ML16053A259

Transmittal of Exelon Radiological Emergency Plan Implementing Procedure Revision

ML16053A259
Person / Time
Site:	Calvert Cliffs
Issue date:	02/11/2016
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML16053A159	List: ML16053A259
References
ERPIP-3.0, Rev. 05901
Download: ML16053A259 (8)

Text

Security-Related and Exelon Confidential/Proprietary Information Withhold Under 10 CFR 2.390 Attachment 3 contains Security-Related and 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)

February 11, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Reriewed 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 NRC Docket No. 72-8

Subject:

Exelon Radiological Emergency Plan Implementing Procedure Revision 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 revision identified in the table below for Calvert Cliffs Nuclear Power Plants (Calvert Cliffs).

Procedure No. Revision Title ERPIP-3.0 05901 Immediate Actions The changes to the Emergency Plan implementing procedure cited 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 Plan for Calvert Cliffs. 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, Attachment 3 of this letter is proprietary and confidential and contains trade secrets and commercial or financial information. EGG maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that Attachment 3 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. The procedure included Security-Related and Exelon Confidential/Proprietary Information Withhold Under 10 CFR 2.390 .I/)

Attachment 3 contains Security-Related and Exelon Confidential/Proprietary Information; /.} ~ /../- /_

upon separation this cover letter and Attachments 1 and 2 are decontrolled. I' 51-Lf' tJ tv'I s

"'~~?']

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision February '11, 2016 Page 2 materials consistent with established FOIA exemptions and precedent. The procedure included in Attachment 2 also contains SUNS/ Security-Related Information and the pages have been marked "Security-Related Information - Withhold Under 10 CFR 2.390, "as appropriate.

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 procedures (Attachment 1).

This submitta[ 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 Emergency Plan implementing procedures and supporting change summary analysis are included in the cited 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.

Respenu11y, I

~c-J T ~ Jyu---

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis

2. Affidavit

3. ERPIP-3.0, Revision 05901, "Immediate Actions" (SUNSI) cc: w/ Attachments 1 and 2 only Regional Administrator - NRC Region I Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRG Senior Resident Inspector - Calvert Cliffs Nuclear Power Station NRG Project Manager, NRR - Calvert Cliffs Nuclear Power Station S. T. Gray, State of Maryland

ATTACHMENT 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1of1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Procedures/Titles Exelon Generation Company, LLC (EGC) is submitting the following Emergency Plan implementing procedure revision for Calvert Cliffs Nuclear Power Plant (Calvert Cliffs):

• ERPIP-3.0, Revision 05091, "Immediate Actions" This procedure contains Security-Related (SUNS/) and Exelon Confidential/Proprietary Information and EGC is requesting that the procedure be withheld from public disclosure pursuant to 10 CFR 2.390.

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

Description of Changes This procedure was revised to update the contact information and guidance in the event site medical cannot be reached during a personnel emergency. The changes are considered administrative in nature.

Description of How the Changes Still Complies with Regulations The revision to the procedure continues to satisfy the applicable Emergency Planning requirements established in 10 CFR 50.54(b)(10) as well as the Program Element guidance of NUREG-0654, Section 11.J.

The change to update the contact information and guidance in the event site medical cannot be reached during a personnel emergency does 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 Changes are Not a Reduction in Effectiveness (RIE)

The revised procedure remains consistent with the requirements of the Emergency Planning requirements specified in 10 CFR 50.54(b)(10) as well as the Program Element guidance of NUREG-0654, Section 11.J. This revision to the procedure does not alter the capability of the Emergency Response Organization (ERO) to implement required Emergency Plan functions, and does not affect the timeliness of the performance of these functions. Therefore, the change does not result in a reduction in the effectiveness of the Emergency Plan for Calvert Cliffs.

ATTACHMENT 2 Affidavit Radiological Emergency Plan Implementing Procedure Revision

AFFIDAVIT OF DAVID T. GUDGER DOCKET NOS. 50-317, 50-318, and 72-8 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"):

• ERPIP-3.0, Revision 05901, "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 document 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.

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):

i.. 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.

