Text

Part II: Planning Standards and Criteria
	ML20307A486
Person / Time
Site:	Dresden
Issue date:	11/02/2020
From:	; Exelon Generation Co
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML20307A433	List: ML20307A434; ML20307A436; ML20307A445; ML20307A455; RS-20-131, Part II: Planning Standards and Criteria;
References
	RS-20-131
	Download: ML20307A486 (40)
	v • d • e

PART II: Planning Standards And Criteria Exelon Nuclear The Emergency Preparedness Managers are assisted by regional corporate and Station Emergency Preparedness staff. Specific responsibilities include the following:

Program Administration

Develop and maintain the E-Plan , Station Annex, implementing procedures and administrative documents.

Develop and maintain 50.54(q) evaluations for changes to EP documents.

Coordinate and maintain the EP Activities Schedule.

Develop and maintain working relationships and coordinate meetings with Federal, state and local agencies.

Ensure integration of plans between Exelon and offsite agencies.

Provide an opportunity to discuss Emergency Action Levels and the availability of Nuclear Oversight audit results relating to interface with governmental agencies.

Coordinate, negotiate and maintain agreements and contracts with offsite agencies and support organizations.

Obtain Letters of Agreement with medical facilities, and medical consultants specifically skilled in the medical aspects of radiation accidents and other medical consultants as might be necessary for the case of a person involved in a radiation incident.

Coordinate the development and annual distribution of the station's public information publication.

Coordinate and administer the Self Evaluation Program to monitor and evaluate the adequacy of the Emergency Preparedness Program.

Coordinate and support EP Self-Assessments, Audits and Inspections.

Ensure the documentation and resolution of adverse conditions in the emergency preparedness program discovered through drills, audits, etc. in accordance with the Exelon Nuclear Corrective Action Program.

Coordinate and develop Operational Experience responses.

Coordinate, document and review Performance Indicator data and reports.

Provide oversight of Drill and Exercise Performance (DEP) evaluations during Operator Training.

Coordinate and conduct EP Event reviews and reports.

November 2021 P-2 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear The E-Plan and its Annex shall be revised as needed and the most current approved revisions shall remain in effect so long as they are certified as current. Revisions to the E-Plan are reviewed by the Station Review Committee (SRC) prior to approval.

Changes to the plan are made without NRC approval only if such changes do not result in a reduction in effectiveness of the plan per 10 CFR 50.54(q), and the plan as changed continues to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E. Proposed changes that reduce or have a potential to reduce the effectiveness of the approved plan are not implemented without prior approval by the NRC.

Proposed revisions to the E-Plan and Station Annex shall be completed in accordance with the Exelon Nuclear review and approval processes.

E-Plan and Station Annex changes shall be categorized as (1) minor/

administrative or (2) significant programmatic changes. Minor/administrative changes shall be implemented within 30 days of approval. Significant programmatic changes shall be implemented as soon as practical and within 60 days of final approval .

After review and approval, the E-Plan and Station Annex shall be:

a) Reviewed by the applicable Emergency Preparedness Manager(s) and EP Director, or designee(s), and b) Approved for use by the Vice President, Fleet Support or designee.

The Implementing Procedures shall be developed and revised concurrent with the E-Plan and Annex, and reviewed every two years.

Annually, each Letter of Agreement is reviewed and certified current in order to assure the availability of assistance from each supporting organization not already a party to the individual State Plan for Radiological Accidents.

5. E-Plan Distribution E-Plan manuals, Station Annex and implementing procedures are distributed on a controlled basis to the Emergency Response Facilities. All controlled documents holders are issued revision changes upon approval. Selected Federal, state, and local agencies, and other appropriate locations requiring them are also issued copies.

Procedures are in place that control the revision of the E-Plan and require the use of revision bars and individual page identifications (i.e. section of plan, revision number, etc.).

6. Supporting Emergency Response Plans Other plans that support this E-Plan are:

NUREG-1471, US Nuclear Regulatory Commission, "Concept of Operations:

NRG Incident Response" November 2021 P-5 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear

National Response Framework (NRF), Nuclear/Radiological Incident Annex.

Illinois Plan for Radiological Accidents (IPRA).

Department of Energy, Region 5, "Radiological Assistance Plan"

Nuclear Station Security Plans - Note: The Station Security Plan contains industrial security information that must be withheld from public disclosure under provisions of 10 CFR 2.790(d).

7. Implementing and Supporting Procedures Appendix 2 of this plan contains a listing, by number and title, of those procedures that implement this plan during an emergency. Additionally, administrative procedures that outline the steps taken to maintain the Exelon Emergency Preparedness Program have been developed and are listed in Appendix 2.

8. Cross Reference to Planning Criteria The Plan is formatted in the same manner as NUREG-0654, FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in support of Nuclear Power Plants." The use of this format lends itself to uncomplicated comparison of the criteria set forth in NUREG-0654, FEMA-REP-1.

9. Audit/Assessment of the Emergency Preparedness Program To meet the requirements of 10 CFR 50.54(t), Exelon Nuclear Oversight shall coordinate an independent review the Emergency Preparedness Program to examine conformance with 10 CFR 50.47, 10 CFR 50.54, and 10 CFR 50 Appendix E.

Included in the audit/assessment are the following:

The E-Plan and associated implementing procedures.

The Emergency Preparedness Training Program including drills and exercises.

The readiness of the station Emergency Response Organization to perform its function .

The readiness of facilities and equipment to perform as outlined in the plan and procedures.

The interfaces between Exelon, the state, and county governmental agencies pertaining to the overall Emergency Preparedness Program.

Results of this audit are submitted for review to Corporate Management and the Plant Manager. The Emergency Preparedness Manager ensures that any findings that deal with offsite interfaces are reviewed with the appropriate agencies. Written notification will be provided to the state and counties of the performance of the audit and the availability of the audit records for review at Exelon facilities. Records of the audit are maintained for at least five years.

November 2021 P-6 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear

18. NUREG-0737, Clarification of TMI Action Plan Requirements, dated October 1980.

19. NUREG-0737, Supplement 1, Requirements for Emergency Response Capability, December 1982.

20. NUREG 0728 - "Report to Congress: NRC Incident Response Plan ."

21. US NRC Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," revision 4, July, 2003.

22. U.S. NRC Response Technical Manual (RTM-96)

23. NEI 99-01, Methodology for Development of Emergency Action Levels.

24. EPA 400-R-92-001, October 1991, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents."

25. FEMA-REP-10, Guide for Evaluation of Alert and Notification Systems for Nuclear Power Plants

26. FEMA-REP-14, Exercise Evaluation Methodology

27. FEMA-Guidance Memorandum, MS-1 "Medical Services"

28. Exelon Decommissioning Quality Assurance Program (DQAP), NO-DC-10

29. Deleted

30. Deleted

31. "Federal Bureau of Investigation and Nuclear Regulatory Commission Memorandum of Understanding for Cooperation Regarding Threat, Theft, or Sabotage in U.S. Nuclear Industry," Federal Register, Vol. 44, p. 75535, December 20, 1979.

32. Illinois Department of Nuclear Safety, Title 32, Chapter II, Subchapter b, Part 340, "Standards for Protection Against Radiation."

33. ComEd April 1983 response to NUREG 0737 Supplement #1 or latest submitted schedule of planned operational dates.

34. "Voluntary Assistance Agreement By and Among Electric Utilities involved in Transportation of Nuclear Materials," dated November 1, 1980.

35. Comprehensive Environmental Response, Compensation and Liability Act of 1980.

November 2021 Appendix 1 Page 2 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear

36. Accidental Radioactive Contamination of Human Food and Animal Feeds; Recommendation for State and Local Agencies, Volume 47, No. 205, October 22, 1982.

37. American Nuclear Insurers Bulletin #5B (1981 ), "Accident Notification Procedures for Liability Insureds".

38. "Potassium Iodide as a Thyroid Blocking Agent in a Radiation Emergency: Final Recommendations on Use," Federal Register Vol. 47, No. 125, June 29, 1982.

39. Letter from William J. Dircks, Executive Director for Operations, NRC, to Dr.

Donald F. Knuth, President KMC, Inc. dated October 26, 1981.

40. Deleted

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

42. ANl/MAELU Engineering Inspection Criteria For Nuclear Liability Insurance, Section 6.0, Rev. 1, "Emergency Planning."

43. NRC RIS 2006-12 , Endorsement of Nuclear Energy Institute Guidance "Enhancement to Emergency Preparedness Programs for Hostile Action. "

44. NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security-Based Events."

42. NRC Information Notice 2009-01, National Response Framework November 2021 Appendix 1 Page 3 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Appendix 3: List of Corporate Letters of Agreements Organization/Agreement Type Department Of Energy (DOE) Radiation Emergency Assistance Center/Training Site, REAC/TS (letter on File)

Medical Consultant Environmental, Inc. (P.O.)

Radiological Environmental Monitoring Landauer, Inc. (P.O.)

