ML20307A434

License Amendment Request - Proposed Changes to Emergency Plan for Post-Shutdown and Permanently Defueled Condition

ML20307A434
Person / Time
Site:	Dresden
Issue date:	11/02/2020
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML20307A433	List: ML20307A434 ML20307A436 ML20307A445 ML20307A455 RS-20-131, Part II: Planning Standards and Criteria
References
RS-20-131
Download: ML20307A434 (47)

Text

Exelon Generation 4300 Winfield Road Warrenville, IL 60555 630 65 7 2000 Office RS-20-131 10 CFR 50.90 10 CFR 50.54(q)

November 2, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington , DC 20555-0001 Dresden Nuclear Power Station, Units 1, 2, and 3 Amended Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010. 50-237. 50-249. and 72-037

Subject:

License Amendment Request - Proposed Changes to Dresden Emergency Plan for Post-Shutdown and Permanently Defueled Condition

Reference:

Letter from Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission , "Certification of Permanent Cessation of Power Operations for Dresden Nuclear Power Station , Units 2 and 3," dated July 2, 2020 (NRC Accession No. ML20246G627)

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 Amended Facility Operating License No. DPR-2 and Renewed Facility Operating License Nos .

DPR-19 and DPR-25 for Dresden Nuclear Power Station, Units 1, 2, and 3, (Dresden) respectively. The proposed amendment would revise the Site Emergency Plan (SEP) for the post-shutdown and permanently defueled condition . The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4).

On August 27, 2020, Exelon announced that it plans to close Dresden, Units 2 and 3, due to severe economic challenges. By letter dated September 2, 2020 (Reference 1), Exelon provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.4(b)(8) and 10 CFR 50.82(a)(1 )(i) that it would permanently cease operations at Dresden on or before November 30, 2021.

Once the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessels are submitted to the NRC in accordance with 10 CFR 50.82(a)(1 )(i) and (ii), then pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 licenses will no longer authorize operation of the Dresden, Units 2 and 3 reactors or emplacement or retention of fuel in the reactor vessels.

November 2, 2020 U.S. Nuclear Regulatory Commission Page 2 Dresden Unit 1 was shutdown October 31, 1978 and was never returned to service. In October 1984 a decision was made to decommission unit. In July 1986, the NRC issued a license amendment to alter the Dresden Unit 1 operating license to possession only status. The unit is being maintained in SAFSTOR and no significant dismantlement activities are underway. There is no Dresden Unit 1 spent fuel in wet storage at Dresden; it is stored on-site in dry cask containers in an Independent Spent Fuel Storage Installation (ISFSI).

The proposed SEP changes would revise the on-shift staffing and the Emergency Response Organization (ERO) staffing. Exelon has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and requirements in 10 CFR 50, Appendix E, and concludes that the standards and requirements will continue to be met.

The proposed changes to the SEP are commensurate with the reduced spectrum of credible accidents in the post-shutdown and permanently defueled condition. In order to assist in the transition from an operating facility to a permanently defueled facility, the changes are required to properly reflect the conditions of the facility while continuing to preserve the Dresden Decommissioning Trust Fund and the effectiveness of the SEP.

The proposed changes have been evaluated in accordance with 10 CFR 50 .91 (a)(1) using criteria in 10 CFR 50.92(c), and Exelon has determined that this change involves no significant hazards consideration. Exelon has also determined that the proposed SEP changes satisfy the criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9) and do not require an environmental review. Therefore, pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment is required.

The description and evaluation of the proposed SEP changes are contained in Attachment 1. provides a tabular summary of the proposed changes to the SEP. Attachment 3, Exhibits A and B provide the revised pages of the SEP with the proposed changes. Attachment 3 Exhibits C and D provide clean copies of the SEP documents. Attachment 4 provides the analysis of ERO tasks assigned to the ERO positions. Attachment 5 of this letter contains a new regulatory commitment.

On October 13, 2020, Exelon provided the Illinois Emergency Management Agency (IEMA),

Grundy County, Will County and Kendall County a draft copy of the Dresden Post-Shutdown Emergency Plan (PSEP) for comment. On October 27, 2020 Exelon conducted a call with IEMA to discuss questions and comments on the proposed License Amendment Request, which were subsequently addressed. IEMA provided a letter dated October 29, 2020 stating they do not anticipate submitting concerns to the U.S. Nuclear Regulatory Commission as part of their review process. There were no comments received from the surrounding Counties. provides a copy of the referenced correspondence from IEMA.

The proposed changes have been reviewed by the Dresden Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

Exelon requests review and approval of the proposed license amendment by October 15, 2021 to support the current schedule for the Dresden, Units 2 and 3, transition to a permanently defueled condition . Exelon requests that the approved amendment become effective following the submittal of the certifications required by 10 CFR 50.82(a)(1) that Dresden , Units 2 and 3 have been permanently defueled. Once approved, the amendments shall be implemented within 90 days from the effective date but will not exceed February 28, 2022.

November 2, 2020 U.S. Nuclear Regulatory Commission Page 3 In accordance with 10 GFR 50.91 "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions concerning this submittal, please contact Leslie Holden at (630) 657-2524.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of November 2020.

Respectfu Ily, Patrick R. Simpson Sr. Manager - Licensing Exelon Generation Company, LLC

Attachment:

1. Description and Evaluation of Proposed Changes

2. Tabular Summary of Proposed Changes to the Site Emergency Plan

3. Proposed Revision to Site Emergency Plan

4. Emergency Response Organization Task Analysis

5. Summary of Regulatory Commitments

6. Correspondence with State of Illinois cc: NRG Regional Administrator, Region Ill NRG Project Manager, NRR - Dresden, Units 2 and 3 NRG Senior Resident Inspector- Dresden NRG Project Manager, NMSS - Dresden, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety

Attachment 1 Dresden Station DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

Attachment 1 License Amendment Request Dresden Nuclear Power Station, Units 1, 2, and 3 NRC Docket Nos.50-010, 50-237, 50-249, and 72-037 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

Subject:

Proposed Changes to the Dresden Emergency Plan for Permanently Shutdown Condition 1.0

SUMMARY

DESCRIPTION

2.0 PROPOSED CHANGE

S 3.0 REASON FOR PROPOSED CHANGES

8.0 REFERENCES

Page 1 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Amended Facility Operating License No.

DPR-2 for Dresden Nuclear Power Station, Unit 1, and Renewed Facility Operating Licenses Nos. DPR-19 and DPR-25 for Dresden Station, Units 2 and 3 (Dresden), respectively. The proposed changes would revise Dresden Emergency Plan on-shift and Emergency Response Organization (ERO) staffing to support the planned permanent cessation of operations and permanent defueling of the Dresden reactors (Reference 8.1). Specifically, the proposed changes would eliminate the on-shift positions not needed for the safe storage of irradiated fuel in the Spent Fuel Pools (SFPs) during the initial decommissioning period and eliminate the ERO positions not necessary to effectively respond to credible accidents. The proposed changes in staffing are commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled power reactor facility.

Exelon Generation Company, LLC (Exelon) has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and has concluded that the standards and requirements will continue to be met. Therefore, no exemption from 10 CFR 50.47 or 10 CFR 50 , Appendix E, is requested in support of this License Amendment Request (LAR).

As specified in Attachment 5 of this submittal, Exelon has committed to conduct a confirmation Emergency Preparedness (EP) drill to demonstrate that no loss of Emergency Preparedness function will result from the implementation of the proposed changes. The drill will include each of the Emergency Response Facilities (ERF) described in the Dresden Emergency Plan.

2.0 PROPOSED CHANGE

S 2.1 Description of Proposed Changes The Dresden Emergency Plan consists of the following documents:

• EP-DR-1000, "Dresden Station Radiological Emergency Plan"

• EP-M-1004, "Radiological Emergency Plan Annex for Dresden Station" (Annex)

• EP-M-1004, Addendum 1, "Dresden Station On-Shift Staffing Technical Basis"

• EP-M-1004, Addendum 2, "Evacuation Time Estimates for Dresden Generating Station Plume Exposure Pathway Emergency Planning Zone"

• EP-M-1004, Addendum 3, "Emergency Action Levels for Dresden Station" The on-shift and augmented ERO positions are being revised to respond to a reduced spectrum of credible accidents for a permanently shutdown and defueled power reactor facility. Once the fuel is permanently removed from the Dresden, Units 2 and 3 reactors and relocated to the SFPs, Exelon will submit written certification to the NRG in accordance with 10 CFR 50.82(a)(1 ). Pursuant to 10 CFR 50.82(a)(2), Exelon will no longer be authorized to operate the Dresden reactors, or to place or store fuel in the reactor vessels. The scope of applicable emergency operating procedures and abnormal response procedures will be significantly reduced.

Page 2 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Attachment 2 to this LAR provides a tabular summary of the proposed changes to the Dresden Emergency Plan and Emergency Plan Annex. Attachment 3 provides the revised pages of the Emergency Plan and Emergency Plan Annex with the proposed changes shown in strikethrough and underline format. Attachment 4 contains an analysis of the ERO tasks. Attachment 5 contains a list of regulatory commitments made as part of this LAR.

2.2 On-Shift Staff Currently, the Dresden Emergency Plan, EP-DR-1000, Appendix 5, Table 5-1:

"Emergency Response Organization (ERO) Staffing and Augmentation Plan," specifies the following on-shift Emergency Response staff:

• One (1) Shift Emergency Director

• Two (2) Radiation Protection (RP) Personnel

• One (1) Shift Communicator 1

• One (1) Shift Dose Assessor 1

• One (1) Emergency Classification Advisor 1

• One ( 1) Core/Thermal Hydraulics Engineer - STA1 1 Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

To support reduced staffing following permanent cessation of operations and permanent removal of fuel from the reactor vessels, the Emergency Plan staffing levels have been evaluated using the methodology in Nuclear Energy Institute (NEI) 10-05 (Reference 8.6), which evaluates the postulated accidents that will be applicable in the permanently defueled condition. The Dresden ERO was revised in 2019 (Reference 8.15) based on the Alternative Guidance for Licensee Emergency Response Organizations (Reference 8.16).

