ML16075A329

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OEDO-16-00165 - Briefing Package for Drop-In Visit on March 23, 2016, by Senior Management of Exelon Generation Company, LLC with the NRC Executive Director for Operations
ML16075A329
Person / Time
Site: Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Oyster Creek, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, LaSalle
Issue date: 03/16/2016
From: Justin Poole
Plant Licensing Branch III
To: Theresa Clark
NRC/EDO
Poole J, NRR/DORL/LPLIII-2
References
CAC A11008, NRC-2017-000292, OEDO-16-00165
Download: ML16075A329 (23)
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Text

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION March 16, 2016 MEMORANDUM TO: Theresa Clark Executive Technical Assistant Office of Executive Director for Operations FROM: Justin C. Poole, Acting Chief /RA/

Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

OEDO-16-00165 - BRIEFING PACKAGE FOR DROP-IN VISIT ON MARCH 23, 2016, BY SENIOR MANAGEMENT OF EXELON GENERATION COMPANY, LLC WITH THE EXECUTIVE DIRECTOR FOR OPERATIONS Enclosed is the briefing package in support of the March 23, 2016, drop-in visit by senior management of Exelon Generation Company, LLC (Exelon) with the Executive Director for Operations. Please contact Blake Purnell at 301-415-1380 if you need any additional information.

Docket Nos. 50-456, 50-457, 50-454, 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-244, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-219, 50-277, 50-278, 50-254, 50-265, and 50-289

Enclosure:

Briefing Package cc w/encl:

W. Dean, NRR M. Evans, NRR J. Lubinski, NRR A. Boland, NRR P. Krohn, NRR G. Wilson, NRR T. Tate, NRR D. Broaddus, NRR A. Dimitriadis, RGN I D. Schroeder, RGN I S. Kennedy, RGN I K. Stoedter, RGN III E. Duncan, RGN III J. Cameron, RGN III M. Kunowski, RGN III J. Poole, NRR C. Scott, OGC T. Inverso, EDO E. Benner, NRR S. Koenick, NRR OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

ML16075A329 Package: ML16074A446 OFFICE NRR/DORL/LPL3-2/PM NRR/DORL/LPL3-2/LA NRR/DORL/LPL3-2/BC (A)

NAME BPurnell SRohrer(JBurkhardt for) JPoole DATE 03/16/16 03/16/16 03/16/16 OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION MEMORANDUM TO: THERESA CLARK RE: OEDO-16-00165 - BRIEFING PACKAGE FOR DROP-IN VISIT ON MARCH 23, 2016, BY SENIOR MANAGEMENT OF EXELON GENERATION COMPANY, LLC WITH THE EXECUTIVE DIRECTOR FOR OPERATIONS DATED MARCH 16, 2016 DISTRIBUTION: OEDO-16-00165 NON-PUBLIC LPL3-2 r/f RidsEdoMailCenter Resource RidsNrrDeEicb Resource RidsNrrDorl Resource RidsNrrDorlLpl1-1 Resource RidsNrrDorlLpl1-2 Resource RidsNrrDorlLpl3-2 Resource RidsNrrDorlLpl4-2 Resource RidsNrrDpr Resource RidsNrrDprPgcb Resource RidsNrrDprPspb Resource RidsNrrDprPrab Resource RidsNrrDra Resource RidsNrrDraAphb Resource RidsNrrDraApla Resource RidsNrrLASRohrer Resource RidsNrrMailCenter Resource RidsNrrOd Resource RidsNrrPMBraidwood Resource RidsNrrPMByron Resource RidsNrrPMCalvertCliffs Resource RidsNrrPMClinton Resource RidsNrrPMDresden Resource RidsNrrPMExelon Resource RidsNrrPMREGinna Resource RidsNrrPMLaSalle Resource RidsNrrPMLimerick Resource RidsNrrPMNineMilePoint Resource RidsNrrPMOysterCreek Resource RidsNrrPMPeachBottom Resource RidsNrrPMQuadCities Resource RidsNrrPMThreeMileIsland Resource RidsRgn1MailCenter Resource RidsRgn3MailCenter Resource OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION BRIEFING PACKAGE Drop-In Visit by Exelon Generation Company, LLC March 23, 2016 ADAMS Accession No. ML16075A329 OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION CONTENTS Page Number AGENDA ........................................................................................................................ 1 FACILITY DATA AND PERFORMANCE Current Issues .................................................................................................... 2 MANAGEMENT DATA Exelon Generation Company, LLC ................................................................ 11 Facility Organization ........................................................................................ 12 Biographical Data of Principal Managers ...................................................... 15 OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION Drop-In Visit Agenda March 23, 2016 ITINERARY TIME PERSON VISITED CONTACT PERSON EXTENSION 0930 Victor McCree, EDO Patti Sprogeris 301-415-1713 VISITORS REPRESENTING EXELON GENERATION COMPANY, LLC

