LR-N14-0141, Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accid.

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Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accid.
ML14168A375
Person / Time
Site: Salem  PSEG icon.png
Issue date: 06/16/2014
From: Jamila Perry
Public Service Enterprise Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
LR-N14-0141
Download: ML14168A375 (48)
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Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 PSEG Nudear!LC 10 CFR 50.54(f)

LR-N14-0141 JUN 16.2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Salem Generating Station Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Salem Generating Station's Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment

References:

1. NRC letter, "Request for Information Pursuant to Title 10 of the Code of Fedral Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012
2. PSEG letter LR-N12-0143, "PSEG Nuclear LLC's 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident: dated March 12, 2012," dated May 10, 2012
3. NEI 12-01, "Guideline for Assessing Beyond-Design-Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012

JUN 1 6 ?014 10 CFR 50.54(f)

Page 2 LR-N14-0141

4. NRC letter to NEI, "U.S. Nuclear Regulatory Commission Review of NEI 12-01, 'Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,' Revision 0, Dated May 2012," dated May 15, 2012
5. PSEG letter LR-N13-0083, "Salem Generating Station's Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness- Staffing, Requested Information Items 1, 2, and 6 -

Phase 1 Staffing Assessment," dated April 26, 2013

6. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

Background

On March 12, 2012, the NRC staff issued a request for information pursuant to 10 CFR 50.54(f), regarding the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident (Reference 1). Enclosure 5 of Reference 1 contains the specific Requested Actions, Requested Information, and Required Response associated with Recommendation 9.3 for Emergency Preparedness - Staffing. In accordance with Reference 1, Enclosure 5, PSEG Nuclear LLC (PSEG) submitted a 60-day response letter (Reference 2) to describe its course of action for performing the requested actions and providing the requested information. Consistent with the actions described in Reference 2, the Phase 2 responses to the NTTF Recommendation 9.3:

Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6, are provided herein for SGS Units 1 and 2.

PSEG's staffing assessment follows a two-phased approach for evaluating a beyond design-basis, large scale external event, consistent with the guidance of NEI 12-01 (Reference 3) as endorsed by the NRC in Reference 4. PSEG provided the results of Phase 1 of the assessment via Reference 5. Phase 1 addresses the staffing levels that are needed to respond to a multi-unit, beyond-design-basis external event (BDBEE) that results in an extended loss of alternating current (AC) power and impeded access to the site, not including the staffing needed to implement actions that address NRC Order EA-12-049 (Reference 6). The Phase 2 assessment provided herein addresses staffing to implement diverse and flexible coping strategies (FLEX) in response to NRC Order EA-12-049.

JUN 1 6 "014 10 CFR 50.54(f)

Page 3 LR-N14-0141 Enclosure 1 to this letter provides the Phase 2 staffing assessment report for SGS Units 1 and 2. In accordance with Reference 2, Enclosure 1, this letter provides the response to the following information requests:

  • Reference 1, Enclosure 5, Staffing, Requested Information Item 1
  • Reference 1, Enclosure 5, Staffing, Requested Information Item 2
  • Reference 1, Enclosure 5, Staffing, Requested Information Item 6 Requested Information Item 1 It is requested that addressees provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the Discussion section (Reference 1, Enclosure 5). This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:
  • How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the Order regarding the NRC Near- Term Task Force ( NTTF) Recommendation
4. 2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-1, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.
  • New staff or functions identified as a result of the assessment.
  • Collateral duties (personnel not being prevented from timely performance of their assigned functions).

Response to Requested Information Item 1 Enclosure 1 provides the requested Phase 2 staffing assessment. Response to the specific items included in Requested Information Item 1 is as follows

  • The Phase 2 assessment concludes that the minimum complement of on-shift staff allowed by the current PSEG Emergency Plan, combined with two additional on-shift personnel to support site-wide (i.e., Hope Creek and SGS) equipment hauling and debris removal, are capable of responding to the Phase 2 scenario.

This assessment considers the major functional areas associated with on-site implementation of the FLEX strategies, including the relocation of equipment from storage areas to deployment locations. The staffing assessment also addresses the ability of the on-shift staff to perform any required emergency

JUN *1 6 ?014 1 0 CFR 50.54(f)

Page 4 LR-N14-0141 response functions prior to the delayed arrival of the augmented Emergency Response Organization (ERO).

  • Based on the results of this assessment, PSEG will establish administrative controls to ensure the availability of the two on-shift individuals assigned to the functions of site-wide equipment hauling and debris removal in support of FLEX strategy implementation.
  • The staffing assessment determined that personnel were not prevented from timely performance of their functions due to collateral duties. There are no conflicts or overlaps in functions or tasks required to be performed by on-shift operations and support personnel.

Requested Information Item 2 Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate, please include in the schedule the time to implement the changes.

Response to Requested Information Item 2 PSEG has initiated the changes to administrative controls for shift staffing to ensure the availability of personnel to support equipment hauling and debris removal. These changes are tracked in PSEG's corrective action program and are planned to be completed on a schedule consistent with FLEX strategy implementation prior to restart from the Salem Unit 1 23rd refueling outage in the Fall of 2014.

Requested Information Item 6 Identify changes that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all ac power, multiunit event, including any new or revised agreements with offsite resource providers (e. g. , staffing, equipment, transportation, etc. ).

Response to Requested Information Item 6 The Phase 2 staffing assessment provided in Enclosure 1 did not identify any changes to the Emergency Plan requirements for on-shift staffing, augmented staffing, or agreements with offsite resource providers.

There are no regulatory commitments contained in this letter.

JUI 16 ,U14 10 CFR 50.54(f)

Page 5 LR-N14-0141 If you have any questions or require additional information, please do not hesitate to contact Mr. Lee Marabella at 856-339-1208.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on __ C-./_t_,-+-/_1__'1_:

( Date )

Sincerely, Jf.:**

Site Vice President Salem Generating Station : Salem Generating Station - Fukushima Response NEI 12-01 Phase 2 Staffing Assessment Report cc: Mr. E. Leeds, Director of Office of Nuclear Reactor Regulation Mr. W. Dean, Administrator, Region I, NRC Mr. J. Lamb, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Manager IV, NJBNE Salem Commitment Tracking Coordinator PSEG Corporate Commitment Coordinator

LR-N14-0141 Enclosure 1 Salem Generating Station - Fukushima Response NEI 12-01 Phase 2 Staffing Assessment Report

SALEM GENERATING STATtON FUKUSHIM'A RESPONSE.

