RS-12-011, Request for Exemption from 10 CFR 50 Appendix R, Section Iii.L

Request for Exemption from 10 CFR 50 Appendix R, Section Iii.L

ML12045A426
Person / Time
Site:	Dresden
Issue date:	02/13/2012
From:	Gullott D Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-11-008, RS-12-011
Download: ML12045A426 (12)

Text

Exelon Generation Exelon Generation Company, Company,LLCLLC www.exeloncorp.com www.exeloncorp.com 4300 Winfield 4300 Winfield Road Road Nuclear Nuclear Warrenville, IL 60555 Warrenville, IL 60555 10 10 CFRCFR 50.12 50.12 10 CFR 10 CFR 50, Appendix R Appendix RS-12-011 RS-12-011 February 13,2012 February 13, 2012 u.s.

U.S. Nuclear Regulatory Commission ATTN: Document Document Control Control Desk Washington, Washington, DC DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Facility Operating License No. No. DPR-19 DPR-1 9 and and DPR-25 DPR-25 NRC Docket Nos. Nos. 50-237 50- 237 and and 50-249

Subject:

Request for for Exemption Exemption from from 1010 CFR CFR 50, Appendix Appendix R, SectionSection III.L III.L

Reference:

Letterfrom Letter fromSteven Steven A.A. Reynolds (NRC) to Michael Michael J. J. Pacilio (Exelon Generation Generation Company, LLC),LLC), "Dresden Nuclear Power PowerStation Station Triennial Triennial FireFire Protection Protection Inspection Report Inspection Report 05000237/2011 05000237 /2011008(DRS); 05000249/2011008(DRS)"

008(DRS); 05000249/2011 008(DRS)"

In accordance In accordance with with 10 CFR 50.12, 50.12, "Specific "Specific exemptions,"

exemptions,* Exelon Exelon Generation Generation Company, Company,LLC LLC (EGC)

(EGC) is requesting a permanent permanent exemption exemption from from the requirements requirements in in 10 10 CFR CFR 50 50Appendix AppendixR, R, "Fire Protection Program "Fire Protection Program forfor Nuclear Nuclear Facilities Operating Prior Prior to January 1, 1,1979,"

1979,"Section SectionIII.L tll.L "Alternative "Alternative and anddedicated dedicated shutdown capability," paragraph 4, for capability," paragraph for Dresden Dresden Nuclear NuclearPower Power Station Station (DNPS) Units 2 and 3. The Therequested requestedexemption exemptionwould wouldeliminate eliminatethe therequirement requirementfor for the on- shift High on-shift High Voltage Voltage Operator Operator (HVO),

(HVO),aamembermember of ofthe the Safe Safe Shutdown (SSD) (SSD)staff, staff,to to remain remain "on"on sitesite at all times" times" and and would would allow the HVO to conduct conduct normal normal shift shift duties, duties,including including those at remote Owner Controlled Areas those at remote Owner Controlled Areas (OCAs), while fulfilling fulfilling aa required requiredposition position on on the the SSDSSD staff. InIn addition, addition, the the exemption exemptionwouldwouldeliminate eliminatethetherequirement requirementto toremain remain"on"onsite siteatatallalltimes" times" for one on-shift Operations Supervisor,Supervisor, also alsoaamember memberof ofthe theSSDSSDstaff, staff,and andallow allowthatthatindividual individual to perform perform the the duties of a Safety/First-Safety/First-aid aid Monitor during switching Monitor during switching operations operations occurring occurring at at aa remote OCA, i.e., the 345kV 345kV switchyard switchyard or or lake lake lift liftstation.

station. This This exemption exemption is being requestedrequested in in accordance accordance with with the requirements requirements of 10 10 CFR CFR 50.12(a)(2)(ii) 50.12(a)(2)(ii) since sincethetheapplication application of ofthe the regulation regulation in in this this particular particularcircumstance circumstanceisis not not necessary necessary to to achieve achievethe theunderlying underlyingpurposepurposeofof the rule.

the rule.

As As described describedin in the thereferenced referencedletter, letter,DNPS DNPStakestakescredit creditforforthe theHVO HVOto toperform perform SSD SSDactions actionsfor for several several SSDSSDprocedures.

procedures. The TheHVOHVO has has been beenresponsible responsiblefor for performing performing thesethese SSD-SSD-related related activities activities since the subject procedures were developed in in the late 1980s.

1980s.ItItwas wasobserved observedthat that the the HVO HVO performs operator rounds rounds (i.e., log taking) at remote locations,locations, such suchas asthethelake lakeliftlift station station and Goose GooseLake Lakepumping pumping station, station, which which areare outside outsidethe theprotected protectedarea area(i.e.,

(i.e.,the the security security fence). Since Since these locations are in OCAs, compliance with 10 CFR 50 AppendixR,R, these locations are in OCAs, compliance with 10 CFR 50 Appendix Section Section III.L.4 III.L.4 waswas considered considered to to be besatisfied; satisfied;however, however,the theHVO HVOhas hastotobriefly brieflyleave leavethe theOCAOCA and and travel travel on aa public public road in order to in order to get get to to and and from fromthe thesubject subject locations.

locations. Subsequently, Subsequently,as as

February 13, February 13, 2012 2012 U.S. Nuclear Nuclear Regulatory Commission Regulatory Commission Page 2 noted inin the the referenced letter, the NRC concluded that that use useof ofthe thepublic public road road constituted constituted aa failure to failure to ensure ensure that all operators, operators, required required forfor SSDSSDactivities, activities,remained remained"on "onsite"site" at at all all times.

times.

This is contrary contrary to to the requirements of 10 10 CFR CFR 50 50Appendix Appendix R, R, Section II I. LA, and SectionIII.L.4, and aaGreen Green Findingwas Finding was issued issued to DNPS.

It has been been demonstrated demonstrated that, that, in in the the event eventthetheHVO HVO is is located located at at the the most mostdistant distant remote remote OCA OCA location at location at the the onset onset of of aa fire, fire, the HVO HVO is able to to return return to to the the protected protected area and complete complete the the required SSD required SSD activities within within thethe required required timeframe.

timeframe. Also, Also, ifif the HVO HVO and an OperationsOperations Supervisor are performing performing switching operationsoperationsin in the the345kV 345kVswitchyard switchyardor orlakelakelift lift station station at at the the onset of a fire, both individuals will be able to return to the protected of a fire, both individuals will be able to return to the protected area and complete area and complete the required SSD required SSD activities activities within within the required required timeframe.