Emergency Dosimetry Murray & Trettel, Inc. (P.O.)

Meteorological Support Arnita Health St. Joseph Hospital (letter on File)

Back-up Emergency Medical Facility Teledyne Brown Engineering (P.O.)

Bioassay Analysis/Radiochemical Analysis Westinghouse Electric Company, PWRs (Letter on File)

PWR Emergency Support J.D Ingenuities (P.O.)

Emergency Met Tower National Foam, Inc.

Fire Foam Supply November 2021 Appendix 3 Page 1 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Appendix 4: Glossary of Terms and Acronyms Accident Assessment Accident assessment consists of a variety of actions taken to determine the nature, effects and severity of an accident and includes evaluation of damage assessment reports, meteorological observations, seismic observations, fire reports, radiological dose projections, in plant radiological monitoring, and environmental monitoring.

Activation (1) "ERO Activation" is the process of initiating actions to notify and mobilize Emergency Response Organization (ERO) personnel following an event classification under the emergency plan.

(2) "Facility Activation" refers to the decision to consider a facility fully operational based on the minimum staffing required in ERO staffing tables contained within the station specific Annex and the ability of facility staffing and equipment to perform its designed function(s).

Annual Frequency of occurrence equal to once per calendar year, January 1 to December 31 .

Assembly/Accountability A procedural or discretionary protective action taken for all persons within the security "Protected Area", which involves the gathering of personnel into pre-designated areas, and the subsequent verification that the location of these personnel is known.

Assessment Actions Those actions taken during or after an emergency to obtain and process information that is necessary to make decisions to implement specific emergency measures.

November 2021 Appendix 4 Page 1 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Drill A supervised instruction period aimed at testing, developing and maintaining skills in a particular operation.

Early Phase The period at the beginning of a nuclear incident when immediate decisions for effective use of protective actions are required and must be based primarily on predictions of radiological conditions in the environment. This phase may last from hours to days. For the purposes of dose projections it is assumed to last four days.

Emergency Action A pre-determined, site-specific, observable threshold for a Levels (EALs) plant Initiating Condition that places the plant in a given emergency class. An EAL can be an instrument reading; an equipment status indicator; a measurable parameter (onsite or offsite ); a discrete, observable event; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

Emergency Alert A network of broadcast stations and interconnecting facilities System (EAS) which have been authorized by the Federal Communications Commission to operate in a controlled manner during a war, state of public peril or disaster, or other national or local emergency. In the event of a nuclear reactor accident, instructions/notifications to the public on conditions or protective actions would be broadcast by state or local government authorities on the EAS.

Emergency Director Individual in Command and Control. One of the following: the Shift Emergency Director (Control Room), Station Emergency Director (TSC) or the Corporate Emergency Director (EOF).

Emergency Notification The NRC Emergency Notification System hot line is a System (ENS) dedicated telephone system that connects the plant with NRC headquarters in White Flint, Maryland. It is directly used for reporting emergency conditions to NRC personnel.

Emergency Operations Designated location from which the Licensee Emergency Facility (EOF) Response Organization conducts the company's overall emergency response in coordination with Federal, State and designated emergency response organizations.

Emergency Operating EOPs are step-by-step procedures for direct actions taken by Procedures (EOPs) qualified operators to mitigate and/or correct an off normal plant condition through the control of plant systems.

November 2021 Appendix 4 Page 4 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Emergency Operations A facility designed and equipped for effective coordination Center (EOC) and control of emergency operations carried out within an organization's jurisdiction. The site from which civil government officials (municipal, county, state, and Federal) exercise direction and control in a civil defense emergency.

Emergency Personnel Those organizational groups that perform a functional role during an emergency condition. Within Exelon Nuclear, emergency personnel include the Managers and Directors of the Emergency Response Organization, accident assessment personnel, radiological monitoring teams, fire brigades, first aid teams and security personnel.

Emergency Planning That area surrounding a nuclear station in which emergency Zones (EPZ) planning is conducted for the protection of the public. With respect to protecting the public from the plume exposure resulting from an incident, the EPZ is usually an area with a radius of about 10 miles surrounding the facility. With respect to the ingestion exposure pathway, the EPZ is usually an area with a radius of about 50 miles.

Emergency A state of readiness that provides reasonable assurance that Preparedness adequate protective measures can and will be taken upon implementation of the E-Plan in the event of a radiological emergency.

Environmental The use of radiological instruments or sample collecting Monitoring devices to measure and assess background radiation levels and/or the extent and magnitude of radiological contamination in the environment around the plant. This may be done in various stages such as pre-operational, operational, emergency, and post operational.

Essential Personnel Essential personnel are those needed to achieve the goals and tasks as deemed necessary by the Station Emergency Director.

Evacuation The urgent removal of people from an area to avoid or reduce high level, short-term exposure usually from the plume or from deposited activity.

November 2021 Appendix 4 Page 5 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Exclusion Area An Exclusion Area is an area specified for the purpose of reactor site evaluation in accordance with 10 CFR 100. It is an area of such size that an individual located at any point on its boundary for two hours immediately following onset of the postulated release would not receive a total radiation dose to the whole body in excess of 25 rem or a total radiation dose of 300 rem to the thyroid from iodine exposure.

Exercise An event that tests the integrated capability of a major portion of the basic elements existing within emergency preparedness plans and organizations.

Exercise Cycle An eight-year period.

Hazardous Material A substance or material which has been determined by the United States Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated in 49 CFR 172.

Health Physics Network In the event of a Site Area Emergency, the NRC HPN line will (HPN) Line be activated by the NRC Operations center in White Flint, Maryland. This phone is part of a network that includes the NRC Regional Office and the NRC Operations Headquarters in White Flint, Maryland . This system is dedicated to the transmittal of radiologica l information by plant personnel to NRC Operations Center and the Regional office. HPN phones are located in the TSC and EOF.

Imminent Mitigation actions have been ineffective and trended information indicates that the event or condition will occur within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Ingestion Exposure The potential pathway of radioactive materials to the public Pathway through consumption of radiologically contaminated water and foods such as milk or fresh vegetables. Around a nuclear power plant this is usually described in connection with the 50-mile radius Emergency Plann ing Zone (50 mile EPZ).

Initiating Condition A predetermined UNIT condition where either the potential exists for a radiological emergency or such an emergency has occurred.

November 2021 Appendix 4 Page 6 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Public Alerting/Warning The process of signaling the public, as with sirens, to turn on their TV's or radios and listen for information or instructions broadcast by state or local government authorities on the Emergency Alert System (EAS).

Quarterly Frequency of occurrence equal to once in each of the following four periods: January 1 through March 31; April 1 through June 30; July 1 through September 30 ; October 1 through December 31.

Recovery The process of reducing radiation exposure rates and concentrations of radioactive material in the environment to levels acceptable for unconditional occupancy or use.

Release A 'Release in Progress' is defined as ANY radioactive release that is a result of, or caused by, the emergency event.

Restricted Area Any area, access to which is controlled by Exelon for purposes of protection of individuals from exposure to radiation and radioactive materials.

Restricted Area For classification and dose projection purposes, the boundary Boundary is a 400-meter (1/4-mile) radius around the plant. The actual boundary is specified in the ODCM .

Safety Analysis Report, The UFSAR is a comprehensive report that a utility is Updated Final (UFSAR) required to submit to the NRC as a prerequisite and as part of the application for an operating license for a nuclear power plant. The multi-volume report contains detailed information on the plant's design and operation, with emphasis on safety-related matters.

Semi-Annual Frequency of occurrence equal to once in each of the following periods: January 1 through June 30 ; July 1 through December 31.

Shall , Should, and May The word "shall" is used to denote a requirement, the word "should" to denote a recommendation and the word "may" to denote permission, neither a requirement nor a recommendation.

Shielding Any material or barrier that attenuates (stops or reduces the intensity of) radiation.

Site Boundary Dresden's Site Boundary is described in detail in the ODCM.

November 2021 Appendix 4 Page 10 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Site Evacuation The evacuation of non-essential personnel from the plant site.

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

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

Threshold Value Measurable, observable detailed conditions which must be satisfied to determine an EAL applicability.

Thyroid Blocking Agent An agent which when properly administered to an individual will result in sufficient accumulation of stable iodine in the thyroid to prevent significant uptake of radioiodine. Potassium Iodide is such an agent.

Total Effective Dose The sum of the deep dose equivalent (for external exposure)

Equivalent (TEDE) and the committed effective dose equivalent (for internal exposure) and 4 days of deposition exposure.

Unrestricted Area Any area to which access is not controlled by the licensee for protecting individuals from exposure to radiation and radioactive materials, and any area used for residential quarters.

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

Vital Equipment Any equipment, system, device or material, the failure, destruction, or release of which could directly or indirectly endanger the public health and safety by exposure to radiation. Equipment or systems which would be required to function to protect public health and safety following such failure , destruction, or release are also considered to be vital.

