View source for JAFP-17-0073, ISFSI - License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel

{{Adams
| number = ML17213A049
| issue date = 07/31/2017
| title = ISFSI - License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel
| author name = Gudger D
| author affiliation = Exelon Generation Co, LLC
| addressee name = Gudger D
| addressee affiliation = NRC/Document Control Desk, NRC/NMSS, NRC/NRR
| docket = 05000333, 07200012
| license number = DPR-059, SFGL-0012
| contact person = 
| case reference number = JAFP-17-0073
| document type = Letter type:JAFP, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 20
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Exelon Generation ~                                               200 Exelon Way Kennett Square. PA 19348 www exeloncorp.com 10 CFR 50.90 JAFP-17-0073 July31,2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant Independent Spent Fuel Storage Installation General License SFGL-12 Docket No. 72-012

==Subject:==
License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel In accordance with 10 CFR 50.90, "Application for arr:iendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the licenses cited for the James A. FitzPatrick Nuclear Power Plant (FitzPatrick).
Specifically, the proposed change would revise the description for Emergency Response Organization (ERO) requalification training frequency defined in FitzPatrick's governing Emergency Plan from annually to "once per calendar year not to exceed 18 months between training sessions." The Emergency Plan is described in the FitzPatrick's Final Safety Analysis Report (FSAR). In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (q),
 "Emergency plans," Exelon requests U.S. Nuclear Regulatory Commission (NRC) approval of the proposed change to the FitzPatrick Emergency Plan.
The proposed change has been reviewed by the Onsite Safety Review Committee at the station in accordance with the requirements of the FitzPatrick Quality Assurance Program.
Attachment 1 provides an evaluation of the proposed change, including a detailed description, technical and regulatory evaluation including a no significant hazards consideration, and an environmental consideration. Attachment 2 contains mark-ups of the existing Emergency Plan pages showing the proposed change to the facility's Emergency Plan.

U.S. Nuclear Regulatory Commission License Amendment Request Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 July 31, 2017 Page 2 Exelon requests approval of the proposed license amendment by July 31, 2018. Once approved, the amendment shall be implemented within 90 days.
There are no regulatory commitments contained in this submittal.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its supporting attachments to the designated state officials.
Should you have any questions regarding this submittal, please contact Richard Gropp at (610) 765-5557.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31 51 day of July 2017.
RefPJectfully, l>-\-'. /..<-... : J -1.
L        j yv--
David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Evaluation of Proposed Change
: 2) FitzPatrick Emergency Plan Mark-up cc:         Regional Administrator - NRC Region I NRC Senior Resident Inspector- J.A. FitzPatrick NRC Project Manager, NRA - J.A. FitzPatrick A.L. Peterson, NYSERDA D. Currier, Oswego County EMO

ATTACHMENT 1 License Amendment Request EVALUATION OF PROPOSED CHANGE

==Subject:==
License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization for the James A. FitzPatrick Nuclear Power Plant 1.0    

==SUMMARY==
DESCRIPTION 2.0    DETAILED DESCRIPTION

==3.0    TECHNICAL EVALUATION==

==4.0    REGULATORY EVALUATION==

4.1    Applicable Regulatory Requirements/Criteria 4.2    Precedent 4.3    No Significant Hazards Consideration 4.4    Conclusions

