ML20307A436

Attachment 2 - Tabular Summary of Proposed Changes to Site Emergency Plan

ML20307A436
Person / Time
Site:	Dresden
Issue date:	11/02/2020
From:	Exelon Generation Co
To:	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: ML20307A436 (40)

Text

Attachment 2 Dresden Station TABULAR

SUMMARY

OF PROPOSED CHANGES TO SITE EMERGENCY PLAN TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Note: Regarding the format of this table, deleted text is indicated by strike through; added text is indicated by Bold font.

EP-DR 1000 Emergency Plan Section EP-DR-1000 EP-DR-1000 Part II Section A.2.a Dresden Nuclear Emergency Response Organization EP-DR-1000 Part II Section A, Fig.

A-2 Dresden Nuclear Emergency Response Oraanization Current Wording Proposed Wording Reason for Change Note: This table provides a summary of changes to documents comprising the Dresden Emergency Plan: EP-DR-1000.

Besides the changes associated with the permanent shutdown evaluated below, there are multiple editorial changes that are proposed in this license amendment request, i.e., they do not change the intent of the document. They do not impact the ability to comply with Regulatory Guidance or level of commitments made in the Emergency Plan. These changes are marked with revision bars within the Emergency Plan (except changes to step numbers); however, they are not specifically evaluated in the change assessment, since they are editorial. These include:

Changes in step numbers as a result of information which has been relocated or deleted.

Page number changes within the Table of Contents Changes in the Table of Contents which reflect changes made within the Plan Changes in Revision numbering and Revision History IEMA Technical has both the command authority for radiological aspects of a nuclear incident and the responsibility for performing various radiological functions. These functions include milk, water and food control, radiation exposure control for state emergency workers, and confirmatory accident assessment. During an emergency situation, IEMA Technical shall make protective action recommendations to the Governor.

Figure A-2:

Agency Response Organization Interrelationships Dept of Safety I Rad Protection IEMATeel:lAieal has both the command authority for radiological aspects of a nuclear incident and the responsibility for performing various radiological functions. These functions include milk, water and food control, radiation exposure control for state emergency workers, and confirmatory accident assessment. During an emergency situation, IEMA Technical shall make protective action recommendations to the Governor.

Figure A-2:

Agency Response Organization Interrelationships DeF>t of Safety I Ras Proteetion 1

The revision replaces the reference to the IEMA Technical branch. The change was made at the request of IEMA based on changes to their Organization Structure. The IEMA Technical group no loner exists.

The revision deletes the reference to the Dept of Safety I Rad Protection group. The change was made at the request of IEMA based on changes to their Organization Structure. The Dept TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section of Safety I Rad Protection group no longer exists.

EP-DR-1000 Section B: Exelon Nuclear Emergency Res12onse Section B: ~Dresden Nuclear Emergency The revision replaces Exelon with Part 11 Section B Organization Res12onse Organization Dresden as it pertains to Nuclear This section describes the Exelon Nuclear Emergency This section describes the Dresden Nuclear Emergency Response Organization. EP Dresden Nuclear functions for the Dresden Emergency Res12onse Response Organization (ERO), its key positions and Response Organization (ERO), its key positions and Emergency Response Organization associated responsibilities. <... >

associated responsibilities. <... >.

Organization will continue to be maintained.

EP-DR-1000

1.

On Shift Emergency Response Organization

1.

On Shift Emergency Response Organization The revision replaces the Station Part II Section B.1 Assignments Assignments Vice President with the Plant The normal plant personnel complement is established Manager as having overall On Shift Emergency authority and directing the site

Response

The normal plant personnel complement is established with the Station Vise PresiEleRtPlant Manager having organization. This change is in Organization with the Station Vice President having overall authority overall authority for station operations. The Station Vise alignment with the site staffing Assignment.§ for station operations. The Station Vice President directs PresiEleRtPlant Manager directs the site organization in changes being made in the the site organization in the management of the various the management of the various departments while the Dresden Technical Specifications departments while the Shift Manager retains the Shift Manager retains the responsibility for actual (TS), Administrative Controls.

responsibility for actual operation of plant systems. <... >

operation of plant systems. <... >

License Amendment Request (LAR) 1.

EP-DR-1000 Shift Technical Advisor (STA): During normal plant Sl=tift +esl=tRisal AElvisoF (S+A }: Ql::IFiR§! ROFFRal 13laRt The revision deletes reference to Part II Section B.1 operations, the Senior Reactor Operators report to the 013eFatioRs, Hie SeRioF ReastoF 013eFatoFs Fe130Ft to Hie Shift Technical Advisor and aligns Shift Manager and directly supervise the licensed Reactor Sl=tift MaRa§leF aREI EliFestly sl::l13eFVise tl=te lieeRseEI with staffing changes in Dresden On Shift Personnel Operators and all activities in the Control Room. During ReaetoF 013erators aREI all aetivities iR tl=te CoRtrol RooFR.

TS, Administrative Controls LAR2.

an abnormal condition, the Shift Manager assumes direct Ql::lriR§ aR al:rnorFRal soREiitioR, tl=te Sl=tift MaRa§er supervision of personnel and all activities in the Control assl::IFRes Elirest Sl::l13ep,*isioR of 13ersoRRel aREI all astivities Dresden will no longer be an Room while a qualified individual steps back and iR tl=le GoRtrol RooFR wl=tile a Ejl::lalifieEI iREliviEll::lal ste13s operating nuclear power plant.

The ST A function for a assumes an overview role as an STA with the specific easl~ aREI assl::IFRes aR oveFView role as aR S+A witl=t tl=te permanently shutdown reactor is responsibility of monitoring the maintenance of core s13esifis Fes130Rsieility of FRORitoriR§ tl=te FRaiRteRaRse of no lonqer required. EP functional 1 Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changed to Unit 1 Technical Specification Section 6.1, "Responsibility," and Technical Specifications 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (NRC Accession No. ML20269A404) 2 Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changed to Unit 1 Technical Specification Section 6.1, "Responsibility," and Technical Specifications 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (NRC Accession No. ML20269A404) 2 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section cooling and containment integrity. An individual assigned eeFe eeeliR§ aR8 eeRtaiRFfleRt iRte§Fity. AR iR8ivi81:Jal requirements for Technical the duty as the ST A shall be available to the Control assi§ReEl tl=te Ell:lty as tl=te STA sl=tall 13e a"ailal31e ts tl=te Support will be performed by Shift Room at all times.

CeAtrsl ReeFfl at all tiFfles.

Manager I Certified Fuel Handler (CFH). Refer to Attachment 1, Section 5.3.7 for further discussion of the STA.

EP-DR-1000

a.

Station Emergency Response Organization

a.

Station Emergency Response Organization The revision removes reference to Part II Section B.5.a

<... > When plant conditions warrant entry into the Severe

<... > Wl=teA 13laRt eeRElitieAs warraRt eAtry iRte tl=te Severe SAMGs. SAMG scenarios are no longer applicable or required in the Station Emergency Accident Management Guidelines (SAMGs), On-shift staff AeeiEleRt MaRa§emeRt G1o1iEleliRes (SAMGs), GR sl=tift staff permanently defueled condition.

Response

or TSC Minimum staff ERO may assume the roles of or TSC MiAiml:lFfl staff E:RG Fflay assl:lFfle tl=te reles of Organization Decision-Maker and Evaluators as directed by station DeeisisR Mal(eF aREl E:val1o1ateFs as EliFeetes 13y statieR procedures.

J3FOGeSl:JFeS.

EP-DR-1000

1) Shift Manager (Shift Emergencl'. Director) - Control

1) Shift Manager (Shift Emergencl'. Director) - Control The revision reflects that the Part II Section B.5.a.1 Room Room duties of the Shift Manager no longer include shutting down the Shift Manager

<... > The Shift Manager's responsibilities, when not in

<... >The Shift Manager's responsibilities, when not in reactor or review prior to returning Command and Control, are described below:

Command and Control, are described below:

to power.

(Shift Emergency The authority and responsibility to shut down the Tl=te al:ltl=tority aREl res130Rsil3ility to sl=tl:Jt sewR tl=te Director) Control The permanent shutdown of the Room reactor when determined that the safety of the reaetor wl=teR EletermiAeEl tl=tat tl=te safety of tl=te reaeter Dresden reactors and defueled reactor is in jeopardy or when operating parameters is iR jee13aF8y OF wl=teA e13eFatiR§ 13aFameteFs exeees status makes these exceed any of the reactor protection circuit set-points aRy sf tl=te reaetor 13reteetioR eirel:lit set 13oiRts aREl responsibilities unnecessary within and automatic shutdown does not occur; al:JIOFflatie SRl:ltSOWR sees ROt OGGlJF; the Emergency Plan.

To ensure a review has been completed to determine

• Te eRSl:JFe a re 11iew l=tas 13eeR eom13lete8 ts EletermiRe the circumstance, cause, and limits under which tl=te eirel:lmstaRee, eal:lse, aREl limits l:lREler wl=tiel=t operations can safely proceed before the reactor is 013erati0Rs eaR safely 13reeeeEl 13efere tl=te reaetor is returned to power following a trip or an unscheduled retl:lmeEl to 13ower fellowiR§ a tri13 er aR tJAsel=teEll:lleEl or unexplained power reduction; SF l:JA9l~f')laiAeEl 13ewer F9Sl:JGtieA; The responsibility to be present at the plant and to Tl=te reSJ30RSil3ility to se 13reseRI at tl=te 13laAI aREl ts provide direction for returning the reactor to power 13rsviEle ElireetioR fer rell:JFRiR§ tl=te reaetor to 13ower following a trip or an unscheduled or unexplained followiR§ a tri13 OF aR l:JRSGReEll:JleEl OF l:JRex13laiAeEl power reduction ;

13ewer reEll:letieR; 3

TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section EP-DR-1000

5) Technical SU[![!Ort Staff TSC

5) Technical SU[![!Ort Staff TSC The TSC discipline specific Part II Section B.5.a.5 The TSC Technical Support Staff consists of the following The TSC Technical Support Staff consists of the following Engineering positions are being combined into the TSC Engineer Technical Support minimum staff engineering positions:

minimum staff engineering positions:

position.

Staff - TSC

- Electrical Engineer

- TSC Electrical Engineer This revision is further discussed

- Mechanical Engineer MestiaRisal ER§iReer in Attachment 1, Section 5.3. 7,

- Core/Thermal Hydraulic Engineer - serves as Core Geret+tierrnal l=lyera1:1lis ER§iReer serves as Gere Evaluation of Proposed Changes.

Damage Assessment Methodology (CDAM) Evaluator, as Qarna§e AssessrneRt Mettieeele§y (GQAM~ E11al1:1ater, as Evaluation of this ERO position's applicable.

ai:>i:>lical::lle.

responsibilities is performed in In addition, station Engineering support will be In addition, station Engineering support will be augmented, ERO Task Analysis, including an evaluation of which augmented on an as needed basis to support accident on an as needed basis to support accident assessment responsibilities can be deleted and assessment and mitigation activities.

and mitigation activities.

which can be reassigned.

EP-DR-1000

8) Ogerations Suggort Center Director osc

8) Ogerations Suggort Center Director osc The revision deletes the OSC l&C, Part II Section B.5.a.8 The OSC Director reports to the Emergency Director and The OSC Director reports to the Emergency Director and Mechanical Maintenance and supervises the activities of OSC personnel.

supervises the activities of OSC personnel.

