ML20307A455

Attachment 3 - Proposed Revision to Site Emergency Plan, Exhibit B, Radiological Emergency Plan Annex for Dresden Station (Procedure EP-AA-1004)

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

Text

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

(Marked-Up Pages)

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

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

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

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

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

The plant eonsists consisted of three Boiling Water Reactor (BWR) Nuclear Steam Supply Systems (NSSS) and turbine generators provided by General Electric Company. Unit 1 is a dual cycle boiling water reactor designed for a power output of 700 MWt and has officially been retired as of August 31, 1984.

Units 2 and 3 are equipped with nuclear steam supply systems (~JSSS) designed for a pov1er output of 2957 MVVtpermanently defueled .

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

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

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

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

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

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

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

• Grundy County

• Kendall County

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

Assessment actions at Dresden Station may include an evaluation of plant conditions; in-plant, onsite, and initial offsite radiological measurements; and initial estimates of offsite doses. Core damage inf.ormation is used to refine dose assessments and oonfirm or extend initial proteotive aotion reoommendations.

Dresden Station utilizes ~JEDC 33045P A, Revision 0, (2001) as the basis for the methodology f.or post aocident sore damage assessment. This methodology utilizes real time plant indications. In addition, Dresden Station may use samples of plant fluids and atmospheres as inputs to the CDAM (Core Damage Assessment Methodology) program f.or sore damage estimation.

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

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

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

November 2021 DR4-1 EP-AA-1004 (Revision x)

Dresden Annex Exelon Nuclear 5.2.2.2 Radiological Noble Gas Effluent Monitoring A wide range monitor is installed in the effluent stream that enters the main chimneys and the reactor building vents. These wide range monitors have a range of 1x10-7 uCi/cc to 1x10 5 uCi/cc.

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

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

5.2.2.4 DeletedHigh Range Containment Radiation Monitors Two high range eontainment radiation monitors are installed on eaeh of Dresden's units. The range of these monitors is from 1 RJhr to 1Og-RIRf.:.

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

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

Station procedures have been developed which would aid personnel in recognizing inadequate core cooling using applicable instrumentation.

5.2 .4 Onsite Fire Detection Instrumentation Dresden Station has a fire protection system that is designed to quickly detect any fires; annunciating locally and in the Control Room . The fire detection system is designed to applicable National Fire Protection Association (NFPA) standards. The majority of the detectors consist of electrically supervised ionization smoke detectors.

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

Attachment 3 Dresden Station PROPOSED REVISION TO SITE EMERGENCY PLAN Exhibit C Dresden Station Radiological Emergency Plan (Procedure EP-DR-1000)

(Clean Pages)

EP-DR-1000 Exelon Generation Revision X EXELON NUCLEAR DRESDEN STATION RADIOLOGICAL EMERGENCY PLAN November 2021 EP-DR-1000 (Revision X)

PART II: Planning Standards And Criteria Exelon Nuclear

2) State Agencies a) The State of Illinois: The State of Illinois has the statutory responsibility and authority for protecting the health and safety of the public in Illinois. The State of Illinois has developed an "Illinois Plan for Radiological Accidents" (IPRA).

This plan was developed in accordance with the guidance suggested by NUREG-0396 and NUREG 0654/FEMA-REP-1, Rev. 1. The IPRA has received 44 CFR 350 unconditional approvals from FEMA for all Exelon Nuclear's generating stations in the state of Illinois. Basic descriptions for the Illinois state agencies responsible for actions in the event of a nuclear power station are as follows:

• Governor of the State of Illinois: The Governor of the State of Illinois has overall command authority for both the radiological and non-radiological aspects of a nuclear incident. The Governor shall make the final recommendation for protective actions and shall serve as the state's primary spokesperson .

• Illinois Emergency Management Agency (IEMA): IEMA coordinates the operational response and recovery functions of all State agencies. IEMA proposes Protective Action Recommendations (PARs) to the Governor.

IEMA also coordinates the implementation of the Governor's PARs.

IEMA has the responsibility to inform the State of Wisconsin Department of Emergency Government (WDEG) with respect to an emergency event at Dresden Nuclear Power Station that impacts the 50-mile Ingestion Pathway Zone.

IEMA has both the command authority for radiological aspects of a nuclear incident and the responsibility for performing various radiological functions. These functions include milk, water and food control , radiation exposure control for state emergency workers, and confirmatory accident assessment. During an emergency situation , IEMA Technical shall make protective action recommendations to the Governor.

For events that impact the 50-mile ingestion pathway for Dresden Nuclear Power Station, IEMA Technical will coordinate technical information with the State of Wisconsin.

The IEMA Technical response to a nuclear incident utilizes two functional subgroups. They are the Radiological Emergency Assessment Center (REAC) and the Radiological Assessment Field Team (RAFT).

- Radiological Emergency Assessment Center (REAC): IEMA has established REAC in Springfield Illinois. REAC will serve as the command location for all (State related) radiological aspects of a nuclear incident. The Manager of the Office of Nuclear Facility Safety, or his/her designated alternate, is in command of REAC.

November 2021 A-5 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear Figure A-2: Agency Response Organization Interrelationships Governor's

- FEMA ~ - Office US NRC . Emergency Mgt.

Headquarters Agency I

US NRC State ,______

Exelon ~

Region Agencies

' *~

- DOE ' - State Police Field Monitoring Teams Agriculture I Fish

- FBI -

& W ild Life

- USCG -

Other Agencies U.S. Army

- Corp of Engrs

- Hospitals

- NWS Fire Department County Medical Agencies Support

- Municipal Local Law Enforcement November 2021 A-10 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear Section B: Dresden Nuclear Emergency Response Organization This section describes the Dresden Nuclear Emergency Response Organization (ERO),

its key positions and associated responsibilities. It outlines the staffing requirements which provide initial emergency response actions and provisions for timely augmentation of on-shift personnel when required. It also describes interfaces among Exelon Nuclear emergency response personnel and specifies the offsite support available to respond to Dresden Station.

1. On-Shift Emergency Response Organization Assignments The normal plant personnel complement is established with the Station Plant Manager having overall authority for station operations. The Station Plant Manager directs the site organization in the management of the various departments while the Shift Manager retains the responsibility for actual operation of plant systems. Emergency Preparedness must consider the capabilities of the normal plant organization, the Station and Corporate Emergency Response Organizations of Exelon Nuclear, and the non-Exelon Nuclear Emergency Response agencies. The initial phases of an emergency situation at a nuclear station will most likely involve a relatively small number of individuals. These individuals must be capable of (1) determining that an emergency exists; (2) providing initial classification and assessment; and (3) promptly notifying other groups and individuals in the emergency organization. The subsequent phases of the emergency situation may require an increasing augmentation of the emergency organization.

Dresden Station has personnel on shift at all times that can provide an initial response to an emergency event. ERO staffing tables, contained within this Emergency Plan outline the plant on-shift emergency organization and its relation to the normal staff complement. Members of the on-shift organization are trained on their responsibilities and duties in the event of an emergency and are capable of performing all response actions in an Unusual Event or the initial actions of higher classifications.

