ML15210A314

License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel

ML15210A314
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna, 07201036
Issue date:	07/29/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
Download: ML15210A314 (24)

Text

200 Exelon Way Kennett Square. PA 19348 Exelon Generation www.exeloncorp.com 10 CFR 50.90 July 29, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Calvert Cliffs Independent Spent Fuel Storage Installation Materials License No. SNM-2505 Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220, 50-410, and 72-1036 A. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 and 72-67

Subject:

License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the licenses for the facilities listed above.

Specifically, the proposed changes would revise the description for Emergency Response Organization (ERO) requalification training frequency defined in Exelon's governing Emergency Plans for the named stations from annually to "once per calendar year not to exceed 18 months between training sessions." The Emergency Plan is described in each facility's Updated Final Safety Analysis Report (UFSAR). In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," Exelon requests U.S.

Nuclear Regulatory Commission (NRC) approval of the proposed changes to the Exelon Nuclear Radiological Emergency Plans for the facilities listed.

U.S. Nuclear Regulatory Commission License Amendment Request Revise Emergency Plan Requalification Training Frequency July 29, 2015 Page 2 The proposed changes have been reviewed by the Plant Operations Review Committees at each station and have been approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program for those facilities required. provides an evaluation of the proposed change, including a detailed description, technical and regulatory evaluations including a no significant hazards consideration, and an environmental consideration. Attachment 2 contains mark-ups of the existing Emergency Plan pages showing the proposed change to each facility's Emergency Plan.

There are no regulatory commitments contained in this submittal.

Exelon requests approval of the proposed license amendments by July 29, 2016. Once approved, the amendments shall be implemented within 90 days.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of Maryland and the State of New York of this application for license amendments by transmitting a copy of this letter and its supporting attachments to the designated state officials.

Should you have any questions regarding this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th day of July 2015.

Re~*:*u-James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Evaluation of Proposed Changes

2) Exelon Nuclear Radiological Emergency Plan Station Annex Mark-ups cc: Regional Administrator - NRG Region I NRG Senior Resident Inspector - Calvert Cliffs NRG Senior Resident Inspector - Nile Mile Point NRG Senior Resident Inspector - R. E. Ginna NRG Project Manager, NRR - Exelon Fleet NRG Project Manager, NRR - Calvert Cliffs NRG Project Manager, NRR - Nile Mile Point NRG Project Manager, NRR - R.E. Ginna S. T. Gray, State of Maryland A. L. Peterson, NYSERDA

ATTACHMENT 1 License Amendment Request EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization for Calvert Cliffs Nuclear Power Plant, Nine Mile Point Nuclear Station, and R. E. Ginna Nuclear Power Plant.

1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 1 of 13 ATTACHMENT 1 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the following Facility Operating Licenses (FOLs) for the plants listed below:

• Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318 Material License No. SNM-2505 Docket No. 72-8

• Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220, 50-410, and 72-1036

• R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket Nos. 50-244 and 72-67 The proposed changes would revise the description of Emergency Response Organization (ERO) requalification training frequency defined in the station Emergency Plans listed above.

The proposed frequency will be defined as "once per calendar year not to exceed 18 months between training sessions." In this context, training session refers to the annual requalification training received by the ERO.

The Emergency Plan is described in each facility's Updated Final Safety Analysis Report (UFSAR). In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (q),

"Emergency plans," Exelon requests U.S. Nuclear Regulatory Commission (NRG) approval of the proposed changes to the Emergency Plan for the facilities identified.

2.0 DETAILED DESCRIPTION Planning Standard 10 CFR 50.47(b)(15) specifies that Radiological Emergency Response Organization (ERO) training is provided to those who may be called on to assist in an emergency. This is further expanded in regulatory guidance provided in NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," which specifies that organizations shall establish specialized initial and periodic retraining programs for those who may be called on to assist in an emergency and that each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 2 of 13 2.1 Calvert Cliffs Nuclear Power Plant Emergency Response Plan The Calvert Cliffs Nuclear Power Plant Emergency Response Plan provides the following frequency requirement for ERO Training in Section 6, Step I.

