RS-16-064, Dresden, Units 1, 2, and 3 - Transmittal of Exelon Nuclear Radiological Emergency Plan Addendum Revision

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Dresden, Units 1, 2, and 3 - Transmittal of Exelon Nuclear Radiological Emergency Plan Addendum Revision
ML16083A502
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 03/23/2016
From: Gullott D M
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML16083A501 List:
References
RS-16-064
Download: ML16083A502 (11)
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Text

Exelon Confidential/Proprietary Information

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

Exelon Ge n'e rati on 10 CFR 50.54(q){5) 10 CFR 50.4 10 CFR 72.44(f) RS-16-064 March 23, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 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

Subject:

Exelon Nuclear Radiological Emergency Plan Addendum Revision In accordance with 10 CFR 50.4(b)(5), "Emergency Plan and related submissions," Exelon Generation Company, LLC (EGC) is submitting an Emergency Plan Addendum revision for Dresden Nuclear Power Station (Dresden) as listed in the table below. Document Revision Title EP-AA-1004, Addendum 3 2 Emergency Action Levels for Dresden Station The change to the Emergency Plan Addendum was evaluated under the requirements of 10 CFR 50.54(q) and was determined not to result in a reduction in the effectiveness of the Emergency Plan for Dresden. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50.4(b)(5).

The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. Furthermore, the Emergency Plan Addendum identified in Attachment 3 of this letter is 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 the Emergency Plan Addendum contained in Attachment 3 be withheld from public disclosure pursuant to 1 O 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.

Exelon Confidential/Proprietary Information

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

U.S. Nuclear Regulatory Commission Emergency Plan Addendum Revision March 23, 2016 Page2 In addition, as required by 10 CFR 50.54(q)(5), this submittal includes a summary analysis of the changes to the Emergency Plan Addendum (Attachment 1 ). This submittal also satisfies the reporting requirements associated with 1 O CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

A copy of the revised Emergency Plan Addendum and supporting change summary analysis are included in the attachments to this letter. There are no regulatory commitments in this submittal.

If you have any questions or require additional information, please contact Amy Hambly at (630) 657-2808.

Respectfully, David M. Gullatt Manager -Licensing Exelon Generation Company, LLC Attachments:

1. 1 O CFR 50.54(q)(5)

Procedure Change Summary Analysis 2. Affidavit

3. EP-AA-1004, Addendum 3, Revision 2, Emergency Action Levels for Dresden Station cc: Regional Administrator

-NRC Region Ill Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector

-Dresden Station NRC Project Manager, NRA -Dresden Station ATTACHMENT 1 10 CFR 50.54{q){5)

Procedure Change Summary Analysis 1 O CFR 50.54(g)(5l Procedure Change Summary Analysis Procedure title Exelon Generation Company, LLC (EGC) is submitting the following Emergency Plan Addendum revision for Dresden Nuclear Power Station (Dresden):

  • EP-AA-1004, Addendum 3, Revision 2, "Emergency Action Levels for Dresden Station 11 This document contains Exelon Confidential/Proprietary Information and is requested to be withheld from public disclosure pursuant to 10 CFR 2.390. Description of procedure EP-AA-1004, Addendum 3 describes the Emergency Action Levels (EALs) implemented at Dresden for entering Emergency Classification Levels (ECLs). Description of change This revision to EP-AA-1004, Addendum 3 for Dresden incorporates the following changes: 1. Implementation of NEI 99-01, Revision 6, 11 Development of Emergency Action Levels for Non-Passive Reactors, 11 which involved a complete rewrite/formatting of the document.
2. Establishes EAL thresholds for the NRC pre-approved EALs RG2 and RS2 and an additional threshold for RA2 based on Spent Fuel Pool (SFP) levels. 3. Revised EAL MU3 (ATWS) to provide clarity regarding a successful reactor shutdown.
4. Revised EALs MG1 (Prolonged Loss of all AC Power) and MS3 (Failure to Scram) to reflect NRC approved changes to the Minimum Steam Cooling Water Level (MSCWL) setpoint.