Ifthe If the HVO HVOisis not notallowed allowed to to perform performhis his normal normalshift shiftduties dutieswhile whilebeing being considered considered a member member of of the SSD SSDstaff; staff; and and ifif an an Operations OperationsSupervisor Supervisorisisnot notallowed allowedtotoperform performthe theSafety/First-aid Safety/First-aid Monitorfunction Monitor functionduring duringswitching switchingoperations, operations, two two additional additional operators operators will willneed need to be added added to to each of of the the DNPS DNPS six sixoperating operating crews, crews,forfor aatotal total of of 12 12additional additional operators. Increasing Increasing the the number of of personnel personnel on each each operating operating crewcrewwouldwould represent representan anunwarranted unwarranted burden burden on EGC EGC since these theseadditional additional operators operators are are not not necessary necessarytotomeet meetthetheunderlying underlyingpurposepurposeofofthe therule.

rule.

Therefore, the Therefore, the special special circumstances for issuance of for issuance of the the exemption exemption are are satisfied satisfied in in accordance with the with the requirements requirementsof of1010 CFR CFR 50.12(a)(2)(ii),

50.12(a)(2)(ii), since since application application of of the the rule rule isis not not necessary necessary to achieve thethe underlying underlying purpose of the rule. rule. In In addition, addition, the requested exemption exemption is is authorized authorized and is consistent by law and consistent with with the common defense defenseand andsecurity; security; therefore, therefore, the the requirements requirements of 10 CFR 50.12(a)(1) 50.12(a)(1) are aresatisfied.

satisfied.Attachment Attachment1 1provides providesadditional additionaldetail detailand andjustification justification for for the requested exemption.

exemption.

EGC requests approval EGC approval of this exemption request request by by February February 14, 14, 2013.

2013.

There are no no regulatory regulatory commitments commitments contained containedin in this this letter.

letter.

Should youyou have any any questions questionsconcerning concerningthis thisletter, letter, please pleasecontact contactMr. Mr. Joseph JosephA. A.Bauer Bauerat at (630) 657-2804.

Respectfully, T2f/$p 4 David M.M. Gullott Manager -- Licensing Licensing Exelon Generation Company, LLC Attachment 1: RequestRequestfor for Exemption Exemption Request Requestfrom from10 10CFRCFR50 50Appendix AppendixR,R,Section SectionIII.L III.L "Alternative "Alternative and and dedicated dedicated shutdown shutdowncapability" capability" cc: NRC NRC Regional Regional Administrator, Administrator, RegionRegion III III NRC Senior Resident Inspector Dresden Nuclear NRC Senior Resident Inspector - Dresden NuclearPowerPowerStation Station

ATTACHMENT 11 ATTACHMENT Request for Exemption Request Request from from 10 10CFR CFR50 50Appendix AppendixR,R,Section Section1111 m.l "Alternative II Alternative and and dedicated shutdown capability" I.1. SPECIFIC EXEMPTION REQUEST In accordance In accordance with with 10 CFR 50.12, 50.12, "Specific "Specific exemptions," Exelon Exelon Generation GenerationCompany, Company,LLC LLC (EGC) is (EGC) is requesting a permanent permanent exemption exemption from from thethe requirements requirementsinin 10 10CFR CFR50 50Appendix AppendixR, R, "Fire Protection "Fire Protection Program for Nuclear Facilities Facilities Operating Operating Prior to to January January 1, 1, 1979,"

1979," Section SectionIII.L III.L "Alternativeand "Alternative anddedicated dedicated shutdown shutdown capability,"

capability,"paragraph paragraph 4, 4, for for Dresden Dresden Nuclear Power Station (DNPS)

Station (DNPS) UnitsUnits22and and 3. 3. The requested requestedexemption exemptionwould would eliminate eliminate the requirement requirement for for the on-shift High VoltageVoltage Operator (HVO), (HVO), aa member member of the Safe Safe Shutdown Shutdown (SSD) (SSD)staff, staff,toto remain "on site at at all all times" and and would would allow allow the HVOHVO to conduct conduct normal normal shift shift duties, duties,including including those at those at remote remoteOwner OwnerControlled Controlled AreasAreas(OCAs),

(OCAs), whilewhile fulfilling fulfilling aa required required position position on on the SSD staff. In staff. In addition, the exemption exemption would would eliminate the requirement to remain "on "on site at at all all times" for one on-shift Operations for Operations Supervisor, also aa member memberof of the theSSDSSDstaff, staff,and andallow allowthat thatindividual individual to perform the duties duties ofof aa Safety/First-aid Safety/First-aid Monitor during switching Monitor during switching operations operations occurring at at aa remote OCA. OCA. This exemption is being requested requested in in accordance accordancewith with the the requirements requirementsof of1010 50.12(a)(2)(ii) since CFR 50.12(a)(2)(ii) since the application of the regulation in this particular circumstance circumstance isis not not necessary to achieve the underlying purpose necessary to achieve the underlying purpose of the rule. of the rule.

Background

10 CFR 50 Appendix Appendix R, R, Section Section IIIII.L.4 I.L.4 states thethe following:

following:

the capability to "If the to achieve achieve and and maintain maintain cold shutdown will not be available because of of fire damage, the equipment and systems comprising the means to achieve achieve and and maintain maintain the hot standby or hot shutdown condition shall be capable of of maintaining such conditions until cold shutdown shutdown can can be be achieved.

achieved. IfIf such equipment equipment and and systems will not not be capable of of being powered by both onsite and and offsite offsite electric powerpower systems systems because because damage, an independent onsite of fire damage, onsite power power system system shall shallbe beprovided.

provided. The number of of personnel, exclusive of fire brigade members, required to operate such operating shift personnel, equipment and systems shall be on site at all times." times. 11 As described described in in Reference Reference 1, 1,DNPS DNPS takestakescredit creditforfor the theHVO HVO (i.e.,

(i.e., aa non-licensed non-licensedoperator) operator)to to perform perform SSD SSD actions actions forforseveral several SSD SSD procedures.

procedures. The The HVO HVO has been been responsible responsible for for performing performing thesethese SSD-related activities since the activities since the subject procedures procedures were were developed developedin in the thelate late 1980s. ItIt was wasobserved observedthat thatthetheHVOHVO performs performs operator operator rounds rounds (i.e.,

(Le., log log taking) taking) at remote remote locations, such as as the the lake lake lift station and Goose lift station Goose Lake Lake pumping station, which which are outside the the protected area (i.e.,

area (Le., the security fence). Since these locations are part of the fence). Since these locations are part of the OCA, compliance OCA, compliance with with 10 CFR 50 Appendix R, R,Section III.L.4 was considered III.L.4 was considered to be be satisfied; satisfied; however, however, the theHVOHVO has has toto briefly briefly leave the OCA OCA and and travel travel onon a public road in in order to to get to and from the noted noted locations. Subsequently, as as noted noted in in Reference Reference1,1,the theNRC NRCconcluded concludedthat thatuseuseofofaapublic publicroadroad constituted a failure ensure that failure to ensure that all all operators, operators, required required forfor SSD SSD activities, activities, remained remained on-site on-siteatat all time. This all time. This is is contrary contrary to the requirements requirements of of 10 10 CFR CFR 50 50 Appendix Appendix R, R, Section Section III.L.4, III.L.4, and aa Green Finding Finding was issuedissued to to DNPS.