I. TRAINING An integrated training program provides for and ensures initial, annual, and continuing training of appropriate individuals and groups involved in emergencies.

8. Emergency Personnel Plant procedures establish a training program for instructing personnel who implement radiological emergency response plans. Specialized initial training, annual, and continuing training programs (including scope, nature and frequency) is provided for:

1. Directors or coordinators of response organizations.

2. Personnel responsible for accident assessment.

3. Radiological monitoring teams and radiological analysis personnel.

4. Security and fire fighting personnel.

5. On-site repair and damage control/correctional action teams.

6. First aid and rescue personnel. This training includes courses equivalent to or exceeding Red Cross Multi-Media.

7. Local support services personnel including Emergency Management/Emergency Services personnel. Site specific training is provided to those off-site organizations who may be called upon to provide assistance.

8. Medical support personnel.

9. Recovery Organization personnel.

10. Personnel responsible for transmission of emergency information instructions.

The training program for members of the emergency organizations includes practical drills in which individuals demonstrate ability to perform assigned emergency functions.

Calvert Cliffs Nuclear Power Plant Emergency Response Plan currently states the ERO requalification training is "annual" for the site emergency response personnel. The term annual is not specifically defined within the Emergency Plan; however, Calvert Cliffs implements ERO requalification training every 12 months. The proposed change in the ERO requalification training frequency for Calvert Cliffs would result in a change to the Emergency Plan. Section 6, Step I, Training provides a description regarding the ERO requalification training frequency.

Exelon proposes to modify the discussion to define the training frequency as: "once per calendar year not to exceed 18 months between training sessions," as described below.

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 3 of 13 Annual requalification training as applied to those personnel assigned Exelon ERO positions is defined as once per calendar year not to exceed 18 months between training sessions. The training program for members of the emergency organizations includes practical drills in which individuals demonstrate ability to perform assigned emergency functions. The training frequency for the practical drills is at least once every 2 years.

2.2 Nine Mile Point Nuclear Station Site Emergency Plan The Nine Mile Point Nuclear Station Site Emergency Plan provides the following frequency requirement for ERO training in Section 6.1 and Figure 6.2:

6. 1. 1 Training Emergency training includes, as appropriate:

c. Personnel assigned to the NMPNS ERO with specific emergency preparedness duties and responsibilities receive specialized training for their respective assignments. Station Annex Figure 6.2 delineates which personnel receive specialized training, the type of training and the required frequency of such training. This table is a summary of the requirements specified in EPMP-EPP-11, Emergency Preparedness Training Program.

Excerpts from Figure 6.2

2. Emergency Directors/ ERF Coordinators Involved Personnel (Tvpical)

Plant Manager; Managers of Operations, SMs, Initial responders, and others as designated Initial Training and Periodic Retraining Initial - Instruction on the scope, responsibilities, and function of the Emergency Plan and Implementing Procedures, including Incident Command System (JCS) concepts, position titles and terminology.

Periodic - On an annual basis. Review of any changes made since the last training period.

3. Personnel responsible for accident assessment and/or accident management Involved Personnel (Typical)

SM/Emergency Director and the Emergency Director at EOF, TSC, OSC and EOF Managers; and Alternates License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 4 of 13 Initial Training and Periodic Retraining Initial - Instruction on the NMPNS Emergency Plan and Implementing Procedures and Technical Support Guidelines germane to their particular assessment/management function, including Incident Command System

(/CS) concepts, position titles and terminology.

Periodic - Retraining will be on an annual basis and will include a review of the above material and any changes made since the last training period.

4. Radiological Monitoring /Analysis personnel Involved Personnel (Typical)

Radiation Management Supervisors, Radiation Protection Technicians, and others as designated Selected Radiation Protection personnel receive substantial training in radiation monitoring.

Initial Training and Periodic Retraining Initial - Training for personnel performing radiation monitoring and analysis duties will consist of instruction in the downwind and/or inplant radiation monitoring and sampling Implementing Procedures, including Incident Command System (/CS) concepts, position titles and terminology.