Page 1of2 Attachment 2

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 the document 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: February 11, 2016 Page 2 of2 Attachment 2

Attachment 2 Appendix 1 Page 1of1 Appendix 1: Information that Should Be Withheld from Public Disclosure Date or Revision Description of Document Reason(s) to Withhold Revision 05901 ERPIP-3.0 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.l 7(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Security-Related and Exelon Confidential/Proprietary Information Withhold Under 10 CFR 2.390 Attachment 3 contains Security-Related and 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)

February 11, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Reriewed 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 NRC Docket No. 72-8

Subject:

Exelon Radiological Emergency Plan Implementing Procedure Revision 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 revision identified in the table below for Calvert Cliffs Nuclear Power Plants (Calvert Cliffs).

Procedure No. Revision Title ERPIP-3.0 05901 Immediate Actions The changes to the Emergency Plan implementing procedure cited 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 Plan for Calvert Cliffs. 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, Attachment 3 of this letter is proprietary and confidential and contains trade secrets and commercial or financial information. EGG maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that Attachment 3 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. The procedure included Security-Related and Exelon Confidential/Proprietary Information Withhold Under 10 CFR 2.390 .I/)

Attachment 3 contains Security-Related and Exelon Confidential/Proprietary Information; /.} ~ /../- /_

upon separation this cover letter and Attachments 1 and 2 are decontrolled. I' 51-Lf' tJ tv'I s

"'~~?']

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision February '11, 2016 Page 2 materials consistent with established FOIA exemptions and precedent. The procedure included in Attachment 2 also contains SUNS/ Security-Related Information and the pages have been marked "Security-Related Information - Withhold Under 10 CFR 2.390, "as appropriate.

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 procedures (Attachment 1).

This submitta[ 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 Emergency Plan implementing procedures and supporting change summary analysis are included in the cited 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.

Respenu11y, I

~c-J T ~ Jyu---

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis

2. Affidavit

3. ERPIP-3.0, Revision 05901, "Immediate Actions" (SUNSI) cc: w/ Attachments 1 and 2 only Regional Administrator - NRC Region I Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRG Senior Resident Inspector - Calvert Cliffs Nuclear Power Station NRG Project Manager, NRR - Calvert Cliffs Nuclear Power Station S. T. Gray, State of Maryland

ATTACHMENT 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1of1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Procedures/Titles Exelon Generation Company, LLC (EGC) is submitting the following Emergency Plan implementing procedure revision for Calvert Cliffs Nuclear Power Plant (Calvert Cliffs):

• ERPIP-3.0, Revision 05091, "Immediate Actions" This procedure contains Security-Related (SUNS/) and Exelon Confidential/Proprietary Information and EGC is requesting that the procedure be withheld from public disclosure pursuant to 10 CFR 2.390.

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

Description of Changes This procedure was revised to update the contact information and guidance in the event site medical cannot be reached during a personnel emergency. The changes are considered administrative in nature.

Description of How the Changes Still Complies with Regulations The revision to the procedure continues to satisfy the applicable Emergency Planning requirements established in 10 CFR 50.54(b)(10) as well as the Program Element guidance of NUREG-0654, Section 11.J.

The change to update the contact information and guidance in the event site medical cannot be reached during a personnel emergency does 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 Changes are Not a Reduction in Effectiveness (RIE)

The revised procedure remains consistent with the requirements of the Emergency Planning requirements specified in 10 CFR 50.54(b)(10) as well as the Program Element guidance of NUREG-0654, Section 11.J. This revision to the procedure does not alter the capability of the Emergency Response Organization (ERO) to implement required Emergency Plan functions, and does not affect the timeliness of the performance of these functions. Therefore, the change does not result in a reduction in the effectiveness of the Emergency Plan for Calvert Cliffs.

ATTACHMENT 2 Affidavit Radiological Emergency Plan Implementing Procedure Revision

AFFIDAVIT OF DAVID T. GUDGER DOCKET NOS. 50-317, 50-318, and 72-8 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"):

• ERPIP-3.0, Revision 05901, "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 document 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.

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):

i.. 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.

Page 1of2 Attachment 2

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 the document 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: February 11, 2016 Page 2 of2 Attachment 2

Attachment 2 Appendix 1 Page 1of1 Appendix 1: Information that Should Be Withheld from Public Disclosure Date or Revision Description of Document Reason(s) to Withhold Revision 05901 ERPIP-3.0 Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.l 7(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.