Weekly Frequency occurrence equal to once per calendar week:

Monday through Sunday.

Any abbreviation followed by a lower case's' denotes the plural form of the term .

November 2021 Appendix 4 Page 11 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear ACRONYMS ac ..... .... .... .... .... .... .... .... .... .... .... ........ ........................... .... .... .... .... .... .... . alternating current ALARA ............. ............ .................................................. as low as reasonably achievable ANI ... .... .... .... .... .... .... .... .... ... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ...... .... .... American Nuclear Insurers ANS .. .... .... .... .... .... .... .... .... ............................................... .... Alert and Notification System ANSI. .... .... .... .... ........ .... ....... .................................. American National Standards Institute ARM ... .. ... ... ... .. .... ... .... ....... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. ...... .. Area Radiation Monitor ASLB .... .... .... .............. ...... .. .. .. .. ... .... .... ... ... ... .. .. .... .... .... .. ...Atomic Safety Licensing Board CB .... ................ ........................ ............................................... .... ................ ... citizen band cc .. .... .... .... .... .... .... .... .... ........ .... ............................... ........ .... .... .... .... .... .... cubic centimeter COE .................. ..................................................................... Committed Dose Equivalent CEOC ... .... .... .... .... .... .... .... ...................................... County Emergency Operation Center CFR .. .... ............ ............ ................................................... .... . Code of Federal Regulations cm2 .. .... .... .... .... .... .... .... .... .... ........................................... .... .... .... .... .... ..square centimeter CNO ..... .... .... .... .... .... .... ........ ............................... ........ .... .... ........ .... . Chief Nuclear Officer cpm .............................. ................................................... .... .................... count per minute CR .... .... .... .... .... .... .... .... ................................................... .... .... .... .... .... .... .... Control Room CRO ..... .... ... .... ..... .... ... .. ........... .... .... .... ....... .... .... .... .... .... .. .. .. .. .... . Control Room Operator CRT .................. ....................................................................... .... ........ Cathode Ray Tube Cs ..... .... .... .... .... .... .... .... ........ .... ............................... ........ .... .... .... .... .... .... .... .... .... .. Cesium de ..... ................ ....................................................................... .... ........ ........ . direct current DEP .. .... .... .... .... ...... ... ..... .... ..... .. .. .. .. .. ......... ... .. .. .. .. .. .. .... ... Drill and Exercise Performance DEQ ..... .... .... .... .... .... .... ........ .... ............................... Department of Environmental Quality DFO .................. ....................................................................... .... ...... Disaster Field Office DGI ... .... .... .... .... .... .... .... ....... ............................................ .... Digital Graphics Incorporated DHFS ... .... .... .... .... .... .... .... .... .... .... .... .... .... ... ... Department of Health and Family Services November 2021 Appendix 4 Page 12 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear DLR ................. ........................ ............................................... Dosimeter of Legal Record DOE ..... .... .... .... .... .... .... .... .... .... ........ ................... .... .... .... .... .. U. S. Department of Energy DOT. ..... ........ .... ............ .............................................. U. S. Department of Transportation DPH .. .... .... .... .... .... .... .... .... ... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. ...... .... ..Department of Public Health dpm .. .... .... .... .... .... .... .... .... ... ............................................ .... .... ... disintegration per minute DQAP ... .... .... .... ........ .... ....... ..................... Decommissioning Quality Assurance Program EAL .. .. .. ... ... ... .. .... ... .... ....... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .. ...... Emergency Action Level EAS ...... .... .... .............. ...... .. .. .. .. ... .... .... ... ... ... .. .. .... .... .... .. ....... Emergency Alerting System EMA ................. ........................ .................................... Emergency Management Agency ENC .. .... .... .... .... .... .... .... ........ .... ............................... ........ .... .... ... Emergency News Center ENS .................. .................................................... Emergency Notification System (NRC)

EOC ..... .... .... .... .... .... .... .... ... ....................... Emergency Operations (or Operating) Center EOF .. .... ............ ............ ................................................... ..Emergency Operations Facility EOP .. .... .... .... .... .... .... .... .... .... ......................................... Emergency Operating Procedure EPA .. .... .... .... .... .... .... .... ....... .. .............................. U.S. Environmental Protection Agency EPDS ........................... ....... ............................... Emergency Preparedness Data System EPZ .. .... .... .... .... .... .... .... ................................................... .... .... Emergency Planning Zone ERF .. .... .... ... .... ..... .... ... .. ........... .... .... .... ....... .... .... .... .... .... .. . Emergency Response Facility ESF .................. ................... .................................................... Engineered Safety Feature FEMA ... .... .... .... .... .... .... ....... .. ... ....................... Federal Emergency Management Agency FRMAC ............ ........................ Federal Radiological Monitoring and Assessment Center FRMAP ..... .... .... ...... ... ... ...... ..... .. .. Federal Radiological Monitoring and Assessment Plan FRPCC ..... .... .... .... .... .... ...... Federal Radiological Preparedness Coordinating Committee FSAR. ............... .................................................................... Final Safety Analysis Report Ge .... .... .... .... .... .... .... .... ....... ............................................ .... .... .... .... .... .... .... .... Germanium GET .. .... .... .... .... .... .... .... .... ... .. ... .... .... .... .... ... .... .... .... ........ .... ... General Employee Training November 2021 Appendix 4 Page 13 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear GM ................... ........................ ......................... Geiger Mueller (radiation detection tube)

HEPA ... .... .... .... .... .... .... .... .... .... ........ ................... .... .... .... .... . high efficiency particulate air HPN .. .... ........ .... ............ ................................................... . Health Physics Network (NRC) hr .. .... .... .... .... .... .... .... .... .... ... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... .... .... .... .... .... .... .... .... .... .... ... hour I .... .... .... .... .... .... .... .... .... .... ... ............................................ .... .... .... .... .... .... .... .... .... .... .Iodine IEMA .... .... .... .... ........ .... ....... ............................... Illinois Emergency Management Agency IRAP ... .. ... ... ... .. .... ... .... ....... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. . lnteragency Radiological Assistance Plan JIC ........ .... .... .............. ...... .. .. .. .. ... .... .... ... ... ... .. .. .... .... .... .. ....... ...... Joint Information Center LGEOC ............. ........................ ........... Local Government Emergency Operations Center Li .. .... .... .... .... .... .... .... .... ........ .... ............................... ........ .... .... .... .... .... .... .... .... .... ... Lithium LPZ ................... ....................................................................... ......... Low Population Zone MAE LU ..... .... .... .... .... .... .... ... ......................... Mutual Atomic Energy Liability Underwriters MCP ..... ............ ............ ................................................... .... .... ..Municipal Command Post mR .... .... .... .... .... .... .... .... .... .... ........................................... .... .... .... .... .... .... .... .. milliroentgen NARS ... .... .... .... .... .... .... ....... .. .............................. ...... Nuclear Accident Reporting System NCRP ........................... ....... .............................. National Council on Radiation Protection NOP ..... .... .... .... .... .... .... .................................................. Nuclear Organization Procedure NRG ..... .... ... .... ..... .... ... .. ........... .... .... .... ....... .... .... .. U. S. Nuclear Regulatory Commission NRF .................. ................... ............................................. National Response Framework NRR ..... .... .... .... .... .... .... ....... .. ... ........................... .... ... Nuclear Reactor Regulation (NRC)

NWS ................. ....................................................................... .. National Weather Service NSRAC ..... .... .... ...... ... ... ...... ..... .. .. .. .. .. ......... . Nuclear Safety Review and Audit Committee OSC ..... .... .... .... .... .... .... ........ .... ........................... .... ........ .... .... Operations Support Center PAG .................. ....................................................................... .... . Protective Action Guide PANS ... .... .... .... .... .... .... ....... .................................... Prompt Alert and Notification System PAR .. .... .... .... .... .... .... .... .... ... .. ... .... .... .... .... ... .... .... .... .. Protective Action Recommendation November 2021 Appendix 4 Page 14 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear R ....................... ........................ ............................................... ............................ roentgen RAA .. .... .... .... .... .... .... .... .... .... .... ........ ................... .... .... ... Remote Assembly Area (off-site)

RAC .. .... ........ .... ............ ......................................... Regional Advisory Committee (FEMA)

RAFT .... .... .... .... .... .... .... .... ... .. .. .. .. .. .. .. .. .. .. Radiological Assistance Field Team (ILLINOIS)

RAP .. .... .... .... .... .... .... .... .... ... .............................. Radiological Assistance Plan (ILLINOIS)

REAC ... .... .... .... ........ .... ....... ...... Radiological Emergency Assessment Center (ILLINOIS)

