Text

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.
	ML13121A353
Person / Time
Site:	San Onofre
Issue date:	04/30/2013
From:	Bauder D; Southern California Edison Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	Download: ML13121A353 (52)
	v • d • e

Douglas R. Bauder Site Vice President & Station Manager San Onofre Nuclear Generating Station An EDISON INTERNATIONAL Company 10 CFR 50.54(f)

Apr; 1 30, 2013 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk 11555 Rockville Pike Washington, DC 20555-0001

Subject:

Docket No. 50-361 and 50-362 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 Oai-Ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness

- Staffing, Requested Information Items 1, 2, and 6 - Phase 1 Staffing Assessment for San Onofre Nuclear Generating Station, Units 2 and 3

References:

1. Letter dated March 12, 2012 from E. J. Leeds and M. R. Johnson, USNRC, to All Power Reactor Licensees, "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"

2. Letter from Douglas R. Bauder (SCE) to Document Control Desk (USNRC),

dated May 9, 2012, "Southern California Edison's 60-Day Response to March 12, 2012 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."

3. NEI12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012.

Dear Sir or Madam,

On March 12,2012, the NRC staff issued a letter entitled Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 9.3 of the Near-Term Task Force 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 10 CFR 50.54, "Conditions of licenses," paragraph (f), addressees were requested to submit a written response to the information requests within 90 days.

In accordance with Reference 1, Enclosure 5, Southern California Edison (SCE) submitted an alternative course of action for performing the requested actions and providing the requested information (Reference 2). Enclosure 1 of Reference 2 described the alternative course of action and schedule for responding to the Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6.

P.O. Box 128 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com

Document Control Desk April 30, 2013 to this letter provides the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Phase 1 Staffing Assessment Report. The SONGS Units 2 and 3 Phase 1 Staffing Assessment Report follows the assessment process described in Reference 3.

In accordance with Reference 2, Enclosure 1, Enclosure 3 to this letter provides the response to the following information requests due by 4/30:

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 This letter contains new regulatory commitments (as defined by NEI 99-04). The specific regulatory commitments are identified in Enclosure 1 of this letter. This letter includes no revisions to existing regulatory commitments.

If you have any questions, or require additional information, please contact Deborah Lindbeck at 949-368-6643.

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

Executed on -L--t--;~-=-.J.---.l"+--

By:

Do las auder Site Vice President and Station Manager Enclosures

1. List of Regulatory Commitments

2. San Onofre Nuclear Generating Station (SONGS) Phase 1 Extended Loss of AC Power (ELAP) Emergency Response Organization (ERO) Staffing Assessment Report

3. Response to 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, Enclosure 5 Items 1, 2 and 6 cc: (with Enclosures)

A. T. Howell III, Regional Administrator, NRC Region IV J. R. Hall, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 R. E. Lantz Branch Chief, Division of Reactor Projects, NRC Region IV

ENCLOSURE 1 List of Regulatory Commitments

Enclosure 1 Page 2 of 2 LIST OF REGULATORY COMMITMENTS This table identifies actions discussed in this letter for which Southern California Edison commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.

TYPE (check one)

SCHEDULED ONE-TIME SUSTAINABLE COMPLETION COMMITMENT ACTION ACTION DATE

1. SONGS will develop a process to Yes No December 20, 2013 integrate the expanded response capability into the existing emergency response organization (ERO).

2. Evaluate expanding the automatic Yes No 4 months prior to response process to include the on-shift Unit 3 Cycle 18 and pooled ERO positions refueling outage or 4 months prior to Unit 2 Cycle 19 refueling outage or August 31, 2016, whichever comes first

3. Evaluate and identify additional work Yes No December 23, 2014 areas and equipment for the performance of expanded response functions in the event that the alternate TSC and OSC are unavailable.

ENCLOSURE 2 San Onofre Nuclear Generating Station (SONGS)

Phase 1 Extended Loss of AC Power (ELAP) Emergency Response Organization (ERO)

Staffing Assessment Report

SOUTHERN CALIFORNIA EDISON An EDISON INTERNATIONAL Comp.any San Onofre Nuclear Generating Station (SONGS)

Phase 1 Extended Loss of AC Power (ELAP) ERO Staffing Analysis Report (Revised)1 Verified and Validated By:

'i-Zt; -13 Date Approved By:

'I/z~/tJ Date 1 Assessment completed on 3129113. Revised based on additional verification activities performed during the month of April. No changes were made to the final assessment results.

SONGS Phase 1 ELAP ERO Staffing Assessment Report TABLE OF CONTENTS 1 INTRODUCTION 4 2 EXECUTIVE

SUMMARY

5 3 ASSESSMENT PROCESS OVERVIEW 6 3.1 On-Shift Staffing Assessment Process 6 3.2 Expanded ERO Assessment Process 7 4 ASSUMPTIONS AND INITIAL CONDITIONS 8 4.1 Assumptions 8 4.1.1 NEI 12-01 Assumptions 8 4.1.2 NEI 10-05 Assumptions 9 4.1.3 Other Assumptions 9 4.2 Event Initial Conditions 10 4.3 Scope 10 4.4 Applicable IER Actions 11 5 ON-SHIFT STAFFING ASSESSMENT 13 5.1 On-Shift Staffing Assessment Process Details 13 5.1.1 On-Shift Staffing Assessment Methodology 13 5.1.2 Minimum On-Shift Staffing Complement 14 5.1.3 Initial Shift Staffing Locations 14 5.1.4 Tabletop Procedural Assessment of On-Shift Staffing for ELAP 15 5.1.5 Time Motion Study 17 5.2 On-Shift Staffing Assessment Results Summary 17 5.2.1 On-Shift Staffing Task Assessment Results 17 5.2.2 On-Shift Staffing Time Motion Study Results 18 6 EXPANDED ERO RESPONSE ASSESSMENT 20 6.1 Expanded ERO Response Assessment Process Details 20 6.1.1 Expanded ERO Response Assessment Methodology 20 6.1.2 Current Augmented ERO Staffing Complement and Response Capability 20 6.2 Expanded ERO Response Assessment Results Summary 22 6.2.1 Mobilization of Expanded Response Staffing Capability 23 6.2.2 Expanded ERO Response Capability 25 6.2.3 Activating the SONGS Expanded Response Capability 30 7 PROGRAM CONTROLS 31 7.1 Emergency Response Drill & Exercise Program 31 7.2 Training 31 Page 2

SONGS Phase 1 ELAP ERO Staffing Assessment Report 7.3 Implementation Guidance 31 8 LIST OF REFERENCES 32 : NEI 10-05 Appendix B On-Shift Staffing Assessment Results Tables................. 34 : NEI 10-05 Appendix D & E OSA Time Motion Study Result Tables .................... 40 Page 3

SONGS Phase 1 ELAP ERO Staffing Assessment Report 1 INTRODUCTION Enclosure 5 of the 50.54(f) letter requested licensees to provide the results of an assessment conducted to determine the ability of the emergency response organization (ERO) staff to respond to a large scale natural event. SCEs 60-Day Alternate Response Letter (Reference 3) responded to the 50.54(f) letter, by providing a NRC accepted alternate course of action. The alternate course of action committed SCE to provide an onsite and augmented staffing assessment that considers all functions except those related to Near Term Task Force (NTTF) Recommendation 4.2 (Phase 1 Staffing Assessment). This report provides the results of the San Onofre Nuclear Generating Stations (SONGS) Phase 1 Staffing Assessment.

Current staffing levels were assessed to determine the staff required to fill all necessary positions in order to respond to a dual-unit, beyond design basis external event (BDBEE), which results in an extended loss of alternating current (AC) power and impeded access to the site. This assessment includes the numbers and composition of the augmented response personnel required to implement mitigation strategies and repair actions intended to maintain or restore functions of core cooling, containment, and spent fuel pool cooling for both units. The Phase 1 staffing assessment considered applicable actions from current station procedures and the Institute of Nuclear Power Event Reports (IER) related to Fukushima actions at the time of the assessment.

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SONGS Phase 1 ELAP ERO Staffing Assessment Report 2 EXECUTIVE

SUMMARY

The following are the results of the assessment conducted to determine the ability of the emergency response organization (ERO) staff to respond to a large scale natural event.

This assessment is based upon a current snapshot of the organization and staffing.

For the on-shift staffing, the phase 1 assessment identified the following:

The current minimum on-shift staffing as defined in the SONGS Emergency Response Plan (ERP) is sufficient to support the implementation of the current station blackout (SBO) strategies on both Units 2 and 3, as well as the required Emergency Plan actions.

The minimum On-Shift Staff performed all actions required by operating and emergency plan procedures in the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period (prior to arrival of augmented staff) relying only on installed structures, systems and components remaining in the initial phase of the response. Plant conditions did not require any other equipment to be used.

A few enhancements and minor deficiencies were identified during the performance of the time motion study as detailed in section 5.2.2 and were entered in the corrective action program.

For the expanded response capability, the phase 1 assessment identified the following:

The number and composition of staffing necessary to support the Expanded Response Capability for the beyond design basis external event (BDBEE) as defined in Nuclear Energy Institute (NEI) 12-01 (refer to Table 6-2 for the results).

The current SCE staffing resources for the emergency response organization (ERO) are sufficient to implement all required coping strategies as required by the NEI 12-01 guidance and to fill the expanded ERO functions.

The need to establish a process to integrate the Expanded Response Capability into the existing ERO (i.e., put in place the ability and clear criteria to transition to unit-specific performance) in the event of a BDBEE.

The need to evaluate expanding the automatic response process to include the on-shift and pooled ERO positions.

The need to evaluate and identify additional work areas and equipment for the performance of expanded response functions in the event that the alternate TSC and OSC are unavailable.

