring; personnel monitoring; requirement.

Personnel monitoring equipment is provided onsite.

DSEP Sections 6.4.3 and 6.4.4 describes the use of direct reading dosimeters and TLDs. DSEP Sections 6.4.2 through 6.4.6 describes the use of ALARA.

2. Equipment for determining the None 2. Equipment for determining the ZionSolutions complies with this magnitude of and for continuously magnitude of and for continuously requirement.

assessing the impact of the release of assessing the impact of the release radioactive materials to the of radioactive materials to the DSAR Section 5.2, Fuel Handling environment; environment; Accident, and Section 5.3 Radioactive Waste Handling Accident show that the release of radioactive material will not exceed Part 100 limits. As a result, radiological assessment and protective actions are limited to determining the dose rates in the area, establishing controls to prevent personnel from entering the area, and assuring recovery and repairs minimize exposure.

DSEP Sections 7.3.1 and 7.3.2 and implementing procedures are used to implement this

__requirement. Based on

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 28 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing (76 FR 72596, Nov. 23, 2011) Procedures radiological conditions, a radiation work permit may be required.

3. Facilities and supplies at the site None 3. Facilities and supplies at the site ZionSolutions complies with this for decontamination of onsite for decontamination of onsite requirement.

individuals; fndividuals; The ZNPS does not have designated decontamination facilities on site.

Gross decontamination is limited to removal of clothing. Removal of contamination on the skin is performed with soap and water.

DSEP Section 6.4.4 states that radiation protection technicians will perform the decontamination, if necessary and arrangements for appropriate temporary accommodations have been prepared.

4. Facilities and medical supplies at None 4. Facilities and medical supplies at ZionSolutions complies with this the site for appropriate emergency the site for appropriate emergency requirement.

first aid treatment; first aid treatment; The ZNPS has medical supplies and a first aid office on site to administer first aid. Additional medical treatment would be provided by offsite ambulance or hospital facilities.

DSEP Section 4.5 states that Radiation Protection Technicians

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 29 of 52 (PriorRule Language HistoricalI 23,anning Curent Exemptions to Historical New Nw Emergency Planning Rule Rule~Cmlac Emergebcy Compliance Discussion, icsin (PriorutoDecember23 2011)age Run tand Requested Exemptions Applicability and Implementing (Prior to December 23, 2011 -____________Rule _(76 FR 72596, Nov. 23, 2011) Procedures and the Emergency Director are trained in first aid. There is also a nurse on site during normal business hours.

5. Arrangements for the services of None 5. Arrangements for medical service ZionSolutions complies with this physicians and other medical providers qualified to handle requirement.

personnel qualified to handle radiological emergencies onsite; radiation emergencies on-site; The Emergency Plan contains Assistance Agreements from local resources for hospital and ambulance services.

DSEP Section 4.6 discusses this requirement.

6. Arrangements for transportation of None 6. Arrangements for transportation ZionSolutions complies with this contaminated injured individuals of contaminated injured individuals requirement.

from the site to specifically from the site to specifically idetifed reamen failiiesoutideidentified treatment facilities outside The Emergency Plan contains the site boundary; the site boundary; Assistance Agreements from local resources for hospital and ambulance services.

DSEP Section 6.4.7 discusses this requirement.

7. Arrangements for treatment of None 7. Arrangements for treatment of ZionSolutions complies with this individuals injured in support of individuals injured in support of requirement.

licensed activities on the site at licensed activities on the site at The Emergency Plan contains treatment facilities outside the site treatment facilities outside the site Assistance Agreements from local boundary; boundary; resources for hospital and ambulance services.

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 30 of 52

..... ~ .... ~ ~ ~ ~ ..~ NwEme Historical Rule Language jCurent Exemptions to Historical

'N rency"Plannin Rule NeEmrncPlnigReCopacesuso, ipCom hace Discu'ssion, (Pror o Dcemer23,201)

Rleand 1(76 FR Requested Exemptions 72596, Nov. 23,2011)

Applicabilty and Implementing

,.Procedures DSEP Section 6.4.7 discusses this requirement.

8. A licensee onsite technical support 8. A licensee onsite technical 8.a. (i) A licensee onsite technical ZionSolutions complies with this center and a licensee near-site support center and a licensee near support center and an emergency requirement as exempted.

emergency operations facility from site emer.gen.y operations faility operations -aelit-y from which which effective direction can be from which effective direction can effective direction can be given and Based on the 1999 exemption, the given and effective control can be be given and effective control can effective control can be exercised need for response by State and exercised during an emergency; be exercised during an emergency; during an emergency; Local organizations has been fo Fr........ ...........

p r eliminated and the Emergency Uee.......

o a p..e r re..... Operations Facility and Technical

... i..nsee, a.......een..te. Support Center shall no longer be per...t......5t,-..........retained.

DSEP Section 7.1 describes the use of the control room as the Emergency Response Facility.

DSEP Section 4.0 provides the steps taken to provide effective direction and control for the Emergency Response Organization during an emergency.

Exemption Request needed for an Emergency Operations Facility.

See Enclosure 1, Item B.3.

&"For a n..learpower rea.to. Exemption Request needed for an li.ensee.s emergen'y opeatwions Emergency Operations Facility.