The proposed changes to Dresden Emergency Plan, EP-DR-1000, Appendix 5, Table 5-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan,"

eliminates the following positions from the present Emergency Plan staffing levels:

• One (1) Radiation Protection (RP) Personnel

• One (1) Core/Thermal Hydraulics Engineer - STA1

• One (1) Emergency Classification Advisor 1 1 Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time .

The required on-shift staff following permanent defueling is commensurate with the need to safely store irradiated fuel at the faci lity in a manner that is protective of public health and safety. The following proposed Emergency Plan on-shift complement will be required in the permanently shutdown condition:

• One (1) Shift Emergency Director Page 3 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

• One (1) Radiation Protection (RP) Personnel

• One (1) Shift Communicator1

• One (1) Shift Dose Assessor 1 1 Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

Refer to section 5.4.1 for a further discussion of the On-Shift Staffing Assessment performed for the permanently shutdown condition at Dresden.

2.3 Emergency Response Organization 60 Minute/90-Minute Augmentation Staff (Minimum Staffing)

Currently, EP-DR-1000, Appendix 5, Table 5-1 specifies the augmented Minimum Staffing for certain positions in the Emergency Preparedness Functions identified in Table B-1 of NUREG-0654, Revision 2. The Dresden Emergency Plan (EP-DR-1000) identifies the Minimum Staff as those ERO members that are required to activate their respective ERF at the appropriate Emergency Action Level (EAL) classification level.

Proposed revisions would eliminate 10 Minimum Staff positions, change one Minimum Staff position to a collateral function, and add one (1) position as shown in the Table 2-1, "Dresden Minimum Staff Positions," below.

Table 2-1, Dresden Minimum Staff Positions (Response times are 60 minutes unless otherwise noted)

Current Minimum Staff Positions Proposed Minimum Staff Positions Technical Support Center (TSC)

Station Emergency Director Station Emergency Director ENS Communicator ENS Communicator Rad Protection Manager Rad Protection Manager Operations Manager Operations Manager Core Thermal Engineer Position Eliminated Mechanical Engineer Position Eliminated Electrical Engineer Position Eliminated

---

TSC Engineer (added)

Security Coordinator Security Coordinator Emergency Operations Facility (EOF)

Corporate Emergency Director Corporate Emergency Director State I Local Communicator State I Local Communicator Radiation Protection Manager Radiation Protection Manager Dose Assessment Coordinator Dose Assessment Coordinator Computer Specialist(@ 90 min) Computer Specialist(@ 90 min)

Page 4 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Joint Information Center JIC Director(@ 90 min) JIC Director(@ 90 min)

Corporate Spokesperson(@ 90 min) Corporate Spokesperson (@ 90 min)

Public Information Director(@ 90 min) Public Information Director (@ 90 min)

Operations Support Center (OSC)

OSC Director OSC Director RP Personnel #1 RP Personnel #1 RP Personnel #2 RP Personnel #2 RP Personnel #3 Position Eliminated RP Personnel #4 (@ 90 min) Position Eliminated RP Personnel #5 (@ 90 min) Position Eliminated RP Personnel #6 (@ 90 min) Position Eliminated Mechanical Maintenance Mechanical Maintenance Electrical Maintenance Electrical Maintenance l&C Technician(@ 90 min) l&C Technician(@ 90 min)

RP Supv/Lead (@ 90 min) RP Supv/Lead 1 Mechanical Maintenance Supv/Lead Position Eliminated

(@ 90 min)

Electrical Maintenance Supv/Lead (@ 90 min) Position Eliminated l&C Supv/Lead (@ 90 min) Position Eliminated Offsite Field Team #1 Personnel Offsite Field Team #1 Personnel Offsite Field Team #1 Driver Offsite Field Team #1 Driver Offsite Field Team #2 Personnel(@ 90 min) Offsite Field Team #2 Personnel

(@ 90 min)

Offsite Field Team #2 Driver(@ 90 min) Offsite Field Team #2 Driver

(@ 90 min)

Onsite Field Team #1 Personnel Onsite Field Team #1 RP (onsite surveys) Personnel (onsite surveys)

Note:

1 Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

2.4 Emergency Response Organization Full Augmentation Staff Full Augmentation staff are those ERO positions which provide support for the Minimum Staff in their response to the emergency. Augmented Staff help facilitate communication and emergency response effort but are not required to implement the key functions/tasks identified in the Emergency Plan . Dresden is planning to maintain the following Full Augmentation positions in support of the Post Shutdown Emergency Plan.

Page 5 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

• TSC Director (TSC) - The TSC Director is responsible for the content of information transmitted from the TSC to other agencies (or facilities) ,

documenting information received at the TSC in coordination with the Station Emergency Director and provides administrative services in support of emergency/recovery operations.

• Chemistry Personnel (OSC) - Perform Chemistry sample and analysis as requested

• EOF Director (EOF) - The EOF Director reports to the Corporate Emergency Director and has the authority, management ability and technical knowledge to assist the Corporate Emergency Director in the management of Exelon Nuclear's offsite ERO. In the event that the Corporate Emergency Director becomes incapacitated, the EOF Director shall assume the responsibilities of the Corporate Emergency Director until a transfer of Command and Control can be affected either back to the station or to another qualified Corporate Emergency Director.

• Technical Advisor (EOF) - The Technical Advisor reports to the EOF Director.

Responsibilities include: Assist the Dose Assessment Coordinator in acquiring technical information pertaining to release pathway and core damage assessment. Provide the Corporate Emergency Director information concerning the status of plant operations, and recommendations for mitigating the consequences of the accident.

• Environmental Coordinator (EOF)- The Environmental Coordinator reports to the EOF Radiation Protection Manager and directs the Field Team Communicator, Field Monitoring Teams and the State Environs Communicator.

• State Environs Communicator (EOF) - The State Environs Communicator is staffed as requested by the applicable state agencies. Responsibilities include coordination of activities and information flow between the EOF Protective Measures Group and the affected state(s) environmental authorities, including periodic updates on meteorological conditions, Field Monitoring Team activities and survey/sample results.

• The Logistics Manager reports to the EOF Director and directs the activities of the administrative, security and liaison personnel. Responsibilities include:

Ensure contact is made and communications are maintained with appropriate Non-Exelon Nuclear personnel whose assistance may be required to terminate the emergency conditions and to expedite the recovery. Ensure shift relief and continual staffing for the EOF.

• EOC Communicator (EOF) - The EOC Communicator coordinates and dispatches EOC Liaisons as needed or requested.

• County EOC Liaison(s) (EOF) - The County EOC Liaison(s) monitor and report County EOC activities to the EOF, Conduct briefings and answer questions as needed. The County EOC Liaisons also assist with confirmation/verification of information distributed through approved channels.

Page 6 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

• State & REAC EOC Liaison(s) (EOF) - At the request of state officials and/or at the discretion of the Corporate Emergency Director, the state EOC Liaisons monitor and report state EOC activities to the EOF. In addition , the Liaisons assist Emergency Public Information personnel in rumor control and media monitoring.

• Technical Advisor (JIC) - The Technical Spokesperson assist in development of technical and plant status information for use in news releases and media briefings.

• Access Controller (EOF/JIC) - The Access Controller(s) is responsible for controlling facility access and obtaining authorization prior to admitting non-Exelon Nuclear officials into the JIC and EOF.

3.0 REASON FOR PROPOSED CHANGES The proposed changes are desired to reflect the pending permanent cessation of operations and permanent defueling of the Dresden , Units 2 and 3 reactors. After the reactors are shutdown, all fuel assemblies will be removed from the reactor vessels and placed in the SFPs. The irradiated fuel will be stored in the SFPs until relocated to the Independent Spent Fuel Storage Installation (ISFSI) at Dresden . Once on the ISFSI ,

the fuel will be stored until it is shipped offsite in accordance with the schedules that will be described in the Post-Shutdown Decommissioning Activities Report (PSDAR) and Spent Fuel Management Plan. Upon submitting the certifications for permanent cessation of operations (10 CFR 50.82(a)(1 )(i)) and permanent removal of fuel from the reactor vessels (10 CFR 50.82(a)(1 )(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 licenses for Dresden will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels.

The proposed revisions to the Dresden Emergency Plan are commensurate with the reduction in hazards associated with the permanently defueled condition and will allow the facility staff to transition from those required for an operating facility to those required for a permanently defueled facility. The proposed changes are required to properly reflect the conditions of the facility while continuing to preserve the Dresden Decommissioning Trust Fund and the effectiveness of the Dresden Emergency Plan .

4.0 BACKGROUND

4.1 On-Shift and ERO Staffing Guidance NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1 (Reference 8.3), Section 11.B, "Onsite Emergency Organization," presents guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. The guidance describes the on-site emergency organization , including the staffing requirements found in Table B-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan ." This table specifies a minimum of 10 on-shift responders in four (4) Emergency Preparedness Functions. It also specifies seven (7) on-shift response functions where the duties may be performed Page 7 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES by shift personnel who are assigned other functions (i.e., there are no dedicated responders to perform these functions) . Table B-1 specifies two Emergency Preparedness Functions (i.e., firefighting and site access control/personnel accountability), which must be staffed on a site-specific basis.

The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the site's Emergency Plan commitments. The augmenting ERO responders assume many managerial , engineering, and administrative duties from the on-shift personnel , allowing on-shift personnel to focus on facility operations.

On November 23, 2011 , the NRC published a final rule in the Federal Register (i.e. , 76 FR 72560) amending certain EP requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 8.4 ). This final rule amended 10 CFR 50, Appendix E, Section IV.A, "Organization ," to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions.

Specifically,Section IV.A.9 states that licensees shall perform, " ... a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan ."

