RS-15-327, Company Submittal of Radiological Emergency Plan Implementing Procedure EP-AA-112-F-01, Revision G, Command and Control Turnover Briefing Form.

From kanterella
Jump to navigation Jump to search
Company Submittal of Radiological Emergency Plan Implementing Procedure EP-AA-112-F-01, Revision G, Command and Control Turnover Briefing Form.
ML15357A044
Person / Time
Site: Dresden, Peach Bottom, Oyster Creek, Byron, Three Mile Island, Braidwood, Limerick, Clinton, Quad Cities, LaSalle  Constellation icon.png
Issue date: 12/15/2015
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML15357A023 List:
References
RA-15-112, RS-15-327, TMI-15-138
Download: ML15357A044 (10)
v • d • e


Text

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

,.al-2.--* Exelon Generation 10 CFR 50, Appendix E 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)

RS-15-327 RA-15-112 TMl-15-138 December 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, STN 50-457, and 72-73 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454, STN 50-455, and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237. 50-249. and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374. and 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 A-Y4S Attachment 3 contains Exelon Confidential/Proprietary Information; /(Jt4SS2b upon separation this cover letter and Attachments 1 and 2 are decontrolled.

µHS)2[_

l'-llL

/LIHS5

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page2 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating [Possession Only] License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278 and 72-79 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only License No. DPR-73 NRC Docket No. 50-320

Subject:

Exelon Generation Company Radiological Emergency Plan Implementing Procedure Revision In accordance with 10 CFR 50, Appendix E, Section V, "Implementing Procedures," Exelon Generation Company, LLC (EGC) is submitting the Emergency Plan implementing procedure revision listed in the table below for the following plants:

  • Braidwood Station
  • Byron Station
  • Clinton Power Station
  • Dresden Nuclear Power Station
  • LaSalle County Station
  • Limerick Generating Station
  • Oyster Creek Nuclear Generating Station
  • Peach Bottom Atomic Power Station
  • Quad Cities Nuclear Power Station
  • Three Mile Island Nuclear Station Procedure No. Revision Title I I EP-AA-112-F-O 1 G I Command and Control Turnover Briefing Form The changes to the Emergency Plan implementing procedure were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plans for the affected sites. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50, Appendix E. The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. In addition, as required by 10 CFR 50.54(q)(5), Attachment 1 of this submittal includes a summary analysis of the changes to the implementing procedure.

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page 3 of this letter contains a copy of the revised Emergency Plan implementing procedure, which is considered proprietary and confidential and contains trade secrets and commercial or financial information. EGC maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4), and has attached an affidavit for this purpose (Attachment 2). However, if the NRC intends to place any of this information in the Public Document Room or on the Agencywide Documents Access and Management System or produce it in response to a Freedom of Information Act (FOIA) request, EGC requests the opportunity to redact the materials consistent with established FOIA exemptions and precedent.

This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee

  • shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

There are no regulatory commitments in this submittal.

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

Respectfully, JamesJ.~b~

Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis
2. Affidavit
3. EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" cc: w/ Attachments 1 and 2 only Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector- Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector- Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page4 cc: w/ Attachments 1 and 2 only (continued)

NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S. T. Gray, State of Maryland

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

Attachment 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1 of 1 Document Title The following Exelon Generation Company, LLC (EGC) Emergency Plan implementing procedure/form has been revised for the EGC Midwest and Mid-Atlantic plants listed:

Affected Plants Braidwood, Byron, Clinton, Dresden, LaSalle, Limerick, Oyster Creek, Peach Bottom, Quad Cities, c:ind Three Mile Island

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" The procedure/form listed above contains Exelon Confidential/Proprietary Information and EGC is requesting that the document be withheld from public disclosure pursuant to 10 CFR 2.390.

Description of Procedure The Emergency Plan implementing procedure/form above provides guidance for conducting Command and Control turnover for the plants cited.