,Weiiy required by paragaph8-.a See Enclosure 1, Item B.3.

ofthis section, either afaciity

________________________________ located behveen 10 miles and-25 _______________

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 31 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing (76 FR 72596, Nov. 23, 2011) Procedures miles*oft/Me nuclear-powerreactor site~s), or a.prm. facility located less than 10 milfes ftom the nuclear power-reactor site(s) anld a backup facdiiy located be~wcen 10 milesi and 25 miles of theic nucearpower reactorsite(s). An emtergencey operatiensfacilitj may serve mor~e than one nuclearpower reaetor site. A licensee desiringto locate an emtergency operationsfacilty more tMan 25 mifles froni a nuiucear-power rvaetor site shiag requestprior Commnission aprWaiy u niitug an applicationfor an amtendment to its license-.For an entergenfey operationsfacility locatedmno-re than 25 mniesfromin a nuclear powver reactorsite, pr v .'n must be mniade for locatimig RC-anid !ffste respomiders closer to the nucleat power raeatorsite so that NRC-and offsite responder-s eami imteractface to face with eter-gemieyriwpons" personime! entering-and leaimig the miuclear power reoetor site-.

P-rovisionsfor locating ARC-and offvite resonder~selosier to"

iuekarpower reaetorsite that i miore thani 25 miles from the emergencey operationsfacility must

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 32 of 52 (risorical toDcRuleer Historical 23,guage Language 2 ) Rn tand Curent Exemptions to Historical Requested Planning New Emergency Exemptions Rule Applicability Compliance andDiscussion, Implementing (Prior to December 23, 2011) ___(76 Rule FR 72596, Nov. 23, 2011) Procedures binclde the followingi: (1) Spaceefot members of an AWC- site tean ana Federal-,State, and local respoffdersT Q)Additional spaceefor conducting bri.efngs t:e ... ,.ergency rionse (3) Communicatin with other

.i.enseeand offike e.lergency respinse facilities; (4) Access to plant data and radiologialin*forma:tio; and (5),Access to copying e ipme*t

________________________________ ~~and office suple;________________

c-. By June 20, 2042-,for a nucflear Exemption Request needed for an power reactorliceitsee's emergenc Emergency Operations Facility.

operationsfacilit required-by See Enclosure 1, Item B.3.

paragraph8-.a of this section, a faciliy having the following epabil~esi.

(1) Thqecapabdiiyfor obtaininigand displayingplant data and radiologicaliniformationfor each reactorat a nuclearpower,reactor site and~fio each ituclear-power raeatorsite that tie faili~ty serves; (2) The capability to analyze plant technical information and proid technical briefings on evenft conditOHS and prognfosis to licensee and offsike responsfe

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 33 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures organizationsfor each reatorat a nuclearpower rectforsite andT fr ea.h nFrularpower raetorEsite thaf the:f*aility se.es; an.

() The eapab-ity to s. pori response to events o rrN sineultaneous*,y at ore than -ne nuclearpower raeetorsite if the emergency operfationsfa:eity serves more than one site; and d-. Fornuclearpower reaco Exemption Request needed for an licensees-,an alterntativefacilty (or Emergency Response facilities) that owoi:i be aceepssiblke Organization augmentation and even if the site is iunder-threat of or alternate facilities. See Enclosure

• eperencnghostileaction, to 1, Item A.3.

function as a staging ar~eafo:

augmentation of emnergency

• rsponse staff and collectively having thefolloing char-acteristics:the capabilityfor commniation with the emergenc operationsfacility, control roomf, and plant security;5 the capability to peiforin offtite notiications;and the capabiltyfor enginern assessment activities, includinfg damage eoniitrl teamt planningaofd prepar-atinforifse wlehen onsit-e em irgencyfacilitis cannot b safely accessed during hostile actin. The requirement-s in this

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 34 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing (76 FR 72596, Nov. 23, 2011) Procedures paragraph &d must be im"plemented no aiter than December 23j, 20,14t, wit the ex..epti* of

. the .apabdiiey for stagi..g e..ergeny rrponso organfization personnel ot the a.ternative faili... (or:faiilitoes) and the capabiiy for commuincations with thr emergency opersations facility, contrclrommncaandplant seuin.ty, shich nmust be implementedfno

_________________________later than June 20, 2012.

e-. A leensee shal not be scdbtles to Exemption Request needed for an the requirement-s .pargraph 9b Emergency Response of this section for an existing Organization augmentation and emtergecy opertionsfaeili0 alternate facilities. See Enclosure

9. At least one onsite and one offsite None 9. At least one onsite and one offsite ZionSolutions complies with this communications system; each communications system; each requirement.

system shall have a backup power system shall have a backup power source. source. All communication plans DSEP Sections 7.2.1 describes shall have arrangements for the onsite and offsite All communication plans shall have emergencies, including titles and communication systems. Back-up arrangements for emergencies, alternates for those in charge at both power is provided by the UPS including titles and alternates for, ends of the communication links and should offsite power be those in charge at both ends of the the primary and backup means of unavailable.

communication links and the primary communication. Where consistent and backup means of with the function of the communication. Where consistent governmental agency, these with the function of the arrangements will include:

governmental agency, these ________________ ______________

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 35 of 52 HistoricalRuleLanguageeemb (risoritolDecembern23,g2011) er3 CurentExemptionsto Rule storical f New Emergency Planning Rule and Requested Exemptions (76 FR 72596, Nov. 23, 2011)

Compliance Discussion, Applicability and Implementing Procedures arrangements will include:

a. Provision for communications a. Provision for communications a. Provision for communications ZionSolutions complies with this with contiguous State/local with contiguous State/local with contiguous State/local requirement as exempted.

governments within the plume governments within-the phlue governmentswithiw he-p1-ule exposure pathway EPZ. Such exp7sure pathway EPZ. Such exposure pathway EP.. Such Based on the 1999 exemption and communications shall be tested communications shall be tested communications shall be tested NRC approval of the Defueled monthly. monthly. monthly. Site Emergency Plan, there is no longer a need for an EOF or field assessment teams.