Coincident with the rule change in 10 CFR 50, Appendix E, Section IV.A.9, the NRC issued Interim Staff Guidance (ISG) NSIR/DPR-ISG-01, "Interim Staff Guidance -

Emergency Planning for Nuclear Power Plants ," (Reference 8.5). This ISG provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI developed NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," (Reference 8.6) to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

In December 2019, NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, "Revision 2, was issued (Reference 8.13). Section 11.B, "Emergency Response Organization," provides revised guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50 , Appendix E,Section IV.A. The guidance provides a revised description of the on-site emergency organization, including the staffing requirements found in Table B-1 , "Emergency Response Organization (ERO) Staffing and Augmentation Plan."

This table specifies a minimum of three (3) on-shift responders in three (3) Emergency Preparedness Functions. It also specifies four (4) on-shift response functions where the duties may be performed by sh ift personnel who are assigned other functions (i.e., there are no dedicated responders to perform these functions) .

Page 8 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES 4.2 Dresden Station On-Shift Staff In December 2012, an initial on-shift staffing assessment (OSA) was completed in accordance with the NEI 10-05 guidance to satisfy the requirements of 10 CFR 50, Appendix E, Section IV.A.9 . This assessment examined the capability of the existing minimum staff to perform the key emergency response actions for events described in the ISG until augmenting ERO staff arrive. The analysis was conducted by a cross disciplinary team of corporate EP personnel and station personnel from the Operations, RP, Chemistry, Licensing, and EP departments. The emergency response to each of the events described in the ISG was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable departmental procedures such as emergency and off-normal procedures.

Each scenario was reviewed to determine what plant actions and emergency plan implementation actions were required prior to staff augmentation based on plant procedures. These actions were then compared to the minimum staffing for emergency response implementation ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency response role or their dedicated operational role, as appropriate. The accident scenarios considered in this OSA were the Design Basis Threat (DST) Ground Assault, Aircraft Probable Threat, Fire Requiring Control Room Evacuation, Design Basis Loss of Coolant Accident (LOCA), Station Blackout (SBO), and Control Rod Drop Accident. The OSA most limiting accident scenario was determined to be a Fire Requiring Control Room Evacuation.

The Dresden ERO was revised in 2019 (Reference 8.15) based on the Alternative Guidance for Licensee Emergency Response Organizations (Reference 8.16). A revised Table B-1 (renamed as Appendix 5, Table 5-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan") was incorporated in the Emergency Plan .

EP-DR-1000, Appendix 5, Table 5-1 currently specifies the minimum staffing requirements for the Dresden ERO and defines the positions initially responsible for satisfying key ERO functions and specifies positions that will augment the on-shift staff.

In support of this LAR, the Post Shutdown Shift Staffing Assessment was conducted using the guidance of NEI 10-05 and a summary of the results is provided in Section 5.4.1. The Fuel Handling Accident (FHA) (OBA) was included as part of the Post Shutdown OSA, along with DST Ground Assault, Aircraft Probable Threat, Fire Requiring Fire Brigade Response and EAL Classification, and an FHA resulting in a General Emergency.

4.3 Dresden Station Emergency Response Organization Staffing The Dresden Emergency Plan defines four classes of emergency events: Notification of Unusual Event (UE), Alert, Site Area Emergency (SAE), and General Emergency (GE).

Because on-shift personnel can normally address an emergency response to UEs without additional support, staff augmentation is not typically activated for a UE declaration. The Operations Shift Manager (SM) maintains responsibility during UEs.

The second classification level, Alert, requires ERO activation of all ERFs. This includes Page 9 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES the Technical Support Center (TSC), the Operations Support Center (OSC), the Emergency Operations Facility (EOF), and the Joint Information Center (JIC). Overall responsibility for the event is assumed by the Emergency Director in the EOF. When ERO activation is required, notification is sent to those required to respond to their assigned ERF.

Emergency Plan, EP-DR-1000, Part II , Section B, "Dresden Emergency Response Organization," describes how the plant operating organization transitions into an ERO to effectively deal with any incident. Section B.1, "On-Shift Emergency Response Organization Assignments," describes the operating organization on duty at the plant during all shifts.

The Dresden Overall ERO Command Structure is shown in EP-DR-1000, Figure B-1a.

Staffing for the Emergency Onsite Organization is shown in EP-DR-1000, Figure B-1 b (TSC and OSC). Staffing for the Emergency Offsite Organization is shown in EP-DR-1000, Figure B-1c (EOF), and staffing for the Emergency Public Information Organization is shown in EP-DR-1000, Figure B-1d (JIC).

These organizations are notified and staffed depending upon the emergency classification . Elements of the emergency response plan are activated subsequent to an emergency declaration by the SM ; designated company personnel are notified and will report to their designated locations, as required. The emergency response actions of the on-shift personnel are performed on a priority basis depending on the emergency conditions, and the immediate need that those conditions dictate, as determined by the on-shift operations crew.

Exelon requires members to act promptly in reporting to their assigned ERF.

Emergency Preparedness Implementing Procedures require that team members respond within the committed response time . The ERO is instructed to respond directly to their ERF upon notification . Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift. The proposed revisions to the Emergency Plan will not change these requirements . It will continue to be a management expectation that all qualified individuals for each position respond and report to their respective ERF as quickly as possible. EP procedures identify ERO positions assigned to each facility and the minimum staffing required before each facility can be declared operational and is available to perform its designated functions.

EP-DR-1000, Appendix 5, Table 5-1 identifies the personnel required to staff and activate the TSC, OSC, EOF, and the JIC. The mobilization scheme ensures that specific technical disciplines identified by Table B-1 of NUREG-0654 can be augmented within appropriate time frames .

Page 10 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

5.0 TECHNICAL EVALUATION

5.1 Accident Analysis Design Bases Accidents Chapter 15, "Accident and Transient Analysis," of the Dresden Final Safety Analysis Report as Updated (UFSAR) describes the Abnormal Operational Transients and Design Basis Accident (OBA) scenarios that are applicable during plant operations. Upon submittal of the certifications required by 10 CFR 50.82(a)(1 )(i) and (ii), pursuant to 10 CFR 50.82(a)(2), the Dresden, Units 2 and 3 Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels.

Therefore, most of the accident scenarios postulated in the UFSAR will no longer be applicable once Dresden is in the permanently defueled condition.

The UFSAR Chapter 15 FHA in the SFP will remain applicable to Dresden in its permanently shutdown and defueled condition. UFSAR Chapter 15 will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition.

Beyond Design Bases Events In the permanently defueled condition, Dresden will be required to respond to events that involve the loss of SFP cooling and/or water inventory, or external events (e.g. fire, flooding, earthquake, high winds, or hostile actions) that would lead to a loss of SFP cooling and/or water inventory. These strategies will be in place for the protection of the SFPs. The strategies will no longer address restoring core cooling and containment since they are not applicable in the permanently defueled condition .

In the permanently shutdown and defueled condition, the Dresden Fire Brigade will implement the SFP inventory makeup strategies required under 10 CFR 50.155(b )(2). The strategies will no longer address restoration of core cooling and containment, since they are not applicable in the permanently shutdown and defueled condition. Dresden will continue to maintain a trained and qualified Fire Brigade responsible for implementation of the SFP inventory makeup strategies. The Fire Brigade personnel identified in the Dresden Emergency Plan are separate and distinct from those responsible for implementing the major elements of the emergency plan including command and control, emergency classification, offsite notifications, and dose assessment and protective action recommendation development. Therefore, sufficient staffing is available to implement SFP inventory makeup strategies required under 10 CFR 50.155(b )(2) without impacting the performance of designated emergency plan functions. Events involving a loss of SFP cooling or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.155(b)(2). These strategies will continue to be maintained to satisfy applicable portions of Dresden Unit 2 License Condition 2.C.(18) and Unit 3 License Condition 3.M, "Mitigation Strategy License Condition" and 10 CFR 50.155(b )(2).

5.2 On-Shift Staffing Assessment To support reduced staffing following permanent cessation of operations and permanent removal of fuel from the reactor vessels, the on-shift staffing levels have been evaluated, Page 11 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES in part, using the methodology in NEI 10-05"" (Reference 8.6) which evaluates the postulated accidents that will be applicable in the permanently defueled condition.

Dresden performed a multi-disciplined team review of the on-shift staffing changes. The on-shift staffing assessment considered the following accident scenarios:

Design Basis Threat - The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

Fuel Handling Accident - The postulated design basis accident that will remain applicable to Dresden in its permanently shutdown and defueled condition is the FHA in the Reactor Building where the SFPs are located.

Aircraft Probable Threat - Notification is received from the NRC that a probable aircraft threat exists.

Fire Requiring Fire Brigade Response and EAL Classification- A fire occurs in the facility requiring entry into the Emergency Plan and dispatch of the Fire Brigade.

General Emergency with radioactive release and Protective Action Recommendation (assumed for analysis purposes) - This event is based on the same initial conditions as the FHA, but assumes a dose that exceeds the Environmental Protection Agency's Protective Action Guides beyond the site boundary, and thus necessitates promulgation of a Protective Action Recommendation.

5.3 Functional Area Technical Evaluation The following provides evaluation of the changes to the Emergency Preparedness Functions found in Table B-1 of NUREG-0654 , Revision 2 (Reference 8.13). The changes to each function are discussed in this section . The analysis addressed both on-shift and augmented ERO for each function . The current Dresden Emergency Plan ,

Appendix 5, Table 5-1 lists the following functional areas which align with NUREG-0654, Revision 2.

Command and Control Communications Radiation Protection Supervision of Radiation Protection Staff and Site Radiation Protection Dose Assessments I Projections Emergency Classifications Engineering Security Repair Team Activities Supervision of Repair Team Activities Field Monitoring Teams (FMTs)

Page 12 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Media Information JIC/EOF Information Technology (IT) 5.3.1 Emergency Preparedness Function: Command and Control Major Tasks Provide overall ERO command and control, until relieved.

Approve emergency action level (EAL) and/ or protective action recommendation (PAR) classifications, until relieved.

Authorize personnel dose extensions, until relieved.

a. ON-SHIFT There are no changes to the on-shift staffing for this function.

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

5.3.2 Emergency Preparedness Function: Communication Major Tasks Communicate EAL and PAR classifications to offsite response organizations (OROs), including the NRC, until relieved.

a. ON-SHIFT There are no changes to the on-shift staffing for this function.