==5.0    ENVIRONMENTAL CONSIDERATION==

==6.0     REFERENCES==

Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 1 of 10 ATTACHMENT 1 1.0      

==SUMMARY==
DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests an amendment to the James A. FitzPatrick Nuclear Power Plant (FitzPatrick) Renewed Facility Operating License (FOL) and Independent Spent Fuel Storage Installation General License.
The proposed change would revise the description of Emergency Response Organization (ERO) requalification training frequency defined in the station's Emergency Plan. The proposed frequency will be defined as "once per calendar year not to exceed 18 months between training sessions." In this context, training session refers to the annual requalification training received by the ERO.
The Emergency Plan is described in the facility's Final Safety Analysis Report (FSAR). In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans,"
Exelon requests U.S. Nuclear Regulatory Commission (NRG) approval of the proposed change to the Fitzpatrick Emergency Plan.
2.0      DETAILED DESCRIPTION Planning Standard 10 CFR 50.47(b)(15) specifies that radiological Emergency Response Organization (ERO) training is provided to those who may be called on to assist in an emergency. This is further expanded in regulatory guidance provided in NUREG-0654, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," which specifies that organizations shall establish specialized initial and periodic retraining programs for those who may be called upon to assist in an emergency and that each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.
2.1   James A. FitzPatrick Nuclear Power Plant Emergency Response Plan The FitzPatrick Emergency Plan provides the following frequency requirements for ERO training in Section 8.
8.2 Training of Emergency Personnel Plant personnel, participating corporate personnel, and offsite response organization personnel that respond to onsite requests for assistance receive emergency response training in accordance with their roles in an emergency...
          . . . Personnel assigned to the JAFNPP with specific emergency preparedness duties and responsibilities shall receive specialized training for their respective assignments. The types of training given in conjunction with Emergency Preparedness are:
: a. Training for directors, coordinators, and personnel responsible for accident assessment
: b. Emergency Communications training Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 2 of 10
: c. Training for Radiological Monitoring Teams and Radiological Assessment personnel
: d. Emergency access control, evacuation and accountability
: e. Search and rescue/first aid response
: f. Emergency repair/corrective actions
: g. Training for onsite fire fighting personnel
: h. Medical support personnel
: i. Offsite fire fighting personnel
: j. Severe Accident Management training Figure 8. 1 - Emergency Response Training presents a summary of the emergency response training program including type of training, personnel receiving training, frequency of training and retraining, applicable procedures, and objectives of the training.
The FitzPatrick Emergency Plan currently states the ERO requalification training is "annual" for the site emergency response personnel. The term "annual" is not specifically defined within the Emergency Plan although it is described in implementing procedures (i.e., SAP-20); however, FitzPatrick implements ERO requalification training every 12 months. The proposed change in the ERO requalification training frequency for FitzPatrick would result in a change to the Emergency Plan. Section 8, Figure 8.1, Emergency Response Training provides a description regarding the ERO requalification training frequency. Exelon proposes to modify the discussion to define the training frequency as: "once per calendar year not to exceed 18 months between training sessions," as described below.
Title I Function                  Assigned Personnel                            Frequency Emergency Plan                         Essential personnel who may    Before assuming position, Indoctrination for Essential           be assigned to specific        Anmm!!y Once per calendar Personnel                              response functions in          year not to exceed 18 JAFNPP Emergency Plan.         months between training sessions thereafter.
Emergency Plan Training for           Designated Primary and         Before assuming position, directors, coordinators, and          Alternates                     Ann1:1a/.!y Once per calendar personnel responsible for              a. Emergency Director          year not to exceed 18 accident assessment                   b. EOF Manager                 months between training
: c. Operations Coordinator*     sessions thereafter.
Emergency Plan Training for           Any personnel not listed       Before assuming position, Licensed Operators and Shift          above who are assigned to a    Ann1:1a!!y Once per calendar Technical Advisors                    position that requires a valid year not to exceed 18 USNRC Operator License, or     months between training who are designated as STAs. sessions thereafter.
Emergency Plan Training for           Non-Licensed Operators         Before assuming position, Non-Licensed Operators                                               Ann1:1a!!y Once per calendar year not to exceed 18 months between training sessions thereafter.
Emergency Communications              Designated Primary and         Before assuming position, Alternates:                     ~::.- ''.:: 11 ~' Once per calendar Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 3 of 10 Title I Function              Assigned Personnel                     Frequency
: a. ENS Communicator              year not to exceed 18
: b. Offsite Communicators         months between training (EOF)                        sessions thereafter.
: c. EOF Communicators Radiological Assessment        Designated Primary and           Before assuming position, Alternates:                      ARR1:1aJ!y Once per calendar
: a. Radiological Assessment       year not to exceed 18 Coordinator (EOF)            months between training
: b. Offsite Team Coordinator     sessions thereafter.
(EOF)
: c. Dose Assessor (EOF)
: d. Dose Assessor Support (EOF)
Radiological Controls and       Designated Primary and          Before assuming position, Surveys during Emergencies      Alternates:                     ARRl::la!!y Once per calendar a) In-Plant Radiological        year not to exceed 18 Controls and Downwind        months between training Survey Teams                 sessions thereafter.
b) RP Technicians c) Chemistry Technicians d) Radiation Protection I Chemistry Coordinator e) Offsite Monitoring Team Emergency Access Control,       Designated Primary and          Before assuming position, Evacuation and Accountability   Alternates                      ARRl::JaJ!y Once per calendar
: a. Plant Security Force         year not to exceed 18
: b. Security Coordinator         months between training
: c. Security Shift Supervisor    sessions thereafter.
: d. Nuclear Security Guards Search and Rescue/First Aide    Plant Fire Bridage members. Before assuming position, Response                                                        Annually Once per calendar year not to exceed 18 months between training sessions thereafter.
Emergency Repair/ Corrective    Designated Primary and          Before assuming position, Actions Training                Alternates:                     ARR1:1a!!y Once per calendar
: a. TSC Maintenance Coord.       year not to exceed 18
: b. OSC Manager                  months between training
: c. Mechanics                    sessions thereafter.
: d. Electricians
: e. Instrument and Control Technicians
: f. Electrical I l&C Coordinator
: g. Mechanical Coordinator Onsite Fire Fighting Personnel  a. Fire Brigade members and     ARRl::la!!y Once per calendar Supervisors as specified in  year not to exceed 18 the Fire Protection           months between training Procedures Manual             sessions.
Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 4 of 10