On Shift Personnel Dresden station has the capability at all times to perform detection, mitigation ,

classification, and notification functions required in the early phases of an emergency.

Shift augmentation and further ERO involvement will be determined by the extent and magnitude of the event.

Shift Manager: While acting as Shift Emergency Director, will take immediate action during an emergency and will activate the Station ERO, as appropriate. In the Shift Manager's absence or incapacitation, the line of succession is defined by Dresden procedures.

Radiation Protection: The Station Radiation Protection personnel are responsible for the handling and monitoring of radioactive materials. Included in this organization are Health Physicists, Radiation Protection Supervisors and Technicians.

Security: The Station Security personnel are responsible for the physical security of the site. Included in this organization are Security Supervisors and Security Guards.

November 2021 B-1 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear

• Rescue operations and First Aid

• Decontamination

• Security of plant and access control

• Repair and damage control

• Personnel protection including Assembly, Accountability and Evacuation

• Communications All Station ERO personnel shall have the authority to perform assigned duties in a manner consistent with the objectives of this plan.

1) Shift Manager (Shift Emergency Director) Control Room A Shift Manager is on duty 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the Shift Emergency Director in a declared emergency until relieved of this function. While serving in this capacity the Shift Manager is responsible for:

• Activating the ERO (as deemed appropriate or as procedurally required).

• Performing those duties outlined in Section B.5.a.2 for the Station Emergency Director.

The on-duty Shift Manager directs the activities of the operating crew and is responsible for the safe operation of the plant in compliance with the station NRC operating license and the station operating procedures. The Shift Manager, after relinquishing Command and Control, functionally reports to the Operations Manager in the TSC.

The Shift Manager's responsibilities, when not in Command and Control, are described below:

• The responsibility to adhere to the station Technical Specifications and to review routine operating data to assure safe operation;

• The responsibility to identify applicable EALs and emergency classifications; and

• The responsibility to adhere to plant operating procedures and the requirements for their use. During an emergency, operations personnel may depart from approved procedures where necessary to prevent injury to personnel, including the public, or damage to the facility consistent with the requirements of 10 CFR 50.54(x) and (y).

• Supervise the activities of the Control Room Crew.

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PART II: Planning Standards And Criteria Exelon Nuclear

• Assist in determining the priority assigned to OSC activities.

• Organize and direct medical response efforts for injured personnel.

• Ensure adequate staffing of the Control Room and TSC subordinates.

• Ensure the Shift Manager is informed of OSC staffing utilization and activities.

• Identify steps or procedures that the Operations staff should be utilizing to properly respond to the emergency condition.

• Assist the Station Emergency Director in evaluating changes in event classification.

• Supervise the activities of the ENS Communicator in the TSC.

• Act as the TSC liaison with the appropriate NRC Site Team Representative.

5) Technical Support Staff TSC The TSC Technical Support Staff consists of the following minimum staff engineering position:

TSC Engineer In addition , station Engineering support will be augmented on an as needed basis to support accident assessment and mitigation activities.

6) Radiation Protection Manager (RPM) TSC The Radiation Protection Manager reports to the Station Emergency Director.

The TSC RPM directs staff in determ ining the extent and nature of radiological or hazardous material problems onsite. Responsibilities include:

• Accumulate, tabulate and evaluate data on plant conditions such as meteorological and radiological monitoring readings, and other pertinent data.

• Act as the TSC liaison with the appropriate NRC Site Team representative.

• Ensure use of protective clothing , respiratory protection, and access control within the plant as deemed appropriate to control personnel exposures.

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• Expedite entry into the Protected Area, as necessary, for the NRC Site Team.

• Act as the TSC liaison with the appropriate NRC Site Team representative.

• Assist the Radiation Protection Manager in determining personnel evacuation routes as necessary.

• Coordinate the evacuation of station non-essential personnel with the appropriate Local Law Enforcement Agencies (LLEAs).

8) Operations Support Center Director osc The OSC Director reports to the Emergency Director and supervises the activities of OSC personnel. Responsibilities include:

• Assign tasks as available:

l&C Maintenance

- Mechanical Maintenance

- Electrical Maintenance

- Radiation Protection

• Coordinate with Operations in the dispatch of Operations personnel to support Control Room and OSC Team activities.

• Notify the Control Room and TSC prior to dispatch of any OSC teams into the plant.

• Maintain OSC resources including personnel, material, and equipment.

• Maintain accountability for all individuals dispatched from the OSC.

• Conduct periodic briefings on the overall plant status, emergency response activities, and station priorities.

• Assemble and dispatch the Field Monitoring Teams as required.

November 2021 B-10 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear

9) OSC RP Lead osc The OSC RP Lead assigned is responsible at all times for the safety of team personnel and to keep the OSC Director apprised of team status. Specifically, the OSC RP Lead is responsible for the managing and supervising RP personnel, including:

Conduct of adequate pre-dispatch briefings.

Ensuring adequate protective equipment and measures have been identified.

Tracking of OSC team activities while dispatched.

Debriefing of team personnel upon return to the OSC.

b. Corporate Emergency Response Organization

1) Corporate Emergency Director EOF a) When the Station Emergency Director has Command and Control, the ongoing responsibilities include:

• Coordinate all Exelon Nuclear activities involved with the emergency response.

• Ensure off-site agency updates are periodically communicated as required/requested.

• Coordinate Exelon Nuclear press releases with the Nuclear Duty Officer and Exelon Communications and Public Affairs.

• Request assistance from non-Exelon Nuclear emergency response organizations, as necessary.

• Direct and coordinate the activation of the EOF.

b) Following assumption of Command and Control. the additional responsibilities assigned to the Corporate Emergency Director include:

• Assumes overall Command and Control of emergency response activities and the non-delegable responsibilities for PAR determination and the notification of offsite authorities.

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

• Approve the technical content of Exelon Nuclear press releases prior to their being released to the media.

November 2021 B-11 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear The EOF is activated at an Alert. The EOF Organization is responsible for evaluating, coordinating and directing the overall company activities involved in the emergency response. Within the EOF, the Corporate Emergency Director shall assume Command and Control from the Shift Emergency Director when classification escalates to an Alert or higher, unless the EOF capabilities are limited such that the overall control and responsibility for PARs and offsite notifications cannot be assumed .

The JIC is activated within 90 minutes of an Alert or higher. Some JIC functions may continue to be performed by the Exelon Communications organization until transferred to the JIC.

8. Industry/Private Support Organizations Exelon Nuclear retains contractors to provide supporting services to nuclear generating stations. A contract/purchase order with a private contractor is acceptable in lieu of an agreement letter for the specified duration of the contract. Among services currently provided are the following :

a. Deleted

b. American Nuclear Insurers (ANI): In early 1982, ANI issued Bulletin #58 (1981)

"Accident Notification Procedures for Liability Insurers" which provides revised criteria for the notification of the Pools in the event of a nuclear emergency at one of the liability insured nuclear power reactor sites. This revision brings the ANl/MAELU (Mutual Atomic Energy Liability Underwriters) notification criteria into alignment with the standard emergency classification system adopted by the nuclear industry. This document also identifies a su itable channel for follow-up communication by ANI after initial notification .