Electrical Maintenance Lead Operations Support Responsibilities include:

Responsibilities include:

positions. These OSC technicians Center Director OSC will be supervised by the OSC Assign tasks to designated Leads as available:

Assign tasks te 9esi§Rate9 Leaes as available:

Director. The pooled positions will

- l&C Maintenance

- l&C Maintenance consist of Mechanical, Electrical, and l&C Technicians. Radiation

- Mechanical Maintenance

- Mechanical Maintenance Protection (RP) Technicians will

- Electrical Maintenance

- Electrical Maintenance be supervised by the RP Supervisor/Lead.

- Radiation Protection

- Radiation Protection This revision is further discussed in Attachment 1, Section 5.3.10, Evaluation of Proposed Changes.

EP-DR-1000

9)

OSC Leads osc 9j OSC RP Leads osc Evaluation of these ERO position's Part II Section B.5.a.9 OSC Leads report to the OSC Director and are assigned GSG Leaes aR9 rei:>ert te ttie GSG Qirester aR9 are responsibilities are performed in from the following station departments:

assi§Ae9 frern ttie fellewiR§ statieR 9ei:>artrneRts:, ERO Task Analysis, OSC Leads OSC including an evaluation of which Mechanical Maintenance I

MesRaAisal MaiRteRaRse responsibilities can be deleted and Electrical Maintenance I

Electrical MaiRteRaRce which can be reassigned.

Instrument and Control I

IAstr1:1rneRt aR8 GeRtrel 4

TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Radiation Protection RaEliatieR PrnteGtieR The re-assignment of ERO The OSC Lead assigned to an OSC team is responsible responsibilities will be further The OSC RP Lead assigned te an OSC team is demonstrated through the at all times for the safety of team personnel and to keep responsible at all times for the safety of team performance of drills utilizing the the OSC Director apprised of team status. Specifically, personnel and to keep the OSC Director apprised of revised procedures and staffing the OSC Leads are responsible for the managing and team status. Specifically, the OSC RP Leads are is (reference Attachment 5 supervising OSC team personnel, including:

responsible for the managing and supervising GSG Commitments).

Conduct of adequate pre-dispatch briefings.

team RP personnel, including:

Ensuring adequate protective equipment and Conduct of adequate pre-dispatch briefings.

measures have been identified.

Ensuring adequate protective equipment and Tracking of OSC team activities while dispatched.

measures have been identified.

Tracking of OSC team activities while Debriefing of team personnel upon return to the dispatched.

OSC.

Debriefing of team personnel upon return to the OSC.

EP-DR-1000

a. Institute of Nuclear Power O[!erations (INPO}:

a. Deleted lnstit1:1te sf ~J1:1GleaF PeweF O~eFatiens {l~JPO~:

The revision reflects deletion of Experience has shown that a utility may need resources E*f3eFieRee !:las sl:lswn tl:lat a 1:1tility may neeEl Fese1:1rnes INPO because INPO's oversight Part II Step 8.8.a beyond in-house capabilities for the recovery from a 9eysR9 in l:le1:1se ea13a8ilities fsF tl:le FeesvefY fFsm a would not apply to a permanently Industry/Private nuclear plant emergency. One of the roles of the n1:1eleaF 13lant emeF§eney. 0Re ef tl:le rnles ef tl:le shutdown facility.

Support Organizations Institute of Nuclear Power Operations (INPO) is to lnstit1:1te sf ~J1:1GleaF PeweF 013eFatieRs (l~JPO) is ts assist affected utilities by quickly applying the assist affeeteEl 1:1tilities 9y t::i1:1iekly a1313lyiR§ tl:le Fess1:1Fees resources of the nuclear industry to meet the needs of ef tl:le R1:1eleaF iREl1:1stFY ts meet tl:le ReeEls sf aR an emergency. INPO has an emergency response plan emeF§eRGy. l~JPO !:las aR emeF§eRGy F9SFJ9RSe 13laR tl:lat that enables it to provide the following emergency ena91es it te 13rnvi8e tl:le fellswin§ emeF§eney s1:11313ort support functions:

fuRGtieRs:

• Assistance to the affected utility in locating sources of OssistanGe to tl:le affeGteEl 1:1tility iR loeatiR§ ss1:1FGes ef emergency personnel, equipment and operational emeF§eRGY 13eFSonnel, et::i1:1i13meRt anEl s13eratienal analysis.

aRalysis.

• INPO, Electric Power Research Institute (EPRI) and l~JPO, EleetFiG PsweF ReseaFGR IRslit1:1te (EPRI) ans Nuclear Energy Institute (NEI) maintain a

~J1:1eleaF EReF§Y IRstit1:1te E~JEI) maintain a

coordination agreement on emergency information G99FElinatieR 8§FeemeRt SR emeF§8RGy iRfeFmatien with their member utilities.

wiU1 tl:leiF mem9eF 1:1tilities.

5

Emergency Plan Section EP-DR-1000 Part II Figure B-1a TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording INPO provides the "Nuclear Network, or its replacement, electronic communications system to its members, participants, NEI, and EPRI to coordinate the flow of media and technical information about the emergency.

Exelon Nuclear may obtain utility industry information and assistance from any party to this agreement through the coordination of INPO.

To support these functions, INPO maintains the following emergency support capabilities:

A dedicated emergency call number.

Designated INPO representative(s) who can be quickly dispatched to the utility emergency response organization to coordinate INPO support activities and information flow.

The 24-hour per day operation of an Emergency Response Center at INPO headquarters.

Exelon Nuclear will notify INPO (via the designated emergency call number) for all situations involving an Alert, Site Area Emergency, or General Emergency declaration per the Exelon Nuclear Reportability Manual.

INPO has coordinated the preparation of a Voluntary Assistance Agreement for Transportation Accidents.

Exelon Nuclear has signed this agreement which establishes the rights and responsibilities of electric utilities in requesting or providing assistance for response to a nuclear materials Transportation Accident.

Figure B-1a: Exelon Overall ERO Command Structure Proposed Wording lt-JPO proviEles the "NldGlear t-Jetwork", or its FeplaGement, eleGtFOniG GommldniGations system to its meml3eFs, partiGipants, NE:I, anEl E:PRI to GoorElinate tRe flow of meElia anEl teGRniGal information al301:1t the

~***~*::1~**~1 El(elon ~J1:1Glear may ol3tain ldtility inElldstry information anEl assistanGe from any party to tRis a§reement tRrOl:l§R tRe GOOFElination of l~JPO.

To s1:1pport tRese f1:1nGtiens, l~JPO maintains tRe followin§ emeF§enGy Sl:lpport Gapal3ilities:

A EleEliGateEl emer§enGy Gall n1:1ml3er.

Desi§nateEl l~JPO representative(s) WRO Gan 13e Ejl:liel<ly ElispatGReEl to tRe ldtility emeF§enGy response or§anization to GoerElinate l~JPO s1:1pport aGtivities anEl information flew TRe 24 ROldF peF Elay operation of an E:meF§enGy Response Center at l~JPO ReaElEJ1:1arters.

E:xelon

~J1:1Glear will notify l~JPO (via the Elesi§nateEl emeF§enGy Gall nldml3eF) for all sit1:1ations involvin§ an Alert, Site Area E:mer§enGy, or General E:meF§enoy EleGlaration per tRe E:xelon ~J1:1Glear Reportal3ility Man1:1al.

l~JPO Ras GoorElinateEl tRe preparation of a Vol1:1ntary

/\\ssistanGe /\\§reement for Transportation AGGiElents.

E:xelon ~JldGlear Ras si§neEl tRis a§reement wRiGR estal31isRes tRe ri§Rts anEl responsil3ilities of eleGtFiG 1:1tilities in reEJ1:1estin§ or proviElin§ assistanse for response to a n1:1Glear materials Transportation

/\\GGiElent.

Figure B-1 a: ~

Dresden Overall ERO Command Structure 6

Reason for Change The revision replaces Exelon with Dresden as it pertains to the Overall ERO Command Structure.

EP functions for the Dresden ERO command structure will continue to be maintained.

Emergency Plan Section EP-DR-1000 Part II Figure 8-1 b Part 11.D.1.b Emergency Classification System

- Alert TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording Figure B-1b: Emergency Onsite Organization Core/Thermal Engineer Mechanical Engineer Electrica l Engineer

~

Electrica l Rad Protection Mechanical

~

Lead Lead Lead Notification of INPO and ANI.

Proposed Wording Figure B-1b: Emergency Onsite Organization I Cere,'TR ern1al I I........., I

~

TSC Engineer

~

I,,,..,,.., I,., "'""

~

l£aI Lead' I... ::::...,

I 1 Rad Protection Lead responsibilities will be performed by a Rad Protection Pool responder as a collateral function.

Notification of l~IPO aAEl ANI.

7 Reason for Change The TSC Core/Thermal, Mechanical, and Electrical Engineer positions are being deleted from the Dresden ERO and are being replaced by the TSC Engineer. This revision is further discussed in Attachment 1, Section 5.3.7 Evaluation of Proposed Changes.

The revision also deletes the OSC l&C, Electrical and Mechanical Lead positions. The pooled positions consist of Mechanical, Electrical, and l&C technicians.

The Pooled OSC technicians will be supervised by the OSC Director.

The Radiation Protection Supervisor/Lead position will be performed as a collateral function by of one of the Pooled RP Technicians.

This revision is further discussed in Attachment 1, Section 5.3.10, Evaluation of Proposed Changes.

Evaluation of these ERO position's responsibilities are performed in, ERO Task Analysis, including an evaluation of which responsibilities can be deleted and which can be reassigned.

The revision reflects deletion of INPO because INPO's oversight would not apply to a permanently shutdown facility.

TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Part 11.D.1.d

d. General Emergency - Event(s) are in process or have

d. General Emergency - Event(s) are in process or have This revision removes the Emergency occurred which involve actual or imminent substantial occurred which involve actual or imminent substantial potential for core degradation (and core degradation or melting with potential for loss of eei:e fuel degradation or melting witl=i 13ateAtial fer lass af replaces it with fuel degradation)

Classification System containment integrity or HOSTILE ACTION that results seAlaiAmeAt iAte§rity or HOSTILE ACTION that results in and for loss of containment

- General Emergency in an actual loss of physical control of the facility.

an actual loss of physical control of the facility. Releases integrity.

Releases can be reasonably expected to exceed EPA can be reasonably expected to exceed EPA Protective The permanent shutdown and Protective Action Guideline exposure levels offsite for Action Guideline exposure levels offsite for more than the more than the immediate site area. <... >

immediate site area. <... >

removal of fuel of the Dresden reactors makes this condition unnecessary within the Emergency Plan. Fuel degradation within the Spent Fuel Pool is considered Part 11.D.1.e The revision reflects deletion of Emergency INPO and ANI notified of Recovery l~JPO aAe ANI are is notified of Recovery INPO because INPO's oversight are would not apply to a permanently Classification System classification.

classification.

shutdown facility.

- Recovery Part 11.D.2 This revision removes matrix Emergency Action An emergency is classified after assessing abnormal plant An emergency is classified after assessing abnormal plant tables related to plant operating conditions and comparing them to EAL Threshold Values conditions and comparing them to EAL Threshold Values for modes.

Level Technical Bases for the appropriate Initiating Conditions. Classifications are the appropriate Initiating Conditions. Classifications are based on the evaluation of each unit for multi-reactor sites.

based on the evaluation of each unit for multi-reactor sites.