A more detailed description of the changes is provided below. 1. The revised EAL schemes based on NEI 99-01, Revision 6 were submitted to the NRC in a License Amendment Request (LAR) dated May 30, 2014. The NRC approved the LAR as documented in a letter and supporting Safety Evaluation (SE) dated July 28, 2015. Training was satisfactorily completed for the Dresden and supporting Corporate Emergency Response Organization (ERO) personnel on the revised EAL schemes during the fourth quarter of 2015. As a result, the NRG-approved EAL schemes based on the NEI 99-01, Revision 6 guidance were implemented and this revision to EP-AA-1004, Addendum 3 reflects the changes. 2. As part of the NRC approval of the new EAL Scheme, three new thresholds were approved generically without specific levels associated with them. The levels are based on enhanced SFP level devices placed in service in accordance with the information provided in Section 1.4, of NRC Order EA-12-051.

NEI 99-01, Revision 6 recommended that these EAL thresholds be implemented when the enhanced SFP level instrumentation is available for use. Page 1 of 4 Attachment 1

At Dresden, the enhanced SFP level instruments were placed in service in accordance with a site-approved design change package. For the new EALs RG2 and RS2 a 11 site specific level 3 11 threshold value is used and for RA2 there is a third threshold that uses a 11 site specific level 2" value. Based on the site-approved design change package the following thresholds were used for each of the site-specific values: A supporting site-approved calculation was used to document the logic and assumptions for establishing the EAL thresholds for SFP 11 site specific level 3 11 and 11 site specific level 2 ...

  • For EAL thresholds RG2 and RS2, the value of 0.60 foot was calculated for 11 site specific level 3 11 value.
  • For EAL threshold RA2.3 the value of 10.20 feet was calculated for 11 site specific level 2 11 value. For EALs RG2 and RS2 the value of 0.60 foot as indicated on applicable instrumentation was chosen as being indicative of the immediate need to restore SPF level. For EAL threshold RA2.3 the value of 10.20 feet as indicated applicable instrumentation was chosen as being the SFP level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck. The site-specific levels are determined in accordance with NRC Order EA-12-051 and NEI 12-02, 11 lndustry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"'

and applicable owner's group guidance, and have been modified to reflect site-specific constraints and limitations associated with the design and operation of the applicable instrumentation as required by the developer guidance in the NRG-endorsed NEI 99-01, Revision 6 guidance.

Updating the EAL threshold values based on an N RC-accepted methodology and the resulting approved design change and supporting calculation does not alter the meaning or intent of the basis of the EAL provided in the NRC's SE approving the EALs. 3. A change is being made to EAL MU3 (ATWS) to provide further clarification regarding a successful reactor shutdown in order to avoid confusion when making the assessment.

The following clarifying statement has been added in three places in the EAL. 11 ... as indicated by Reactor Power < 6% ... 11 This will ensure that the same indication that is being used within EAL MU3 (A TWS) to determine that the reactor is not shutdown is also being used to determine a successful reactor shutdown.

This is also in keeping with the escalation path for EALs MA3 and MS3 in determining a reactor shutdown.

4. A change to reflect the need to update the N RC approved EA Ls with the changes made in November 2015 to the MSCWL setpoint.

The evaluation and justification provided in 50.54(q) #15-105 are still valid. The thresholds based on NEI 99-01 Revision 6 that are affected by the change in the MSCWL are MG 1 (Prolonged Loss of all AC Power) and MS3 (Failure to Scram). Page 2 of 4 Attachment 1

Description of how the change still complies with regulations This revision to the EP-AA-1004, Addendum 3 continues to satisfy the applicable Emergency Planning requirements established in 1 O CFR 50.47(b)(4) and the Program Element guidance specified in NUREG-0654, Section 11.D as noted below. 1. This revision to EP-M-1004, Addendum 3 implements the EAL scheme changes reviewed and approved by the NRC as documented in its letter dated July 28, 2015. As such, the NRC has determined that this revision to the Emergency Plan Addendum is acceptable and the changes satisfy regulatory requirements and commitments.