Description of Changes This procedure/form was revised to remove items that are no longer considered necessary to conduct Command and Control turnover functions.

Description of How the Changes Still Comply with Regulations The revision to the procedure/form continues to satisfy the applicable Emergency Planning Standard requirements established in 10 CFR 50.47(b)(1) and 50.47(b)(2), and the Program Element guidance specified in NUREG-0654, Sections II.A and B. The changes made to the procedure/form do not alter assigned emergency preparedness responsibilities and functions.

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

The revised procedure/form remains consistent with the requirements of the Emergency Planning Standard requirements specified in 10 CFR 50.47(b)(1) and 50.47(b)(2}, as well as the Program Element guidance included NUREG-0654, Sections II.A and B. This revision to the procedure/form does not alter the capability of the Emergency Response Organization (ERO) to implement required Emergency Plan functions, and does not affect the timeliness of the performance of these functions. Therefore, the changes to the procedure/form do not result in a reduction in the effectiveness of the Emergency Plans for the affected sites.

ATTACHMENT 2 Affidavit

AFFIDAVIT OF JAMES BARSTOW DOCKET NOS. STN 50-456, STN 50-457, 72-73, STN 50-454, STN 50-455, 72-68, 50-461,50-010, 50-237, 50-249, 72-37, 50-373, 50-374, 72-70, 50-352, 50-353, 72-65, 50-219, 72-15, 50-171, 50-277, 50-278, 72-79, 50-254, 50-265, 72-53, 50-289, and 50-320 I, James Barstow, Director, Licensing and Regulatory Affairs, Exelon Generation Company, LLC, do hereby affirm and state:

1. I am Director, Licensing and Regulatory Affairs for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf ofEGC.
2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission

("NRC):

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form"
3. I am also authorized to apply to the NRC for the withholding of the aforementioned documents from public disclosure under 10 C.F.R. §§ 2.390(a)(4) and 9.17(a)(4) on the grounds that the documents contain privileged or confidential or proprietary commercial information. The documents EGC seeks to withhold from public disclosure have been marked "Proprietary" and are summarized in the attachment to my Affidavit.
4. On behalf of EGC, I request that the documents marked by EGC as "Proprietary" and described in the attached list (Appendix 1) be withheld, in their entirety, by the NRC from public disclosure.
5. In making this application for withholding of proprietary and confidential information of which EGC is the owner, EGC relies on 10 C.F.R. § 2.390(a)(4) and 10 C.F.R. 9.17(a)(4). The proprietary documents contain privileged or confidential or proprietary commercial information.
6. The proprietary information described in Appendix 1 should be withheld from disclosure by the NRC pursuant to the policy reflected in 10 C.F.R. § 2.390(a)(4), and for the following reasons to be considered pursuant to 10 CFR § 2.390(b)(4):

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

IL The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business. It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM. EGC derives Page 1 of2 Attachment 2

economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the ENMM.

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

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

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.
7. EGC requests that each of the documents listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v.

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

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Date: December 15, 2015 Page 2 of2 Attachment 2

Attachment 2 Appendix 1 Page 1 of2 Appendix 1: Information that Should Be Withheld from Public Disclosure Date or Revision Description of Document Reason(s) to Withhold Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.l 7(a)(4)

Revision G EP-AA-112-F-01 based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

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

,.al-2.--* Exelon Generation 10 CFR 50, Appendix E 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)

RS-15-327 RA-15-112 TMl-15-138 December 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, STN 50-457, and 72-73 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454, STN 50-455, and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237. 50-249. and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374. and 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 A-Y4S Attachment 3 contains Exelon Confidential/Proprietary Information; /(Jt4SS2b upon separation this cover letter and Attachments 1 and 2 are decontrolled.