==3.0     TECHNICAL EVALUATION==

Exelon proposes to revise the site Emergency Plan for FitzPatrick in order to establish a common annual ERO requalification training frequency for Exelon personnel assigned to ERO positions and to align the training frequency across the Exelon fleet.
This constitutes a minor change which will allow application of common procedural guidance and administrative tracking tools throughout the Exelon fleet. This LAR does not affect established training frequencies for non-Exelon Offsite Response Organizations (ORO) responders where Exelon may provide periodic training.
Exelon's Mid-Atlantic stations (i.e., Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station), Midwest Stations (Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, and Quad Cities Nuclear Power Station), and Northeast stations (Calvert Cliffs Nuclear Power Plant, Nine Mile Point Nuclear Station, and R.
E. Ginna Nuclear Power Plant) previously submitted LARs to revise their ERO training frequency (References 6.3, 6.4, 6.5, and 6.6). These LARs requested approval to align the training frequency between those Exelon's stations to "once per calendar year not to exceed 18 months between training sessions." These LARs have been subsequently approved as noted in References 6.7, 6.8, and 6.9.
The revised training frequency applies only to those personnel assigned to ERO positions. The change does not apply to training for ORO provided by Exelon. This change also does not apply to training provided to Exelon personnel as part of their normal job specific duties (e.g., plant operations, maintenance, radiation protection, first aid, fire brigade).
From a business needs and resource perspective, there is a benefit to have all of Exelon's nuclear facilities perform ERO training under the same requirements. Exelon utilizes common procedures and programs to manage the Emergency Preparedness training program and having all of its stations under the same program would provide efficiency and simplicity in program administration.
James A. FitzPatrick Nuclear Power Plant The ERO training frequency is not specifically defined in the FitzPatrick Emergency Plan although it is described in implementing procedures (i.e., SAP-20); however, FitzPatrick implements ERO requalification training every 12 months.
The current practice of utilizing a 12-month period for annual ERO training introduces some hardships and unintended consequences which can complicate the scheduling of training. For example, station maintenance outages or other major station events may require the ERO requalification cycle to be rescheduled (entirely or partially) either earlier or later within the year.
Considering FitzPatrick utilizes four ERO teams and train over several weeks or months; this may introduce individual tracking and scheduling complications, particularly when individuals switch to other ERO teams. Qualifications are required to be closely monitored. The need for emergent or individual training is minimized with this proposed change. The monitoring of

