CP-201300539, Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-chi Accident,...

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Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-chi Accident,...
ML13128A077
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/30/2013
From: Madden F
Luminant Generation Co, Luminant Power
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201300539, TXX-13081
Download: ML13128A077 (30)
v • d • e


Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Luminant rafael.flores@Luminant.com Glen Rose, TX 76043 T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201300539 Ref: 10 CFR 50.54(o TXX-13081 April 30, 2013 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 RESPONSE TO MARCH 12,2012, REQUEST FOR INFORMATION PURSUANT TO TITLE 10 OF THE CODE OF FEDERAL REGULATIONS 50.54(F) REGARDING RECOMMENDATIONS OF THE NEAR-TERM TASK FORCE REVIEW OF INSIGHTS FROM THE FUKUSHIMA DAI-ICHI ACCIDENT, ENCLOSURE 5, RECOMMENDATION 9.3, EMERGENCY PREPAREDNESS - STAFFING, REQUESTED INFORMATION ITEMS 1, 2, AND 6 - PHASE 1 STAFFING ASSESSMENT

REFERENCE:

1. NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3 and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated March 12, 2012
2. Luminant Generation Company LLC's 60-Day Response, dated May 10, 2012, to NRC Letter Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012
3. NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012
4. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012

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 2.1, 2.3 and 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 A member of the STARS Alliance Callaway - Comanche Peak

  • Diablo Canyon
  • Palo Verde
  • San Onofre - South Texas Project
  • Wolf Creek

U. S. Nuclear Regulatory Commission TXX-13081 Page 2 04/30/2013 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, Luminant Generation Company LLC (Luminant) submitted an alternative course of action for performing the requested actions and providing the requested information (Reference 2). Attachment I 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.

The enclosure to this letter provides the Units 1 and 2 Phase 1 Staffing Assessment Report. The Phase 1 Staffing Assessment Report follows the assessment process described in Reference 3.

In accordance with Reference 2, the enclosure to this letter provides the response to the following information requests:

" Reference 1, Enclosure 5, Staffing, Requested Information Item 1

  • Reference 1, Enclosure 5, Staffing, Requested Information Item 2
  • Reference 1, Enclosure 5, Staffing, Requested Information Item 6 A list of regulatory commitments contained in this letter is provided in the attachment to this letter.

Should you have any questions, please contact Dennis Buschbaum at (254) 897-5851 or dennis.buschbaum@lumirnant.com.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of April 2013.

U. S. Nuclear Regutatory Commission TXX-13081 Page 3 04/30/2013 Sincerely, Luminant Generation Company LLC Rafael Flores By:

/Fred W. Madden Director, Oversight & Regulatory Affairs Attachment - List of Regulatory Commitments COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 Enclosure - PHASE 1 ON-SHIFT STAFFING ASSESSMENT c- A. T. Howell, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak

Attachment to TXX-13081 Page 1 of 1 List of Regulatory Commitments This communication contains the following enhancements which will be entered into the CPNPP Commitment Tracking System and completed or incorporated into the licensing basis as noted:

Number Commitment Due Date/Event 4630659 Integrate the expanded response capability into existing 10/31/2014 augmented Emergency Response Organization (ERO) processes (i.e., the ability to transition from a single-unit to a multi-unit expanded response capability).

4630672 Develop plans/procedures that address the use of 10/31/2014 expanded response capability in the on-site/near-site primary and alternate emergency response facilities (e.g.,

OSC and TSC) for declared emergency events that involve more than one-unit at multi-unit sites. This should include the relocation of expanded response capability to the alternate emergency response facility, should the primary emergency response facility be rendered inoperable.

4630681 Identify and Integrate into the ERO 12/31/2013 notification/activation protocol those non-ERO response personnel (e.g., Operations and Maintenance) necessary to support expanded response capability functions.

