Text

Transmittal of Radiological Emergency Implementing Procedure Revisions
	ML16039A303
Person / Time
Site:	Calvert Cliffs, Nine Mile Point, Ginna, 07201036
Issue date:	01/26/2016
From:	David Gudger; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML16039A309	List: ML16039A303;
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	Download: ML16039A303 (11)
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Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 Attachments 3 through 13 contain Exelon Confidential/Proprietary Information; upon separation this cover letter and Attachments 1 and 2 are decontrolled.

Exelon Generation 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)

January 26, 2016 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 NRG Docket Nos. 50-317 and 50-318 Calvert Cliffs Independent Spent Fuel Storage Installation Materials License No. SNM-2505 NRG Docket No. 72-8 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRG Docket Nos. 50-220, 50-410, and 72-1036 R.E. Ginna Nuclear Power Station Renewed Facility Operating License No. DPR-18 NRG Docket Nos. 50-244 and 72-67

Subject:

Exelon Nuclear Radiological Emergency Implementing Procedure Revisions In accordance with 10 CFR 50.4(b)(5), "Emergency plan and related submissions," Exelon Generation Company, LLC (EGC) is submitting the Emergency Plan implementing procedure revisions identified in the table below for Calvert Cliffs Nuclear Power Plants (Calvert Cliffs),

Nine Mile Point Nuclear Station (NMP), and R.E. Ginna Nuclear Power Station (Ginna).

I Procedure No. Revision" Title I I I 0

Calvert Cliffs, Nine Mile Point, and Ginna EP-AA-112-1 OO-F-50 D Shift Emergency Director Checklist (CNG)

EP-AA-112-1 OO-F-51 c Shift Communicator Checklist (CNG)

EP-AA-112-1 OO-F-54 B Security Shift Supervisor Checklist (CNG)

EP-AA-112-1 OO-F-57 B ERONS Notification Details (CNG)

EP-AA-112-200-F-61 B Security Coordinator Checklist (CNG)

EP-AA-112-400-F-50 c Corporate Emergency Director Checklist (CNG)

Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 Attachments 3 through 13 contain Exelon Confidential/Proprietary Information; upon separation this cover letter and Attachments 1 and 2 are decontrolled.

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revisions January 26, 2016 Page 2 Procedure No. Revision Title EP-AA-112-400-F-54 c EOF Logistics Manager (CNG)

EP-AA-122-1 OO-F-22 B ERONS Activation for Call In and Drive In Drills EP-CE-114-100 2 Emergency Notifications Nine Mile Point (only)

EP-CE-113-F-03 c NMP Evacuation, Assembly and Accountability Calvert Cliffs (only)

ERPIP-3.0 05900 Immediate Actions The changes to the Emergency Plan implementing procedures were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plans for Calvert Cliffs, NMP, and Ginna. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50.4(b)(5). The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

Furthermore, Attachments 3 through 13 of this letter are proprietary and confidential and contain trade secrets and commercial or financial information. EGC maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that Attachments 3 through 13 be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4), and has attached an affidavit for this purpose (Attachment 2). However, if the NRC intends to place any of this information in the Public Document Room or on the Agencywide Documents Access and Management System or produce it in response to a Freedom of Information Act (FOIA) request, EGC requests the opportunity to redact the materials consistent with established FOIA exemptions and precedent.

In addition, as required by 10 CFR 50.54(q)(5), this submittal includes a summary analysis of the changes to the Emergency Plan implementing procedure (Attachment 1).

This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

A copy of the revised procedures and supporting change summary analysis are included in the attachments to this letter.

There are no regulatory commitments in this submittal.

If you have any questions or require additional information, please contact Richard Gropp at (610) 765-5557.

R ~i7tfully:_

1 ..

