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

{{Adams
| number = ML12173A316
| issue date = 06/20/2012
| title = Request for Exemption to Revised Emergency Planning Rule
| author name = Thurman P
| author affiliation = ZionSolutions, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/FSME, NRC/NMSS
| docket = 05000295, 05000304, 07201037
| license number = DPR-039, DPR-048
| contact person = 
| case reference number = ZS-2012-0307
| document type = Emergency Preparedness-Emergency Plan, Letter type:ZS
| page count = 73
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter: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 &sect; 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-&sect; 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 &sect; 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 &sect; 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 hour 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 hour 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 &sect;            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 &sect; 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 &sect; 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 &#xfd;s 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 &sect; 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-Oth&#xfd;     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 &sect; 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 &sect; 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
&sect; 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&#xa2;. 223, 2011)
Exemptions         Applicability and Implementing (Prior to December 23, 2011)                        Rule Rule Procedures re&#xfd;sponse 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     &#xa3;             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    &#xfd;*       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'&#xfd;s 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 &sect; 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 &sect; 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 &sect; 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 pathway&#xfd;p'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 &sect;     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.Qijlin&#xfd;    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 &#xfd;,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 RuleLanguage&#xfd;
* 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 &sect;                                       to the Commission as specified in       of the reactor with spent fuel in 50.4. Licensees who are authorized                                     &sect; 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 &sect; 50.4,                                    procedures to the Commission, as within 30 days of such changes.                                        specified in &sect; 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.}}