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SONGS Phase 1 ELAP ERO Staffing Assessment Report 3 ASSESSMENT PROCESS OVERVIEW 3.1 On-Shift Staffing Assessment Process The Phase 1 On-Shift Staffing Assessment (OSA) for SONGS Units 2 and 3 was conducted in accordance with NEI 12-01 and NEI 10-05. The assessment was performed by a multi-disciplined team using current site procedures to analyze the performance of tasks by the minimum on-shift staff as designated in the Emergency Plan.

The following departments and personnel were present to complete the assessment:

Personnel (Position/Title) # Organization/Department Tabletop Procedural Fire Protection Supervisor 1 SONGS / Fire Protection Assessment Emergency Preparedness (EP) 1 SONGS / EP Supervisor / SRO SRO 1 SONGS / Operations Maintenance Supervisor 1 SONGS / Maintenance SONGS / Chemistry and Chemistry Manager 1 Environmental SONGS / Nuclear Training Training Specialist 1 Division Radiation Protection (RP) Manager 1 SONGS / RP Security Manager 1 SONGS / Security Security 1 SONGS / Security EP Manager 1 SONGS / EP EP Specialist 1 SONGS / EP Contingency Management EP Consultant 2 Consulting Group (CMCG)

SONGS / Nuclear Strategic Fukushima Project Manager 1 Projects Time Motion Study Shift Technical Advisor (STA) / Senior 1 SONGS / Operations Reactor Operation (SRO)

EP Supervisor / SRO 1 SONGS / EP SRO 1 SONGS / Operations RO 1 SONGS / Operations Plant Equipment Operator (PEO) 2 SONGS / Operations EP Specialist 2 SONGS / EP EP Consultant 1 CMCG SONGS / Nuclear Training Training Specialist 1 Division SONGS / Nuclear Strategic Fukushima Project Manager 1 Projects Task areas analyzed include:

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SONGS Phase 1 ELAP ERO Staffing Assessment Report

Event Mitigation (Emergency Operating Procedures (EOP))

Radiation Protection (RP) and Chemistry Technician Functions (site RP and Chemistry procedures)

Emergency Preparedness Functions (NUREG-0654 Table B-1/ISG-01)

Existing strategies for responding to an extended loss of AC power (ELAP) were used in the OSA. The assessment addressed the abilities of the on-shift staff to perform required emergency response functions that may be degraded prior to the delayed arrival of the augmented ERO.

3.2 Expanded ERO Assessment Process The expanded ERO assessment was conducted in accordance with NEI 12-01. NEI 12-01 provided recommended staffing considerations for the postulated event to enable the performance of unit-specific accident assessment and mitigation functions. The capability of the current ERO staffing at SONGS to perform these expanded ERO functions was assessed.

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SONGS Phase 1 ELAP ERO Staffing Assessment Report 4 ASSUMPTIONS AND INITIAL CONDITIONS 4.1 Assumptions The Phase 1 staffing study assumptions were based on the guidance provided in NEI 12-01 and NEI 10-05.

4.1.1 NEI 12-01 Assumptions

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

All on-site units affected Extended loss of alternating current power Impeded access to the units

2. Initially, all on-site reactors are operating at full power and are successfully shut down

3. A hostile action directed at the affected site does not occur 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (i.e., private resource providers or public sector support), etc.

B. Post event time: 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation resources (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 site emergency plan (i.e. the minimum required number for each required position). This would typically be the on-shift complement present during a backshift, weekend, or holiday.

6. The phase 1 staffing assessment considered the applicable actions from the Station Blackout (SBO) coping strategies in place at the time of the assessment (i.e., shedding of non-essential battery loads, opening room and cabinet doors, etc). These actions did not include those associated with cross-tying AC power sources or electrical distribution busses between units since all on-site units are experiencing an extended loss of AC power.

7. Following the accident at Fukushima Daiichi, the Institute of Nuclear Power Operations (INPO) issued three Event Reports (referred to IERs) requiring the assessment and implementation of a range of actions intended to improve the capabilities for responding to a beyond design basis event and an extended loss of AC power, including events that impact the cooling of spent fuel. The phase 1 staffing assessment considered those Page 8

SONGS Phase 1 ELAP ERO Staffing Assessment Report IER improvements actions already implemented at the time of the assessment (i.e.,

incorporated into plant procedures).

8. The phase 1 staffing assessment considered existing strategies for responding to an extended loss of AC power affecting all on-site units.

4.1.2 NEI 10-05 Assumptions

1. On-shift personnel can report to their assigned 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 Radiological Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection (RP) Technician.

3. Personnel assigned to the major response area of Plant Operations & Safe Shutdown meet these requirements and guidance, and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown.

4. The on-site security organization is able to satisfactorily perform all tasks related to Site and Protected Area Access Controls under all event or accident conditions. 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 notification actions specifically called out in the assessment methodology; these actions must be assessed.

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 (i.e., during a backshift, weekend or holiday). For purposes of this assessment, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months will be used as the time period for the conduct of the on-shift ERO response actions.

4.1.3 Other Assumptions

1. All equipment credited in current coping strategies remains available for use (i.e., a non-seismic water tank).

2. For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase, and any required Transition Phase, coping actions.

3. Offsite facilities and staging areas are available.

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SONGS Phase 1 ELAP ERO Staffing Assessment Report 4.2 Event Initial Conditions The large scale natural event results in a Site Area Emergency based on Emergency Action Level (EAL) SS1.1, Loss of AC/DC Power Sources, which escalates to a General Emergency based on EAL SG1.1 once it has been determined that power cannot be restored before the coping time has been exceeded. This loss of all AC power scenario impacts both units.

Initial Conditions: Both units 100% power at steady state, middle of core life.

Abnormal Conditions: None Scenario Events: An offsite electrical transient occurs resulting in a loss of all offsite power.

None of the EDGs can be synchronized to any Unit 2 or Unit 3 AC bus, resulting in a dual-unit Loss of all installed AC power.

Notes: This scenario constitutes a dual unit event.

The scenario is designed such that restoration of any AC power source is not possible.

4.3 Scope

1. The staffing assessment determined the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, any Transition Phase actions that must be performed prior to the end of the no site access time period.

Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

Transition Phase - Implementation of strategies that involve the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment, and spent fuel pool cooling.

Setup for these strategies should be performed prior to the end of the Initial Phase.

2. The applicable actions from the Station Blackout (SBO) coping strategies in place at the time of the assessment were evaluated.

Such actions included the shedding of non-essential battery loads, use of portable generators or batteries, opening room and cabinet doors, water/coolant conservation or makeup using portable equipment, etc.

These actions did not include those associated with cross-tying AC power sources or electrical distribution busses between units since all on-site units are experiencing an extended loss of AC power.

3. INPO IER improvement actions already implemented at the time of the assessment (i.e., incorporated into plant procedures) were evaluated (refer to Section 4.4). INPO IERs that were considered are:

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SONGS Phase 1 ELAP ERO Staffing Assessment Report IER L1-11-1, Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami (including Supplement 1)

IER L1-11-2, Fukushima Daiichi Nuclear Station Spent Fuel Pool Loss of Cooling and Makeup IER L1-11-4, Near-Term Actions to Address the Effects of an Extended Loss of All AC Power in Response to the Fukushima Daiichi Event.

4. Existing strategies for responding to an extended loss of AC power affecting all on-site units were evaluated.

5. The staffing assessment evaluated the ability of the on-shift staff to perform any required emergency response functions that would be degraded or lost prior to the arrival of the augmented ERO.

6. Consistent with the site access assumption, the ability of the augmented staff to implement Transition Phase coping strategies performed after the end of the no site access time period was determined.

7. The ability of the on-site staff to move back-up equipment (i.e., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor will be evaluated as part of the Phase 2 staffing assessment.

4.4 Applicable IER Actions Response to IER-L1-11-1 included two applicable procedure revisions that govern actions that are performed by the on-shift staff, based on the assumptions of this assessment, and were evaluated during this assessment.

Procedure SO23-12-11, Emergency Operating Instruction (EOI) Supporting Attachments, was revised for additional guidance on non-1E inverter Y005 load shedding. Use of Attachment 19 (Non 1E DC bus load shedding) was included as part of the Phase 1 assessment.

Procedure SO23-12-11, EOI Supporting Attachment 9, was revised to add Unit 3 room numbers. Use of Attachment 9 was included as part of the Phase 1 assessment.

Response to IER-L1-11-2 included three applicable procedure revisions that govern actions that are performed by the on-shift staff, based on the assumptions of this assessment, and were evaluated during this assessment.

Procedure SO23-13-23, Loss of Spent Fuel Pool (SFP) Cooling, was revised to initiate local monitoring of SFP temperature and level via SO23-3-2.11 Attachment 17 if there is a loss of spent fuel pool cooling concurrent with a loss of AC power.

This action was included as part of the Phase 1 assessment.

Procedure SO23-13-23, Loss of Spent Fuel Pool (SFP) Cooling, was revised to perform closure of the SFP hatches in the event of a loss of SFP cooling event.

Although in place at the time of the assessment, the Phase 1 scenario event conditions will not warrant the use of this action in the procedure (ELAP conditions assume that the SFP hatches are closed and the transfer canals are empty).

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SONGS Phase 1 ELAP ERO Staffing Assessment Report Procedure SO23-12-11, EOI Supporting Attachments, was revised to contain precautionary statement that SFP Level and Temperature be monitored. Use of SO23-12-11 and the local monitoring of SFP temperature and level via SO23-3-2.11 Attachment 17 were included as part of the Phase 1 assessment.

Procedure SO23-3-2.11, SFP Operations, was revised to include criteria on when to update the SFP Time to Boil Calculation and to provide direction on updating the Control Room placard with this information. These actions was included as part of the Phase 1 assessment.

Response to IER-L1-11-4 included one applicable procedure revision that governs an action that is performed by the on-shift staff, based on the assumptions of this assessment, and were evaluated during this assessment.