DNPS.

Page 1 of 10 10

ATTACHMENT ATTACHMENT 11 Request for for Exemption Request from Exemption Request from 10 CFR 50 Appendix AppendixR,R,Section Section lII.l 111.1

""Alternative Alternative and and dedicated shutdowncapability" dedicated shutdown capability" II. BASIS FOR EXEMPTION REQUEST REQUEST In accordance with In accordance with 1010 CFR 50.12, the NRC may grant exemptions CFR 50.12, exemptions from from the requirements requirements of of 10 CFR 50, which are:

"(1) Authorized Authorized by by law, will will not not present present an an undue undue risk risk toto public public health healthor orsafety, safety, and andare are consistent with the common defense and and security."

security."

Further, 10 CFR 50.12(2) notes Further, notes that:

that: `The

The Commission Commission will will not consider consider granting granting an an exemption exemption unless special circumstances are are present."

present." Paragraph Paragraph(ii) (ii)specifies specifiesone oneof of those thosespecial special circumstances:

"(ii) Application of of the the regulation in the the particular particular circumstances circumstances would would not notserve serve thethe underlying purpose of of the rule or is not not necessary necessary to to achieve achieve the the underlying underlying purpose purpose of of the rule;"

On Site Definition 10 CFR 50 Appendix R, Section III.L.4 uses the term "on site" as noted above; however, however, "on "on specifically defined site" is not specifically defined inin the the CFR.

CFR. For For the the purposes purposes of of the following following discussion, discussion, DNPS DNPS considers "on "on site" site" as as used used inin Appendix Appendix R R to to be be equivalent equivalent to to OCAs.

OCAs. NoteNote that that the DNPS DNPS OCA DCA extends beyond the protected area (i.e., (Le., outside the security security fence).

fence).

The intent of restricting operators, dedicated restricting operators, dedicated to SSD SSDactivities, activities,to toan an"on"on site" site" location location isis to to ensure they ensure they are are readily readily available to perform perform their theirassigned assigned SSD SSDduties dutiesininthe thetimeframe timeframe required required the associated analysis by the analysis of of record (AOR). As discussed record (AOR). discussedbelow, below,itit has hasbeen beendemonstrated demonstratedthat that an operator, operator, located anywhere in in the subject remote OCAs, is able to subject remote to return return to the station and perform his/her perform his/her assigned assigned SSD SSDduties dutieswithin withinthetherequired required timeframe.

timeframe.

HVO Safe Shutdown Duties Dresden Safe Shutdown Shutdown Procedures (i.e., (Le., DSSP DSSP series seriesofofprocedures) procedures) addresses addressesactivities activities associated with associated with safe safe shutdown shutdown of of the plant followingaa severe plant following severe fire.

fire. These Theseprocedures procedureswere were initiallydeveloped initially developed in in the the late 1980s timeframe. The HVO 1980s timeframe. HVO has activities specified specified in in the the following following procedures:

DSSP 01 0100-A1, OO-A 1, "Hot Shutdown Procedure - Path Al," A 1,"Revision Revision31 31 DSSP 01 0100-B1, 00-B1, "Hot Shutdown Procedure - Path B1," Revision 32 DSSP 0100-CR, "Hot Shutdown Procedure - Control Room Evacuation," Evacuation," Revision Revision 42 DSSP 0100-B, "Hot Shutdown Procedure - Path Path B,"

B," Revision Revision 22 22 DSSP 01 0100-B1, 00-B1 , "Hot Shutdown Procedure - Path Path B1,"

B1," Revision Revision 32 32 DSSP 0100-C, "Hot Shutdown Procedure - Path Path C,"

C," Revision Revision 22 22 DSSP 0100-CR, "Hot Shutdown Procedure - Control Control Room Room Evacuation,"

Evacuation,"Revision Revision 42 42 0100-D, "Hot Shutdown Procedure - Path DSSP 0100-0, Path D,"

0," Revision Revision 22 22 DSSP 0100-E, "Hot Shutdown Procedure - Path Path E,"

E," Revision Revision 30 30 DSSP 0100-F, "Hot Shutdown Procedure - Path Path F,"

F," Revision Revision 28 28 Page 2 of 10

ATTACHMENT 11 ATTACHMENT Request for Exemption Request from 10 CFR 50 Appendix R, R,Section III.L lII.l "Alternative and dedicated shutdown shutdown capability" capability" Section F, "Limitations "Limitations and and Actions,"

Actions,"ofofeach each of ofthese these procedures, in part, states: states:

"DSSPs define actions to be performed by specific individuals. individuals. Time Time critical criticalactions actions need to be completed within the assumed time. time. Operations Operations personnelpersonnel outside outside the protected area (i.e., switchyard, lift lift station, etc.)

etc.) will will be recalled recalled to to assist assist inin the the safe safe shutdown efforts.

efforts. In In the the event eventthatthatperson person assigned assigned to to perform perform an an action action is NOT NOT available OR is performing performing other other tasks, tasks, anyany qualified qualified individual individual can perform the the required required actions, as determined determined by by the the Shift Shift Manager."

Manager."

It should be notednoted that that all all operators operators dedicated dedicatedto to SSD SSDactivities activities are are trained trained andand qualified qualified to to perform all perform all non-licensed non-licensed operator operator SSD SSD related activities and; therefore, activities and; therefore, are are interchangeable.

As noted in in Reference Reference1,1,Attachment AttachmentD, 0,"HVO "HVO Actions,"

Actions," of of DSSP DSSP 01 0100-A1 OO-A1 and DSSP DSSP 0100-B1 0100-81 directs the the HVOHVO to perform a number number of of activities, activities, one one ofof which which is to remove power power and andde- de-energize aa spuriously spuriously openopen safety safety relief relief valve. This This isis aatime time critical critical action assumedassumed to to occur occur within within 1010 minutes as as defined defined in in the the Appendix Appendix R R hydraulic hydraulic AOR. In In the theevent eventthatthatthetheHVOHVOisis performing rounds performing rounds in in a remote OCA, OCA, another available operator operator within within the protected area area would would perform this perform this action action asas allowed allowed by by the the procedural procedural limitations limitationsand andactions actions notednoted above.

above. The The shift shift staffing levels discussed staffing discussed belowbeloware areofofsufficient sufficient number numberto tocomplete completethis thistime timecritical critical action action regardless ofofHVO regardless availability. With HVO availability. With thethe exception of of DSSP-0100-CR DSSP-0100-CR as as discussed discussedbelow, below,shift shift staffing levels are of sufficient staffing sufficient number to complete all SSD-related SSD-related time time critical critical actions regardless of regardless of HVO HVO availability availability for forallallDSSPs DSSPs noted above.