• ANl/MAELU Emergency Assistance: In the event of an extraordinary nuclear occurrence (as defined in the Price-Anderson Law) ANI and MAELU (the insurance pools) have plans prepared to provide prompt emergency funding to affected members of the public.

• ANl/MAELU Emergency Assistance (Claims Handling Procedures): The pools' emergency assistance arrangements contemplate the mobilization and dispatch of emergency claims teams to directly dispense emergency assistance funds to affected members of the public.

The pools should be notified in the event of a nuclear emergency requiring notification of state or Federal governmental agencies, or if the insured believes that offsite persons may be affected and financial assistance of a nature discussed may be required. In these instances, ANI expects notification as soon as possible after the initiation of the emergency. Exelon notification to the pools in the event of an Alert, Site Area Emergency, or General Emergency will be in accordance with the Exelon Nuclear Reportability Manual.

November 2021 B-17 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear Figure B-1a: Dresden Overall ERO Command Structure Corporate Emergency Director Station Corporate Emergency Spokesperson Director November 2021 B-20 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear Figure B-1 b: Emergency Onsite Organization Station Emergency Director I

Security Coordinator I I I Rad Protection osc Operations Manager Director Manager ENS Communicator -

I 1 p~ Electrical Pool Rad Protection Lead 1 Mechanical Pool Control Room Shift Manager Control Room Shift Staff Rad Protection **

Pool TSC Engineer ERO response pool personnel do not include the on-shift complement.

1 Rad Protection Lead responsibilities will be performed by a Rad Protection Pool responder as a collateral function November 2021 B-21 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear

• When the event is terminated, close-out is performed over communication links to offsite authorities participating in the response (i.e., NRC, state, county), followed by formal transmission of a state/local notification form within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

b. Alert - Events are in process or have occurred which indicate an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of EPA Protective Action Guideline exposure levels.

The purpose of this classification is to ensure that emergency response personnel are readily available and to provide offsite authorities with current status information. An Alert will be classified as the initiating event or as escalation from an Unusual Event. In either case, the classification will most likely made by the Shift Manager (Shift Emergency Director) prior to the transfer of Command and Control.

Required actions at this classification include:

• Notifications to station management and the NDO.

• Notification , within 15 minutes, of the state and local communities. The EOF will assume state update responsibilities.

• Activation of the TSC, OSC, EOF, and the JIC organizations.

• Transfer of Command and Control.

• Notification of the NRC immediately after notification of the appropriate State and local agencies and not later than 60 minutes of classification.

• Notification of ANI.

• Assessment of the situation and response as necessary, which may include escalating to a higher classification if conditions warrant.

• On-site and off-site Field Monitoring Teams are sent to staging areas or dispatched to monitor for releases of radiation to the environment.

• Keeping offsite authorities informed of plant status by providing periodic updates to include meteorological and radiological data.

• When the event is terminated, notification is performed over communication links followed by an Initial Incident Report to offsite authorities participating in the response (i.e., NRC, state, county) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

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

PART II: Planning Standards And Criteria Exelon Nuclear

c. Site Area Emergency - Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; 1) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

The purpose of this classification, in addition to those of the Alert level, is to ensure that all emergency response centers are staffed and provisions are made for information updates to the public through offsite authorities and the news media.

The classification will most likely be made by the Station Emergency Director following activation of the TSC.

Required actions at this classification , in addition to those listed under the Alert level, include:

• If not previously performed, Assembly/Accountability shall be performed and Site Evacuation of non-essential personnel shall be initiated.

• Keeping offsite authorities informed of plant status by providing periodic updates to include meteorological data and projected or actual doses for any releases that have occurred.

d. General Emergency - Event(s) are in process or have occurred which involve actual or imminent substantial fuel degradation or melting or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

The purpose of this classification, in addition to those of the Site Area Emergency level, is to initiate predetermined protective actions for the public and provide continuous assessment of information from monitoring groups. The classification will most likely be made by the Station Emergency Director following activation of the TSC.

Required actions at this classification, in addition to those listed under the Alert and Site Area Emergency, include:

• A Protective Action Recommendation will be determined.

• Assessment of the situation and response as necessary.

November 2021 D-3 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear

e. Recovery: That period when the emergency phase is over and activities are being taken to return the situation to a normal state (acceptable condition). The plant is under control and no potential for further degradation to the plant or the environment is believed to exist.

Recovery will be classified by the Station Emergency Director after obtaining authorization from the Corporate Emergency Director.

Required actions at this classification include:

• The affected state(s) and the NRC should be consulted prior to entry into Recovery.

• Notifications will be made to station management, the NDO, state(s) and NRC.

• A Recovery organization will be established to manage repairs to return the Unit to an acceptable condition , and support environmental monitoring activities as requested in coord ination with Federal and state efforts.

• ANI is notified of Recovery classification.

f. Classification Downgrading: Exelon Nuclear policy is that emergency classifications shall not be downgraded to a lower classification . Once declared ,

the event shall remain in effect until no Classification is warranted or until such time as conditions warrant classification to Recovery.

g. Guidance for Termination of an Emergency: The purpose of terminating an emergency is to provide an orderly turnover of plant control from the Emergency Response Organizations to the normal Exelon Nuclear plant organization .

Termination of the emergency is authorized by the Emergency Director in Command and Control. The considerations provided in the Recovery/Termination Checklist in the emergency implementing procedures must be performed prior to exiting the emergency event. Consultation with governmental agencies and other parties should be conducted prior to termination of an event classified as Site Area or General Emergency. Notifications shall be transmitted to appropriate agencies to terminate an event.

h. Station Nuclear Security Plan: Dresden has a Security Plan that complies with the requirements of 10 CFR 73. The interface between the E-Plan and the Security Plan is one of parallel operation. The plans are compatible. The E-Plan response measures, once initiated, are executed in parallel with measures taken in accordance with the Security Plan.

November 2021 D-4 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear An emergency is classified after assessing abnormal plant conditions and comparing them to EAL Threshold Values for the appropriate Initiating Conditions. Classifications are based on the evaluation of each unit for multi-reactor sites. Matrix tables organized by recognition categories are used to facilitate the comparison.

All recognition categories should be reviewed for applicability prior to classification .

The initiating conditions are coded with a letter and/or number designator. All initiating conditions, which describe the severity of a common condition (series), have the same initial designator.

3. Timely Classification of Events Classification of an emergency condition occurs within 15 minutes after the availability of indications from plant instrumentation, plant alarms, computer displays, or incoming verbal reports that an EAL has been exceeded and, is then promptly made upon identification of the appropriate EAL. The 15-minute period encompasses all assessment, classification, and declaration actions associated with making an emergency declaration from the first availability of a plant indication or receipt of a report up to and including the declaration of the emergency.

