ML20083L804

Requests Exemption from 10CFR50,App E,Part IV.F.1.a & IV.F.3, Emergency Planning & Preparedness for Production & Utilization Facilities Training. Forwards Final Rept for 830413-14 Small Scale Joint Emergency Exercise

ML20083L804
Person / Time
Site:	Davis Besse
Issue date:	04/11/1984
From:	Crouse R TOLEDO EDISON CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20083L807	List: ML20083L804
References
1037, TAC-54796, NUDOCS 8404170367
Download: ML20083L804 (15)

Text

. . .

9 9

Docket No. 50-346 TOLEDO License No. NPF-3

!!EIlkI(Ifl RcHAno P. CROUSE Serial No. 1037 U"

atsons-wat April 11, 1984 Mr. Harold R. Denton Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Denton:

This letter is being submitted pursuant to 10 CFR 50.12(a), to request an exemption from portions of 10 CFR 50, Appendix E Part IV.F.1.a. and Part IV.F.3, " Emergency Planning and Preparedness for Production and Utilization Facilities - Training", for the Davis-Besse Nuclear Power Station, Unit No. 1. Specifically, this request is provided to lift the requirement for State and local government participation in a 1984 exercise at Davis-Besse.

Title 10 CFR 50, Part IV.F.1.a and 10 CFR 50, Part IV.F.3. , specify that Toledo Edison conduct a full scale exercise with Ottawa County annually.

Based upon the fact the Toledo Edison's last exercise for Davis-Besse was conducted in April, 1983, current Nuclear Regulatory Commission.(NRC) regulations require another exercise for Davis-Besse to be held sometime during the period April to July, 1984. In this regard, we wish to note that the requirements of 10 CFR 50, Appendix E, Part IV.F.1.a to hold.a full scale exercise with the State of Ohio have been satisfied.

Toledo Edison requests that it be exempted from conducting a full scale exercise with Ottawa County during calendar year 1984. The Company intends to conduct an exercise with Ottawa County and the State of Ohio by April 30, 1985, subject to State.and County participation and the results of the current NRC rulemaking on the frequency of exercises.

We believe this exemption is appropriate for two reasons. First, recently enacted Federal Emergency Management Agency (FEMA) regulations (44 CFR 350.9(c)(1)-(4)) and the implementation of these regulations by FEMA Region V, do not require Ottawa County to participate in a radiological emergency response exercise during 1984.

Historically, Davis-Besse conducted a full scale NRC/ FEMA graded exercise in November, 1980, which included full participation by Ottawa County and the State'of Ohio. .In both January -1982, and April, 1983, Toledo Edison conducted radiological emergency _ exercises at Davis-Besse that included 8404170367 840411 PDR ADOCK 05000 g ,

THE TOLEDO EDISON COMPANY EDISON PLAZA ' 4 300 MAOISON AVENUE ' - TOLEDO, OHIO 43652

.e g-

,+ s.,\.,.

---p-, -.

O Deckst'No. 50-346-

". License No. NPE-3 Serial No. 1037 April 11, 1984 Page 2 full participation by Ottawa County. In addition, as part of the April, 1983 Davis-Besse exercise, the NRC Region III Emergency Response Plan was tested and both Region III and NRC Headquarters personnel and facilities were activated and participated in the exercise.

On September 28. 1983, FEMA promulgated final modifications to its rule 44 CFR 350 " Review and Approval of State and Local Radiological Emergency Plans and Preparedness". The revised final FEMA rule allows, under specific conditions, state and local governments to participate in exer-cises at a nuclear power plant site every two years as opposed to the every year, requirement currently contained in NRC regulations. . Directly applied to Davis-Besse, the FEMA and State of Ohio position identifies'the next exercise for the State of Ohio and Ottawa County at Davis-Besse to be in 1985 (Attachment 1). Both the State of Ohio (see Attachment 1) and Ottawa County (see Attachment 2) agree that the schedule offered by YEMA is acceptable for the adequate training of their organizations and will not in any way degrade the present high level of protection of public health and safety.

Secondly, Ottawa County, with the assistance of Toledo Edison, is con-structing a new Emergency Operations Center (EOC), which will not be-functional until early 1985. Therefore, practical reasons suggest that the next full scale exercise involving Ottawa County be held after the EOC is functional.

Additionally, from a practical standpoint, in both the 1982 and 1983 exercises, significant findings by FEMA identifying an area where improve-ment to the offsite emergency preparedness capability could be made were related to the physical' layout of the Ottawa County Emergency Operations Center. In recognition of the exercise critiques as well as other~ ongoing discussions between Toledo Edison and the Ottawa County Board of.Commis-sioners t it was decided to provide a'"new" E0C in-Ottawa County.

Based upon the currently expected schedule for' completion of construction, installation of equipment, and training of county personnel, the new

~

Ottawa County EOC is not expected to be functional before the end of 1984.