Procedure SO23-12-11, EOI ISS2 Extended SBO, was revised to modify the class 1E battery load reduction steps. Use of Attachment 20 was included as part of the Phase 1 assessment.

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SONGS Phase 1 ELAP ERO Staffing Assessment Report 5 ON-SHIFT STAFFING ASSESSMENT 5.1 On-Shift Staffing Assessment Process Details The On-Shift Staffing Assessment (OSA) for SONGS Units 2 and 3 was conducted using the guidance of NEI 12-01 and NEI 10-05. The assessment analyzed the ability of the on-shift staff to perform required emergency response functions that may be degraded or lost prior to the arrival of the augmented ERO.

A cross functional team of subject matter experts from SONGS and an outside consultant were assembled to provide assessment support during the Phase 1 OSA.

The assessment was conducted via tabletop procedural assessment using current site procedures to determine if tasks have been sufficiently analyzed for performance by the minimum on-shift staff as designated in the SONGS Emergency Plan and a subsequent time motion study (TMS) to confirm if any potential overlapping tasks exist. The following provides a summary of the process that was utilized:

5.1.1 On-Shift Staffing Assessment Methodology The guidance and documentation in NEI 10-05 were used to document a review of the on-shift staffing actions relating to an extended loss of AC power. The review documented the times required to complete these tasks as described below:

The minimum on-shift positions were entered into Table 1 of Attachment 1. The Unit number was assigned to duplicate control room position titles. For example, U2 Control Operator or U3 Control Operator etc. Otherwise, a unique sequential number was assigned to position titles with more than one position holder. The site emergency plan reference that describes the requirement for the position to be on-shift was entered into column 2 of Table 1. Using the on-shift positions entered in Table 1, the following Attachment 1 tables were completed by entering the shift position that fills a described role, or performs a specific function or tasks:

Table 2 Minimum Operations Crew Necessary to Implement EOPs (in response to the extended loss of all AC power)

Table 3 Firefighting Table 4 Radiation Protection & Chemistry Timeline of Activities 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 Table 1 of Attachment 1. For each position, the table number and associated line number was then entered in column 5, Role in Table#/Line#. If the associated task was not analyzed (i.e., performance capability has not been validated), a Yes would have been placed in column 6, Unanalyzed Task?

If the task was analyzed, a No was placed in column 6. For any Yes in column 6 or if a potential task overlap exists, a Time Motion Study is required and a Yes placed in column 7. For SONGS, there were four positions with potential task overlaps identified; thus, Time Motion Studies were required to be conducted and are located in Attachment 2.

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SONGS Phase 1 ELAP ERO Staffing Assessment Report 5.1.2 Minimum On-Shift Staffing Complement Only personnel required to be on-shift are credited in the staffing assessment. The on-shift personnel complement includes the minimum required number and composition as described in the SONGS Emergency Plan.

Assessment Functional Area Major Tasks Emergency Positions Shift Staffing Shift Manager (SRO) 1

1. Plant Operations and CR Supervisor (SRO) 2 Assessment of Control Room Staff Control Operator (RO) 3 Operational Aspects Nuc Plant Equip Op (NPEO) 4 Appendix R LO 1

2. Emergency Direction Command and Control Shift Manager 1(a) and Control Licensee Shift Communicator 1(a)

3. Notification &

Local/State Shift Communicator 1 Communication Federal Licensed Operator (RO/SRO) 1(a)

Dose Assessment HP Technician 1 In-plant Surveys HP Technician 1

4. Radiological Onsite Surveys HP Technician 1 Assessment Offsite Surveys HP Technician 1 Chemistry Chemistry Technician 1 Tech Support - OPs Shift Technical Advisor 1

5. Plant System - Core Damage Shift Technical Advisor 1(a)

Engineering, Repair, Mechanical Maintenance 1 and Corrective Actions Repair and Corrective Actions Electrical Maintenance 1 I&C Maintenance 1

6. In-Plant PAs Radiation Protection HP Technician 2(a)

Fire Brigade (including leader) 5

7. Fire Fighting --

Fire Technical Advisor (ARO) 1 st

8. 1 Aid and Rescue -- Fire Brigade 2(a)

9. Site Access Control Security & Accountability Security Personnel (b) and Accountability TOTAL: 27 (a) Indicates concurrent or sequential functions performed by existing on-shift minimum staff.

(b) Per SONGS Physical Security Plan. Staffing numbers of on-shift security personnel are safeguards information and are not included in the minimum staffing total.

5.1.3 Initial Shift Staffing Locations As described in NEI 10-05 Assumption #1, on-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions. The following are the typical locations of the on-shift personnel:

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SONGS Phase 1 ELAP ERO Staffing Assessment Report Shift Manager .......................................................................................... Control Room U2 Control Room Supervisor .................................................................. Control Room U3 Control Room Supervisor .................................................................. Control Room Shift Technical Advisor ........................................................... Control Room (30 elev.)

U2 Control Room Operator ..................................................................... Control Room U2 Aux Control Room Operator .............................................................. Control Room U3 Control Room Operator ..................................................................... Control Room U3 Aux Control Room Operator .............................................................. Control Room Nuclear Equipment Operator #1............................................................... In Plant Tour Nuclear Equipment Operator #2............................................................... In Plant Tour Nuclear Equipment Operator #3............................................. Radwaste Control Room Nuclear Equipment Operator #4.............................................. Work Processing Office Shift Communicator ................................................................................. Control Room Mechanical Maintenance............................................. K-10 Maint Shop (ground level)

Electrical Maintenance ................................................ K-10 Maint Shop (ground level)

I&C Maintenance ................................................................ K-20 Maint Shop (2nd floor)

Fire Technical Advisor .................... Work Processing Office (Stacked trailers 2nd floor)

HP Technician #1 ........................................................................... Control Point Office HP Technician #2 ........................................................................... Control Point Office HP Technician #3 ........................................................................... Control Point Office HP Technician #4 ........................................................................... Control Point Office Chemistry Technician .................................. Chemistry Lab 70 elev. (Control Building)

Fire Brigade Leader.......................................................... AWS Building (ground level)

Fire Brigade Member #1................................................... AWS Building (ground level)

Fire Brigade Member #2................................................... AWS Building (ground level)

Fire Brigade Member #3................................................... AWS Building (ground level)

Fire Brigade Member #4................................................... AWS Building (ground level) 5.1.4 Tabletop Procedural Assessment of On-Shift Staffing for ELAP The tabletop procedural assessment was conducted in the SONGS Mesa Training Facility which enabled the team to have readily available access to procedures and support documents. Using the guidance and documentation in NEI 10-05, the team performed a tabletop review of on-shift actions performed for both Units to address the extended loss of all AC power. This review included the identification of needed resources and the time required to complete identified actions for the first 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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SONGS Phase 1 ELAP ERO Staffing Assessment Report Prior to conducting the OSA, all initial conditions and event assumptions were reviewed for basic understanding of the event. The senior reactor operator (SRO) reviewed EOP and other operating procedure actions and identified them to the team. Other team members, such as the RP and Maintenance, identified functions that would be required of them to support in-plant mitigation activities. All Emergency Plan functions were reviewed and assigned to the appropriate on-shift resources. The resulting on-shift resources and their applicable actions were documented in Table 1 of Attachment 1.

Specific site procedures referenced during assessment of this postulated event included:

SO23-2-13, Diesel Generator Operation SO23-6-9, 6.9kV, 4kV and 480V Bus and Feeder Faults SO23-12-1, Standard Post Trip Actions SO23-12-8, Station Blackout SO23-12-1, Attach 4, Administrative Actions SO23-12-1, Attach 5, Diesel Generator Follow-Up Actions SO23-12-11, EOI Supporting Attachments SO23-12-11, Attach 5, Core Exit Saturation Margin Control SO23-12-11, Attach 6, Diesel Generator Failure Follow-Up Actions SO23-12-11, Attach 8, Restoration of Offsite Power SO23-12-11, Attach 9, Control Building Ventilation Emergency Actions SO23-12-11, Attach 19, Non-1E DC Load Reduction SO23-12-11, Attach 20, Class 1E Battery Load Reduction SO23-13-23, Loss of SFP Cooling SO23-3-2.11, SFP Operations SO123-IV-13.100, Security Tactical Response SO123-0-A2, Operations Division Personnel Responsibilities SO123-0-A7, Notifications and Reporting of Significant Events SO123-VIII-1, Recognition and Classification of Emergencies SO123-VIII-10, Emergency Coordinator Duties SO123-VIII-10.3, Protective Action Recommendations SO123-VIII-30, Units 2/3 Operations Leader Duties SO23-VIII-30.7, Emergency Notifications SO123-VIII-40, TSC Health Physics Leader Duties SO123-VIII-50, TSC Technical Leader Duties SO123-VIII-60, Security leader Duties SO123-VIII-60.1, OSC Security Coordinator Duties SO123-VIII-0.200, Emergency Plan Drills and Exercises Page 16

SONGS Phase 1 ELAP ERO Staffing Assessment Report SO123-VIII-0.210, Emergency Planning Drill Objectives and Demonstration Criteria 5.1.5 Time Motion Study Performance of a time motion study is required if there are any unanalyzed tasks or if there are potential task overlaps identified such that the integrated performance of the functions has not been previously analyzed. A time motion study is a performance-based assessment, essentially a drill, which confirms or modifies the results of the OSA.

5.2 On-Shift Staffing Assessment Results Summary The current minimum on-shift staffing as defined in the SONGS Emergency Response Plan (ERP) is sufficient to support the implementation of the current station blackout (SBO) strategies on both Units 2 and 3, as well as the required Emergency Plan actions.

The minimum on-shift staff performed all actions required by operating and emergency plan procedures in the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period (prior to arrival of augmented staff) relying only on installed structures, systems and components remaining in the initial phase of the response. Plant conditions did not require any other equipment to be used.