  • Bryan Hanson, Senior Vice President Exelon Generation, President and Chief Nuclear Officer, Exelon Nuclear
  • Scot Greenlee, Senior Vice President, Engineering and Technical Services
  • Brad Fewell, Senior Vice President, Regulatory Affairs and General Counsel
  • Keith Jury, Vice President, Licensing and Regulatory Affairs TOPICS OF DISCUSSION
  • Risk-Informed Approach to Regulation
  • Delivering the Nuclear Promise - Industry Initiative
  • Generic Issue Resolution
  • Open-Phase Condition
  • Accident Tolerant Fuel OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION CURRENT ISSUES A. EXPECTED DISCUSSION TOPICS A.1 Risk-Informed Approach to Regulation A.1.1 Crediting Mitigating Strategies (MS)/FLEX
  • Licensees have installed new equipment and developed procedures to address Commission Orders to deal with beyond-design-basis events.
  • Both the U.S. Nuclear Regulatory Commissions (NRCs) and industrys Risk-Informed Steering Committees identified that ability to credit MS/FLEX in risk-informed decision-making (RIDM) is a high priority.
  • NRC staff have identified ten RIDM processes where MS/FLEX may be credited:

o Risk-Informed License Amendment Requests o Mitigating Systems Performance Indicators o Maintenance Rule - Section 50.65(a)(4) of Title 10 of the Code of Federal Regulations (10 CFR) o Accident Sequence Precursor Program o Generic Issue Resolution o Rulemaking - Regulatory Analysis o Significance Determination Process o Notices of Enforcement Discretion (NOEDs) o Incident Response (Management Directive (MD) 8.3, NRC Incident Investigation Program)

  • NRC has held a large number of meetings and reviewed two white papers that the industry has prepared during the last 6 months:

o Held internal NRC stakeholder workshop (November 13, 2015) o Met with staff and management in the NRC Office of Research, Office of Nuclear Reactor Regulation (NRR), and Office of New Reactors who support RIDM (November 2015) o Received industry white papers (December 2, 2015) o Held public meeting (December 9, 2015) o Received NRC staff comments on white papers (December/January) o Held public call with the Nuclear Energy Institute (NEI) (January 21, 2016) o Transmitted comments to NEI (February 8, 2016) o Public Risk-Informed Steering Committee meeting (February 9, 2016) o Held public meeting with NEI to discuss comments on white papers (March 16, 2016)

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

  • NRC will develop internal guidance to supplement NEI white-papers.
  • Initial focus will be on the following four areas:

o Significance Determination Process o NOED Process o Maintenance Rule (50.65(a)(4))

o Qualitative Inputs to Risk-Informed Licensing Process Challenges

  • Staff has no access to reliability data of MS/FLEX equipment. The Electric Power Research Institute has an initiative underway to address this challenge.

Conservative screening values will be used until better data becomes available.

  • Human reliability methods have to be developed to estimate human error probability of operator actions that implement MS/FLEX. Screening values will be used until better methods/data becomes available.