Periodic - Retraining will be on an annual basis with hands-on instrumentation usage including interpretation of results.

8. Communication Personnel Involved Personnel (Typical)

As designated Initial Training and Periodic Retraining Initial - Training shall consist of a review of appropriate Implementing Procedures, communications equipment and messages, including Incident Command System (/CS) concepts, position titles and terminology.

Periodic - Retraining will be conducted annually.

The Nine Mile Point Nuclear Station Emergency Plan currently states the ERO requalification training is "annual" for the site personnel assigned to ERO positions. The term annual is not specifically defined within the Emergency Plan; however, Nine Mile Point implements ERO requalification training every 12 months. The proposed change in the ERO requalification training frequency for Nine Mile Point would result in a change to the Emergency Plan. Figure 8.2 provides a description regarding the ERO requalification training frequency. Exelon proposes to modify the discussion to state the training frequency as: "once per calendar year not to exceed 18 months between training sessions," as described below.

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 5 of 13

2. Emergency Directors/ ERF Coordinators Initial Training and Periodic Retraining Periodic - Once per calendar year not to exceed 18 months between training sessions. Review of any changes made since the last training period.

3. Personnel responsible for accident assessment and/or accident management Initial Training and Periodic Retraining Periodic - Retraining will be once per calendar year not to exceed 18 months between training sessions and will include a review of the above material and any changes made since the last training period.

4. Radiological Monitoring /Analysis personnel Initial Training and Periodic Retraining Periodic - Retraining will be once per calendar year not to exceed 18 months between training sessions with hands-on instrumentation usage including interpretation of results.

8. Communication Personnel Initial Training and Periodic Retraining Periodic - Retraining will be conducted once per calendar year not to exceed 18 months between training sessions.

2.3 Ginna Station Nuclear Emergency Response Plan The Ginna Nuclear Emergency Response Plan provides the following frequency requirement for ERO Training in section 6.1.

6. 1 Training and Drills:

Training classes on the emergency plan shall be conducted annually(+/- 3 months) for all Ginna emergency response personnel who may actively participate in the radiation emergency plan. Details of the training programs are established in Exelon ERO Training and Qualification procedures. Training will include a demonstration of their ability to perform the functions to which they may be assigned by participating in a Drill or Exercise at least once every two years. During drills, on-the-spot corrections of erroneous performance may be made, followed by a critique or corrective action.

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 6 of 13 Ginna Station currently implements ERO requalification training annually(+/- 3 months) for all emergency response personnel. The proposed change in the ERO requalification training frequency for Ginna would result in a change to the Emergency Plan. Section 6.1, Training and Drills provides a description regarding the ERO requalification training frequency. Exelon proposes to modify the discussion to state the training frequency as: "once per calendar year not to exceed 18 months between training sessions," as described below.

6. 1 Training and Drills:

Training classes on the emergency plan shall be conducted BRR1:1ally (1/ 3 moRU:Js) once per calendar year not to exceed 18 months between training sessions for all Ginna emergency response personnel who may actively participate in the radiation emergency plan. Details of the training programs are established in Exelon ERO Training and Qualification procedures. Training will include a demonstration of their ability to perform the functions to which they may be assigned by participating in a Drill or Exercise at least once every two years. During drills, on-the-spot corrections of erroneous performance may be made, followed by a critique or corrective action.

3.0 TECHNICAL EVALUATION

Exelon proposes to revise the site Emergency Plan for the following facilities in order to establish a common annual ERO requalification training frequency for Exelon personnel assigned to ERO positions and to align the training frequency across the Exelon fleet.

• Calvert Cliffs Nuclear Power Plant

• Nine Mile Point Nuclear Station

• R.E. Ginna Nuclear Power Plant This constitutes a minor change which will allow application of common procedural guidance and administrative tracking tools throughout the Exelon fleet. This License Amendment Request (LAR) does not affect established training frequencies for non-Exelon Offsite Response Organizations (ORO) responders where Exelon may provide periodic training.