REP .. .. .. ... ... ... .. .... ... .... ....... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .Radiological Emergency Preparedness RERP ... .... .... .............. ...... .. .. .. .. ... .... .... ... ... ... .. .. ..Radiological Emergency Response Plan RMS ................. ........................ ............................................ Radiation Monitoring System SCBA ... .... .... .... .... .... .... ........ .... ............................... . Self Contained Breathing Apparatus SEOC ............... ........................................................ State Emergency Operations Center SFCP .... .... .... .... .... .... .... ....... ............................................ .. State Forward Command Post SPCC ... ........ .... ............ ....... ...................... Spill Prevention Control and Countermeasure SPDS ... .... .... .... .... .... .... .... ... .. ....................................... Safety Parameter Display System Sr .. .... .... .... .... .... .... .... .... ....... .. .............................. ........ .... .... ........ .... .... .... .... .... ... Strontium SRC .............................. ....... ............................................ .. State Radiological Coordinator SSC .. .... .... .... .... .... .... .... ....... ............................................ .... .... .... .... . State Staging Center TDD .. .... .... ... .... ..... .... ... .. ........... .... .... .... ....... .... .. Telecommunications Device for the Deaf TEDE ............ .... ................... ............................................. Total Effective Dose Equivalent TSC .. .... .... .... .... .... .... .... ....... .. ... ........................... .... ........ .... .... ..Technical Support Center

µCi .... ............ .... ....................................................................... .... .... .... ........ ...... microcurie UFSAR ..... .... .... ...... ... ... ...... ..... .. .. .. .. .. ......... ... .. .. .. .. . Updated Final Safety Analysis Report November 2021 Appendix 4 Page 15 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Appendix 5 Table 5-1: Emergency Response Organization {ERO} Staffing and Augmentation Plan TSC I OSC EOF - Alert or Emergency Greater Preparedness {EP) On-Shift Alert or Greater Alert or Greater Functions Augment Augment Augment w/in 60 min. w/in 90 min. w/in 60 min.

Command and Control

Provide overall ERO command and control, until relieved .

Approve emergency action level (EAL) (1) Shift (1) Station ( 1) Corporate Emergency Emergency Not applicable Emergency and/ or protective action Director Director Director recommendation (PAR) classifications, until relieved.

Authorize personnel dose extensions, until relieved .

Communications 3

Communicate EAL and PAR (1) ENS classifications to Shift (1) State I Local Communicator Not applicable offsite response Communicator 1 Communicator (TSC) organizations (OROs),

including the NRG, until relieved .

Radiation Protection

Provide qualified radiation protection coverage for responders accessing potentially (2) Additional unknown radiological Radiation environments during (1) Radiation Protection emergency Protection Personnel [In As needed Not applicable conditions. Personnel addition to

Provide in-plant personnel on-shift]

surveys. (OSC)

Control dosimetry and radiologically controlled area access.

November 2021 Appendix 5 Page 1 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Appendix 5 Table 5-1: Emergency Response Organization {ERO} Staffing and Augmentation Plan TSC I OSC EOF - Alert or Emergency Greater Preparedness {EP) On-Shift Alert or Greater Alert or Greater Functions Augment Augment Augment w/in 60 min. w/in 90 min. w/in 60 min.

Emergency Classifications

Evaluate plant conditions and Not applicable (1) Operations Not applicable Not applicable recommend Manager (TSC) emergency classifications , until relieved .

(1) TSC Engineer:

Engineering Provide engineering

Provide engineering Not applicable coverage for the As needed Not applicable coverage until ERO relieved .

Additional staff as needed November 2021 Appendix 5 Page 3 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Appendix 5 Table 5-1: Emergency Response Organization {ERO} Staffing and Augmentation Plan TSC I OSC EOF - Alert or Emergency Greater Preparedness {EP) On-Shift Alert or Greater Alert or Greater Functions Augment Augment Augment w/in 60 min. w/in 90 min. w/in 60 min.

(1) Security Coordinator

{TSC)

Security staffing per the site-

Coordinate Security security- related Not applicable Not applicable specific security plan . activities and information with the Emergency Coordinator.

Maintenance Personnel

{OSC)

(1) l&C Technician:

Maintenance Provide Personnel assistance with

{OSC) logic manipulation ,

(1) Electrical support for event Maintenance mitigation and Technician: equipment repair, Provide and support electrical of digital l&C support for if applicable.

event Additional l&C Repair Team Activities Not applicable mitigation, and Not applicable staff may be equipment called out if repair. needed .

(1) Mechanical Maintenance . Electrical Technician: Provide Maintenance mechanical support Technicians - As for event mitigation , needed .

and equipment repair. . Mechanical Maintenance Technicians - As needed .

November 2021 Appendix 5 Page 4 EP-DR-1000 (Revision x)

PART Ill: Appendices Exelon Nuclear Appendix 5 Table 5-1: Emergency Response Organization {ERO} Staffing and Augmentation Plan TSC I OSC EOF - Alert or Emergency Greater Preparedness {EP) On-Shift Alert or Greater Alert or Greater Functions Augment Augment Augment w/in 60 min. w/in 90 min. w/in 60 min.

OSC Supervisor{s)

(1) osc As needed Director . (1) Radiation Supervision of

Supervise OSC Protection Repair Team Not applicable activities as Supervisor I Not applicable Activities directed by Lead 1 : Supervise Emergency OSC activities Coordinator. related to radiation protection.

Onsite FM Individual

(1) RP Personnel to assess the protected area for radiation and contamination and provide input to the Offsite FMT B TSC RPM . * (1) Qualified Responsible for individual to radiation protection assess the area(s) coverage for the outside the FMT as directed protected area for by TSC RPM or radiation and EOF RPM . contamination ,

and for radioactive Offsite FMT A plume tracking , as

(1) Qualified directed by, and Field Monitoring Not applicable under the control Not applicable individual to assess Teams {FMTs) of, the EOF DAC the area(s) outside the protected area or RPM .

for radiation and Responsible for contamination, and the radiation for radioactive protection plume tracking, as coverage of the directed by, and FMT as directed under the control of, by EOF RPM .

the EOF DAC or * (1) Driver to RPM . Responsible provide for the radiation transportation.

protection coverage of the FMT as directed by EOF RPM .

(1) Driver to provide transportation .

November 2021 Appendix 5 Page 5 EP-DR-1000 (Revision x)

Attachment 3 Dresden Station PROPOSED REVISION TO SITE EMERGENCY PLAN Exhibit D Radiological Emergency Plan Annex for Dresden Station (Procedure EP-AA-1004)

(Clean Pages)

EP-AA-1004 Exelon Generation ~ Revision x EXELON NUCLEAR RADIOLOGICAL EMERGENCY PLAN ANNEX FOR DRESDEN STATION

Dresden Annex Exelon Nuclear Section 1: Introduction As required in the conditions set forth by the Nuclear Regulatory Commission (NRC) for the operating license for the Dresden Station, the management of Exelon recognizes its responsibility and authority to operate and maintain the nuclear power stations in such a manner as to provide for the safety of the general public.

The Dresden Emergency Preparedness Program consists of EP-DR-1000, the Dresden Radiological Emergency Plan (E-Plan), EP-AA-1004, Radiological Emergency Plan Annex for Dresden Station, Exelon emergency plan implementing procedures, and associated program administrative documents. The Dresden Station Radiological Emergency Plan outlines the basis for response actions that would be implemented in an emergency.

This document serves as the Dresden Station Emergency Plan Annex and contains information and guidance that is unique to the station. This includes facility geography location for a full understanding and representation of the station's emergency response capabilities. The Station Annex is subject to the same review and audit requirements as the Dresden Radiological Emergency Plan.

1.1 Facility Description Dresden Station, Units 1, 2 and 3, is located in the Goose Lake Township of Grundy County in northeastern Illinois. Unit 1 is in permanent shutdown (see Figure 1-1 ).

The plant consisted of three Boiling Water Reactor (BWR) Nuclear Steam Supply Systems (NSSS) and turbine generators provided by General Electric Company.

Unit 1 is a dual cycle boiling water reactor designed for a power output of 700 MWt and has officially been retired as of August 31 , 1984. Units 2 and 3 are permanently defueled.

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

Exelon is the sole owner of the 953-acre tract subject only to an easement of the U.S. Government for an access road to Dresden Island Lock and Dam maintained and operated DR the U.S. Corps. of Engineers. This road traverses the site from north to south - 0.8 mile west of the plant.

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

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

November 2021 DR 1-1 EP-AA-1004 (Revision x)

Dresden Annex Exelon Nuclear Section 4: Emergency Measures Dresden emergency response actions are covered DR Section E of the Dresden Radiological Emergency Plan.

4.1 Notification of the Emergency Organization The Emergency Director is responsible for notifying the State of Illinois Emergency Management Agency (IEMA) via NARS. Grundy County, Kendall County, and Will County will also be notified via NARS; however, IEMA will maintain responsibility of county notification. At the Dresden Station, if a General Emergency is the initiating event, the Emergency Director is also responsible for notifying the following local agencies:

Grundy County

Kendall County

Will County 4.2 Assessment Actions Throughout each emergency situation, continuing assessment will occur.