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

5.3.3 Emergency Preparedness Function: Radiation Protection Major Tasks Provide qualified radiation protection coverage for responders accessing potentially unknown radiological environments during emergency conditions.

Provide in-plant surveys.

Control dosimetry and radiologically controlled area access.

Page 13 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

a. ON-SHIFT Current Requirements The current Dresden Emergency Plan staffs the following on-shift RP Staff positions:

(2) Radiation Protection Personnel Proposed Changes Exelon proposes to eliminate one RP person providing the following on-shift RP Staff positions:

(1) Radiation Protection Personnel Analysis Dresden will no longer be an operating nuclear power plant. In accordance with 10 CFR 50.82(a)(1 ), pursuant to 10 CFR 50.82(a)(2), the Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels. With irradiated fuel being stored in the SFPs and ISFSI, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced as compared to an operating plant. The risk in the permanently shutdown and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. Additionally, the duties and coverages required for the on-shift RP Technician position is reduced. The reduced spectrum of possible accidents limits the necessity to take measures requiring multiple damage control or survey teams in the Protected Area. If additional resources are determined to be necessary during an emergency, Exelon maintains the necessary staffing to provide sufficient personnel trained in RP to respond and perform the required actions, as necessary, in the permanently shutdown and defueled condition.

During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, RP coverage would not be required for all areas. Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFPs are limited, there is a significant decrease in areas potentially requiring RP coverage in a permanently shutdown and defueled condition. If RP coverage is deemed necessary, multiple emergency teams can be covered by an RP Technician. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate setpoints) and because of the installed Area Radiation Monitors (ARMs),which alarm locally and remotely at preset dose rates, and are located throughout the plant.

The On-Shift RP Technician at Dresden also performed the collateral duty of performing the initial Dose Assessment Activities . With the reduction of RP Technicians to one (1 ),

the responsibility for Dose Assessment will be re-assigned to the Operations crew who Page 14 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES will be trained and qualified to perform the function. The re-assignment of the function was assessed in Post Shutdown On-Shift Staffing Assessment for Dresden.

b. AUGMENTED ERO Current Requirements The Augmented ERO consists of the following positions (3) Radiation Protection Personnel (in addition to on-shift coverage)@ 60 minutes (3) Radiation Protection Personnel (in addition to on-shift coverage)@ 90 minutes Proposed Changes Eliminate (1) RP Techs at 60 Minutes Eliminate (3) RP Tech at 90 Minutes Analysis RP OSC Coverage I In-Plant Surveys One primary function of the RP Technicians augmenting the ERO is to provide RP oversight of the on-shift complement and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue ,

first aid, firefighting, and personnel monitoring.

Dresden will no longer be an operating nuclear power plant. In accordance with 10 CFR 50.82(a)(1 ), pursuant to 10 CFR 50.82(a)(2), the Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels . With irradiated fuel being stored in the SFPs and ISFSI, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced as compared to an operating plant. The risk in the permanently shutdown and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. Additionally, the duties and coverages required for the RP Technician positions are reduced . If additional resources are determined to be necessary during an emergency, Exelon maintains the necessary staffing to provide sufficient personnel trained in RP to respond and perform the required actions, if necessary, in the permanently shutdown and defueled condition.

The reduced spectrum of possible accidents limits the necessity to take measures requiring multiple damage control or survey teams in the Protected Area. During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, RP coverage would not be required for all areas.

Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFPs are limited, there is a significant decrease in areas potentially Page 15 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES requiring radiation protection coverage in a permanently shutdown and defueled condition. If RP coverage is deemed necessary, multiple emergency teams can be covered by an RP Technician. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters, which will alarm at preset dose and dose rate setpoints , and because of the installed ARMs , which alarm locally and remotely at preset dose rates, and are located throughout the plant.

Radioactive Protection I Access Control The function of these resources is to provide RP oversight of the on-shift complement of personnel and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid , firefighting and personnel monitoring . They can also be expected to provide for access control and the issuance of dosimetry. Dresden will no longer be an operating nuclear power plant. In accordance with 10 CFR 50.82(a)(1 ), pursuant to 10 CFR 50.82(a)(2), the Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels. With irradiated fuel being stored in the SFPs and ISFSI ,

the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced as compared to an operating plant. The risk in the permanently shutdown and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving operating reactors provides additional time to plan and execute assessment and mitigation actions. If additional resources are determined to be necessary during an emergency, Exelon maintains the necessary staffing to provide sufficient personnel trained in RP to respond and perform the required actions, if necessary, in the post-shutdown condition.

During a declared emergency, Radiation Work Permits (RWPs) and dose set points will change depending on the emergency and plant conditions. Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired , the worker's access would be precluded, and the access control system would not allow issuance of an electronic dosimeter. In an emergency, approval to exceed dose margins is required.

During the log-in process, workers acknowledge their electronic dosimeter alarm set points, and they have read and understand their RWP. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates and will alarm at preset dose and dose rates. Worker use of electronic dosimeters facilitates more efficient use of RP Technicians to provide RP coverage while preserving the As Low As Reasonably Achievable (ALARA) concept. Access control is maintained because the worker must obtain an electronic dosimeter and enter an RWP number into the access control computer system prior to being allowed access into the Radiologically Controlled Area (RCA). No setup is required for the RWP access control computers, which allows RP Technicians to be used for more critical tasks during emergency response . Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA. No RP involvement is necessary for this contamination monitoring activity because workers are trained to perform this task Page 16 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES without supervision or oversight. However, contaminated personnel exiting the RCA will require RP oversight. The analysis of proposed post-shutdown staffing concluded that in a permanently shutdown and defueled condition, RP Technicians can perform this required action in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

RP coverage will only be performed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a task.

The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed ARMs .

Tasks requiring the issuance of dosimetry are not expected in the initial stages of an event, but during the recovery phase. Prior to self-issuance of dosimetry, workers are assigned an RWP, setpoints are adjusted, and briefings are conducted by RP.

The analysis of proposed post-shutdown on-shift staffing determined there are no time critical RP tasks, and that task performance is directed and prioritized by the Shift Manager for the 60-minute time frame used in the analysis. There are no overlapping RP tasks. RP tasks could be performed without augmented personnel in the 60-minute time frame used in the analysis.

Activities related to the conduct of surveys of the owner controlled area or radiological assessment of the area surrounding Dresden are performed by the Field Team Members described under the Field Monitoring Section of the Appendix 5, Table 5-1 of the Dresden Emergency Plan, and are independent of the augmenting RP Technician positions.

Conclusion The reduction of augmented RP Technicians listed in the Radiation Protection function in Table 5-1 of the Dresden Emergency Plan from six (6) to two (2) is acceptable. As discussed above , the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced as compared to an operating plant. The RP Technicians are supported with the additional on-shift RP Technician and the On-Site Field Team position.

Additional RP Technicians are available, and time is available to call in additional personnel should conditions warrant. The risk in the permanently shutdown and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving operating reactors provides additional time to plan and execute assessment and mitigation actions.

Page 17 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES 5.3.4 Emergency Preparedness Function: Supervision of Radiation Protection Staff and Site Radiation Protection Major Tasks Evaluate and assess plant and offsite radiological data in the development of onsite protective actions and offsite PARs, until relieved.

Recommend onsite protective actions and offsite PARs to the applicable decision-maker, until relieved.

Direct all radiation protection activities, including field monitoring team (FMT) direction, until relieved .

Provide relevant information to applicable communicators who are communicating offsite PARs to OROs, until relieved.

a. ON-SHIFT There are no changes to the on-shift staffing for this function.

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

5.3.5 Emergency Preparedness Function: Dose Assessment I Projections Major Tasks Perform dose assessments/projections and provide input to applicable PAR decision-maker, until relieved.

a. ON-SHIFT There are no changes to the on-shift staffing for this function .

The Dose Assessment Function is re-assigned to the Operations Crew. The elimination of one RP Technician position does not impact the ability of the on-shift staff to perform the initial dose assessment. The analysis of proposed post-shutdown On-Shift Staffing Assessment concluded that in a permanently defueled condition, the Operations crew can perform all required Dresden Emergency Plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions . Operations staff can perform initial dose assessment using existing Emergency Preparedness Implementing Procedures (EPIPs).

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

Page 18 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES 5.3.6 Emergency Preparedness Function: Emergency Classifications Major Tasks Evaluate plant conditions and recommend emergency classifications, until relieved.

a. ON-SHIFT Current Requirements The On-Shift ERO consists of the following position:

Emergency Classification Advisor 1 Note 1. Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

Proposed Changes Eliminate the Emergency Classification Advisor position .

Analysis This function of the Emergency Classification Advisor is to evaluate plant conditions and recommend emergency classifications, until relieved .

Dresden will no longer be an operating nuclear power plant. In accordance with 10 CFR 50.82(a)(1 ), pursuant to 10 CFR 50.82(a)(2), the Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels . With irradiated fuel being stored in the SFPs and ISFSI, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced as compared to an operating plant. The risk in the permanently shutdown and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible, and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions.

With the reduced spectrum of credible accidents and operational events, the need for an Emergency Classification Advisor to assist the Emergency Director is no longer needed.

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

5.3.7 Emergency Preparedness Function: Engineering Major Task:

Provide engineering coverage related to the specific discipline of the assigned engineer, until relieved .

Page 19 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

a. ON-SHIFT Current Requirements The current Dresden Emergency Plan staffs one (1) Core/ Thermal Hydraulics Engineer

- STA to evaluate reactor conditions.

Proposed Changes Exelon proposes to eliminate the Core/Thermal Hydraulics Engineer - STA from the on-shift staffing.

Analvsis The emergency planning function of the Core/Thermal Hydraulic Engineer - STA is to provide confirmation of adequacy of core cooling , maintenance of coolable core geometry, and to verify that actual plant response to the event is as expected. This function is initially performed by the Core/Thermal Hydraulics Engineer- STA under the guidance of the Operations Shift Manager.