µHS)2[_

l'-llL

/LIHS5

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page2 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating [Possession Only] License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278 and 72-79 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only License No. DPR-73 NRC Docket No. 50-320

Subject:

Exelon Generation Company Radiological Emergency Plan Implementing Procedure Revision In accordance with 10 CFR 50, Appendix E, Section V, "Implementing Procedures," Exelon Generation Company, LLC (EGC) is submitting the Emergency Plan implementing procedure revision listed in the table below for the following plants:

  • Braidwood Station
  • Byron Station
  • Clinton Power Station
  • Dresden Nuclear Power Station
  • LaSalle County Station
  • Limerick Generating Station
  • Oyster Creek Nuclear Generating Station
  • Peach Bottom Atomic Power Station
  • Quad Cities Nuclear Power Station
  • Three Mile Island Nuclear Station Procedure No. Revision Title I I EP-AA-112-F-O 1 G I Command and Control Turnover Briefing Form The changes to the Emergency Plan implementing procedure were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plans for the affected sites. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50, Appendix E. The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. In addition, as required by 10 CFR 50.54(q)(5), Attachment 1 of this submittal includes a summary analysis of the changes to the implementing procedure.

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page 3 of this letter contains a copy of the revised Emergency Plan implementing procedure, which is considered proprietary and confidential and contains trade secrets and commercial or financial information. EGC maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4), and has attached an affidavit for this purpose (Attachment 2). However, if the NRC intends to place any of this information in the Public Document Room or on the Agencywide Documents Access and Management System or produce it in response to a Freedom of Information Act (FOIA) request, EGC requests the opportunity to redact the materials consistent with established FOIA exemptions and precedent.

This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee

  • shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

There are no regulatory commitments in this submittal.

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

Respectfully, JamesJ.~b~

Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis
2. Affidavit
3. EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" cc: w/ Attachments 1 and 2 only Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector- Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector- Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page4 cc: w/ Attachments 1 and 2 only (continued)

NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S. T. Gray, State of Maryland

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

Attachment 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1 of 1 Document Title The following Exelon Generation Company, LLC (EGC) Emergency Plan implementing procedure/form has been revised for the EGC Midwest and Mid-Atlantic plants listed:

Affected Plants Braidwood, Byron, Clinton, Dresden, LaSalle, Limerick, Oyster Creek, Peach Bottom, Quad Cities, c:ind Three Mile Island

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" The procedure/form listed above contains Exelon Confidential/Proprietary Information and EGC is requesting that the document be withheld from public disclosure pursuant to 10 CFR 2.390.

Description of Procedure The Emergency Plan implementing procedure/form above provides guidance for conducting Command and Control turnover for the plants cited.

Description of Changes This procedure/form was revised to remove items that are no longer considered necessary to conduct Command and Control turnover functions.

Description of How the Changes Still Comply with Regulations The revision to the procedure/form continues to satisfy the applicable Emergency Planning Standard requirements established in 10 CFR 50.47(b)(1) and 50.47(b)(2), and the Program Element guidance specified in NUREG-0654, Sections II.A and B. The changes made to the procedure/form do not alter assigned emergency preparedness responsibilities and functions.

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

The revised procedure/form remains consistent with the requirements of the Emergency Planning Standard requirements specified in 10 CFR 50.47(b)(1) and 50.47(b)(2}, as well as the Program Element guidance included NUREG-0654, Sections II.A and B. This revision to the procedure/form does not alter the capability of the Emergency Response Organization (ERO) to implement required Emergency Plan functions, and does not affect the timeliness of the performance of these functions. Therefore, the changes to the procedure/form do not result in a reduction in the effectiveness of the Emergency Plans for the affected sites.