Assessment actions at Dresden Station may include an evaluation of plant conditions; in-plant, onsite, and initial offsite radiological measurements; and initial estimates of offsite doses.

4.3 Protective Actions for the Offsite Public To aid the Emergency Response Organization during a developing emergency situation, EP-AA-111, "Emergency Classification and Protective Action Recommendations" has been developed based on Section J.1 O.m of the Dresden Radiological Emergency Plan.

4.3.1 Alert and Notification System (ANS) Sirens This ANS consists of a permanently installed outdoor notification system within a ten mile radius around the station. The ten-mile radius around the station is a mix of agriculture and industry with a relatively low population distribution. The ANS, as installed , consists of mechanical and electronic sirens that will cover this entire area with a minimum sound level of 60 db. Additionally, the ANS will cover the heavily populated areas within the ten-mile radius around the station with a minimum sound level of 70 db to ensure complete coverage.

The ANS sirens are controlled and monitored on a daily basis, DR a computerized telemetry system. The daily monitoring assures early failure detection and therefore maximizes system operability and reliability.

Backup means of notification is achieved through Route Alerting, which is contained within the State and respective counties' Radiological Emergency Response Plans and procedures. The means consists of utilizing vehicles with public address (PA) systems in the event the primary method of alerting and notification is unavailable. The backup method has the capability to alert and notify the public within the plume exposure pathway EPZ within a reasonable November 2021 DR4-1 EP-AA-1004 (Revision x)

Dresden Annex Exelon Nuclear 5.2.2.2 Radiological Noble Gas Effluent Monitoring A wide range monitor is installed in the effluent stream that enters the main chimneys and the reactor building vents. These wide range monitors have a range of 1x10-7 uCi/cc to 1x105 uCi/cc.

The method of converting instrument readings to release rates will be determined after the energy responses of the detector are obtained. Due to system design, the monitors give an estimate of a release. Actual releases will be determined by periodically collecting grab samples, counting the samples collected and calculating the releases.

5.2.2.3 Radioiodine and Particulate Effluent Monitoring Effluent sampling media are analyzed in the Station counting room. Silver based cartridges are available to reduce the interference of noble gases.

5.2.2.4 Deleted5.2.2.5 In-plant Iodine Instrumentation Dresden Station has the capability to sample and determine iodine concentrations in the plant using charcoal cartridges and gamma ray spectroscopy. Portable monitors may be used to measure increasing levels of iodine during emergency conditions.

5.2.3 Onsite Process Monitors Adequate monitoring capability exists to properly assess plant status. The operability of the post-accident instrumentation ensures information is available on selected plant parameters to monitor and assess important variables following an accident. Instrumentation is available to monitor the parameters and ranges given in the Dresden Station Technical Specifications.

5.2.4 Onsite Fire Detection Instrumentation Dresden Station has a fire protection system that is designed to quickly detect any fires; annunciating locally and in the Control Room. The fire detection system is designed to applicable National Fire Protection Association (NFPA) standards. The majority of the detectors consist of electrically supervised ionization smoke detectors.

5.2.5 Facilities and Equipment for Offsite Monitoring Consult the Offsite Dose Calculation Manual (ODCM) for the most current location for fixed continuous air samplers and DLR.

November 2021 DR 5-3 EP-AA-1004 (Revision x)

Attachment 4 Dresden Station EMERGENCY RESPONSE ORGANIZATION TASK ANALYSIS

Attachment 4 EMERGENCY RESPONSE ORGANIZATION TASK ANALYSIS provides a summary Table of the existing Emergency Response Organization (ERO) positions and their respective Emergency Plan tasks as defi ned in the Emergency Plan .

The duties of the Dresden ERO positions being eliminated were reviewed against NUREG-0654, Rev 2 and the Dresden Radiological Emergency Plan. Each eliminated ERO position was analyzed to ensure key tasks of the position are retained and performed by other ERO members, and unnecessary tasks were appropriately eliminated. The tasks were also evaluated against the NUREG 0654 Planning Standards to ensure regulatory requirements were maintained.

The table will be used to update and revise Emergency Plan Implementing Procedures (EPIPs) with regard to reassignment and revision of tasks resulting from this analysis.

The Table is arranged in columns as described below:

Facility (Column A) : This column identifies the affected Emergency Response Facility MCR- Main Control Room ,

TSC - Tech Support Center, OSC - Operations Support Center, EOF - Emergency Off-site Facility and JIC - Joint Information Center.

Current ERO Position (Column B): This column identifies the ERO Position title . Each ERO position is also identified with a unique abbreviation for reference throughout the table.

For example, MSED is for Main Control Shift Manager (Shift Emergency Director).

Position Eliminated (Column C) : This column identifies whether the position is being eliminated as part of this License Amendment Request.

Minimum Staff (Column D): This column identifies those positions that are considered Minimum Staff in the current approved E-Plan (i .e., Yes/No) .

NRC Pl Key ERO (Column E): This column identifies whether the position is a Key ERO position with respect to the NRC Performance Indicator for ERO performance at the station.

Tasks defined by Station Emergency Plan (Column F): This column identifies the specific position tasks identified in the Emergency Plan . Each task is identified with a unique task ID number for quick reference throughout the table .

Task Disposition (Eliminated/Reassigned To) (Column G): This column identifies the disposition of those tasks assigned to a deleted ERO position under this License Amendment Request. Each ERO task was evaluated and dispositioned as either Eliminated , Modify, or Reassigned. Tasks that are reassigned designate the ERO member receiving the task. Note that tasks which are assigned to a person who remains on the Dresden ERO were not dispositioned.

Attachment 4 EMERGENCY RESPONSE ORGANIZATION TASK ANALYSIS Justification / Implementing Action (Column H): This column provides a conclusion as to why this change is acceptable. In some cases, for tasks not being reassigned , this column provides an action needed when the change is implemented.

Tasks transferred to this position per this Assessment (Column I): This column identifies tasks which have been transferred to the identified ERO position per this Assessment.

Emergency Plan Section Reference (Column J): This column identifies the section of the Dresden Emergency Plan which contains the position tasks/responsibilities. The identified Emergency Plan location refers to the step number in the current Dresden Emergency Plan.

ERO STAFFING ASSESSMENT MATRIX A B c D G H Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference MCR Shift Manager No Yes Yes E-MSED1 - Activate the ERO as deemed appropriate or as procedurally EP-DR-1 000, Part II, (Shift Emergency re uired . Section B.5.a.1 &

~ Director) E-MSED2 - Perfo1111 duties outlined for the Station Emergency Director. The Appendix 5 MSED responsibilities described for the Station Emergency Director applies to either I the Shift Emergency Director or the Station Emergency Director depending on 3 which individual is in Command and Control.

e P1Sel:JJ SAYl~e Ates reaster ASA ~etermiAs~ teat tes safst1 ef tee I Eliminate Reactor operation is not applicable in a permanently reastor is iA jaof]aFG

- -.-- -_, er

- l:ieA Of;eraliR~

-.- - flarametars e;mae'tt aA ef tl:la raaster f)FatastiaA sirst.iit sat f)BiRts aRG a1:1tamatis st:i1:1t1fa A Gees Rat ass1:1r.

defueled condition .

4

~ MS~C4 e:Astue a re ie l=las BeeA semf)leteEI ta EtetermiAe tt:le Eliminate Reactor operation is not applicable in a permanently sirs1::1mstaAse, sa1:1se , aAEI limits 1::1At:ter t:li st:I SfJeratia As saA safel) fJresee9 defueled condition .

~afars t~a reastar 's retl.4rAe8 ta fJa er f.ella iAg a trifJ er aA 1:JRSS~BBl.4la8 er 5

E MSEC5 Qe fJFBSBRt at tt:le fJlaRt aA9 fJFS i9e 9irestiaA fer retl4FAir1g tl=le Eliminate Reactor operation is not applicable in a permanently reastar ta fJB ar fGlla iAJ a trifJ ar aA 1:JAsst:le91:Jle9 ar YAaJEfJlaiAe9 fJB er defueled condition .

6 E-MSED6 - Adhere to th e station Technical Specifications and review routine ooeratinq data to assure safe operation .

E-MSED? - Identify applicable EALs and emergency classifications.

E-MSEDB - Adhere to plant operating procedures and the requirements for their use.

E-MSED9 - Supervise the activities of the Control Room Crew.

MCR I Shift RP Techs I No I Yes I No E-MCRRP1 - The Station Radiation Protection personnel are responsible for Appendix 5 IPer the On Shift Staffing Assessment, this task may be IShift Operations the handling and monitoring of radioactive materials.