A few enhancements and minor deficiencies were identified during the performance of the time motion study as detailed in section 5.2.2 and were entered in the corrective action program.

5.2.1 On-Shift Staffing Task Assessment Results 5.2.1.1 Unanalyzed Task Assessment No unanalyzed tasks were identified for the on-shift positions (see Attachment 1 Table 1 Column 6).

5.2.1.2 Potential Task Overlap Assessment NEI 10-05 assumes that personnel assigned to the major response area of Plant Operations & Safe Shutdown are able to satisfactorily perform the design basis functions and tasks necessary to achieve and maintain safe shutdown for the period prior to ERO augmentation. This assumption does not apply for the NEI 12-01 study because existing SBO coping strategies include actions that presuppose that the augmented ERO would otherwise be available to perform them; therefore, it is required to have the collective performance of those tasks analyzed and validated by a time motion study.

The results of the task analysis determine that the following four (4) on-shift positions may experience task overlap and meet the requirements for a time motion study:

1. Nuclear Plant Equipment Operator (NPEO) #1 was directed to perform EOP and coping tasks during the extended loss of all power (perform U2 Diesel Generator Failure Follow-up Actions per SO23-12-1 Attachment 5, SO23-6-9, and SO23 13 Attachment 2, perform U2 1E DC Bus load reductions in plant per SO23 11 Attachment 20, perform U2 S/G drain closure per SO23-12-8, and perform local monitoring of U2 spent fuel pool level and temperature per SO23-3-2.11 Attachment 17).

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SONGS Phase 1 ELAP ERO Staffing Assessment Report

2. Nuclear Plant Equipment Operator (NPEO) #2 was directed to perform EOP and coping tasks during the extended loss of all power (perform U2 Non-1E DC bus load reductions per SO23-12-11 Attachment 19 and perform U2 Control Building Ventilation Emergency Actions to improve ventilation per SO23-12-11 Attachment 9).

3. NPEO #3 was directed to perform EOP and coping tasks during the extended loss of all power (perform U3 Diesel Generator Failure Follow-up Actions per SO23-12-1 Attachment 5, SO23-6-9, and SO23-2-13 Attachment 2, perform U3 1E DC Bus load reductions in plant per SO-23-12-11 Attachment 20, perform U3 S/G drain closure per SO23-12-8, and perform local monitoring of U3 spent fuel pool level and temperature per SO23-3-2.11 Attachment 17).

4. NPEO #4 was directed to perform EOP and coping tasks during the extended loss of all power (U3 Non-1E DC bus load reductions (perform U3 Non-1E DC bus load reductions per SO23-12-11 Attachment 19 and perform U3 Control Building Ventilation Emergency Actions to improve ventilation per SO23-12-11 Attachment 9).

The Security Watch Commander performed security contingency plan and EP tasks (personnel accountability) during the event. A representative of the Security Department analyzed the tasks assigned to the Security Watch Commander for potential overlap. It was concluded that performance of the EP tasks did not cause an overlap with their security force tasks. Security program commitments are identified in the Site Security Plan and are not specifically documented in this assessment due to their security-sensitive nature. Site security was not tasked with the performance of any Unit 2 or Unit 3 SBO operations related coping strategy activities.

5.2.2 On-Shift Staffing Time Motion Study Results Time motion studies were conducted for the above potential task overlaps identified in section 5.2.1. The studies were performed as separate walkdowns that began and ended in the control room. The time motion study results regarding potential task overlap were as follows (see Attachment 2 for Time Motion Study Tables):

NPEOs #1-4 were directed to perform EOP and coping tasks during the extended loss of all power as indicated in section 5.2.1. No task overlap occurred during the time motion study of the activities for these positions as the tasks could be performed sequentially.

Since all potential task overlaps have been resolved through the performance of a time motion study, it was concluded that the current minimum on-shift staffing as defined in the SONGS Emergency Response Plan (ERP) is sufficient to support the implementation of the current station blackout (SBO) strategies on both Units 2 and 3, as well as the required Emergency Plan actions, with no unacceptable collateral duties.

A few enhancements and minor deficiencies were identified during the performance of the time motion study and were subsequently entered into the corrective action program.

Specifically:

Adding a key identifier to distinguish between Unit 2 and Unit 3 keys Refurbishing a door mechanism which was hard to open Page 18

SONGS Phase 1 ELAP ERO Staffing Assessment Report Adding a statement that panels 2L154 and 3L154 require a ladder and crescent wrench Staging an 8 inch crescent wrench near the L154 panels and changing the lock type of the locked and stored ladder to include an operations 55 key Yale lock Staging cabinet keys in unit specific key lockers Add identification of panel 2(3) D7 to EOI Supporting Attachments procedure step to facilitate quicker breaker location identification Plant labeling discrepancies between the plant and procedure Discrepancy between the number of keys between Unit 2 and Unit 3 used to disable the automatic alert system Page 19

SONGS Phase 1 ELAP ERO Staffing Assessment Report 6 EXPANDED ERO RESPONSE ASSESSMENT 6.1 Expanded ERO Response Assessment Process Details For purposes of assessing augmented and expanded ERO staffing, it is assumed that the on-shift staff successfully performs all Initial Phase, and any required Transition Phase coping actions. Initial and Transition phase are described as follows:

Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

Transition Phase - Implementation of strategies that involve the use of portable equipment and consumables to extend the coping period, and maintain or restore the functions of core cooling, containment, and spent fuel pool cooling.

This section of the assessment documents the ability of the augmented ERO to implement Transition Phase coping strategies performed after the end of the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months no site access time period.

6.1.1 Expanded ERO Response Assessment Methodology The expanded ERO assessment was conducted in accordance with NEI 12-01. NEI 12-01 provided recommended staffing considerations for the postulated event to enable the performance of unit-specific accident assessment and mitigation functions. No additional ERO functions or resources were identified beyond those detailed in Table 3.1 would be required following a BDBEE at SONGS.

The capability of the current ERO staffing at SONGS to perform these expanded ERO functions was assessed as described below:

Number and composition of personnel required to perform the expanded ERO response functions of Table 6-2 was determined by performing the following:

o Current ERO rosters and qualification information were obtained and entered into Table 6-1.

o A Severe Accident Management Guidelines (SAMG) Assessment was performed to identify the two strategies for each unit that require the greatest number of staff to implement within time periods compatible with successful performance and the corresponding number and composition of staff to implement them.

Work areas for the expanded ERO were identified and analyzed for habitability.

Transportation and access to the site were assessed to reasonably ensure that the sufficient augmented staff can arrive onsite by the sixth hour of the event.

Position specific guidance was assessed in accordance with NEI 12-01.

6.1.2 Current Augmented ERO Staffing Complement and Response Capability The SONGS ERO consists of four teams. These teams include the on-site staff and on-duty personnel able to respond to emergency events. Staffing resources for the Page 20

SONGS Phase 1 ELAP ERO Staffing Assessment Report assessment of the expanded ERO are provided by the depth of personnel filling the existing ERO positions. Table 6-1 below documents the augmented ERO staffing requirements (minimum and full staffing) from SONGS Emergency Plan Table 5-1.

Table 6-1 Augmented ERO Response Resources(2)

per #

Assigned Major Function/Task ERO Title Team Qualified Emergency Direction and Control Corporate Emergency Director(1) 1 7 (Command and Control) Station Emergency Director(1) 1 4 EOF Manager(1) 1 4 Emergency Direction and Control TSC Manager(1) 1 6 (Facility Control)

OSC Emergency Group Leader(1) 1 7 Advises ERO in Emergency Plan EOF EP Coordinator(1) 1 4 requirements OSC EP Coordinator(1) 1 4 EOF/TSC EA for Notifications(1) 2 11 TSC Red Phone Communicator(1) 1 10 EOF Brown Phone Communicator 1 5 EOF Ivory Phone Communicator 1 5 Notification / Communication TSC Ivory Phone Communicator 1 9 (Emergency Communications)

OSC Ivory Phone Communicator 1 5 CR Operations Leader(1) 1 8 EOF Offsite Briefer 1 4 EOF Offsite Liaison 1 5 EOF HP Communicator 1 4 TSC HP Advisor 1 5 Notification / Communication (Team TSC HP Communicator 1 4 Communications)

OSC HP Communicator 1 4 OSC HP Radio Operator 1 72 Notification / Communication EOF Yellow Phone Communicator(1) 1 3 (Governmental)

EOF Health Physics Engineer 1 8 Rad Assessment (Offsite Dose EOF Meteorologist 1 4 Assessment) EOF Effluent Engineer 1 5 TSC HP DAC Operator 1 7 Rad Assessment (Offsite Surveys) RP Technician(1) 4 Rad Assessment (Onsite Surveys) RP Technician 3 49 Rad Assessment (In-Plant Surveys) RP Technician 2 Rad Assessment (ERF Surveys) RP Technician 1 Rad Assessment (Env Sampling) EOF Environmental Support 1 4 Rad Assessment (Sample EOF MCA Computer Operator 1 4 Analyses)

EOF Health Physics Leader(1) 1 4 Rad Assessment (RP Supervisory)

TSC Health Physics Leader(1) 1 4 Rad Assessment (RP Admin) EOF RP Support 1 72 TSC Accident Assessor 1 9 TSC Technical Leader 1 4 TSC Technical Team Assessor(1) 1 9 Plant System Engineering TSC Technical Team Mitigator(1) 1 11 EOF Technical Team Leader(1) 1 5 TSC EA for Operations(1) 1 6 OSC Operations Coordinator(1) 1 5 OSC Maintenance Coordinator(1) 1 35 Repair and Corrective Actions OSC Emergency Services Coord. (1) 1 6 OSC Security Coordinator(1) 1 29 OSC Chemistry Coordinator(1) 1 4 Page 21

SONGS Phase 1 ELAP ERO Staffing Assessment Report

per #

Assigned Major Function/Task ERO Title Team Qualified OSC Asst. Maint Coordinator 1 33 OSC HP Planner 1 3 OSC I&C Technician 1 [pooled]

OSC Electrical Technician 1 [pooled]

OSC Hazmat Technician 1 4 OSC HP Coordinator(1) 1 6 In-Plant Protective Actions OSC Asst. HP Coordinator(1) 1 4 OSC HP Technicians(1) 5 [pooled]

EOF Security Director(1) 1 5 EOF Security Liaison(1) 1 6 Facility Access and Security TSC Security Leader(1) 1 14 JIC Security Team Leader 1 5 EOF Administrative Leader(1) 1 4 EOF Administrative Coordinator 1 4 TSC Technical Team Status Board 1 8 Keeper Resource Allocation and TSC Technical Team CFMS Computer Administration 1 5 Operator OSC Team Status Board Keeper 1 11 OSC CDM Support 1 2 JIC Admin Support Pool 1 3 JIC Director/Spokesperson(1) 1 4 JIC Asst. Spokesperson 1 3 JIC Media Writer Team 2 7 JIC Technical Team 3 10 JIC Media Liaison Team 2 6 Public Information JIC Logistics Team 1 9 JIC Audio/Visual Team 1 3 JIC Telephone Responder & Media 3 12 Monitoring Team JIC PIO Facilitator Team 3 11 JIC Technical Liaison 1 5 Notes: (1) Bolded positions indicate minimum staff positions.