-On March 28, 1984, the Ottawa County Board of Commissioners. selected contractors to construct the EOC._ It is expected that by the end of May, a detailed schedule forl constructing the .EOC will be available.

The results of the 1980 through 1983 exercise critiques have demonstrated:

that adequate emergency preparedness. capabilities exist to assure the continued protection of the'public health and safety around Davis-Besse.

No significant; organizational or functional changes have occurred that-would require extensive retraining offcounty personnel in :the ~ existing -

' facilities. -The extensive program that Toledo Edison and Ottawa County have initiated to . improve the EOC,; represents ' a conscientious ' joint effort "

-by a utility:and'the-localfgovernment within the~ plume' exposure EPZ to dedicate significant -resources to improve the local Emergency Operations' Center,

_ __ m _

i Dockst No.~50-346

+ License No. NPF-3 Serial No. 1037 April 11, 1984 Page 3-4 I

t l

When the new EOC facility becomes operational, personnel retraining and

j. exercise of all new equipment and interfaces will be required. 'The

facility will be used by the County for all future radiological drills and 1 exercise activities, as well'as in the event of an emergency at Davis-Besse.

1 Toledo Edison recognizes that the NRC is currently conducting a rulemaking j- that could modify the existing NRC requirements regarding the frequency of emergency preparedness exercises. In this regard, Toledo Edison concurs with the Commission's statement in the prologue to the proposed rule that.-

l "...It has become apparent that a disproportionate amount of-Federal, State, local government and licensee resources are being expended in order

, to conduct and evaluate emergency preparedness exercises at the presently '

required frequency." Toledo Edison believes that the current situation at Davis-Besse provides an excellent example where an exemption from the

~

existing NRC rule would result in more appropriate and effective use of local, state, federal, and licensee resources, j This conclusion is firmly supported by the position being taken by the  ;

Ohio Disaster Services Agency (see Attachment 1), the Federal Emergency i

! Management Agency (FEMA) (see Attachment 1), and Ottawa County (see Attachment 2).

We trust the information presented in this letter has adequately. supported our exemption request. We intend to proceed with plans to conduct a Davis-Besse site exercise at the end of July. If you'have any questions, plese contact Judith Hirsch, Emergency Planning Supervisor.

I Very truly yours, b ,

RPC:MSF:nif  ;

encl./3 cc: . James G. Keppler, Regional Administrator.

DB-1 NRC Resident Inspector L Kenneth Cole, Ohio Disaster Services Agency

• James Greer, Ottawa County Disaster Services Agency l'

4 A

y

?

____._.____.__._______u. u i _ __ ._1___.___..__._ . . _ _ _ . . _ _ _ _ _ _

__._.m._mm _ _. i. ._. _. _ _M.

A -

STATE OF OHl0 ADJUTANT GENERAL'S DEPARTMENT 2e26 WEST GRANVlu.E ROAD ATTACHMENT 1 WORTHINGToN. OHBO 43o86 DISASTER SERVICES AGENCY AGoll-1)S January 9, 1984 Mr. . James P. Greer, Director Ottawa County Disaster Selvices 315 Madison Street, Room 103 Port Clinton, 011 43452

Dear Jim:

For your information and comment I have enclosed a copy of the most recent All-State I.etter from FEMA, Region V. This letter clarifies the proposed rule in the Federal Register, Thursday, July 21, 1983 that suggests a biennial RERP exe rcise. Those counties which may be excempt in 1984 are Columbiana and Ottawa.

Please consider the attached exercise schedule which will be proposed to FEMA, Region V during the January 11, 1984 conference in Chicago. I feel this schedule will provide the optimum conditions for beginning the two year rotation of exercises in Ohio while tdking advantage of the fact that Columbiana, Lake, Genuga and Ashtabula counties are presently preparing for the 1984 exercise.

If you have any concerns or comments, please contact me at your convenience.

Since ley, ,

c F /

bin i B. CO Nuclear Operations Officer KBC:kjs Attachments: FEMA All-State Letter Federal Register l ner. p;cm ,M LEE ~

Nuclear Power Facility Exercise Schedule E.wrg Pb..

• O 1 1 $$yi g cc: Ms. .ludy liirsch, j ' '

g' Toledo Edison Company ~ ~

Mr. Ron Young, '

~

Resident Radiological Analyst , ,

1

._j L. . . m . .

.-.....-. .. j . ,,' . 4 -

! t I f_ _  !

Ats

.i

t G .