Validation or confirmation of plant indications or reports of the condition are to be accomplished within the 15-minute period as part of the assessment. Since this validation or confirmation is being performed to determine the validity of an alarm ,

indication, or report, the 15-minute period starts with the availability of the alarm ,

indication, or report to any qualified EAL assessor, and not the completion of the validation or confirmation, because the former is the time that the information was first available.

A qualified EAL assessor means any member of the plant staff who, by training and experience, is qualified to assess the indications or reports for validity and to compare the same to the EALs. A qualified EAL assessor may be, but need not be, a Certified Fuel Handler, Non Certified Operator, or member of the ERO. Qualified EAL assessors may be in the MCR or in another facility where emergency declarations are performed. A qualified EAL assessor does not include personnel such as chemists, radiation protection technicians, craft personnel, security personnel, and others whose positions require they report, rather than assess, abnormal conditions to the MCR.

The 15-minute criterion ends as soon it is determined that an EAL has been exceeded and upon identification of the appropriate Emergency Classification Level (ECL) and when the Emergency Director makes the emergency declaration. The emergency condition should be declared as soon as possible following the identification of the appropriate ECL. As used here, "promptly" means the next available opportunity unimpeded by activities not related to the emergency declaration, unless such activities are necessary for protecting health and safety.

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

PART II: Planning Standards And Criteria Exelon Nuclear

b. Offsite: Notifications are promptly made to offsite emergency response organizations as follows:

1) State/Local Agencies: A notification shall be made within fifteen (15) minutes of:

• The initial emergency classification.

• Classification escalation.

• The issuance of or change to a Protective Action Recommendation (PAR) for the general public.

• Changes in radiological release status, occurring outside of an event classification or PAR notification, based on an agreement with the state(s).

The emergency warning points are simultaneously notified using the Nuclear Accident Reporting System (NARS), or a commercial telephone line as backup.

A notification will also be initiated to cognizant state/local government agencies as soon as possible but within one hour of the termination of an event classification, or entry into Recovery Phase.

2) Nuclear Regulatory Commission (NRG): An event will be reported to the NRG Operations Center immediately after notification of the appropriate state or local agencies but not later than one (1) hour after the time of initial classification, escalation, termination or entry into the Recovery Phase. The NRG is notified by a dedicated telephone system called the Emergency Notification System (ENS). If the ENS is inoperative, the required notification is made via commercial telephone service, other dedicated telephone service, or any other method that shall ensure that a report is made as soon as practical. An NRG Event Notification Worksheet should be utilized to transmit initial information to the NRC. If a continuous communication is requested and established, a log is used in lieu of the ENS Worksheet.

Specific requirements for the notifications to the NRC for classified emergency events are detailed in 10 CFR 50.72 with guidance provided in the Exelon Reportability Manual.

Mobilization of federal, state, and county response organizations is performed in accordance with their applicable emergency plan and procedures. At a minimum, mobilization of federal response organizations and activation of state and county EOCs is expected to occur at the declaration of a Site Area Emergency.

The state and county authorities are responsible for the process of notification of the general public.

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PART II: Planning Standards And Criteria Exelon Nuclear

c. Support Organizations: When an emergency is initially classified, escalated or terminated, notifications are promptly made to the following support organizations:

• Medical, rescue, and fire fighting support services are notified for assistance as the situation dictates.

• The American Nuclear Insurers (ANI) are notified at an Alert or higher classification with requests for assistance as necessary.

• Vendor and contractor support services are notified for assistance as the situation dictates.

3. Initial Notification Messages Exelon Nuclear, in conjunction with state and county authorities, has established the contents of the initial notification message form transmitted during a classified emergency. The contents of the form include, as a minimum:

• Designation ("This is a Drill" or "Actual Event").

• Identity of site .

• Event classification.

• EAL number (as agreed upon with state authorities).

• Non-technical event description (as agreed upon with state authorities).

• Date and time of declaration (or entry into Recovery or Termination).

• Whether a release is taking place (Note: "Release" means a radiological release attributable to the emergency event.)

• Wind direction and speed .

• Whether offsite protective measures may be necessary.

• Potentially affected Subareas (or Sectors as applicable) when a General Emergency is declared.

Notification approval, transmittal date and time, and offsite agencies contacted are recorded either on the notification form or in an event logbook.

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PART II: Planning Standards And Criteria Exelon Nuclear The ANS is operated by local governmental agencies and maintained by Exelon Nuclear. To assure the ANS is maintained in an operational readiness posture, the local agencies have agreed to test the system (by sounding the sirens) on a periodic basis that meets or exceeds FEMA guidance and to report inoperable equipment to EP-designated maintenance personnel. The goal of the testing and maintenance program is to identify inoperable equipment in a timely manner and to restore equipment to a functional status commensurate with FEMA operability requirements as referenced in FEMA-REP-10, "Gu ide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants". In addition to this routine test and repair program, preventive maintenance of the ANS will be performed on an annual basis.

A more site-specific description of the various prompt public notification systems is presented in the Station Annex to the E-Plan. The activation of the ANS sirens, deployment of emergency service vehicles and operation of the Emergency Alerting System is discussed in detail in the state specific response plans.

7. Messages to the Public The respective States have developed EAS messages for the public consistent with the classification scheme. These draft messages are included as part of the States' Emergency Plan and contain instructions with regard to specific protective actions to be taken by occupants and visitors of affected areas. Messages may include instructions such as: take shelter and go indoors, close windows and doors, turn off ventilation systems; directions given for evacuation ; directions to stay tuned to specific stations for further information, ad-hoc respiratory protection , (e.g. handkerchief over mouth, etc.). Exelon will provide support for the content of these messages when requested . The States control the distribution of radioprotective drugs to the general public.

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PART II: Planning Standards And Criteria Exelon Nuclear

1) Nuclear Accident Reporting System (NARS): The NARS is a dedicated communications system that has been installed for the purpose of notifying state and local authorities of declared nuclear emergencies. This system links together the station Control Rooms, the EOF, TSCs and state and local authorities as appropriate.

2) Operations Status Line: An independent interfacility telephone link called the Operations Status Line that enables communication between the Control Room , the TSC, the OSC, and the EOF to monitor the activities throughout the Emergency Response Facilities (see Figure F-2). The Operations Status line consists of a dedicated Private Branch Exchange (PBX) Telephone System or a Voice Over Internet Protocol (VoIP) system.

3) Director's Hotline: A dedicated telephone link called the Director's Hotline that enables direct Emergency Director communication between the Control Room ,

TSC, and the EOF (see Figure F-2). The Directors Hotline consists of a dedicated PBX or a VoIP system.

4) Local Commercial Telephone System: This system provides standard commercial telephone service through the public infrastructure, consisting of central offices and the wire line. The commercial vendor provides primary and secondary power for their lines at their central office.