Exelon's Mid-Atlantic stations (i.e., Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station) and Midwest Stations (Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, and Quad Cities Nuclear Power Station) previously submitted License Amendment Requests (LARs) to revise their ERO training frequency (References 6.2, 6.3, and 6.4). These LARs requested approval to align the training frequency between those Exelon's stations to "once per calendar year not to exceed 18 months between training sessions." These LARs have been subsequently approved as noted in References 6.5 and 6.6.

The revised training frequency applies only to those personnel assigned to ERO positions. The change does not apply to training for the ORO provided by Exelon. This change also does not apply to training provided to Exelon personnel as part of their normal job specific duties (e.g.,

plant operations, maintenance, radiation protection, first aid, fire brigade).

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 7 of 13 From a business needs and resource perspective, there is a benefit to have all of Exelon's nuclear facilities perform ERO training under the same requirements. Exelon utilizes common procedures and programs to manage the Emergency Preparedness training program and having all of its stations under the same program would provide efficiency and simplicity in program administration.

Calvert Cliffs and Nine Mile Point Stations The ERO training frequency defined in the Calvert Cliffs and Nine Mile Point Emergency Plans is designated as "annual," but do not specifically define the term within the Emergency Plans. In practice, Calvert Cliffs and Nine Mile Point implement a training frequency of 12 months. As such, performance of ERO requalification training has been performed each year at nominally a one-year interval.

The current practice of performing a 12-month training frequency for ERO training introduces some hardships and unintended consequences which can complicate the scheduling of training.

For example, station maintenance outages or other major station events may require the ERO requalification cycle to be rescheduled (entirely or partially) either earlier or later within the year.

Considering some stations utilize four ERO teams and train over several weeks or months, this may introduce individual tracking and scheduling complications, particularly when individuals switch to other ERO teams. Qualifications are required to be closely monitored. The need for emergent or individual training is minimized with this proposed change. The monitoring of individual training becomes less burdensome by implementing a frequency of once per calendar year not to exceed 18 months between training sessions.

When the two frequencies for training requalification are compared over a period of several years, both methods result in the same number of training opportunities for the ERO personnel.

The proposed changes in the ERO requalification training frequency for Calvert Cliffs and Nine Mile Point would allow alignment with other Exelon Station ERO requalification training requirements. The flexibility to schedule training within the calendar year allows the Emergency Preparedness organizations to schedule around planned and emergent outages, operations training cycles, and other emergent station priorities. Additionally, the proposed change will add a clear definition to the term "annual" within the Emergency Plan as applied to ERO training .

Ginna Station The ERO training frequency defined in the Ginna Station Nuclear Emergency Response Plan is annually(+/- 3 months). As such, the grace period would not be additive, and as applied to the EP program, performance of ERO requalification training would be performed each year at nominally a one-year interval.

The current practice of utilizing a 25% grace period for annual ERO training introduces some hardships and unintended consequences which can complicate the scheduling of training. For example, station maintenance outages or other major station events may require the ERO requalification cycle to be rescheduled (entirely or partially) either earlier or later within the year.

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 8 of 13 Considering some stations utilize four ERO teams and train over several weeks or months, this may introduce individual tracking and scheduling complications, particularly when individuals switch to other ERO teams. Qualifications are required to be closely monitored. The need for emergent or individual training is minimized with this proposed change. The monitoring of individual training becomes less burdensome by implementing a frequency of once per calendar year not to exceed 18 months between training sessions.

When the two frequencies for training requalification are compared over a period of several years, both methods result in the same number of training opportunities for the ERO personnel, with the understanding that the allowed grace periods are not permitted to extend training intervals.

The proposed changes in the ERO requalification training frequency for Ginna would allow alignment with other Exelon Station ERO requalification training requirements. The flexibility to schedule training within the calendar year allows the Emergency Preparedness organizations to schedule around planned and emergent outages, operations training cycles, and other emergent station priorities.