The permanent shutdown and Matrix tables organized by recognition categories are used Matrix tables organized by recognition categories are used defueling of the Dresden reactors to facilitate the comparison. The matrix tables are used to facilitate the comparison. TRe FRatriJc tal31es are 1:1see makes these matrices when the unit is in the Technical Specification defined wl=ieA tl=ie l:JRit is iR tl=ie +esl=iAisal S13esifisatiaA eefiAee unnecessary within the modes of Power Operations, Hot Standby, Hot Shutdown FRaees af Pe111er 013eratiaAs, l=lat StaAelay, l=lat Sl=i1:1teawA Emergency Plan.

(for classifications purposes, startup evolutions are included (fer slassifisatiaAs 131:1r13ases, starl1:113 evel1:1tiaAs are iAsl1:1eee in the Power Operations mode) and Cold Shutdown or iA tl=ie Pawer 013eratiaAs Ffleee) aAe Gale Sl:i1:1teawA er Refueling (for classification purposes a defueled plant will

~efl:JeliR§ (fer elassifieati9R J3l:lrJ39S9S a eefl:Jelee 13laAl Will be considered in the Refueling mode).

13e seAsieeree iA tl=ie ~ef1:1eliA~ F!'leee).

8

Emergency Plan Section Part 11.D.3 Timely Classification of Events Part 11.E.2.b.2 Notification and Mobilization of Emergency Response Personnel - Nuclear Regulatory Commission (NRG)

Part 11.E.2.c Notification and Mobilization of Emergency Response Personnel - Support Organizations TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording A qualified EAL assessor means any member of the plant staff who, by training and experience, is qualified to assess the indications or reports for validity and to compare the same to the EALs. A qualified EAL assessor may be, but need not be, a licensed operator or member of the ERO.

Qualified EAL assessors may be in the MGR or in another facility where emergency declarations are performed. A qualified EAL assessor does not include personnel such as chemists, radiation protection technicians, craft personnel, security personnel, and others whose positions require they report, rather than assess, abnormal conditions to the MGR.

The computerized data link to the NRG, referred to as the Emergency Response Data System (EROS),

continuously supplies specified plant data to the NRG.

The Institute of Nuclear Power Operations (INPO) is notified at an Alert or higher classification with requests for assistance as necessary.

Proposed Wording A qualified EAL assessor means any member of the plant staff who, by training and experience, is qualified to assess the indications or reports for validity and to compare the same to the EALs. A qualified EAL assessor may be, but need not be, a liseAsea S[ilerater Certified Fuel Handler, Non-Certified Operator, or member of the ERO. Qualified EAL assessors may be in the MGR or in another facility where emergency declarations are performed. A qualified EAL assessor does not include personnel such as chemists, radiation protection technicians, craft personnel, security personnel, and others whose positions require they report, rather than assess, abnormal conditions to the MGR.

The somr;>t:JterizeEl Elata liAk to the ~JRC, referreEl to as the ER'ler§eAsy Resr;>aAse gata SysteFA (ERgs),

GOAtiAl:J9l:JSly Sl:Jf)f)lies Sf)eGifieEl r;>laAt aata ts the ~JRC.

The IAstitl:Jte of ~l1::1slear Pewer Or;>eratieAs (l~IPO) is AetifieEl at aA Alert er hi§her slassifisatieA with reelJests fer assistaAse as Aesessarv.

Reason for Change The revision replaces "licensed operator" with "Certified Fuel Handler, Non-Certified Operator."

This change is in alignment with the site staffing changes being made in the Dresden Technical Specifications (TS), Administrative Controls License Amendment Request (LAR).3 This revision removes the computer data link to the NRG (EROS).

The permanent shutdown of the Dresden reactors and defueled status makes EROS references unnecessary within the Emergency Plan.

The revision reflects deletion of INPO because INPO's oversight would not apply to a permanently shutdown facility.

3 Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changed to Unit 1 Technical Specification Section 6.1, "Responsibility," and Technical Specifications 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (NRC Accession No. ML20269A404) 9

Emergency Plan Section Part 11.E.6 Notification of the Public Part 11.F.1.b-d.1 Communications/

Notifications -

Emergency Response Data System (EROS Part 11.F.1.b-d.5 Communications/

Notifications -

Emergency Response Data System (EROS)

TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording The ANS is operated by local governmental agencies and maintained by Exelon Nuclear. To assure the ANS is maintained in an operational readiness posture, the local agencies have agreed to test the system (by sounding the sirens) on a periodic basis that meets or exceeds FEMA guidance and to report inoperable equipment to EP designated maintenance personnel.

The goal of the testing and maintenance program is to identify inoperable equipment in a timely manner and to restore equipment to a functional status commensurate with FEMA operability requirements as referenced in FEMA-REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" Section E.6.2.1. In addition to this routine test and repair program, preventive maintenance of the ANS will be performed on an annual basis.

1) Nuclear Accident Reporting System (NARS): The NARS is a dedicated communications system that has been installed for the purpose of notifying state and local authorities of declared nuclear emergencies. This system links together the station Control Rooms, the EOF, TSCs and state and local authorities as appropriate. The specific design, operation, and responsibility for maintenance of the NARS systems vary between Exelon Nuclear regions. Note that some stations refer to NARS as Radiological Emergency Communications System (RECS).

5) Emergency Response Data System (EROS): EROS will continuously supply the NRG with selected plant data points on a near real time basis. The selected data points are transmitted automatically to the NRG at approximately 1-minute intervals.

Proposed Wording The ANS is operated by local governmental agencies and maintained by Exelon Nuclear. To assure the ANS is maintained in an operational readiness posture, the local agencies have agreed to test the system (by sounding the sirens) on a periodic basis that meets or exceeds FEMA guidance and to report inoperable equipment to EP designated maintenance personnel.

The goal of the testing and maintenance program is to identify inoperable equipment in a timely manner and to restore equipment to a functional status commensurate with FEMA operability requirements as referenced in FEMA-REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" SeetieA

~- In addition to this routine test and repair program, preventive maintenance of the ANS will be performed on an annual basis.

1) Nuclear Accident Reporting System (NARS): The NARS is a dedicated communications system that has been installed for the purpose of notifying state and local authorities of declared nuclear emergencies. This system links together the station Control Rooms, the EOF, TSCs and state and local authorities as appropriate. TRe s13esifis Elesi§A, e13eralieA, aAEI ms13eAsil3ilily fer maiAleAaAse ef the ~JARS systems "ary eetweeA E:i<eleA ~Jl:lslear re§ieAs. ~Jete that same statieAs refer te ~JARS as RaEliele§isal E:mer§eAsy Cemml:lAisatieAs System (RE:CS).

a) E:mer§eAsy Res13eAse Oata Systern (E:ROS): E:ROS will 69AliAl:JOl:JSly Sl:lJ3J3IY the ~JRC with selesteEI 13laAI Elata 13eiAls eA a Rear real lime easis. The selesleEI Elala 13eiAts are lraAsmitteEI al:llemalisally le the ~JRC at a1313rei<imalely 1 miAl:lle iAlervals.

10 Reason for Change The revision deletes the reference to FEMA Rep 10 specific Step number E.6.2.1. The procedure has subsequently been revised and the step number is no longer applicable. FEMA Rep 1 O is still retained as an appropriate reference.

The revision removes reference to other station's NARs systems, as well as reference to the North East region's RECS systems. Both references are no longer applicable to the station specific Emergency Plan.

This revision removes the computer data link to the NRG (EROS) as communication portal.

The permanent shutdown of the Dresden reactors and defueled status makes EROS references unnecessary within the Emergency Plan.

Emergency Plan Section Part II, Figure F-1 Exelon Notification Scheme (For Full Augmentation)

Part 11.H.1.a Control Room, Technical Support Center, and Operations Support Center - Station Control Room Part 11.H.1.b Control Room, Technical Support Center, and Operations Support Center - Technical Support Center TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording

a. Station Control Room: The Control Room is the centralized onsite location from which the Nuclear Station's reactors and major plant systems are operated. The Control Room is equipped with instrumentation to supply detailed information on the reactors and major plant systems. The Control Room is continuously staffed with qualified licensed 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 until such time that support centers can be activated. These activities shall include:

Reactor and plant control.

The TSC has access to a complete set of as-built drawings and other records, including general arrangement diagrams, P&IDs, and the electrical schematics. The TSC has the capability to record and display vital plant data, in real time, to be used by knowledgeable individuals responsible for engineering and management support of reactor operations, and for implementation of emergency procedures.

Proposed Wording

a. Station Control Room: The Control Room is the centralized onsite location from which the Nuclear Station's FeasteFs aAEI A'lajeF plant systems necessary to support the spent fuel pool are monitored e13erate8. The Control Room is equipped with instrumentation to supply detailed information on the rnasteFs aAEI FAajeF plant systems. The Control Room is continuously staffed with qualified liceAsed 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 until such time that support centers can be activated. These activities shall include:

ReasteF aAEI Plant control.

The TSC has access to a complete set of as-built drawings and other records, including general arrangement diagrams, P&IDs, and the electrical schematics. The TSC has the capability to record and display vital plant data, in real time, to be used by knowledgeable individuals responsible for engineering and management support of reaetef operations, and for implementation of emergency procedures.

11 Reason for Change The revision reflects deletion of INPO because INPO's oversight would not apply to a permanently shutdown facility This revision removes the reference to the site reactors and major plant equipment.

The permanent shutdown of the Dresden reactors and defueled status makes these conditions reference unnecessary within the Emergency Plan.

This revision removes the reference to the reactor operation.

The permanent shutdown of the Dresden reactors makes this condition unnecessary within the Emergency Plan.

TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Part 11.H.5.a.1 This revision changes the quality Monitoring Equipment With regard to Exelon Nuclear's meteorological monitoring With regard to Exelon Nuclear's meteorological monitoring assurance program reference based on the permanent shutdown Onsite -

program, there has been a quality assurance program program, there has been a quality assurance program of the Dresden reactors. The Meteorological adopted from 10 CFR 50, Appendix B. However, since the adopted from 10 CFR 50, Appendix B. However, since the Station's QATR is replaced by the Instrumentation meteorological facilities are not composed of structures, meteorological facilities are not composed of structures, Decommissioning Quality systems, and components that prevent or mitigate the systems, and components that prevent or mitigate the Assurance Program consequences of postulated accidents and are not "safety consequences of postulated accidents and are not "safety related," not all aspects of 10 CFR 50, Appendix B, apply.

related," not all aspects of 10 CFR 50, Appendix B, apply.

Those aspects of quality assurance germane to supplying Those aspects of quality assurance germane to supplying good meteorological information for a nuclear power good meteorological information for a nuclear power station station were adopted into the meteorological quality were adopted into the meteorological quality assurance assurance program. The meteorological program is also program. The meteorological program is also subject to the subject to the requirements of the QATR, Section 19, requirements of the Decommissioning Quality Augmented Quality.

Assurance Program Q/\\TR, SeetioA 19, /\\ugmeAteEl Ql:lality.

Part 11.H.5.b.1.c This revision removes the Radiological Monitors c) The accident, or high range, radiation monitoring c) The accident, or high range, radiation monitoring instruments that monitor and Sampling system monitors radiation levels at various locations system monitors radiation levels at various locations containment radiation.

within the operating area. These are high range within the operating area. These are high range The permanent shutdown and instruments used to track radiation levels under instruments used to track radiation levels under removal of fuel of the Dresden accident or post accident conditions. These instruments accident or post accident conditions. These iAstF1:1meAts reactors makes these instrument include the Containment/Drywell Radiation Monitors.

inel1:1Ele the CoAtaiAment/DPfWell RaEliation MoAitoFs.

references unnecessary within the Emergency Plan.