5) Field Monitoring Team (FMT) Communications: A separate communications system has been installed to allow coordinated environmental monitoring and assessment during an emergency. This system consists of the necessary hardware to allow communication via Satellite Phones between TSC, EOF, and mobile units in Exelon Nuclear vehicles. Commercial cell phones are available as back up to the primary field team communications system.

In addition, station communication links exist to ensure appropriate information transfer capabilities during an emergency. The station may also utilize its Public Address System , station radios and notification devices to augment its emergency communications.

e. ERO Notification System: Exelon Nuclear utilizes an automated ERO Notification System to rapidly notify members of the ERO. The system consists of a network of physical infrastructure capable of initiating and receiving contact via multiple notification devices. When activated, the system contacts the notification devices (e.g., through commercial and cellular phone, email, text message) belonging to members of the ERO. The System includes redundant activation methods via the internet, call-centers, or direct telephone activation, as well as redundant, geographically separated call centers and data centers, with redundant power sources. Implementing procedures specify the course of action to be taken if the primary ERO Notification System activation path fails to respond . The ERO Notification System provides primary and back-up notification functions.

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PART II: Planning Standards And Criteria Exelon Nuclear Figure F-1: Exelon Notification Scheme (For Full Augmentation)

Control Room (Shift Manager)

TSC _ NRC Headquarters _ NRC Region (ENS Comm) i - - - - -1 (Duty Officer) 1---..i (Duty Officer)

(Emergency Director)

EOF (State/Local Comm)

I._______ Commercial - Nuclear Duty I VoIP ----ei~ Officer I

As appropriate

~

(NARS) _ State Warning Local Warning Points/EOCs -+ Points/EOCs

~------.i

~ (Dispatcher/comm) (Dispatcher/comm)

Updates (Commerc1alNolP)

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PART II: Planning Standards And Criteria Exelon Nuclear Section H: Emergency Facilities and Equipment Onsite and offsite facilities are available for emergency assessment, communications, first aid and medical care, and damage control. Of particular importance are the Emergency Response Facilities (ERFs); the Control Room (CR), the Technical Support Center (TSC), the Operations Support Center (OSC), the Emergency Operations Facility (EOF), and the Joint Information Center (JIC).

This section describes the emergency facilities and equipment used by the Emergency Response Organization and outlines the requirements which aid in timely and accurate response actions. It also describes the surveillance programs used to monitor and ensure that these facilities and equipment are maintained in a high degree of constant readiness.

1. Control Room, Technical Support Center, and Operations Support Center Dresden has established a TSC and an on-site OSC, which are activated upon declaration of an Alert or higher classification. Until they become operational, required functions of these facilities are performed in the Control Room.

Under certain adverse conditions for Security-Based Events, personnel may be assembled in an "ERO Alternative Facility" prior to being dispatched to one of the facility ERFs.

a. Station Control Room: The Control Room is the centralized onsite location from which the Nuclear Station's plant systems necessary to support the spent fuel pool are monitored. The Control Room is equipped with instrumentation to supply detailed information on the plant systems. The Control Room is continuously staffed with qualified operators. The Control Room is the first onsite facility to become involved with the response to emergency events. Control Room personnel must evaluate and effect control over the emergency and initiate activities necessary for coping with the emergency until such time that support centers can be activated. These activities shall include:

• Plant control.

• Initial direction of all plant related operations.

• Accident recognition, classification, mitigation and initial corrective actions.

• Alerting of onsite personnel.

• Notification of appropriate individuals.

• Activation of emergency response facilities and ERO notification.

• Notification of offsite agencies.

• Continuous evaluation of the magnitude and potential consequences of an incident.

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PART II: Planning Standards And Criteria Exelon Nuclear Personnel in the TSC shall be protected from radiological hazards, including direct radiation and airborne contaminants under accident conditions with similar radiological habitability as Control Room personnel. To ensure adequate radiological protection, permanent radiation monitoring systems have been installed in the TSC and/or periodic radiation surveys are conducted . These systems indicate radiation dose rates and airborne radioactivity inside the TSC while in use. In addition, protective breathing apparatus (full-face air purifying respirators) and Kl are available for use as required.

The TSC has access to a complete set of as-built drawings and other records, including general arrangement diagrams, P&IDs, and the electrical schematics.

The TSC has the capability to record and display vital plant data, in real time, to be used by knowledgeable individuals responsible for engineering and management support of operations, and for implementation of emergency procedures.

c. Operations Support Center (OSC): Dresden has established an OSC. The OSC is the onsite location to where station support personnel report during an emergency and from which they will be dispatched for assignments or duties in support of emergency operations. The OSC shall be activated whenever the TSC is activated, but need not remain activated at the Alert level if its use is judged unnecessary by the Station Emergency Director. At the Site Area and General Emergency levels, the OSC or an alternate OSC shall be activated at all times. The OSC is not activated for a HOSTILE ACTION when the Alternative Facility is implemented.

Activation for other events is optional. Station disciplines reporting to the OSC include, but are not limited to:

• Operating personnel not assigned to the Control Room,

• Radiation Protection Personnel ,

• Maintenance Personnel (mechanical, electrical and l&C).

Figure 8-1 b illustrates the staffing and organization for the OSC.

The OSC is equipped with communication links to the Control Room, the TSC and the EOF (see Section F). A limited inventory of supplies will be kept for the OSC.

This inventory will include respirators, protective clothing, flashlights and portable survey instruments.

2. Emergency Operations Facility (EOF)

The EOF is the location where the Corporate Emergency Director will direct a staff in evaluating and coordinating the overall company activities involved with an emergency. Activation of the EOF is mandatory upon declaration of an Alert or higher classification. The EOF provides for:

• Management of overall emergency response.

• Coordination of radiological and environmental assessments.

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PART II: Planning Standards And Criteria Exelon Nuclear

a. Geophysical Monitors

1) Meteorological Instrumentation: A permanent meteorological monitoring station is located near each station for display and recording of wind speed, wind direction, and ambient and differential temperature for use in making offsite dose projections. Meteorological information is presented in the CR, TSC, and EOF by means of the plant computer system. This information is remotely interrogated using a computer or other data access terminal.

With regard to Exelon Nuclear's meteorological monitoring program , there has been a quality assurance program adopted from 10 CFR 50, Appendix B.

However, since the meteorological facilities are not composed of structures, systems, and components that prevent or mitigate the consequences of postulated accidents and are not "safety related," not all aspects of 10 CFR 50, Appendix B, apply. Those aspects of quality assurance germane to supplying good meteorological information for a nuclear power station were adopted into the meteorological quality assurance program . The meteorological program is also subject to the requirements of the Decommissioning Quality Assurance Program.

The National Weather Service (NWS), or regional weather forecast providers, may be contacted during severe weather periods. These providers analyze national and local weather in order to provide localized weather forecasts for the system or for the station area as appropriate.