E r1G~~P~ PeFferm 9ese assessmeAtS'fJrejestieAs aA9 fJrB i9e iAfJYt ta Re-assigned to afJfJlisal:Jle P" ~ 9osisiaA mal~a r , YAtil relia a9. Shift Operations performed by available Operations staff as a collateral 12 duty.

r-I MCR STA No Yes No Ii ~~CAST' 1 ~ all:late plaAt Genc:litians anc:I reGammenc:I emergeAG) Eliminate Evaluation of Plant conditions will performed by the Appendix 5

"" - -** ... .. . u Shift Emerqencv Director. (Reference E-MSED7 )

Eliminate This task is deleted because the reactor is 14 C_Ul"'DCTA') - Cu .. 1.....+9 reaster 69Ac:liti9AS. Ipermanently shutdown and defueled till TSC Istation Emergency No Yes Yes IE-TED1 -Activate the Facility E-TED2 - Conduct personnel assembly/accountability and evacuation of EP-DR-1 000, Part 11 ,

Section B.5.a.2 &

Director non essential personnel at Site Area Emergency, General Em ergency or as Appendix 5 16 I ITED conditions warrant.

E-TED3 - If the emergency involves a hazardous substance and/or oil discharges , ensure that appropiate notifications and response have been 17 made.

E-TED4 - Determine if the OSC is to remain activated at the Alert Classification.

18 E-TED5 - Event classification E-TED6 - Emergency exposure controls.

E-TED? - Protective actions for all onsite personnel.

E-TEDB - Supervision of the Station ERO.

E-TED9 - Inform the Corporate Emergency Director and onsite NRC as to the 23 status of the plant E-TED10 -Assist the Corporate Emergency Director in the acquisition of information for the state/local notifications, NRC notifications and offsite agency 24 updates.

E-TED11 - Provide information and recommendations to the Corporate 25 Em erQency Director.

Page 1

ERO STAFFING ASSESSMENT MATRIX A B c D E F G H I J Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section 1 Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference E-TED12 - Implement plans, procedures and schedules to meet emergency response objectives as directed by the Corporate Emergency Director

~

E-TED13 - Request from the Corporate ERO any additiona l material , personnel resources or equipment needed to implement response plans and operations 27 TSC ENS No Yes No E-TENS1 - Establish communications with approp riate parties as directed. EP-DR-1000, Part II ,

~ Communicator Section B.5.a.3 &

TENS E-TENS2 - Transmit information that has been reviewed and/or approved by Appendix 5

.12. the responsible Manaqer or Coordinator .

E-TEN S3 - Document time , date and information being transmitted or received 2Q. on aooroori ate forms.

E-TEN S4 - Record and relay inquiries and the responses to those inquiries.

~

31 E-TENS5 - Assist appropriate Managers and Coordinators in maintaining 32 proper records and logs of emergency related activities.

}I E-TENS6 - Gather, record and post appropriate information.

E-TENS? - Notify the NRG of changes in event classification and assist in completing the NRC Event Notification Worksheet and responding to NRC

.1i innuiries.

E-TENSB - Provide real time updates of significant changes to plant and

~ svstem status and responses to NRC inquiries E-TEN S9 - Maintain continuous communications with the NRC , if requested , via 36 the NRG ENS phone or commercia l telephone line.

TSC Operations No Yes Yes E-TOM1 - In the event that the Station Emergency Director becomes EP-DR-1 000, Part II ,

Manager incapacitated and can no longer fulfill the designated responsibilities , the Section B.5.a.4 &

TOM Operations Manager wi ll normally assume the responsibi lities until relieved by Appendix 5

.lI.. another qualified Station Emeraencv Director E-TOM2 - Coordi nate TSC efforts in determining the nature and extent of emergencies pertaining to equipment and plant facilities in support of Control Room actions.

~

E-TOM3 - Initiate immediate corrective actions to lim it or contain the

~ emerqencv invokinq the provisions of 10 CFR 50.54(x) if appropriate E-TOM4 - Recommend equipment operations checks and miscellaneous actions to the Control Room in support of restoration and accident mitigation .

~

E-TOM5 - Approve emergency special procedures, and implement as required 41 under the provisions of 10 CFR 50.54(x).

42 E-TOM6 - Assist in determining the priority assigned to OSC activities E-TOM? - Organize and direct medical response efforts for injured personnel.

~

E-TOM8 - En su re adequate staffing of the Control Room and TSC

~ subordinates E-TOM9 - En sure the Shift Manager is informed of OSC staffing utilization and

~ activities.

E-TOM10 - Identify steps or procedures that the Operations staff shou ld be

...§. utilizina to oraoerlv resoond to the emeraencv condition.

E-TOM11 - Assist the Station Emergency Director in evaluating changes in

,..£. event classification 48 E-TOM12 -Supervise the activities of the-ENS Communicator in the TSC.

~

E-TOM13 - Act as the TSC liaison with the appropriate NRG Site Team

~ Reoresentative.

E-TOM14 - App ri se the TSC and EOF staff of the overall plant condition and 50 significant changes to system and equipment status Page 2

ERO STAFFING ASSESSMENT MATRIX A B c D E F G H I J Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section 1 Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference TSC Core Thermal Yes Yes Yes E TG+E1 E alt1ate re aster seAeffsAs . Eliminate Core assessment and the associated Engineering N/A Engineer support not required after fuel removed from reactor 2..1.. TCTE vessel.

Ii! +G+I!!~ SsP es as Gere blaFRa111 e OssessFReAt ~4eU::)e8eleg~ ~G QDi~4~ Elimin ate Core assessment and the associated Engineering

~ support not required after fuel removed from reactor 52 vessel.

TSC Mechanical Yes Yes No i. :mi.1 Pre i9e eAgiAeeriAg se erage fer Re-assigned to Re-assign task to TSC Engineer TEN - TSC Engineer N/A Engineer tl=l e l!!RG relateEI ta mesl=laAisal eqt1iflFRBAt. new TSC TME Engineer 53 Position TSC Electrical Yes Yes No e Tee1 PFB i8e eAgiAeeriAg se erage fur tl=le ERG relateEI ta elestrisal er 1g G Re-assigned to Re-assign task to TSC Engineer TEN - TSC Engineer Engineer ~ newTSC TEE Engineer 54 Position TSC TSC Engineer New Position Yes No E-TEN1 Provide engineering coverage for the ERO From TME an Reassigned tasks from Mechanical and Electrical E-TME1 & TEE1 - N/A TEN TEE Engineers Provide engineering 55 coverage for the ERO TSC TSC Radiation No Yes Yes E-TRPM1 - Accumulate, tabulate and evaluate data on plant conditions such as EP-DR-1000, Part II ,

Protection meteorological and radiological monitoring readings , and other pertinent data . Section B.5.a.6 &

..22. Manager TRPM E-TRPM2 - Act as the TSC liaison with the appropriate NRC Site Team Appendix 5 21.... representative.

E-TRPM3 - Ensure use of protective clothing, respiratory protection , and access control within the plant as deemed appropriate to contro l personnel

~ exoosures.

E-TRPM4 - Ensure that appropriate bioassay procedures have been implemented fo r onsite personnel when a radioactivity incident has occurred .

59

...§2. E-TRPM5 - Ensure that personnel are decontaminated , if necessary .

E-TRPM6 - Authorize personnel exposures below 5 Rem TEDE (EPA-400 lower limit).

~

E-TRPM7 - Assist the Station Emergency Director in determining if exposures in excess of the 5 Rem TEDE (EPA-400 lower limit) are necessary.

_g E-TRPM8 - Advise the Station Emergency Director of situations when the use

,.22.. of Kl should be considered .

E-TRPM9 - Advise the Station Emergency Director and EOF Radiation

~ Protection Manaaer of chanaes in rad ioloaical release status.

E-TRPM1 0 - Assist the Operations Manager in planning rescue operations and provide monitoring services as required , including the transfer of injured and/or

.§._ contaminated personnel.

E-TRPM11 - Coordinate with the Security Coordinator to determine the routes

~ to be used fo r evacuation of non-essential personnel.

E-TRPM12 - Assure additional radiation protection personnel and/or equipment 67 is arranaed for, as necessarv.

TSC Security No No No E-TSEC1 - Maintain plan t security and account for all personnel with in the EP-DR-1000, Part II ,

~ Coordinator I orotected area. Section B.5.a.7 &

TSEC E-TSEC2 - Assist the Station Emergency Director in evaluating cha nges in Appendix 5

,..§2. securitv related th reats and even t classifications E-TSEC3 - Identify any non-routine security procedures and/or contingencies 2Q. that are in effect or that reauire a response.

E-TSEC4 - Expedite ingress and egress of emergency response personnel 71 Page 3

ERO STAFFING ASSESSMENT MATRIX A B c D E F G H I J Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section 1 Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference E-TSEC5 - Coordinate with the Radiation Protection Manager in control ling ingress and egress to and from the Protected Area if radiological concerns are

,E_ loresent.

E-TSEC6 - Provide for access control to the Control Room , TS C and OSC, as 21 aoorooriate.

E-TSEC7 - Expedite entry into the Protected Area, as necessary, for the NRC

.2! Site Team .

E-TSEC8 - Act as the TSC liaison with the appropriate NRC Site Team

~ representative.