~~.;) r #olr--'

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revisions January 26, 2016 Page 3 Attachments:

1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis

2. Affidavit

3. EP-AA-112-100-F-50, Revision D, "Shift Emergency Director Checklist (CNG)"

4. EP-AA-112-1 OO-F-51, Revision C, "Shift Communicator Checklist (CNG)"

5. EP-AA-112-1 OO-F-54, Revision B, "Security Shift Supervisor Checklist (CNG)"

6. EP-AA-112-100-F-57, Revision B, "ERONS Notification Details (CNG)"

7. EP-AA-112-200-F-61, Revision B, "Security Coordinator Checklist (CNG)"

8. EP-AA-112-400-F-50, Revision C, "Corporate Emergency Director Checklist (CNG)"

9. EP-AA-112-400-F-54, Revision C, "EOF Logistics Manager (CNG)"

10. EP-AA-122-1 OO-F-22, Revision B, "ERONS Activation for Call In and Drive In Drills"

11. EP-CE-114-100, Revision 2, "Emergency Notifications"

12. EP-CE-113-F-03, Revision C, "NMP Evacuation, Assembly and Accountability"

13. ERPIP-3.0, Revision 05900, "Immediate Actions" cc: w/ Attachments 1 and 2 only Regional Administrator - NRG Region I Director, NRG Division of Spent Fuel Storage and Transportation, ONMSS NRG Senior Resident Inspector - Calvert Cliffs Nuclear Power Station NRG Senior Resident Inspector - Nine Mile Point Nuclear Station*

NRG Senior Resident Inspector- R.E. Ginna Nuclear Power Station NRG Project Manager, NRR - Calvert Cliffs Nuclear Power Station NRG Project Manager, NRR - Nine Mile Point Nuclear Station NRG Project Manager, NRR - R. E. Ginna Nuclear Power Station S. T. Gray, State of Maryland A. L. Peterson, NYSERDA

ATTACHMENT 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis

Attachment 1 Page 1 of 3 1o CFR 50.54(g)(5) Procedure Change Summary Analysis I. ProceduresfTitles Exelon Generation Company, LLC (EGC) is submitting the following Emergency Plan implementing procedure/form revisions for Calvert Cliffs Nuclear Power Station (Calvert Cliffs), Nine Mile Point Nuclear Station (NMP), and R.E. Ginna Nuclear Power Station (Ginna):

EP-AA-112-1 OO-F-50, Revision D, "Shift Emergency Director Checklist (CNG)"

EP-AA-112-1 OO-F-51, Revision C, "Shift Communicator Checklist (CNG)"

EP-AA-112-1 OO-F-54, Revision B, "Security Shift Supervisor Checklist (CNG)"

EP-AA-112-100-F-57, Revision B, "ERONS Notification Details (CNG)"

EP-AA-112-400-F-50, Revision C, "Corporate Emergency Director Checklist (CNG)"

EP-AA-122-100-F-22, Revision B, "ERONS Activation for Call In and Drive In Drills"

EP-CE-114-100, Revision 2, "Emergency Notifications" These Emergency Plan implementing procedure/form revisions contain Exelon Confidential/Proprietary Information and EGC is requesting that they be withheld from public disclosure pursuant to 10 CFR 2.390.

Description of Procedures The Emergency Plan implementing procedure/form revisions identified above for Calvert Cliffs, NMP, and Ginna provide guidance to aid Emergency Response Organization (ERO) personnel located in various Emergency Response Facilities (ERFs) in responding to an emergency at the sites.

Description of Changes These documents have been revised to replace Notifind (ERO call-out system) instructions and references with Everbridge instructions and references.

Description of How the Changes Still Comply with Regulations The revised documents continue to satisfy the applicable Emergency Planning requirements established in 10 CFR 50.47(b)(5) and (6) and 10 CFR 50, Appendix E, Sections Vl.D and VI.I, as well as the Program Element guidance of NUREG-0654, Sections 11.E and 11.F.

The changes made to update the notification system references and instructions do not alter the assigned responsibilities and functions and do not result in a reduction of effectiveness of the Emergency Plans for CCNPP, NMP and Ginna.