NEI12 Q1 PHASE. 2 STAFFlNG ASSESSMENT REPORT Facilitated for PSEG Nuclear LLC by EP Consulting, LLC

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report Table of Contents

1. Executive Summary............................................................................................................... 1
2. Introduction ............................................................................................................................ 1
3. Staffing Assessment Process Overview ................................................................................ 2
4. NEI 12-01 Phase 2 Assessment Results ............................................................................... 4
5. NEI 12-01 Phase 2 Actions ................................................................................................... 5
6. Staffing Assessment Details .................................................................................................. 5 6.1 Assumptions ................................................................................................................... 6 6.1.1 NEI 12 Assumptions for Staffing Assessment ................................................. 6 6.1.2 NEI 10 Applicable Assumptions ....................................................................... 7 6.1.3 NEI 12-06 Assumptions ........................................................................................... 7 6.1.4 Plant Specific Assumptions ..................................................................................... 9 6.2 Methodology ................................................................................................................... 9 6.3 Security Considerations ................................................................................................ 11
7. Strategy Resource Loading ................................................................................................. 11
8. Conclusions ......................................................................................................................... 14
9. References .......................................................................................................................... 14
10. Table of Acronyms ............................................................................................................... 15 i

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report

1. Executive Summary PSEG Nuclear LLC (PSEG) conducted an assessment of the capability of the on-shift organization as defined by the Emergency Plan, Fire Protection staffing procedures, and Operations shift staffing procedures to implement mitigation strategies in response to a beyond-design-basis extended loss of AC power (ELAP) event, based on lessons learned from the Fukushima Dai-ichi accident. The on-shift staffing analysis was facilitated by EP Consulting, LLC and was conducted in accordance with the guidance in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities. This report describes the methods and results of the staffing assessment for Salem Generating Station (SGS) Units 1 and 2. It takes into account actions that would be taken by Hope Creek Generating Station (HCGS) and actions of shared site resources such as the Fire Brigade and personnel for equipment hauling and debris removal.

This assessment concluded that sufficient on-shift resources are available at all times to implement the strategies developed to maintain or restore core cooling, containment and spent fuel pool cooling during a beyond-design-basis external event (BDBEE) that results in an ELAP affecting all on-site units simultaneously. The personnel that are assumed to be on-site during the BDBEE are part of the minimum complement allowed by the PSEG Emergency Plan, except for two personnel resources that are assumed to be available on site for equipment hauling and debris removal. These two personnel resources are part of the 12-hour shift providing continuous on-site coverage and will be subject to administrative controls for shift staffing to support the SGS and HCGS BDBEE mitigation strategies.

2. Introduction This report documents the analysis performed to meet the commitments for conducting a staffing assessment for a BDBEE at a multi-unit site affecting all units. This report is in response to the Nuclear Regulatory Commissions (NRCs) March 12, 2012, request for information pursuant to 10 CFR 50.54(f) regarding the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident (Reference 1). The assessment uses NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communication Capabilities, (Reference 2) and NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, (Reference 3) to determine the response of on-shift and augmented resources to an ELAP incident impacting all units at a site. The assessment addresses Phase 2 of the analysis applicable to implementation of existing and FLEX strategies for an ELAP, which is applicable to all units at a multi-unit site during the initial and transition phases of the event, utilizing the methodology of NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities (Reference 4). The assessment was performed to support the SGS response.

The assessment was conducted using draft FLEX Support Guidelines (FSGs) in place as of February 27, 2014 and draft revisions to Operations procedures. The assessment 1

Salem Generating Sttation NEI 12-0 01 Phase 2 Staffing S Asse essment Report considerrs required actions performed during the inittial and tran nsition phasses of an EELAP (first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />). Co onsistent with NEI 12-0 01 and NEII 12-06, nea ar-normal ssite access and the abilitty to receive and deplo oy offsite re esources arre considerred to be esstablished during thhe final pha ase (24+ ho ours followinng the ELA AP).

3. Stafffing Asses ssment Pro ocess Ove erview Draft strrategies inc cluding FSG Gs for respo onding to ann ELAP affe ecting all on n-site units (SGS Un nits 1 and 2,2 and HCG GS) were ev valuated du uring the NEEI 12-01 Ph hase 2 stafffing analysis s by a multi--discipline team.

t The staffing ana alysis also addressed the ability of the on-s shift staff to perform an ny required emergencyy response e functions p prior to the delayed arrival of th he augmen nted Emerge ency Respo onse Organ nization (ERRO).

The Pha ase 2 staffin ng assessm ment require es that the ELAP scen nario be eva aluated usin ng the minimum staffin ng in the PS SEG Emerg gency Plan (consisten nt with NEI 12-01) alon ng with the supplemen ntal staff allowed by minimum m administrativee staffing prrocedures (consiste ent with NE EI 12-06). Table T 3-1 iddentifies the e personne el that were used to impleme ent the strattegies cons sidered in thhis staffing assessmen nt.

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Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report Table 3-1 Supplemental PSEG Nuclear LLC Emergency Plan, Rev 28 Administrative On-Shift Staffing Staff Emergency Response Organization (NEI 12-06)

Position On-shift On-Shift Shift Manager (SM) 1 Control Room Supervisor (SRO) 1 2 Field Supervisor/Initial Operations 1 Support Center (OSC) Coordinator Shift Technical Advisor (STA) 1 Reactor Operator (RO) 2 Plant Operator (RO) 2 Control Room Communicator 2 2 Equipment Operator (EO) 5 Radwaste Operator 3 (EO) 1 Radiation Protection (RP) 4 Technician 4 Chemistry Technician 5 2 Shift Maintenance Supervisor 1 8

Scheduled I&C Technician 2 Shift Electrician 8 2 Total: 28 6

Fire Department 5 Rescue Operations/First Aid 7 2 Security Sec plan MM resources9 2 1

One Unit Supervisor assigned to each unit.

2 Two Control Room Communicators for offsite notifications which typically includes one additional RO and one additional Equipment Operator.

3 This position is staffed by a dedicated Equipment Operator.

4 Two RP Technicians on shift per station. This assessment assumes the two SGS technicians are available, and did not use Hope Creek (HCGS) technicians to support SGS.