The Commitment number is used by Luminant Power for the internal tracking of CPNPP commitments

Enclosure to TXX-13081 Page 1 of 26 ENCLOSURE TO TXX-13081 COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 PHASE 1 ON-SHIFT STAFFING ASSESSMENT

Enclosure to TXX- 13081 Page 2 of 26 Table of Contents 1 Introduction .......................................................................................................................................... 3 2 Staffing Analysis Process Overview ............................................................................................. 3 2.1 On-Shift Staffing Analysis Process. ....................................................................................... 3 2.2 Expanded ERO Analysis Process ........................................................................................... 3 3 NEI 12-01 Phase 1 Analysis Sum m ary ......................................................................................... 4 3.1 Enhancem ents Identified ..................................................................................................... 4 4 Assum ptions ......................................................................................................................................... 4 4.1 NEI 12 Assum ptions for Staffing Analysis ..................................................................... 4 4.2 N EI 10 Applicable Assum ptions ..................................................................................... 6 4.3 Plant Specific Assum ptions ....................................................................................................... 7 5 On-Shift Staffing Analysis .......................................................................................................... 8 5.1 On-Shift Staffing Analysis ....................................................................................................... 8 5.2 On-Shift Staffing Analysis Summ ary ..................................................................................... 12 6 Expanded ERO Response Analysis .............................................................................................. 12 6.1 Expanded ERO Response Analysis Details ......................................................................... 12 6.2 Expanded ERO Response Analysis Sum m ary ..................................................................... 14 7 Program Controls ............................................................................................................................... 17 7.1 Em ergency Response Drills & Exercise Program ................................................................. 17 7.2 Training .......................................................................................................................................... 17 7.3 Implem enting Guidance .............................................................................................................. 17 7.4 Onsite Staff Ability to M ove Back-up Equipm ent .............................................................. 17 8 Security Consideration ...................................................................................................................... 18 9 Im plem entation Schedule - Regulatory Com mitm ents ............................................................ 18 10 References ............................................................................................................................................ 19 11 Attachm ent 1 - Staffing Assessm ent Tables ............................................................ 21

Enctosure to TXX-13081 Page 3 of 26

1. Introduction This report provides the staffing assessment for Comanche Peak Nuclear Power Plant (CPNPP)

Units 1 and 2 to comply with the: 1) U.S. Nuclear Regulatory Commissions (NRC) request issued in Reference 1, Enclosure 5 and 2) approach endorsed by the NRC in Reference 2. The CPNPP Units 1 and 2 Phase 1 staffing assessment is in accordance with the guidance provided in Interim Staff Guidance NSIR/DPR ISG-01, Nuclear Energy Institute (NEI) 10-05, and NEI 12-01 (References 17, 18, and 19, respectively). CPNPP is providing the Phase 1 information to address Request Numbers 1, 2, and 6 of Reference 20.

CPNPP assessed the current Units 1 and 2 staffing levels to determine the appropriate staff to fill the positions required to respond to a dual-unit, Beyond Design Basis External Event (BDBEE), that results in an extended loss of alternating current (AC) power (i.e., extended Station Blackout (SBO))

and impeded access to the units. The assessment establishes the minimum number of personnel and the specific composition of the response staff required to implement existing mitigation strategies and repair actions intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling for both units. This Phase I staffing assessment considered applicable actions from the SBO coping strategies in place at CPNPP at the time of the assessment.

2. Staffing Analysis Process Overview 2.1 On-Shift Staffing Analysis Process The Comanche Peak Phase 1 On-Shift Staffing Analysis (OSA) was conducted in accordance with NEI 12-01 and NEI 10-5. The On-Shift Staffing Analysis was performed by a multi-disciplined team using site procedures to analyze the performance of tasks by the minimum on-shift staff as designated in the Emergency Plan. Task areas analyzed include:
  • Event Mitigation (Emergency Operating Procedures (EOP), Abnormal Operating Procedures (ABN), other site procedures
  • Station Blackout Procedures (EOP and ABN)

" Radiation Protection (RP) and Chemistry Technician Functions (as specified in site response procedures)

Existing strategies for responding to an extended loss of AC power (Station Blackout) affecting all onsite units were evaluated in the On-Shift Staffing Analysis. The staffing analysis addressed the ability of the on-shift staff to perform any required emergency response functions that would be degraded or lost prior to the delayed arrival of additional Emergency Response Organization (ERO) personnel.