Description of Why the Changes are Not a Reduction in Effectiveness CRIE)

The revised documents remain consistent with the requirements of the Emergency Planning requirements specified in in 10 CFR 50.47(b}(5} and (6) and 10 CFR 50, Appendix E, Sections Vl.D and VI.I, as well as the Program Element guidance of NUREG-0654, Sections 11.E and 11.F. The revised documents do not alter the capability of the ERO to implement required Emergency Plan functions, and do not affect the timeliness of the performance of

Attachment 1 Page 2 of 3 these functions. Therefore, the changes do not result in a reduction in the effectiveness of the Emergency Plans for CCNPP, NMP and Ginna.

II. Procedures!Titles EGC is submitting the following Emergency Plan implementing procedures/forms for Calvert Cliffs, Nine Mile Point, and Ginna:

EP-AA-112-200-F-61, Revision B, "Security Coordinator Checklist (CNG)"

EP-AA-112-400-F-54, Revision C, "EOF Logistics Manager (CNG)"

Nine Mile Point (only)

EP-CE-113-F-03, Revision C, "NMP Evacuation, Assembly and Accountability" These procedures/forms contain Exelon Confidential/Proprietary Information and EGC is

requesting that they be withheld from public disclosure pursuant to 10 CFR 2.390.

Description of Procedures The Emergency Plan implementing procedures/forms cited above for Calvert Cliffs, Nine Mile Point, and Ginna provide guidance to aid ERO personnel located in various ERFs in responding to an emergency at the sites.

Description of Changes These documents were revised to update references for a procedure that had been superseded.

Description of How the Changes Still Complies with Regulations The revision to the procedures/forms continue to satisfy the applicable Emergency Planning requirements established in 10 CFR 50.47(b)(2) and (10), as well as the Program Element guidance of NUREG-0654, Sections 11.B and 11.J.

The changes made to update references in the procedures/forms do not alter the assigned responsibilities and functions and do not result in a reduction of effectiveness of the Emergency Plans for CCNPP, NMP and Ginna.

Description of Why the Changes are Not a Reduction in Effectiveness CRIE)

The revised procedures/forms remain consistent with the requirements of the Emergency Planning requirements specified in 10 CFR 50.47(b)(2) and (10), as well as the Program Element guidance of NUREG-0654, Sections 11.B and 11.J. The revisions to these documents do not alter the capability of the ERO to implement required Emergency Plan functions, and do not affect the timeliness of the performance of these functions. Therefore, the changes to these procedures do not result in a reduction in the effectiveness of the Emergency Plans for Calvert Cliffs, Nine Mile Point, and Ginna.

Attachment 1 Page 3 of 3 Ill. Procedure!Title EGG is submitting the following Emergency Plan implementing procedure revision for Calvert Cliffs:

ERPIP-3.0, Revision 05900, "Immediate Actions" This procedure contains Security-Related (SUNS/) and Exelon Confidential/Proprietary Information and EGG is requesting that it be withheld from public disclosure pursuant to 10 CFR 2.390.

Description of Procedure The Emergency Plan implementing procedure above for Calvert Cliffs provides guidance to aid the Shift Emergency Director during a Security Event.

Description of Changes This procedure was revised to replace Notifind (ERO call-out system) instructions and references with Everbridge instructions .

. Description of How the Change Still Complies with Regulations The revision to the procedure continues to satisfy the applicable Emergency Planning requirements established in 10 CFR 50.47(b)(6) as well as the Program Element guidance of NUREG-0654, Section 11.F.

The change made to update the notification system references and instructions do not alter the assigned responsibilities and functions and does not result in a reduction of effectiveness of the Emergency Plan for Calvert Cliffs.

Description of Why the Change is Not a Reduction in Effectiveness (RIE)

The revised procedure remains consistent with the requirements of the Emergency Planning requirements specified in 10 CFR 50.47(b)(6), as well as the Program Element guidance of NUREG-0654, Section 11.F. This revision to the procedure does not alter the capability of the ERO to implement required Emergency Plan functions, and does not affect the timeliness of the performance of these functions. Therefore, the change to the procedure does not result in a reduction in the effectiveness of the Emergency Plan for Calvert Cliffs.