5 One Chemistry Technician per station, for a total of two, provides chemistry sampling support. This assessment assumes the SGS technician is available, and did not use the HCGS technician to support SGS.

6 Fire Department is a separate department serving the entire site. The Fire Brigade for each shift consists of one Fire Department Leader and five Fire Department Members.

7 Rescue Operations/First Aid are a collateral duty of the Fire Department.

8 One Instrumentation and Control (I&C) Technician and one Shift Electrician per station. This assessment assumes the SGS I&C Technician and Shift Electrician are available, and did not use HCGS personnel to support SGS.

9 Maintenance Mechanic (MM) refers to resources capable of performing debris removal and heavy equipment towing (see Appendix 1) 3

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report

4. NEI 12-01 Phase 2 Assessment Results The minimum on-shift staff as shown in Table 3-1 performed all actions required by operating and emergency plan procedures in the first one-hour period, relying only on installed structures, systems and components remaining in the initial phase of the response. PSEG determined that the draft FSGs were capable of being successfully implemented via table top exercise, using on-shift resources during the first six (6) hours and augmented responders from six (6) to twenty-four (24) hours.

No conflicts or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during this analysis. Transition phase actions were required within the first six hours of the event.

Resources that may be shared between SGS and Hope Creek (HCGS) such as RP Technicians and Chemistry Technicians were not used for the SGS analysis, with the exception of supplemental maintenance mechanics (MMs). One MM from each site was used. A parallel assessment for HCGS was conducted to ensure there was no conflict over resources shared with SGS.

An evaluation of each FSG was conducted in order to determine the resources needed and estimated duration of each task associated with the strategy. The total number of resources identified and task duration were then used to identify the two most resource limiting FLEX strategies. This analysis identified that the two most resource limiting FLEX strategies are:

Restoration of 125 vdc Battery Chargers (FSG-5, Attachment 1)

Ultimate Heat Sink (UHS) pump hookup and Service Water (SW) pressurization (FSG-5, Attachment 3).

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Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report

5. NEI 12-01 Phase 2 Actions During the tabletop procedural analysis, the following actions to support the conclusions of this staffing assessment were identified:
1. Revise Attachment 18 of OP-SA-112-101-1001, Shift Turnover Responsibilities (Reference 6) and Attachment 5 of OP-HC-112-101-1001, Shift Turnover Responsibilities (Reference 7), to reflect the addition of one Maintenance Mechanic resource for each station.
2. Review final FSGs and associated station procedure revisions against this staffing assessment and reconcile any significant differences (i.e., changes affecting staffing resource needs).
6. Staffing Assessment Details The Phase 2 Staffing Analysis for SGS was conducted on February 25, 2014, using the guidance of NEI 12-01, NEI 12-06 and NEI 10-05.

Table 6-1 identifies the personnel who participated in the assessment.

Table 6-1 Phase 2 Assessment Participants Personnel (Position/Title) Number Organization/Department Senior Reactor Operator 2 Fukushima Team (SRO) (formerly licensed at SGS)

Nuclear Control Operator 1 Fukushima Team (RO) (formerly licensed at SGS)

Nuclear Equipment 1 Operations Operator (NEO)

Radiation Protection 1 RP Technician Chemistry Superintendent 1 Chemistry EP Manager 1 EP Fire Department Supervisor 1 Site Protection Maintenance Supervisor 1 Maintenance EP Specialist 2 EP Consulting, LLC 5

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 6.1 Assumptions The extended loss of AC power event was evaluated using the following assumptions, consistent with NEI 12-01, NEI 12-06, and applicable assumptions from NEI 10-05.

6.1.1 NEI 12 Assumptions for Staffing Assessment

1. A large-scale external event occurs that results in:

all on-site units affected extended loss of AC power impeded access to the units

2. Initially, all on-site reactors are operating at full power and are successfully shut down.
3. No Hostile Action is directed at the affected site during the period that the site is responding to the event.
4. The event impedes site access as follows:

A. Post-event time: 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

B. Post-event time: 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).

C. Post-event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

5. On-shift personnel are limited to the minimum complement allowed by the Emergency Plan (i.e., the minimum required number for each required position), supplemented with additional on-shift staff consistent with NEI 12-06 (Assumption #12 in Subsection 6.1.3, below).
6. Following the accident at Fukushima Dai-ichi, the Institute of Nuclear Power Operations (INPO) issued three Industry Event Reports (IERs) requiring the assessment and implementation of a range of actions intended to improve the capabilities for responding to a BDBEE and ELAP, including events that impact the cooling of spent fuel. The Phase 2 staffing assessment includes the INPO IER improvement actions already implemented at the time of the assessment.

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Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 6.1.2 NEI 10 Applicable Assumptions

1. On-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.
2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.
3. Personnel assigned to the major response area of plant operations and safe shutdown meet the requirements and guidance established by NRC regulations and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown. Staff performance within this area is not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.
4. On-site security organization: Performance of this function is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.
5. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.
6. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.
7. The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions.
8. The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday). For purposes of this analysis, and consistent with NEI 12-01 Assumption #4, 360 minutes (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) will be used as the time period for the conduct of on-shift ERO response actions.

6.1.3 NEI 12-06 Assumptions

1. Prior to the event both units have been operating at 100 percent rated thermal power for at least 100 days or have just been shut down from such a power history as required by plant procedures in advance of the impending event.

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Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report

2. At the time of the postulated event, both units reactors and supporting systems are within normal operating ranges for pressure, temperature, and water level for the appropriate plant condition. All plant equipment is either normally operating or available from the standby state as described in the plant design and licensing basis.
3. No specific initiating event is used. The initial condition is assumed to be a loss of off-site power (LOOP) at a plant site resulting from an external event that affects the off-site power system either throughout the grid or at the plant with no prospect for recovery of off-site power for an extended period. The LOOP is assumed to affect all units at a plant site.
4. All installed sources of emergency on-site ac power and SBO Alternate ac power sources are assumed to be not available and not imminently recoverable.
5. Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles are available.
6. Normal access to the ultimate heat sink is lost, but the water inventory in the UHS remains available and robust piping connecting the UHS to plant systems remains intact. The motive force for UHS flow, i.e., pumps, is assumed to be lost with no prospect for recovery.
7. Fuel for FLEX equipment stored in structures with designs which are robust with respect to seismic events, floods and high winds and associated missiles, remains available.
8. Permanent plant equipment that is contained in structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles, are available.
9. Other equipment, such as portable ac power sources, portable back up dc power supplies, spare batteries, and equipment for 50.54(hh)(2), may be used provided it is reasonably protected from the applicable external hazards per Sections 5 through 9 and Section 11.3 of this guidance and has predetermined hookup strategies with appropriate procedures/guidance and the equipment is stored in a relative close vicinity of the site
10. Installed electrical distribution system, including inverters and battery chargers, remain available provided they are protected consistent with current station design.
11. No additional events or failures are assumed to occur immediately prior to or during the event, including security events.
12. On-site staff is at administrative minimum shift staffing levels per Section 2 of the NEI 12-06 guidance. All personnel on-site are available to support site response.