Because of the permanent cessation of operations and removal of fuel from the reactor vessels, Exelon proposes to eliminate the Core/Thermal Hydraulics Engineer - STA position from the emergency plan, since this condition no longer makes the position necessary for technical and analytical assistance for plant operational concerns during abnormal and emergency situations or analysis of events and their effects. The position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary in a permanently shutdown and defueled condition.

The NRC requires that Dresden's Emergency Plan be at a level of effectiveness commensurate with the potential consequences to public health and safety and common defense and security at the Dresden site . With the permanent cessation of operations and the permanent removal of the fuel from the reactor vessels at Dresden, most of the accident scenarios postulated for operating power reactors are no longer possible. The irradiated fuel is stored in the SFPs or at the ISFSI and will remain on-site until it can be moved offsite for long-term storage or disposal. The reactors , Reactor Coolant Systems (RCSs), and reactor support systems are no longer in operation and have no functions related to the storage of the irradiated fuel. Therefore, postulated accidents involving a failure or malfunction of the reactors, RCSs, or reactor support systems are no longer applicable. During reactor decommissioning , the principal public safety concerns involve the radiological risks associated with the storage of irradiated fuel on-site. The proposed level of on-site Operations staff will continue to provide for communication and coordination capabilities with offsite organizations for the level of support required for the remaining DBAs and the prompt implementation of mitigative actions in response to an SFP accident. The Shift Manager/Certified Fuel Handler (CFH) will maintain the capability to perform the function of on-shift technical analysis for the limited applicable accident scenarios associated with the storage of irradiated fuel.

The on-shift technical support function for the remaining accident scenarios associated with the storage of irradiated fuel will be assumed by the Control Room personnel.

Dresden's post-shutdown OSA validated that the on-shift Shift Manager/CFH can Page 20 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES perform any required technical analysis associated with the storage of irradiated fuel until augmented as needed.

Additionally, Dresden "License Amendment Request - Proposed Changes to Technical Specifications Sections 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition" (Reference 8.2), has been submitted to delete the STA from the Dresden Technical Specifications.

b. AUGMENTED ERO Current Requirements The current Dresden Emergency Plan staffs the following TSC Engineering Staff positions:

Electrical/Instrumentation and Control (l&C) - Provide engineering coverage for the ERO related to electrical or l&C equipment Mechanical - Provide engineering coverage for the ERO related to mechanical equipment Core/Thermal Hydraulics - Evaluate reactor conditions Proposed Changes Dresden proposes to combine the above TSC Engineering Staff positions into a single TSC Engineer position:

TSC Engineer - Provide engineering coverage for the ERO Analvsis With the permanent cessation of operations and the permanent removal of the fuel from the reactor vessels at Dresden, most of the accident scenarios postulated for operating power reactors are no longer possible. As such, the number and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced, as compared to an operating plant. The set of plant equipment required for a permanently defueled condition is also greatly reduced, which also reduces the spectrum of mitigation activities for an emergency.

The Engineering function will be provided by the TSC Engineer position . The TSC Engineer will be trained to provide engineering support in response to a fuel handling accident or an event resulting in damage to the SFP integrity or loss of SFP cooling or inventory.

Elimination of the TSC Core Thermal/Hydraulic Engineer The elimination of the Core Thermal/Hydraulic Engineer position will have no effect on emergency response in a permanently defueled condition because the position is primarily responsible to assess the condition of fuel in a reactor core during an emergency. TSC Core Thermal/Hydraulic Engineers have expertise in the area of core Page 21of43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES damage assessment and core parameter monitoring. The Core Damage Assessment Tool used by the TSC Core Thermal/Hydraulic Engineers does not address assessments of SFP fuel damage.

However, the Dose Assessment Program utilized by the Dose Assessment Coordinator does include in its assessment, irradiated fuel damage in the SFPs. The information to support the Dose Assessment program is not specific to the TSC Core Thermal/Hydraulic Engineer qualification and can be provided by the TSC Engineer or the Operations Manager. The information includes information such as age of fuel, location , or whether the fuel is exposed or covered by water.

The Core Thermal/Hydraulic Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary in a permanently shutdown and defueled condition. A review of major tasks of the Core/Thermal Hydraulics Engineer is provided in , and no essential tasks were identified to support Emergency Planning Functions.

Mechanical/Electrical/Instrumentation & Control Engineer The primary duties of the TSC Engineer positions include responding to engineering requests from the TSC Emergency Director and assisting the OSC in preparing to send repair teams into the plant. The specific Mechanical and Electrical/l&C Engineer positions in the TSC are being combined into the TSC Engineer position. The position will be filled by a trained engineer.

The TSC Engineer can provide the initial response to an emergency condition. In accordance with the site training program , engineers receive general training in the station's mechanical , electrical and l&C systems, as well as training in print reading and troubleshooting methods. The combination of the TSC Engineer positions into the single engineer is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently shutdown and defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.

Additional engineering resources will continue to be available as augmented positions, video consultation, or remote response.

The assessment and disposition of specific responsibilities and tasks for the TSC Engineers is addressed in Attachment 4 of this submittal. It is concluded that the Core/Thermal , Mechanical, and Electrical/l&C Engineers' responsibilities and tasks can be maintained by the TSC Engineer. As such , TSC Engineer positions can be reduced without impacting Exelon's ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor. If additional engineering support is identified as needed at any time during the response to the emergency condition, engineering support can be obtained through call-outs, video conferencing , or remote work support. The engineering staff has the capability to respond remotely with access to the station procedures and drawings.

Page 22 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES The proposed change to the level of augmented ERO staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50, commensurate with the reduced spectrum of credible accidents in the permanently defueled condition, and ensures that Dresden retains the ability to promptly implement the SFP mitigation actions.

5.3 .8 Emergency Preparedness Function: Security Major Tasks Coordinate security-related activities and information with the Emergency Coordinator.

a. ON-SHIFT There are no changes to the on-shift staffing for this function.

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

5.3.9 Emergency Preparedness Function: Repair Team Activities Major Tasks Provide support for event mitigation and equipment repair.

Provide assistance with logic manipulation, support for event mitigation and equipment repair, and support of digital l&C if applicable (l&C).

a. ON-SHIFT There are no changes to the on-shift staffing for this function.

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

5.3.10 Emergency Preparedness Function: Supervision of Repair Team Activities Major Tasks Supervise OSC activities

a. ON-SHIFT There are no proposed changes to this on-shift function.

Page 23 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

b. AUGMENTED ERO Current Requirements The current Dresden Emergency Plan staffs the following OSC Supervision of Repair Team Activities Staff positions:

(1) OSC Director - Supervise OSC activities as directed by Emergency Coordinator OSC Supervisors (1) Electrical Maintenance Supervisor /Lead@ 90 mins: Supervise OSC activities related to electrical equipment.

(1) Mechanical Maintenance Supervisor I Lead @ 90 mins: Supervise OSC activities related to mechanical equipment.

(1) l&C Supervisor I Lead@ 90 mins: Supervise OSC activities related to l&C equipment. May be combined with Electrical Supervisor.

(1) Radiation Protection Supervisor I Lead @ 90 mins: Supervise OSC activities related to radiation protection .

Proposed Changes Exelon proposes to eliminate the following Supervision of Repair Team Activities positions:

(1) Electrical Maintenance Supervisor /Lead@ 90 mins: Supervise OSC activities related to electrical equipment.

(1) Mechanical Maintenance Supervisor I Lead @ 90 mins: Supervise OSC activities related to mechanical equipment.

(1) l&C Supervisor I Lead@ 90 mins: Supervise OSC activities related to l&C equipment. May be combined with Electrical Supervisor.

Exelon proposes to revise the following position to allow this to be assigned as a collateral duty for an RP Technician:

(1) Radiation Protection Supervisor I Lead 1 Note 1. Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

Analvsis Exelon proposes to eliminate the Mechanical Maintenance, Electrical Maintenance and l&C Supervisor I Lead positions. Exelon will maintain the OSC Director position and the Radiation Protection Supervisor/Lead function.

The OSC Director will provide overall supervision and direction to the initial OSC responders . If at any time the OSC Director determines that additional support is Page 24 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES necessary to accomplish the mission of the OSC, the OSC Director will contact the EOF to arrange for support by additional personnel.

Dresden ERO staffing , as required by the Dresden Emergency Plan, is intended to address the risks to public health and safety inherent in operating reactors . The risk in the permanently shutdown and defueled condition is significantly reduced. Many of the potential initiating conditions that would lead to an emergency declaration will no longer be credible. The set of plant equipment required in the permanently shutdown and defueled condition is also greatly reduced, which reduces the assessments and mitigation activities that the OSC must perform. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for safe storage of irradiated fuel is reduced, as compared to operating power reactors.

The primary events of concern in the immediate post-shutdown and defueled condition will be an FHA or a loss of SFP cooling and/or water inventory. Restoration of equipment supporting irradiated fuel cooling and inventory will be the primary focus of emergency mitigation actions for the TSC/OSC in a permanently shutdown and defueled condition.

In the permanently shutdown and defueled condition, there is no longer any complex automatic control systems in service. The OSC Technician response is reduced , and therefore , the need for direct oversight of each of the OSC Maintenance disciplines can be performed by the OSC Director given the reduced spectrum of credible accidents and operational events. The OSC Director will continuously evaluate the need for resources and call in additional qualified personnel, as needed. OSC resources will continue to be augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. Note that the RP Technicians' response will be supported by the Radiation Protection Supervisor I Lead function.

The proposed change to the level of ERO staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, commensurate with the reduced spectrum of credible accidents in the permanently defueled condition, and ensures that Exelon retains the ability to promptly implement SFP mitigation actions.

5.3.11 Emergency Preparedness Function: Field Monitoring Teams (FMTs)

Major Tasks Assess the protected area for radiation and contamination and provide input to the TSC Radiation Protection Manager (RPM). Responsible for radiation protection coverage for the FMTs as directed by TSC RPM or EOF RPM.

Assess the area(s) outside the protected area for radiation and contamination, and for radioactive plume tracking , as directed by, and under the control of, the EOF DAC or RPM. Responsible for the radiation protection coverage of the FMTs as directed by EOF RPM.