Federal Emergency Management Agency k$ (b Rcymn V 300 South Wacker. 24th Floor. C 60606 (312) 353-lp00 December 27, 1983 /,, ,

ASL 71-83 l

ALL-STATE LETTER ,

TO STATE EMERGENCY SEWICES DIRECTORS: Illinois, Indiap, Michigan, 6 Minnesota, Ohio, and Wisconsin

SUBJECT:

Biennial Frequency of REP Exercises The application of FEMA's Final Rule 44 CFR Part 350, dated September 28, 1983, concerning Biennial Radiological Emergency Preparedness Exercises

( 350.9) should be construed as follows:

A State that exercised fully between the period October 1, 1982, and the present, is eligible for exercising biennially.

A local organization which has exercised fully between October 1, 1982, and the present is eligible for exercising biennially. The above is illustrated in the following examples .

Example # 1 The State of Illinois fully participated in an exercise with the Byron Nuclear Power Station and Ogle County, Illinois, on November 15, 1983 Therefore, the State of Illinois is eligible for exercising biennially. I Example # 2 The State of Wisconsin fully participated with the Kewaunee Nuclear Power Plant and Kewaunee and Manitowoc Counties, Wisconsin, on November 1, 1983 Therefore, the State of Wisconsin is eligible for exercising biennially.

Example # 3 N Local jurisdictions that have fully participated in an REP exercise between October 1, 1982, and the present are eligible-for exercising biennially. Eligibility is established even though the State may not have fully participated.

i Examples am: Lake County, Illinois, and Kenosha County, Wisconsin, fully participated in the January 18, 1983, Zion  ;

exercise when the State of Illinois and Wisconsin did not fully pa rticipat e. In this instance, Lake County, Illinois, and i Kenosha County, Wisconsin, are eligible for exercising biennially.

I 1

.e,

• J -

2.

The National Federal Emergency Management Agency has confinmed this uraderstanding of the September 28, 1983, FEMA Final Rule. It is impo rt an t the States and the local governments consider the above as part of their preparation for the January 12, 1984, meeting at the Ra ma da Inn , O' Ha re . The Radiological Emergency Preparedness Exercise Schedule, as currently developed, will change as a result of the j new FEMA Rule.

Attachment A to this letter is a listing of State and local jurisdictions that are eligible for exercising biennially. Attachment B is a listing of State and local jurisdictions that are not eligible for

, biennial exercising.

Sincerely, 3

,/ / -

, ki( '/ -c Edward J. Roche, Sr.

Regional Director Attachment I

i l

1 l

i

, p *

~"

J -

K *.' ti"' :;I a STATE ' LO C AL .I t'u l S D G I DS S 'l !iAT 1A'! E!: C05S IDi'.Kr.D l'LIG ILLE FO., L.c rN lSI:;G hlES51 ALLY S t a f. s or s ..n i . . t i o ns County Organizations 11 J i n..i: Ogle 1.a Salle UinnebaEo P,ock Island Grundy Ubiteside Kendall Lake Will

li( h it;a n Eerrien Charlevoix Van Buren E::a.e t Allegan

linn reta s

• atota Sherburne Gnadhue ,

Wright

{

t i

Ohio Coluabiana Ottawa I

h* 0 nv 5 ha !an'. ;OWOC Wisconsin K0waunee Pierce I

l u

t

(

,y

, l' .

l l

f r , 'l . . ,

l STATC f local .Jri;I6111C1]O::S :;01 i !. !(. I F.~.

. TO .\LI:CI S E iilr:0:I ALLY State O ry .. r. .tignj; Cuent) Or; ani za t ions In Illinefs: De'li t t Macon McClean Platt Will I n

.-+.,.w,w-,~w..,..,-.-me-e,---,-.,wn-n,,.-Yveve-----*~w-- 3ifuu . hderat Hugh.tur / Vol. 40. No.141 / Thursday July 21. 1903 / Proposed Rules i.___._ _.. . . _ _ _ . - . _ . ~ Jtillon oro. for thu most past. utilitics. untypical,is not untformly true at all insiuncos. A provision hzs therefore ' .bgan tirias and consulun;; firin. situs. been udded to require licensees to , s epreseraing utilities, und a s. umber of A Notice of Ilucalpt of petition for conduct exercises annually with full ! itate aind local governinental agencies. Rulemaking was published in the State participatton if requested by the l2. A&utant Generalof the State of South * " P # *" " * "

• 9'**' " "

Can oNno. Emergency Preparedness g, comment. To date.10 comment letters it permits a State to require the conduct have been received and evaluated by of joint exercises with greater frequency On August 30.1982. the Commission the staff. One letter opposes relaxing the than might be required by NRC. In the' , received from the State of South frequency of exercises whde nine letters Commission's view, this provision is

• i Carolins a petition for rulemaking were in favor of relaxing the frequency desirable in light of the strong State role