Reference 1 also also discusses discussesHVO HVOactivities activities directed directed by DSSP-0100-CR. DSSP-0100-CR DSSP-0100-CR describes SSD describes SSDactivities activities required required in in the the event eventof of aaControl Control RoomRoom (CR) (CR) evacuation evacuation due dueto toaafire fire in the CR or in or Auxiliary Electrical Equipment Room (AEER);

AUXiliary Electrical (AEER); and and isis the themost mostlimiting limiting DSSP DSSPwith with regard to resources; i.e., i.e., all all SSD-dedicated operators are needed needed to to complete complete the the SSD-required SSD-required actions. The Thehydraulic hydrauliCAOR AOR requires requiresthat thatthe thetime timecritical critical actions actions assigned assignedtotothe theHVO HVObe be completed withinwithin 3232 minutes. As As acknowledged acknowledgedin in Reference Reference1,1,aatime timevalidation validationof of DSSP DSSP 0100-CR was completed in January January 2006. 2006. AllAll required required actions actions in in this procedure were were completed in in 25 25 minutes minutes assuming assuming all all necessary operators were were readily available. Attachment readily available. Attachment H, "HVO H, "HVOActions,"

Actions,"ofofDSSPDSSP0100-CR0100-CR directsdirects the the HVO HVO to to perform perform aa number of activities, one one ofof which is to locally locally start the 2A (3A) Control Rod (3A) Control Rod Drive Drive (CRD)

(CRD)pump. pump. The The noted notedtime timevalidation validation indicated that this time time critical criticalaction action could couldbe be completed completed in in 14 14 minutes.

minutes. For For this this case, case,the theHVOHVO is relied on to relied on to complete complete thisthis action action as as the shift staffing staffing levels levelsdiscussed discussed below below are are not such that an extra extra operator operatorwouldwould be beavailable availableto toperform performthis thisfunction function in in lieu lieu of the HVO. HVO. In In the theevent event that DSSP DSSP 0100-CR 0100-CR isisinitiated initiated while while thethe HVO HVO is performing performing rounds at at aa remote remoteOCA, OCA, the theHVOHVO would would be immediately notifiedand immediately notified and directed directed to to return return to to the the protected protected area area and and perform perform the the required HVO SSD duties. duties.

The HVOHVO conducts operator rounds rounds and and takes takeslogslogsininvarious variousplant plantlocations, locations,including including aa number of of "remote "remoteOCAs"OCAs"that thatareareoutside outsidethe theprotected protectedarea. area. Rounds at remote OCAs are conducted every shift (i.e., (i.e., three three shifts/day shifts/day on on weekdays; weekdays; two two shifts/day shifts/dayon onweekends) weekends) and and are accessed by accessed bydriving driving aa company company vehicle vehicle to the location.

location. The Thetotal total time time thethe HVO spends HVO spends performing rounds in the remote OCAs performing OCAs varies varies from from approximately approximately one-two hours hours per pershift.

shift.

These remote These remoteOCAs OCAsinclude includethe the345kV 345kVelectrical electrical switchyard, switchyard, lake lakeliftlift station, Goose GooseLake Lake pumping station and hot and and coldcold cooling cooling towers. The TheHVO HVO may may also alsoneedneedtotoperform performswitching switching Page 3 of 10 10

ATTACHMENT ATTACHMENT 11 Request for Exemption Request from 10 CFR 50 Appendix R, R, Section Section III.Lm.l "Alternative and dedicated shutdown shutdown capability" capability" operations in operations in the the 345kV 345kV electrical electrical switchyard switchyard and and lake lakeliftlift station. The Themostmostlimiting limitinglocation, location, from a travel from travel time time standpoint, standpoint, is the Goose Goose Lake Lake pumping pumping station station which which is is approximately approximately miles from 1.5 miles fromthe theplant plantentrance.

entrance. It has recently (Le., (i.e., February February 2012) 2012) beenbeen demonstrated demonstrated that the HVO, performing duties HVO, when performing duties at the GooseGoose Lake Lake pumping pumping station,station, can canbe benotified notifiedusing usingthethe normal radio communication system, radio communication system, and and return return to to the the protected protectedarea areawithin within 15 15minutes minutestoto perform the perform the required required SSD-related activities. Note Note thatthatthetheHVOHVO maintains maintains radio radio contact contact capability withwith thethe control control room room at all times.

Adding the Adding the 15 minute travel travel time time back back to to the the plant to the 14 minutes to complete complete the the HVO HVO time time--

critical task critical task described described above, indicatesindicates thatthat this this task taskcancanbe becompleted completedinin29 29minutes; minutes;i.e.,Le.,within within the acceptable acceptabletime timeof of 32 32minutes minutesnoted notedininthe theAppendix AppendixRRhydraulic hydraulicAOR. AOR.

HVO Travel Time and Station Access Impediments Unforeseen issues issuesaffecting affecting the the ability ability of the HVO HVO to to return return to to the the protected area area to to perform perform the the required SSD required SSD functions functionshave havealso alsobeen been assessed.

assessed.

As noted in Reference 1, one one instance instance (documented (documentedby byAR AR 01258591, 01258591, `Truck Truck Stranded Stranded Operator During Rounds") was During Rounds") was identified identified whenwhen an an operator performing performing duties outside of the protected areaarea was was delayed delayed forfor approximately approximately 40 minutes due due to to vehicle vehicle related related issues.

issues.

Unforeseen equipment problems equipment problems affecting affecting travel time back to the protected protected area wouldbe area would be similar to similar to an an unforeseen unforeseen personal personalinjury injuryor orillness illnessthatthatwould would incapacitate incapacitatean anindividual individualduring duringan an event requiring requiring aa SSD-related action action by thatthat individual.

individual. These These types of of issues issuesare areofoflow low probabilityand probability and areare not specifically specificallyaddressed addressed in in a staffing staffing plan. However, However, environmental environmental conditions, such as severe conditions, severeweather, weather,that thatmay mayimpact impacttravel travel times, times, willwill be considered. InInthe the case of case of severe severeweather weatherwhere wheretravel travel times timesmay maybe beunacceptably unacceptablyimpacted, impacted,discretion discretionwill will be be used for used for conducting HVO HVO rounds in remote OCAs OCAs consistent consistentwith with procedures OP-AA-108-111--

proceduresOP-AA-108-111 1001, "Severe Weather Weather and andNatural NaturalDisaster DisasterGuidelines,"

Guidelines,"and andOP-AA-1 OP-AA-102-102,02-102, "General "General Area Area Checks and OperatorOperator Field Field Rounds."