(2) The number qualified represents a snap shot on March 11, 2013. In some cases, individuals may be on more than one ERO Team when the number qualified falls below the number per team.

In accordance with current regulatory guidance, the on-site ERO at a multi-unit site is designed to respond to a design basis accident affecting a single unit. According to NEI 12-01, a typical augmented ERO for a multi-unit site would be challenged to effectively respond to a BDBEE simultaneously affecting both units. In an event of this magnitude, it would be necessary to expand the capability of the augmented ERO in order to facilitate timely and effective performance of critical response functions. The focus of this expanded response capability would be to enable unit-specific accident assessment and mitigation functions. NEI 12-01 tables 3.1 and 3.2 provide recommended staffing considerations to fulfill these functions. The assessment results for SONGS are described in the following section.

6.2 Expanded ERO Response Assessment Results Summary Sufficient augmented ERO resources exist to fill the expanded ERO functions. Thus, the ability of the responding ERO members to implement Transition Phase coping strategies Page 22

SONGS Phase 1 ELAP ERO Staffing Assessment Report performed after the end of the no site access 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months time period has been demonstrated. Refer to Table 6-2 for additional documentation of the expanded ERO functional staffing resources.

The following enhancements were identified during the Expanded ERO Response Assessment:

A process to integrate the expanded response capability into the existing ERO (i.e., put in place the ability to transition to unit-specific performance) will be developed and implemented in the event of a BDBEE. The process will include clear decision-making criteria for initiating the actions necessary to ensure timely performance of expanded response functions.

Evaluate expanding the automatic response process to include the on-shift2 and pooled ERO positions.

Evaluate and identify additional work areas and equipment for the performance of expanded response functions in the event that the alternate TSC and OSC are unavailable.

6.2.1 Mobilization of Expanded Response Staffing Capability 6.2.1.1 Notification of ERO Resources The SONGS ERO augmentation process consists of an all call / all come expectation in a declared event at an Alert level or higher. When the ERO notification system is operable, all qualified ERO members are contacted and expected to report if fit for duty.

In the absence of the call out system, all ERO members who are not part of the on-shift staff or pooled positions are trained to respond automatically following significant events.

SO123-XV-ERO-1, Emergency Response Organization (ERO) Standards and Expectations, Section 6.1.2 provides instruction that ERO personnel are expected to automatically respond to their assigned Emergency Response Facility (ERF) following significant events (such as earthquakes, tsunami or large area grid loss) when normal communications may not be available for an extended period of time. If the ERO member is not able to get to their assigned ERF, they are instructed to go to the nearest of three designated locations and await further instructions.

Currently, the automatic response process does not address all ERO resources that would be required for the expanded ERO. The on-shift and pooled resources are not currently included as part of the process. Methods exist (i.e.; satellite phones) to recall these personnel individually. However, as an enhancement, SCE will evaluate expanding the process to include these members.

6.2.1.2 Site Access/Alternate Transportation Capability The following methods of access are available to the SONGS site. One or more of these methods are expected to be available after a widespread large scale natural event:

2 On-shift personnel are Operations Operators who are typically on-shift, but not at work (i.e., NPEOs).

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SONGS Phase 1 ELAP ERO Staffing Assessment Report Roadway - There are several roadways into the San Onofre Nuclear Generating Station (SONGS). If one path were impassable, detours using other roadways are viable. Major routes include:

o Interstate 5 and adjoining roadways from the north and from the south o Surface roads through Marine Corps Base - Pendleton from the east o Interstate 15 is available for north/south movement o State Routes 74, 76, and 78 support east/west movement To facilitate access and restoration of the routes, the following are available to San Onofre:

o SONGS belongs to both the Orange County and San Diego County Operational Areas as part of the Regional Emergency Operation Center network. In an Emergency, a mission task request can be made to either operational area to support restoration of access to the plant.

o A mutual aid assistance agreement with Camp Pendleton exists for personnel services and equipment required for emergency response.

o The State of California, working with local agencies, is responsible to ensure that the evacuation routes are passable, free of impediments, and they coordinate actions of key support agencies. The evacuation routes include Interstate 5 and Pacific Coast Highway.

Air - Access to San Onofre can be provided via helicopters owned or arranged for by Southern California Edison (SCE). Availability of these helicopters is established in the SCE Operations Support Business Unit, Transportation Services Department Emergency Response and Business Continuity Plan. Air access is from seven (7) helicopters, owned and operated as SCE resources, with two being dedicated specifically for the transport of emergency response personnel and equipment to SONGS. The helicopters are capable of transporting up to 33 personnel per lift (accounting for the capacity of all the aircraft). The contact number for the Transportation Services Department is maintained in the Emergency Response Telephone Directory. This would provide reasonable assurance of sufficient ERO personnel arriving on-site prior to the end of the no site access period of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

6.2.1.3 Work Areas for Personnel Performing Expanded Response Functions The Technical Support Center (TSC) and the Operations Support Center (OSC) both have alternative facility locations, the Alternate TSC and the Alternate OSC. These alternate facilities will be utilized to support the expanded response capabilities if available. These locations are not robust from the perspective of a BDBEE. SONGS will evaluate and identify additional work areas and equipment for the performance of expanded response functions in the event that the alternate TSC and OSC are unavailable. In addition, enhancements to these areas will be assessed in accordance with the EP rulemaking on alternate ERFs. (Existing obligation)

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SONGS Phase 1 ELAP ERO Staffing Assessment Report 6.2.2 Expanded ERO Response Capability 6.2.2.1 Expanded Response Functions The focus of an expanded response capability at SONGS will be to enable the performance of unit-specific accident assessment and mitigation functions. To be effective, the SONGS expanded response capability will encompass those functions necessary for preventing damage to irradiated fuel, or if such damage occurs, minimizing radiological releases. Selected functions will directly support the assessment and implementation of a range of mitigation strategies intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling Table 6-2 addresses NEI 12-01 Table 3.1 expanded staffing requirements and documents the staffing necessary to support the simultaneous deployment of emergency repair and corrective action teams to each affected unit. The number required column is equal to the specified staffing consideration for two units assuming a 12-hour shift. In order to support 24-hour expanded ERO staffing, the resources required would be double the numbers listed in Table 6-2.

As indicated in Table 6-2, current SCE staffing resources for the ERO are sufficient to fill the expanded response functions.

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Table 6-2 Expanded ERO Response Functions SONGS Augmented Resources Resources Resources Function Location Key Roles and Staffing Considerations ERO Position Required Sufficient? Available*

Overall cognizance of the activities related to implementation of repair and corrective actions, and implementation of Transition Unit Response Phase coping and Severe Accident Management (SAM) strategies Station Emergency TSC for an assigned unit 2 Yes 4 Coordination Director One individual per unit; individuals should not be assigned other functions Provides coordination of Operations staff and support for an Operations assigned unit TSC TSC EA for Ops. 2 Yes 6 Coordination One individual per unit; individuals should not be assigned other functions Provides coordination of Maintenance staff and support for an Maintenance assigned unit Maintenance OSC 2 Yes 35 Coordination One individual per unit; individuals should not be assigned other Coordinator functions Provides coordination of Engineering staff and support for an Engineering TSC or assigned unit TSC Technical Leader 2 Yes 4 Coordination EOF One individual per unit; individuals should not be assigned other functions One team for each unit to perform engineering assessments in support repair and corrective actions Engineering Team composition (i.e., number and represented disciplines) as Tech Team Assessor 2 9 TSC Yes Assessments described in the emergency plan Tech Team Mitigator 2 11 Team may include personnel responsible for performing other functions for the same assigned unit Evaluation of One team for each unit to evaluate selection of SAM strategies; Severe team performs evaluations not done by Control Room personnel Accident Team composition (i.e., number and represented disciplines) as Tech Team Assessor 2 9 Management TSC Yes described in governing site programs, procedures and guidelines Tech Team Mitigator 2 11 (SAM)

Strategies Team may include personnel responsible for performing other functions for the same assigned unit

SONGS Phase 1 ELAP ERO Staffing Assessment Report SONGS Augmented Resources Resources Resources Function Location Key Roles and Staffing Considerations ERO Position Required Sufficient? Available*