E-TSEC9 - Assist the Radiation Protection Manager in determining personnel 2§_ evacuation routes as necessarv.

E-TSEC 10 - Coordinate the evacuation of station non-essential personnel with

]!_ the aoorooriate Local Law Enforcement Aaencies I LLEAs l .

E-TSEC 11 - Coordinate security- related activities and information with the 78 Emerqencv Coordinator.

osc Offsite Field No Yes No E-OSCFMT1 - Assess the area(s) outside the protected area for radiation and Appendix 5 Monitoring contamination, and for radioactive plume tracking, as directed by, and under Teams (2 persons the con trol of, the EOF DAC or RPM. Responsible for the radiation protection

-79 80 each) coverage of the FMT as directed by EOF RPM.

E-OSCFMT2 - Driver to provide transportation.

osc OSC Director No Yes Yes E-ODIR1 - Assign tas ks as available:(l&C Maint, Mech Maint, Electrical Maint, Task Revised Revised task to recognize removal of some OSC EP-DR-1000, Part II ,

J!l_ ODIR Rad Protection) Leads Section B.5.a.8 &

E-ODIR2 - Coordinate wi th Operations in the dispatch of Operations personnel Appendix 5

,_g to support Control Room and OSC Team activities E-ODI R3 - Notify the Control Room and TSC prior to dispatch of any OSC

~ teams into the plant.

E-ODIR4 - Maintain OSC resources including personnel, material , and 84 eauipment.

E-ODIR5 - Maintain accountability for all individuals dispatched from the OSC.

85 E-ODIR6 - Conduct periodic briefings on the overall plant status, emergency resoonse activities, and station oriorities

~

87 E-ODIR7 - Assemble and dispatch the Field MonitorinQ Teams as required.

Ba E-ODIR8 - Supervise OSC activities as directed bv Emerq encv Coordinator.

osc l&C Tech (1) No Yes No E-OSCIC1 - Provide assistance with logic manipulation, support for event EP-DR-1000, Part 11 ,

mitigation and equipment repair, and support Section B.5.a.9 & App 89 of diQital l&C if applicable 5 osc Electrical Tech (1) No Yes No E-OSCEM1 - Provide electrical support for ECCS equipment, event mitigation , EP-DR-1000, Part II ,

and equipment repair. Section B.5.a.9 & App 90 5 osc Mechanical Tech No Yes No E-OSCMM1- Provide mechanical support for ECCS equipment, event EP-DR-1000, Part II ,

(1) mitigation , and equipment repair. Section B.5.a.9 & App 91 5 osc l&C Yes Yes No o; gsc;u;;c;b1 1:1psP iss QSG asti it'es FelataG ta 18£ as:tciipmaRt. Ma~ Ba Eliminate The need for a Group Lead/Supervisor is no longer N/A Supervisor/Lead samBiRBEI itl=l ~lestr:isal S1:1r;>eP iser. needed initially due to the smaller response. The Techs will be managed by the OSC Director. Leads 92 will be supplemented if necessary.

osc Electrical Yes Yes No e QS(;eP1Gb1 S1c1peP ise GSG asti ities relates ta elestrisal BEt1o:1ipmeAt. Eliminate The need for a Group Lead/Supervisor is no longer N/A Supervisor/Lead needed initially due to the smaller response. The Techs will be managed by the OSC Director Leads 93 will be supplemented if necessary.

Page 4

ERO STAFFING ASSESSMENT MATRIX A B c D E F G H I J Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section 1 Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference osc Mechanical Yes Yes No e GSGP01Gb1 S1:1peP ise GSG asti ities FelateEI ts mest:laRisal eq1:1ipmeRt. Eliminate The need for a Group Lead/Supervisor is no longer N/A Supervisor/Lead needed initially due to the smaller response. The Techs will be managed by the OSC Director. Leads 94 will be suoolemented if necessarv.

osc RP No Yes No E-OSCRPGL 1 - Supervise OSC activities related to radiation protection Maintan as EP-DR-1000, Part 11 ,

Supervisor/Lead collateral duty The duties for oversight of the RP OSC staff will be Section B.5.a.9 &

95 taken as a collateral function for a RP Technician. Appendix 5 osc Onsite Field No Yes No E-OSCRPOS1 - Q"alifiee IAei ie"al RP Personnel to assess the protected Revised Task was revised to recognize performance by RP Appendix 5 Team area for radiation and contamination and provide input to the TSC RPM Personnel rather than Qualified Individuals.

Responsible for radiation protection coverage for th e FMT as directed by TSC 96 RPM or EOF RPM.

osc Radiation Reduced Yes No E-OSCRPT1 - Provide qualified radiation protection coverage for responders The proposed OSC staff is revised to (2) RP EP-DR-1000, Part II ,

Protection Tech accessing potentially unknown radiological environments during emergency personnel. While no responsibilities are deleted, the Section B.5.a.9 &

(6) cond itions. response in a permanently shutdown condition is Appendix 5 limited when compared to an operating reactor. See

I!.. Attachment 1 of the LAR for discussion.

E-OSCRPT2 - Provide in-plant surveys. The proposed OSC staff is revised to (2) RP personnel. While no responsibilities are deleted, the response in a perm anently shutdown condition is limited when compared to an operating reactor. See 98 Attachment 1 of the LAR for discussion.

E-OSCRPT3 - Control dosimetry and radiologically controlled area access. The proposed OSC staff is revised to (2) RP personnel. While no responsibilities are deleted, the response in a permanently shutdown condition is limited when compared to an operating reactor. See 99 Attachment 1 of the LAR for discussion.

EOF Corporate No Yes Yes E-EED1 - Coordinate all Exelon Nuclear activi ties involved with the emergency EP-DR-1000, Part II ,

.1QQ Emergency response . Section B.5.b.1 &

Director E-EED2 - Ensure off-site agency updates are periodically communicated as Appendix 5

.lQ1 EEO required/requested .

E-EED3 -Coordinate Exelon Nuclear press releases with the Nuclear Duty 102 Officer and Exelon Communications and Public Affairs.

E-EED4 - Request assistance from non Exelon Nuclear emergency response 103 oraanizations, as necessarv.

E-EED5 - Following assumption of Command and Control, Assumes overall Command and Control of emergency response activities and the non-delegable responsibilities for PAR determination and the notification of offsite authorities

~

E-EED6 - Following assumption of Command and Control, En sure that Federal ,

state and local authorities and industry support agencies remain cognizant of the status of the emergency situation. If requested , dispatch informed individuals to offsite governmental Emergency Operation Centers (EOCs)

~

E-EED7 - Following assumption of Command and Control , Approve the technical content of Exelon Nuclear press releases prior to their being released 106 to the media.

EOF EOF Radiation No Yes Yes E-ERPM1 - Recommend changes in event class ification and PARs based upon EP-DR-1000, Part II ,

.lQZ Protection effluent releases or dose projections Section B.5.b.2 &

Manager E-ERPM2 - Assist the Emergency Director in the evaluation of the significance Appendix 5 108 ERPM of an emeraencv with resoect to the oublic.

E-ERPM3 - Notify the Emergency Director of meteorological changes that may 109

,____ imoact identification of downwind areas.

E-ERPM4 - Advise the Corporate Emergency Director of protective actions 110 taken bv the station for olant oersonnel.

Page 5

ERO STAFFING ASSESSMENT MATRIX A B c D E F G H I J Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section 1 Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference E-ERPM5 - Assist the TSC in the planning and coordination of activities 2.!2 associated with the evacuation of non-essential personnel.

E-ERPM6 - Advise the Corporate Emergency Director on the need for emergency exposures or for issuance of Kl to the Fi eld Monitoring T eams or J.]1 Exelon oersonnel reauired to enter the olume.

E-ERPM7 - Determine the need for and contact Occupational Health/Industrial J..Ji Safetv Services oersonnel for assistance.

E-ERPMB - Monitor plant radiological conditions and advise the TSC Radiation Protection Manager of any adverse trends or potential release pathways that

~ mav imoact existina event classification.

E-ERPM9 - Assist in the completion and review of the state/local notification J.12 form.

11 6 E-ERPM10 - Maintain cognizance of environmental sampling activities.

E-ERPM11 - Ensure state authorities are provided information pertaining to 117 Exelon Field Monitorina Team activities and samole results.

E-ERPM12 -Assist the affected stati on in planning and coordination of

~ activities associated with the evacuation of non essential oersonnel.

E-ERPM13 - Assist the affected station in acquisition of additional instrumentation. dosimetry, protective equipment and radiological support

-11 9 loersonnel E-ERPM14 -Assist and interface with the EOF Technical Support Group and the station in the development of plans for plant surveys, sampling , shielding ,

and special tools in support of waste systems processing and design modification activities

~

E-ERPM15 - Upon request. provide in-plant health physics data to Emergency E.!. Public Information oersonnel.

122 E-ERPM16 - Coordinate Field Monitoring Team activities.

E-ERPM17 - Determine needs of the Dose Assessment Coordinator and the ENS Communicator for updates on Field Monitoring Team data and ensure

.112 distribution of new data to them in accordance with those needs.