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Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report

13. Reliance on the fire protection system ring header as a water source is acceptable only if the header meets the criteria to be considered robust with respect to seismic events, floods, and high winds, and associated missiles.

6.1.4 Plant Specific Assumptions

1. Spent Fuel Pool Time-to-Boil is 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> from the time of the loss of Fuel Pool Cooling based on 100 days of operations since refueling outage with a heat up rate of 2.1 F/hour (reference S1(2).OP-AB.SF-001).
2. The AFW Storage Tank has a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> capacity as the turbine-driven auxiliary feedwater (TD AFW) pump source during seismic events.
3. The AFW Storage Tank is unavailable as the TD AFW pump source during hurricane (high wind) and tornado events.
4. The 28 vdc batteries have greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of capacity with implementation of deep load shed.
5. The 125 vdc batteries have greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of capacity with implementation of deep load shed.
6. NEOs have access to vital area door keys to allow access to areas/rooms without security support.
7. Two FLEX diesel generators are staged in the area between the Unit 2 auxiliary and fuel handling buildings (canyon area) and are reasonably protected from external events. The canyon area is provided with temporary flood protection.

6.2 Methodology An assessment of on-shift staffing was performed using NEI 12-01, NEI 12-06 and NEI 10-05. Subject matter experts and consultants were assembled to provide analysis support. The assessment was conducted via a tabletop procedural analysis using SGS procedures to determine if tasks have been sufficiently analyzed for performance by the minimum on-shift staff as designated in the Emergency Plan and supplemental administrative staff. The following provides a summary of the process that was used.

The existing on-shift staff structure and size is defined by Figure 3-1 of the PSEG Emergency Plan (Reference 5) and References 6 through 9.

Each on-shift position used in this staffing analysis was entered in Appendix 1, Table 1.

For position titles with more than one position holder, a unique sequential number was assigned to each position. The PSEG Emergency Plan reference that describes the requirement for the position to be on-shift was then entered into column 3 of Appendix 1, Table 1.

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Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report Using only the on-shift positions entered in Appendix 1, Table 1, the following Appendix 1 tables were completed by entering the shift position that fills a described role, or performs a specific function or task:

Table 2, Plant Operations & Safe Shutdown (Minimum Operations Crew Necessary to Implement AOPs and EOPs, FSGs or SAMGs if applicable)

Table 2A, Procedure Task Timing (Hurricane Response)

Table 2B, Procedure Task Timing (Tornado Response)

Table 3, Firefighting (not applicable for this event analysis)

Table 4, Radiation Protection & Chemistry Table 5, Emergency Plan Implementation Following completion of each of the above tables, each on-shift position assigned to the associated table was located on Appendix 1, Table 1. For each position, the table number and associated line number was then entered in column 4, Role in Table#/Line#. If the associated task required additional actions, a Yes was placed in the last column and the additional action was included in Section 5 of this report, i.e.,

establish administrative controls to ensure the availability of personnel to perform debris removal and equipment hauling.

The assessment was conducted using the following process:

1. Selection of the multi-disciplined work group
2. Scheduling the tabletop with access to required procedures and administrative documents
3. Conduct of a pre-job briefing outlining the requirements of NEI 12-01, NEI 12-06 and NEI 10-05
4. Review of the event initial conditions and assumptions
5. Performance of the tabletop procedural analysis
6. Documentation of the results of the tabletop by EP Consulting using the NEI 10-05 forms modified to extend to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This review provided the team with a basic understanding of the event and resulting emergency classifications. The SRO reviewed EOP, AOP and FSG actions and identified them to the team. Specific site procedures referenced during assessment of this postulated event are provided in Tables 2A and 2B. Specific resources needed to perform initial event response actions were identified from the EOP, AOP, or FSG procedures and documented. The team determined when other on-shift resources, such as the RP or Chemistry Technician, would be required and identified the time required to perform expected emergency plan functions. This information was documented on the applicable tables in Appendix 1 of this report. Finally, the on-shift resources and their actions were summarized in the tables using the NEI 10-05 documentation process in Appendix 1, Table 1.

10

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 6.3 Security Considerations Mitigation strategies for a BDBEE do not require the use of Security Department personnel to perform duties unrelated to their security roles, e.g., the SGS mitigation strategies do not rely on Security Officers to perform any collateral duties such as equipment hauling or debris removal.

7. Strategy Resource Loading An evaluation of each FSG was conducted to determine the resources needed and estimated duration of each task associated with the strategy. This evaluation is not associated with any specific event. Resource loading analyses are contained in Table 7-1.

Table 7-1 FLEX Support Guideline (FSG) Resource Requirements FSG Description Resources Duration Notes FSG-1 RCS Long Term RCS EO (4) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Contingency Inventory Control (Service RO (2) Action Water to 13 Charging Pump)

FSG-2 Alternate Aux Feedwater EO (2) 55 Time sensitive -

Suction Source (align to SP (2) minutes S/G Inventory HCGS FP Tank)

FSG-3 Alternate Low Pressure EO (4) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Time sensitive -

Feedwater S/G Inventory FSG-4 ELAP DC Bus Load EO (2) 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Time sensitive -

Shed/Management extend battery capacity FSG-5 Initial Assessment and Flex Equipment Staging Vent generator H2 (both SP (1) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Task completed units) in series by one person Att 1, Part Restore 125 vdc Battery EO (2) 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Time sensitive -

1 Chargers EM (1) battery charger restoration Att 1, Part Restore 230 vac MCCs EO (2) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> N/A 2

Att 2 Debris Removal and MM (2) 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Performed in Equipment Transport for conjunction with Salem HCGS debris removal and deployment (HCGS - 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) 11