To conduct the assessment, a team of subject matter experts representing Comanche Peak Operations, Radiation Protection, Chemistry, and Security as well as Emergency Preparedness met with consultants in a tabletop exercise in February 2013. The participants reviewed the assumptions and applied existing procedural guidance in coping with a BDBEE using minimum On-Shift Staffing. Particular attention was given to the sequence and timing of each procedural step, its duration, and the position performing it.

2.2 Expanded ERO Analysis Process The expanded ERO analysis 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

Enclosure to TXX-13081 Page 4 of 26 specific accident analysis and mitigation functions. The capability of the current ERO staffing at Comanche Peak to perform these expanded ERO functions was assessed.

3. NEI 12-01 Phase 1 Analysis Summary No conflicts, deficiencies, or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during the initial 6-hour period. No Transition Phase actions were required within the first six hours of the event.

Using NEI 12-01 guidance, the minimum On-Shift Staff as defined in Staffing Table 1, CPNPP Emergency Plan, performed all actions required by operating and Emergency Plan procedures in the initial 6-hour period, relying only on installed structures, systems, and components available in the Initial Phase of the response. Plant conditions did not require any other equipment to be used.

Using existing procedures and strategies, the site was able to respond to the event utilizing installed plant equipment and the minimum On-Shift Staffing complement.

There were no unanalyzed tasks that required a time motion study.

3.1 Enhancements Identified Three enhancements are planned as a result of the assessment;

1. Integrate the expanded response capability into existing augmented Emergency Response Organization (ERO) processes (i.e., the ability to transition from a single-unit to a multi-unit expanded response capability).
2. Develop plans/procedures that address the use of expanded response capability in the onsite/near-site primary and alternate emergency response facilities (e.g., OSC and TSC) for declared emergency events that involve more than one-unit at multi-unit sites. This should include the relocation of expanded response capability to the alternate emergency response facility, should the primary emergency response facility be rendered inoperable.
3. Identify and integrate into the ERO notification/activation protocol those non-ERO response personnel (e.g., Operations and Maintenance) necessary to support expanded response capability functions.
4. Assumptions 4.1 NEI 12 Assumptions for Staffing Analysis NEI 12-01 establishes a set of standard assumptions that have been used in the development of this report.
1. A large-scale external event occurs that results in:

" all onsite units affected

" extended loss of AC power

" impeded access to the units

2. Initially, all onsite reactors are operating at full power and are successfully shut down.

Enctosure to TXX- 13081 Page 5 of 26

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

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

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

Each licensee should identify transportation and site access-enhancing methods in accordance with Section 3.9 of NEI 12-01, and include this information in the response to Staffing Information Request #4. The Information Request #4 response should also include an overview discussion of how the identified methods will be implemented following a beyond design basis external event.

A staffing assessment may utilize a "no site access" end time of less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and greater than or equal to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, if supported by a documented basis. This basis should include a discussion of the site-specific transportation-related resources and capabilities, and related supporting arrangements, which provide assurance that augmented staff would be available on the site starting at the time used in the assessment. These resources and capabilities could be provided by Company-internal, private or public sources (including vehicles and aircraft, such as helicopters from military and National Guard organizations). All arrangements with the anticipated service providers should be documented (e.g., Letter of Agreement, contract, etc.).

A staffing assessment may not utilize a "no site access" end time of less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

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 (for licensee Action #6 of Table 1.1) should consider the applicable actions from the Station Blackout (SBO) coping strategies in place at the time of the assessment. Such actions may include 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 do not include those associated with cross-tying AC power sources or electrical distribution buses between units since, as stated in assumption number 2.2.1, all onsite units are experiencing an extended loss of AC power.