Attachment 1 Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 5 of 10 individual training becomes less burdensome by implementing a frequency of once per calendar year not to exceed 18 months between training sessions.
When the two frequencies for training requalification are compared over a period of several years, both methods result in the same number of training opportunities for the ERO personnel, with the understanding that the allowed grace periods are not permitted to extend training intervals.
The proposed changes in the ERO requalification training frequency for the FitzPatrick would allow alignment with other Exelon station ERO requalification training requirements. The
*flexibility to schedule training within the calendar year allows the Emergency Preparedness organizations to schedule around planned and emergent outages, operations training cycles, and other emergent station priorities.
Impact on Performance Indicators and Drill Participation The proposed revision to the training frequency would have no impact to NRG Performance Indicators (Pis). The NRG ERO Drill Participation performance indicator tracks the participation of ERO members assigned to fill key positions in performance enhancing experiences and through linkage to the Drill and Exercise Performance (DEP) indicator ensures that the risk significant aspects of classification, notification, and Protective Action Recommendation (PAR) development are evaluated and included in the Pl process. This indicator measures the percentage of ERO members assigned to fill key positions who have participated recently in performance-enhancing experiences such as drills, exercises, or in an actual event during the previous eight quarters, as measured on the last calendar day of the quarter.
The proposed revision to the annual training frequency is unrelated to drill participation requirements for the indicator. It does not impact the objective for key ERO members to have a performance-enhancing experience every eight quarters.
The proposed change in the ERO requalification training frequency for Exelon personnel assigned to ERO positions for FitzPatrick would result in consistency the with other Exelon station ERO requalification training requirements as described in References 6.3, 6.4, 6.5, and 6.6. The flexibility to schedule training within the calendar year as described allows the Emergency Preparedness organizations to schedule around planned and emergent outages, operations training cycles, and other emergent station priorities.

==4.0      REGULATORY EVALUATION==

4.1      Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.
The criteria in 10 CFR 50.54(q) provide direction to licensees seeking to revise their Emergency Plans. The requirements related to nuclear power plant Emergency Plans are specified in the standards in 10 CFR 50.47, "Emergency Plans," and the requirements of 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."
Planning Standard 10 CFR 50.47(b)(15) states that: "Radiological emergency response training is provided to those who may be called on to assist in an emergency." This is further discussed Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 6 of 10 in NUREG-0654, Section 11.0, "Radiological Emergency Response Training, "which states that:
 "Each organization shall assure the training of appropriate individuals." More specifically, step 5 states: "Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities." The proposed change to the Emergency Plan for FitzPatrick reflects a change in frequency in how ERO requalification training is implemented at this affected Exelon facility. Exelon has determined that the proposed change does not require any exemptions or relief from regulatory requirements and does not affect conformance with any 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," (GDC) differently than that described in the Final Safety Analysis Report (FSAR) for the affected facility.
NRC Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011 (Reference 6.1 ), provides guidance concerning: 1) clarifying the meaning of a "decrease in effectiveness," as stated in 10 CFR 50.54(q); 2) clarifying the process for evaluating proposed changes to emergency plans; 3) providing a method for evaluating proposed changes to emergency plans; and 4) providing clarifying guidance on the appropriate content and format of applications submitted to the NRC for approval prior to implementation.
Regulatory Guide 1.219, Revision 1, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," dated July 2016 (Reference 2), provides guidance acceptable to the NRC for making changes to the licensee's emergency preparedness plans.
4.2     Precedent There is current precedent within the Exelon fleet supporting the proposed change. By letter dated October 30, 2013 (Reference 6.3), as supplemented by letter dated June 13, 2014 (Reference 6.4), Exelon submitted an amendment request to revise the ERO requalification training requirements specified in the Emergency Plans for Limerick Generating Station, Oyster Creek Nuclear Generating Station, Peach Bottom Atomic Power Station, and Three Mile Island Nuclear Station to include provisions that the training be conducted "once per calendar year not to exceed 18 months between training sessions." By letter dated August 11, 2014 (Reference 6.5), Exelon submitted an amendment request to revise the ERO requalification training requirements specified in the Emergency Plans for Braidwood Station, Byron Station, Clinton Power Station, Dresden Nuclear Power Station, LaSalle County Station, and Quad Cities Nuclear Power Station to include provisions that the training be conducted "once per calendar year not to exceed 18 months between training sessions." By letter dated July 29, 2015 (Reference 6.6), Exelon submitted an amendment request to revise the ERO requalification training requirements specified in the Emergency Plans for Calvert Cliffs Nuclear Power Plant, Nine Mile Point Nuclear Station, and R. E. Ginna Nuclear Power Plant to include the same provisions that the training be conducted "once per calendar year not to exceed 18 months between training sessions." These license amendment requests were subsequently approved by the NRC as noted in References 6.7, 6.8, and 6.9.
4.3      No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the Renewed Facility Operating License (FOL) and Independent Spent Fuel Storage Installation General Listed listed below for the James A. FitzPatrick Nuclear Power Plant (FitzPatrick).
Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 7 of 10 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant Independent Spent Fuel Storage Installation General License SFGL-12 Docket No. 72-012 Specifically, the proposed change would revise the Emergency Response Organization (ERO) requalification training frequency for Exelon personnel assigned ERO positions defined in the station Emergency Plan as "annual" to a frequency defined as "once per calendar year not to exceed 18 months between training sessions." The Emergency Plan is described in the station's Final Safety Analysis Report (FSAR). In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," Exelon requests NRG approval of the proposed changes to the Emergency Plan for FitzPatrick.
The proposed change has been reviewed considering the applicable requirements of 10 CFR 50.47, 10 CFR 50, Appendix E, and other applicable NRG documents. Exelon has evaluated the proposed change to the FitzPatrick Emergency Plan and determined that the change does not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92, "Issuance of amendment," is provided below.
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change only affects the administrative aspects of the annual ERO requalification training frequency requirements and not the content of the training. The proposed change does not involve the modification of any plant equipment or affect plant operation. The proposed change will have no impact on any safety-related Structures, Systems, or Components (SSC).
The proposed change would revise the ERO requalification frequency from an annual basis to once per calendar year not to exceed 18 months between training sessions as defined in the FitzPatrick Emergency Plan. The proposed change will support aligning the FitzPatrick training with the rest of the Exelon fleet under one standard regarding the annual requalification training frequency of personnel assigned Exelon ERO positions.
Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected site does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 8 of 10
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change has no impact on the design, function, or operation of any plant SSC. The proposed change does not affect plant equipment or accident analyses. The proposed change only affects the administrative aspects related to the annual ERO requalification training frequency requirements. There are no changes in the content of the training being proposed under this submittal. The proposed change will support aligning the FitzPatrick training with the rest of the Exelon fleet under one standard regarding the annual requalification training frequency of personnel assigned Exelon ERO positions.
Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected site does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change only affects the administrative aspects of the annual ERO requalification training frequency requirements and does not change the training content.
The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by the proposed change to the frequency in the ERO requalification training requirements.
Therefore, the proposed change to the Emergency Plan requalification training frequency for the affected site does not involve a significant reduction in a margin of safety.
4.4      Conclusions In conclusion, based on the considerations discussed above: 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the Commission's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==5.0      ENVIRONMENTAL CONSIDERATION==