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report FSG Description Resources Duration Notes Att 2 Energize Flex 480 vac bus EO (2) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Time sensitive -

bus restoration Att 2 Energize the A 460/230 bus. EO (2) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Time sensitive -

bus restoration Att 3 Debris removal and pump MM (2) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Time sensitive -

deployment (UHS) S/G Inventory Att 3 UHS pump hookup and SW Sec (1) 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Time sensitive -

header pressurized EO (2) S/G Inventory MM(2) (augmented resources used)

Att 7 Feed Steam Generators EO (2) continuous Time sensitive -

S/G Inventory FSG-6 Alternate Aux Feedwater N/A N/A Not required Storage Tank Makeup during initial or transition phase FSG-7 Loss of Vital Instrumentation or Control Power Att 1 Addressed by FSG 5 N/A N/A N/A Att 2 Manual Steam Generator EO (4) 30 Contingency Pressure Control minutes Action Att 3 Steam Generator Pressure EO (4) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Contingency Action Att 4 RCS Pressure Indication IC (1) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Contingency Action Att 5 Alternate CETs IC (1) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Contingency Action Att 6 Containment Pressure IC (1) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Contingency Indication Action Att 7 Aux Feedwater Storage Tank EO (1) 30 Contingency Level Indication minutes Action Att 8 Pressurizer Level Indication IC (1) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Contingency Action Att 9 Refueling Water Storage Tank EO (1) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Contingency Level Indication Action FSG-8 Alternate RCS Boration (Flex EO (4) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Contingency Charging pump from Boric Action Acid Storage Tank)

FSG-9 Low Decay Heat Temperature EO (2) 30 Contingency Control RO (2) minutes Action FSG-10 Passive RCS Injection RO (2) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> N/A Isolation FSG-11 Alternate Spent Fuel Pool EO ( 2) 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Not required Makeup and Cooling (Makeup during initial or from Fresh/Fire Protection) transition phase 12

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report FSG Description Resources Duration Notes FSG-12 Alternate Containment N/A N/A Not required Cooling during initial or transition phase FSG-13 Transition from FLEX N/A N/A Not required Equipment during initial or transition phase Time Sensitive Task 13

8. Conclusions The existing on-shift staff structure and size is described in the documents referenced in Section 6.2 of this report. Collectively these documents describe a staff structure and size that is sufficient to carry out the FSG actions for the most limiting BDBEE situations.

One resource (currently designated as MM in the Appendix 1 tables) is being added to References 6 and 7 for Salem and Hope Creek, respectively. For the purposes of this analysis the team assumed that one resource capable of performing debris removal and equipment towing assigned to Salem and one assigned to Hope Creek would be available as anticipated by FSG-5. However, any qualified personnel who are not already assigned to minimum shift staffing / emergency response / Fire Brigade roles may be so assigned.

9. References
1. NRC letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, March 12, 2012
2. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012
4. NEI 10-5, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0, June 2011
5. PSEG Nuclear LLC Emergency Plan Revision 28
6. OP-SA-112-101-1001 Revision 3, Shift Turnover Responsibilities (Attachment 18)
7. OP-HC-112-101-1001 Revision 18, Shift Turnover Responsibilities (Attachment 5)
8. FP-AA-012 Revision 2, Fire Protection Organization, Duties and Staffing
9. OP-AA-101-111 Revision 4, Roles and Responsibilities of On-Shift Personnel 14
10. Table of Acronyms Acronym Definition AC Alternating Current AFW Auxiliary Feed Water AOP Abnormal Operating Procedure BDBEE Beyond-Design-Basis External Event B/O Blackout BOP Balance of Plant CFST Critical Function Status Tree CT Chemistry Technician DC Direct Current DG Diesel Generator ELAP Extended Loss of AC Power EM Electrical Maintenance EO Equipment Operator EOP Emergency Operating Procedure EP Emergency Plan ERO Emergency Response Organization (on shift and supplemental)

FB Fire Brigade FLEX Diverse and Flexible Coping Strategies FP Fire Protection FSG FLEX Support Guideline H2 Hydrogen HCGS Hope Creek Generating Station I&C Instrumentation and Control IER Industry Event Report 15

Acronym Definition INPO Institute of Nuclear Power Operations LOOP Loss of Off-site Power MCC Motor Control Center MDAFP Motor-driven Auxiliary Feedwater Pump MM Maintenance Mechanic NEI Nuclear Energy Institute NEO Nuclear Equipment Operator NRC Nuclear Regulatory Commission OATC Operator at the Controls ORO Offsite Response Organization OSA On-Shift Staffing Analysis OSC Operations Support Center PO Plant Operator PSEG Public Service Enterprise Group LLC RCS Reactor Coolant System RO Reactor Operator RP Radiation Protection SAMG Severe Accident Management Guideline SBO Station Blackout SAS/CAS Secondary Alarm Station/Central Alarm Station SEC1 Security - SAS/CAS Operator SEC Safeguards Equipment Controller SGS Salem Generating Station SM Shift Manager SMS Shift Maintenance Supervisor SP Site Protection 16

Acronym Definition SRO Senior Reactor Operator STA Shift Technical Advisor SW Service Water TD Turbine-driven TSC Technical Support Center U1 Unit 1 U2 Unit 2 UHS Ultimate Heat Sink 17

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report Appendix 1 - Staffing Tables

Salem Generating Station Operations On-Shift Personnel Assignments Used During Analysis Position Designation Assignment Shift Manager SM Shift Manager/Emergency Director Control Room SRO1 Unit 1 Control Room Supervisor Supervisor Control Room SRO2 Unit 2 Control Room Supervisor Supervisor Field Supervisor SRO3 Field Supervisor/Initial OSC Coordinator Shift Technical STA Shift Technical Advisor Advisor Reactor Operator RO1 Unit 1 Operator At Controls (OATC)

Plant Operator PO1 Unit 1 Balance of Plant (BOP)

Reactor Operator RO2 Unit 2 Operator At The Controls (OATC)

Plant Operator PO2 Unit 2 Balance of Plant (BOP)

CR Communicator CM1 Offsite Communications CR Communicator CM2 Offsite Communications Equipment Operator EO1 Unit 1 Aux Building EO Equipment Operator EO2 Unit 2 Aux Building EO Equipment Operator EO3 Unit 1 Turbine Building EO Equipment Operator EO4 Unit 2 Turbine Building EO Equipment Operator EO5 Outside EO Equipment Operator EO6 Radwaste Operator