In the In the event aa lossloss of of off-site off-site power would occur while the HVO HVO is is outside the protected protected area,area, access to access to the the protected protected area areathrough through normal normal gatehouse gatehousesecurity securityturnstiles turnstiles wouldwould not be impacted as there is aa backup backup powerpower supply to security security equipment.

equipment. In In the event that the security turnstiles are non-functional non-functional for for some some unforeseen unforeseen issue, issue,the theSecurity Securitypersonnel personnelwould would allow the allow the HVO HVOaccess access to the protected protected area areathrough throughkey-locked key-locked doors. doors.

Operations Supervisor Supervisor Electrical Electrical Switching Switching Safety/First-Aid Safety/First-Aid Monitor Monitor Duties During switching During switching operations, operations, the HVO HVO is is procedurally procedurally requiredrequired to be accompanied accompaniedby byaa Safety/First-aid qualified individual. This ThisSafety/First-aid Safety/First-aidMonitor Monitorrole roleisisfulfilled fulfilled byby an an on-shift on-shift Operation Supervisor. IfIf switching switching operations operations are areperformed performed at ataaremote remoteOCA OCA(i.e.,

(Le.,thethe345kV 345kV electrical switchyard electrical switchyard or or lake lift liftstation),

station),the the Operations Operations Supervisor would need need to to accompany accompany the HVO HVO to to these remote remote OCAs;OCAs; thus, thus, the theexemption exemptionfrom fromAppendix AppendixRRSection SectionIII.L.4 III.LA isis also also requested for requested for aa single single Operations Operations Supervisor Supervisorduring during remote remoteOCA OCA switching switching operations.

operations.

Planned switching operations occur approximately two times per week and two times and take take approximately approximately two hours for each each operation. Typically, Typically, no no switching switching operations operations are are conducted conductedduring duringthe the summer months (i.e., (Le., June, July July andand August)

August) exceptexcept for emergent emergent events. events.

Page 4 of 10

ATTACHMENT ATTACHMENT11 Request for Exemption Request from 10 10 CFR 50 AppendixAppendix R, R, Section.III.L Section.III.L "Alternative and dedicated shutdown shutdown capability" capability" Only one of the DSSPs; Only DSSPs; i.e., Le., DSSP DSSP0100-CR, 0100-CR,"Hot "Hot Shutdown Shutdown Procedure Procedure- -ControlControlRoomRoom Evacuation," Revision Evacuation," Revision 42, 42, specifies SSD-related SSD-related duties duties forfor all all on-shift Operations Supervisors.

Supervisors.

As noted above, it has been been demonstrated demonstratedthat thatthe theHVOHVO is is able able to to return return to the protected area area in 15 minutes from in from the most distancedistance remote remoteOCA, OCA, (i.e.,

(Le., the the Goose GooseLakeLakepumping pumpingstation).

station).

Therefore, if if an Operation Supervisor Supervisorwas wasperforming performingswitching switchingoperations operationsininthe the345345kV kV switchyard or lake lift switchyard liftstation stationat at the the onset onset of a fire, fire, the the supervisor could also return return to thethe protected areaareawithin within 15 minutes minutes or or less lessand andwould wouldbe beable abletotocomplete completethe thetimetimecritical critical activities defined in DSSP-0100-CR DSSP-0100-CR required required by bythe theAppendix AppendixRRhydraulichydrauliC AOR. AOR.

The "HVO The "HVO Travel Time and Station Access AccessImpediments" Impediments" discussion discussion above, above,addressing addressinginjuryinjuryoror illness, severe severeweather, weather, and and loss lossofofoff-site off-sitepower, power,isisalso alsoapplicable applicabletotothe theOperations Operations Supervisor.

Operating Shift Staffing Requirements The operating shift staffingstaffing requirements requirements are specified in in Dresden Operating Procedure, OP-DR-101-111-1001, OP-DR-1 01-111-1 001, "On-Shift Staffing Requirements."

"On-Shift Staffing Requirements." The Thenumber numberof ofoperations operationsindividuals individuals noted in in Attachment A of of OP-DR-1 OP-DR-101-111-1001 01-111-1 001 meets meets the thefollowing following staffing staffing requirements:

10 CFR 50.54(m)(2)(i) for licensed licensed operators operators 10 CFR 50 Appendix R, Section H for Fire Brigade; and 10 CFR 50 Appendix R, Section L for Safe Shutdown The requirements requirements for for Fire Fire Brigade and and SSD SSD staffing staffing exceeds exceedsthe thestaffing staffingrequirements requirementsfor for licensed operators operators under under10 10CFR CFR50.54(m);

50.54(m);therefore, therefore,this thisdiscussion discussionwill will focus focus on on the the requirements for the Fire Brigade and SSD SSD staff.

staff.

As specified in OP-DR-101-111-1001 Attachment A, "Staffing Requirements Requirements with either either Unit Unit in in Mode 1, 1, 2, 3," the "SSD Staffing" consists consists of of the the following following operations operationsindividuals:

individuals:

Position Safe Shutdown (SSD) Staffin Staffing g Shift Manager Shift 1 1

Unit Supervisor 2 WEC [Work Execution Center] Supervisor 1 1

Field Supervisor 1 1

NSO [Nuclear Station Operator] Operator] 4 STA 1 1

Equipment Operator (EO) 7 It should be noted that that the the Shift Shift Manager also also serves servesas asthetheSite SiteEmergency EmergencyDirector Directorand andisisnot not a member member of of either either thethe Fire Fire Brigade Brigade or or SSD SSD staff.

staff. The TheSTA STAposition position isisfilled filled as as aaconcurrent concurrent responsibility of responsibility ofone one of ofthe thenoted noted Operations Operations Supervisors Supervisors and is not a separate separate individual.

individual. Also, Also, the Field Field Supervisor positionposition is not required to be be staffed staffed to to meet meetthetheFire Fire Brigade Brigade or or SSD SSD staffing requirements. DNPS staffing DNPSelectively electively staffs staffs this this position position for for additional operational support and additional operational as aa contingency contingency for for unforeseen unforeseen operator operator absences.

absences. Thus, Thus,therethereareare14 14individuals individuals (i.e., three Supervisors, four four NSOs NSOs and and seven EOs) EOs) dedicated to to the Fire Fire Brigade and SSD staff. staff. Note Note that that one of the EOsEOs is is the the HVO.

HVO.