Page 25 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

a. ON-SHIFT There are no changes to the on-shift staffing for this function.

b. AUGMENTED ERO Current Requirements The current Dresden Emergency Plan staffs the Onsite Field Team member as one (1)

Qualified individual to assess the protected area for radiation and contamination and provide input to the TSC RPM.

Proposed Changes The staffing of the position is revised to one (1) RP Personnel to assess the protected area for radiation and contamination and provide input to the TSC RPM.

Analysis The staffing of the Onsite Field Monitoring position is revised from a Qualified individual to specify RP Personnel. RP Personnel consists of persons with an ANSI qualification.

This includes RP Techn icians or qualified RP Staff members. This is consistent with the guidance provided in the NRC's Technical Basis for the Proposed Guidance in NUREG-0654/FEMA-REP-1, Section 11.B, "Emergency Response Organization" (Reference 8.17). The revision of this requirement allows for the Onsite Survey RP person to support other station RP responsibilities during the emergency if needed.

5.3.12 Emergency Preparedness Function: Media Information Major Tasks Manage and coordinate media information related to the event.

a. ON-SHIFT There are no changes to the on-shift staffing for this function .

b. AUGMENTED ERO There are no changes to the augmented staffing for this function .

5.3.13 Emergency Preparedness Function: JIC/EOF Information Technology (IT)

a. ON-SHIFT There are no changes to the on-shift staffing for this function.

Page 26 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

b. AUGMENTED ERO There are no changes to the augmented staffing for this function.

5.4 Dresden Emergency Plan ERO Changes - ERF Analysis 5.4.1 Control Room For Dresden, the Emergency Plan commitment for minimum staffing is based on the 2019 "Issuance of Amendments to Revise the Emergency Response Organization Staffing Requirements," dated March 21, 2019 (Reference 8.15).

As described in Section 11.H of the Dresden Emergency Plan, EP-DR-1000, the Control Room is the centralized on-site location from which Dresden's plant systems are monitored. The Control Room is equipped with the instrumentation to supply detailed information on the plant systems. The Control Room is continuously staffed with qualified operators. The Control Room is the first onsite facility to become involved with the response to emergency events. Control Room personnel must evaluate and effect control over the emergency and initiate activities necessary for coping with the emergency and initiate activities necessary for coping with the emergency until such time that support centers can be activated.

The proposed on-shift staffing changes were evaluated using the Functional Area Analysis of the NUREG-0654 Table B-1, Revision 2, Functions. With the permanent cessation of operations and the permanent removal of the fuel from the reactor vessels at Dresden, most of the accident scenarios postulated for operating power reactors are no longer possible. The irradiated fuel is stored in the SFPs or at the ISFSI, and will remain on-site until it can be moved offsite for long-term storage or disposal. The reactors, RCSs, and reactor support systems are no longer in operation and have no function related to the storage of the irradiated fuel. Therefore, postulated accidents involving a failure or malfunction of the reactors, RCSs, or reactor support systems are no longer applicable. During facility decommissioning, the principal public safety concerns involve the radiological risks associated with the storage of irradiated fuel on-site. The proposed level of on-site operations staff will continue to provide for communication and coordination capabilities with offsite organizations for the level of support required for the remaining DBAs and the prompt implementation of mitigative actions in response to an SFP accident.

The Functional Analysis (Section 5.3) concluded that the proposed on-shift staffing changes do not impact the capabilities of the on-shift staff to respond to an emergency and continues to comply with the Emergency Plan , site commitments and regulations.

On-Shift Staffing Assessment To support ERO staffing changes following permanent cessation of operations and permanent removal of fuel from the reactor vessels, the Post-Shutdown On-Shift Staffing Assessment was evaluated in conjunction with the postulated accidents previously evaluated using NEI 10-05 methodology. The Post-Shutdown On-Shift Staffing Assessment results validated the following changes to the Dresden on-shift staff.

Page 27 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Note that changes in position titles (e.g., Non-Certified Operator (NCO), Certified Fuel Handler (CFH), respectively) are consistent with proposed changes to the Dresden Technical Specifications (TS) (Reference 8.2) that revise the minimum shift staffing requirements at Dresden by replacing references to licensed and non-licensed operators with references to CFHs and NCOs.

The term NCO is used to differentiate from CFH. CFHs will supervise/perform fuel handling operations in the permanently defueled condition. Shift Managers (SMs) will be qualified as CFHs. Therefore, any reference to the SM position throughout this submittal is considered to encompass the CFH position requirements . NCOs will perform duties typically associated with those performed by Auxiliary Operators (AO),

such as manipulation and monitoring of plant equipment. NCOs can also be assigned to monitor indications and communications in the Control Room . The NCO position may be filled by a Certified Fuel Handler (CFH).

Current On-Shift Staff Post Shutdown On-Shift Staff (1) Shift Manager (1) Shift Manager/CFH(1 l (1) Control Room Supervisor (1) NCQ(1l (1) Shift Technical Advisor (1) NCQ(1l (3) Reactor Operators (1) EP Communicator (4) Equipment Operators (1) RP Technician (1) EP Communicator (*) Fire Brigade (per the Fire Plan)

(2) RP Technicians (1) Core/Thermal Hydraulics Engineer - STA(2 l (1) Emergency Classification Advisor(2 l

(*) Fire Brigade (per the Dresden Fire Plan)

Total = 13 plus Fire Brigade Total = 5 plus Fire Brigade r1! Titles are consistent with changes to Technical Specifications. Non-Certified Operators (NCO) will perform duties typically associated with those performed by Auxiliary Operators (AO) and Reactor Operators (RO) , such as manipulation and monitoring of plant equipment. NCOs are also qualified to perform EP Communications (ENS/State Local Notifications) . The NCO position may be filled by a Certified Fuel Handler (CFH) .

The SM will be qualified as a CFH. However, the SM requires additional qualification to perform Emergency Director responsibilities beyond the CFH training.

r2! Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time Page 28 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES The OSA validated that in a permanently defueled condition one (1) on-shift SM (CFH),

one (1) RP Technician, two (2) NCOs, one (1) EP Communicator, and fire brigade members can perform all required Emergency Plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of Emergency Plan functions.

Specifically, Dresden will no longer be an operating nuclear power plant. In accordance with 10 CFR 50.82(a)(1 ), pursuant to 10 CFR 50.82(a)(2), the Part 50 licenses will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels. With irradiated fuel being stored in the SFP and ISFSI, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of irradiated nuclear fuel is reduced as compared to an operating plant. The risk in the permanently shutdown and defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. As such, the following On Shift positions can be removed:

Control Room Supervisor Shift Technical Advisor Reactor Operators Core/Thermal Hydraulics Engineer - STA Emergency Classification Advisor Exelon will ensure a sufficient number of personnel are initially trained to support the on-shift positions prior to implementation of the post shutdown Emergency Plan.

Consistent with the methodology of NEI 10-05, the present Emergency Plan OSA evaluated postulated accident scenarios. Chapter 15 of the Dresden UFSAR describes the Abnormal Operational Transients and OBA scenarios that are applicable during plant operations. Upon the submittal of the certifications required by 10 CFR 50.82(a)(1 ), the 10 CFR 50 licenses for Dresden , Units 2 and 3 will no longer authorize operation of the reactors or emplacement or retention of fuel into the reactor vessels , as specified in 10 CFR 50.82(a)(2). Therefore, most of the accident scenarios postulated in the UFSAR will no longer be applicable once Dresden is in the permanently defueled condition.

The primary events of concern in the immediate post-shutdown and defueled condition will be an FHA or a loss of SFP cooling and/or water inventory.

Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of normal and emergency SFP inventory makeup strategies and mitigating strategies required under Dresden , Unit 2 License Condition 2.C.(18) and Unit 3, License Condition 3.AA, "Mitigation Strategy License Condition" and 10 CFR 50.155(b )(2).

Page 29 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES The following scenarios were evaluated for Dresden in the Post-Shutdown OSA:

Design Basis Threat - The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release , and no fire that requires firefighting response before the ERO is staffed.

Aircraft Potential Threat (50 .54(hh)) - Notification is received from the NRC that a potential aircraft threat exists.

Fire Requiring Fire Brigade Response and EAL Classification - A fire occurs in the facility requiring entry into the Emergency Plan and dispatch of the Fire Brigade.

Fuel Handling Accident (FHA) - The postulated design basis accident that will remain applicable to Dresden in its permanently shutdown and defueled condition is the FHA in the Reactor Building where the SFPs are located.

FHA General Emergency (GE) with radioactive release and Protective Action Recommendation (PAR) (assumed for analysis purposes) - This event is based on the same initial conditions as the FHA, but assumes a dose that exceeds the EPA PAGs beyond the site boundary, and thus necessitates promulgation of a PAR.

The OSA validated that in a permanently defueled condition one (1) on-shift SM (CFH),

one (1) RP Technician, two (2) NCOs, one (1) EP Communicator and station fire brigade members can perform all required Emergency Plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of Emergency Plan functions.

5.4.2 Augmented ERO Staff The Dresden Emergency Plan identifies Minimum Staff as those ERO members needed to support Facility Activation . A facility is activated only after it reaches minimum staff and is available to perform its designed functions.

In the permanently defueled condition , Dresden will maintain multiple ERO teams.

When the SM directs the activation of the ERO call out system , all ERO members on all teams are notified and are directed to respond to ensure adequate coverage of all ERO positions at all ERFs.

Exelon requires members to act promptly in reporting to their assigned ERF. All ERO staff are trained to respond directly to their ERF if available. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift. This conservative policy ensures timely activation . The proposed revisions to the Emergency Plan will not change these requirements. It will continue to be a management expectation that all qualified individuals for each position respond and report to their respective ERF as quickly as possible. EP procedures identify ERO positions assigned to each facility and the minimum staffing required before each facility can be declared operational and is available to perform its designed functions.

Page 30 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES The EP procedures will continue to assign responsibilities to ERO responders, with the purposes of removing the responsibilities of coordinating with offsite responders and delivering information to the public from the Control Room, allowing operations personnel to focus on returning the plant to a safe condition.