Impact on Performance Indicators and Drill Participation The proposed revision to the training frequency would have no impact to NRC Performance Indicators (Pis). The NRC ERO Drill Participation performance indicator tracks the participation of ERO members assigned to fill key positions in performance enhancing experiences and through linkage to the Drill and Exercise Performance (DEP) indicator ensures that the risk significant aspects of classification, notification, and Protective Action Recommendation (PAR) development are evaluated and included in the Pl process. This indicator measures the percentage of ERO members assigned to fill key positions who have participated recently in performance-enhancing experiences such as drills, exercises, or in an actual event during the previous eight quarters, as measured on the last calendar day of the quarter.

The proposed revision to the annual training frequency is unrelated to drill participation requirements for the indicator. It does not impact the objective for key ERO members to have a performance-enhancing experience every eight quarters.

The proposed change in the ERO requalification training frequency for Exelon personnel assigned to ERO positions for the Exelon facilities noted in this submittal would result in consistency with other Midwest and Mid-Atlantic station ERO requalification training requirements as described in References 6.2, 6.3, and 6.4. The flexibility to schedule training within the calendar year as described allows the Emergency Preparedness organizations to schedule around planned and emergent outages, operations training cycles, and other emergent station priorities.

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 9 of 13

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

The criteria in 10 CFR 50.54(q) provides direction to licensees seeking to revise their Emergency Plans. The requirements related to nuclear power plant Emergency Plans are specified in the standards in 10 CFR 50.47, "Emergency plans," and the requirements of 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."

Planning Standard 10 CFR 50.47(b)(15) states that: "Radiological emergency response training is provided to those who may be called on to assist in an emergency." This is further discussed in NUREG-0654, Section 11.0, "Radiological Emergency Response Training," which states that:

"Each organization shall assure the training of appropriate individuals." More specifically, step 5 states: "Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities." The proposed change to the Emergency Plans for Calvert Cliffs Nuclear Power Plant, Nine Mile Point Nuclear Station, and R.E. Ginna Nuclear Power Plant reflect a change in frequency in how ERO requalification training is implemented at those affected Exelon facilities. Exelon has determined that the proposed change does not require any exemptions or relief from regulatory requirements and does not affect conformance with any 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," (GDC) differently than that described in the Updated Final Safety Analysis Reports (UFSARs) for each affected facility.

NRC Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011 (Reference 6.1 ), provides guidance concerning: 1) clarifying the meaning of a "decrease in effectiveness," as stated in 10 CFR 50.54(q); 2) clarifying the process for evaluating proposed changes to emergency plans; 3) providing a method for evaluating proposed changes to emergency plans; and 4) providing clarifying guidance on the appropriate content and format of applications submitted to the NRC for approval prior to implementation.

4.2 Precedent There is current precedent within the Exelon fleet supporting the proposed change. By letter dated October 30, 2013 (Reference 6.2), as supplemented by letter dated June 13, 2014 (Reference 6.3), Exelon submitted an amendment request to revise the ERO requalification training requirements specified in the Emergency Plans for Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station to include provisions that the training be conducted "once per calendar year not to exceed 18 months between training sessions." Additionally, by letter dated August 11, 2014 (Reference 6.4), Exelon submitted an amendment request to revise the ERO requalification training requirements specified in the Emergency Plans for Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, and Quad Cities Nuclear Power Station to include the same provisions that the training be conducted License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 10 of 13 "once per calendar year not to exceed 18 months between training sessions. These license amendment requests were subsequently approved by the NRC as noted in References 6.5 and 6.6.

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the Facility Operating Licenses (FOLs) listed below.

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318 Material License No. SNM-2505 Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220, 50-410, and 72-1036

• R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 Docket Nos. 50-244 and 72-67 Specifically, the proposed change would revise the Emergency Response Organization (ERO) requalification training frequency for Exelon personnel assigned ERO positions defined in the station Emergency Plans as "annual" to a frequency defined as "once per calendar year not to exceed 18 months between training sessions." The Emergency Plan is described in each station's Updated Final Safety Analysis Report (UFSAR). In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," Exelon requests NRC approval of the proposed changes to the Exelon Nuclear Radiological Emergency Plans for Calvert Cliffs Nuclear Power Plant, Nine Mile Point Nuclear Station, and R.E. Ginna Nuclear Power Plant.