2) Seismic Monitoring: The seismic monitoring system measures and records the acceleration (earthquake ground motion) of the structure . Earthquakes produce low frequency accelerations which, when detected by the remote sensing devices, are permanently recorded as information which defines the response spectrum. The system remains in a standby condition until an earthquake causes the remote unit(s) to activate the recording circuits and tape transports.

It also provides signals for immediate remote indication that specific preset response accelerations have been exceeded.

3) Hydrological Monitors: The design basis flood, probable maximum precipitation, and other improbable, conceivable extremes in hydrologic natural phenomena are well below any design limits for the station as detailed in the UFSAR.

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b. Radiological Monitors and Sampling

1) The Radiation Monitoring System (RMS): In-plant radiological measurements provide information that may help determine the nature, extent and source of emergency conditions. The RMS is available to give early warning of a possible emergency and provides for a continuing evaluation of the situation in the Control Room. Radiation monitoring instruments are located at selected areas within the facility to detect, measure, and record radiation levels. In the event the radiation level should increase above a preset level , an alarm is initiated in the Control Room. Certain radiation monitoring instruments also alarm locally in selected areas of the facility. The RMS is divided into 3 subsystems:

a) Area Radiation Monitors (ARMs) are used for the direct measurement of in-plant exposure rates . The ARM readings allow in-plant exposure rate determinations to be made remotely without requiring local hand-held meter surveys. This information may be used, initially, to aid in the determination of plant area accessibility. In addition to permanent monitors, portable Continuous Air Monitors (CAMs) measure airborne particulate and airborne iodine activities at various locations within the operating areas.

b) Process Radiation Monitors (PRMs) are used for the measurement of radioactive noble gas, iodine, and particulate concentrations in plant effluent and other gaseous and fluid streams.

c) The accident, or high range, radiation monitoring system monitors radiation levels at various locations within the operating area. These are high range instruments used to track radiation levels under accident or post accident conditions.

The RMS provides the necessary activity or radiation levels required for determining source terms in dose projection procedures. Key RMS data is linked to the plant computer, which allows information to be passed to the TSC and EOF. The isotopic mix, including isotopes such as those in Table 3 of NUREG-0654, is based upon a default accident mix. Refer to the Dresden UFSAR for further detail on the RMS capabilities and design.

2) Liquid and Gaseous Sampling Systems: The process sampling system consists of the normal sampling system and additional sampling panels located throughout the plant. Sampling systems are installed or can be modified to permit sampling even under severe accident conditions.

The sampling systems use a number of manual sampling techniques to enable sampling operations over a wide range of plant conditions. It is capable of providing information relative to post-accident plant conditions to allow operator actions to be taken to mitigate and control the course of an accident. Refer to the Dresden UFSAR for further detail on sampling capabilities.

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3) Portable Radiation Monitoring Equipment: Portable radiation survey instruments are available for a wide variety uses such as area, sample, and personnel surveys and continued accident assessment. Instruments are stored throughout the plant and in the emergency facilities .

c. Process Monitors: The Control Room and applicable redundant backup locations are equipped with extensive plant process monitors for use in both normal and emergency conditions. These indications include but are not limited to liquid levels, flow rates, status or lineup of equipment components. This instrumentation provides the basis for initiation of corrective actions.

1) Plant Monitoring/Information System : A plant monitoring/information system provides the data acquisition and database capability for performing plant monitoring and functions . The system is designed to scan , convert to engineering units, make reasonability and alarm limit checks, apply required transformations, store for recall and analysis, and display the reading of transformed data from plant instrumentation. The system scans flows ,

pressures, temperatures , fluid levels, radiation levels, equipment, and valve status at required frequencies. Scanned variables are quality tagged. The system provides for short and mid term storage of data for on-line retrieval and fast recall , and long term storage to appropriate media.

2) Safety Parameter Display (SPDS) & Plant Parameter Display (PPDS) Systems:

SPDS and PPDS provide a display of plant parameters from which the safety status of operation may be assessed in the Control Room, TSC and EOF. The primary function of the SPDS and PPDS is to help operating personnel in the Control Room make quick assessments of plant safety status . SPDS and/or PPDS displays in the TSC and EOF promote the exchange of information between these facilities and the Control Room and assists the emergency organization in the decision making process.

d. Fire Detection System: The Fire Detection System is designed to quickly detect visible or invisible smoke (or other products of combustion) and/or heat in designated areas of the plant. The fire alarm communication systems and subsystems are located at strategic points throughout the plant to warn personnel of a nuclear incident or other emergency conditions. Existing plant alarm systems are sufficiently audible to alert personnel in the event of a fire or need for assembly.

These alarm communication systems consist of warning sirens and lights (in high noise areas) and the PA system. Refer to the Dresden UFSAR for further description of the station's fire protection system.

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PART II: Planning Standards And Criteria Exelon Nuclear Section I: Accident Assessment To effectively coordinate and direct all facets of the response to an emergency situation ,

diligent accident assessment efforts are requ ired throughout the emergency. All four emergency classifications have similar assessment methods, however, each classification requires a greater magnitude of assessment effort dependent upon the plant symptoms and/or initiating event(s) .

1. Plant Parameters and Corresponding Emergency Classification Plant system and effluent parameter values are utilized in the determination of accident severity and subsequent emergency classification. Environmental and meteorological events are also determining factors in emergency classification. An emergency condition can be the result of just one parameter or condition change , or the combination of several. The specific symptoms, parameter values or events for each level of emergency classification are detailed in the emergency implementing procedures. Specific plant system and effluent parameters that characterize a classifiable event (EALs) are presented in Addendum 3 to each Station Annex.

In order to adequately assess the emergency condition , each emergency facility has the necessary equipment and instrumentation installed to make available essential plant information on a continuous basis. Evaluation of plant conditions is accomplished through the monitoring of plant parameters both from indication in the Control Room and within the plant. Some of the more important plant parameters to be monitored in the Control Room are assembled into a single display location, which is entitled the "Safety Parameter Display System" (SPDS). The SPDS monitors such parameters as: safety system status, and effluent monitor readings. The instrumentation and equipment capabilities available for each emergency facility are described in Section H.

2. Onsite Accident Assessment Capabilities The resources available to provide initial and continuing information for accident assessment throughout the course of an event include plant parameter display systems, liquid and gaseous sampling system, Area and Process Radiation Monitoring Systems, and Accident Radiation Monitoring Systems. Descriptions of these systems are given in Section H.5.b.

3. Source Term Determination Source term (or fuel damage) estimations serve several roles within the Exelon Emergency Preparedness Program. For planning purposes, fuel damage considerations are used as the bases for several of the Emergency Action Level (EAL)

Initiating Conditions and as the threshold for the declaration of a General Emergency (the definition of a General Emergency specifies conditions which involve 'substantial' fuel degradation or melting as one of the bases for classification).

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PART II: Planning Standards And Criteria Exelon Nuclear From an implementation perspective, fuel damage estimations provide a means of realistically differentiating between the fuelstates (no damage, clad failure, and fuel melt) to:

• Evaluate the status of the fuel clad and how their status relates to the risks and possible consequences of the accident.