E-ERPM18 - Promptly report new environmental or Field Monitoring Team 124 exoosure data to the Dose Assessme nt Coordinator E-ERPM19 - Evaluate and assess plant and offsite radiological data in the 125 develooment of onsite orotective actions and offsite PARs , until relieved E-ERPM20 - Recommend onsite protective actions and offsite PARs to the 126 aoolicable decision- maker, until relieved .

E-ERPM2 1 - Direct all radiation protection activities, including field monitoring

~ team (FMT) direction, until relieved.

E-ERPM22 - Provide relevant information to applicable communicators who are 128 communicatinQ offsite PARs to OROs, until relieved.

EOF Dose Assessment No Yes No E-EDAC1 - Interp ret radiological data and provide PARs based upon dose EP-DR-1000, Part II ,

Coordinator I oroiections to the EOF Radiation Protection Manaaer Section B.5.b.3 &

~

EDAC E-EDAC2 - Advise the EOF Radiation Protection Manager of cha nges in event Appendix 5 J1Q classification based on effluen t releases or dose oroiections.

E-EDAC3 - Initiate evaluation of the need for administering Kl to Exelon nuclear Jll workers E-EDAC4 - Remain cognizant of forecast and meteorological data and ensure E the status is updated periodically E-EDAC5 - Notify the EOF Radiation Protection Manager of meteorological J..22 chanQes that may impact identification of downwind areas.

E-EDAC6 - Upon request , provide release and dose assessment data to

~ Emeraencv Public Information oersonnel.

E-EDAC7 - Perform dose projections using the Dose Assessmen t computer 135 models.

Page 6

ERO STAFFING ASSESSMENT MATRIX A B c D E F G H I J Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section 1 Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference 136 E-EDAC8 - Monitor meteorological and plant effluent conditions.

E-EDAC9 - Eva luate the need for administering Kl to Exelon nuclear workers.

m E-EDAC10 - Perform dose assessments/projections and provide input to 138 aoolicable PAR decision- maker, until relieved .

EOF Computer No Yes No E- ECOMPS1 - Assist any personnel in logging in, initializing or using a desired EP-DR-1 000, Part II ,

.ill Specialist computer proqram. Section B.5.b.4 &

ECOMPS E- ECOMPS2 - Investigate and repair problems encountered with Appendix 5 140 communications eauioment and comouter eauiomenUaoolications.

EOF EOF State/Local No Yes No E-ESL 1 - Communicate and receive information via the Nuclear Accident EP-DR-1000, Part II ,

Communicator Reporting System (NARS) circuit or commercia l telephone line with appropriate Section B.5.b.5 &

..!.+/-!. ESL state and county agencies Appendix 5 E-ESL2 - Prepare state/local notification forms with the assistance of the 142 Corporate Emerqencv Director.

JIC Corporate No Yes No E-JCSP1 - Maintain command and control of the Joint Information Center. EP-DR-1000, Part 11 ,

~

Spokesperson E-JCSP2 - Coordinate with Federal , state and local agencies, as we ll as with Section B.5.c.1 &

JCSP other organizations involved in the emergency response , to maintain factual Appendix 5 consistency of information to be conveyed to the news media/public.

~

E-J CSP3 - Conduct periodic briefings with the news media.

,!.12 146 E-JCSP4 - Interface with the Public Information Director

~ E-JCSP5 - Coordinate and direct responses to media inquiries.

E-JCSP6 - Ensure that the composition and timeliness of Exe lon News

~ Releases are adeauate.

E-JCSP7 - Provide for timely exchange of information between other 149 spokespersons.

JIC JIC Director No Yes No E-JDIR1 - Maintain cognizance of conditions of the plant and environment, and EP-DR-1000, Part 11 ,

150 JDIR the actions of Exelon Nuclear and aovernmental suooort oersonnel. Section B.5.c.2 &

E-JDIR2 - Coordinate with Federal, state and local agencies, as well as with Appendix 5 other organizations involved in the emergency response , to maintain factual consistency of information to be conveyed to th e news media/public.

151 E-JDIR3 - Participate, as needed , in rumor control activities.

~

E-JD IR4 - Ensure that adequate information flow between the EOF and the JIG

.ill is coordinated.

154 E-JDIR5 - Authorize admittance of non-Exelon Nuclear officials to the JIC.

E-JDIR6 - Until the JIG is fully staffed, work with Corporate Communications to 155 comoose draft news releases .

E-JDIR7 - Provide the drafted news releases to the Corporate Emergency

~ Director for technical review prior to Public Information Director approval.

E-JDIR8 - Until the JIG is fully staffed , work with Corporate Communications to ensure that rumors are reviewed , documented and responded to by Exelon 157 Nuclear oersonnel as deemed aoorooriate E-JDIR9 - Until the JIG is fully staffed, work with Corporate Communications to document and respond to rumors as quickly as possible, through the Exelon

..!2§ Communications and Public Affai rs .

E-JDIR10 - Until the JIG is fully staffed , work with Corporate Communications to ensure that the media is being monitored and that Exe lon Nuclear personnel review th e information detailed or contained in media releases 159 JIC Public Information No Yes No E-JP ID1 - Provide the Corporate Emergency Director with an overview of the EP-DR-1000, Part II ,

Director public and media impacts resulting from the Exelon Nuclear and governmental Section B.5.c.3 &

160 JPID activities Aooendix 5 Page 7

ERO STAFFING ASSESSMENT MATRIX A B c D E F G H I J Task Disposition (Eliminated/ Tasks transferred Current ERO Position Min NRCPI Tasks defined by Station Emergency Plan Reassigned Justification I to this position per E-Plan Section 1 Facilty Position Eliminated Staff Key ERO To) Implementing action this Assessment Reference E-JPID2 - Participate with the Corporate Emergency Director regarding 161 information to be released to the public.

162

,____ E-JPID3 - Authorize the issuance of news releases .

,.!§ E-JPID4 - Interface with the Corporate Spokesperson at the JIG.

E-JPID5 - Act as a liaison between the ERO and Exelon Nuclear's corporate JM execu tives.

E-JPID6 - Maintain cognizance of conditions of the plant and environment, and

]§ the actions of Exelon Nuclear and aovernmental suooort oersonnel.

2§ E-JPID7 - Coordinate information flow between the EOF and the JIG.

167 E-JPIDS - Review and access media coverage of the emergency event Page 8

Attachment 5 Dresden Station

SUMMARY

OF REGULATORY COMMITMENTS

Attachment 5

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME PROGRAMMATIC "OUTAGE" ACTION (YES/NO)

(YES/NO)

Dresden will perform a drill to Prior to Yes No confirm the ability of the post- implementation of shutdown ERO to perform the the Post-Shutdown necessary functions of each Emergency Plan .

emergency response facility and to utilize the post-shutdown procedures being developed depicting the revised assignment of duties. State and local response organizations will be offered the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities.

In addition, other training drills will be conducted to train post-shutdown station ERO members.

Attachment 6 Dresden Station CORRESPONDENCE WITH THE STATE OF ILLINOIS

ILLINOIS EMERGENCY MANAGEMENT AGENCY JB Pritzker Alicia Tate-Nadeau Governor Director October 29, 2020 Christina Nelson Midwest Emergency Preparedness Manager Exelon Generation 4300 Winfield Road Warrenville, IL 60555

Dear Ms. Nelson,

The Illinois Emergency Management Agency has completed its initial review of the License Amendment Request (LAR), "Proposed Chan9es to the Byron and Dresden Emergency Plan for Post-Shutdown and Permanently Defueled Condition". We appreciate the opportunity to comment on this document.

The objective of our review was to identify any potential impacts to off-site emergency preparedness and response. This review focused on those changes that have the potential to negatively affectthe implementation of the Illinois Plan for Radiological Accidents (IPRA) and the health and safety of the public.

During our TEAMS meeting this morning, we raised several questions regarding the proposed amendment. We also requested that Exelon revisit our previous comments from AR Number 02701960. Our questions and previous comments were addressed in an expeditious manner.

Based upon our review of this document and the proposed changes, lEMA does not anticipate submitting concerns to the U.S. Nuclear Regulatory Commission as part of their review process of the above referenced LAR.

Sincerely,

~!!=of.~

1035 0 t '1"LR P .\Rt-.. ORl \11. S l?Rl!'<Gl 'll .LO, IL 62 04 I 2l7 .782-2700 illinois.gov/ iema ready.illinois.gov

v t e Letter Sequence Request
EPID:L-2020-LLA-0217, TSTF-448 (Withdrawn, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Administration Questions 2 March 2021 10 August 2021 Answers Results Withdrawal Other:
MONTHYEAR2021-02-23 [Table View]

RS-20-131, Part II: Planning Standards and Criteria

Text

SUMMARY

SUMMARY

Dear Ms. Nelson,

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