ATTACHMENT 2 Affidavit

AFFIDAVIT OF JAMES BARSTOW DOCKET NOS. STN 50-456, STN 50-457, 72-73, STN 50-454, STN 50-455, 72-68, 50-461,50-010, 50-237, 50-249, 72-37, 50-373, 50-374, 72-70, 50-352, 50-353, 72-65, 50-219, 72-15, 50-171, 50-277, 50-278, 72-79, 50-254, 50-265, 72-53, 50-289, and 50-320 I, James Barstow, Director, Licensing and Regulatory Affairs, Exelon Generation Company, LLC, do hereby affirm and state:

1. I am Director, Licensing and Regulatory Affairs for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf ofEGC.
2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission

("NRC):

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form"
3. I am also authorized to apply to the NRC for the withholding of the aforementioned documents from public disclosure under 10 C.F.R. §§ 2.390(a)(4) and 9.17(a)(4) on the grounds that the documents contain privileged or confidential or proprietary commercial information. The documents EGC seeks to withhold from public disclosure have been marked "Proprietary" and are summarized in the attachment to my Affidavit.
4. On behalf of EGC, I request that the documents marked by EGC as "Proprietary" and described in the attached list (Appendix 1) be withheld, in their entirety, by the NRC from public disclosure.
5. In making this application for withholding of proprietary and confidential information of which EGC is the owner, EGC relies on 10 C.F.R. § 2.390(a)(4) and 10 C.F.R. 9.17(a)(4). The proprietary documents contain privileged or confidential or proprietary commercial information.
6. The proprietary information described in Appendix 1 should be withheld from disclosure by the NRC pursuant to the policy reflected in 10 C.F.R. § 2.390(a)(4), and for the following reasons to be considered pursuant to 10 CFR § 2.390(b)(4):

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

IL The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business. It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM. EGC derives Page 1 of2 Attachment 2

economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the ENMM.

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

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

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.
7. EGC requests that each of the documents listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v.

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

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Date: December 15, 2015 Page 2 of2 Attachment 2

Attachment 2 Appendix 1 Page 1 of2 Appendix 1: Information that Should Be Withheld from Public Disclosure Date or Revision Description of Document Reason(s) to Withhold Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.l 7(a)(4)

Revision G EP-AA-112-F-01 based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Text

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

,.al-2.--* Exelon Generation 10 CFR 50, Appendix E 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)

RS-15-327 RA-15-112 TMl-15-138 December 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, STN 50-457, and 72-73 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454, STN 50-455, and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237. 50-249. and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374. and 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 A-Y4S Attachment 3 contains Exelon Confidential/Proprietary Information; /(Jt4SS2b upon separation this cover letter and Attachments 1 and 2 are decontrolled.

µHS)2[_

l'-llL

/LIHS5

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page2 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating [Possession Only] License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278 and 72-79 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only License No. DPR-73 NRC Docket No. 50-320

Subject:

Exelon Generation Company Radiological Emergency Plan Implementing Procedure Revision In accordance with 10 CFR 50, Appendix E, Section V, "Implementing Procedures," Exelon Generation Company, LLC (EGC) is submitting the Emergency Plan implementing procedure revision listed in the table below for the following plants:

  • Braidwood Station
  • Byron Station
  • Clinton Power Station
  • Dresden Nuclear Power Station
  • LaSalle County Station
  • Limerick Generating Station
  • Oyster Creek Nuclear Generating Station
  • Peach Bottom Atomic Power Station
  • Quad Cities Nuclear Power Station
  • Three Mile Island Nuclear Station Procedure No. Revision Title I I EP-AA-112-F-O 1 G I Command and Control Turnover Briefing Form The changes to the Emergency Plan implementing procedure were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plans for the affected sites. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50, Appendix E. The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. In addition, as required by 10 CFR 50.54(q)(5), Attachment 1 of this submittal includes a summary analysis of the changes to the implementing procedure.

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page 3 of this letter contains a copy of the revised Emergency Plan implementing procedure, which is considered proprietary and confidential and contains trade secrets and commercial or financial information. EGC maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4), and has attached an affidavit for this purpose (Attachment 2). However, if the NRC intends to place any of this information in the Public Document Room or on the Agencywide Documents Access and Management System or produce it in response to a Freedom of Information Act (FOIA) request, EGC requests the opportunity to redact the materials consistent with established FOIA exemptions and precedent.