,(PRM-50-341 which requested that the of exercises. . in emergency preparedness ~. j NRC rsduce the frequency that local By adoption of a final rule similar to in reviewing the emersucy . l Hovstnm:nta must participate in full- this proposed rule. the Commission preparedness exercise experience the l; cxarcis:s. scala smsrgency preparednesswould grant the petitions for rulemaking staff notes that within the last year, the . cited above. NRC and FEMA have evaluated 52 , h3 State of South Carolina's The Commission is considering emergency preparedness exercises

rausnels was that local county changing its requirements concerning involving a utility. State and local .

governments rely heavily on trained emergency preparednese exercises in governments.These evaluations have-voluntetr citizens to respond on a day- ordu to provide flexibuity inits identified deficiencies related to a

to-d

y b: sis to natural and technical regulations.The proposed rule would numbw of the planning standards in10 f em2rg:ncies that occur within the retain the presently required annual full- CFR 50.47. In almost all cases, the

county.The requirement for an annual participation exercise, with h proviso evaluations did not identify fundamental

{ full.scals exercise by counties was that if all me;or elements in the defects in the way that the emerger.cy

atatid is impon an undue burden on emergency plan are per{prmed in a plan was conceived orimplemented

thess volunteers who. in many cases, satisfactory manner during the annual such that it called into quesuon whether

wruld have to be exercise participants exercise. FEMA raay recommend and a finding could be made that a state of -

. ca th:ir own time. the NRC may find that anobt exercise emergency preparedness existed which la its petition. the State of South with State andlocal gowwnmutal would provide reasonable assurance

Carolina stated that

**The requirement participation is not required for a period that appr priate protective measures for offsits plannmg and response to two years.

1 c:psbility exists for those counties . ofTuke proposed rule would not relaxcould in and would be taken in the event

p

rtisily or wholly within the 10-mile any manner the onsite exercise that *g g, *",*",'g'8 ge a Secuon IV.F of EFZ wh:re a nuclear power reactr.ris each licensee is required to conduct ist Iscated as for the county where a which includes emera.! sing control room. Appendia Eis also proposed which

' nucle:r reactoris located.The point would speciti y allow the use ot alu-technical support f. enter, and emergency I b:ra being, of course. that the county in opwaung facility functions. A astial or sPecinc contml rum simulames or ' which a nuclear power reactor is full participation exegelse wou d satisfy computers to aid in realism of rea ter l located derives revenue from the reactor b licensee's annual requirement for an parameters and theirinterplayin e ' cwnw. which should help offset exercise onsite exercise as fulllicensee ***"I , c:st.The other affected county (les) participation la required for either type Addidonelly. in I 50.47 and Appendix . I derive little or no revenue from the of exercise. E an editorial change is being pmposed re:ctor cwner and the cost of an annual The minimum frequency of exercises in order to delete the existing footnote la ! full ecala exercise is an annual in which a State would participate for a the emagency puparednen reguleHons cddiurn:1 expense to the county. Most particular site would be relaxed from nlaung m Nmm FEMAM1. el thsee counties have a low economic the present once every five years to Rev.t. November 19e0.This deletion base and the requirement for a full. scale once every seven years.nis change was made because the NUREC is now 4 cxercise places an undue financial would usure that States with the *. endorsed by Regulatory Guide 1.101. burd:n en county resources." greater number of nuclear power plant Rev.2. , Finilly, the State of South Carolina sites will not be required to exercise in a The Commission believn that st:ted that. "None of the counties full participation mode more often than adoption of these rule changa will more i located partially or wholly within 4.10- about once a year.De minimum . . . . . . effectively focus available resources onA i mits Ep2 question 4hetiesd foe ---- -- frequency of opportunity 1or Federal" '8 the pertinent issues and probleme'in - .- i partiefpation at each site would also be establishing and maintaining an l appropriate steining to respond plans, to a exercises, reactor - and extended to once every seven years to upgraded and effective day to day state , i r:di logical accident or a natural be consistent with the proposed change of emergency preparedness. disaster, but they have questioned the in b State participation troquency. Additionally, the added flexibility will ' need for en annual full scale exercise. Although not specifically required by be an incentive for licensees and State ! Ftr the continuing enthusiastic the rule, the Comunission e athat and local governmental agencies to } p sticipation by b counties and county Federal participation. Inclu . perform emergency preparednese I valuateer emergency response participation by an NRC site team, exercises in a satisfactory manner would occur in an exercise in which b which will assist in ensuring appropriate )l personnel, NRC to tavaluate thethe peutioner requirement requests for- the fully participates at least once State protection of the hulth and safety of the , ! local sovernments to participate in an every seven years et each site. public.  ; I annu:1 full. scale exercise." la early 19s2, some Because FEMA is directly involved in ' The Coasmission notes that the interorganisat6onal Advisory Committee the evaluation of offsite emergency , distnbution of the revenues varies from (IOAC) members expressed concern preparedness exercises and, therefore. ! Stats te State and be the situation that single eite States might need more would be effected by the promulgetion . descnbed by the petihoner, while not than a biennial anestise la certain of a final rule, the NRC consulted with ~ i - - . . - - - . . , , - , - - , . - - - . - . . - , - , . , . - _ - --,w,- ,,,,r -,n-,-,,.--,,_.._,_,,,.,._.,-,.s,n - _ - -, - - - - . D ' Federal Regwer ! Vol. 48. No.141 / Thursday. }uly 21, 1983 / Proposed Rules 33309 ~ ' PEhtA dune g Ine development vi th,. Cast 4.-Foun Satss WiTH ALL PLuwt preparedness exercises falls un State propawd rule. ExPoscas EPZ'S WsTMas ONE SrATE and local governments. the proposed Tha followmg talles .Ntrate the (**. 8. i.a rule would lesson this burden by imm.r.um frecuen y for tne partic.pation ' possibly decreasing the frequency of of State and lo6al governmunts in '** 8 8 * * * ' i emerbency exercises t...t could result if sa. these exercises. would impose Thus.,ficant economicthe ne signi FEhtA were to retumraend and the NRC A- ' - 8 3 - - . t impact on a substantial number of small .wsro to find th4: u,e sesults of each $ a 7~ ' 'n entatin, as defmed in the Regulatqry s. exercise are such that a subsequen, o a n , Flexibihty Act of 1980.