Communications with the NRC and State agencies are made from the Control Room. The communications systems are discussed in DSEP Section 7.2.1.

DSEP Section 6.1 describes the process for notifying the NRC and State agencies.

Communications with the NRC and State are verified at least monthly per DSEP Section 8.3.2.1.

b. Provision for communications None b. Provision for communications ZionSolutions complies with this with Federal emergency response with Federal emergency response requirement.

organizations. Such communications organizations. Such communications systems shall be tested annually. systems shall be tested annually. Communications with the NRC and Stateagencies are made from the Control Room. The communications systems are discussed in DSEP Section 7.2.1.

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 36 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, and Requested Exemptions Applicability and Implementing rior o Decemer ue (76 FR 72596, Nov. 23, 201-1) Procedures DSEP Section 6.1 describes the process for notifying the NRC and State agencies.

Communications with the NRC and State are fully tested at least annually per DSEP Section 8.3.2.1.

c. Provision for communications c. Provision for communications c. Provision for communications ZionSolutions complies with this among the nuclear power reactor among the nuclear power reactor among the nuclear power reactor requirement as exempted.

control room, the onsite technical control room, the onsite technical control room, the onsite technical emergen erationsacility support center, and the near-uite support center, and the emergency Based on the 1999 exemption and emergency operations facility; and.emergency operations fa*ility; and operations facility; and am..ng the NRC approval of the Defueled among the nuclear facility, the eergthenyeperatn faity; nudlear fa.ility, the principal State Site Emergency Plan, there is no principal State and local emergency am...ng Sthte nucleear faciity te and local emer.gency oper-atio longer a need for an EOF or field operations centers, and the field opertinsia Ster andlalemeend ent.ers, and the field assessment assessment teams.

assessmentcommnicaion teams.sysemshal.be...e.men Such operatio-s centers, and the feams.

teams.. Such Such communications comniaiossytmssal e communications systems shall be systems shall be tested annually. The Control Room functions as tested annually. tested annually. the technical support center for purposes of the Zion plan and procedures. Communications with the NRC and State agencies are made from the Control Room.

The communications systems are discussed in DSEP Section 7.2.1.

DSEP Section 6.1 describes the process for notifying the NRC and State agencies.

Communications with the NRC and State are fully tested at least

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-20i2-0307 Page 37 of 52 New Emergency Planning Rule Compliance Discussion, Historical Rule Language Curent Exemptions to Historical and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures I annually per DSEP Section 8.3.2.1.

d. Provisions for communications by d. Provisions for communications d. Provisions for communications by ZionSolutions complies with this the licensee with NRC Headquarters by the licensee with NRC the licensee with NRC Headquarters requirement as exempted.

and the appropriate NRC Regional Headquarters and the appropriate and the appropriate NRC Regional Office Operations Center from the NRC Regional Office Operations Office Operations Center from the Based on the 1999 exemption and nuclear power reactor control room, Center from the nuclear power nuclear power reactor control room, NRC approval of the Defueled the onsite technical support center, reactor control room,-the-ensite the ensite technical suipport center-, Site Emergency Plan, there is no and the near-site emergency teehfnial supp... center, and the and the emer-gency operation longer a need for an EOF or field operations facility. Such near site emprgenc oprtionls faei44ty. Such communications shall assessment teams.

communications shall be tested fa-ility. Such communications shall be tested monthly.

monthly. be tested monthly. Communications with the NRC and State agencies are made from the Control Room. The communications systems are discussed in DSEP Section 7.2.1.

DSEP Section 6.1 describes the process for notifying the NRC and State agencies.

Communications with the NRC and State are tested at least monthly per DSEP Section 823.2.1.

F. Training. None F. Training ZionSolutions complies with this

1. The program to provide for: (a) requirement.

1. The program to provide for: (a) The training of employees and The training of employees and exercising, by periodic drills, of DSEP Sections 8.2 and 8.3 exercising, by periodic drills, of emergency plans to ensure that describe the actions taken for this radiation emergency plans to ensure employees of the licensee are requirement. Overall that employees of the licensee are familiar with their specific administrative controls for

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 38 of 52 H New Emergency Planning Rule- Compliance Discussion, Historical (Prior(Pioto Rule Language o December eeme 23 01)Rl .

213, 2011) Curent Exemptions

.Rule to Historical

- (76 andFR 72596, Nov.

Requested 23, 2011)

Exemptions 1 Applicability

"* Procedures and Implementing familiar with their specific emergency response duties, and (b) Emergency Planning emergency response duties, and (b) The participation in the training and commitments are provided in The participation in the training and drills by other persons whose DSEP Section 8.1.