2. Updating the threshold values for EALs RG2, RS2, and RA2 based on NRG-accepted methodology and site-approved design change documentation does not alter the meaning or intent of the basis for the approved EALs. The applicable emergency planning regulations and commitments continue to be met. 3. Updating the threshold value for MU3 to provide further clarification regarding the assessment for determining a successful reactor shutdown does not alter the meaning or intent of the basis of the approved EAL. The applicable emergency planning regulations and commitments continue to be met. 4. Following the submittal of the License Amendment Request to implement the NRC approved NEI 99-01 Rev 6 EAL scheme, it was identified that the current Dresden Station Emergency Action Level thresholds, based on NEI 99-01 Rev 5, for FC2 (RPV Level) and MG2 (Failure to Scram) required revision.

This revision was performed and implemented under 50.54(q) evaluation number 15-105 and Revision 1 of EP-AA-1004 Addendum 3. The revision was reviewed by Dresden PORC and implemented in November 2015. This change reflects the need to update the NRC approved EALs with the changes made in November 2015. The evaluation and justification provided in 50.54( q) #15-105 are still valid. The change is due to the full core use of Optima2 fuel vice all GE14 fuel or a mix of Optima2 and GE14 fuels. This change is documented in the approved Design Analysis No.: OPTIMA2-TR058D3-EOP, SVEA-96 OPTIMA2 Fuel Input to the Emergency Operating Procedures Revision 2. The change in MSCWL to -191 inches affects thresholds used in NEI 99-01 Rev 6 EALs MG1 (Prolonged Loss of all AC Power) and MS3 (Failure to Scram). Updating the EAL threshold values based on an approved technical basis change does not alter the meaning or intent of the basis of the approved EAL. The change has been previously evaluated under 50.54(q) #15-105 and approved by the Station PORC. Therefore this change is not a reduction In Effectiveness because no existing Exelon EP requirements have been deleted or minimized under this revision.

The applicable emergency planning regulations and commitments continue to be met. Description of why the change is not a reduction in effectiveness CRIE) 1 . The change to the Dresden EAL schemes reflects the N RC's approval of the LAR as documented in its letter and supporting SE dated July 28, 2015 (i.e., Dresden Amendment No. 45 to Facility Operating License No. DPR-2, Amendment No. 245 to Renewed Facility Operating License No. DPR-19, and Amendment No. 238 to Renewed Facility Operating License No. DPR-25 for Dresden Nuclear Power Station, Units 1, 2 and 3, respectively.

Page 3 of 4 Attachment 1

The applicable emergency planning regulations and commitments continue to be met. Therefore, this change does not result in a reduction in effectiveness of the Dresden Emergency Plan. 2. The changes to EALs RG2, RS2, and RA2 reflect the changes as approved by the NRC as documented in its letter and supporting SE dated July 28, 2015. The approved EALs had indicated that a site-specific threshold value would be added upon installation of enhanced SFP level devices in accordance with NRC Order EA-12-051.

Dresden has subsequently installed the enhanced SFP level devices and threshold values have been established in accordance with a site-approved design change and supporting calculation.

Updating the EAL threshold values based on an approved technical analysis does not alter the meaning or intent of the basis of the approved EALs. The applicable emergency planning regulations and commitments continue to be met. Therefore, this change doe.s not result in a reduction in effectiveness of the Dresden Emergency Plan. 3. The change to EAL MU3 (ATWS) is being made to provide additional clarification regarding a successful reactor shutdown.

This clarification will help to avoid confusion when assessing a successful reactor shutdown.

The addition of the phrase "as indicated by Reactor Power < 6%," to EAL MU3, as the criteria to determine a successful reactor shutdown clarifies the indication to be used for this determination and will eliminate any potential confusion.

This ensures consistency is applied within EAL MU3 for determining that the reactor is not shutdown and also being used to determine a successful reactor shutdown.

This change is also in keeping with the escalation path for EAL MA3 and MS3 regarding the determination of reactor shutdown.

Updating the EAL threshold to include the additional clarification does not alter the meaning or intent of the basis of the approved EAL. The applicable emergency planning regulations and commitments continue to be met. Therefore, this change does not result in a reduction in effectiveness of the Dresden Emergency Plan. 4. Updating the EAL threshold values based on an approved technical basis change does not alter the meaning or intent of the basis of the approved EAL. The change has been previously evaluated under 50.54(q) #15-105 and approved by the Station PORC. Therefore this change is not a reduction in effectiveness because no existing Exelon EP requirements have been deleted or minimized under this revision.