Unit In-Plant Overall cognizance of on-site and in-plant teams performing or Team supporting repair and corrective actions for an assigned unit Emergency Group Coordination OSC 2 Yes 7 One individual per unit; individuals should not be assigned other Leader functions Nuclear Plant Two individuals per unit to assist with implementation of repair and Equipment OSC corrective actions NPEO** 4 Yes** 115 Operator Should not include members of the on-shift staff Mechanical Two individuals per unit to implement repair and corrective actions Maintenance Staffing may include an on-shift individual (i.e., 2 individuals for a Mechanical Repair and OSC unit composed of 1 on-shift and 1 augmented) 4 Yes 61 Maintenance Corrective Action Electrical Two individuals per unit to implement repair and corrective actions Maintenance Staffing may include an on-shift individual (i.e., 2 individuals for a Repair and OSC unit composed of 1 on-shift and 1 augmented) Electrical Maintenance 4 Yes 46 Corrective Action I&C Repair and Two individuals per unit to implement repair and corrective actions Corrective OSC Staffing may include an on-shift individual (i.e., 2 individuals for a I&C Maintenance 4 Yes 60 Action unit composed of 1 on-shift and 1 augmented)

Number and composition of personnel capable of simultaneous Control Operator 2 38 implementation of any 2 SAM strategies at each unit NPEO** 4 115 Implementation of SAM OSC Should not include personnel assigned to other functions (i.e., Mechanical Maint. 2 Yes**

57 emergency repair and corrective actions); however, may include RP Technician 2 49 Strategies members of the on-shift staff and personnel responsible for Fire Fighters** 4 15***

implementation of Transition Phase coping strategies Support Personnel 4 155

Total # based on current qualifications and the current ERO roster

- Not part of existing recall process; manual call out required

- - Memorandum of Agreement exists between the Marine Corps Base at Camp Pendleton and SCE to provide personal services and equipment required for firefighting and emergency services Page 27

SONGS Phase 1 ELAP ERO Staffing Assessment Report 6.2.2.2 Position Specific ERO Response

1. Radiation Protection Technicians The SONGS process for establishing the expanded response capability will include a minimum number of available Radiation Protection Technicians (RPTs) following a BDBEE, to support performance of assigned emergency plan functions and the expanded response capability. The equation in Section 3.5.1 of NEI 12-01 was used to determine the total number of required RPTs on shift.

RPTT = RPTCOP + RPTRCA + RPTNC Where:

RPTT = Total required number of on-site RP Technicians.

RPTCOP = Number needed to support implementation of any 2 extended loss of AC power coping strategies per unit. Determine this number by reviewing strategies for each unit.

RPTRCA = Number needed for repair and corrective action (2 x the number of units).

RPTNC = Number of on-site RP Technicians performing other emergency plan functions that would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams.

8 (RPTT) = 1 (RPTCOP) + 4 (RPTRCA) + 3 (RPTNC)

RPTCOP = 1 The SONGS RPTCOP number is based upon the coping strategies of currently implemented EOPs which were evaluated during the task analysis and is documented in Table 4 of Attachment 1. The EOP tasks required the support of 1 RP Technician to provide access point monitoring for operations personnel to perform their assigned actions. SONGS has one access point for Units 2 and 3.

RPTRCA = 4 Based on the number needed for repair and corrective actions, two are required per unit.

RPTNC = 3 The SONGS RPTNC number is based upon Emergency Plan Table 5-4(a) functions that require 3 RP Technician to perform in-plant and onsite surveys which would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams.

The SONGS minimum number of RPTs required for expanded response is 8. To account for 24-hours of coverage, the total required number of RPTs is 16 based on 12-hour shifts.

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SONGS Phase 1 ELAP ERO Staffing Assessment Report Following a beyond design basis external event, 48 RPTs are available to support performance of assigned emergency plan functions and the expanded response capability (Refer to Table 5-1).

In the event of fuel damage, prevailing dose rates would likely require that the sites RPT complement be augmented with technicians from outside sources. SONGS has a letter of agreement from the Institute of Nuclear Power Operations (INPO),

addressed to all INPO member utilities, certifying plant emergency assistance. If requested INPO will provide assistance to locate personnel with technical expertise. This would include RPTs. The agreement remains in effect until terminated in writing.

2. Administrative Support Personnel A review of the SONGS Emergency Plan and procedures revealed that administrative support personnel that assist the augmented ERO members are not assigned critical response tasks. Augmented ERO personnel, in their roles as an expanded ERO, are capable of performing their assigned tasks and responsibilities without requiring support from administrative personnel.

3. SAMG Implementation Personnel The assessment considered the number and qualifications of SAMG implementation personnel required for simultaneous implementation of the two most task intensive SAMG strategies on both units. The two most labor intensive strategies are as follows:

Inject into the Steam Generators (S/Gs) (fire water low pressure S/G feed using long path recirculation)

Flood the Safety Equipment Building (SEB)/Radwaste Building Implementation of the Inject into the Steam Generators strategy requires the following personnel resources:

Resource # Per Unit Function Depressurize SGs and Close the upstream valves Control Operator 1 (performed in the Control Room)

Open the long path recirculation isolation valve in the NPEO 1 trench Maintenance 1 Reopen the MFW Isolation Valve with N2 Fire Department 1 Start and operate pump and/or fire truck Lay and connect fire hoses to the SEB roof and to Support Personnel 1 move/connect pump Implementation of the Flood the SEB/Radwaste Building strategy requires the following personnel resources:

Resource # Per Unit Function NPEO 1 Monitor and coordinate Fire Department 1 Start and operate pump and/or fire truck RP Technician 1 Monitor the dose and water accumulation Support Personnel 1 Lay and connect fire hoses Page 29

SONGS Phase 1 ELAP ERO Staffing Assessment Report These two strategies, implemented simultaneously, would require the following personnel resources:

2 Control Operators 4 Nuclear Plant Equipment Operators 2 Mechanical Maintenance 2 RP Technicians 4 Fire Department personnel 4 Support Personnel As indicated in Table 6-2, sufficient resources are currently available to support this expanded response function.

6.2.3 Activating the SONGS Expanded Response Capability SO123-VIII-10, Emergency Coordinator Duties, currently has instructions to allow the facility leader to determine the ERO resources needed for the specific event. To enhance the decision making ability during a BDBEE, SONGS will develop and implement a process to integrate the expanded response capability into existing ERO (i.e., put in place the ability to transition to unit-specific performance) in the event of a BDBEE. The process will include clear decision-making criteria for initiating the actions necessary to ensure timely performance of expanded response functions.

Page 30

SONGS Phase 1 ELAP ERO Staffing Assessment Report 7 PROGRAM CONTROLS 7.1 Emergency Response Drill & Exercise Program NEI 12-01 states that a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. In particular, standard objectives and extent-of-play may need to be revised to clarify the expected demonstration of functions that are dependent upon the type of scenario event or accident (i.e., within or beyond design basis, and number of affected units). For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit.

Current SONGS drill and exercise procedures do not include evaluation objectives or demonstration criteria for dual unit events or expanded ERO activities. As future guidance is expected from the NRC in this area, no changes are necessary to the drill and exercise procedures at this time.

7.2 Training No new ERO tasks or functions have been identified to implement the expanded response capability. SONGS has a sufficient number of qualified ERO personnel to implement the expanded response; qualification of additional personnel will not be required.

7.3 Implementation Guidance SONGS will develop and implement a process to activate and integrate the expanded response capability into existing ERO (i.e., put in place the ability to transition to unit-specific performance) in the event of a BDBEE. The process will include decision-making criteria for initiating the actions necessary to ensure timely performance of expanded response functions.

Page 31

SONGS Phase 1 ELAP ERO Staffing Assessment Report 8 LIST OF REFERENCES

1. NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Rev 0

2. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Rev 0

3. SONGS 60 Day Response to March 12, 2012 Information Request Regarding Recommendation 9.3 of the Near Term Task Force Report San Onofre Nuclear Generating Station, Units 2 and 3, 05/09/12

4. SONGS 90 Day Response to March 12, 2012 Information Request Regarding Recommendation 9.3 of the Near Term Task Force Report San Onofre Nuclear Generating Station, Units 2 and 3, 07/18/12

5. Emergency Plan for San Onofre Nuclear Generating Station, Section 5, Rev 28

6. SO23-2-13, Diesel Generator Operation, Rev. 61

7. SO23-6-9, 6.9kV, 4kV and 480V Bus and Feeder Faults, Rev. 12

8. SO23-12-1, Standard Post Trip Actions, Rev. 26

9. SO23-12-8, Station Blackout, Rev. 23

10. SO23-12-11, EOI Supporting Attachments, Rev. 12

11. SO23-13-23, Loss of Spent Fuel Pool Cooling, Rev. 12

12. SO23-3-2.11, Spent Fuel Pool Operations, Rev. 15

13. SO123-0-A2, Operation Division Personnel Responsibilities, Rev. 35

14. SO123-0-A7, Notifications and Reporting of Significant Events, Rev. 22

15. SO123-IV-13.100, Security Tactical Response, Rev. 17

16. SO123-VIII-1, Recognition and Classification of Emergencies, Rev. 37

17. SO123-VIII-10, Emergency Coordinator Duties, Rev. 32

18. SO123-VIII-10.3, Protective Action Recommendations, Rev. 15

19. SO23-VIII-30, Units 2/3 Operations Leader Duties, Rev. 21

20. SO123-VIII-30.7, Emergency Notifications, Rev. 16

21. SO123-VIII-40, TSC Health Physics Leader Duties, Rev. 27

22. SO123-VIII-50, TSC Technical Leader Duties, Rev. 19

23. SO123-VIII-60, Security Leader Duties, Rev. 24 Page 32

SONGS Phase 1 ELAP ERO Staffing Assessment Report

24. SO123-VIII-60.1, OSC Security Coordinator Duties, Rev. 22

25. SO123-VIII-0.200, Emergency Plan Drills and Exercises, Rev. 16

26. SO123-VIII-0.210, Emergency Planning Drill Objectives and Demonstration Criteria, Rev. 0

27. SO123-XV-ERO-1, Emergency Response Organization Standards and Expectations, Rev. 3 Page 33

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI B On-Shift Staffing Analysis Results Tables TABLE 1 - On-Shift Positions Extended Loss of All Power (ELAP)

Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time (min) Table#/Line# Task? Required?