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

emergency personnel:

i. Directors and/or coordinators of i. Directors and/or coordinators of i. Directors and/or coordinators of ZionSolutions complies with this the plant emergency organization; the plant emergency organization; the plant emergency organization; requirement as exempted.

ii. Personnel responsible for accident ii. Personnel responsible for ii. Personnel responsible for accident assessment, including control room accident assessment, including assessment, including eefitr! reofm Based on the 1999 exemption, shift personnel; control room shift personnel; shift personnel; there is no longer a need for iii Radiological monitoring teams; iii Radiological monitoring teams; iii Radiological monitoring teams; offsite company personnel to iv. Fire control teams (fire brigades); iv. Fire control teams (fire iv. Fire control teams (fire brigades); provide assistance in the event of

v. Repair and damage control teams; brigades); v. Repair and damage control teams; a radiological emergency.

vi. First aid and rescue teams; v. Repair and damage control vi. First aid and rescue teams; Additional personnel are not vii. Medical support personnel; teams; vii. Medical support personnel; required to respond to an viii. Licensee's headquarters support vi. First aid and rescue teams; viii. Licensees' headquarters s*ppr emergency other than first personnel; Medical support personnel; pefsennel; responders from offsite ix. Security personnel. viii. Li.ensee's headqua.t.r. ix. Security personnel. emergency organizations

.Seuritper-sonne... depending on the nature of the In addition, a radiological orientation In addition, a radiological emergency.

training program shall be made In addition, a radiological orientation training program shall be available to local services personnel; orientation training program shall made available to local services DSEP Sections 8.2 and 8.3 e.g., local emergency services/Civil be made available to local services personnel; e.g., local emergency provide guidance on this Defense, local law enforcement personnel; e.g., local emergency services/Civil Defense, local law requirement. Overall

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 39 of 52 Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, Historical Rule Language Rule and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) (76 FR 72596. Nov. 23, 2011)

Procedures personnel, local news media persons. services/Civil Defense, local law enforcement personnel, Ieal-news administrative controls for enforcement personnel,-leeal-news nediaper-so. Emergency Planning media-per*-so commitments are provided in DSEP Section 8.1.

2. The plan shall describe provisions 2. The plan shall describe 2. The plan shall describe provisions ZionSolutions complies with this for the conduct of emergency provisions for the conduct of for the conduct of emergency requirement as exempted.

preparedness exercises as follows: emergency preparedness exercises preparedness exercises as follows:

Exercises shall test the adequacy of as follows: Exercises shall test the Exercises shall test the adequacy of ZionSolutions meets this timing and content of implementing adequacy of timing and content of timing and content of implementing requirement for drills and procedures and methods, test implementing procedures and procedures and methods, test exercises except there is no longer emergency equipment and methods, test emergency equipment emergency equipment and a need for a public notification communications networks, test the and communications networks,4est communications networks, test-the system as discussed in the 1999 public notification system, and the publi notification zytcm and publip alAer and notification SyStem, exemption.

ensure that emergency organization ensure that emergency organization and ensure that emergency personnel are familiar with their personnel are familiar with their organization personnel are familiar DSEP Section 8.3 describes the duties. duties. with their duties.- drills and exercises for the onsite

a. A full participation exercise which organization. Overall tests as much of the licensee, State, administrative controls for and local emergency plans as is Emergency Planning reasonably achievable without commitments and for performing mandatory public participation shall drills and exercises are discussed be conducted for each site at which a in DSEP Section 8.1.

power reactor is located.

a. A full participation 4 exercise Exemption Request needed for which tests as much of the licensee, challenging drills and exercises.

State, and local emergency plans as See Enclosure 1, Item A.6. The is reasonably achievable without NRC approved 1999 exemption mandatory public participation shall already includes exemption from be conducted for each site at which a the requirement for a full power reactor is located. NAueeai participation exercise (Enclosure power

... reat -...ensees shall 1, Item A.6, F.2.c)

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 40 of 52 Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, Historical Rule Language (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing (76 FR 72596, Nov. 23, 2011) Procedures submit exercise scenfaries under S0.4 at least 60 days before tse in a fu~llpaulicipationexercise required (i) For an operating license issued under this part, this exercise must be conducted within two years before the issuance of the first operating license for full power (one authorizing operation above 5 percent of rated power) of the first reactor and shall include participation by each State and local government within the plume exposure pathway EPZ and each state within the ingestion exposure pathway EPZ. If the full participation exercise is conducted more than 1 year prior to issuance of an operating license for full power, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before issuance of an operating license for full power. This exercise need not have State or local government participation.

(ii) For a combined license issued under part 52 of this chapter, this exercise must be conducted within two years of the scheduled date for

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 41 of 52 New Emergency Planning Rule Compliance Discussion, Historical Rule Language Curent Exemptions to Historical and Requested Exemptions Applicability and Implementing (itD1Rule (76 FR 72596, Nov. 23, 2011) Procedures initial loading of fuel. If the first full participation exercise is conducted more than one year before the scheduled date for initial loading of fuel, an exercise which tests the licensee's onsite emergency plans must be conducted within one year before the scheduled date for initial loading of fuel. This exercise need not have State or local government participation. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of the first full participation exercise, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of § 50.54(gg) apply.