ensrcise is not sequ;re3 for up to tw pars. Exercises could be csore frequent L!st of Subjects in 10 CFR Part 50 Cast 5.-Fivs Seves WiTH Act.Ptuus 1

than indicated on these tables af a Exposune EPZ's Withm Ons STATS Antitrust. Classified information. Fire i satisfactory finding could not be made prevention. Intergovernmental relations. by NRC. g ,. ism. oru Nuclear power p. ants and reactors. For planning purpoi,es, exercises '*" e a s e s e r Penalty. Radiation protection. Reactor should be scheduled in a menner which sitios criteria. Reporting requirements. rssulta in all State and local *"A .,_,_ P X X 1 i governments within the plume exposure s a , a Regulatory Analysis ( Em:rgincy Planning Zone fully f * # * * . a x e The Commission has prepared a

ptrticipating in some exercise on an 8 x a x '- regulatory analysis for this regulation.

canutt basis.When a favorable The analysis examines the costs and reccmmendation from TEAtA along with CAss 4.-Seven sates WrTH ALL PLuus benefits of the rule as considered by the , a favstable finding from NhC is Exposuns EPZ's WiTHin One STATS Commission. A copy of the regulatory

ceived. appropriately schedulad g,,, ,an. sau analysis is available for inspection and eurcis:s can be canc411ed to conform to copying, for a fee, at the NRC Public h bi:nnial frequency. v s s . s e r Document Room.1717 H Street NW.,

e,, Washington. DC. Single copies of the Em:mpin E.ancise frequ.ucles foe state and a p x a a analysis may be obtained from Michael Local Governmeets for Various Numbers of a P a a i z p T.jamgoChian. Office of Nuclear , hucJear sitw If am NRC Findtag Permits sa f-"'~~ g _ p a a Regulatory Research. U.S. Nuclear

Emudse Evwy a Years e a a E P ---- Regulatory Commission. Washington.

F= Full parucipallon by Siese and local e a a a F. DC 20665. Telephone (301) 443-6890. .

• gov 2rnmental agencies and licensee X = Full petticipation by liceasse and local Paperwork Reduction Act Statement gov:rtuneatal agencies and partial Caes 7. -4sasspLa Pon a nma..y gaggar participation by states withm plume Tunse Statsa This proposed rule contains no esposure EPz information collection requ!rements and g.,, ,,,, , ,u .

Blank or L-I.lconese only therefore is not subject to the l vm i e e s * ' requirements of the Paperwork  ! l Casa 1.-.Oma Sets WITH PLuus Exposuns ,,, Requirements Act of 1980 (44 U.S.C. 3801 l , EPZ WiTHm One SrATs a,. _ p a a s' et seq.). i g.,. su *= a - P a . Pursuant to the Atomic Energy Act of v ar s e e r e,_ , e , 1954, as arsended, the Energy i e m e - a s Reortenisation Act of1974. as amended, l 7 " - ' and section saa of Title 5 of the United r t