The proposed change has been reviewed considering the applicable requirements of 10 CFR 50.47, 10 CFR 50, Appendix E, and other applicable NRC documents. Exelon has evaluated the proposed change to the affected sites' Emergency Plans and determined that the change does not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92, "Issuance of amendment," is provided below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change only affects the administrative aspects of the annual ERO requalification training frequency requirements and not the content of the training. The proposed change does not involve the modification of any plant equipment or affect plant License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 11 of 13 operation. The proposed change will have no impact on any safety-related Structures, Systems, or Components (SSC).

The proposed change would revise the ERO requalification frequency from an annual basis to once per calendar year not to exceed 18 months between training sessions as defined in the Exelon Nuclear Radiological Emergency Plans for the affected plants.

The proposed change is to align the Exelon fleet under one standard regarding the annual requalification training frequency of personnel assigned Exelon ERO positions.

Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected sites does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change has no impact on the design, function, or operation of any plant SSC. The proposed change does not affect plant equipment or accident analyses. The proposed change only affects the administrative aspects related to the annual ERO requalification training frequency requirements. There are no changes in the content of the training being proposed under this submittal. The proposed change is to align the Exelon fleet under one standard regarding the annual requalification training frequency of personnel assigned Exelon ERO positions.

Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected sites does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change only affects the administrative aspects of the annual ERO requalification training frequency requirements and does not change the training content.

The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by the proposed change to the frequency in the ERO requalification training requirements.

Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected sites does not involve a significant reduction in a margin of safety.

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 12 of 13 4.4 Conclusions In conclusion, based on the considerations discussed above: 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the Commission's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed change is applicable to emergency planning standards involving ERO requalification training requirements and does not reduce the capability to meet the emergency planning standards established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. In addition, the proposed change specifically relates to education, training, experience, qualification or other employment suitability requirements. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10 CFR 51.22(c)(3)(iv).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

6.0 REFERENCES

6.1 NRC Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011 6.2 Letter from James Barstow, Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission - License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel, dated October 30, 2013.

6.3 Letter from James Barstow, Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission - Supplemental Response to License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel, dated June 13, 2014.

6.4 Letter from James Barstow, Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission - License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel, dated August 11, 2014.

6.5 Letter from Joel S. Wiebe, U.S. Nuclear Regulatory Commission to Michael J. Pacilio, Exelon Generation Company, LLC - Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 1, 2 and 3; and Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendments Regarding the Emergency Plan Definition of Annual Training, dated December 24, 2014 (ML14226A940).

License Amendment Request Revise Emergency Plan Requalification Training Frequency Page 13 of 13 6.6 Letter from Joel S. Wiebe, U.S. Nuclear Regulatory Commission to Bryan C. Hanson, Exelon Generation Company, LLC - Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 1, 2, and 3; LaSalle County Station, Units 1 and 2; and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments Regarding the Emergency Plan Definition of Annual Training, dated April 8, 2015 (ML14323A522).

ATTACHMENT 2 Exelon Nuclear Radiological Emergency Plan Station Annex Mark-ups

CALVERT CLIFF NUCLEAR POWER PLANT EMERGENCY RESPONSE PLAN Markup of Emergency Plan Pages Pages cc 6-1

Exelon Confidential/Proprietary Calvert Cliffs Annex Exelon Nuclear Section 6: Maintaining Nuclear Emergency Preparedness 6.1 Trajning An integrated training program provides for and ensures initial, annual, and continuing training of appropriate individuals and groups involved in emergencies.

6.1.1 General Orientation General Employee Training describes the program that provides training to all persons having access to Calvert Cliffs Nuclear Power Plant and includes Emergency Plan indoctrination .

6.1.2 Emergency Personnel Plant procedures establish a training program for instructing personnel who implement radiological emergency plans. Specialized initial training, annual, and continuing training programs (including scope, nature and frequency) is provided for:

1. Directors or coordinators of response organizations.

2. Personnel responsible for accident assessment.

3. Radiological monitoring teams and radiological analysis personnel.

4 . Security and fire fighting personnel.