The proposed change is applicable to emergency planning standards involving ERO requalification training requirements and do not reduce the capability to meet the emergency planning standards established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 9 of 10 types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. In addition, the proposed change specifically relates to education, training, experience, qualification or other employment suitability requirements. Accordingly, the proposed change meets the eligibility criterion tor categorical exclusion set forth in 10 CFR 51.22{c)(9) and 10 CFR 51.22(c)(3)(iv).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs be prepared in connection with the proposed change.

==6.0      REFERENCES==

6.1      NRG Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011 6.2      Regulatory Guide 1.219, Revision 1, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," dated July 2017.
6.3      Letter from James Barstow, Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission - License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel, dated October 30, 2013.
6.4     Letter from James Barstow, Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission - Supplemental Response to License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel, dated June 13, 2014.
6.5     Letter from James Barstow, Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission - License Amendment Request to Revise the Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel, dated August 11, 2014.
6.6     Letter from James Barstow, Exelon Generation Company, LLC, to U.S. Nuclear Regulatory Commission - License Amendment Request to Revise the Emergency Plan Requa/ification Training Frequency for Emergency Response Organization Personnel, dated July 29, 2015.
6.7     Letter from Joel S. Wiebe, U.S. Nuclear Regulatory Commission to Michael J. Pacilio, Exelon Generation Company, LLC- Limerick Generating Station, Units 1 and 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 1, 2 and 3; and Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendments Regarding the Emergency Plan Definition of Annual Training, dated December 24, 2014 (ML14226A940).
6.8     Letter from Joel S. Wiebe, U.S. Nuclear Regulatory Commission to Bryan C. Hanson, Exelon Generation Company, LLC - Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 1, 2, and 3; LaSalle County Station, Units 1 and 2; and Quad Cities Nuclear Power Station, Units 1 and 2 - Issuance of Amendments Regarding the Emergency Plan Definition of Annual Training, dated April 8, 2015(ML14323A522).
Evaluation of Proposed Changes Revise ERO Requalification Training Frequency Docket Nos. 50-333 and 72-012 Page 10 of 10 6.9    Letter from Blake A. Purnell, U.S. Nuclear Regulatory Commission to Bryan C. Hanson, Exelon Generation Company, LLC - Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; and R. E. Ginna Nuclear Power Plants -
Issuance of Amendments Regarding Emergency Plan Requalification Training Frequency for Emergency Response Organization Personnel, dated March 17, 2016 (ML15352A164).