Part 11.H.5.b.2

2) Liquid and Gaseous Sampling Systems: The process

2) Liquid and Gaseous Sampling Systems: The process This revision removes sampling Liquid and Gaseous sampling system consists of the normal sampling sampling system consists of the normal sampling requirements for reactor coolant system and additional sampling panels located system and additional sampling panels located and containment. The permanent Sampling Systems:

throughout the plant. Sampling systems are installed or throughout the plant. Sampling systems are installed or shutdown of the Dresden reactors can be modified to permit reactor coolant and can be modified to permit maetoF eoolaAt aAEl and defueled status makes these containment atmosphere sampling even under severe eeAlaiAmeAt atmosFJhere sampling even under severe sampling references unnecessary accident conditions.

accident conditions.

within the Emergency Plan.

The sampling systems use a number of manual The sampling systems use a number of manual sampling techniques to enable reactor coolant and sampling techniques to enable FeaetoF eoelant anEl containment samplinQ operations over a wide ranQe of eeAlaiAmeAt samplinQ operations over a wide ranQe of 12 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section plant conditions. It is capable of providing information plant conditions. It is capable of providing information relative to post-accident plant conditions to allow relative to post-accident plant conditions to allow operator actions to be taken to mitigate and control the operator actions to be taken to mitigate and control the course of an accident. Refer to the specific UFSAR for course of an accident. Refer to the specific UFSAR for further detail on sampling capabilities.

further detail on sampling capabilities.

Part 11.H.5.c

c. Process Monitors: The Control Room and applicable

c. Process Monitors: The Control Room and applicable This revision removes indications Process Monitors redundant backup locations are equipped with redundant backup locations are equipped with extensive for the reactor coolant system and extensive plant process monitors for use in both normal plant process monitors for use in both normal and containment parameters. The and emergency conditions. These indications include emergency conditions. These indications include but are permanent shutdown of the but are not limited to reactor coolant system pressure not limited to FeaeteF eeelaAt system J3FeSSl:lFe aAEI Dresden reactors and defueled and temperature, containment pressure and tem13eFatl:lFe, eeAtaiAmeAt 13ressl:lFe aAEI tem13eratl:lre, status makes these indication temperature, liquid levels, flow rates, status or lineup of liquid levels, flow rates, status or lineup of equipment references unnecessary within the equipment components. This instrumentation provides components. This instrumentation provides the basis for Emergency Plan.

the basis for initiation of corrective actions.

initiation of corrective actions.

Part 11.1.1

<... >The SPDS monitors such parameters as: reactor

<... >The SPDS monitors such parameters as: reaetef This revision removes indications Plant Parameters and coolant system pressure, reactor or pressurizer water eeelaAt system 13ressl:lre, reaeter er wessl:lrii!:er water that SPDS provides for the reactor Corresponding level, containment pressure, suppression pool water level, 69AtaiAmeAt 13ressl:lre, Sl:lJ3J3ressieA J399I water coolant system and containment Emergency level and temperature, reactor power, safety system level aAEI teFA13eFatl:lre, Feaster 13ewor, safety system parameters. The permanent status, containment radiation level and effluent monitor status, eeAtaiAFAeAt FaEliatieA level and effluent monitor shutdown of the Dresden reactors Classification readings. The instrumentation and equipment readings. The instrumentation and equipment and defueled status makes these capabilities available for each emergency facility are capabilities available for each emergency facility are indications unnecessary within the described in Section H described in Section H Emergency Plan.

Part 11.1.2

2. Onsite Accident Assessment Capabilities

2. Onsite Accident Assessment Capabilities This revision removes the Onsite Accident The resources available to provide initial and continuing The resources available to provide initial and continuing instruments that monitor containment radiation. The Assessment information for accident assessment throughout the information for accident assessment throughout the permanent shutdown and removal Capabilities course of an event include plant parameter display course of an event include plant parameter display of fuel of the Dresden reactors and systems, liquid and gaseous sampling system, Area systems, liquid and gaseous sampling system, Area and their defueled status makes this and Process Radiation Monitoring Systems, and Process Radiation Monitoring Systems, and Accident accident assessment capability Accident Radiation Monitoring Systems (which includes Radiation Monitoring Systems (wl:lisl:l iAGll:lEles tl:le Ri§R unnecessary within the the high range containment radiation monitors).

raA§e seAtaiAmeAt raEliatieA meAiters). Descriptions of Emergency Plan.

Descriptions of these systems are given in Section these systems are given in Section H.5.b.

H.5.b.

13 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Part 11.1.3

3. Source Term Determination

3. Source Term Determination This revision removes the Source Term Source term (or core damage) estimations serve several Source term (or oore fuel damage) estimations serve possibility of the reactor core as source term and affected Determination roles within the Exelon Emergency Preparedness several roles within the Exelon Emergency Preparedness assessment methodologies.

Program. For planning purposes, core damage Program. For planning purposes, eere fuel damage considerations are used as the bases for several of the considerations are used as the bases for several of the The permanent shutdown of the Emergency Action Level (EAL) Initiating Conditions and Emergency Action Level (EAL) Initiating Conditions and Dresden reactors and their as the threshold for the declaration of a General as the threshold for the declaration of a General defueled status makes the Emergency (the definition of a General Emergency Emergency (the definition of a General Emergency possibility of the reactor core as specifies conditions which involve 'substantial' core specifies conditions which involve 'substantial' eere fuel source term and affected degradation or melting as one of the bases for degradation or melting as one of the bases for assessment methodologies classification).

classification).

unnecessary within the From an implementation perspective, core damage From an implementation perspective, oore fuel damage Emergency Plan.

estimations provide a means of realistically estimations provide a means of realistically differentiating differentiating between the four core states (no damage, between the-fuel fel::lr sere states-fno damage, clad clad failure, and fuel melt, and vessel melt-through) to:

failure, and fuel melt, aAEl vessel A'lelt tl=lrel::l§R) to:

• Evaluate the status of the fuel barriers and how their Evaluate the status of the fuel 9aFFiefs clad and how status relates to the risks and possible their status relates to the risks and possible consequences of the accident.

consequences of the accident.

• Provide input on core configuration (coolable or Provide input on OOFe fuel configuration (coolable or uncoolable) for prioritization of mitigating activities.

uncoolable) for prioritization of mitigating activities.

• Determine the potential quality (type) and/or quantity Determine the potential quality (type) and/or quantity

(%)of source term available for release in support of

(%)of source term available for release in support of projected offsite doses and protective action projected offsite doses and protective action recommendations.

recommendations.

• Provide information that quantifies the severity of an Provide information that quantifies the severity of an accident in terms that can be readily understood and accident in terms that can be readily understood and visualized.

visualized.

• Support the determination of radiological protective Support the determination of radiological protective actions that should be considered for long term actions that should be considered for long term recovery activities.

recovery activities.

The assessment methodologies utilized by Exelon are The assessment methodologies utilized by~

intended to provide a rapid best estimate of core Dresden are intended to provide a rapid best estimate of damage which, when evaluated together, help to eere fuel damage which, when evaluated together, help develop an overall picture of the extent of core damage.

to develop an overall picture of the extent of oore fuel The methods used to estimate the amount or type of damacie. +t=ie A'letl=leEls l::lseEl te estiA'late tl=le aA'lel::IAt er 14

Emergency Plan Section TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording core damage occurring under accident conditions includes the following:

Containment Radiation Monitors: An indirect method used to determine the amount of core damage.

Applicable to Loss of Coolant Accident (LOCA) scenarios. Based upon an end-of-life source term and static nuclide ratio assumptions yielding a limited accuracy. Valid any time following an accident.

Core Temperatures: Methods such as Core Exit Thermocouple (CET), Peak Core Temperatures and Hot Leg Temperatures provide indirect methods used to indicate the type and/or amount of core damage. Applicable for all types of accidents. Valid any time following an accident.

Core Uncovery: Methods such as Core Uncovery Time, RVLIS Level and Source Range Monitor count rate provide indirect methods used to indicate the type of core damage (clad failure or fuel melt).

Applicable for all types of accidents. Provides a relatively accurate estimate of the state of the core early in the event. Valid any time following an accident.

Containment Hydrogen Concentration: An indirect method used to establish the type of core damage.

Applicable to LOCA type accidents where all the hydrogen generated by the metal-water reaction is released into containment. Valid any time following an accident.

Sample Analysis - Isotopic Ratio Comparison: A direct method used to establish the type of core damage. Compares expected isotopic ratios with a sample to determine a general core state. Applicable under all types of accidents. Valid any time following an accident.

Sample Analysis - Presence of Abnormal Isotopes: A direct method used to provide a go/no go indication of fuel melt by the presence of unusually high concentrations of the less volatile fission products.

Proposed Wording type af eore damage aemmiRg uRder aeeideRt eaRditiaRs iRell:JEles tl=ie follawiRg:

CaRtaiRmeRt R.adiatiaR MoRitors: AR iRdireet metl=iod used to determiRe tl=ie amol:JRt of eore damage.

/\\pplieal31e to Loss of CoolaRt /\\GeiseRt (LOG/\\)

sGeRarios. Bases l:lpoR aR eRs of life sol:lree term aREI statiG Rl:JGliEle ratio assl:lmptioRs yielEliRg a limiteEI aGel:lraey. ValiEI aRy time fellowiRg aR aeGiEleRt.

Core Temaeratures: Metl=iods Sl:JSA as Core EJEit Tl=iermoeouple (GET), Peal< Core Temperatures aRd Hot Leg Temperatl:lres previEle iRElireGt metl=ioEls l:JseEI to iRdiGate tl=ie type aRd/or amol:lnt of sere samage.

Ap13lieal3le for all ty13es of aGGiElents. Valid aRy time followiRg aR aGeideRt.

Core URGoverv: Metl=iods SUGA as Core URGovery Time, R.VLIS Level aRd Sol:lrGe RaRge MoRitor Gol:JRt rate 13reviEle iRElireGt methoEls l:JseEI to iRdieate the type of Gore damage (Glas faill:Jre or fuel melt).

/\\1313lieal3le for all ty13es of aGGidents. Provides a relatively aGGl:lrate estimate of the state of the Gore early iR tl=ie eveRt. Valid aRy time followiRg aR aGeideRt.

CoRtaiRmeRt HydroaeR CoReeRtratioR: AR iRdireet metl=ioEI l:Jses to estal31isl=i the type of Gore samage.

/\\p13lieal3le to LOCA type aGGiseRts wl=iere all tl=ie l=iydrogeR geRerated 13y tl=ie metal water reaetioR is releases iRto GoRtaiRmeRt. "alid aRy tiFRe follo"'iR§J aR aeeideRt.

Sam ale ARalysis lsotoaie Ratio ComaarisoR: A Elireet methoEI l:JseEI to estal31ish the type of Gore sama§Je. Compares expeGtes isoto13iG ratios witl=i a sample to setermiRe a geReral Gore state. AppliGal31e uRder all types of aGeiseRts. Valid aRy time followiR§J aR aeeideRt.

Sam ale ARalysis PreseRee of Al3Rormal lsotoaes: A 15 ElireGt methos uses to proviEle a §Jo/Ro §Jo iRsieatioR of fl:Jel melt 13y tl=ie 13reseRee of l:JRl:JSl:Jally l=iigl=i

,.,,f.&.l-- *--- **-*-.&.:1-r..

Reason for Change TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Applicable under all types of accidents. Valid any

!\\pplioable l:JRder all types of aooideRts. Valid aRy time following an accident.

tiFRe fello"'iA§ aA aooideRt.