Additionally, the regulations and commitments to the N RC continue to be met. Page 4 of 4 Attachment 1

ATTACHMENT 2 Affidavit AFFIDAVIT OF DAVID M. GULLOTT DOCKET NOS.50-010, 50-237, 50-249 and 72-37 I, David M. Gullatt, Manager -Licensing, Exelon Generation Company, LLC, do hereby affirm and state: 1. I am Manager, Licensing for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf of EGC. 2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission

("NRC"):

  • EP-AA-1004, Addendum 3, Revision 2, 11 Emergency Action Levels for Dresden Station 11 3. I am also authorized to apply to the N RC for the withholding of the aforementioned documents from public disclosure under 1 O CFR 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 11 Proprietary 11 and are summarized in the attachment to my Affidavit.

4. On behalf of EGC, I request that the documents marked by EGC as 11 Proprietary 11 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 1 O CFR 2.390(a)(4) and 1 O CFR 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 1 O CFR 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). ii. The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business.

It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM. EGC derives economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the ENMM. 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.

Page 1 of 3 Attachment 2

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.
7. EGC requests that the document listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v. I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information, and belief. Manager -Licensing Exelon Generation Company, LLC Date: March 23, 2016 Page 2 of 3 Attachment 2

Appendix 1: Information that Should Be Withheld from Public Disclosure Revision 2 Entire document exempt from disclosure under 10 CFR 2.390(a)(4) and EP-AA-1004, Addendum 3 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Page 3 of 3 Attachment 2

Exelon Confidential/Proprietary Information

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

Exelon Ge n'e rati on 10 CFR 50.54(q){5) 10 CFR 50.4 10 CFR 72.44(f) RS-16-064 March 23, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 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

Subject:

Exelon Nuclear Radiological Emergency Plan Addendum Revision In accordance with 10 CFR 50.4(b)(5), "Emergency Plan and related submissions," Exelon Generation Company, LLC (EGC) is submitting an Emergency Plan Addendum revision for Dresden Nuclear Power Station (Dresden) as listed in the table below. Document Revision Title EP-AA-1004, Addendum 3 2 Emergency Action Levels for Dresden Station The change to the Emergency Plan Addendum was evaluated under the requirements of 10 CFR 50.54(q) and was determined not to result in a reduction in the effectiveness of the Emergency Plan for Dresden. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50.4(b)(5).

The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. Furthermore, the Emergency Plan Addendum identified in Attachment 3 of this letter is 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 the Emergency Plan Addendum contained in Attachment 3 be withheld from public disclosure pursuant to 1 O 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.

Exelon Confidential/Proprietary Information

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

U.S. Nuclear Regulatory Commission Emergency Plan Addendum Revision March 23, 2016 Page2 In addition, as required by 10 CFR 50.54(q)(5), this submittal includes a summary analysis of the changes to the Emergency Plan Addendum (Attachment 1 ). This submittal also satisfies the reporting requirements associated with 1 O CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containing a description of the changes to the Director, Division of Spent Fuel Storage and Transportation.

A copy of the revised Emergency Plan Addendum and supporting change summary analysis are included in the attachments to this letter. There are no regulatory commitments in this submittal.

If you have any questions or require additional information, please contact Amy Hambly at (630) 657-2808.

Respectfully, David M. Gullatt Manager -Licensing Exelon Generation Company, LLC Attachments:

1. 1 O CFR 50.54(q)(5)

Procedure Change Summary Analysis 2. Affidavit

3. EP-AA-1004, Addendum 3, Revision 2, Emergency Action Levels for Dresden Station cc: Regional Administrator

-NRC Region Ill Director, NRC Division of Spent Fuel Storage and Transportation, ONMSS NRC Senior Resident Inspector

-Dresden Station NRC Project Manager, NRA -Dresden Station ATTACHMENT 1 10 CFR 50.54{q){5)

Procedure Change Summary Analysis 1 O CFR 50.54(g)(5l Procedure Change Summary Analysis Procedure title Exelon Generation Company, LLC (EGC) is submitting the following Emergency Plan Addendum revision for Dresden Nuclear Power Station (Dresden):