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 staffing assessments performed in response to the NRC letter should include consideration

EncLosure to TXX-13081 Page 6 of 26 of those IER improvement actions already implemented at the time of the assessment (e.g.,

incorporated into plant procedures).

Sites with existing strategies for responding to an extended loss of AC power affecting all onsite units should consider those actions in their Phase 1 staffing assessment.

4.2 NEI 10 Applicable Assumptions NEI 10-05 establishes a set of standard assumptions that have been used in the development of this report.

The following assumptions and limitations are applicable to the OSA.

1. On-shift personnel can report to their assigned response locations within the timeframes sufficient to allow for performance of assigned actions.
2. The On-Shift Staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.
3. It is assumed that personnel assigned to the major response area of Plant Operations and Safe Shutdown meet the requirements and guidance established by NRC regulations and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown.

Staff performance within this area is not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.

4. Onsite security organization: Performance of this function is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.
5. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.
6. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.
7. The task of performing a peer check has minimal impact on the ability to perform other assigned functions/ tasks, and is therefore an acceptable collateral duty for all positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.
8. The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday). For purposes of this analysis, and consistent with NEI 12 Assumption 4, 360 minutes (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) will be used as the time period for the conduct of on-shift ERO response actions.

Enclosure to TXX-13081 Page 7 of 26 4.3 Plant Specific assumptions NEI 12-01 defines the following phases for response to the BDBEE:

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.

For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase coping actions. No Transition Phase actions involving the use of portable equipment are required in the first six hours, based on plant conditions.

No longer term Transition Phase actions were evaluated because none were established at the time of this assessment. The Transition Phase will be addressed in the Phase 2 staffing assessment.

Enclosure to TXX-13081 Page 8 of 26

5. On-Shift Staffing Analysis 5.1 On-Shift Staffing Analysis The On-Shift Staffing requirements for Comanche Peak Units 1 & 2 are listed in the table below. The methodology of NEI 12-01 requires that only personnel required to be on-shift complement (shown below) can be credited in the staffing analysis.

Position Emergency Plan Shift Manager SM 1 Unit Supervisor US 1 Shift Technical Advisor STA 1 Reactor Operator RO 2 Nuclear Equipment Operator NEO 4 Chemistry Technician CHEM 2 Radiation Protection Technician RP 2 Prompt Team Members Mechanic MM 1 Electrician EM 1 I&C Technician IC 1 Emergency Communicator I&C Technician #2 IC 1 Security Personnel SEC Per Security Plan This event assumes a loss of offsite power combined with a failure of the emergency diesel generators to load. All remaining power is supplied by the station batteries. The loss of AC power to emergency buses initially results in the declaration of a Site Area Emergency (EAL SS4.1). When it becomes apparent that power will be unavailable for a prolonged period, the event classification is escalated to a General Emergency (EAL SG1.1).

Table 5.1 designates each member of the minimum shift complement with a brief description of duties.

Table 5.1 On-Shift Positions On-Shift Duties Position SM Overall command of both units Emergency Plan implementation US Unit I supervision STA Unit 2 supervision RO #1 Manipulation of Unit I controls RO #2 Manipulation of Unit 2 controls NEO #1 Perform local equipment manipulations as needed NEO #2 Perform local equipment manipulations as needed NEO #3 Perform local equipment manipulations as needed NEO #4 Perform local equipment manipulations as needed Chem #1 Perform local equipment manipulations as needed Chem #2 Perform local equipment manipulations as needed RP #1 Conducts radiological monitoring as needed RP #2 Conducts radiological monitoring as needed MM Perform local equipment manipulations as needed EM Perform local equipment manipulations as needed IC #1 Perform local equipment manipulations as needed IC #2 Emergency Communicator

Enclosure to TXX-13081 Page 9 of 26 ECA-0.0 A/B (Unit 1 & 2 "Loss of All AC Power" procedures) are the governing procedures for this event which involves loss of all onsite and offsite AC power with the exception of that provided from the station batteries. Battery life to support instrumentation, with load shedding as prescribed in ECA 0.0, is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Valve and breaker operation must be performed locally by Nuclear Equipment Operators (NEO).