Page 55of10 Page of 10

ATTACHMENT ATTACHMENT 1 1 Request Request for for Exemption Exemption Request Requestfrom from1010CFR CFR50 50Appendix AppendixR,R,Section Section lII.l 111.1 Alternative and "Alternative II anddedicated dedicated shutdown capability" shutdown capability" As stated in As in OP-DR OP-DR-1 - 101-111 01-111-1001,- 1001, Step Step 4.1, 4.1,"Per "Per Technical Technical Requirements RequirementsManual Manual(TRM) (TRM)

Section 5.0, aa site Section site Fire Fire Brigade Brigade of at least least five members members shallshall be be maintained maintained on-site on-site at atall all times.

times.

The Fire Brigade Brigade SHALL SHALL NOT include include thethe personnel necessary necessaryfor for safe safeshutdown shutdownofofthe theunit."

unit."

Fire Brigade The Fire Brigade is is comprised comprised of four four EOs EOs andand one Supervisor.

As stated As stated in OP-DR-101-111-1001, OP-DR-101-111-1001, Step 5.2, "Per "Per 1010 CFR CFR Appendix Appendix R to Part Part 50 50 documentation, the personnelpersonnel assignedassignedtotoperform performSafe SafeShutdown Shutdownduties dutiesSHALLSHALLNOT NOT include include the personnel assigned assignedto toFire Fire Brigade Brigade staffing.

staffing. SSD SSDstaffing staffing consists consistsof oftwo two Supervisors, Supervisors,four four NSOs, and NSOs, and three Equipment Operators." Operators." Therefore, nine individuals individuals are are dedicated dedicated to SSD activities.

five Fire The five Fire Brigade Brigade members members plus plus the the nine SSD staff staff members account account for all all 14 operations positions staffed positions staffed onon an operating operating crew.crew. Thus, Thus, isis cancanbebeseen seenthat thatififthe theHVO HVOisisnot notallowed allowed to to perform his/her normal shift duties in remote OCAs perform his/her normal shift duties in remote OCAs while being considered a while being considered a member of the staff, an SSD staff, an additional additional operator operator wouldwouldneed need to to be be added to each each of of the the DNPS DNPS six six operating operating crews. Further, Further,ifif one one of of the the on-shift on-shift Operations Operations Supervisors Supervisorsisisnot notallowed allowed to toprovide provide the the Safety/First-aid Monitor functionduring Monitor function duringswitching switchingoperations operations at a remote remote OCA, OCA, an anadditional additional supervisor would also need to be added would also added to to each eachof ofthe thesix sixoperating operatingcrews; crews; forfor aatotal total of of 12 12 additional operators.

additional NUREG-1791 Guidance In July In July 2005, 2005, the the NRC NRC published published NUREG-1791, NUREG-1791, "Guidance "Guidance for forAssessing Assessing Exemption Exemption Requests Requests from the Nuclear Power Plant Licensed Operator Staffing Requirements from the Requirements SpecifiedSpecified in in 10 10 CFR CFR 50.54(m)," (Le.,

50.54(m)," (i.e., Reference Reference 2). 2). The The Foreword Foreword of of the the NUREG NUREG states statesthe thefollowing:

following:

'This document "This document provides guidance for the NRC staff staff to systematically systematically review review and and assess assess requests by licensees of nuclear power plants for exemption from the licensed licensed operator operator staffing requirements of Title 10, 10, Part 50 of the Code of of Federal Regulations (10 (10 CFR CFR

50) contained in 10 CFR 50.54(m). 50.54(m). The The purpose of of the NRC's review is to ensure public health andand safety by by verifying that the applicant's applicanfs staffing plan and and supporting supporting analyses analyses sufficiently justify the sufficiently justify the requested requested exemption.

exemption.

The increased use use of advanced automation technologies in existing nuclear power power plants plants and and thethe introduction of of advanced advanced reactor reactor designs will will likely likely change change the the roles, roles, responsibilities, composition, composition, and and size size ofofthe the crews crews required requiredtotocontrol controlplant plantoperations.

operations.

Current regulations regarding control room staffing, staffing, which are based based on the conceptconcept of of operation for existing light-waterlight-water reactors, reactors, may may nono longer longer apply.

apply. Licensees of of nuclear power power plants plants who who have have implemented implemented significant significant changes changes to to existing existing control control rooms rooms or or who have introduced increased use of advanced automation technologies may may submit submit applications for exemption from from thethe requirements.

requirements. Likewise, Likewise, because because of of the the anticipated anticipated changes in operator operator roles and responsibilities in new new reactor reactor designs, deSigns, an applicant applicant for for an an operating license for a new reactor may wish to seek exemption from from the the current current licensed licensed operator operator staffingstaffing requirements."

requirements."

Although Although this guidance was was published published specifically specifically for for exemptions exemptions to to licensed licensedoperator operatorstaffing staffing requirements in in 10 10 CFR 50.54(m)50.54(m) due to advanced automation automation technologies technologies or or advanced advanced reactor designs, deSigns, thethe same samerationale rationalefor for acceptability acceptability can can also also be beapplied appliedto tothe thesubject subject Page 66 of Page of 10 10

ATTACHMENT 1 ATTACHMENT Request Request for for Exemption Request Requestfrom from10 10CFRCFR50 50Appendix AppendixR,R,SectionSection 111.1 III.L "Alternative and "Alternative and dedicated dedicated shutdown capability" exemption request.

exemption request. NUREG-1791 NUREG-1791 Part PartII,II, "Evaluation "Evaluation of Exemption Exemption Requests," lists lists 11 11 review review areas. Section 8, "Review of the Staffing Plan,"

areas. Section 8, "Review of the Staffing Plan," states the following:states the following:

'The purpose "The purpose of the the staffing plan review is to ensure that the applicant applicant has systematically analyzed systematically analyzed the requirements for the numbers of of qualified personnel that are necessary to necessary to operate operate the the plant plant safely under the operational conditions analyzed. That Thatis, is, the staffing the staffing plan plan should should answeranswer the question, question, "How many individuals must be qualified and available and available to to fill fill each eachjob?"job?"

The applicant's The applicant's staffing staffing plan plan should should be be supported by the results of of the functional requirements analysis requirements analysis and function allocation, task analyses, and and the job definitions for each position each position required required under under thethe operational operational conditions conditions considered.

considered. In addition, the applicant's submittal should define the proposed applicant's proposed shift shift composition and and shift shift scheduling.

Shift composition refers to the different types of of jobs that that must must be filled on each shift shift and and the number of personnel the personnel required for each of of the jobs on a shift. InInthe thecase caseof ofremote remote operations or operations that will take place outside of of a traditional traditional control control room, the applicant should also define the locations of of the the personnel comprising aa shift."

personnel comprising shift."