  • EP-AA-1004, Addendum 3, Revision 2, "Emergency Action Levels for Dresden Station 11 This document contains Exelon Confidential/Proprietary Information and is requested to be withheld from public disclosure pursuant to 10 CFR 2.390. Description of procedure EP-AA-1004, Addendum 3 describes the Emergency Action Levels (EALs) implemented at Dresden for entering Emergency Classification Levels (ECLs). Description of change This revision to EP-AA-1004, Addendum 3 for Dresden incorporates the following changes: 1. Implementation of NEI 99-01, Revision 6, 11 Development of Emergency Action Levels for Non-Passive Reactors, 11 which involved a complete rewrite/formatting of the document.
2. Establishes EAL thresholds for the NRC pre-approved EALs RG2 and RS2 and an additional threshold for RA2 based on Spent Fuel Pool (SFP) levels. 3. Revised EAL MU3 (ATWS) to provide clarity regarding a successful reactor shutdown.
4. Revised EALs MG1 (Prolonged Loss of all AC Power) and MS3 (Failure to Scram) to reflect NRC approved changes to the Minimum Steam Cooling Water Level (MSCWL) setpoint.

A more detailed description of the changes is provided below. 1. The revised EAL schemes based on NEI 99-01, Revision 6 were submitted to the NRC in a License Amendment Request (LAR) dated May 30, 2014. The NRC approved the LAR as documented in a letter and supporting Safety Evaluation (SE) dated July 28, 2015. Training was satisfactorily completed for the Dresden and supporting Corporate Emergency Response Organization (ERO) personnel on the revised EAL schemes during the fourth quarter of 2015. As a result, the NRG-approved EAL schemes based on the NEI 99-01, Revision 6 guidance were implemented and this revision to EP-AA-1004, Addendum 3 reflects the changes. 2. As part of the NRC approval of the new EAL Scheme, three new thresholds were approved generically without specific levels associated with them. The levels are based on enhanced SFP level devices placed in service in accordance with the information provided in Section 1.4, of NRC Order EA-12-051.

NEI 99-01, Revision 6 recommended that these EAL thresholds be implemented when the enhanced SFP level instrumentation is available for use. Page 1 of 4 Attachment 1

At Dresden, the enhanced SFP level instruments were placed in service in accordance with a site-approved design change package. For the new EALs RG2 and RS2 a 11 site specific level 3 11 threshold value is used and for RA2 there is a third threshold that uses a 11 site specific level 2" value. Based on the site-approved design change package the following thresholds were used for each of the site-specific values: A supporting site-approved calculation was used to document the logic and assumptions for establishing the EAL thresholds for SFP 11 site specific level 3 11 and 11 site specific level 2 ...

  • For EAL thresholds RG2 and RS2, the value of 0.60 foot was calculated for 11 site specific level 3 11 value.
  • For EAL threshold RA2.3 the value of 10.20 feet was calculated for 11 site specific level 2 11 value. For EALs RG2 and RS2 the value of 0.60 foot as indicated on applicable instrumentation was chosen as being indicative of the immediate need to restore SPF level. For EAL threshold RA2.3 the value of 10.20 feet as indicated applicable instrumentation was chosen as being the SFP level that is adequate to provide substantial radiation shielding for a person standing on the SFP operating deck. The site-specific levels are determined in accordance with NRC Order EA-12-051 and NEI 12-02, 11 lndustry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation,"'

and applicable owner's group guidance, and have been modified to reflect site-specific constraints and limitations associated with the design and operation of the applicable instrumentation as required by the developer guidance in the NRG-endorsed NEI 99-01, Revision 6 guidance.

Updating the EAL threshold values based on an N RC-accepted methodology and the resulting approved design change and supporting calculation does not alter the meaning or intent of the basis of the EAL provided in the NRC's SE approving the EALs. 3. A change is being made to EAL MU3 (ATWS) to provide further clarification regarding a successful reactor shutdown in order to avoid confusion when making the assessment.

The following clarifying statement has been added in three places in the EAL. 11 ... as indicated by Reactor Power < 6% ... 11 This will ensure that the same indication that is being used within EAL MU3 (A TWS) to determine that the reactor is not shutdown is also being used to determine a successful reactor shutdown.