(iii) For a combined license issued under part 52 of this chapter, if the applicant currently has an operating reactor at the site, an exercise, either full or partial participation,- shall be conducted for each subsequent reactor constructed on the site. This exercise may be incorporated in the exercise requirements of Sections

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 42 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) Rule and Requested Exemptions Applicability and Implementing (76,FR 72596, Nov. 23, 2011) Procedures IV.F.2.b. and c. in this appendix. If FEMA identifies one or more deficiencies in the state of offsite emergency preparedness as the result of this exercise for the new reactor, or if the Commission finds that the state of emergency preparedness does not provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency, the provisions of § 50.54(gg) apply.

b. Each licensee at each site shall b. Each licensee at each site shall b. Each licensee at each site shall ZionSolutions complies with this conduct an exercise of its onsite conduct an exercise of its onsite conduct a subsequent exercise of its requirement as exempted.

emergency plan every 2 years. The emergency plan every 2 years. The onsite emergency plan every 2 years.

exercise may be included in the full e e I.

may be included in the full N lear

.. power re-etr 1i... ZionSolutions meets this participation biennial exercise pai*ieipation biennial exer.ise sal submit .... s s requirement for drills and required by paragraph 2.c. of this requir.ed by paragraph 2.. of this' under § 5.L4 at leaist 60 days befo.e exercises except there is no longer section. In addition, the licensee see-on. In addition; the licensee use in an ex..eise r.quired by this a need for emergency response shall take actions necessary to ensure shall take actions necessary to paragraph 2A.. Th e . i. may be facilities as discussed in the 1999 that adequate emergency response ensure that adequate emergency included in the full participation exemption.

capabilities are maintained during response capabilities are maintained bie.*ial ex r *equired by the interval between biennial during the interval between biennial paragraph 2.e. of this seti-n.-In DSEP Section 8.2 describes the exercises by conducting drills, exercises by conducting drills, addition, the licensee shall take drills and exercises for the onsite including at least one drill involving including at least one drill actions necessary to ensure that organization. Overall a combination of some of the involving a combination of some of adequate emergency response administrative controls for principal functional areas of the the principal functional areas of the capabilities are maintained during Emergency Planning licensee's onsite emergency response licensee's onsite emergency the interval between biennial commitments and for performing capabilities. The principal functional response capabilities. The principal exercises by conducting drills, drills and exercises are discussed areas of emergency response include functional areas of emergency including at least one drill involving in DSEP Section 8.1.

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 43 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (2and Requested Exemptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures activities such as management and response include activities such as a combination of some of the coordination of emergency response, management and coordination of principal functional areas of the Exemption Request needed for accident assessment, protective emergency response, accident licensee's onsite emergency response challenging drills and exercises.

action decision making, and plant assessment, protective action capabilities. The principal functional See Enclosure 1, Item A.6.

system repair and corrective actions. decision making, and plant system areas of emergency response include During these drills, activation of all repair and corrective actions. activities such as management and of the licensee's emergency response During these drills, activation of all coordination of emergency response, facilities (Technical Support Center of the licensee's emergency accident assessment, event (TSC), Operations Support Center response facilities (-eehniei4 classification,notificationof offsite (OSC), and the Emergency authorities,assessment of the onsite Operations Facility (EOF)) would Sti ai-'r Center- (O'S7 I'll... .. .

and amd*dofsi impact of radiological r

not be necessary, licensees would il1:+/-~

1-mer-gency ".per-ations ruaeH-ffy releases,protective action have the opportunity to consider (EOF)) would not be necessary, recommendation development, accident management strategies, licensees would have the protective action decision making, supervised instruction would be opportunity to consider accident plant system repair and mitigative permitted, operating staff would management strategies, supervised action implementation. During have the opportunity to resolve instruction would be permitted, these drills, activation of all of the problems (success paths) rather than operating staff would have the licensee's emergency response have controllers intervene, and the opportunity to resolve problems facilities (Technical Support Center drills could focus on onsite training (success paths) rather than have (TW'Q C0n'er-ti'rn' Strnnert Center-I fl IN -- 1 -

objectives. controllers intervene, and the drills I~JA~,an'J tme ffn~ergefey could focus on onsite training Operatin"s Faeihity (EOF)) would objectives. not be necessary, licensees would have the opportunity to consider accident management strategies, supervised instruction would be permitted, operating staff in all participating facilities would have the opportunity to resolve problems (success paths) rather than have controllers intervene, and the drills

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 44 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, and Requested Exemptions Applicability and Implementing (76 FR 72596, Nov. 23, 2011) Procedures may focus on the onsite exercise training objectives.

c. Offsite plans for each site shall be c. Offsite plans for-each site shall. C. ZionSolutions is exempted from exercised biennially with full be exerceised biennially with full A I_: U 11 this requirement in its entirety.

participation by each offsite participation by each offsite pariciipation by each off-site authority having a role under the auithor-ity having a role under the authority having a role under the Based on the 1999 exemption, no radiological response plan. Where plan. Where the offsite autherity r-adiological response plan. Where action is expected from the State the offsite authority has a role under has a role under a radiological or local government organizations a radiological response plan for more response plan for-more than one a ra.iotogical r-esponse pian,1o in response to events at the site.