The risk in the permanently defueled condition is significantly reduced. Many of the potential initiating conditions that would lead to an emergency declaration will no longer be credible. The set of plant equipment required in the permanently defueled condition is also greatly reduced , which reduces the assessments and mitigation activities the ERO staff (TSC/OSC/EOF) must perform. Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC/OSC staff in a permanently shutdown and defueled condition . Although ERO activation/response time requirements will be unchanged , the elimination of accidents involving operating reactors provides additional time to plan and execute assessment and mitigation actions.

5.4.3 Technical Support Center As described in Section 11.H of the Dresden Emergency Plan, the TSC is the on-site location utilized to support the Control Room for assessment of plant status and potential offsite impact, and for implementation of emergency actions. The TSC provides technical data and information to the EOF.

The proposed changes to the Dresden Emergency Plan do not involve any physical modifications to, or layout/configuration changes , or relocation of the TSC . The TSC meets the requirements of NUREG-0696 for size and habitability, including a filtered heating , ventilation and air conditioning (HVAC) system that can be isolated in the event of a radiological accident.

The proposed changes to the TSC Minimum Staff do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency.

Appropriate assessment and mitigation are well within the capabilities of the proposed TSC staff provided in Table 5.1.

Table 5.1 Emergency Response Organization TSC Minimum Staffing Positions Current Minimum Staff Positions Proposed Minimum Staff Positions (response times are 60 minutes unless otherwise noted)

Station Emergency Director Station Emergency Director Radiation Protection Manager Radiation Protection Manager Operations Manager Operations Manager ENS Communicator ENS Communicator Security Coordinator Security Coordinator Core Thermal Engineer (Position Eliminated)

Mechanical Engineer (Position Eliminated)

Page 31of43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Electrical Engineer (Position Eliminated)

TSC Engineer (position added)

The functional analysis in Section 5.3 provided justification for the elimination of key TSC Minimum Staffing Positions. ERO tasks have been reviewed and tasks for eliminated positions will be transferred appropriately. The analysis of the ERO staff tasks assigned by the Emergency Plan is found in Attachment 4 of this submittal.

Attachment 4 evaluates and dispositions each EP task as being reassigned or eliminated and provides justification , as appropriate. It is ascertained from the Attachment 4 assessment, that given the elimination of credible accidents involving operating reactors , the proposed ERO Minimum Staff can continue to satisfactorily perform their existing Emergency Plan responsibilities as well as any transferred responsibilities .

5.4.4 Operations Support Center (OSC)

As described in Section 11.H of the Dresden Emergency Plan , the OSC is the on-site location where station support personnel report during and emergency and from which they will be dispatched for assignments or tasks in support of emergency operations.

The proposed changes to the Dresden Emergency Plan do not involve any physical modifications to, or layout/configuration changes to the OSC.

In the permanently shutdown and defueled condition, the primary functions of the OSC will remain dispatching of, and accounting for, Repair and Corrective Action Teams .

The OSC Director is responsible for ensuring adequate staffing of the OSC supporting the emergency; working with the TSC staff to set priorities for the OSC; and directing the activities of the OSC to support the emergency response .

The proposed staffing to the OSC Minimum Staff does not impact the ability to respond to issues related maintaining irradiated fuel in the SFPs. Appropriate repair and corrective action capability are provided by the OSC Minimum Staff provided in Table 5.2.

Table 5.2 Emergency Response Organization OSC Minimum Staffing Positions Current Minimum Staff Positions Proposed Minimum Staff Positions (response times are 60 minutes unless otherwise noted)

OSC Director OSC Director RP Personnel #1 RP Personnel #1 RP Personnel #2 RP Personnel #2 RP Personnel #3 (Position Eliminated)

RP Personnel #4 @ 90 Min (Position Eliminated)

RP Personnel #5 @ 90 Min (Position Eliminated)

RP Personnel #6 @ 90 Min (Position Eliminated)

Mechanical Maintenance Tech Mechanical Maintenance Tech Page 32 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Electrical Maintenance Tech Electrical Maintenance Tech l&C Tech @ 90 Min l&C Tech @ 90 Min Mechanical Maintenance Supv/Lead @ 90 (Position Eliminated)

Min Electrical Maintenance Supv/Lead @ 90 (Position Eliminated)

Min l&C Supv/Lead @ 90 Min (Position Eliminated)

RP Supv/Lead @ 90 Min RP Supv/Lead - Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

Offsite Field Team #1 Personnel Offsite Field Team #1 Personnel Offsite Field Team #1 Driver Offsite Field Team #1 Driver Offsite Field Team #2 Personnel @90 Min Offsite Field Team #2 Personnel @90 Min .

Offsite Field Team #2 Driver@90 Min Offsite Field Team #2 Driver @90 Min.

On-site Field Team #1 Personnel On-site Field Team #1 RP Personnel (onsite surveys) (onsite surveys)

The functional analysis in Section 5.3 provided justification for the elimination of key OSC Minimum Staffing Positions. ERO tasks have been reviewed and tasks for eliminated positions will be transferred appropriately. The analysis of the ERO staff tasks assigned by the Emergency Plan is found in Attachment 4 of this submittal. The Attachment evaluates and dispositions each EP task as being reassigned or eliminated and provides justification , as appropriate. It is ascertained from the assessment, that given the elimination of credible accidents involving operating reactors , the proposed ERO Minimum Staff can continue to satisfactorily perform their existing Emergency Plan responsibilities as well as any transferred responsibilities.

Dresden ERO staffing , as required by the Dresden Emergency Plan , is intended to address the risks to public health and safety inherent in operating reactors . The risk in the permanently shutdown and defueled condition is significantly reduced. Many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible. The set of plant equipment required in the permanently shutdown and defueled condition is also greatly reduced, which reduces the assessments and mitigation activities that the OSC must perform. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for safe storage of irradiated fuel is reduced , as compared to operating power reactors. Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC/OSC in a permanently shutdown and defueled condition.

The proposed staffing can respond to the expected repair activities with adequate RP oversight.

The primary events of concern in the immediate post-shutdown and defueled condition will be an FHA or a loss of SFP cooling and/or water inventory. Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of the SFP Page 33 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES inventory makeup strategies, as required under Dresden, Unit 2, License Condition 2.C.(18) and Unit 3, License Condition 3.AA, "Mitigation Strategy License Condition" and 10 CFR 50.155(b)(2). OSC staff is not relied upon to implement SFP inventory makeup.

The proposed change to the level of ERO staffing continues to meet the planning standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, commensurate with the reduced spectrum of credible accidents in the permanently defueled condition, and ensures that Exelon retains the ability to promptly implement SFP mitigation actions.

5.4.5 Emergency Operations Center (EOF)

As described in Section 11.H of the Dresden Emergency Plan, the EOF is the location where the Corporate Emergency Director will direct a staff in evaluating and coordinating the overall company activities involved with an emergency.

The EOF is located west of Chicago, in Warrenville IL, in the Exelon Nuclear Cantera facility. This facility supports the Braidwood, Byron, Clinton, Dresden, LaSalle and Quad Cities stations. The EOF facility is shared between the six nuclear plants. The EOF staffing for Dresden will align with the Exelon Fleet EOF staffing levels. The proposed changes to the Dresden Emergency Plan do not involve any physical modifications to, or layout/configuration changes to the EOF.

There are no proposed changes to the EOF Minimum Staff. Appropriate assessment and mitigation are well within the capabilities of the EOF minimum staff provided in Table 5.3.

Table 5.3 Emergency Response Organization EOF Minimum Staffing Positions Dresden Operational ERO Dresden Post-Shutdown ERO Minimum Staff Positions Minimum Staff Positions Corporate Emergency Director Corporate Emergency Director State I Local Communicator State I Local Communicator Radiation Protection ManaQer Radiation Protection ManaQer Dose Assessment Coordinator Dose Assessment Coordinator Computer Specialist @ 90 min Computer Specialist @ 90 min 5.4.6 Joint Information Center (JIC)

As described in Section 11.G of the Dresden Emergency Plan, the JIC is the facility in which media personnel gather to receive information related to the emergency event.

The JIC is the location where approved news releases will be provided to the media for dissemination to the public.

The JIC is located west of Chicago, in Warrenville IL, in the Exelon Nuclear Cantera facility. This facility supports the Braidwood, Byron, Clinton, Dresden, LaSalle and Quad Cities stations. The JIC facility is shared between the six nuclear plants. The JIC staffing for Dresden will align with the Exelon Fleet JIC staffing levels . The proposed Page 34 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES changes to the Dresden Emergency Plan do not involve any physical modifications or layout/configuration changes to the JIC.

The JIC Minimum Staffing as shown in Table 5.4 and has not been changed.

Table 5.4 Emergency Response Organization JIC Minimum Staffing Positions Current Minimum Staff Positions Proposed Minimum Staff Positions (response times are 90 minutes)

JIC Director J IC Director Corporate Spokesperson Corporate Spokesperson Public Information Director Public Information Director 5.5 Assessment of Staff Changes on Offsite Emergency Response Organizational Interfaces The proposed changes to the Dresden Emergency Plan were evaluated for impacts on the ability of State and local response organizations to effectively implement their FEMA-approved Radiological Emergency Plans.

The following list of additional actions involve support or direct interface with the State of Illinois, are not being revised and will continue to be performed by ERO positions as currently assigned and shown in Attachment 4.

1. Corporate Emergency Director - Following assumption of Command and Control, ensure that Federal , state and local authorities and industry support agencies remain cognizant of the status of the emergency situation . If requested , dispatch informed individuals to offsite governmental Emergency Operation Centers (EOCs).

2. EOF Radiation Protection Manager - Ensure State authorities are provided information pertaining to Exelon Field Monitoring Teams activities and sample results.

3. JIC Corporate Spokesperson - Coordinate with Federal, State and local agencies, as well as with other organizations involved in the emergency response , to maintain factual consistency of information to be conveyed to the news media/public.