• Provide input on fuel configuration (coolable or uncoolable) for prioritization of mitigating activities.

• Determine the potential quality (type) and/or quantity(%) of source term available for release in support of projected offsite doses and protective action recommendations.

• Provide information that quantifies the severity of an accident in terms that can be readily understood and visualized.

• Support the determination of radiological protective actions that should be considered for long term recovery activities.

The assessment methodologies utilized by Dresden are intended to provide a rapid best estimate of fuel damage which, when evaluated together, help to develop an overall picture of the extent of fuel damage.

4. Effluent Monitor Data and Dose Projection Dose assessment or projection represents the calculation of an accumulated dose at some time in the future if current or projected conditions continue. During an accident, the Plant Parameter Display System and personal computers will provide the ERO with the timely information required to make decisions. Radiological and meteorological instrumentation readings are used to project dose rates at predetermined distances from the station, and to determine the integrated dose received. Dose assessment methods used by Exelon personnel to project offsite doses include:

A. Monitored Release Points - This method utilizes the plant's effluent radiation monitors and system flow rates. Effluent release points are used to directly calculate a release rate. The point of the release determines the way the source term is affected and is adjusted by the dose assessment process.

B. Release Point Samples - This method uses a sample at the release point and an estimated flow rate to develop a release rate at the point of release.

C. Field Monitoring Team Data - This method uses a field survey or sample and the atmospheric model to back calculate a release rate and ratio concentrations of radioactive material at various points up and downwind of plume centerline.

The computer applications used to provide dose calculations are evaluated against the EPA-400 plume exposure Protective Action Guides (PAGs) applicable for the early phase of an accident. These evaluations place an emphasis on determining the necessity for offsite protective action recommendations. Dose assessment actions will be performed in the following sequence:

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PART II: Planning Standards And Criteria Exelon Nuclear

m. At a General Emergency classification, Exelon Nuclear will provide the state with recommendations for protective actions for the public. For incidents involving actual, potential, or imminent releases of radioactive material to the atmosphere, EPA 400-R-92-001, the NRC Response Technical Manual (RTM-96) and NUREG-0654, Supp. 3, Revision 1 are used as the basis for the general public PARs.

1) Plant Based PARs Station specific PAR Flowcharts have been developed to aid Exelon Nuclear personnel providing PARs based on the above. Station specific PAR Flowcharts with Subarea or Sector tables are documented in the Exelon EP Implementing Procedures, including station-specific requirements regarding PAR determination. These flowcharts and tables provide technically based Protective Action Recommendations based on plant conditions indicators as applicable to the Exelon site and described within the implementing procedures. Possible plant based PARs issued by Exelon Nuclear, in support of NUREG-0654 Supp. 3, at a General Emergency could include as appropriate for the Station:

• Response to a Rapidly Progressing Severe Accident.

• Utilization of the staged evacuation concept as determined by station ETE's.

• Shelter of the general public in response to but not limited to impediments to evacuation or Hostile Action event.

• Evacuation of the general public.

In addition to the above actions to minimize or prevent potential exposure to radiation, a recommendation of "monitor and prepare" will be issued for the remainder of the EPZ.

2) Dose Based PARs Evacuation is recommended if projected doses reach the minimum EPA PAGs

(~ 1 Rem EPA TEDE 1 or ~ 5 Rem COE Thyroid).

Many assumptions exist in dose assessment calculations, involving both source term and meteorological factors, which make computer predictions over long distances highly questionable. However, in the event dose assessment results indicate the need to recommend actions beyond the outer EPZ boundaries, which is past 10 miles, Field Monitoring Teams are dispatched to downwind areas to verify the calculated exposure rates prior to issuing PARs outside the EPZ. In the event dose assessment results indicate the need to recommend actions beyond the outer EPZ boundaries (past 10 miles):

1 EPA TEDE is defined as the sum of the doses from external exposure and inhalation from the plume, and from 4 days of external exposure to deposited materials.

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PART II: Planning Standards And Criteria Exelon Nuclear Establishment of Recovery can be conducted from any emergency classification level. However, it is possible that the lower classifications of Unusual Event and Alert will conclude with the event being terminated . There may be cases where certain EAL initiating conditions remain exceeded , but the station is under control and no further danger of degradation exists. In such a case, it may be appropriate to enter Recovery. Site Area and General Emergencies will require a Recovery Phase to be established prior to event termination. Exelon Nuclear may consult with/notify cognizant governmental agencies prior to declaring Recovery or event termination.

Termination/Recovery considerations are contained in the implementing procedures to provide guidance for evaluating the risk of entering Recovery without alleviating the intent of the Initiating Condition. The purpose of Recovery is to provide the necessary personnel to handle the long-term activities and to return the plant to an acceptable condition.

The following conditions are guidelines for the determination of establishing Recovery (this is not intended to be a complete list and additional criteria may apply, depending on the specifics of the event):

• The risk to the health and safety of the public has been mitigated.

• Plant parameters and equipment status have been established and controlled.

• In-plant radiation levels are stable or decreasing, and acceptable, given the plant conditions.

• The potential for uncontrolled releases of radioactive material to the environment has been eliminated.

• Environmental monitoring has been established.

• The radioactive plume has dissipated and plume tracking is no longer required (the only environmental assessment activities in progress are those necessary to assess the extent of deposition resulting from passage of the plume).

• Exelon Nuclear workers have been protected.

• Any security threat has been neutralized, and/or plant security is under the direction of Exelon Nuclear personnel.

• Adequate plant safety systems are operable.

• The fuel pool damage has been mitigated, or spent fuel damage has been contained and controlled .

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PART II: Planning Standards And Criteria Exelon Nuclear

• For events involving major damage to systems where offsite radioactive releases have occurred, (i.e. for Site Area Emergency or General Emergency classifications) the station recovery organization is put in place.

The specific members of the station recovery organization are selected based on the sequence of events that preceded the recovery activities as well as the requirements of the recovery phase. The basic framework of the station recovery organization is as follows:

a. The Recovery Director: The Corporate Emergency Director is initially designated as the Recovery Director. The Recovery Director is charged with the responsibility for directing the activities of the station recovery organization. These responsibilities include:

• Ensuring that sufficient personnel , equipment, or other resources from Exelon and other organizations are available to support recovery.

• Directing the development of a recovery plan and procedures.

• Deactivating any of the plant Emergency Response Organization which was retained to aid in recovery, in the appropriate manner. Depending upon the type of accident and the onsite and offsite affects of the accident, portions of the ERO may remain in place after initiation of the recovery phase.

• Coordinating the integration of available federal and state assistance into onsite recovery activities.

• Coordinating the integration of Exelon support with federal, state and county authorities into required offsite recovery activities.

• Approving information released by the public information organization which pertains to the emergency or the recovery phase of the accident.