This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee

  • shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

There are no regulatory commitments in this submittal.

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

Respectfully, JamesJ.~b~

Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis
2. Affidavit
3. EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" cc: w/ Attachments 1 and 2 only Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector- Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector- Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page4 cc: w/ Attachments 1 and 2 only (continued)

NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S. T. Gray, State of Maryland

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

Attachment 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1 of 1 Document Title The following Exelon Generation Company, LLC (EGC) Emergency Plan implementing procedure/form has been revised for the EGC Midwest and Mid-Atlantic plants listed:

Affected Plants Braidwood, Byron, Clinton, Dresden, LaSalle, Limerick, Oyster Creek, Peach Bottom, Quad Cities, c:ind Three Mile Island

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" The procedure/form listed above contains Exelon Confidential/Proprietary Information and EGC is requesting that the document be withheld from public disclosure pursuant to 10 CFR 2.390.

Description of Procedure The Emergency Plan implementing procedure/form above provides guidance for conducting Command and Control turnover for the plants cited.

Description of Changes This procedure/form was revised to remove items that are no longer considered necessary to conduct Command and Control turnover functions.

Description of How the Changes Still Comply with Regulations The revision to the procedure/form continues to satisfy the applicable Emergency Planning Standard requirements established in 10 CFR 50.47(b)(1) and 50.47(b)(2), and the Program Element guidance specified in NUREG-0654, Sections II.A and B. The changes made to the procedure/form do not alter assigned emergency preparedness responsibilities and functions.

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

The revised procedure/form remains consistent with the requirements of the Emergency Planning Standard requirements specified in 10 CFR 50.47(b)(1) and 50.47(b)(2}, as well as the Program Element guidance included NUREG-0654, Sections II.A and B. This revision to the procedure/form does not alter the capability of the Emergency Response Organization (ERO) to implement required Emergency Plan functions, and does not affect the timeliness of the performance of these functions. Therefore, the changes to the procedure/form do not result in a reduction in the effectiveness of the Emergency Plans for the affected sites.

ATTACHMENT 2 Affidavit

AFFIDAVIT OF JAMES BARSTOW DOCKET NOS. STN 50-456, STN 50-457, 72-73, STN 50-454, STN 50-455, 72-68, 50-461,50-010, 50-237, 50-249, 72-37, 50-373, 50-374, 72-70, 50-352, 50-353, 72-65, 50-219, 72-15, 50-171, 50-277, 50-278, 72-79, 50-254, 50-265, 72-53, 50-289, and 50-320 I, James Barstow, Director, Licensing and Regulatory Affairs, Exelon Generation Company, LLC, do hereby affirm and state:

1. I am Director, Licensing and Regulatory Affairs for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf ofEGC.
2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission

("NRC):

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form"
3. I am also authorized to apply to the NRC for the withholding of the aforementioned documents from public disclosure under 10 C.F.R. §§ 2.390(a)(4) and 9.17(a)(4) on the grounds that the documents contain privileged or confidential or proprietary commercial information. The documents EGC seeks to withhold from public disclosure have been marked "Proprietary" and are summarized in the attachment to my Affidavit.
4. On behalf of EGC, I request that the documents marked by EGC as "Proprietary" and described in the attached list (Appendix 1) be withheld, in their entirety, by the NRC from public disclosure.
5. In making this application for withholding of proprietary and confidential information of which EGC is the owner, EGC relies on 10 C.F.R. § 2.390(a)(4) and 10 C.F.R. 9.17(a)(4). The proprietary documents contain privileged or confidential or proprietary commercial information.
6. The proprietary information described in Appendix 1 should be withheld from disclosure by the NRC pursuant to the policy reflected in 10 C.F.R. § 2.390(a)(4), and for the following reasons to be considered pursuant to 10 CFR § 2.390(b)(4):

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

IL The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business. It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM. EGC derives Page 1 of2 Attachment 2

economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the ENMM.