The strategy employed in this event is to establish core cooling by natural circulation and to perform a plant cooldown using the steam-driven auxiliary feedwater pump. Manual local control is required of the steam generator relief valves to control the cooldown. Because no condenser vacuum exists due to the loss of AC power, heat removal from the steam generators is achieved by venting steam directly to the atmosphere thereby continually depleting the feedwater supply. The seismically qualified condensate storage tank (CST) volume is sufficient for at least 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> without replenishment.

Table 5.2 provides a timeline of each position during the event. Table 5.2 lists the major activities by position in 15-minute increments for the first six hours of the event. Table 5.2 shows that no overlap occurs in assigning actions to the on-shift staff. Adequate staffing is in place to allow each position to complete an assigned task before assuming another one.

Each on-shift position from Emergency Plan minimum Staffing Table 1 was entered in Table 1 of Attachment

1. For position titles with more than one position holder, a unique sequential number was assigned to each position (e.g., RO #1, RO #2 etc). The site Emergency Plan reference that describes the requirement for the position to be on-shift was then entered into column 3 of Table 1 of Attachment 1. Using only the on-shift positions entered in Table 1 of Attachment 1, the remaining Attachment 1 tables were completed by entering the shift position that fills a described role, or performs a specific function or tasks:
  • Table 2 - Plant Operations & Safe Shutdown - Two Units - Two Control Rooms

" Table 3 - Firefighting (not applicable for this event analysis)

  • Table 4 - Radiation Protection & Chemistry Time Line 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 Attachment 1, Table 1. For each position, the table number and associated line number was then entered in column 4, "Role in Table# /Line#." If the associated task required compensatory actions, a YES was placed in the last column and the compensatory action recorded in the results section of this report.

In addition to the operational activities listed, other members of the On-Shift Staff are engaged in Emergency Plan implementation activities as shown in Table 5 of Attachment 1. While the initial emergency declaration is a Site Area Emergency, the scenario assumes that the Shift Manager is informed at T= 60 that offsite power will be unavailable for an extended period. That notification prompts the declaration of a General Emergency at T= 61.

Enclosure to TXX-1 3081 Page 10 of 26 Table 5.2 Summary of On-Shift Staff Actions SAction in progress Event Time (hrs.)

1 0 1 1 1 2 13 41 5 0- 15- 30- 45- 0- 15- 30- 45- 0- 15 45 15- 30 0 30 Position 0- 115- 30 1 15 30 45 60 15 30 45 60 15 30 45 60 15 30 45 60 15 30 45 60 15 30 45 60 Shift Manager Emergency Plan implementation Unit Supervisor #1 Unit 1 supervision Shift Technical Advisor Unit 2 supervision Reactor Operator # 1 ECA-0.0 A performance Reactor Operator #2 ECA-0.0 B performance Nuclear Equipment Operator #1 Attempt local start of emergency diesels Nuclear Equipment Operator #2 Attempt local start of emergency Nuclear Equipment Operator #3 Isolate RCP Seals CST Isolation Attempt start Alternate Power Generator Local Control of SG atmospherics Nuclear Equipment Operator #4 Isolate RCP Seals CST Isolation Attempt start Alternate Power Generator Local Control of SG atmospherics

Enclosure to TXX-13081 Page 11 of 26 Table 5.2 Summary of On-Shift Staff Actions Action in progress Event Time (hrs.)