Section 8.3, "Review "Review Criteria,"

Criteria," lists lists aa number of staffing staffing plan review criteria.

criteria. TwoTwo of these these criteria are:

The staffing plan The plan will provide an adequate number number of of qualified qualified personnel personnel to operate the plant plant safely safely under under the the operational operational conditions conditions considered."

considered." and and

'Travel and response times "Travel times areare adequate adequateand anddo donot nottrigger triggeradverse adverseconditions conditions for for the the safety safety of of the plant."

Section 10,10, "Review "Review the Staffing Staffing Plan Plan Validation," states:

Validation," states:

'The "The purpose of of reviewing reviewing the the validation validation of ofthe the staffing staffing plan plan is is to to ensure ensure that that the the applicant applicant fullyfully considered considered the the dynamic dynamic interactions interactions between between the the plant plantdesign, design, itsits systems, and and control control personnel personnel for for thethe operational operational conditions conditions identified identifiedfor for the the exemption exemption request."

Section Section 10.1.1, 10.1.1, "Operational "Operational Conditions Conditions Sampling,"

Sampling," also also states:

states:

'The "The applicant applicant should should include include the the operational operationalconditions conditionsrelevant relevantto tothe theexemption exemption request request in in the the staffing staffing plan plan validation.

validation. As Asaapractical practicalmatter, matter,however, however,ititmay maybe be unnecessary unnecessary to to address address all all of ofthe the possible possible variations variations of ofthese these conditions.

conditions. ItItmay maybe be reasonable reasonable to to combine combine some some of ofthem them intointo scenarios."

scenarios."

Section 10.3.4, Section 10.3.4,"Staffing "Staffing Plan Plan Validation Validation Outcomes,"

Outcomes," lists lists aanumber numberof ofcriteria.

criteria. The Thefirst firstcriterion criterion states:

states:

"The "The results results ofofanalyses analyses demonstrate demonstratethat thatcontrol controlpersonnel, personnel,individually individuallyand andworking workinginin crews, crews, ififapplicable, applicable, can can accomplish accomplishtheir theirtasks taskswithin within performance performancecriteria."

criteria."

Page Page 77of of1010

ATTACHMENT 1 ATTACHMENT Request for Request for Exemption Exemption Request Request from from 1010 CFR CFR 50 50 Appendix Appendix R, R, Section Section lII.l III.L "Alternative and "Alternative and dedicated dedicated shutdown capability" These specific excerpts from These from NUREG-1791 NUREG-1791 and the overall philosophy of the guidance support the subject exemption the exemption request as presented above.

NUREG 1852 Guidance NUREG In October In October 2007, 2007, the NRC also published published NUREG-1852, NUREG-1852, "Demonstrating "Demonstrating the the Feasibility Feasibility andand Reliability of Operator Manual Actions in Response to Fire,"

Reliability of Operator Manual Actions in Response to Fire," (Le., Reference 3) as a (i.e., Reference 3) as a reference for NRC guide for NRC StaffStaffwhowhoevaluate evaluate the the acceptability acceptability of ofmanual manual actions, actions, submitted submitted by licensees licensees as as exemption requests requests fromfrom the the requirements requirementsofofAppendix AppendixR, R,Section SectionIII.G, III.G, "Fire "Fire protection protection of of safe safe shutdown capability,"

shutdown capability,"paragraph paragraph 2. 2. This guidance does does notnot directly directly address addressstaffing staffing levels; levels; however, it does however, does provide provideinsights insightsintointo"feasibility

feasibility and andreliability reliability criteria" criteria" for completing manual manual operator actions, similar similar toto SSD SSD activities, activities,which whicharearegermane germane to to the the subject subject exemption exemption request.

The issue of the HVO being located HVO being located at at aa remote remote DCAOCAatatthe theonset onset of ofan an event event appears appears to be specifically acknowledged specifically acknowledged in Section 3.2.2, "Analysis "Analysis Showing Adequate Adequate Time Time Available Available to Ensure Reliability."

Reliability." ItemItem 22 of of this this section section discusses discusses potential potential demonstration demonstration shortcomings; shortcomings; however, states states thethefollowing:

following:

`The demonstration might "The might be limited limited in its ability ability to to account accountfor for (or (orenvelop) envelop) allallpossible possible fire locations where the actions are needed and for all the different travel paths and fire distances to where the the actions are are toto be be performed.

performed. A similar limitation concern is that the current location and activities of needed plant personnel when the fire starts could delay their participation in executing the operator manual actions (e.g., they may may typically be at a location that is on the opposite side of of the plant relative to a postulated postulated fire location and/or may need to restore certain equipment before being able to participate such as if they are routinely dOing doing maintenance).

maintenance). The The intent intent is not not to address temporary/infrequent situations but to account for those that are typical and may impact impact the timing of of the action."

Again, in Section 3.2.10, "Staffing,"

"Staffing," thethe NUREG NUREG acknowledges acknowledges that some somerequired requiredstaff staff responding to to aa fire fire may be be located located off-site off-site but able to respond respond in in an anacceptable acceptabletimeframe:

timeframe:

Section 3.2.10 states:

`The "The intent of of the staffing staffing criterion criterion is is to to ensure ensure that that anan adequate adequatenumber numberofofqualified qualified personnel personnel will will be be available available so so that that hothot shutdown shutdown conditions conditions can can be be achieved achievedand and maintained maintained in the event of of a fire.

fire. Credited Credited personnel personnel may may be be normally normally onon site, or or available through the the emergency emergency planningplanning staff staff augmentation augmentation system system inin time time toto successfully successfully perform the the desired desired action.

action. Further, Further,individuals individualsthat thatmight mightbe beneeded neededtoto perform perform the the operator operator manual manual actions actions should should not not have have collateral collateral duties, duties, such such asas firefighting, security security duties, duties, or orcontrol controlroom room operation, operation, during duringthe theevolution evolutionofofthe thefire fire scenario. In other words, enough trained people, without collateral duties during afire, scenario. In other words, enough trained people, without collateral duties during a fire, should should be be available available to to ensure ensure thatthat operator operator manual manual actions actions can can be be completed completed as as needed."

needed."

Page Page 88 of of 10 10

ATTACHMENT ATTACHMENT 1 1 Request for Request for Exemption Exemption Request Request from from 10 CFR CFR 50 50 Appendix R,Section III.L lII.l "Alternative and "Alternative and dedicated dedicated shutdown capability" Another reference Another reference thatthat would would appear appear to support the HVO HVO being able to conduct conduct rounds rounds at at remote OCAs remote OCAs is is Section Section 4.2.10, 4.2.10, "Information "InformationRegardingRegarding the the Staffing StaffingCriterion."