4. JIC Director - Coordinate with Federal, State and local agencies, as well as with other organizations involved in the emergency response, to maintain factual consistency of information to be conveyed to the news media/public.

5. State/Local Communicator - Communicate and receive information via the Nuclear Accident Reporting System (NARS) circuit or commercial telephone line with appropriate state and county agencies.

Although the State EOC liaisons/communicators were previously removed from the Dresden Emergency Plan (Reference 8.15) and will be managed and controlled by EPIPs, they are still available to be dispatched per Corporate Emergency Director discretion.

Page 35 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Exelon also concluded there were no interface or coordination impediments identified because of the change to the Dresden Emergency Plan.

A preliminary review of the proposed changes prior to the formal submission of the LAR has been performed by the Illinois Emergency Management Agency.

5.6 Validation and Training To validate the results of the analysis, a drill will be developed and conducted prior to implementation of the changes described within this LAR. The drill will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drill will evaluate and validate the ability to accomplish the stated mission of each ERF and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drill will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the Dresden Emergency Plan, site commitments, and applicable regulations . Implementing procedures will be revised to address the permanently shutdown and defueled conditions. The revised procedures will be used to support training of the ERO staff and the conduct of drills described above.

Training and procedures will be developed and in place prior to performing the post-shutdown ERO drill. The drill scenario will include SFP events and will be designed to test the major elements of the Dresden post shutdown Emergency Plan . Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, local, and Federal response organizations will be provided the opportunity to participate in or observe the drills, as specified in the commitment in Attachment 5.

Also as provided in Attachment 5, other training drills will be conducted to train post-shutdown station ERO members. These drills may not involve all Exelon ERFs or State/local participation; however, all ERO members will participate in at least one training drill. The post shutdown EP procedures which support the defueled condition will be available in draft form to support the drills. Final implementation of the procedures will occur concurrent with implementation of the post shutdown emergency plan.

5.7 ERO Change Summarv Exelon completed an evaluation of the proposed reduction in on-shift and ERO staffing and completed a post-shutdown OSA for Dresden to validate the ability of the proposed defueled on-shift to respond to an emergency. Exelon further assessed the ability of the ERO augmented staff to respond to an emergency through a Task Analysis.

The proposed ERO staffing changes do not impact the capabilities of the on-shift staffing or augmented response. The ERFs will continue to be activated at an Alert or higher classification. Functional responsibilities of the positions eliminated as a result of the changes described within are being reassigned to remaining positions or eliminated if no longer applicable to the permanently defueled condition. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the Emergency Plan, site commitments, and regulation.

Page 36 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES The proposed changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency and the ability to promptly implement SFP mitigation actions. Appropriate assessment and mitigation actions are within the capabilities of the reduced ERO staff.

6.0 REGULATORY EVALUATION

6.1 Applicable Regulatory Requirements On-Shift and ERO Staffing The specific standards for establishing an onsite emergency organization to respond to emergency events appears in 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. Specifically:

• 10 CFR 50.47(b)(1) states in part that: " .. .each principal response organization has staff to respond and to augment its initial response on a continuous basis."

• 10 CFR 50.47(b)(2) states in part that: " ... adequate staffing to provide initial facility accident response in key functional areas is maintained at all times," and that "timely augmentation of response capabilities is available .... "

• 10 CFR 50, Appendix E, Section IV, Part A, "Organization," states in part that: "The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization ...."

• 10 CFR 50, Appendix E, Section IV.A.1 : [Emergency Plans must contain] "A description of the normal plant operating organization."

• 10 CFR 50, Appendix E, Section IV.A.2: [Emergency Plans must contain] "A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a. Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency;

b. Plant staff emergency assignments;

c. Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures."

• 10 CFR 50, Appendix E, Section IV.A.9 states that licensees shall perform " ... a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan ."

Page 37 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES Guidance Regulatory Guide 1.101 (RG 1.101 ), Revision 4, "Emergency Planning and Preparedness for Nuclear Power Reactors" (Reference 8.7), Section C, states in part, The criteria and recommendations in Revision 1 of NUREG-0654/FEMA-REP-1 ,

"Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (November 1980),

are methods acceptable to the NRG staff for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans.

These criteria provide a basis for NRG licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness.

In NUREG-0654 (Reference 8.3),Section II, "Planning Standards and Evaluation Criteria," Evaluation Criteria 11.B.1and11.B.5 address the 10 CFR 50.47(b)(2) planning standard . Evaluation Criterion 11.B.1 specifies the on-site emergency organization of plant staff personnel for all shifts, and its relation to the responsibilities and duties of the normal staff complement. Evaluation Criterion 11.B.5 states in part that:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies. " The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1 .

NSIR/DPR-ISG-01 , "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants" (Reference 8.5) provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," (Reference 8.6) is an acceptable methodology for performing the staffing analysis. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," (Reference 8.8), describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.54(q). In Section 2.a.(1 ),

the NRC encourages licensees to arrange a conference call with the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for EP changes that increase the activation time of emergency response facilities.

Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1 (Reference 8.9) was issued by the NRC to clarify the meaning of "decrease in effectiveness" and the process for making changes to emergency plans, and to provide some examples of changes that are considered to be a decrease in effectiveness.

Page 38 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES 6.2 Precedent The requested changes to the on-shift staffing and ERO staffing are similar in nature to the post-shutdown changes approved by the NRC and implemented by Vermont Yankee Nuclear Power Station (Reference 8.10) and Duane Arnold (Reference 8.11 ).

6.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50 .92 , Exelon Generation Company, LLC (Exelon) has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed changes would revise the Dresden Station (Dresden) Emergency Plan to reduce the number of on-shift and Emergency Response Organization (ERO) positions commensurate with the hazards associated with a permanently shutdown and defueled facility.

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

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

Response: No.

The proposed changes to the Dresden Emergency Plan do not impact the function of plant Structures, Systems, or Components (SSCs). The proposed changes do not involve the modification of any plant equipment or affect plant operation. The proposed changes do not affect accident initiators or precursors, nor do the proposed changes alter design assumptions. The proposed changes do not prevent the ability of the on-shift staff and ERO to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently defueled condition. The proposed changes only remove positions that will no longer be needed or credited in the Emergency Plan in the permanently defueled condition.

Therefore, the proposed changes do 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 changes reduce the number of on-shift and ERO positions Page 39 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES commensurate with the hazards associated with a permanently shutdown and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced. Also , the proposed changes do not result in a change to the way that the equipment or facility is operated so that no new accident initiators are created.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response : No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e. , fuel cladding , reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes do not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analyses. There are no changes 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 changes. The proposed changes are associated with the Emergency Plan and staffing and do not impact operation of the plant or its response to transients or accidents. The proposed changes do not affect the Technical Specifications. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes . Safety analysis acceptance criteria are not affected by the proposed changes and margins of safety are maintained . The revised Emergency Plan will continue to provide the necessary response staff with the proposed changes .

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and ,

accordingly, a finding of "no significant hazards consideration" is justified.

6.4 Conclusion 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 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.

Page 40 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

7.0 ENVIRONMENTAL CONSIDERATION

This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows :

{i) The amendment involves no significant hazards consideration.

As described in Section 6.3 of this evaluation, the proposed changes involve no significant hazards consideration.

{ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a change in the type or amount of effluent release offsite.

{iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, Exelon concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

8.0 REFERENCES

1. Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Dresden Nuclear Power Station, Units 2 and 3," dated September 2, 2020 (NRC Accession No. ML20246G627)

2. Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, " License Amendment Request -

Proposed Changes to Unit 1 Technical Specifications Section 6.1 ,

"Responsibility," and Units 2 and 3 Technical Specifications 1.1, "Definitions,"

and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (Accession No. ML20269A404)

3. NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, published November 1980 (Accession No. ML040420012)

Page 41 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

4. Federal Register Volume 76, Number 226, Wednesday, November 23, 2011, Rules and Regulations, "Enhancements to Emergency Preparedness Regulations; Final Rule."

5. NRC NSIR/DPR-ISG-01 , "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants," Revision 0, November 2011 (Accession No. ML113010523)

6. NEI 10-05, Rev. 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," June 2011 (Accession No. ML111751698)

7. NRC Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 4, July 2003 (Accession No. ML032020276)

8. NRC Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," Revision 0, November 2011 (Accession No. ML102510626)

9. NRC Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1, April 19, 2011 (Accession No. ML100340545)

10. Letter from U.S. Nuclear Regulatory Commission to Entergy Nuclear Operations, Inc., "Vermont Yankee Nuclear Power Station - Issuance of Amendment to Renewed Facility Operating License Re: Changes to the Emergency Plan (TAC No. MF3668)," dated February 4, 2015 (Accession No. ML14346A065)

11. Letter from U.S. Nuclear Regulatory Commission to Florida Power & Light Company, "Duane Arnold Energy Center - Issuance of Amendment No. 310 RE:

Changes to the Post-Shutdown Emergency Plan for Duane Arnold Energy Center (EPID L-2019-LLA-0075)," dated April 29, 2020 (Accession No. ML20083G008)

12. Final Response to Emergency Preparedness Frequently Asked Question 2013-008, dated January 27, 2014 (Accession No. ML14017A276)

13. NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 2, dated December 2019 (Accession No. ML193470139)

14. Letter from James Barstow, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements," dated January 31, 2018 (Accession No. ML18053A159)

Page 42 of 43

Attachment 1 DESCRIPTION AND EVALUATION OF PROPOSED CHANGES

15. Letter, USNRC to 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 To Revise The Emergency Response Organization Staffing Requirements, dated March 21, 2019. (Accession No. ML19036A586)

16. Letter from U.S. Nuclear Regulatory Commission to Ms. Susan Perkins-Grew, Nuclear Energy Institute (NEI), Alternative Guidance for Licensee Emergency Response Organizations", dated June 12, 2018. (Accession No. ML18022A352)

17. Technical Basis for The Proposed Guidance In NUREG-0654/FFEMA-REP-1, Section 11.B, "Emergency Response Organization" July 2017 (Accession No:

ML16117A427)

Page 43 of 43