A.1.2 10 CFR 50.46c

  • The proposed 10 CFR 50.46c rule contains an optional provision allowing for risk-informed treatment of debris. The risk-informed option received significant industry and stakeholder input through public comment as well as a numerous public meetings. This input was thoroughly considered and incorporated in the development of the final risk-informed option. The disposition of public comment responses is included with the final rulemaking package.
  • The final 50.46c rule was just sent to the Commission (signed by EDO March 16, 2016).
  • The implementation guidance for this portion of the rule (Regulatory Guide (RG) 1.229) completed inter-office concurrence and Office of the General Counsel (OGC) legal review in February 2016.

A.1.3 Digital Instrumentation and Controls (DI&C)

DI&C Integrated Action Plan

  • In Staff Requirements Memorandum (SRM) for SECY-15-0106,1 the Commission disapproved the NRC staffs recommendation to publish for comment in the Federal Register the proposed rule: Incorporation by Reference of Institute of 1

Agencywide Documents Access and Management System (ADAMS) Accession No. ML16056A614.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION Electrical and Electronics Engineers (IEEE) Standard 603-2009, IEEE Standard Criteria for Safety Systems for Nuclear Power Generating Stations.

  • Following the SRM, the NRC took prompt action to develop an integrated strategy to modernize the NRCs DI&C regulatory infrastructure. The DI&C Integrated Action Plan will modify the DI&C licensing and oversight framework in a manner that maintains safety and that increases efficiency, supports a more risk-informed/performance-based approach where appropriate, and improves regulatory effectiveness and predictability.
  • This integrated plan presents the specific topical challenges to be addressed, along with a proposed plan for resolving each topic. Each plan identifies the expected outcome of each issue resolution.
  • The development of the NRCs DI&C Integrated Action Plan will be consistent with the requirements of SRM for SECY-15-0106: (1) DI&C safety requirements should be technology neutral, (2) new or revised requirements should be performance-based, (3) there should be the same regulatory requirements for new and operating reactors, and (4) the requirements should not pose an unnecessary impediment to advancement in nuclear applications of digital technology.

Use of 10 CFR 50.59 for DI&C

  • The NRC and NEI have identified problems with the use and implementation of previously-issued industry guidance described in NEI 01-01, Guidelines on Licensing Digital Upgrades, for implementing digital upgrades under 10 CFR 50.59.
  • NEI is preparing new guidance for implementing digital upgrades under 10 CFR 50.59, as a new Appendix D to NEI 96-07, Guidelines for 10 CFR 50.59 Evaluations. Appendix D would replace in whole the guidance in NEI 01-01 for digital implementation using 10 CFR 50.59, which has been previously endorsed by NRC through Regulatory Issue Summary (RIS) 2002-22, Use of EPRI

[Electric Power Research Institute] /NEI Joint Task Force Report, Guideline on Licensing Digital Upgrades: EPRI TR-102348, Revision 1, NEI 01-01: a Revision of EPRI TR-102348 to Reflect Changes to the 10 CFR 50.59 Rule, dated November 25, 2002.2

  • The NRC staff plans to evaluate and comment on the new NEI draft Appendix D when it is provided to NRC by end of March 2016. If appropriate, the NRC will endorse the use of this new guidance in a regulatory guide.
  • The NRC staff has previously expressed concern with a proposed NEI approach to eliminate consideration of DI&C common cause failure in 10 CFR 50.59 evaluations through qualitative consideration of likelihoodwithout supporting data or accepted PRA methods.

2 ADAMS Accession No. ML023160044.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION A.2 Delivering the Nuclear Promise - Industry Initiative Exelon specifically would like to discuss security programs as it relates to this industry initiative.