Sam~le Analysis - Concentration Evaluation: A direct SaFR1::1le AAal}'.sis GeAoeAtratieA EValt:JatioA: A Elireot method that yields the most accurate numerical FRetl=lod tl=lat yields tl=le FRost aoot:Jrate Rl:JFRerioal estimations of the amount of core damage.

estiFRatioRs of tl=le aFROl:JAt of sore daFRa§e. Applicable Applicable for all types of accidents. Requires the fer all types of aooideAts. ReElt:Jires tl=le saFRpled sampled system(s) be in a steady state that usually systeFR(s) be iA a steady state tl=lat l:JSl:Jally preveAts prevents its use until the plant is in a stable condition.

its t:Jse t:JAtil tl=le plaAt is iR a stable ooAElitioR.

Part 11.1.4.b B. Containment Leakage/Failure - This method uses a B. GoAtaiRFReAt beal~a§lelFailt:Jre +l=lis FRetl=lod t:Jses a This revision removes the variety of containment failures or leak rates in variety of ooAtaiAFReAt railt:Jres or leal~ rates iA containment leakage/failure as an Effluent Monitor Data and Dose Projection conjunction with available source term estimations to oeAjt:JAotioA witl=l availasle sot:Jroe terFR estiFRatioAs to assessment methodology. The develop a release rate to the environment. A direct vent Elevelop a release rate to tl=le eAviroRFReAt. A Elireot veRt permanent shutdown of the of containment can be modeled as a failure to isolate.

Of GOAtaiAFReAt GaA Se FR09eled as a faill:Jre to isolate.

Dresden reactors and their defueled status makes this assessment methodology unnecessary within the Emergency Plan.

Part 11.J.10.m.1

1) Plant Based PARs

1) Plant Based PARs This revision removes core Plant Based PARs Station specific PAR Flowcharts have been developed Station specific PAR Flowcharts have been developed damage indications and a controlled containment vent as to aid Exelon Nuclear personnel providing PARs based to aid Exelon Nuclear personnel providing PARs based they related to plant based PARs.

on the above. Station specific PAR Flowcharts with on the above. Station specific PAR Flowcharts with The permanent shutdown of the Subarea or Sector tables are documented in the Exelon Subarea or Sector tables are documented in the Exelon Dresden reactors and their EP Implementing Procedures, including station-specific EP Implementing Procedures, including station-specific defueled status makes these requirements regarding PAR determination. These requirements regarding PAR determination. These conditions unnecessary within the flowcharts and tables provide technically based flowcharts and tables provide technically based Emergency Plan.

Protective Action Recommendations based on plant Protective Action Recommendations based on plant conditions and core damage indicators as applicable to conditions aAEI sore ElaFRa§e indicators as applicable to the Exelon site and described within the implementing the Exelon site and described within the implementing procedures. Possible plant based PARs issued by procedures. Possible plant based PARs issued by Exelon Nuclear, in support of NUREG-0654 Supp. 3, at Exelon Nuclear, in support of NUREG-0654 Supp. 3, at a General Emergency could include as appropriate for a General Emergency could include as appropriate for the Station:

the Station:

• Response to a Rapidly Progressing Severe Accident.

• Response to a Rapidly Progressing Severe Accident.

• Utilization of the staged evacuation concept as

• Utilization of the staged evacuation concept as determined by station ETE's.

determined by station ETE's.

16 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section

• Shelter of the general public in response to but not

• Shelter of the general public in response to but not limited to; a controlled containment vent lasting less limited to; a eeAtrnlleEl eeAtaiAFfleAt ><eAt lastiAg less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in duration less than PAGs, impediments tl=iaA 1 t:le1;1r iA El1;1ratieA less tt:laA P/\\Gs, impediments to evacuation, or Hostile Action event.

to evacuation, or Hostile Action event.

• Evacuation of the general public.

• Evacuation of the general public.

Part 11.M.1.b This revision removes reactor Evaluating Entry into The reactor is in a stable shutdown condition and

+Fie reaeter is iA a stasis st:l1;1tElewA eeAElitieA aAEl conditions and establishment of primary/secondary integrity The Recovery long-term core cooling is available leAg terFfl sere eeeliAg is availal31e permanent shutdown of the

. The fuel pool damage has been mitigated, or spent

. The fuel pool damage has been mitigated, or spent Dresden reactors and their fuel damage has been contained and controlled.

fuel damage has been contained and controlled.

defueled status makes these

. Primary and/or secondary containment integrity has

. Primary aAEl/er seeeAElary eeAtaiAFfleAt iAtegrity t:ias conditions unnecessary within the been established.

13eeA estal31ist:ieEl.

Emergency Plan.

Part 11.M.2

2.

Recovery Organization

2.

Recovery Organization This revision removes systems to Recovery maintain the plant shutdown. The permanent shutdown of the Organization For events involving major damage to systems

. For events involving major damage to systems Dresden reactors and defueled required to maintain safe shutdown of the plant reE11;1ireEl ta FflaiAtaiA safe st:l1;1tElewA ef tt:ie plaAt status makes this condition and offsite radioactive releases have occurred, a00 where offsite radioactive releases have unnecessary within the (i.e. for Site Area Emergency or General occurred, (i.e. for Site Area Emergency or General Emergency Plan.

Emergency classifications) the station recovery Emergency classifications) the station recovery organization is put in place.

organization is put in place.

Part 11.N.2.e

e. Health Physics Drills: Health Physics Drills involving a

e. Health Physics Drills: Health Physics Drills involving a This revision removes core Health Physics Drills response to, and analysis of, simulated airborne and response to, and analysis of, simulated airborne and damage assessment objectives.

liquid samples and direct radiation measurements liquid samples and direct radiation measurements The permanent shutdown of the within the plant are conducted semi-annually. At least within the plant are conducted semi-annually. At least Dresden reactors and defueled annually, these drills shall include a demonstration of annually, these drills shall include a demonstration of status makes reference to core the sampling system capabilities, or the Core Damage the sampling system capabilities, er tt:ie Gere QaFflage damage assessment objectives Assessment Methodology (CDAM) objectives as

/\\ssessFfleAt Mett:ieeelegy (CQ/\\M) ol3jeetives as unnecessary within the applicable.

a1313lieal3le.

Emergency Plan.

17 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Part 11.0.4.b

b. Personnel Responsible for Accident Assessment:

b. Personnel Responsible for Accident Assessment:

This revision removes the Personnel The skills and knowledge required to perform plant The skills and knowledge required to perform plant personnel responsibilities of power changes, unplanned shutdowns, Responsible for stabilization and mitigation are a normal function of stabilization and mitigation are a normal function of and core damage assessment.

Accident Assessment operations specific positions, as identified in Section B operations specific positions, as identified in Section B The permanent shutdown of the of this plan. Power changes and planned and of this plan. PeweF si:iaR§les am:J 13laRReEI aREI Dresden reactors and defueled unplanned reactor shutdowns are handled on a l:lR13laAReEI FeasteF SRl:ltElewAs aFe l:iaRElleEI eA a status makes these normal operation basis. Subsequent plant stabilization RSFR'lal e13eFatieR easis. Subsequent plant stabilization responsibilities unnecessary within and restoration is pursued utilizing normal operating and restoration is pursued utilizing normal operating the Emergency Plan.

procedures. Licensed Operators receive routine procedures. LiseRseEI Qualified Operators receive classroom and simulator training to ensure proficiency routine slassFeeffl aREl siffll:llateF training to ensure It also changes designation of in this area.

proficiency in this area.

responsibilities from active senior

1) Active Senior Licensed Control Room Personnel

1) /\\stive SeRieF LiseRseEI CeRtrnl Reem PeFSORRel licensed to Certified Fuel Handlers. This change is in shall have training conducted in accordance with Certified Fuel Handlers shall have training alignment with the site staffing the approved ERO Training Program such that conducted in accordance with the approved ERO changes being made in the proficiency is maintained on the topics listed Training Program such that proficiency is Dresden TS Administrative below. These subjects shall be covered as a maintained on the topics listed below. These Controls LAR4.

minimum on an annual basis.

subjects shall be covered as a minimum on an annual basis.

To remove peripheral duties from the Operations shift, the following group of positions responsible for

+e Femeve 13eFi13tieral Ell:lties frnffl tl:ie G13eratieAs sRift, accident assessment, corrective actions, protective tl:ie fellewiA§ §F9l:lfl ef 13esitieAs Fes13eAsil3le feF actions, and related activities receive the training assiEleAt assessffleAt, seFFestive aGtieAs, 13rntestive listed below:

aGtieRs, aREI FelateEI asti'*ities Fesei"e ttie tFaiRiA§! listeEI

2) Core Damage Assessment Personnel: During an

~

emergency when core/cladding damage is

~~ CeFe gaffla§le AssessffleAt PeFseAAel: gl:JFiA§! aA suspected, a specialized group of trained effleF§eRsy wl:ieA eeFelslaEIEliA§ Elaffla§le is individuals perform core damage assessment. At a Sl:lSJ::JesteEI, a s13esialiit'eEI §FOl:lFJ ef !FaiAeEI minimum, personnel responsible for core damage iREliviEll:lals 13eFfeFm seFe Elaffla§e assessffleAt. /\\t a assessment receive classroom and hands-on ffliRiffll:Jffl, 13eFSORAel FeSJ::JSRSiele feF eeFe Elaffla§le training in the following areas:

assessffleRt Feseive slassrnem aREI i:iaREls eR

. Available Instrumentation and Equipment traiRiA§ iR tl:ie fellewiR§! aFeas:

4 Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changed to Unit 1 Technical Specification Section 6.1, "Responsibility," and Technical Specifications 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (NRG Accession No. ML20269A404) 18 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section

. Isotopic Assessment and Interpretation

. Availasle IAstrtimeAtatieA aAEl E:E1tii13meAt

. Computerized Core Damage Assessment

. lsete13ie AssessmeRt aREl IAter13retatieR Methodology (CDAM) and/or proceduralized

. Gem13titerizeEl Gere Qama§e AssessmeRt assessment methods.

MetheElele§y (GQ/\\M) aAElier weeeEltiralizeEl assessmeRt FfletheEls.

Part 11.P.2

2. Authority for the Emergency Preparedness Effort

2.

Authority for the Emergency Preparedness Effort The revision replaces the Station Authority for the The Site Vice President is responsible for the safe and The Site Vise PresiEleRt Plant Manager is responsible Vice President with the Plant Manager as having overall Emergency reliable operation of the generating station. The for the safe and reliable operation of the §eAeratiA§ authority and directing the site Preparedness Effort issuance and control of this plan and the activities station. The issuance and control of this plan and the organization. This change is in associated with emergency preparedness at Dresden activities associated with emergency preparedness at alignment with the site staffing shall be the overall responsibility of the Vice Dresden shall be the overall responsibility of the Vice changes being made in the President, Fleet Support. This individual is assigned President, Fleet Support. This individual is assigned Dresden TS Administrative the responsibility for overall implementation of the E-the responsibility for overall implementation of the E-Controls LAR.4 Plan and station Annex.

Plan and station Annex.

Part 11.P.3 Program Administration Program Administration This revision changes the name of Responsibility for the operator training program. This change is in alignment with the Development and

. Coordinate, document and review Performance

. Coordinate, document and review Performance site staffing changes being made Maintenance of the Indicator data and reports.