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

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

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.
7. EGC requests that each of the documents listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v.

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

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Date: December 15, 2015 Page 2 of2 Attachment 2

Attachment 2 Appendix 1 Page 1 of2 Appendix 1: Information that Should Be Withheld from Public Disclosure Date or Revision Description of Document Reason(s) to Withhold Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.l 7(a)(4)

Revision G EP-AA-112-F-01 based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

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

,.al-2.--* Exelon Generation 10 CFR 50, Appendix E 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)

RS-15-327 RA-15-112 TMl-15-138 December 15, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, STN 50-457, and 72-73 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454, STN 50-455, and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237. 50-249. and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374. and 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Exelon Confidential/Proprietary Information - Withhold Under 10 CFR 2.390 A-Y4S Attachment 3 contains Exelon Confidential/Proprietary Information; /(Jt4SS2b upon separation this cover letter and Attachments 1 and 2 are decontrolled.

µHS)2[_

l'-llL

/LIHS5

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page2 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating [Possession Only] License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278 and 72-79 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only License No. DPR-73 NRC Docket No. 50-320

Subject:

Exelon Generation Company Radiological Emergency Plan Implementing Procedure Revision In accordance with 10 CFR 50, Appendix E, Section V, "Implementing Procedures," Exelon Generation Company, LLC (EGC) is submitting the Emergency Plan implementing procedure revision listed in the table below for the following plants:

  • Braidwood Station
  • Byron Station
  • Clinton Power Station
  • Dresden Nuclear Power Station
  • LaSalle County Station
  • Limerick Generating Station
  • Oyster Creek Nuclear Generating Station
  • Peach Bottom Atomic Power Station
  • Quad Cities Nuclear Power Station
  • Three Mile Island Nuclear Station Procedure No. Revision Title I I EP-AA-112-F-O 1 G I Command and Control Turnover Briefing Form The changes to the Emergency Plan implementing procedure were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plans for the affected sites. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50, Appendix E. The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. In addition, as required by 10 CFR 50.54(q)(5), Attachment 1 of this submittal includes a summary analysis of the changes to the implementing procedure.

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page 3 of this letter contains a copy of the revised Emergency Plan implementing procedure, which is considered proprietary and confidential and contains trade secrets and commercial or financial information. EGC maintains this information on a confidential basis and protects it from disclosure to the general public or unauthorized individuals. EGC requests that be withheld from public disclosure pursuant to 10 CFR 2.390(a)(4), and has attached an affidavit for this purpose (Attachment 2). However, if the NRC intends to place any of this information in the Public Document Room or on the Agencywide Documents Access and Management System or produce it in response to a Freedom of Information Act (FOIA) request, EGC requests the opportunity to redact the materials consistent with established FOIA exemptions and precedent.

This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee

  • shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

There are no regulatory commitments in this submittal.

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

Respectfully, JamesJ.~b~

Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. 10 CFR 50.54(q)(5) Procedure Change Summary Analysis
2. Affidavit
3. EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" cc: w/ Attachments 1 and 2 only Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector- Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector- Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station

U.S. Nuclear Regulatory Commission Emergency Plan Implementing Procedure Revision December 15, 2015 Page4 cc: w/ Attachments 1 and 2 only (continued)

NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ S. T. Gray, State of Maryland

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

Attachment 1 10 CFR 50.54(q)(5) Procedure Change Summary Analysis Page 1 of 1 Document Title The following Exelon Generation Company, LLC (EGC) Emergency Plan implementing procedure/form has been revised for the EGC Midwest and Mid-Atlantic plants listed:

Affected Plants Braidwood, Byron, Clinton, Dresden, LaSalle, Limerick, Oyster Creek, Peach Bottom, Quad Cities, c:ind Three Mile Island

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form" The procedure/form listed above contains Exelon Confidential/Proprietary Information and EGC is requesting that the document be withheld from public disclosure pursuant to 10 CFR 2.390.