than one site, it shall fully participate site, it shall flly par.ticipate in on-e mor-e than one site, it shall fully in one exercise every two years and exercie ever two years and- shall, paniecpate in one efxercise ever two ZionSolutions no longer has an shall, at least, partially participate in at least, partially pariciipate(S)i years and shall, at least, partiall4y EPZ and onsite and offsite other offsite plan exercises in this participate in other offsite plan organizations have the staff and period. period exercises in this period. .If .o resources to respond to an onsite different licensees,, each hae emergency, if requested.

licensedfacilities located either on The onsite plan is exercised at the samte site or on adjacent, least once every two years.

condgtigous sites-, and share most 0 the elemtents deffining co located DSEP Section 8.3 describes the fieenseesjA then each licensee shall: drills and exercises for the onsite (1 Conduct an exercise bienniall organization. Overall ofits onsite emfergency plan; administrative controls for

() P .artiipate quadrenniallyin an Emergency Planning offsite biennial)ful or partia commitments and for performing participatinexrcie1; drills and exercises are discussed (3 Conduct emterg-enc in DSEP Section 8.1.

preparedness

-jj ..

• 11,,*. activitis

- . I . anfd I I interactionsin the years ben reenit Exemption Request needed for partiipatinin the offsiteW ful o challenging drills and exercises.

partialpartiipationex-ercise with See Enclosure 1, Item A.6.

_____________________ ______________I____ 1jsr auzoiu1 to test anaff

ZionSolttions, LLC . Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 45 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, and Requested Exemptions Applicability and impiementing (Prior tD(76 FR 72596, Nov. 23, 2011) Procedures mai-ntain interface aniong-the affected State and local authorities and the licensee-. Go locate licensees shall also participatein em:rgencypreparedness activities and interaction with offsit" auithoritesfor the period between eeeises; (4 Gontduct a hostile action ex-ercise of its onsite emtergency plant in each exercise cycle; and (5) P-articipatein an offsite biennial full or partialpartiipatiefn hostl action exercise in alternating

__ exereise-eyele& __

d. A State should fully participate in d. A State should fu"lly paic**ipate d-.Each State with responsibdiyfo. ZionSolutions is exempted from the ingestion pathway portion of in the ingeStiOn pathwayýp'Ortin o. nuclearpeowerreactorem.ergenc this requirement in its entirety.

exercises at least once every six ex.c.s at.....*

least *.......

ne c,.......... * ...

• . pre.paredness

... ,pate in. shold.

.the ....flly, iF to..... thw.... Based on the 1999 exemption, n years. In States with more than one years. In States with more than one patcpt in the i pathway B no site, the State should rotate this site, the State should rotate ti portion . o ex.erises at least once action is expected from the State participation from site to site. pa4*tiipation from site to si....... ercs c .4#. States with or local government organizations imoe than one n.clearpowe. in response to events at the site.

reactorpleexposr p..* -athw., Zion no longer has an EPZ and

_Z-, the State should rotate this onsite and offsite organizations par4tiipatinfrom site to site-. Eaeh have the staff and resources to State with resp-nsibilg.y f. r nucleat respond to an onsite emergency, power reactorem.ergency if requested.

preparedtes-ssho::df:lly participatein a hostile action The onsite plan is exercised at exercise at least once eve.y cycle least once every two years.

a o .h e - , DSEP Section 8.3 describes the

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units I and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 46 of 52 New Emergency Planning Exemptions Rule AppliCompliance Icability andDiscussion, Implementing Historical Rule Language (rotoDcme23201Rueand Curent Exemptions to Historical Nd Requested Eqested Exempins Applicabiliand imcemning (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures hostile a.tion ex:erise by De.ember drills and exercises for the onsite 31, 2015. States w.ith m..r.e than one organization. Overall

..... ear p. wer

. .e.tor plu.e administrative controls for expos.re pathway, EPZ should- Emergency Planning retate this partieipation from site to commitments and for performing sdrills and exercises are discussed in DSEP Section 8.1.

Exemption Request needed for challenging drills and exercises.

See Enclosure 1, Item A.6.

e. Licensees shall enable any State or e. Licensees shall enable any State e. Licensees shall enable any State ZionSolutions complies with this local Government located within the or local Government support or local government support service requirement as exempted.

plume exposure pathway EPZ to service located within the plume loated within the plume exposure participate in the licensee's drills exposu.r.e pathway EPZ to pathway,-.PZ to participate in the Based on the 1999 exemption, no when requested by such State or participate in the licensee's drills licensee's drills when requested by action is expected from the State local Government. when requested by such State or such State or local government, or local government organizations local Government support service. in response to events at the site.