A.3 Generic Issue Resolution Exelon expressed an interest in generic issue resolution (e.g., task interface agreements (TIAs), role of the Committee to Review Generic Requirements, and backfits) but did not provide specific issues of interest. Brief information on TIAs is included in this section, as this was a topic of interest in a previous discussion between Exelon and the Office of Nuclear Reactor Regulation. Specific information on the Byron/Braidwood backfit appeal is provided in Section B.1 below.

A.3.1 TIAs

  • The TIA process has been recently revised in COM-106, Revision 5, Control of Task Interface Agreements.3
  • The TIA process is not intended for generic issue resolution. If a potential generic issue is identified during a TIA review, the process described in COM-106 outlines an exit path to remove the issue from the TIA process. Screening is conducted using MD 6.4, Generic Issues Program, to ensure plant-specific scope.
  • Exelon expressed concern regarding a recently closed TIA for Palisades. The TIA concerned the recording and reporting of operational radiation dose. The staff concluded that occupational radiation dose is required to be recorded and reported for required monitoring, but not for voluntary monitoring. Exelon is concerned because it uses EPRI guidance which states that recording and reporting is not needed below 10 mrem. In addition, the industry stated that we did not follow our revised process for this TIA. The revised TIA process precludes using a TIA for generic decisions, such as the Palisades TIA.

However, the Palisades TIA was initiated under the old process and the staff decided that it was more efficient to complete the TIA review under the old process rather than transfer it to the generic communications process.

A.4 Open-Phase Condition (OPC)

A.4.1 OPC Key Messages

  • With compensatory measures in place, the risk associated with an OPC is significantly reduced. Compensatory measures include operator awareness and procedure modifications.

3 ADAMS Accession No. ML15219A174.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

  • Staff reviewed and agreed with the interim compensatory measures. These will be inspected via a Temporary Instruction (TI) under the Reactor Oversight Process once the interim enforcement policy (IEP) is issued.
  • To date, the NRC has not reviewed an industry proposal for a long-term solution or agreed that an OPC is within the design bases; however, the staff believes that the regulations require consideration of such a phenomenon.

A.4.2 OPC Facts

  • The Institute of Nuclear Power Operations (INPO) issued a Level 2 INPO Event Report, which required corrective actions by plant operators.
  • NRC communicated its position to the nuclear industry regarding licensees adopting a proposed open phase isolation system (OPIS) by providing four functional criteria that must be achieved in the proposed OPIS in a letter to NEI dated November 25, 2014.4
  • Licensees have committed to install permanent solutions by the end of calendar year 2018.
  • The NRC staff is developing an Interim Enforcement Policy (IEP) for Commission approval that would provide discretion to avoid unnecessary plant shutdown if a nuclear power plant is found to be not in compliance with their licensing basis while interim measures are in place, but before a permanent solution is implemented. The staff will seek Commissions approval of the IEP by early third quarter 2016.
  • A RIS will be issued to notify stakeholders of the IEP and provide the results of NRCs review of the licensee responses to NRC Bulletin 2012-01, Design Vulnerability in Electric Power System. 5 Staff will request CRGR review of the RIS.
  • The staff is also preparing a TI to inspect licensees interim corrective actions and compensatory measures in parallel with RIS. Another TI will be prepared to verify the licensees permanent corrective actions once licensees notify the NRC that they are in compliance in accordance with the IEP.
  • A 2.206 petition on OPC was submitted to the NRC by several NRC staff. This petition is being processed per the NRC 2.206 petition process.

4 ADAMS Accession No. ML14120A203.

5 ADAMS Accession No. ML12074A115.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION A.4.3 OPC Background NRC Actions