Description of Procedure The Emergency Plan implementing procedure/form above provides guidance for conducting Command and Control turnover for the plants cited.

Description of Changes This procedure/form was revised to remove items that are no longer considered necessary to conduct Command and Control turnover functions.

Description of How the Changes Still Comply with Regulations The revision to the procedure/form continues to satisfy the applicable Emergency Planning Standard requirements established in 10 CFR 50.47(b)(1) and 50.47(b)(2), and the Program Element guidance specified in NUREG-0654, Sections II.A and B. The changes made to the procedure/form do not alter assigned emergency preparedness responsibilities and functions.

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

The revised procedure/form remains consistent with the requirements of the Emergency Planning Standard requirements specified in 10 CFR 50.47(b)(1) and 50.47(b)(2}, as well as the Program Element guidance included NUREG-0654, Sections II.A and B. This revision to the procedure/form does not alter the capability of the Emergency Response Organization (ERO) to implement required Emergency Plan functions, and does not affect the timeliness of the performance of these functions. Therefore, the changes to the procedure/form do not result in a reduction in the effectiveness of the Emergency Plans for the affected sites.

ATTACHMENT 2 Affidavit

AFFIDAVIT OF JAMES BARSTOW DOCKET NOS. STN 50-456, STN 50-457, 72-73, STN 50-454, STN 50-455, 72-68, 50-461,50-010, 50-237, 50-249, 72-37, 50-373, 50-374, 72-70, 50-352, 50-353, 72-65, 50-219, 72-15, 50-171, 50-277, 50-278, 72-79, 50-254, 50-265, 72-53, 50-289, and 50-320 I, James Barstow, Director, Licensing and Regulatory Affairs, Exelon Generation Company, LLC, do hereby affirm and state:

1. I am Director, Licensing and Regulatory Affairs for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf ofEGC.
2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission

("NRC):

  • EP-AA-112-F-01, Revision G, "Command and Control Turnover Briefing Form"
3. I am also authorized to apply to the NRC for the withholding of the aforementioned documents from public disclosure under 10 C.F.R. §§ 2.390(a)(4) and 9.17(a)(4) on the grounds that the documents contain privileged or confidential or proprietary commercial information. The documents EGC seeks to withhold from public disclosure have been marked "Proprietary" and are summarized in the attachment to my Affidavit.
4. On behalf of EGC, I request that the documents marked by EGC as "Proprietary" and described in the attached list (Appendix 1) be withheld, in their entirety, by the NRC from public disclosure.
5. In making this application for withholding of proprietary and confidential information of which EGC is the owner, EGC relies on 10 C.F.R. § 2.390(a)(4) and 10 C.F.R. 9.17(a)(4). The proprietary documents contain privileged or confidential or proprietary commercial information.
6. The proprietary information described in Appendix 1 should be withheld from disclosure by the NRC pursuant to the policy reflected in 10 C.F.R. § 2.390(a)(4), and for the following reasons to be considered pursuant to 10 CFR § 2.390(b)(4):

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

IL The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business. It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM. EGC derives Page 1 of2 Attachment 2

economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the ENMM.

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

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

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.
7. EGC requests that each of the documents listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v.

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

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Date: December 15, 2015 Page 2 of2 Attachment 2

Attachment 2 Appendix 1 Page 1 of2 Appendix 1: Information that Should Be Withheld from Public Disclosure Date or Revision Description of Document Reason(s) to Withhold Entire document exempt from disclosure under 10 C.F.R. § 2.390(a)(4) and 9.l 7(a)(4)

Revision G EP-AA-112-F-01 based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Retrieved from "https://kanterella.com/w/index.php?title=RS-15-327,_Company_Submittal_of_Radiological_Emergency_Plan_Implementing_Procedure_EP-AA-112-F-01,_Revision_G,_Command_and_Control_Turnover_Briefing_Form.&oldid=2085183"