ATTACHMENT 2 FitzPatrick Emergency Plan Mark-up JAMES A. FITZPATRICK NUCLEAR POWER PLANT EMERGENCY PLAN Markup of Emergency Plan Pages Pages Figure 8.1 (Pages 8-13, 8-14, 8-15, 8-16, and 8-17)

FIGURE 8.1 EMERGENCY RESPONSE TRAINING TITLE/FUNCTION         ASSIGNED PERSONNEL            FREQUENCY               TRAINING OBJECTIVE Ensure Ability to:
Emergency Plan         Personnel requiring           Per General Indoctrination                                                       a. Report emergency conditions regular access to the         Employee for Non-Essential                                                       correctly and expeditiously.
site.                         Training,
: b. Recognize and recall the Personnel                                            EN-TQ-107, significance of site alarms.
Requirements
: c. Evacuate affected areas and the site.
: d. Locate and assemble in designated assembly areas.
: e. Facilitate personnel accountability process.
: f. Rumor Control.
: g. Overview of JAFNPP Emergency Plan.
Emergency Plan         Essential personnel           Before          The objective of Emergency Plan Indoctrination         who may be assigned           assuming        Indoctrination for Essential for Essential          to specific response          position,       Personnel shall be to provide Personnel              functions in JAFNPP           annually        Emergency Response Personnel a more Emergency Plan.               thereafter. detailed knowledge of the plant Emergency Plan and Procedures to ensure these personnel are familiar with their scope, applicability, and once per calendar year not to exceed                       implementation.
18 months between training sessions Rev. No. 35                                                                                       Page   8-13

FIGURE 8.1 EMERGENCY RESPONSE TRAINING (continued)
TITLE/FUNCTION      ASSIGNED PERSONNEL             FREQUENCY              TRAINING OBJECTIVE Emergency Plan      Designated Primary             Before         The objective of training for Training for        and Alternates                 assuming       Emergency Directors/Coordinators directors,                                         position       shall be to ensure the capability for coordinators, and   a. Emergency Director                         immediate response, assessment and personnel           b. EOF Manager                 Annually       the implementation of measures to responsible for     c. Operations                  thereafter     prevent or mitigate the consequences accident               Coordinator*                               of emergencies through effective assessment                                                        management of the Emergency Organization.
*Licensed Operator training may be substituted for Emergency Director training.
Emergency Plan      Any personnel not              Before         The objective of Emergency Plan Training for        listed above who are           assuming       training for Licensed Operators and Licensed            assigned to a                  position       STAs shall be to ensure the Operators and       position that                                 capability for immediate response, Shift Technical     requires a valid                              assessment, and the implementation of Advisors            USNRC Operator                                measures to prevent or mitigate the License, or who are            Annually       consequences of emergencies.
designated as STAs.            thereafter Once per year not to exceed 18 months between training sessions Rev. No. 35                                                                                   Page    8-14

FIGURE 8.1 EMERGENCY RESPONSE TRAINING (continued)
TITLE/FUNCTION      ASSIGNED PERSONNEL             FREQUENCY              TRAINING OBJECTIVE Severe Accident      Designated Staff              Before         The objective of SAM training shall be Management                                         assuming       to ensure the capabilities for Training                                           position       coordination, and assumption of responsibilities of actions associated Once every     with Severe Accident Operations two years      Guidelines.
thereafter training or drill Emergency Plan       Non-Licensed                  Before         The objective of Emergency Plan Training for Non-    Operators                     assuming       training for Non-Licensed Operators Licensed                                           position       shall be to ensure the capability for Operators                                                         immediate response by conducting Annually       measures to prevent or mitigate thereafter     accident conditions.
Emergency            Designated Primary            Before         The objective of training for Communications       and Alternates:               assuming       emergency communicators shall be to position       develop and maintain a group of
: a. ENS Communicator                          Emergency Communicators qualified to
: b. Offsite                    Annually       operate emergency communication Communicators             thereafter     systems and effectively transmit (EOF)                                    emergency information and data to the
: c. EOF Communicators                         applicable personnel and/or agencies.
Once per year not to exceed 18 months between training sessions Rev. No. 35                                                                                     Page   8-15