• "a_,.,_,_ r*

, , ,. e-sisse s. 4 es States Code' motice is hereby given tinat g $ 2 $!"".g. ,sens a,,,,,, ar; se on.sses . - adoption of the following amendment to , 10 CFR Part so is contemplated. j Cass 2.-Two Srtes' Wii.a BoTM Ptuus Exposuna EPZ's WrTHen Ows STATE RegulWry FbibiMiy CMincab ' ' la accordance with the Regulatory PART 50 -. DOMESTIC LICENSING OF. tea. an. Fu Flexibility Act of teen. A U.S.C. section PRODUCTION AND UTILIZATION v i a s e s e r aos(b), the NRC certines that this rule FACILITIES , will not,if promulgated. have a 1. The authority citation for Pa'rt 30 e.- el cant eea-te impact on a continues to read as follows: ' "i~~ p p tantial number of small entities. The Amabestey Sess.10s,104.141.18L tea. las, proposed rule concerns the bequency 188,08 Stat. Set 887. 944 983. 064. 084. 98& se M%" 'C" ". ="'.* '".*E.' ',3 " ena extent of conducting full.ecale = ==s= * = i=== a = <*===* m a == emersises of emergency plans for nuclear (4a UAc atas,asse sact.saas. :aa.aass. amended. sec. 234. es Stat. tsee, as amended power pianu.The electric utility . asse. assal: sees. set sea. act as seat tsea. Casa a.-Tnnas s Tas Wirw Au. Pouus companies owning and operating these 1244. see, se amended (sa UAc seet, sota. E.arcaunt EPZ's Watn.N Ops ETArs nuclear power plants are dominant la setel, unleu odimwiu noted. . far, ru. siu their Section s&F aise immed under W. es-401, sec. to. 92 Sest. 2881 42 UAC. Seat). ,, , , , , , , g , , the efinition o. service of a small stess busineseandfound do not sectfall6en withinse.7e else issued (mader se ( la Section 3 of the Small Business Act, seas. sas (42 U.S.C. atsal. Sections taso aast L. l 15 U.S.C. section 632, or within the Small aim tweed under ses. see, as stat, set, a i' a P a n - E Business Size Stenderde set forth in 13 emended (en USC assel. Sectione 80.10D. s is I '_ i~~ ~~ .--. 1 CFR Part 121. Although part of the burden for the eenduct of emergency 80.10s also 6eswd under see. naa, as Seas. ens (ea UAC asael. t r I .- . _ - - _ . _ _ . . - _ _ . - - . . _ _ _ . . - . . _ . _ , _ . ~ _ . . _ _ _ - . . _ _ . . . . _ _ . . . _ _ _ _ , - , - _ _ _ . . - . _ xiito ** l'edural Kcxlvict / Vol. 40. No.141 / Thursday. July 21. 1083 / Proposed ibles II ' for the purpose of eec zza w Siet.'ose. se by each Siete end local government within For the Nuclear itegulatcry Commleelen. amendeo 142 U b C. 2341. lt unolui. iul. the plume esposure EPZ and each State Sensuel J. Cida. i and (c,. 39 44. 60 so. I,0 40. 50 to .au Su ndle) within the insestion pathway EPZ. Secevrory of the Commluson. , ato ses.ed 4.im sec.10lb oc but I+4a. se 2. Each licensee et sech ette shell:

1. '""'"***'*******'I

! cmendeo itz t.: :; C :;uitb!, Ii *,J 10(W und e. Annually esercise its emergency plan.'

b. Encept as provided in peregraph 3 l (c) and 50 34 are isewed und* r .ec.101. so below, include in lie annual esercise:

Stes. 949. es amended t4: t' 5 C uutill) end , il 50.5Siel So :,wib) 5010. 4 71. .s0 72. erd (1) Annual full participellen

• by local sovernei*nt e8'aCl**- DEPARTMENT 0,F TRANSPORTAT[ON

! emence i lt 5 b:1 (ii) Annuel full or partial participation 8 by States within the plume esposure EPZe. Federal Avtetion Administrauen i.45047 [ Amended) ***"* ! 2. In l 5o.47. Footnots 1 is deleted * .enorcies with eamultaneous full partscapetion 14qpgperg71 by local seurnment egencies within the l

3. In Appendix E. Sectiva IV.F le plume aposure Ept and full porticipollon bY (Airspeee poetet No. SS-ANH F)

Siena within the plume espesure end

revised to read as follows.

e to P uction ab be sne e m ly

• ""8

! IJt111 andes Faculties esaully if FEMA recunmende and NRC Aosacy Federal Aviation l IV.Coeneet of Emweeecy I'lew makes a findtag that au maler elemente la ** Administreuen (FAA). DOT. 4 l*p. Tre/nhis *

• een.res=N*dwCheuw"=awme, enether wercise to not needed for up to a Aameen Notice el propeeed rulessaking (NPRM). .