Criterion." Section Section 4.2.104.2.10 states:

states:

`Adequate numbers "Adequate numbers of of qualified qualified personnel personnel should be available within the timeframe credited in credited in the the analysis analysis for for performing performing the the various various operator operatormanual manualactions.

actions. Credited personnel may be normally on personnel on site, site, oror available available through through the the emergency emergency planning planning staff staff augmentation system, system, as long as the the necessary necessary timing of the action(s) can be met."

III. ENVIRONMENTAL III. ENVIRONMENTAL ASSESSMENT In accordance In accordance with with 10 CFR 51.30, "Environmental "Environmental assessment," and 51.32, "Finding "Finding of no significant impact,"

significant impact," the the following followinginformation informationisisprovided providedininsupport support of of an an environmental assessment and assessment andfinding finding of of no no significant impact for significant impact forthe theproposed proposed action.

action. The proposed proposed actionaction would result would result in in aa permanent exemption exemption from from the requirements requirements of of 10 10CFRCFR 50 50 Appendix Appendix R, R, "Fire "Fire Protection Program for Nuclear Facilities Operating Prior Protection Prior to January January1, 1, 1979,"

1979,"Section SectionIII.L III.L "Alternativeand "Alternative and dedicated dedicated shutdown capability," paragraph 44 for capability," paragraph for DNPS DNPS Units Units 22 and and3.3.

The proposed proposed exemption exemption will significantlyincrease will not significantly increase the the probability probability or orconsequences consequences of of accidents, no no changes changesare arebeing beingmade madeininthe thetypes typesororquantities quantitiesofofany anyradiological radiologicaleffluents effluents that may be released releasedoffsite, offsite, and and there thereisisno nosignificant significant increase increaseinin occupational occupationalor orpublic public radiation radiation exposure. Therefore, there are no significant radiological Therefore, there are no significant radiological environmental environmental impacts associated with associated with the proposed exemption.exemption. In Inaddition, addition, the the proposed proposedexemption exemption does doesnot notaffect affect non-radiological non-radiological plant plant effluents effluentsand and has has no other environmental environmental impact. impact. Therefore, Therefore, therethere are areno no significant non-radiologicalimpacts significant non-radiological impactsassociated associated with withthe the proposed proposed exemption.

exemption. As As aa result, result, thethe proposed proposed exemption exemption will will not have have aa significant significant effecteffect onon the the quality quality ofof the the human humanenvironment.

environment.

IV. CONCLUSION The proposed proposedexemption exemptionfrom from thetherequirements requirementsofof10 10CFRCFR5050Appendix AppendixR,R,Section Section IIIIII.L.4 will

.L.4 will not result in undue risk to the public risk to public health and safety. The Theintent intentofofAppendix AppendixR, R,Section SectionIII.L.4III.L.4 is to ensure ensure thatthat sufficient operating operating shiftshiftpersonnel personnel are are available available to to operate operate systems systems and and equipment necessary necessary to to achieve achieve hot hot shutdown shutdown in in the event of fire firedamage.

damage. As As discussed discussed

above, above, itit hashasbeen beendemonstrated demonstratedthat, that,ininthe theevent eventthe theHVO HVOisisconducting conductingoperator operatorrounds roundsatat the most most distant distant remote remote OCA OCA location at the onset onset of of aafire, fire, the the HVO will will be be able able toto return return to the the protected area area andandcomplete completethe therequired requiredSSD SSDactivities activitieswithin withinthe therequired requiredtimeframe.

timeframe.InIn

addition, addition, if the HVO HVO and and an Operations Operations Supervisor Supervisorare areperforming performing switching switching operations operationsin in either either the 345kV the 345kV switchyard switchyard or lake lift station at the onset lift station onsetof ofaafire, fire, both both individuals individuals willwill be be able ableto to return return toto the the protected protected area and complete completethe therequired required SSD SSDactivities activitieswithin within the therequired required timeframe.

timeframe.

If the HVO If the HVO is is not not allowed allowed to to perform perform his his normal normal shiftshift duties duties while while being being considered considered aa member memberof of the the SSDSSDstaff; staff; and and ifif an an Operations OperationsSupervisor Supervisorisisnot notallowed allowedto toperform perform the theSafety/First-aid Safety/First-aid Monitor function during Monitor function during switching switchingoperations, operations, two two additional additional operators operators will need to be added will need added to to each each of of the the DNPS DNPS six six operating operating crews,crews, forfor aa total total of 12 additional additional operators. Increasing Increasingthe the number number of of personnel personnel on on each eachoperating operatingcrew crewwould would represent representan anunwarranted unwarrantedburden burdenon onEGCEGC Page Page 99 of of 10 10

ATTACHMENT ATTACHMENT 11 Request for Request for Exemption ExemptionRequest Requestfromfrom1010CFR CFR50 50Appendix AppendixR,R,Section Section 111.1 lII.l "Alternativeand "Alternative and dedicated dedicated shutdown shutdown capability" capability" these additional since these additional operators are are not not necessary necessaryto tomeet meetthetheunderlying underlying purpose purposeof of the the rule rule as as discussed above. Therefore, the special circumstances for issuance of the above. Therefore, the special circumstances for issuance of the exemption are exemption are satisfied in accordance accordance with with the the requirements requirementsof of 10 10CFR CFR 50.12(a)(2)(ii) 50.12(a)(2)(ii) since application application ofof the rule is rule is not not necessary necessary to achieve the underlying underlying purpose of the the rule.

rule. In In addition, the requested addition, the exemption is exemption is authorized authorized by law law and and is consistent with the common with the common defense defense and and security; security; therefore, the requirements requirements of of 10 10 CFR CFR 50.12(a)(1) 50.12(a)(1) are satisfied.

satisfied.

V. REFERENCES

1. Letter

1. Letter from from Steven Steven A.

A. Reynolds (NRC)

(NRC) to Michael Michael J. J. Pacilio (Exelon Generation Company, Pacilio (Exelon LLC),"Dresden LLC), "Dresden Nuclear Nuclear Power Power Station Triennial Triennial Fire Fire Protection Protection Inspection Report 05000237/2011008(DRS); 05000249/2011008(DRS)"

05000249/2011 008(DRS)"

NUREG-1791, "Guidance

2. NUREG-1791, "Guidance forforAssessing Assessing Exemption Requests from Exemption Requests from thethe Nuclear Nuclear Power Power Plant Plant Licensed Operator Operator Staffing Staffing Requirements RequirementsSpecified Specifiedinin10 10CFR CFR50.54(m)"

50.54(m)"

3. NUREG-1852, "Demonstrating the the Feasibility Feasibility and and Reliability Reliability of Operator Operator Manual Manual Actions Actions in in Response to Response to Fire" Fire" Page 10 10 ofof 10 10