00 1 1 2 I 3 14 I 5 0 30 0- 15- 30 0- 15- 30- 45- 0- 15- 30- 45 15 45- 0 30 Position 15 30 45 60 15 30 45 60 15 30 45 60 15 30 45 60 15 30 45 60 15 30 45 60 Radiation Protection Tech #1 Access Control Radiation Protection Tech #2 Available for job coverage Chemistry Technician #1 Establish Local Control of Auxil Feedwater Establish Local control of SG Atmospherics Mechanical Maintenance #1 Establish Local control of SG Atmospherics Electrical Maintenance #1 Direct Current (DC) Load Shed I&C Technician #1 DC Load Shed I&C Technician #2 CR Communicator

Enclosure to TXX-13081 Page 12 of 26 5.2 On-Shift Staffing Analysis Summary Using existing procedures and strategies, the minimum On-Shift Staff as defined in the Emergency Plan, shown on Table 5.1, was able to cope by relying on installed plant equipment and the minimum On-Shift Staffing complement.

No conflicts, deficiencies, or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during the initial 6-hour period. No Transition Phase actions were required within the first six hours of the event.

The minimum On-Shift Staff performed all actions required by operating and Emergency Plan procedures in the 6-hour period, relying only on installed structures, systems and components available in the Initial Phase of the response. Plant conditions did not require any other equipment to be used.

6. Expanded ERO Response Analysis 6.1 Expanded ERO Response Analysis Details The augmented ERO for a multi-unit site such as Comanche Peak would be challenged to effectively respond to a beyond design basis external event that resulted in an extended loss of AC power affecting more than one unit. 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 emergency response functions. The focus of this "expanded response capability" at Comanche Peak would be to enable the performance of unit-specific accident assessment and mitigation functions across multiple units.

The generic assumptions of NEI 12-01 stipulate that site access is unavailable for six hours post-event, thereby limiting all response and mitigation actions to the capability of the On-Shift Staff. After six hours, a significant portion of the augmented ERO is assumed to have arrived onsite. Because Comanche Peak employs an "all-call, all-come" approach to ERO response in that all ERO members are expected to respond upon notification, sufficient personnel will be available to meet the immediate needs of the station with additional personnel designated as relief.

Table 3.1 of NEI 12-01 lists the recommended complement and staffing considerations for each expanded ERO position. Table 6.1 below replicates the substance of that table and includes information specific to Comanche Peak.

Enclosure to TXX- 13081 Page 13 of 26 Table 6.1 Expanded Response Functions for Phase 1 Staffing Assessment ERO Expanded Response Location Key Roles and Staffing Considerations Members Remarks Function Available Unit Response TSC

  • Overall cognizance of the activities related to TSC 4 trained and Coordination implementation of repair and corrective actions Manager qualified and implementation of Transition Phase coping individuals and Severe Accident management (SAM) available strategies for an assigned unit.
  • One individual per unit; individuals should not be assigned other functions.

Operations TSC

  • Provides coordination of Operations staff and TSC Ops 4 trained and Coordination support for an assigned unit. Coordinator qualified
  • One individual per unit; individuals should not individuals be assigned other functions. available Maintenance OSC
  • Provides coordination of Maintenance staff and OSC 4 trained and Coordination support for an assigned unit. Manager qualified
  • One individual per unit; individuals should not individuals be assigned other functions, available Engineering TSC
  • Provides coordination of Engineering staff and TSC 8 trained and Coordination support for an assigned unit. Engineering qualified
  • One individual per unit; individuals should not Coordinators individuals be assigned other functions, available Engineering TSC
  • One team for each unit to perform engineering Trained and Assessments assessments in support of repair and corrective TSC qualified actions. Engineering individuals
  • Team composition (i.e., number and Teams available as follows; represented disciplines) as described in the Emergency Plan. Mechanical - 8 e Team may include personnel responsible for Electrical - 8 performing other functions for the same I&C -8 assigned unit.

Evaluation of Severe TSC

  • One team for each unit to evaluate selection of TSC Eng. Trained and Accident SAM strategies; team performs evaluations not Team qualified Management (SAM) done by Control Room personmel. consisting of individuals Strategies o Team composition (i.e., number and the available as follows; represented disciplines) as described in following governing site programs, procedures, and members; guidelines. SAMG Eng., SAMG Eng. - 4
  • Team may include personnel responsible for Ops Eng., OPS Eng. - 4 performing other functions for the same Analysis Analysis Eng. - 8 assigned unit. Eng., RX Eng. - 5 Rx Eng.