2/1 5/1 5/2

1. Shift Manager Table 5-5 No No 5/3 5/5 5/8

2. U2 Control Room (CR) Supervisor Table 5-5 2/2 No No

3. U3 CR Supervisor Table 5-5 2/3 No No

4. Shift Technical Advisor Table 5-5 2/4 No No

5. U2 Control Operator Table 5-5 2/5 No No

6. U2 Aux Control Operator Table 5-5 2/6 No No

7. U3 Control Operator Table 5-5 2/7 No No

8. Appendix R LO / U3 ACO Table 5-5 2/8 No No 2 / 9.A 2 / 9.B

9. NPEO #1 Table 5-5 No Yes 2 / 9.C 2 / 9.D 2 / 10.A

10. NPEO #2 Table 5-5 No Yes 2 / 10.B 2 / 11.A 2 / 11.B

11. NPEO #3 Table 5-5 No Yes 2 / 11.C 2 / 11.D 2 / 12.A

12. NPEO #4 Table 5-5 No Yes 2 / 12.B 5 / 10

13. Fire Tech Advisor (ARO) Table 5-5 No No 5 / 13

14. Mechanical Maintenance Table 5-5 2 / 14 No No

15. Electrical Maintenance Table 5-5 2 / 15 No No

16. I&C Maintenance Table 5-5 2 / 16 No No 5/6

17. Shift Communicator Table 5-5 No No 5/9

18. HP Technician #1 Table 5-5 360 4/5 No No

19. HP Technician #2 Table 5-5 360 4/3 No No

20. HP Technician #3 Table 5-5 360 4/1 No No

21. HP Technician #4 Table 5-5 360 4/2 No No Page 34

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI B On-Shift Staffing Analysis Results Tables

22. Chemistry Technician Table 5-5 360 4/7 No No

23. Fire Brigade Leader Table 5-5 3/1 No No

24. Fire Brigade Member #1 Table 5-5 3/2 No No

25. Fire Brigade Member #2 Table 5-5 3/3 No No

26. Fire Brigade Member #3 Table 5-5 3/4 No No

27. Fire Brigade Member #4 Table 5-5 3/5 No No

28. Security Watch Commander Table 5-5 5 / 15 No No TABLE 2 - Plant Operations & Safe Shutdown Extended Loss of All Power (ELAP)

Minimum Operations Crew Necessary to Implement EOPs (in response to the extended loss of all AC power) (Two Units - One Control Room)

Line Generic Title/Role On-Shift Position Task Description Controlling Method

1. Shift Manager Shift Manager Plant and crew oversight Ops Training Program

2. Unit Supervisor #1 U2 CR Supervisor Direct Control room EOP actions Ops Training Program

3. Unit Supervisor #2 U3 CR Supervisor Direct Control room EOP actions Ops Training Program

4. Shift Technical Advisor Shift Technical Advisor STA tasks Ops Training Program

5. Reactor Operator #1 U2 Control Operator Perform control room actions Ops Training Program

6. Reactor Operator #2 U2 Aux Control Operator Perform control room actions Ops Training Program

7. Reactor Operator #3 U3 Control Operator Perform control room actions Ops Training Program

8. Reactor Operator #4 Appendix R LO / U3 ACO Perform control room actions Ops Training Program A. U2 DG Failure Follow-up Actions Ops Training Program B. U2 1E DC bus reductions Ops Training Program

9. Auxiliary Operator #1 NPEO #1 C. U2 S/G Drain Valve Closure Ops Training Program D. Local Monitoring of U2 SFP Level Ops Training Program and Temperature Ops Training Program A. U2 Non-1E DC bus load reductions Ops Training Program

10. Auxiliary Operator #2 NPEO #2 B. U2 CB ventilation emergency actions Ops Training Program A. U3 DG Failure Follow-up Actions Ops Training Program B. U3 1E DC load reductions Ops Training Program

11. Auxiliary Operator #3 NPEO #3 C. U3 S/G Drain Valve Closure Ops Training Program D. Local Monitoring of U3 SFP Level Ops Training Program and Temperature Ops Training Program A. U3 Non-1E DC bus load reductions Ops Training Program

12. Auxiliary Operator #4 NPEO #4 B. U3 CB ventilation emergency actions Ops Training Program

13. Other Fire Tech Advisor (ARO) N/A NA Page 35

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI B On-Shift Staffing Analysis Results Tables Other (non-Operations) Personnel Line Generic Title/Role On-Shift Position Task Description Controlling Method

14. Mechanic Mechanical Maintenance Troubleshoot & Repair EDGs Maint Training Program

15. Electrician Electrical Maintenance Troubleshoot & Repair EDGs Maint Training Program

16. I&C Technician I&C Maintenance Troubleshoot & Repair EDGs Maint Training Program TABLE 3 - Firefighting Extended Loss of All Power (ELAP)

Line Performed By Task Description Controlling Method

1. Fire Brigade Leader Support Operations Activities Fire Protection Program

2. Fire Brigade Member #1 Support Operations Activities Fire Protection Program

3. Fire Brigade Member #2 Support Operations Activities Fire Protection Program

4. Fire Brigade Member #3 Support Operations Activities Fire Protection Program

5. Fire Brigade Member #4 Support Operations Activities Fire Protection Program Page 36

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI B On-Shift Staffing Analysis Results Tables TABLE 4 - Radiation Protection and Chemistry Timeline of Activities Extended Loss of All Power (ELAP)

Position Performing Performance Time Period After Emergency Declaration (minutes) ( Note 1)

Function/Task 0-30 30-60 60-90 90-120 120-150 150-180 180-210 210-240 240-300 300-330 330-360 In-Plant Radiological Survey

1. On-Shift Position:

RP Technician #3 (Note 2) X X X X X X X X X X X On-Site Radiological Survey

2. On-Shift Position:

RP Technician #4 (Note 2) X X X X X X X X X X X Personnel Monitoring

3. On-Shift Position:

RP Technician #2 X X X X X X X X X X X Job Coverage

4. On-Shift Position:

Offsite Radiological Assessment

5. On-Shift Position:

RP Technician #1 (Note 2) X X X X X X X X X X X Other RP - Describe:

6. On-Shift Position:

Sampling

7. On-Shift Position:

Chemistry Technician (Note 3) X Other Chem - Describe:

8. On-Shift Position:

Notes: 1.The basis for the selected performance time period was established by the results of the NEI 10-05 assessment and subject matter experts during the task assessment review.

2. RP Techs are available to perform In-Plant Radiological Surveys, On-Site Radiological Surveys, and Offsite Dose Assessment for the period as indicated in Table 4 above, but since no release is in progress, tasks are not required to be performed and could be available to perform other duties.

3. Upon a reactor trip, Chemistry Technician would start a reactor coolant system sample to monitor for failed fuel. However, without any power, Chemistry would prepare for a sample, but no sample would be able to be obtained.

Page 37

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI B On-Shift Staffing Analysis Results Tables TABLE 5 - Emergency Plan Implementation Extended Loss of All Power (ELAP)

OPs Training Program and EP Drill Program Task Assessment Line Function/Task On-Shift Position Controlling Method Controlling Methods Task ID 192840 - Classify emergency events requiring emergency plan Declare the Emergency Ops Training

1. Shift Manager implementation.

Classification Level (ECL) Program SIM 2RS766, Emergency Coordinator Duties Task ID 192841 - Determine additional protective action Approve Offsite Protective recommendation during implementation of the emergency plan. Ops Training

2. Shift Manager Action Recommendations Program JPM - J126A, Determine PAR Task ID 188229 - Direct Notifications of state and local agencies Approve content of concerning emergency classification. Ops Training

3. Shift Manager State/local notifications Program SIM 2RS766, Emergency Coordinator Duties Approve extension to Task ID 192333 - Authorize overexposure of an emergency worker. Ops Training

4. N/A allowable dose limits JPM- J208A, Approve emergency radiation exposure. Program Notification and direction to Task ID 176608 - Coordinate emergency response activities during implementation of the emergency plan. Ops Training

5. on-shift staff (i.e., to Shift Manager Program assemble, evacuate, etc.) SIM 2RS766, Emergency Coordinator Duties Task ID 188229 - Direct Notifications of state and local agencies Shift concerning emergency classification. Ops Training

6. ERO notification Communicator Program SIM 2RS766, Emergency Coordinator Duties Abbreviated NRC notification

7. N/A N/A - based on the assessment assumptions N/A for DBT event Task ID 188229 - Direct Notifications of state and local agencies Complete State/local concerning emergency classification. Ops Training

8. Shift Manager notification form Program SIM 2RS766, Emergency Coordinator Duties SIM 2RS766, i) During an emergency, notify offsite authorities within Ops Training Perform State/local Shift prescribed time limits. (SM & NOA) iii) During a declared emergency

9. Program notifications Communicator function as the Shift Communicator, performing all notifications specified EP Drill Program in SO123-VIII-30.5. (NOA)

Complete NRC event Task ID 192858 - Report significant events to the NRC.

10. Fire Tech Advisor notification form SIM 2RS766, Emergency Coordinator Duties.

11. Activate ERDS N/A N/A - continuously active N/A Offsite radiological

12. N/A N/A - based on the assessment assumptions N/A assessment Task ID 192879 - Operate the Red Phone emergency notification Ops Training

13. Perform NRC notifications Fire Tech Advisor system. Program Page 38

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI B On-Shift Staffing Analysis Results Tables Objective C-01: Perform NRC notifications. EP Drill Program Perform other site-specific

14. event notifications (i.e., N/A N/A - based on assessment assumptions N/A INPO, ANI, etc.)