1- years, ualees en annisel emerelse is . I The regram to provide for (1) the treintag aussesARY:Thl 1 of e, nees and see,cieing. b, ,e,iodia s,po , , a,,,Aeo,,llyrege,n,te,d,,by ,e , ,, b S,, tele la which ,,d ,e th, , e .notice proposes roe, t,enetites ,,ea le ai dettle, of redletten emergency plass to enoun 348 e, entene. to 18 late that esiployees of the licensee are familler netweesteading, meh late wittila e plume empoewe pathway EpE oben fully partielpete natismal  ; with their specific emergency reopense la est sureise et least ease every a yeere et comp lance with guidelines.*!he establie reduced yo .' transitica  ; j dxties, sad (2) the participation in the i uslains and drille by other persons whose some ette. [ 4.'I1 e plan eheu descr6be peevleiesis for sees will shaalnete restrictions on VisualFilskt unnecessary Rwee (VFR) l l su6et::ce may be needed in the event of e i re' action emergency shall tee described.This levolving Federal emergency mpense operations but will accommodate i ohillinclude e desenplien of speciellaed egeme&es la eri emergency papendnem . Instrurnent Flight Rules (IFR) arrivale, j lattial u:tains and penodic rettelatos enerdee involvtag State and lesel authertu" departures, and holding altereft, where . prose:me le be prov1Jed to each of the by seehileensee et seek elle et which one er applisable, within controlled airspace. I 3 i

fctiowmg caisgeries of emergency pereoameh , mese power reactere are lesated and licensed -

o. D6tectere endler coordinatore of the for operetten at least enee overy F yeare. SATs:Commente must be resolved en er

-l 3. Au treintas, including nutm. ebou belers September 10.1008. l pt:nt emergency

b. pereennel mopensible ergenseetien; for accident provide for formal edugen la wder le Asemassent Send comfnente en the ,

, cu:ument, including control room stuft ideaufy -, w eimemos week er denment - deaam-that.ned ee Rreposaledu,esto:,anch. . Manager. AuM Alt. Fae,ei space & i -4 . et am i autned shau be masted. Aviation Administration.Nerthwest l l d. F re cui t7eN$te br$e*d$el;

e. septte end desiese convot seeme; Mountain Region.179ao pseine Highway l l South. C-40008. Seattle. Washlagtes i f. F6tet and and rucue toerne; Appendia Eg--- "~ - -a -

e. Medtui euepet pomn=1; estes. .  !

j h.um: u o imedquartere empport -

4. In Appendia E. Feetnotes 1 and 4 'the ofRcial docket may be emandnad I m removed l P*Y,y ,,,,s.n.:"

g . is the ResionalCounsel OfSee and as lafernal decket may be esamined la the in addipen, a radiological orientadoe I' trein6ag program ehell be made eveilable to Dated tido 14th day of July.1 gel . Airspace & Precedures Breach at the , ! loc:1 a:rvices personnel; e 3 local Civil same address. For further laformelles , l Defenee,laullaw placement persommi. e use et one pemas sismioise a mapen.18 eentact Ka6y Paul. Airopese  !

• " " ** Teeknisian. ANM-438.'!he telepheme i naal news media penom. . .y,g g*,,,',,*, , * . ,4 m d., l 1

Ths pl:n shall desenbe previesem fee the seaber la (Ele)4318880. l conduit of emergency preparednese eaereisee wie amasses, peeperedum ,,,unge,see, ,,,,,,,, m,, ,esem tw agen, ggang ,,g ) es fIllows. Eserciese shall teen the adequacy ggppt.et0SgtfAfff181,00e64T9003 (f 14 ming and content of implemenung base eethendem and aesteely inte penesed inessess in seenns pa.ssessel phyeeselly ser Isseyeeed espotilley se edequessly essess and peepend to se Casasseste Invited .

• procedures and methods, test emerge -

essident et e esamesetal suelow pasar plass. -phil l 4 ogetpment and communicetsoas netw latmeted pmene may perdespete la ' l teet the e.iblic nautication e y. tem, and 78'umpsese easlede imens es meter stoneMe 8 the proposed rulemaklag by submittlag seewe diet emergency ersemaeuse 8"*"" d ** *""a*m**en,88"" imeland ""gener *' ,8am such written dela, views. er argussente pweennel are femalier wide their duties. ',',,d,,,,g ,, es,, ,,, am"" men" ambon

1. A hall particapet6es emersase wh6ch teste i, ,,,,,, g , ,,,ggm ,e,,,,,,,g g, gens se they may desire. Ceausumiestiene se m:ch of the licenm. sum ud lacei ses e , should idenuty the siropees doeket <