  • January 30, 2012: Byron Station, Unit 2, shut down automatically due to unbalanced voltage entering the onsite power distribution system from the transmission network. The plants electric power systems protection scheme was not designed to sense the loss of one of three power phases and automatically trip circuits to isolate the degraded outside power source and switch to emergency backup power. Plant operators diagnosed the problem eight minutes later and manually tripped the necessary circuits.
  • March 1, 2012: NRC issued Information Notice 2012-03, Design Vulnerability in Electric Power System, 6 to inform licensees of recent experience involving loss of one of three phases of the offsite power circuit, including the Byron event.
  • March 27, 2012: NRC issued Special Inspection Team (SIT) Report 05000455/20120087 at Byron Station.
  • July 27, 2012: NRC issued Bulletin 2012-01, Design Vulnerability in Electric Power System, to all nuclear power plant licensees requesting information about their electric power system designs and alerting them to a potential design vulnerability that could affect the operation of key safety equipment.
  • February 26, 2013: NRC issued Summary Report8 with evaluation of Bulletin responses.
  • December 20, 2013: NRC issued a generic request for additional information9 to all operating reactor licensees.
  • May 2014: The staff published a draft Branch Technical Position10 (issued final as BTP 8-9) in the Federal Register and obtained public comments.
  • November 25, 2014: NRC staff issued a letter to NEI11 communicating its position with functional criteria addressing staffs concerns with the most current industry proposed OPIS.
  • July 2015: NRC issued BTP 8-9, Open Phase Conditions in Electrical Power System, 12 to provide guidance to the staff in reviewing future licensing actions.

6 ADAMS Accession No. ML120480170.

7 ADAMS Accession No. ML12087A213.

8 ADAMS Accession No. ML13052A711.

9 ADAMS Accession No. ML13351A314.

10 ADAMS Accession No. ML14057A433.

11 ADAMS Accession No. ML14120A203.

12 ADAMS Accession No. ML15057A085.

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  • March 2016: Compliance backfit evaluation completed by NRR (in coordination with Office of Enforcement) as part of IEP development, and no legal objection received from Office of the General Counsel.

Industry Actions

  • February 16, 2012: INPO issued a document describing the event and requiring a review of the lessons-learned and corrective actions for applicability by all licensees.
  • Interim actions were taken to include enhancements to plant operating procedures and operator training to diagnose and respond to an OPC.
  • October 9, 2013: NEI submitted an industry initiative (strategy paper) which was approved by the Nuclear Strategic Issues Advisory Committee (NSIAC) to support the resolution of the OPC issue. NSIAC is comprised of all Chief Nuclear Officers for the operating nuclear power reactors.

A.4.4 OPC Talking Points

  • Since the open phase issue came up, the staff and industry have proactively engaged to address it for current operating and new nuclear power reactors.
  • NRC continues to believe that the licensees interim measures, as described in responses to NRC Bulletin 2012-01 and requests for additional information, are adequate to maintain the current safety of operating power plants.
  • NRC continues to expect that licensees will implement permanent corrective measures by 2018, consistent with the February 2012 Level 2 INPO Event Report and the October 2013 NEI strategy paper, which was approved by NSIAC.
  • NRC plans to conduct future NRC inspections to verify resolution of the OPC issue and compliance with applicable regulatory requirements.
  • Over the last year, NRC staff have worked to identify the appropriate regulatory vehicle for ensuring that the licensees commitments for addressing OPC vulnerabilities are enforceable, while avoiding unnecessary regulatory burden.
  • NRC continues to work towards the following regulatory actions: (1) enforcement discretion and (2) compliance backfit for licensees who do not implement the permanent corrective measures by 2018.
  • Some NRC staff felt that it was a safety-significant issue that warranted timely regulatory action, and that a path to resolution was not eminent. Consequently, these individuals filed a 2.206 petition (as members of the public) requesting that NRC issue orders requiring operating plants to either immediately implement corrective actions or to shut down until OPC vulnerabilities are addressed.

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  • NRC has formed a petition review board to review the petition in accordance with MD 8.11, Review Process for 10 CFR 2.206 Petitions; at the same time, NRC will continue efforts to identify the appropriate regulatory vehicle.