Security Watch

15. Personnel accountability Objective 36: Exercise w/assembly and accountability. EP Drill Program Commander Notes: 1: Line #3, #8 and #9 includes initial and follow-up State/local notifications.

2: EP performance objectives taken from SO123-VIII-0.200, Attachment 2 and from SO123-VIII-0.210.

Page 39

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI 10-05 Appendix D & E OSA Time Motion Study Result Tables Extended Loss of All Power (ELAP) Position: NPEO #1 (23 Operator) Line #:1-9 Appendix D: Function / Responsibility (Task) Assessment Duration Function Responsibility (Task) Action Step (min) 1.1.1 SO23-12-1, Att 5 1.1 Perform U2 in-plant operations: U2 DG Failure Follow-up 1.1.2 SO23-6-9 72 Actions (2/9.A) 1.1.3 SO23-2-13, Att 2

1. Plant Operations (status 1.2 Perform U2 in-plant operations: U2 1E DC bus load reductions 1.2.1 SO23-12-11, Att 20 81 monitoring and EOP actions) (2/9.B) 1.3 Perform U2 in-plant operations: U2 S/G Drain Valve Closure 1.3.1 SO23-12-8 7 1.4 Perform local monitoring of U2 SFP level and temperature 1.4.1 SO23-3-2.11 Att 17 39 (2/9.D)

Appendix E: Work Activities Assessment Plant/equipment/environmental events and conditions Task / Action Step description Time applicable to the functions and tasks (start & stop)

Perform U3 in-plant operations: U3 DG Failure Follow-up Actions Actions completed in U3* Control and Diesel Bldg. Refer to SO23-12-1 Att 5 - DG Failure Follow-up Actions (15.02-15:56) 15:02 section 4.2 and section 4.3 for event and conditions description. SO23-6 6.9kV, 4k and 480V Bus and Feeder Faults (15:56-16:06)

SO23-2-13 Att 2 - Diesel Generator Operation (16:06-16:14)

Actions completed in U3* Control Bldg. Refer to section 4.2 and Perform U3 in-plant breaker actions: Reduce U3 1E DC bus loads 08:28 section 4.3 for event and conditions description. (08:28 - 09:49)

Actions completed in U3* Main Steam Isolation Valve Room. Perform U3 in-plant operations: Close S/G Drain Valves (11:31 - 11:38) 11:31 Refer to section 4.2 and section 4.3 for event and conditions description.

Actions completed in U3* Fuel Handling Building. Refer to Perform U3 in-plant operations: Perform local monitoring of U3 SFP level and 13:57 section 4.2 and section 4.3 for event and conditions description. temperature (13:57 - 14:36)

Unit 3 time motion study data was used for Unit 2 as the implementing steps, locations, and routes are similar between Units Page 40

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI 10-05 Appendix D & E OSA Time Motion Study Result Tables Extended Loss of All Power (ELAP) Position: NPEO #2 (24 Operator) Line #:1-9 Appendix D: Function / Responsibility (Task) Assessment Duration Function Responsibility (Task) Action Step (min)

1. Plant Operations (status 1.1 Perform U2 Non 1E bus load reductions 1.1.1 SO23-12-11 Attachment 19 51 monitoring and EOP actions) 1.2 Perform U2 Control Building Ventilation Emergency Actions 1.2.1 SO23-12-11 Attachment 9 34 Appendix E: Work Activities Assessment Plant/equipment/environmental events and conditions Task / Action Step description Time applicable to the functions and tasks (start & stop)

Actions completed in U2 Radwaste Building. Refer to section Perform U2 Non 1E bus load reductions (10:16-10:59, 11:10-11:18) 10:16 4.2 and section 4.3 for event and conditions description.

Actions completed in U2 Control Building. Refer to section 4.2 Perform U2 Ventilation actions: (13:33-14:07) 13:33 and section 4.3 for event and conditions description.

Page 41

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI 10-05 Appendix D & E OSA Time Motion Study Result Tables Extended Loss of All Power (ELAP) Position: NPEO #3 (33 Operator) Line #:1-11 Appendix D: Function / Responsibility (Task) Assessment Duration Function Responsibility (Task) Action Step (min) 1.1.1 SO23-12-1, Att 5 1.1 Perform U3 in-plant operations: U2 DG Failure Follow-up 1.1.2 SO23-6-9 72 Actions (2/9.A) 1.1.3 SO23-2-13, Att 2

1. Plant Operations (status 1.2 Perform U3 in-plant operations: 1E DC bus load reductions 1.2.1 SO23-12-11, Att 20 81 monitoring and EOP actions) (2/11.B) 1.3 Perform U3 in-plant operations: Close S/G Drain Valves 1.3.1 SO23-12-8 7 1.4 Perform local monitoring of U3 SFP level and temperature 1.4.1 SO23-3-2.11 Att 17 39 (2/9.C)

Appendix E: Work Activities Assessment Plant/equipment/environmental events and conditions Task / Action Step description Time applicable to the functions and tasks (start & stop)

Perform U3 in-plant operations: U3 DG Failure Follow-up Actions Actions completed in U3 Control and Diesel Bldg. Refer to SO23-12-1 Att 5 - DG Failure Follow-up Actions (15.02-15:56) 15:02 section 4.2 and section 4.3 for event and conditions description. SO23-6 6.9kV, 4k and 480V Bus and Feeder Faults (15:56-16:06)

SO23-2-13 Att 2 - Diesel Generator Operation (16:06-16:14)

Actions completed in U3 Control Bldg. Refer to section 4.2 and Perform U3 in-plant breaker actions: Reduce U3 1E DC bus loads 08:28 section 4.3 for event and conditions description. (08:28 - 09:49)

Actions completed in U3* Main Steam Isolation Valve Room. Perform U3 in-plant operations: Close S/G Drain Valves (11:31 - 11:38) 11:31 Refer to section 4.2 and section 4.3 for event and conditions description.

Actions completed in U3 Fuel Handling Building. Refer to Perform U3 in-plant operations: Perform local monitoring of U3 SFP level and 13:57 section 4.2 and section 4.3 for event and conditions description. temperature (13:57 - 14:36)

Page 42

SONGS Phase 1 ELAP ERO Staffing Analysis Assessment Report : NEI 10-05 Appendix D & E OSA Time Motion Study Result Tables Extended Loss of All Power (ELAP) Position: NPEO #4 (34 Operator) Line #:1-9 Appendix D: Function / Responsibility (Task) Assessment Duration Function Responsibility (Task) Action Step (min)

1. Plant Operations (status 1.1 Perform U3 Non 1E bus load reductions 1.1.1 SO23-12-11 Attachment 19 51 monitoring and EOP actions) 1.2 Perform U3 Control Building Ventilation Emergency Actions 1.2.1 SO23-12-11 Attachment 9 30 Appendix E: Work Activities Assessment Plant/equipment/environmental events and conditions Task / Action Step description Time applicable to the functions and tasks (start & stop)

Actions completed in U2* Radwaste Building. Refer to section Perform U2 Non 1E bus load reductions (10:16-10:59, 11:10-11:18) 10:16 4.2 and section 4.3 for event and conditions description.

Actions completed in U3 Control Building. Refer to section 4.2 Perform U3 Ventilation actions: (14:21-14:51) 14:21 and section 4.3 for event and conditions description.

Unit 2 time motion study data was used for Unit 3 as the implementing steps, locations, and routes are similar between Units Page 43

ENCLOSURE 3 Response to 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, Enclosure 5 Items 1, 2 and 6

Enclosure 3 Page 2 of 4 SCE Response to NRC Requested Information SCE Alternative Course of Action for NRC Staffing Request for Information Item #1 Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in Enclosure 5 of the 50.54(f) letter. 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 Nuclear Regulatory Commission (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).

Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]

SCE Response to Item #1 SCEs Phase 1 Staffing Assessment is provided in Enclosure 2 of this letter.

The Assessment did not include actions of how staff will move back-up equipment from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NRC NTTF Recommendation 4.2. SCE will perform this assessment as a part of the Phase 2 Staffing Assessment as described in SCEs 60-Day Alternate Response Letter, dated May 9, 2012.

No new staff or functions were identified as a result of this assessment. Refer to , Sections 5.2 and 6.2.

Four on-shift personnel were identified as having collateral duties. Time motion studies validated that the on-shift personnel were able to complete all tasks in a timely manner

Enclosure 3 Page 3 of 4 without degraded performance of their assigned functions. Refer to Enclosure 2, Section 5.2.

SCE Alternative Course of Action for NRC Staffing Request for 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.

1. Conduct the onsite and augmented staffing assessment:

a. The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]

2. A schedule of the time needed to implement changes will be provided as follows:

a. Those associated with the Phase 1 staffing assessment.

SCE Response to Item #2

1. The SCE Phase 1 Staffing Assessment is provided in Enclosure 2 of this letter.

2. The time needed to implement changes are as follows:

a. The development of a process to integrate the expanded response capability into the existing ERO will be implemented by December 20, 2013.

b. The evaluation of the automatic response process to include the on-shift and pooled ERO positions will be completed 4 months prior to Unit 3 Cycle 18 Refueling outage or 4 months prior to Unit 2 Cycle 19 Refueling outage or August 31, 2016, whichever comes first.

c. The evaluation and identification of additional work areas and equipment for the performance of expanded response functions will be completed by December 23, 2014.

SCE Alternative Course of Action for NRC Staffing Request for 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, multi-unit event, including any new or revised agreements with offsite resource providers (e.g., staffing, equipment, transportation, etc.).

Changes will be identified as follows:

Enclosure 3 Page 4 of 4 Those associated with the Phase 1 staffing assessment.

SCE Response to Item #6 No changes will be made to the emergency plan as a result of the Phase 1 staffing assessment.

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