FIGURE 8.1 EMERGENCY RESPONSE TRAINING (continued)
TITLE/FUNCTION  ASSIGNED PERSONNEL        FREQUENCY                  TRAINING OBJECTIVE Radiological     Designated Primary       Before         The objective of training for Assessment       and Alternates:          assuming       radiological assessment personnel shall position       be to develop and maintain a group of
: a. Radiological                         personnel qualified to assess real or Assessment           Annually       potential radiological hazards during Coordinator (EOF)    thereafter     emergencies in order to provide the
: b. Offsite Team                         Emergency Director with the necessary Coordinator (EOF)                   information and advice to make offsite
: c. Dose Assessor                        protective action recommendations and (EOF)                               mitigate radiological consequences.
: d. Dose Assessor Support (EOF)
Radiological     Designated Primary       Before         The objective of training for Controls and     and Alternates:          assuming       radiological controls personnel shall be Surveys during                            position       to develop and maintain a group of Emergencies      a) In-Plant                             personnel qualified to measure real or Radiological          Annually       assess potential radiological conditions Controls and          thereafter     during emergencies in order to provide Downwind Survey                      radiological assessment personnel with Teams                                the necessary information to assess or b) RP Technicians                       project radiological hazards both on and c) Chemistry                            offsite.
Technicians d) Radiation                             Once per year not to exceed 18 Protection /                          months between training sessions Chemistry Coordinator e) Offsite Monitoring Team Emergency Access Control,         Designated Primary       Before         The objective of training in Emergency Evacuation and   and Alternates           assuming       Access Control/ Evacuation and Accountability                            position       Accountability is to develop and Rev. No. 35                                                                              Page  8-16

FIGURE 8.1 EMERGENCY RESPONSE TRAINING (continued)
TITLE/FUNCTION   ASSIGNED PERSONNEL      FREQUENCY                 TRAINING OBJECTIVE
: a. Plant Security                     maintain the station security force's Force               Annually       ability to maintain personnel
: b. Security            thereafter     accountability, and ensure effective Coordinator                        coordination of personnel movements,
: c. Security Shift                     onsite, and during an emergency.
Supervisor
: d. Nuclear Security Guards.
Search and        Plant Fire Brigade     Before         The objective of training fire brigade Rescue/First Aid  members.               assuming       members in Search and Rescue/First Aid Response                                 position       Response is to assure that prompt medical attention is provided to Annually       contaminated, injured or ill personnel thereafter     and to provide effective search and rescue capabilities for missing, trapped or injured personnel in an emergency situation.
Emergency Repair/ Designated Primary      Before         The objective of Emergency Repair/
Corrective        and Alternates:         assuming       Corrective Action is to develop and Actions Training                          position       maintain a group of personnel capable of
: a. TSC Maintenance                     assessing and performing emergency repair Coord.               Annually       or corrective action operations in-plant
: b. OSC Manager          thereafter     in an emergency situation.
: c. Mechanics
: d. Electricians
: e. Instrument and Control                             Once per year not to exceed 18 Technicians                         months between training sessions
: f. Electrical/I & C Coordinator
: g. Mechanical Coordinator Onsite            a. Fire Brigade         Annually       Develop well-trained fire brigade whose Rev. No. 35                                                                             Page 8-17

FIGURE 8.1 EMERGENCY RESPONSE TRAINING (continued)
TITLE/FUNCTION  ASSIGNED PERSONNEL       FREQUENCY               TRAINING OBJECTIVE Fire Fighting       members and                          actions minimize injuries, property loss Personnel           Supervisors as                       and damage and lost generation time.
specified in the Fire Protection Procedures Manual Medical Support  a. Oswego Hospital      Annually       Ensure a high state of emergency Personnel           Personnel                           preparedness and medical awareness of handling of contaminated injuries that
: b. Ambulance Drivers                   may occur at a nuclear facility.
and Attendants
: c. University Hospital Personnel Offsite Fire     Designated personnel    Annually       The objective of training for fire Fighting         from those fire                        fighting personnel is to ensure that Personnel        agencies which will                    offsite individuals who may be called most likely respond                    upon in an emergency to access the JAFNPP to a request for aid                   will be knowledgeable in applicable through Oswego                         procedures and intended roles.
County E-911.
Rev. No. 35                                                                            Page   8-18}}