I emergency pine = w rueoubir schwable e pweespuusposes whm endaseminada number and be submitted le the address witheet meadecery public perucipetsen ohell esteh emessener; , 2 emesmees for a listed above.Commenters wish the pensadne een means esempdow esde essenem ,g to conducted for each site es which a power 7AAtea,g,,wg,gg,,,,, g, r:naer le neceiod for which ihe Aret opereung nl. ahmeset es.swer.inte .es se e es pen~in e.s iel ==== enames iscomme,,ia. ie-usem.ee ma " Eve"1.* sit;'s"e'".l"!r 'e'L">"i e --t: e.e.  :::w;*.?m:ee. wi* stemped *.a psicard -aenew gd*a-4. *e . e.e esweis.ee ehen ios be co endwied .f withia eu one year sees M,i.e.e.s.,i e i. g .enseied el seees f.u. win.and .iamai iss,se ==ele.e,pe ee be.e.,s. u, e , ewe,. e.d ein.n i-iu ope.,e ,ng ineene.e I,e e. .e, .e - .e es.ne e. -C.emie. Aa.,seenahei e . _ _-_-- ~ ,----- - _ _ - . _ . - - - . - - - - . - _ - _ i . OHIO  ? NUCLEAR POWER FACILITY EXERCISE SCHEDULE r .. i I . YEAR 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 PNPS F -- X -- F -- X -- F -- X DBNPS -- X -- F -- X -- F -- X -- BVNPS X -- F -- X -- F -- X -- F ZNPS -- F -- X -- F -- X -- F -- j i h i 'I 's \ i I F = Full. participation by State and local governmental agencies and licensee. l X = Full participation by lincensee and local governmental agencies and partial participation by states i within plus exposure EPZ. l b l I i . s OTTAWA COUNiT DISASTER SERVICES AGENCY g/,4 Ja'7M COURT HOUSE 315 MADISON. ROOM 308 ATTACHMENT 2 PORT CLINTON. OHIO 43452 PHONE (419)734-4431 EXT 206 James P.Greer Residence 734-3102 Director / Coordinator Emergency Phone Only 734 4404 April 10, 1984 Ms. Judith Hirsch l Emergency Planning Supervisor l Toledo Edison Company 300 Madison Ave. Toledo, Ohio 43652 l

Dear Judy:

As we recently discussed, Ottawa County concurs with Ohio Disaster l

Services Agency's (ODSA) interpretation of Federal Emergency Management Agency (FEMA) guidance in 44 CFR 350. The January 9, 1984, letter ,

from ODSA supported our contention that county participation in a radiological emergency exercise with the Davis-Besse Nuclear Power Station (DBNPS) is not mandated until 1985.

Ottawa County agencies have proven their ability to protect the public health and safety during past exercises. The few deficiencies noted in F.E.M.A. critiques have been addressed and will be corrected when our new Emergency Operations Center (EOC) becomes operational in January. We anticipate in-house exercises to perfect internal procedures and several " table top" exercises with ODSA and DBNPS personnel to further improve our capabilities.

In view of our record in previous exercises, FEMA guidance in 44 CFR 350 and the unavailability of our new E.O.C., Ottawa County does not feel it is imperative to participate in a DBNPS exercise in 1984. It is certainly not the intent of the county to jeopardize Toledo Edison's compliance with Nuclear Regulatory Connaission regulations.

We offer our full support to you in your request to the NRC for an exemption from a full scale utility / state / county exercise during

! 1984. l l

Sincerely, D:so F,ctow?d LO3 NO.

Emotg Fhmma n '

I i

i Apg i j gy 84-135 f' ~a>= v iL James P. Crear m.7 - . ... . .

g . &. .

.. ... ~

JPG/tm . . . . . . . .

i ' .

}.. -I ~.n.- i '

I  ! l AE E 1.24 L

. 3 ~

ATTACHMENT 3

/

l Federal Emergency Management Agency Region V 300 South Wacker,24th Floor, Chicago, IL 60606 (312) 353-1500 f4AY 1 V l'383 Mr. Richard M. Lockhart Deputy Director Ohio Disaster Services Agency 2825 West Granville Road Worthington, Ohio 43085

Dear Mr. Lockhart:

Enclosed is a copy of the Final Exercise Report for the Davis Besse exercise conducted April 13, 1983. A copy has been forwarded to the FEMA National office.

The Federal evaluation team concluded the State of Ohio and Ottawa County emergency organizations demonstrated their capability to protect the population should an accident occur at the Davis Besse Nuclear Power Station.

There are, however, a number of significant discrepancies as indicated in Part IV of this report that will require your immediate attention. Of particular concern is the time delay in establishing the seven mile protective actions and repeat discrepancies.

This report indicates certain areas that will require varying degrees of changes to your plan and/or implementing procedures. It is intended to assist you in this endeavor. If you have any questions relative to this report, office.

or require assistance in making these changes, please advise this Although you are only required to provide this of fice with a schedule of corrections for the significant discrepancies Part IV, please review the minor discrepancies in Part V as well to include in your own schedule of corrections.

Your schedule of corrections for the significant deficiencies should provide a concise narrative of how you intend to correct the significant discrepancies as well as the date or anticipated date of completed action. We appreciate receiving this schedule no later than June 4 ',,1983.

o/ 4 %

Do not hesitate to contact Dan Bement or B'o b Shapiro at FTS 372-6011 if you have any questions or problems with this deadline.

Sincerely, 9

Qu WN

~

i Frank Finch, Chairman Regional Assistance Committee Enclosure