ATTACHMENT 2 Radiological Emergency Plan Implementing Procedure Revision Affidavit

AFFIDAVIT OF DAVID T. GUDGER DOCKET NOS. 50-317, 50-318, 72-8, 50-220, 50-410, 72-1036, 50-244, and 72-67 I, David T. Gudger, Manager, Licensing and Regulatory Affairs, Exelon Generation Company, LLC, do hereby affirm and state:

1. I am Manager, Licensing and Regulatory Affairs for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf of EGC.

2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission

("NRC"):

EP-AA-112-100-F-50, Revision D, "Shift Emergency Director Checklist (CNG)"

EP-AA-112-100-F-51, Revision C, "Shift Communicator Checklist (CNG)"

EP-AA-112-100-F-54, Revision B, "Security Shift Supervisor Checklist (CNG)"

EP-AA-112-100-F-57, Revision B, "ERONS Notification Details (CNG)"

EP-AA-112-200-F-61, Revision B, "Security Coordinator Checklist (CNG)"

EP-AA-112-400-F-50, Revision C, "Corporate Emergency Director Checklist (CNG)"

EP-AA-112-400-F-54, Revision C, "EOF Logistics Manager (CNG)"

EP-AA-122-100-F-22, Revision B, "ERONS Activation for Call In and Drive In Drills"

EP-CE-114-100, Revision 2, "Emergency Notifications"

EP-CE-113-F~03, Revision C, NMP Evacuation, Assembly and Accountability

ERPIP-3.0, Revision 05900, "Immediate Actions"

3. I am also authorized to apply to the NRC for the withholding of the aforementioned documents from public disclosure under 10 C.F.R. §§ 2.390(a)(4) and 9.17(a)(4) on the grounds that the documents contain privileged or confidential or proprietary commercial information. The documents EGC seeks to withhold from public disclosure have been marked "Proprietary" and are summarized in the attachment to my Affidavit.

4. On behalf of EGC, I request that the documents marked by EGC as "Proprietary" and described in the attached list (Appendix 1) be withheld, in their entirety, by the NRC from public disclosure.

5. In making this application for withholding of proprietary and confidential information of which EGC is the owner, EGC relies on 10 C.F.R. § 2.390(a)(4) and 10 C.F.R. 9.17(a)(4). The proprietary documents contain privileged or confidential or proprietary commercial information.

Page 1of2 Attachment 2

6. The proprietary information described in Appendix 1 should be withheld from disclosure by the NRC pursuant to the policy reflected in 10 C.F.R. § 2.390(a)(4), and for the following reasons to be considered pursuant to 10 CFR § 2.390(b)(4):

L. The documents are each either a policy, procedure, process, technical requirements document, or other document that forms part of the Exelon Nuclear Management Model ("ENMM").

11. The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business. It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM. EGC derives economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC' s sale or licensing of the ENMM.

iii. The documents are now, and have been, held in confidence by EGC. EGC does not customarily make these documents available to the public. EGC has not authorized making the documents available through public sources.

iv. EGC is providing the NRC with the documents and information in confidence.

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.

7. EGC requests that each of the documents listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v.

I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information, and belief.

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Date: January 26, 2015 Page 2 of2 Attachment 2

Attachment 2 Appendix 1 Page 1of1 Appendix 1: Information that Should Be Withheld from Public Disclosure Description of '

Date or Revision Reason( s) to Withhold Document * ** . ,' ',>

~ .. .. * *.

Revision D EP-AA-112-100-F-50 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision C EP-AA-112-100-F-51 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision B EP-AA-112-100-F-54 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision B EP-AA-112-100-F-57 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision B EP-AA-112-200-F-61 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision C EP-AA-112-400-F-50 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision C EP-AA-112-400-F-54 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision B EP-AA-122-100-F-22 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision 2 EP-CE-114-100 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision C EP-CE-113-F-03 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Revision 05900 ERPIP-3.0 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.