A.5 Accident-Tolerant Fuels

  • Accident-tolerant fuels (ATF) are intended to maintain integrity of the fuel cladding in extreme high temperatures and prevent hydrogen generation and heating due to cladding oxidation.
  • Multiple international partners are developing different types of ATF with a target of putting test fuel rods into commercial reactors in 2022.
  • Current ATF designs have a variety of limitations including leakage potential, manufacturing issues, high costs, and reduced neutronic efficiency.
  • Recent discussion indicates that industry may seek to leverage the use of ATF to reduce requirements on safety-related equipment.

B. OTHER TOPICS OF INTEREST B.1 Braidwood/Byron Backfit B.1.1 Background

  • In 1973, American Nuclear Society (ANS) 18.2-1973 was issued and licensees incorporated it into their Final Safety Analysis Reports (FSARs). This standard classifies transients and accidents according to frequency of occurrence and preserves this classification by requiring non-escalation.

Condition II) fills the pressurizer and causes water relief through power-operated relief valves (PORVs). Unqualified PORVs stick open resulting in a small break loss-of-coolant accident (SBLOCA, Condition III) with the frequency of an AOO (Condition II), which violates the design requirements for AOOs. If, inadvertent safety injection is shown to not fill the pressurizer and PORVs relieve only steam, then the AOO (Condition II) design requirements are met.

  • In 2005, RIS 2005-29, Anticipated Transients That Could Develop into More Serious Events,13 informs licensees of their commitments to ANS 18.2 and provides examples where the non-escalation requirement has not been met.
  • Between 2005 and now, several licensees have made improvements to analyses and/or the plant to address this issue.

13 ADAMS Accession No. ML051890212.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION B.1.2 Recent Actions The NRC staff issued a compliance backfit to the Braidwood and Byron stations on October 9, 2015.14 On December 8, 2015, Exelon submitted a letter to the NRR Office Director to appeal the backfit.15 NRC MD 8.4, Management of Facility-Specific Backfitting and Information Collections, and NRR Office Instruction LIC-202, Procedures for Managing Plant-Specific Backfits and 50.54(f) Information Requests, describe the NRC backfit process, including the backfit appeal process, and NRRs office-specific implementation.

The compliance backfit was issued because three Updated Final Safety Analysis Report (UFSAR) Chapter 15 events failed to demonstrate compliance with the non-escalation requirement: Inadvertent Operation of the Emergency Core Cooling System; Chemical and Volume Control System Malfunction that Increases RCS Inventory; and Inadvertent Operation of a PORV. Other issues identified in the same Chapter 15 events included the nonconservative assumption that pressurizer PORVs and spray are inoperable; the prediction of prolonged water relief through pressurizer safety valves (PSVs), which are not water-qualified per American Society for Mechanical Engineers Boiler and Pressure Vessel Code or tested under water-solid conditions; the failure to address return to operation, as required for analyses of AOOs; and incorrect statements in the UFSAR.

In accordance with LIC-202, the NRR Office Director appointed a three-member panel to review the backfit appeal16 and Exelon was offered an opportunity to present its appeal to the panel at a public meeting. The public meeting was held on March 7, 2016.17 The panel will continue to review the information provided in the Exelon appeal letter, at the March 7 public meeting, and contained in related documents and provide a recommendation to the NRR Office Director toward the end of March. A letter responding to the licensee is expected in early April.

14 ADAMS Accession No. ML14225A871.

15 ADAMS Accession No. ML15342A112.

16 Charter at ADAMS Accession No. ML15355A081.

17 Meeting slides at ADAMS Accession No. ML16062A422; transcript at ADAMS Accession No. ML16070A364.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION EXELON GENERATION COMPANY, LLC 4300 Winfield Road Warrenville, IL 60555 www.exeloncorp.com Exelon Generation Company, LLC (EGC) is one of the largest competitive power generators in the United States, with owned generating assets totaling approximately 34,700 megawatts.

With strong positions in the Midwest, Mid-Atlantic, Texas, and California, EGC is the largest owner and operator of nuclear plants in the United States and maintains a growing renewable energy development business headquartered in Baltimore, Maryland.