5. On-site repair and damage control/correctional action teams.

6 . First aid and rescue personnel. This training includes courses equivalent to or exceeding Red Cross Multi-Media.

7. Local support services personnel including Emergency ManagemenUEmergency Services personnel. Site specific training is provided to those off-site organizations who may be called upon to provide assistance.

8. Medical support personnel.

9. Recovery Organization personnel.

1O. Personnel responsible for transmission of emergency information instructions.

The training program for members of the emergency ~~tiGRs includes..

-0fi3'etltea-1n£tfl.f!s-ifl-Wflieh individuals demonstrate ability to perform assigflecl-netions. In the context of station ERO training for those individual itions, annually is defined as once evel)* 12 mol'tths-:

6.1.3 Public Annual requalification training as applied to those personnel assigned

1. Calvert Cliffs Exelon ERO positions is defined as once per calendar year not to exceed dissemination of 18 months between training ses sions. The training program for members what their actio of tf?e emergency organizations inclucles practical drills in which individuals not necessarily I demonstrate ability to pelform assigned emergency functions. The training

. . frequency for the practical drills is at least once every 2 years.

a. Educational lt-rTI::nTTRr<lr<:TrY-=rTrn:n:m:rm;:n-r.- - - - -- -- - - - - -- -- - ---'

b. Contact for additional information.

c. Protective measures, e.g., evacuation routes and reception centers, sheltering, respiratory protection, radioprotective drugs.

April 2015 cc 6- 1 EP-AA-1011 (Revision 0)

NINE MILE POINT NUCLEAR STATION SITE EMERGENCY PLAN Markup of Emergency Plan Pages Pages NM 6-11 NM 6-12

Exelon Confidential/Proprietary Nine Mile Point Annex FIGURE 6.2 \_,.Once per calendar year not to exceed INITIAL TRAINING AND PERIODIC RETRAINING*

<... 18 months between training sessions.

Emergency Response Categ_ory Involved Personnel (Typical) Initial Training and Periodic Retraini~

1.  !;_r:D.filQ.~!29'..P.!fill Persons granted unescorted access to the lniii_;;ij - Emergency Plan content and implementation, lriqQ£1rj_QS!tion Protected Area specifically: personal actions, warnings, assembly areas, use of station communications, personnel accountability and evacuation to an offsite assembly area.

2.  !;merge[l~QJr~ctornLERf' Plant Manager; Managers of Operations, SMs, lniti?.! - Instruction on the scope, responsibilities, and function of Coordinators Initial responders, and others as designated the Emergency Plan and Implementing Procedures, including Incident Command System (ICS) concepts, position titles and terminology.

Periodic - Review of any changes made sincethe las ra1 g pefl * * * - - -..* - - - - - - - - -

3. Personnel responsible ior SM/Emergency Director and the Emergency Initial - Instruction on the NMPNS Emergency Plan and accident assessment and/or Director at EOF, TSC, OSC and EOF Implementing Procedures and Technical Support Guidelines accide.!i Managers; and Alternates germane to their part;cular assessmenUmanagemenl function,

!I@nagemsint including Incident Command System (ICS} concepts, position

!itles and terminoiogy.

Period.!£ - Retraining will b*~~~~~~~~

a review of the above material and any c last training period.

4. Radiological Mo111tonng Rad1at1on Management Supervisors. Radiation Selected Radiation Protection personnel receive substantial

/Analv.si.§. personnel Protection Technicians, and others as training in radiation mo111toring.

designated Initial- Training for personnel performing radiation mo111toring and analysis duties will consist of instruction in the downwind and/or in plant radiation monitoring and sampling lrnplernentmg Procedures, including Incident Command System (JCS) concepts, position titles and terminology.

February 2015 NM6-11 EP-AA-1013 (Revision 0)

Exelon Confidential/Proprietary Nine Mile Point Annex Exelon Nuclear FIGURE 6.2 (Cont.)