10CFR50 Appendix E. IV.F.2.e. - Zion no longer has an EPZ and Exemption is being requested to onsite and offsite organizations Exemptiorisy bheil rveqmeste thave the staff and resources to clarify the local Governmentrepntoa si mrgcy entities permitted to participate in respond to an onsite emergency, emergency preparedness drills by including the phase 'support The onsite plan is exercised at service' modifying 'local least once every two years.

governmental organizations provide DSEP Section 8.3 describes the governmeny suporgaatinsei pvide drills and exercises for the onsite emergency support service (viz. organization. Overall ambulance, fire, police) to administrative controls for ZionSolutions upon request. These Emergency Planning

ZionSolutions,LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 47 of 52 Historical Rule Language (Prior to December 23, 2011)

Curent Exemptions to Historical' Rule T New Emergency Planning Rule and Requested Exemptions (76 FR 72596, Nov. 23, 2011)

Compliance Discussion, Applicability and Implementing Procedures organizations are identified in the commitments and for performing DSEP pursuant to IOCFR50 drills and exercises are discussed Appendix E IV.A.6. in DSEP Section 8.1.

f. Remedial exercises will be f. Remedial exercises will be f. Remedial exercises will be ZionSolutions complies with this required if the emergency plan is not required if the emergency plan is required if the emergency plan is not requirement as exempted.

satisfactorily tested during the not satisfactorily tested during the satisfactorily tested during the biennial exercise, such that NRC, in biennial exercise, such that NRC, in biennial exercise, such that NRC, in consultation with FEMA, cannot find consultation with FEMA, cannot ecnsultation with FEMA, cannot (1) action is expected from the State reasonable assurance that adequate find reasonable assurance that find reasonable assurance that orlocal government organizations adequate protective measures can adequate protective measures can inresponse to events at the site.

protective measures can be taken in the event of a radiological be taken in the event of a and will be taken in the event of a Zion no longer has an EPZ and emergency. The extent of State and radiological emergency. The-ex-ten radiological emergency or (2) onsite and offsite organizations local participation in remedial of State and leeal pa..icipati.n in determine that the Emergency have the staff and resources to exercises must be sufficient to show remedial exercises must be Response Organization (ERO) has respond to an onsite emergency, that appropriate corrective measures sufficient to show that apprepri ate maintainedkey skills specific to if requested.

have been taken regarding the rretie measures have been taken regarding the elements o th, emergency response.

• The onsite plan is exercised at elements of the plan not properly plan not pr.oper.ly tested in (ththe State and local participationn least once every two years.

tested in the previous exercises. __........________ remedial exercises must be.I to shoW that appr...priate DSEP Section 8.3 describes the pre.ious.e ,sufficient corrective measures hav'e been taken drills and exercises for the onsite r.egarding the elements of the plan organization. Overall not pr.operly tested ini the previeous administrative controls for Emergency Planning commitments and for performing drills and exercises are discussed in DSEP Section 8.1.

g. All training, including exercises, None g. All exercises, drills, and training ZionSolutions complies with this shall provide for formal critiques in that provideperformance requirement.

order to identify weak or deficient opportunities to develop, maintain, DSEP Section 8.3 describes the areas that need correction. Any or demonstrate key skills must drills and exercises for the onsite

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 48 of 52 a Curent ENew Emergency Planning Rule Compliance Discussion, and Rquested Exemptions Applicability and Implementing (Prior to December 23, 2011)*  : Rule * ~~(76 FRW72596, Nov. 23, 2011) Procedures Poeue weaknesses or deficiencies that are provide for formal critiques in order organization. Overall identified shall be corrected. to identify weak or deficient areas administrative controls for that need correction. Any Emergency Planning weaknesses or deficiencies that are commitments and for performing identified in a critique of exercises, drills and exercises are discussed drills, or training must be corrected. in DSEP Section 8.1.

h. The participation of State and None h. The participation of State and ZionSolutions complies with this local governments in an emergency local governments in an emergency requirement.

exercise is not required to the extent exercise is not required to the extent that the applicant has identified those that the applicant has identified DSEP Section 8.3 describes the governments as refusing to those governments as refusing to drills and exercises for the onsite participate further in emergency participate further in emergency organization. Overall planning activities, pursuant to 10 planning activities, pursuant to § administrative controls for CFR 50.47(c)(1). In such cases, an 50.47(c)(1). In such cases, an Emergency Planning exercise shall be held with the exercise shall be held with the commitments and for performing.

applicant or licensee and such applicant or licensee and such drills and exercises are discussed governmental entities as elect to governmental entities as elect to in DSEP Section 8.1.

participate in the emergency participate in the emergency planning process. planning process.

i. Licensees shall use drill and Exemption Request needed for exercise scenarios thatprovide challenging drills and exercises.

reasonableassurancethat See Enclosure 1, Item A.6.

anticipatory responses will not resultfrom preconditioningof participants.S"ch scenarios foi nuclear"power recetor licensees must include a wtide spectrum -q radiological releses ond events,

ienlding hositie a:tion. Exercise and drill scenarios as appropriate must emphasize coordination

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 49 of 52 Historical Rule Language TCurent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (Prior to December 23, 2011) 1Prior Rule and Requested Exemptions to Deember 23, 211)____Rule(76 FR 72596; Nov. 23, 2011)

Applicability and Implementing Procedures among onsite and offsite response organizations.