Unit In-Plant Team OSC

  • Overall cognizance of onsite and in-plant teams OSC ERDC 10 trained and Coordination performing or supporting repair and corrective Team qualified actions for an assigned unit. Coordinators individuals o One individual per unit; individuals should not available be assigned other functions.

Non-Licensed OSC o Two individuals per unit to assist with NEO's 39 trained and Operators (NEOs) implementation of repair and corrective qualified actions. individuals o Should not include members of the On-Shift available Staff.

Enclosure to TXX- 13081 Page 14 of 26 Table 6.1 Expanded Response Functions for Phase 1 Staffing Assessment ERO Key Roles and Staffing Considerations Members Remarks Available

" Two individuals per unit to implement repair OSC MM 34 trained and and corrective actions, qualified

" Staffing may include an on-shift individual individuals (i.e., 2 individuals for a unit composed of 1 on- available shift and 1 augmented).

" Two individuals per unit to implement repair OSC EM 23 trained and and corrective actions. qualified

" Staffing may include an on-shift individual individuals (i.e., 2 individuals for a unit composed of I on- available shift and 1 augmented).

" Two individuals per unit to implement repair OSC IC 16 trained and and corrective actions, qualified

" Staffing may include an on-shift individual individuals (i.e., 2 individuals for a unit composed of I on- available shift and 1 augmented).

" Number and composition of personnel capable See separate of simultaneous implementation of any 2 SAM SAMG strategies at each unit. strategy

  • Should not include personnel assigned to other analysis functions (e.g., emergency repair and corrective below actions); however, may include members of the On-Shift Staff and personnel responsible for Transition Phase coping strategies.

Review of the Comanche Peak ERO roster indicates that there are sufficient numbers of experienced and qualified individuals to fill the positions in Table 6.1 with adequate depth to staff at least two 12-hour shifts.

The following enhancement is planned:

Identify and integrate into the ERO notification/activation protocol those non-ERO response personnel (e.g., Operations and Maintenance) necessary to support expanded response capability functions.

6.2 Expanded ERO Response Analysis Summary Exnanded ERO - RP Coverage NEI 12-01 also recommends that each station have a sufficient number of Radiation Protection Technicians (RP's) to support Emergency Plan functions and expanded response capability following a BDBEE. That number is determined by the following formula:

RPTT = RPTcoP + RPTRcA + RPTNc Where:

RPTT = Total required number of onsite RPTs

Enclosure to TXX-13081 Page 15 of 26 RPTcoP = Number needed to support implementation of any 2 extended loss of AC power coping strategies per unit.

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

RPTNC = Number of onsite RPTs 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.

For Comanche Peak, the resulting number of RPTs is:

RPT Number Category Required Comments RPTcop 1* Staffing assessment results indicate that normal support of RP Technicians to provide access point monitoring for operations personnel to perform their assigned actions. CPNPP has one access point for Units 1 and 2.

RPTRCA 4 2 technicians x 2 units RPTNC 2* Offsite Radiological Assessments RPTT 7*

  • Note this number applies to Initial Phase actions only. Transition Phase actions will be determined in the Phase 2 assessment.

Following a beyond design basis external event, RP Technicians are available to support performance of assigned Emergency Plan functions and the expanded response capability. In the event of fuel damage, prevailing dose rates would likely require that the site's RP Technician complement be augmented with technicians from outside sources. The Comanche Peak ERO has a sufficient number of RPTs to perform these functions for two continuing 12-hour shifts. If needed, additional resources can be obtained through agreements in place with Chicago Bridge and Iron for maintenance and radiation protection personnel.

Work Location for the Expanded ERO If access to designated emergency response facilities is not possible, ERO members are trained to report to the alternate location.