• Determining when the recovery phase is terminated.

b. The Recovery Plant Manager: The Station Manager or a designated alternate will become the Recovery Plant Manager. The Recovery Plant Manager reports to the Recovery Director and is responsible for:

• Coordinating the development and implementation of the recovery plan and procedures.

• Ensuring that adequate engineering activities to restore the plant, are properly reviewed and approved .

• Directing all onsite activities in support of the station recovery effort.

• Designating other Exelon recovery positions required in support of onsite recovery activities.

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PART II: Planning Standards And Criteria Exelon Nuclear

c. Medical Emergency Drills: A medical emergency drill, involving a simulated contaminated individual, and containing provisions for participation by local support services organizations (i.e., ambulance and support hospital) are conducted annually . Local support service organizations, which support more than one station, shall only be required to participate once each calendar year. The offsite portions of the medical drill may be performed as part of the required biennial exercise.

d. Radiological Monitoring Drills: Plant environs and radiological monitoring drills (onsite and offsite) are conducted annually. These drills include collection and analysis of all sample media (such as, water, vegetation, soil, and air), and provisions for communications and record keeping.

e. Health Physics Drills: Health Physics Drills involving a response to, and analysis of, simulated airborne and liquid samples and direct radiation measurements within the plant are conducted semi-annually. At least annually, these drills shall include a demonstration of the sampling system capabilities.

f. Augmentation Drills: Augmentation drills serve to demonstrate the capability of the process to augment the on-shift staff with a TSC, OSC and EOF in a short period after declaration of an emergency. These drills are conducted using the following methods:

• Quarterly, each station will initiate an unannounced off-hours ERO augmentation drill where no actual travel is required . Each region's Corporate ERO shall also perform an unannounced off-hours ERO augmentation drill that may be conducted independent of, or in conjunction with, a station drill.

• At least once per exercise cycle, an off-hours unannounced activation of the ERO Notification System with actual response to the emergency facilities is conducted by each station. Each region's Corporate ERO need only participate once per cycle.

g. Accountability Drills: Accountability drills are conducted annually. The drill includes identifying the locations of all individuals within the protected area.

3. Conduct of Drills and Exercises Advance knowledge of the scenario will be kept to a minimum to allow "free-play" decision making and to ensure a realistic participation by those involved. Prior to the drill or exercise, a package will be distributed to the controllers and evaluators that will include the scenario, a list of performance objectives, and a description of the expected responses.

For each emergency preparedness exercise or drill conducted, a scenario package is developed that includes at least the following:

a. The basic objective(s) of the drill or exercise and the appropriate evaluation criteria.

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PART II: Planning Standards And Criteria Exelon Nuclear Emergency response personnel in the following categories receive knowledge and/or performance based training initially and retraining thereafter once per calendar year not to exceed 18 months between training sessions.

a. Directors. Managers and Coordinators within the station and corporate ERO:

Personnel identified by the Emergency Response Organization Telephone Directory as Directors, Managers and Coordinators for the station and corporate EROs receive training appropriate to their position in accordance with the approved ERO Training Program. These personnel receive specialized training in the areas of:

• Notifications

• Emergency Classifications

• Protective Action Recommendations

• Emergency Action Levels

• Emergency Exposure Control Selected Directors, Managers, Coordinators and Shift Emergency Directors receive training in accordance with the approved ERO Training Program. Training in accident assessment sufficient to classify an event and to mitigate the consequences of an event are also covered.

b. Personnel Responsible for Accident Assessment:

The skills and knowledge required to perform plant stabilization and mitigation are a normal function of operations specific positions, as identified in Section B of this plan. Subsequent plant stabilization and restoration is pursued utilizing normal operating procedures. Qualified Operators receive routine training to ensure proficiency in this area.

1) Certified Fuel Handlers shall have training conducted in accordance with the approved ERO Training Program such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

• Event Classification.

• Protective Action Recommendations.

• Radioactive Release Rate Determination.

• Notification form completion and use of the Nuclear Accident Reporting System (NARS).

• Federal , state and local notification procedures as appropriate.

• Site specific procedures for activating the onsite and offsite ERO.

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PART II: Planning Standards And Criteria Exelon Nuclear

c. Radiological Monitoring Teams and Radiological Analysis Personnel

1) Offsite Radiological Monitoring: Offsite radiological monitoring is performed by trained individuals who provide samples and direct readings for dose assessment calculations and dose projection comparisons.

Personnel identified as members of Field Monitoring Teams receive training in accordance with the approved training program. Field Monitoring Team members receive classroom and hands-on training in the following areas:

• Equipment and Equipment Checks

• Communications

• Plume Tracking Techniques

2) Personnel Monitoring: Personnel monitoring is performed by trained individuals who monitor station personnel and their vehicles for contamination during an emergency. Personnel Monitoring Team members receive classroom and hands-on training in the following areas:

• Personnel Monitoring Equipment and Techniques

• Decontamination Techniques for Personnel

• Decontamination Techniques for Vehicles

3) Dose Assessment: Dose Assessment training includes the skills and knowledge necessary for calculation and interpretation of an offsite release and its impact on the environment under varying meteorological conditions.

Individuals responsible for performing dose assessment are trained in the following areas:

• Computerized Dose Assessment

• Protective Action Recommendations

• Field Monitoring Team Interface

• Protective Action Guidelines associated with offsite plume exposu re doses

• Basic Meteorology November 2021 0-4 EP-DR-1000 (Revision x)

PART II: Planning Standards And Criteria Exelon Nuclear Section P: Responsibility for the Maintenance of the Planning Effort This section describes the responsibilities for development, review and distribution of the E-Plan and actions that must be performed to maintain the emergency preparedness program. It also outlines the criteria for insuring that personnel who perform the planning are properly trained.

1. Emergency Preparedness Staff Training The Emergency Preparedness staff is involved in maintaining an adequate knowledge of state of the art planning techniques and the latest applications of emergency equipment and supplies. At least once each calendar year each member of the Emergency Preparedness staff is involved in one of the following activities:

• Training courses specific or related to emergency preparedness.

• Observation of or participation in drills and/or exercises at other stations.

• Participation in industry review and evaluation programs.

• Participation in regional or national emergency preparedness seminars, committees, workshops or forums.

• Specific training courses in related areas, such as systems, equipment, operations, radiological protection, or Problem Identification & Resolution (Pl&R).

2. Authority for the Emergency Preparedness Effort The Plant Manager is responsible for the safe and reliable operation of the station. The issuance and control of this plan and the activities associated with emergency preparedness at Dresden shall be the overall responsibility of the Vice President, Fleet Support. This individual is assigned the responsibility for overall implementation of the E-Plan and station Annex.

3. Responsibility for Development and Maintenance of the Plan Each regional Emergency Preparedness Manager is responsible for the overall radiological emergency preparedness program associated with the operation of the nuclear power stations within their respective region and to administer the program to ensure availability of resources in the event of an emergency. The regional Emergency Preparedness Managers report to an EP Director who in turn reports to the Vice President, Fleet Support.

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