Other On-Shift Personnel Assignments Used During Analysis Position Designation Assignment RP Technician RP1 Offsite Dose Assessment (SRPT)

RP Technician RP2 RP Support (ORPT)

Chemistry Technician CT1 Chemistry Sampling/Count Room Shift Maintenance SMS OSC Coordinator Supervisor Scheduled I&C IC1 I&C Maintenance Support Technician Shift Electrician EM1 Electrical Maintenance Support Site Protection SP1 Fire Department Chief Site Protection SP2 Fire Department Responder Site Protection SP3 Fire Department Responder Site Protection SP4 Fire Department Responder Site Protection SP5 Fire Department Responder SAS/CAS Operator SEC1 Accountability Maintenance MM1 Maintenance Maintenance MM2 Maintenance

APPENDIX 1 Loss of all AC Power TABLE 1 - On-shift Positions Role in Action Line On-shift Position Emergency Plan Reference Table#/Line# Required?

1. Shift Manager/SM PSEG Nuclear LLC - EP, Figure T2/L1 No 3-1 T5/L1 T5/L2 T5/L3 T5/L5 T5/L6 T5/L7 T5/L9 T5/L13
2. Control Room Supervisor - U1 (SRO1) PSEG Nuclear LLC - EP, Figure T2/L2 No 3-1
3. Control Room Supervisor - U2 PSEG Nuclear LLC - EP, Figure T2/L3 No (SRO2) 3-1
4. Reactor Operator - U1 OATC (RO1) PSEG Nuclear LLC - EP, Figure T2/L4 No 3-1
5. Plant Operator - U1 BOP (PO1) PSEG Nuclear LLC - EP, Figure T2/L5 No 3-1
6. Reactor Operator - U2 OATC (RO2) PSEG Nuclear LLC - EP, Figure T2/L6 No 3-1
7. Plant Operator - U2 BOP (PO2) PSEG Nuclear LLC - EP, Figure T2/L7 No 3-1
8. Shift Technical Advisor (STA) PSEG Nuclear LLC - EP, Figure T2/L8 No 3-1
9. CR Communicator (CM1) PSEG Nuclear LLC - EP, Figure T2/L15 No Note 1 (Equipment Operator) 3-1 T5/L8

Role in Action Line On-shift Position Emergency Plan Reference Table#/Line# Required?

10. CR Communicator (CM2) PSEG Nuclear LLC - EP, Figure T2/L16 No Note 1 (Reactor Operator) 3-1 T5/L8 T5/L12
11. Equipment Operator (EO1) PSEG Nuclear LLC - EP, Figure T2/L9 No 3-1
12. Equipment Operator (EO2) PSEG Nuclear LLC - EP, Figure T2/L10 No 3-1
13. Equipment Operator (EO3) PSEG Nuclear LLC - EP, Figure T2/L11 No 3-1
14. Equipment Operator (EO4) PSEG Nuclear LLC - EP, Figure T2/L12 No 3-1
15. Equipment Operator (EO5) PSEG Nuclear LLC - EP, Figure T2/L13 No 3-1
16. Equipment Operator - Radwaste PSEG Nuclear LLC - EP, Figure T2/L14 No Operator (EO6) 3-1
17. RP Technician (RP1) PSEG Nuclear LLC - EP, Figure T4/L1 No 3-1
18. RP Technician (RP2) PSEG Nuclear LLC - EP, Figure T4/L3 No 3-1
19. Shift Maintenance Supervisor (SMS) PSEG Nuclear LLC - EP, Figure T2/L17 No 3-1
20. Scheduled I&C Technician (IC1) PSEG Nuclear LLC - EP, Figure T2/L18 No 3-1
21. Shift Electrician (EM1) PSEG Nuclear LLC - EP, Figure T2/L19 No 3-1
22. Site Protection (SP2) PSEG Nuclear LLC - EP, Figure T2/L20 No 3-1
23. Site Protection (SP3) PSEG Nuclear LLC - EP, Figure T2/L21 No 3-1

Role in Action Line On-shift Position Emergency Plan Reference Table#/Line# Required?

24. Site Protection (SP4) PSEG Nuclear LLC - EP, Figure T2/L22 No Note 2 3-1
25. Site Protection (SP5) PSEG Nuclear LLC - EP, Figure T2/L23 No 3-1
26. Maintenance Mechanic (MM1) N/A T2/L24 Yes Note 3
27. Maintenance Mechanic (MM2 - N/A T2/L25 Yes Note 3 HCGS)
28. Security PSEG Nuclear LLC - EP, Figure T5/L14 No 3-1 Notes: Note 1 - No conflict; Table 2 and Table 5 functions are the same.

Note 2 - Assumes that venting hydrogen from generators will be addressed as part of FSG-5 approval and familiarization.

Note 3 - Establish administrative controls to ensure availability of on-shift MMs.

APPENDIX 1 TABLE 2 - Plant Operations & Safe Shutdown Two Units - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, FSGs, or SAMGs if applicable Task Line Generic Title/Role On-Shift Position Performance Validation

1. Shift Manager Shift Manager Operator Training
2. Shift Supervisor Control Room Supervisor - U1 Operator Training (SRO1)
3. Shift Supervisor Control Room Supervisor - U2 Operator Training (SRO2)
4. Reactor Operator Reactor Operator - U1 (RO1) Operator Training (OATC)
5. Reactor Operator Plant Operator - U1 (PO1) Operator Training (BOP)
6. Reactor Operator Reactor Operator - U2 (RO2) Operator Training (OATC)
7. Reactor Operator Plant Operator - U2 (PO2) Operator Training (BOP)
8. Shift Technical Advisor Shift Technical Advisor (STA) Operator Training
9. Auxiliary Operator Equipment Operator (EO1) Operator Training
10. Auxiliary Operator Equipment Operator (EO2) Operator Training
11. Auxiliary Operator Equipment Operator (EO3) Operator Training
12. Auxiliary Operator Equipment Operator (EO4) Operator Training
13. Auxiliary Operator Equipment Operator (EO5) Operator Training
14. Auxiliary Operator Equipment Operator (EO6) Operator Training
15. Auxiliary Operator Control Room Communicator EP Training (CM1)
16. Reactor Operator Control Room Communicator EP Training (CM2)

Notes: See Tables 2A and 2B for AOP/EOP/FSG support actions for hurricane and tornado BDBEE, respectively.