This is also in keeping with the escalation path for EALs MA3 and MS3 in determining a reactor shutdown.

4. A change to reflect the need to update the N RC approved EA Ls with the changes made in November 2015 to the MSCWL setpoint.

The evaluation and justification provided in 50.54(q) #15-105 are still valid. The thresholds based on NEI 99-01 Revision 6 that are affected by the change in the MSCWL are MG 1 (Prolonged Loss of all AC Power) and MS3 (Failure to Scram). Page 2 of 4 Attachment 1

Description of how the change still complies with regulations This revision to the EP-AA-1004, Addendum 3 continues to satisfy the applicable Emergency Planning requirements established in 1 O CFR 50.47(b)(4) and the Program Element guidance specified in NUREG-0654, Section 11.D as noted below. 1. This revision to EP-M-1004, Addendum 3 implements the EAL scheme changes reviewed and approved by the NRC as documented in its letter dated July 28, 2015. As such, the NRC has determined that this revision to the Emergency Plan Addendum is acceptable and the changes satisfy regulatory requirements and commitments.

2. Updating the threshold values for EALs RG2, RS2, and RA2 based on NRG-accepted methodology and site-approved design change documentation does not alter the meaning or intent of the basis for the approved EALs. The applicable emergency planning regulations and commitments continue to be met. 3. Updating the threshold value for MU3 to provide further clarification regarding the assessment for determining a successful reactor shutdown does not alter the meaning or intent of the basis of the approved EAL. The applicable emergency planning regulations and commitments continue to be met. 4. Following the submittal of the License Amendment Request to implement the NRC approved NEI 99-01 Rev 6 EAL scheme, it was identified that the current Dresden Station Emergency Action Level thresholds, based on NEI 99-01 Rev 5, for FC2 (RPV Level) and MG2 (Failure to Scram) required revision.

This revision was performed and implemented under 50.54(q) evaluation number 15-105 and Revision 1 of EP-AA-1004 Addendum 3. The revision was reviewed by Dresden PORC and implemented in November 2015. This change reflects the need to update the NRC approved EALs with the changes made in November 2015. The evaluation and justification provided in 50.54( q) #15-105 are still valid. The change is due to the full core use of Optima2 fuel vice all GE14 fuel or a mix of Optima2 and GE14 fuels. This change is documented in the approved Design Analysis No.: OPTIMA2-TR058D3-EOP, SVEA-96 OPTIMA2 Fuel Input to the Emergency Operating Procedures Revision 2. The change in MSCWL to -191 inches affects thresholds used in NEI 99-01 Rev 6 EALs MG1 (Prolonged Loss of all AC Power) and MS3 (Failure to Scram). Updating the EAL threshold values based on an approved technical basis change does not alter the meaning or intent of the basis of the approved EAL. The change has been previously evaluated under 50.54(q) #15-105 and approved by the Station PORC. Therefore this change is not a reduction In Effectiveness because no existing Exelon EP requirements have been deleted or minimized under this revision.

The applicable emergency planning regulations and commitments continue to be met. Description of why the change is not a reduction in effectiveness CRIE) 1 . The change to the Dresden EAL schemes reflects the N RC's approval of the LAR as documented in its letter and supporting SE dated July 28, 2015 (i.e., Dresden Amendment No. 45 to Facility Operating License No. DPR-2, Amendment No. 245 to Renewed Facility Operating License No. DPR-19, and Amendment No. 238 to Renewed Facility Operating License No. DPR-25 for Dresden Nuclear Power Station, Units 1, 2 and 3, respectively.

Page 3 of 4 Attachment 1

The applicable emergency planning regulations and commitments continue to be met. Therefore, this change does not result in a reduction in effectiveness of the Dresden Emergency Plan. 2. The changes to EALs RG2, RS2, and RA2 reflect the changes as approved by the NRC as documented in its letter and supporting SE dated July 28, 2015. The approved EALs had indicated that a site-specific threshold value would be added upon installation of enhanced SFP level devices in accordance with NRC Order EA-12-051.

Dresden has subsequently installed the enhanced SFP level devices and threshold values have been established in accordance with a site-approved design change and supporting calculation.