Exelon Nuclear, a division of EGC, operates 23 reactors at 14 facilities located in Illinois, Maryland, Nebraska, New Jersey, New York, and Pennsylvania. The fleet has the capacity to generate more than 22,000 megawatts of electricity.

Exelon Nuclear operates the following nuclear facilities:

Illinois: Braidwood Station, Units 1 and 2 Byron Station, Unit Nos. 1 and 2 Clinton Power Station, Unit 1 Dresden Nuclear Power Station, Units 2 and 3 LaSalle County Station, Units 1 and 2 Quad Cities Nuclear Power Station, Units 1 and 2 Maryland: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Nebraska: Fort Calhoun Nuclear Station, Unit 1 New Jersey: Oyster Creek Nuclear Generating Station, Unit 1 New York: Nine Mile Point Nuclear Station, LLC, Units 1 and 2 R.E. Ginna Nuclear Power Plant, Unit 1 Pennsylvania: Limerick Generating Station, Units 1 and 2 Peach Bottom Atomic Power Station, Units 2 and 3 Three Mile Island Nuclear Station, Unit 1

Owned by Omaha Public Power District OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION EXELON CORPORATION MANAGEMENT DATA Exelon Senior Executives CEO: Chief Executive Officer CFO: Chief Financial Officer COO: Chief Operating Officer EVP: Executive Vice President SVP: Senior Vice President VP: Vice President President and CEO Exelon Christopher M. Crane Senior EVP Exelon Senior EVP CEO Exelon Utilities Chief Strategy Officer Denis P. OBrien William A. Von Hoene Sr . EVP & Chief Commercial Officer EVP& Chief Administrative Officer President & CEO Exelon Generation

& President BSC Kenneth W. Cornew EVP & CFO Jonathan W. Thayer SVP & VP and Senior VP & Chief HR Officer Exelon Chief Enterprise Risk Officer Chief of Staff Amy Best Aliabadi Paymon Sue Wallace OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION Exelon Generation Sr. EVP & Chief Commercial Officer President & CEO Exelon Generation Kenneth Cornew VP & Managing Director EVP & Chief Operating EVP Exelon &

Generation Officer CEO Constellation Development Exelon Generation Joseph Nigro Corey Hessen Michael Pacilio SVP Exelon Generation, President & SVP Exelon Generation, Chief Nuclear Officer President Exelon Power Exelon Nuclear Ronald DeGregorio Bryan Hanson OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION Exelon Nuclear SVP Exelon Generation &

CNO Exelon Nuclear Bryan Hanson VP Nuclear SVP Strategy &

Oversight Planning David Hoots Carol Peterson SVP Organizational SVP Regulatory Affairs &

Effectiveness and General Counsel Performance Bradley Fewell Assessment Susan Landahl VP Licensing &