APPENDIX 1 TABLE 2 - Plant Operations & Safe Shutdown (continued)

Two Units - One Control Room Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, FSGs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation Shift Maintenance Shift Maintenance Supervisor EP/Maintenance 17.

Supv (SMS) Training I&C Technician Scheduled I&C Technician I&C Training 18.

(IC1)

Electrician Shift Electrician (EM1) Electrical Mnt 19.

Training

20. Fire Brigade Site Protection (SP2) Fire Brigade Training
21. Fire Brigade Site Protection (SP3) Fire Brigade Training
22. Fire Brigade Site Protection (SP4) Fire Brigade Training
23. Fire Brigade Site Protection (SP5) Fire Brigade Training Maintenance Maintenance Mechanic (MM1) Maintenance 24.

Training Maintenance Maintenance Mechanic (MM2) Maintenance 25.

(HCGS) Training Notes: See Tables 2A and 2B for AOP/EOP/FSG support actions for hurricane and tornado BDBEE, respectively.

APPENDIX 1 Table 2A - Procedure Task Timing (Hurricane Response)

12-01 Phase 2 OSA applicable to Salem Generating Station Table 2A - Procedure Task Timing (Hurricane Response)

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-1 Post Trip Actions SRO1 Step 1-9 SRO2 RO1 x

PO1 RO2 PO2 S1-OP-SO-AF- Identify AF source.

0001 PO1 x

S2-OP-SO-AF- PO2 0001 FSG-2 Align AFW source EO1 x

(flood water) EO2 FSG-2 Monitor and control EO1 x

Aux Feed EO2 EP-EP-102 Enter Emergency SM Plan CM1 x x CM2 SMS EOP-CFST-1 Monitoring CFSTs STA x EOP-LOPA-1 Deenergize SECs PO1 Step 10 PO2 x

EO3 EO4 EOP-LOPA- Perform B/O coping PO1 1,step 10.1 actions, includes PO2 initial 125vdc load x EO5 shed. EO6

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-1 Vital Power RO1 x

Steps12-14 restoration RO2 EOP-LOPA-1 Start Diesel EO3 Steps12-15 Generators EO4 x

IC1 EM1 EOP-LOPA-1, Align charging Prioritized by step 18 pump suction SM as resources are available EOP-LOPA-1, Service water Prioritized by step 19 isolation SM as resources are available EOP-LOPA-1, SI Initiation and RO1 reset x step 21-23 RO2 EOP-LOPA-1, Remove control Prioritized by step 24 power from MDAFP SM as resources are available EOP-LOPA-1, Restore Off-site PO1 step 25 power x PO2 Per AB-LOOP-1 EOP-LOPA-1, Isolate RCP seals EO3 step 27 EO4 x EOP-LOPA-1, Isolate S/G RO1 x

step 28 RO2

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-1, ELAP declaration SM step 29 SRO1 x SRO2 EOP-LOPA-4 Implement FSG-4 Step 1 FSG-4 Perform the Deep EO5 Load shed.(1.5 hr x EO6 completion time)

FSG-5 Restore 125 and 28 EO3 Att. 1 Part 1 VDC battery EO4 x chargers EM1 FSG-5 Energize Flex 480 EO5 x

Att 2 VAC bus, EO6 FSG-5 Energize the A EO5 x

Att 2 460/230 bus. EO6 FSG-5 Vent generator H2 SP4 x FSG-5 Initiate Att 3 (SW),

ERO Augment Att 3 debris removal and MM1 x pump deployment MM2(HCGS)

(UHS)

FSG-5 UHS pump hookup ERO Augment Att 3 and SW header Sec (1) x pressurized Ops (2)

Maint (2)

FSG-3 Low Pressure AF Prioritized by SM as resources are available

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-4 Depressurize S/Gs RO1 x

Step 12-13 RO2 EOP-LOPA-4 Initiate FSG-8 Step 16.1 FSG-8 Alternate RCS RO1 Att 1 Section boration from Boric RO2 x (Periodic) 2.3 Acid Storage Tank. EO1 EO2 FSG-10 Isolate RO1 x

accumulators RO2 FSG-5 Energize remaining EO3 x

Att. 1 Part 2 230 VAC busses. EO4 EOP-LOPA-4 S/G RO1 Step 16.5 depressurization for x RO2 Long Term Cooling EOP-LOPA-4 Return to Step 3 RO1 Step 20 RO2 FSG-5 Fuel Flex Augment x x x x Generators EO (1)

Notes: Communications maintained with Equipment Operators at Aux Feedwater using sound powered phones and radios.

Pre-Augmentation Post-Augmentation Site Area Emergency Declaration - SS1 General Emergency Declaration - SG1 FLEX Strategy (FSG)

Task completion time estimate

APPENDIX 1 Table 2B - Procedure Task Timing (Tornado Response)

12-01 Phase 2 OSA applicable to Salem Generating Station Table 2B- Procedure Task Timing (Tornado Response)

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-1 Post Trip Actions SRO1 Step 1-9 SRO2 RO1 x

PO1 RO2 PO2 S1-OP-SO-AF- Identify AF source.

0001 PO1 x

S2-OP-SO-AF- PO2 0001 FSG-2 Align AFW source EO1 Feed Steam EO2 x Generators (HCGS SP2 (55 minute task)

FP Tank) SP3 FSG-2 Align AFW source and monitor fire SP5 x pump (FP crosstie)

FSG-5 Monitor and control EO1 x

Att 7 AFW EO2 EP-EP-102 Enter Emergency SM Plan CM1 x x CM2 SMS EOP-CFST-1 Monitoring CFSTs STA x

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-1 Deenergize SECs PO1 Step 10 PO2 x

EO3 EO4 EOP-LOPA- Perform B/O coping PO1 1,step 10.1 actions, includes PO2 initial 125vdc load x EO5 shed. EO6 EOP-LOPA-1 Vital Power RO1 x

Steps12-14 restoration RO2 EOP-LOPA-1 Start Diesel EO3 Steps12-15 Generators EO4 x

IC1 EM1 EOP-LOPA-1, Align charging Prioritized by step 18 pump suction SM as resources are available EOP-LOPA-1, Service water Prioritized by step 19 isolation SM as resources are available EOP-LOPA-1, SI Initiation and RO1 reset x step 21-23 RO2 EOP-LOPA-1, Remove control Prioritized by step 24 power from MDAFP SM as resources are available

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-1, Restore Off-site PO1 step 25 power x PO2 Per AB-LOOP-1 EOP-LOPA-1, Isolate RCP seals EO3 step 27 EO4 x EOP-LOPA-1, Isolate S/G RO1 x

step 28 RO2 EOP-LOPA-1, ELAP declaration SM step 29 SRO1 x SRO2 EOP-LOPA-4 Implement FSG-4 Step 1 FSG-4 Perform the Deep EO5 Load shed.(1.5 hr x EO6 completion time)

FSG-5 Debris removal and Att 2 towing.