Updating the EAL threshold values based on an approved technical analysis does not alter the meaning or intent of the basis of the approved EALs. The applicable emergency planning regulations and commitments continue to be met. Therefore, this change doe.s not result in a reduction in effectiveness of the Dresden Emergency Plan. 3. The change to EAL MU3 (ATWS) is being made to provide additional clarification regarding a successful reactor shutdown.

This clarification will help to avoid confusion when assessing a successful reactor shutdown.

The addition of the phrase "as indicated by Reactor Power < 6%," to EAL MU3, as the criteria to determine a successful reactor shutdown clarifies the indication to be used for this determination and will eliminate any potential confusion.

This ensures consistency is applied within EAL MU3 for determining that the reactor is not shutdown and also being used to determine a successful reactor shutdown.

This change is also in keeping with the escalation path for EAL MA3 and MS3 regarding the determination of reactor shutdown.

Updating the EAL threshold to include the additional clarification does not alter the meaning or intent of the basis of the approved EAL. The applicable emergency planning regulations and commitments continue to be met. Therefore, this change does not result in a reduction in effectiveness of the Dresden Emergency Plan. 4. Updating the EAL threshold values based on an approved technical basis change does not alter the meaning or intent of the basis of the approved EAL. The change has been previously evaluated under 50.54(q) #15-105 and approved by the Station PORC. Therefore this change is not a reduction in effectiveness because no existing Exelon EP requirements have been deleted or minimized under this revision.

Additionally, the regulations and commitments to the N RC continue to be met. Page 4 of 4 Attachment 1

ATTACHMENT 2 Affidavit AFFIDAVIT OF DAVID M. GULLOTT DOCKET NOS.50-010, 50-237, 50-249 and 72-37 I, David M. Gullatt, Manager -Licensing, Exelon Generation Company, LLC, do hereby affirm and state: 1. I am Manager, Licensing for Exelon Generation Company, LLC (EGC), and I am authorized to execute this affidavit on behalf of EGC. 2. I am further authorized to review the documents sought to be withheld from public disclosure in connection with submittals to the Nuclear Regulatory Commission

("NRC"):

  • EP-AA-1004, Addendum 3, Revision 2, 11 Emergency Action Levels for Dresden Station 11 3. I am also authorized to apply to the N RC for the withholding of the aforementioned documents from public disclosure under 1 O CFR 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 11 Proprietary 11 and are summarized in the attachment to my Affidavit.

4. On behalf of EGC, I request that the documents marked by EGC as 11 Proprietary 11 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 1 O CFR 2.390(a)(4) and 1 O CFR 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 1 O CFR 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). ii. The ENMM is a set of confidential policies and procedures that enable EGC to consistently achieve excellence in all key dimensions of its business.

It documents proven ways of achieving excellence and defines how EGC executes and manages performance and assesses results. EGC expended significant resources, in terms of time and money, to develop, implement, and update the ENMM. EGC derives economic benefit from the ENMM in terms of increased efficiency and improved results as well as revenue generated from EGC's sale or licensing of the ENMM. 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.

Page 1 of 3 Attachment 2

v. Economic harm would come to EGC with the publication of the individual documents that form the ENMM, as it would reduce or eliminate the need for any third party to purchase or license the ENMM from EGC, and would reduce the competitive position of EGC based on the benefits that the ENMM provides to EGC in the management of its own nuclear plants. The ENMM is considered by EGC to be a very valuable part of our intellectual property and it would be very difficult, costly and time-consuming for another to duplicate it without access to these documents.
7. EGC requests that the document listed in Appendix 1 be withheld from public disclosure based on the reasons stated above in paragraph 6.i. through 6.v. I declare under penalty of perjury that the foregoing affidavit and statements therein are true and correct to the best of my knowledge, information, and belief. Manager -Licensing Exelon Generation Company, LLC Date: March 23, 2016 Page 2 of 3 Attachment 2

Appendix 1: Information that Should Be Withheld from Public Disclosure Revision 2 Entire document exempt from disclosure under 10 CFR 2.390(a)(4) and EP-AA-1004, Addendum 3 9.17(a)(4) based on paragraph 6 of the affidavit to which this Appendix 1 is attached.

Page 3 of 3 Attachment 2

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