INITIA L TRAINI NG AND PERIODIC RETRAINING' Emergency Response Category Involved Personnel (Typical) Initial Training and Penodic Retraining

5. Fire... Response /First NMPNS Fire Brigade/Offs1te Fire Departments Designated members will receive training as appropriate in basic Aid/Rescue/Medical Support Ambulance and Hospital Personnel patient care and treatment. Members will also be instructed on the availability of ons1te medical treatment supplies and equipment; communication systems, access controls radiological hazards. and roles, interfaces and responsibilities with iocal fire/

medical support personnel, including Incident Command System

(!CS) concepts, position titles and terminology.

6. Dam~Gontrol/Repair Teams Nuclear Operators, Nuclear Auxiliary Repair and Damage Control are considered a normal part of the personnel Operators, Maintenance Supervision. l&C job functions of the listed personnel and, as such, special Supervision, Radiation Protection Supervision training in these functions, other than appropriate emergency Selected Maintenance. l&C and Radiation plan and procedures training, is not required.

_ ....- -....- -..- - * - - * - - - - - - Protection Personnel. and others__a_s_d_e_s~ig._n_a_te_..d..__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

7 . Security Personnel/Local Law Security personnel assigned responsibilities for Training and retraining requirements are outlined in the Nine Enforcement Officials Emergency Plan function, and Local Law Mile Point Nuclear Security Training and Qualification Plan, Enforcement Officials. including Incident Command System {ICS) concepts, position

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - . . . ; t " ' i t l " ' - e s , and !~_io_~----------------

8. Communication Personnel As designated lni~<a! - Training shall consist of a review of appropriate Implementing Procedures, communications equipment and messages, including Incident Command System (ICSJ concepts.

pos;tion titles and terminology.

Periodic - Retraining will be conducted6J~ . .

~~~~-

once per calendar year not to exceed 18 months between training sessions.

~

February 2015 NM 6-12 EP-M-1013 (Revision 0)

R. E. GINNA NUCLEAR POWER PLANT NUCLEAR EMERGENCY RESPONSE PLAN Markup of Emergency Plan Pages GN 6-1

Exelon Confidential/Proprietary Ginna Annex Exelon Nuclear Section 6: Maintaining Nuclear Emergency Preparedness Formalized training program(s) have been established to ensure that all personnel who actively participate in the Nuclear Emergency Plan maintain their familiarity with the plan and their required response. A radiation emergency exercise shall be conducted at least annually, with emphasis placed upon orderly implementation of the emergency plan.

It is the Company management's expectation that responders will respond immediately upon being notified and not wait for additional time. This expectation is reinforced as part of the responder training.

Personnel trained for onsite response to a radiation emergency are part of the regular plant staff and are trained to specific responsibilities within the emergency organization.

Training is documented by the Manager, Emergency Preparedness and the Emergency Preparedness Staff. Any emergency plan work by consultants will be under the control of, and reviewed by, the Manager, Emergency Preparedness.

Exercises shall be evaluated by the Manager, Emergency Preparedness and reviewed by the Emergency Preparedness Station and Corporate Management, thereby assuring the effectiveness of the plan throughout the lifetime of the R. E. Ginna facility.

6.1 Training and Drills:

f rainin classes on the emer ency plan shall be condu~d~

o e er calendar y r no >foeeil between training sessions or in erge cy response personnel w o m e rtic1 te in the radiation emergency plan . Details of the training programs are established in Exelon ERO Training and Qualification procedure. Training will include a demonstration of their ability to perform the functions to which they may be assigned by participating in a Drill or Exercise at least once every two years. During drills, on-the-spot corrections of erroneous performance may be made, followed by a critique or corrective action.

Provisions must be made to start a drill or exercise between 6:00 p.m. and 4:00 a.m. at least once in every eight-year cycle. Some drills or exercises should be unannounced.

Specialized training will be provided for:

1. Technical Support Center assignees

2. Operations Support Center assignees

3. First Aid Teams

4. Offsite Monitoring Teams

5. Emergency Operations Facility personnel

6. Security personnel

7. local Emergency Support Services personnel

8. Fire Brigade personnel

9. Dose Assessment personnel

10. Core Damage Assessment personnel February 2015 GN 6-1 EP-AA-1012 (Revision 0)