MM1 (2.5 hrs)(HCGS) x MM2(HCGS) and an additional 1 hr for SGS FSG-5 Restore 125vdc EO3 Att. 1 Part 1 battery chargers EO4 x EM1 FSG-5 Energize Flex EO5 x

Att 2 480vac bus, EO6 FSG-5 Energize the A EO5 x

Att 2 460/230 bus. EO6

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 FSG-5 Vent the Main SP4 x Generator FSG-5 Initiate Att 3 (SW),

Att 3 debris removal and MM1 x

pump deployment MM2(HCGS)

(UHS)

FSG-5 UHS pump hookup ERO Att 3 and SW header Augmentation pressurized Sec (1) x Ops (2)

Maint (2)

FSG-2 Shift Aux feed EO (2) x suction to SW FSG-3 Low Pressure AF Prioritized by SM as resources are available EOP-LOPA-4 Depressurize S/Gs RO1 x

Step 12-13 RO2 EOP-LOPA-4 Initiate FSG-8 Step 16.1 FSG-8 Alternate RCS RO1 Att 1 Section boration from Boric RO2 X (Periodic) 2.3 Acid Storage Tank. EO1 EO2 FSG-10 Isolate RO1 x

accumulators RO2 FSG-5 Energize remaining EO3 x

Att. 1 Part 2 230vac busses. EO4

Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Hour 3 4 5 10 20 0- 0 0- 1 1 1 1 1 1 1 1 1 2 2 2 2 2 Step Task Resource - - 2 3 4 5 6 7 8 9 15 10 4 5 6 0 1 2 3 4 6 7 8 9 0 1 2 3 4 20 30 0 0 0 EOP-LOPA-4 S/G RO1 Step 16.5 depressurization for x RO2 Long Term Cooling EOP-LOPA-4 Return to Step 3 RO1 Step 20 RO2 FSG-5 Fuel Flex Augment x x x x generators EO (1)

Notes: Communications maintained with Equipment Operators at Aux Feedwater using sound powered phones and radios.

Pre-Augmentation Post-Augmentation Site Area Emergency Declaration - SS1 General Emergency Declaration - SG1 FLEX Strategy (FSG)

Task completion time estimate

APPENDIX 1 TABLE 3 - Firefighting Task Analysis Line Performed By Controlling Method

1. Not required by scenario N/A
2. Not required by scenario N/A
3. Not required by scenario N/A
4. Not required by scenario N/A
5. Not required by scenario N/A Notes: Fire Brigade response not required for this event.

APPENDIX 1 TABLE 4 - Radiation Protection & Chemistry Performance Time Period After Event Initiation Position Performing Minutes Hours Line Function/Task 10- 20- 30- 40- 50-0-10 1-2 2-3 3-4 4-5 5-6 6-7 7-8 8-9 9-10 20 30 40 50 60

1. In-Plant Survey X

On-Shift Position: RP1

2. Out of Plant Survey On-Shift Position: RP2
3. Personnel Monitoring X (Control Point Coverage)

On-Shift Position:

4. Job Coverage On-Shift Position:
5. Offsite Radiological Assessment On-Shift Position: RP
6. Other Site-Specific RP -

Describe:

On-Shift Position:

7. Chemistry function/task #1

- Describe:

On-Shift Position: CT1 Note 1

8. Chemistry function/task #2

- Describe:

On-Shift Position: CT1 Note 1 Notes: Note 1 - The Phase 2 scenario did not result in the use of this on-shift position.

Augmented resources available to support actions after T=6 hours - no actions identified requiring support.

TABLE 4 - Radiation Protection & Chemistry Performance Time Period After Event Initiation (hours)

Position Performing Line 10- 11- 12- 13- 14- 15- 16- 17- 18- 19- 20- 21- 22 Function/Task 11 12 13 14 15 16 17 18 19 20 21 22 23 24

1. In-Plant Survey On-Shift Position: RP1
2. Out of Plant Survey On-Shift Position: RP2
3. Personnel Monitoring On-Shift Position:
4. Job Coverage On-Shift Position:
5. Offsite Radiological Assessment On-Shift Position: RP/CSF
6. Other Site-Specific RP -

Describe:

On-Shift Position:

7. Chemistry function/task #1 -

Describe:

On-Shift Position: CT1

8. Chemistry function/task #2 -

Describe:

On-Shift Position: CT2 Notes: Augmented resources available to support actions after T=6 hours. No response actions identified requiring support.

APPENDIX 1 TABLE 5 - Emergency Plan Implementation Line Function/Task On-Shift Position

1. Declare the Emergency Classification Level (ECL) Shift Manager
2. Approve Offsite Protective Action Recommendations Shift Manager
3. Approve content of State/local notifications Shift Manager
4. Approve extension to allowable dose limits Not Required
5. Notification and direction to on-shift staff (e.g., to Shift Manager assemble, evacuate, etc.)
6. ERO notification Shift Manager Note 1
7. Complete State/local notification form Shift Manager
8. Perform State/local notifications CM1 CM2
9. Complete NRC event notification form Shift Manager
10. Activate ERDS Not Available
11. Offsite radiological assessment Not Available Note 2
12. Perform NRC notifications CM2
13. Perform other site-specific event notifications (e.g., INPO, Shift Manager ANI, etc.)
14. Personnel accountability Security Notes: Note 1 - Self activation of ERO based on event (wide spread loss of grid)

Note 2 - Dose Assessment capability is impacted by ELAP - no data available to perform dose assessment. In addition, no radiological release exists - dose assessment not required.

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