Regulatory Affairs Keith Jury Director Director Licensing - West Licensing - East Glen Kaegi Jim Barstow COO Fleet SVP Engineering & SVP Strategy & COO CENG Operations Technical Services Planning SVP NE Operations David Rhoades Scot Greenlee Carol Peterson Chris Mudrick OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION Biographical Data of Principal Managers Bryan Hanson Senior Vice President Exelon Generation President and Chief Nuclear Officer, Exelon Nuclear Hanson is responsible for ensuring that Exelon Generation maintains high levels of performance and safety across its nuclear fleet. Exelon Generation operates the largest nuclear fleet in the nation, which includes 23 reactors at 14 facilities located in Illinois, Maryland, Nebraska, New Jersey, New York, and Pennsylvania. Hanson has more than 25 years of progressive experience in the nuclear power industry. Prior to his current role, Hanson was chief operating officer of Exelon Generations nuclear fleet with oversight for the daily operation of Braidwood, Byron, Calvert Cliffs, Clinton, Dresden, Fort Calhoun, Ginna, LaSalle, Limerick, Nine Mile Point, Oyster Creek, Peach Bottom, Quad Cities, and Three Mile Island nuclear stations. During his tenure with Exelon, Hanson served as the senior vice president of Midwest operations, site vice president for Exelons Braidwood Generating Station and the site vice president for Clinton Power Station. He also has been vice president of nuclear oversight, Limerick Generating Station plant manager and director of operations and work control. Hanson earned a bachelors degree in nuclear engineering from the University of Wisconsin at Madison and a Master of Business Administration from St. Ambrose University in Davenport, Iowa. Hanson is a graduate of the Institute of Nuclear Power Operations Senior Nuclear Plant Management Program and the Exelon Leadership Institute at the Kellogg Graduate School of Management at Northwestern University.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION Scot Greenlee Senior Vice President Engineering and Technical Services Greenlee is responsible for governance and oversight of engineering functions for Exelons 22 nuclear reactors and the Fort Calhoun Nuclear Station in Omaha, Neb. Prior to this role, Greenlee was Exelons vice president of engineering and served as the engineering director at Byron station. Greenlee began his nuclear career as an officer in the United States Nuclear Navy.

Following a successful Navy career, Greenlee was a Nuclear Regulatory Commission resident inspector at the Beaver Valley Nuclear Station in Pennsylvania. He has held numerous leadership positions in engineering and operations, having worked at four other nuclear facilities prior to joining Exelon.

Greenlee obtained his bachelors degree in electrical engineering from the Georgia Institute of Technology. He completed the Navy Nuclear Power School and Prototype Training, NRC Inspector Training and the Institute of Nuclear Power Operations Senior Nuclear Plant Management Course.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION J. Bradley Fewell Senior Vice President Regulatory Affairs and General Counsel Fewell oversees the licensing and regulatory affairs functions, as well as the coordination of issues that involve legal, communication and governmental affairs activities, for Exelon Generations nuclear fleet. The fleet consists of 23 reactors at 14 locations in Illinois, Maryland, Nebraska, New Jersey, New York and Pennsylvania. He also manages legal matters involving all of Exelons generation assets. Fewell joined Exelon in 2003 as an Assistant General Counsel and has held several key leadership positions within Exelons Legal department during his tenure with the company. Previously, Fewell served as Regional Counsel for the Nuclear Regulatory Commission.

Fewell earned a bachelors degree from Wabash College in Indiana, with a double major in English and Psychology. He earned his law degree at Rutgers University Law School. Fewell serves as chairman with both the Nuclear Energy Institute and Nuclear Electric Insurance Limited lawyer advisory committees. He also serves as vice chair of the nuclear division of the American Bar Associations Section of Public Utility, Communications and Transportation Law.

He is a member of the technical advisory board for the National Museum of Nuclear Science and History.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION Keith Jury Vice President, Licensing and Regulatory Affairs Jury is responsible for the governance and oversight of corporate licensing, site regulatory affairs, environmental, and licensing programs for Exelons 14 nuclear generating facilities.

Previously, Jury served as director of licensing and regulatory affairs. He joined Exelon in 2000 at Byron station, holding positions as site support services director and mechanical maintenance manager. Jury began his nuclear career at First Energy Nuclear Operating Companys Perry nuclear facility in Ohio in quality assurance. Afterward, he worked for the Nuclear Regulatory Commission as a regional inspector, a resident inspector at Robinson nuclear plant in South Carolina, and a senior resident inspector at Point Beach nuclear plant in Wisconsin. After leaving the NRC, Jury worked for Progress Energy as a licensing/regulatory programs manager at the Robinson facility and a regulatory affairs manager at Brunswick nuclear facility in North Carolina. He also worked at First Energys Perry facility as a compliance manager. Jury attended Case Western Reserve University in Cleveland, Ohio, where he earned a bachelors degree in mechanical engineering.

OFFICIAL USE ONLY - SENSITIVE INTERNAL INFORMATION

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