Indicator data and reports.

in the Dresden TS Administrative Plan Controls LAR. 5

. Provide oversight of Drill and Exercise Performance

. Provide oversight of Drill and Exercise Performance (DEP) evaluations during License Operator (DEP) evaluations during biGeAse Operator Requalification (LOR) Training.

ReEJtialifieatieA (LOR) Training.

. Coordinate and conduct EP Event reviews and

. Coordinate and conduct EP Event reviews and reports.

reports.

5 Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changed to Unit 1 Technical Specification Section 6.1, "Responsibility," and Technical Specifications 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (NRC Accession No. ML20269A404) 19

Emergency Plan Section Part 11.P.4 E-Plan and Agreement Revisions Part 11.P.6 Supporting Emergency Response Plans Part 11.P.9 AudiUAssessment of the Emergency Preparedness Program TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording

4. E-Plan and Agreement Revisions The E-Plan and its Annex shall be revised as needed and the most current approved revisions shall remain in effect so long as they are certified as current. Revisions to the E-Plan are reviewed by the Station's Plant Operational Review Committee (PORC) prior to approval. Changes to the plan are made without NRC approval only if such changes do not result in a reduction in effectiveness of the plan per 10 CFR 50.54(q), and the plan as changed continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. Proposed changes that reduce or have a potential to reduce the effectiveness of the approved plan are not implemented without prior approval by the NRC.

6. Supporting Emergency Response Plans INPO Emergency Resources Manual.

9. Audit/Assessment of the Emergency Preparedness Program Results of this audit are submitted for review to Corporate Management and the Station Vice President. The Emergency Preparedness Manager ensures that any findings that deal with offsite interfaces are reviewed with the appropriate agencies.

Proposed Wording

4. E-Plan and Agreement Revisions The E-Plan and its Annex shall be revised as needed and the most current approved revisions shall remain in effect so long as they are certified as current. Revisions to the E-Plan are reviewed by the Station's PlaRt 013erati0Ral Review Committee (PGSRq prior to approval. Changes to the plan are made without NRC approval only if such changes do not result in a reduction in effectiveness of the plan per 10 CFR 50.54(q), and the plan as changed continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. Proposed changes that reduce or have a potential to reduce the effectiveness of the approved plan are not implemented without prior approval by the NRC.

6. Supporting Emergency Response Plans l~JPO EmergeRey ResoL:Jrees MaRL:Jal.

9. Audit/Assessment of the Emergency Preparedness Program Results of this audit are submitted for review to Corporate Management and the StatioR Vise PresideRt Plant Manager. The Emergency Preparedness Manager ensures that any findings that deal with offsite interfaces are reviewed with the Reason for Change Once the plant has permanently defueled and implemented the Defueled Quality Assurance Program the Plant Operational Review Committee is replaced with the Station Review Committee (SRC)

The revision reflects deletion of INPO because INPO's oversight would not apply to a permanently shutdown facility.

The revision replaces the Station Vice President with the Plant Manager as having overall authority and directing the site organization. This change is in alignment with the site staffing changes being made in the Dresden TS Administrative Controls LAR. 6 6 Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changed to Unit 1 Technical Specification Section 6.1, "Responsibility," and Technical Specifications 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (NRC Accession No. ML20269A404) 20 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Written notification will be provided to the state and appropriate agencies. Written notification will be counties of the performance of the audit and the provided to the state and counties of the performance availability of the audit records for review at Exelon of the audit and the availability of the audit records for facilities. Records of the audit are maintained for at review at Exelon facilities. Records of the audit are least five years.

maintained for at least five years.

Part Ill App 1 Exelon has a previously NRC References

28. Exelon Nuclear Quality Assurance Topical Report

28. Exelon NooleaFDecommissioning Quality Assurance approved Decommissioning Quality Assurance Program (QATR), NO-AA-10 Program To13ieal Re13ort (QATR DQAP), NO-AADC-(DQAP). 7 Dresden will be added

29. INPO Emergency Resources Manual 10 to the DQAP under 50.54(a) upon

29. Deleted l~JPG eR'leF§eAGJ' Reso1:1FGes MaA1:1al submittal of the certifications

30. "Maintaining Emergency Preparedness Manual,"

required by 10 CFR50.82(a).

dated December, 1996 INPO 96-009 30 Deleted "MaiAtaiAiA§ eR'leF§eAsy PFe13aFeElAess MaAl:lal," Elates geeeFASeF, rn9a l~JPG 9l QQ9 The revision reflects deletion of 31. "Federal Bureau of Investigation and Nuclear INPO because INPO's oversight Regulatory Commission Memorandum of

31. "Federal Bureau of Investigation and Nuclear would not apply to a permanently Understanding for Cooperation Regarding Threat, Regulatory Commission Memorandum of shutdown facility.

Theft, or Sabotage in U.S. Nuclear Industry," Federal Understanding for Cooperation Regarding Threat, Register, Vol. 44, p. 75535, December 20, 1979.

Theft, or Sabotage in U.S. Nuclear Industry," Federal Register, Vol. 44, p. 75535, December 20, 1979.

39. Letter from William J. Dircks, Executive Director for Operations, NRC, to Dr. Donald F. Knuth, President

39. Letter from William J. Dircks, Executive Director for KMC, Inc. dated October 26, 1981.

Operations, NRG, to Dr. Donald F. Knuth, President

40. INPO Coordination agreement on emergency KMC, Inc. dated October 26, 1981.

information among USCEA, EPRI, INPO, NUMARC

40. Deleted l~JPG GooFEliAatioA a§FeeR'leAt oA eR'leF§eAsy and their member utilities, dated April (1988).

iAfeFFAatioA aR'lOA§ bJSGE:A, E:PRI, l~JPG, ~JbJMARG 41. Babcock and Wilcox Company, Post Accident Sample aAEl tl=leiF R'leR'lseF 1:1tilities, Elates Awil (1Qgg).

Offsite Analysis Program (1982).

41. Babcock and Wilcox Company, Post Accident Sample Offsite Analysis Program (1982).

7 Letter from U.S. Nuclear Regulatory Commission to Bryan C. Hanson (Exelon Generation Company, LLC), "Oyster Creek Nuclear Generating Station and Independent Spent Fuel Storage Installation - Review and Acceptance of Changes RE: Decommissioning Quality Assurance Program (EPID L-2017-LLQ-0003)," dated June 27, 2018 (ADAMS Accession No. ML18165A136) 21 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Part Ill App 3 Am;~endix 3:

List of Cori;~orate Letters of AE!E!endix 3:

List of CorE!orate Letters of The revision reflects deletion of List of Corporate Agreements Agreements INPO because INPO's oversight would not apply to a permanently Letters of Agreements shutdown facility.

INPO (Letter on File) lt>JPG (betteF SA File)

Emergency Event Support eFAeF§eAsy E"eAt Sl::lflfJSFt Part Ill App 4 AE!E!endix 4:

Glossa!Y of Terms and Acron)lms AQQendix 4:

Glossaey of Terms and Acronyms These revisions modify terms Glossary of Terms Accident Assessment Accident assessment consists Accident Assessment Accident assessment consists related to reactor operator status reports, source term, Technical and Acronyms of a variety of actions taken to determine the nature, of a variety of actions taken to determine the nature, Support Center, and vital areas.

effects and severity of an accident and includes effects and severity of an accident and includes evaluation evaluation of reactor operator status reports, damage of mastsF s13eratsF statl::ls m13srts, damage assessment The revisions also remove terms assessment reports, meteorological observations, seismic reports, meteorological observations, seismic related to EROS, fission product observations, fire reports, radiological dose projections, in observations, fire reports, radiological dose projections, in barrier, high radiation sampling plant radiological monitoring, and environmental plant radiological monitoring, and environmental and puff release.

monitoring.

monitoring.

The permanent shutdown of the Dresden reactors and their Emergency Operating Procedures (EOPs)

EOPs are Emergency Operating Procedures (EOPs)

EOPs are defueled status makes these terms unnecessary within the step by step procedures for direct actions taken by step by step procedures for direct actions taken by Emergency Plan.

licensed reactor operators to mitigate and/or correct an lieeAseEI fea6tef qualified operators to mitigate and/or off normal plant condition through the control of plant correct an off normal plant condition through the control of systems.

plant systems.

Emergency Response Data System (EROS) EROS is a eFAeF§eAsy Res13sAse Qata SysteFA (E:RQS) E:RQS is a continuous direct near real-time electronic data link 6SAtiAl::ISl::IS EliFeet AeaF Feal tiFAe eleetFeAiS Elata liAI~

between the licensee's onsite computer system and the sePA<eeA U1e lieeAsee's SASite 6SFAf)l::lteF systeFA aAEI U1e NRC Operations Center that provides for the automated t>JRG G13eFatisAs GeAteF tl:lat 13FsviEles feF tl:le al::ltsFAateEI transmission of a limited data set of selected parameters.

tFaAsFAissisA sf a liFAiteEI Elata set sf seleeteEI 13aFaFAeteFs.

Fission Product Barrier The fuel cladding, reactor F'.issisA PFsEll::let BaFFieF

+tie fl::lel elaEIEliA§, mastsF coolant system boundary, or the containment boundary.

ssslaAt systeFA 9sl::IAElary, SF the esAtaiAFAeAt 9sl::IAElary.

22

Emergency Plan Section Part Ill Appendices ACRONYMS TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Current Wording High Radiation Sampling System Post-accident sampling capability to obtain and perform radioisotopic and chemical analyses of reactor coolant and containment atmosphere samples.

Puff Release A controlled containment vent that will be terminated prior to exceeding 60 minutes in duration and is less than the limit as defined in the Station Annexes.

Source Term Radioisotope inventory of the reactor core, or amount of radioisotope released to the environment, often as a function of time.

Technical Support Center (TSC)

A center outside of the Control Room in which information is supplied on the status of the plant to those individuals who are knowledgeable or responsible for engineering and management support of reactor operations in the event of an emergency, and to those persons who are responsible for management of the on site emergency response.

Vital Areas Areas within the station security fence which contain vital equipment. Examples include Control Rooms, ContainmenUReactor Buildings, Turbine Buildings and Electrical Equipment Rooms.

ACRONYMS CHRMS Containment High Range Monitoring System CHRRMS Containment High Range Radiation Monitoring System Proposed Wording l=ligti RaEliatioR 8ampliRg System Post aeeiEleRt sampliRg eapaeility to oetaiR aREl pe1:form raElioisotopie aREl eFiemieal aRalyses of reaetor eoolaRt ans eentaiRmeRt atmosptiere samples.

Pl:l# Release A eentrolleEl GORtaiRmeRI \\'ORt ttiat will ee termiRateEl prior to OlEGOOSiRg eQ miRl:ltOS iR Sl:lratiOR aREl is less tt'laR !Fie limit as ElefiReEl in tFie Station ARROJEes Source Term Radioisotope inventory of ttie roaster 68F&,--Or amount of radioisotope released to the environment, often as a function of time.

Technical Support Center (TSC)

A center outside of the Control Room in which information is supplied on the status of the plant to those individuals who are knowledgeable or responsible for engineering and management support of reaetaF site operations in the event of an emergency, and to those persons who are responsible for management of the on site emergency response.

Vital Areas Areas within the station security fence which contain vital equipment. Examples include Control Rooms, CoRtainmeRt/Reactor Buildings, Turbine Buildings and Electrical Equipment Rooms.

ACRONYMS Cl=IRMS CoRtaiRment l=ligti RaRge MenitoriRg System Cl=IRRM8 CoRtaiRment l=li§t'l RaR§O RaEliatioR Meniterine S"storn 23 Reason for Change This revision removes acronyms related to Containment, INPO, loss of coolant accident, PASS and STA. This revision replaced the QA TR with the DQAP.