Tha aw-ar--icaq a.Qijliný I "v-dar Exemption Request needed for paragraph2 of this section 4y challenging drills and exercises.

nuclearpower r-eoetor licenses See Enclosure 1, Item A.6.

imistprovide the opportunty-fot inf the key ski&l nieeessaiy t inp.enientfthe principalfunctional areas of emtergency respons identified in paraggr-aph2.b of this section. Each exercise mutst provide the oport~unifyfior the ERO to denionstratekey skills specific to emnergency response duties in the joint inf-ormation eentem; Additionall, ii ech eightcalenda year exereise yele, nuclearpower reactor-licensees ý,flaf vamy the content of scenariosduring exercses onduted undem paragraph2 of this section to provide the oppormtiiyfor the ERO to denionstrateproqficieuicy bi the key skills necessary to respomid to tme feoll n sceari eleffents:

hostille acioed-9f -irv ted of the plan site, no radioleogialrilkase or-an

__________________________ I__ I________________________

I mimowf~ne raamoefeglea I_______________________

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 50 of 52 Historical Rule Language Curent Exemptions to Historical New Emergency Planning Rule Compliance Discussion, (risorical to ueemb 23,rlem guaer n tand Requested Exemptions Applicability and Implementing (Prior to December 23, 2011 Rule (76 FR 72596, Nov. 23, 2011) Procedures release that does not requir ubi preteetive aetionfs, an initia elassifleationof or rapid esealation to a Site Area Emtergeney tw Genera! E-mergency, imlemtentation of strategies-,

pro.edures,and guidan.e vel~pe un r Trr and integradionof offsite r~esources with onsite response-. The lieense-e shall maintain a record of ex-ercises conducited duiring each eight year excercise cyc le that docuitents th-e content of scenariosused to compy wh rhe requ ireenfs of rfs paragraph.Eacg-h licene"e shall

.ond f a nosle

.. ae..on exercise for each ofits sites no later-than December 31, 2015. The first eight year exercise cycek-for a site wil ifl t4Ll ar donL iyL.14f eI &f*S J~~J 7:' 1 eoiiafuefw. r1r of di Weeeff-e-under Part52j, the first eight year ex-ereise.cycle begins in the calenidaryear of the initial exercise d~roir.hrA .~FS. rlVEl a G. MaintainingEmergency None G. MaintainingEmergency ZionSolutions complies with this Preparedness Preparedness requirement.

Provisions to be employed to ensure Provisions to be employed to ensure DSEP Section 8.1, 8.2 and 8.4 that the emergency plan, its that the emergency plan, its

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for EmergencyPlan ZS-2012-0307 Page 51 of 52

• Histricg Historical RuleLanguageý

• C u nEnE xemptions pion toto Hto Hilstorical*l New Emergency Req'se "*Planning Exei <.** Rule. . Compliance

.*

• Discussion, and ReusedEeptions Applicability and Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) . Procedures implementing procedures, and implementing procedures, and describe how the DSEP, EPIPS, emergency equipment and supplies emergency equipment and supplies and the equipment and supplies are maintained up to date shall be are maintained up to date shall be are maintained up to date.

described, described.

H. Recovery None H. Recovery ZionSolutions complies with this Criteria to be used to determine Criteria to be used to determine requirement.

when, following an accident, reentry when, following an accident, reentry DSEP Section 5.0 describes the of the facility would be appropriate of the facility would be appropriate recovery actions following an or when operation could be resumed or when operation could be resumed accident. The EPIPs implement shall be described. shall be described.

the recovery actions described within the Emergency Plan.

I. Onsite Protective Actions Exemption Request for protection During Hostile Action of onsite personnel. See By Junc 20, 2012, for Huelc.r Enclosure 1, Item A.5 powcr FcactOr liccnsccs, at range ot protective acetionS to protcct onsite personnel dur-ing hostile actio-n mut be dcvcelopcd to ensurc te eontiatued ability of the liccnsee to safely shut down the r.a.tor.an perform the fu-nc-tions of the licensce's cmcr-gcncy plan V. Implementing Procedures None V. Implementing Procedures ZionSolutions complies with this requirement.

No less than 180 days before the No less than 180 clays before the scheduled issuance of an operating scheduled issuance of an operating ZionSolutions maintains an NRC license for a nuclear power reactor or license for a nuclear power reactor approved Emergency Plan. It is a license to possess nuclear material, or a license to possess nuclear included by reference in DSAR

ZionSolutions, LLC Enclosure 2 Zion Nuclear Power Station, Units 1 and 2 Zion Compliance Matrix for Emergency Plan ZS-2012-0307 Page 52 of 52

• Historical Rule Language Curent Exemptions "Newto Historical :ne Eergency PlanniongRuleiComplit anc DImcussion andEmergency Requested Planning ExemptionsRule Compliance Applicability andDiscussion, Implementing (Prior to December 23, 2011) Rule (76 FR 72596, Nov. 23, 2011) Procedures or the scheduled date for initial material, or the scheduled date for Section 6.5.1. The Emergency loading of fuel for a combined initial loading of fuel for a combined Plan has been modified based on license under part 52 of this chapter, license under part 52 of this chapter, the current conditions of the site.

the applicant's or licensee's detailed the applicant's or licensee's detailed Previous exemptions were issued implementing procedures for its implementing procedures for its by the NRC on August 31, 1999 emergency plan shall be submitted to emergency plan shall be submitted to reflect the defueled condition the Commission as specified in § to the Commission as specified in of the reactor with spent fuel in 50.4. Licensees who are authorized § 50.4. Licensees who are the spent fuel pool.

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

VI. Emergency Response Data None VI. Emergency Response Data Zion is decommissioning the site System System and is not required to have an ERDS per Appendix E,Section VI.2.