The permanent shutdown of the Dresden reactors and defueled status makes these acronyms TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Section INPO Institute of Nuclear Power Operations LOCA Loss of Coolant Accident PASS Post Accident Sampling System QATR Quality Assurance Topical Report STA Shift Technical Advisor WEM Wisconsin Emergency Management Proposed Wording DQAP Decommissioning Quality Assurance Program l~JPO IAstitlolte ef Nlolslear Pewer 013eratieAs LOG/\\ Less ef CeelaAt AssiEleAt PASS Pest /\\ssiEleAt Sam13liA§ System QATR Qlolality /\\sslolraAse Te13isal Re13ert STA Sl=iift TeGRAisal AEl\\'iser llllE~ 4 'MsseAsiA EFAOF§OAGY MaAa§OFAOAt 24 Reason for Change unnecessary within the Emergency Plan.

TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN EP-DR-1000, Part II, Appendix 5, Table DRESDEN B-1: Emergency Response Organization (ERO) Staffing and Augmentation Plan The following tables identify the changes made to Table DRESDEN B-1. The table format is revised to more clearly present the changes within the Table.

TSC I OSC EOF - Alert or Emergency Preparedness (EP)

On Shift Alert or Greater Alert or Greater Greater Functions Augment w/in 60 Augment w/in 90 Augment w/in 60 min.

min.

min.

Current Wording Radiation Protection (2) Radiation (3) Additional (3) Additional Not applicable EP-DR-1000, Part Ill

• Provide qualified radiation Protection Personnel Radiation Protection Radiation Protection Appendix 5, Table 5-1 protection coverage for Personnel [In addition Personnel [In addition responders accessing to personnel on-shift]

to personnel on-shift potentially unknown (OSC) and those responding radiological environments during emergency within 60 min.] (OSC) conditions.

• Provide in-plant surveys.

• Control dosimetry and radiologically controlled area access.

Proposed Wording Radiation Protection

(~ 1) Radiation

(~ 2) Additional (3) AEIElitieRal Not applicable EP-DR-1000, Part Ill

• Provide qualified radiation Protection Personnel Radiation Protection RaEliatieR PFetestieR Appendix 5, Table 5-1 protection coverage for Personnel [In addition PeFseRRel [IA aElsitieR responders accessing to personnel on-shift]

te 13eFS8RRel SR shift potentially unknown (OSC) radiological environments aR8 U:iese Fes13eR8iR§ during emergency withiR 0Q FRiR.] (OSC) conditions.

As needed

• Provide in-plant surveys.

• Control dosimetry and radiologically controlled area access.

25 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Reason for Change - Changes to Table B-1 reflect the changes to the Dresden ERO discussed in this Attachment. Evaluation of this ERO position's responsibilities is performed in Attachment 4, ERO Task Analysis, including an evaluation of which responsibilities can be deleted and which can be reassigned. This revision is further discussed in Attachment 1, Section 5.3.3, Evaluation of Proposed Changes. The reassignment of ERO responsibilities will be further demonstrated through the performance of drills utilizing the revised procedures and staffing (reference Attachment 5 Commitments).

TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 90 Augment w/in 60 Augment w/in 60 min.

min.

min.

Current Wording Emergency EP-DR-1000, Part Ill Classifications Emergency Appendix 5, Table 5-1 Evaluate plant Classification Advisor1 (1) Operations Not applicable Not applicable conditions and Manager (TSC) recommend emergency classifications, until relieved.

Proposed Wording Emergency EP-DR-1000, Part Ill Classifications Emergency Evaluate plant Glassificatien (1) Operations Not applicable Not applicable Appendix 5, Table 5-1

/\\sviser Manager {TSC) conditions and recommend emergency Not applicable classifications, until relieved.

Reason for Change - Changes to Table B-1 reflect the changes to the Dresden ERO discussed in this Attachment. Evaluation of this ERO position's responsibilities is performed in Attachment 4, ERO Task Analysis, including an evaluation of which responsibilities can be deleted and which can be reassigned. This revision is further discussed in Attachment 1, Section 5.3.6, Evaluation of Proposed Changes. The reassignment of ERO responsibilities will be further demonstrated through the performance of drills utilizing the revised procedures and staffing (reference Attachment 5 Commitments) 26 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 90 Augment w/in 60 Augment w/in 60 min.

min.

min.

Current Wording Engineering (1) Core/ Thermal TSC Engineering Staff As Needed Not Applicable EP-BY-1000, Part Ill Provide Hydraulics Engineer -

• ( 1) Electrical/

Appendix 5, Table 5-1 engineering coverage STA1 Instrumentation and related to the specific Evaluate Control (l&C): Provide discipline of the reactor conditions assigned engineer, until engineering coverage relieved.

for the ERO related to electrical or l&C equipment.

• (1) Mechanical:

Provide engineering coverage for the ERO related to mechanical equipment.

. (1) Core/Thermal Hydraulics: Evaluate reactor conditions.

Proposed Wording Engineering p ~ GoFe,l +t::ieFmal (1) TSC As needed Not applicable EP-BY-1000, Part Ill

. Provide l=lydmulios E:ngineeF Engineer:

Appendix 5, Table 5-1 engineering coverage s+A Provide Felated to tt::ie s13esifis

. E:valuate rnastoF engineering dissi131ine of tt::ie sonditions coverage for assigned engineeF, until Not applicable the ERO relieved.

Additional staff as needed

+SG E:ngineeFing Staff

• ~~ ~ E:lestFisal,l I nstFumentation and 27 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Preparedness (EP)

Functions On Shift TSC I OSC Alert or Greater Augment w/in 60 min.

Central (l&C): Previse

...,, '8" '""""" "'8 vv v ""'""'SI""'

fer the ERO relates te electrical er l&C equipment.

• (1) Mechanical:

Previse engineering ceverage fer the ERO relates te mechanical equipment.

(1) Gere/Thermal Hysraulics: Evaluate reacter censitiens Alert or Greater Augment w/in 90 min.

EOF - Alert or Greater Augment w/in 60 min.

Reason for Change - The revision deletes the Core/ Thermal Hydraulics Engineer - STA position. The Core/ Thermal Hydraulics Engineer - STA function for a permanently shutdown reactor is no longer required. EP functional requirements for Technical Support will be performed by Shift Supervisor/ Certified Fuel Handler (CFH). Refer to Attachment 1, Section 5.3.7 for further discussion of the Core/ Thermal Hydraulics Engineer - STA.

This change is in alignment with the site staffing changes being made in the Dresden TS Administrative Controls LAR. 8 Additionally, changes to Table 5-1 reflect the changes to the Dresden Engineering positions. Evaluation of the Engineering ERO position's responsibilities is performed in Attachment 4, ERO Task Analysis, including an evaluation of which responsibilities can be deleted and which can be reassigned. This revision is further discussed in Attachment 1, Section 5.3.7, Evaluation of Proposed Changes. The reassignment of ERO responsibilities will be further demonstrated through the performance of drills utilizing the revised procedures and staffing (reference Attachment 5 Commitments).

8 Letter from Patrick R. Simpson (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changed to Unit 1 Technical Specification Section 6.1, "Responsibility," and Technical Specifications 1.1, "Definitions," and 5.0, "Administrative Controls," for Permanently Defueled Condition," dated September 24, 2020 (NRC Accession No. ML20269A404) 28 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 90 Augment w/in 60 min.

min.

min.

Current Wording Repair Team Activities Not Applicable Maintenance Maintenance Not applicable EP-DR-1000, Part Ill Personnel (OSC)

Personnel Appendix 5, Table 5-1

• ( 1) Electrical (OSC)

Maintenance

• (1)1&C Technician: Provide Technician:

electrical support Provide forECCS assistance with equipment, event logic mitigation, and manipulation, equipment repair.

support for event mitigation and equipment repair,

• (1) Mechanical and support Maintenance of digital l&C Technician: Provide if applicable.

mechanical support Additional l&C forECCS staff may be equipment, event called out if mitigation, and needed.

equipment repair.

• Electrical Maintenance Technicians-As needed.

• Mechanical Maintenance Technicians - As needed.

29 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 90 Augment w/in 60 min.

min.

min.

Proposed Wording Repair Team Activities Not Applicable Maintenance Maintenance Not applicable EP-DR-1000, Part Ill Personnel (OSC)

Personnel Appendix 5, Table 5-1

• (1) Electrical (OSC)

Maintenance

• (1) l&C Technician:

Technician: Provide Provide assistance electrical support with logic foreGGS manipulation, eq1;1i13meRt, event support for event mitigation, and mitigation and equipment repair.

equipment repair, and support of digital l&C

.. (1) Mechanical if applicable.

Maintenance Additional l&C staff Technician: Provide may be called out if mechanical support needed.

foreGGS eq1;1i13meRt, event mitigation, and

• Electrical equipment repair.

Maintenance Technicians - As needed.

• Mechanical Maintenance Technicians - As needed.

Reason for Change - Changes to Table B-1 reflect the changes to the Dresden ERO discussed in this Attachment. The reference to ECCS equipment is removed since the equipment is no longer required to support a permanently shutdown reactor with all fuel moved to the Fuel Pool. The revision of ERO responsibilities will be further demonstrated through the performance of drills utilizing the revised procedures and staffing (reference Attachment 5 Commitments).

30 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 60 min.

Augment w/in 90 min.

min.

Current Wording Supervision of Repair Not Applicable (1) OSC Director OSC Supervisors Not applicable EP-DR-1000, Part Ill Team Activities Supervise OSC

• Electrical Maintenance Appendix 5, Table 5-1 activities as Supervisor /Lead:

directed by Supervise OSC Emergency activities related to Coordinator.

electrical equipment.

• Mechanical Maintenance Supervisor I Lead:

Supervise OSC activities related to mechanical equipment.

• l&C Supervisor I Lead:

Supervise OSC activities related to l&C equipment. May be combined with Electrical Supervisor.

• (1) Radiation Protection Supervisor I Lead:

Supervise OSC activities related to radiation protection.

31 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 60 min.

Augment w/in 90 min.

min.

Proposed Wording Supervision of Repair Not Applicable (1) OSC Director OSC Supervisor(s)

Not applicable EP-DR-1000, Part Ill Team Activities Supervise OSC. Electrical Appendix 5, Table 5-1 activities as MaiAteAaAce directed by S1:113eFViser tbeas:

Emergency S1:113eFVise GSG Coordinator.

activities relates te electrical eEJ1:1i13FfleAt.

. Mecl=laAical MaiAteAaAce S1:113eFViser t beas:

S1:113eFVise GSG activities relates te Fflecl=laAical eEJ1:1i13FfleAt.

. l&G S1:113eFViser I beas: S1:113er¥ise GSG activities relates te l&G eEJ1:1i13FfleAt. May se C8FflBiAeS witl=I Electrical S1:113eFViser.

As needed

. (1) Radiation Protection Supervisor I Lead1: Supervise OSC activities related to radiation protection.

32 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 60 min.

Augment w/in 90 min.

min.

Reason for Change - Changes to Table B-1 reflect the changes to the Dresden ERO discussed in this Attachment. The Electrical, Mechanical and l&C Supervisor/Lead positions have been deleted. Additionally, the RP Supervisor/Lead position has been identified as a collateral responsibility for a responding RP Tech. Evaluation of this ERO position's responsibilities is performed in Attachment 4, ERO Task Analysis, including an evaluation of which responsibilities can be deleted and which can be reassigned. This revision is further discussed in Attachment 1, Section 5.3.10, Evaluation of Proposed Changes. The reassignment of ERO responsibilities will be further demonstrated through the performance of drills utilizing the revised procedures and staffing (reference Attachment 5 Commitments).

TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 90 Augment w/in 60 min.

min.

min.

Current Wording Field Monitoring Teams Not Applicable Onsite FM Not applicable EP-DR-1000, Part Ill (FMTs)

Individual Appendix 5, Table 5-1

• ( 1) Q1::1alifie8 insivi81::1al RP Personnel to Offsite FMT B assess the

• Qualified protected area for individual to radiation and assess the area(s) contamination outside the and provide in put protected area for to the TSC RPM.

radiation and Responsible for contamination, radiation and for radioactive protection plume tracking, as coverage for the directed by, and FMT as directed under the control 33 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 90 Augment w/in 60 min.

min.

min.

byTSC RPM or of, the EOF DAG EOF RPM.

or RPM.

Responsible for Offsite FMT A the radiation

• (1)Qualified protection individual to coverage of the assess the area(s)

FMT as directed outside the by EOF RPM.

protected area for radiation and

. (1) Driver to provide contamination, transportation.

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 FMT as directed by EOF RPM.

• (1) Driver to provide transportation.

Proposed Wording Supervision of Repair Not Applicable Onsite FM Not applicable EP-DR-1000, Part Ill Team Activities Individual Appendix 5, Table 5-1

• ( 1) Ql:lalifieEl 34 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 90 Augment w/in 60 min.

min.

min.

iAEliviEl1:1al RP Personnel to assess the protected area for radiation and contamination Offsite FMT B and provide input

• Qualified to the TSC RPM.

individual to Responsible for assess the area(s) radiation outside the protection protected area for coverage for the radiation and FMT as directed contamination, byTSC RPM or and for radioactive EOF RPM.

plume tracking, as directed by, and Offsite FMT A under the control

• (1)Qualified of, the EOF DAC individual to or RPM.

assess the area(s)

Responsible for outside the the radiation protected area for protection radiation and coverage of the contamination, FMT as directed and for radioactive by EOF RPM.

plume tracking, as (1) Driver to provide directed by, and under the control transportation.

of, the EOF DAC or RPM.

Responsible for 35 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN TSC I OSC EOF - Alert or Emergency Greater Preparedness (EP)

On Shift Alert or Greater Alert or Greater Functions Augment w/in 60 Augment w/in 90 Augment w/in 60 min.

min.

min.

the radiation protection coverage of the FMT as directed by EOF RPM.

... ( 1) Driver to provide transportation.

Reason for Change - Changes to Table B-1 reflect the changes to the Dresden ERO discussed in this Attachment. The On Site Field Monitoring Team Member has been revised from a Qualified Individual to one (1) RP Personnel. Evaluation of this ERO position's responsibilities is performed in, ERO Task Analysis, including an evaluation of which responsibilities can be deleted and which can be reassigned. This revision is further discussed in Attachment 1, Section 5.3.11, Evaluation of Proposed Changes. The reassignment of ERO responsibilities will be further demonstrated through the performance of drills utilizing the revised procedures and staffing (reference Attachment 5 Commitments).

36 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Summary of Changes to Dresden Emergency Plan EP-AA-1004 - Radiological Emergency Plan Annex for Dresden Station Emergency Plan Section EP-AA-1004 EP-AA-1004 Annex EP-AA-1004 Annex Section 1.1; Facility Description Current Wording Proposed Wording Reason for Change Note: This table provides a summary of changes to EP-AA-1004, Radiological Emergency Plan Annex for Dresden Station.

Besides the changes associated with the permanent shutdown evaluated below, there are multiple editorial changes that are proposed in this license amendment request, i.e., they do not change the intent of the document. They do not impact the ability to comply with Regulatory Guidance or level of commitments made in the Emergency Plan. These changes are marked with revision bars within the Emergency Plan (except changes to step numbers);

however, they are not specifically evaluated in the change assessment, since they are editorial. These include:

Changes in step numbers as a result of information which has been relocated or deleted.

Page number changes within the Table of Contents Correction of spelling errors Changes in Revision numbering and Revision History 1.1 Facility Description Dresden Station, Units 1, 2 and 3, is located in the Goose Lake Township of Grundy County in northeastern Illinois. Unit 1 is in permanent shutdown (see Figure 1-1).

The plant consists of three Boiling Water Reactor (BWR)

Nuclear Steam Supply Systems (NSSS) and turbine generators provided by General Electric Company. Unit 1 is a dual cycle boiling water reactor designed for a power output of 700 MWt and has officially been retired as of August 31, 1984. Units 2 and 3 are equipped with nuclear steam supply systems (NSSS) designed for a power output of 2957 MWt.

The station property consists of a 953-acre tract of land with boundaries generally following the Illinois River to the north, the Kankakee River on the south and east and the Elgin, Joliet and Eastern Railway right-of-way on the west. Exelon is the sole owner of the 953-acre tract subject only to an easement of the U.S. Government for an access road to Dresden Island Lock and Dam maintained and operated by the U.S. Corps. of 1.1 Facility Description Dresden Station, Units 1, 2 and 3, is located in the Goose Lake Township of Grundy County in northeastern Illinois.

Unit 1 is in permanent shutdown (see Figure 1-1).

The plant seAsists consisted of three Boiling Water Reactor (BWR) Nuclear Steam Supply Systems (NSSS) and turbine generators provided by General Electric Company. Unit 1 is a dual cycle boiling water reactor designed for a power output of 700 MWt and has officially been retired as of August 31, 1984. Units 2 and 3 are eE11:1i1313eEl wiU1 Al:lslear steaFA s1:11313ly systeFAs (~JSSS)

Elesi§AeEl fer a 13ewer e1:1t131:1t ef 29a7 MV\\/t permanently defueled.

The station property consists of a 953-acre tract of land with boundaries generally following the Illinois River to the north, the Kankakee River on the south and east and the Elgin, Joliet and Eastern Railway right-of-way on the west.

Exelon is the sole owner of the 953-acre tract subject only to an easement of the U.S. Government for an access road to Dresden Island Lock and Dam maintained and 37 This revision recognizes the permanently defueled condition for Dresden.

TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section Engineers. This road traverses the site from north to operated by the U.S. Corps. of Engineers. This road south - 0.8 mile west of the plant.

traverses the site from north to south - 0.8 mile west of In addition to ownership of the 953-acre tract, Exelon the plant.

Nuclear also leases approximately 17 acres in two In addition to ownership of the 953-acre tract, Exelon narrow strips of river frontage located near the northeast Nuclear also leases approximately 17 acres in two narrow corner of the site from the State of Illinois. The terms of strips of river frontage located near the northeast corner of the lease provide that these "buffer" strips shall remain the site from the State of Illinois. The terms of the lease idle.

provide that these "buffer" strips shall remain idle.

For more specific site location information, refer to the For more specific site location information, refer to the Station UFSAR.

Station UFSAR.

EP-AA-1004 Annex 4.2 Assessment Actions 4.2 Assessment Actions This revision deletes reference to Section 4.2 Throughout each emergency situation, continuing Throughout each emergency situation, continuing Core Damage Assessment assessment will occur. Assessment actions at Dresden assessment will occur. Assessment actions at Dresden personnel and CDAM.

Assessment Actions Station may include an evaluation of plant conditions; in-Station may include an evaluation of plant conditions; in-The permanent shutdown of the plant, onsite, and initial offsite radiological plant, onsite, and initial offsite radiological measurements; Dresden reactors and defueled measurements; and initial estimates of offsite doses.

and initial estimates of offsite doses. GeFe lama§e status makes the reference to Core damage information is used to refine dose iAfeFA'latieA is l:JseEI te rnfiAe Elese assessffleAts aAEI CDAM unnecessary within the assessments and confirm or extend initial protective eeAfiFA'l eF e*teAEI iAitial 13Feteetive aetieA Emergency Plan.

action recommendations. Dresden Station utilizes FeeefflffleAElatieAs. QFesEleA StatieA l:Jtili:t:es ~H~QG NEDC-33045P-A, Revision 0, (2001) as the basis for the ddQ4 aP /\\, RevisieA Q, (~QQ~) as Hie 9asis feF Hie methodology for post-accident core damage rneUmElele§y feF 13est assiEleAt seFe ElaFAa§e assessrneAt.

assessment. This methodology utilizes real-time plant

+t=iis rnett=ieElele§y l:Jtili:t:es Feal tiffle 13laAt iAElieatieAs. IA indications. In addition, Dresden Station may use aEIElitieA, QFesEleA StatieA Fflay l:JSe saffl13les ef 13laAt fll:JiEls samples of plant fluids and atmospheres as inputs to the aAEI atffles13t=leFes as iA13l:Jts te tt=ie GQAM (GeFe Qaffla§e CDAM (Core Damage Assessment Methodology)

/\\ssessFAeAt Mett=ieElele§y) 13FS§FaFA feF eern ElaFAa§e program for core damage estimation.

estirnatieA.

38 TABULAR

SUMMARY

OF CHANGES TO DRESDEN EMERGENCY PLAN Emergency Plan Current Wording Proposed Wording Reason for Change Section EP-AA-1004 Annex 5.2.2.4 High Range Containment Radiation Monitors a. ~.~.4 Deleted ~i§IR RaA§le GeAlaiAFReAI RaElialieA This revision deletes high range Section 5 Two high range containment radiation monitors are MeAileFs containment radiation monitors.

5.2.2.4 installed on each of Dresden's units. The range of

+>11*9 Ri§R FaA§9 69AlaiAFA9AI FaElialieA FA9Ail9F6 aFe The permanent shutdown of the these monitors is from 1 R/hr to 108 R/hr.

iAstalleEl eA easl=i ef QFesEleA's 1:mits. +Re FaA§e ef Dresden reactors and defueled High Range tl=iese FReAiteFS is fFeFA 1 R/l=iF ta 1 Q8-Rfl::lf,.

status makes the reference to Containment high range containment radiation Radiation Monitors monitors unnecessary within the Emergency Plan EP-AA-1004 Annex 5.2.3 Onsite Process Monitors 5.2.3 Onsite Process Monitors This revision removes modes of Section 5 Adequate monitoring capability exists to properly Adequate monitoring capability exists to properly operation and reference to inadequate core cooling.

5.2.3 assess the plant status for the modes of operation.

assess the plant status foF tl=ie FAeEles ef e13emtieA.

The operability of the post-accident instrumentation The operability of the post-accident instrumentation The permanent shutdown of the Onsite Process ensures information is available on selected plant ensures information is available on selected plant Dresden reactors and defueled Monitors parameters to monitor and assess important parameters to monitor and assess important variables status makes the reference to variables following an accident. Instrumentation is following an accident. Instrumentation is available to modes of operation and core available to monitor the parameters and ranges monitor the parameters and ranges given in the cooling unnecessary within the given in the Dresden Station Technical Dresden Station Technical Specifications.

Emergency Plan Specifications.

StatieA 13rnseEl1:JFes l=iave 9eeA Elevele13eEl wl=iisl=i wel:llEl Station procedures have been developed which aiEl 13eFS9AAel iA Fe69§Aii!'iA§ iAaEleE11:Jale 69Fe seeliA§ would aid personnel in recognizing inadequate core l:lSiA§ a1313lisal3le iAStFl:lFAeAlatieA.

cooling using applicable instrumentation.

39