The following enhancement is planned:

Develop plans/procedures that address the use of expanded response capability in the onsite/near-site primary and alternate emergency response facilities (e.g., OSC and TSC) for declared emergency events that involve more than one-unit at multi-unit sites. This should include the relocation of expanded response capability to the alternate emergency response facility, should the primary emergency response facility be rendered inoperable.

Enclosure to TXX-13081 Page 16 of 26 Administrative Support Personnel A limited number of administrative personnel are designated as part of the ERO. Other administrative support personnel who assist the augmented ERO members are not assigned critical response tasks. Augmented ERO personnel are capable of performing their assigned tasks and responsibilities without requiring administrative support other than what is provided as part of the existing ERO.

SAMG Implementations The assessment considered the number and qualifications of SAMG implementers required for simultaneous implementation of the two most intensive SAMG strategies on both units.

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. Two strategies were evaluated:

Control Containment Conditions SAG-6 Flood Containment SAG-8 Implementation of the Control Containment Conditions SAG-6 strategy requires the following resources.

Resource Number per unit Function NEOs Implement EDMG A.4-1 for 2 Refueling Water Storage Tank (RWST) Makeup as needed NEOs 2 Implement EDMG A.4.7 for

+ Portable Spray if Containment is 1 common for Fire breached protection water source RP Technician 1 Monitor Dose rates Implementation of the Flood Containment SAG-8 Strategy requires the following resources.

Resource Number per Unit Function NEOs Implement EDMG A.4-1 for 2 Refueling Water Storage Tank RWST Makeup as needed NEOs Implement EDMG A.4-6 2 Containment Flooding with Portable Pump Mechanic (MM) Removing blank flange from 2 Containment spray line for EDMG A.4-6 Containment flooding with Portable Pump RP Technician 1 Monitor Dose rates

Enclosure to TXX-13081 Page 17 of 26 Implementation of strategies SAG-6 and SAG-8 simultaneously would require the following personnel resources:

  • 17 Nuclear Equipment Operators
  • 4 OSC Mechanics
  • 4 RP Technicians
7. Program Controls 7.1 Emergency Response Drills & 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 CPNPP 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 planned 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. CPNPP 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 The following enhancement is planned:

Integrate the expanded response capability into existing augmented Emergency Response Organization (ERO) processes (i.e., the ability to transition from a single-unit to a multi-unit expanded response capability).

7.4 Onsite Staff Ability to Move Back-up Equipment US Nuclear Regulatory Commission (NRC) letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident,"

dated March 12, 2012 REQUESTED INFORMATION states in part.

The following function is 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 NTIF Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table 8-1, such as plant operations and assessment of operational aspects, emergency direction and control,

Enclosure to TXX-13081 Page 18 of 26 notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.

Response to "How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor" will be provided in the Phase 2 staffing analysis.

8. Security Considerations Existing coping strategies do not anticipate the use of Security Officers to perform duties unrelated to their assigned roles. Security Officers will perform functions within their current roles such as monitoring and controlling site access and providing compensating measures for any vital area doors that may need to remain open to facilitate room environmental conditions.
9. Implementation Schedule - Regulatory Commitments The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions and are not considered to be regulatory commitments.

SCHEDULED COMMITMENT COMPLETION COMMITMENT NUMBER DATE Integrate the expanded response capability into existing augmented Emergency Response Organization (ERO) processes (i.e., the ability to 4630659 10/31/2014 transition from a single-unit to a multi-unit expanded response capability).

Develop plans/procedures that address the use of expanded response capability in the onsite/near-site primary and alternate emergency response facilities (e.g., OSC and TSC) for declared emergency events that involve more than one-unit at multi-unit sites. This 4630672 10/31/2014 should include the relocation of expanded response capability to the alternate emergency response facility, should the primary emergency response facility be rendered inoperable.

Identify and Integrate into the ERO notification/activation protocol those non-ERO response personnel (e.g., Operations and 4630681 12/31/2013 Maintenance) necessary to support expanded response capability functions.

Enclosure to TXX-13081 Page 19 of 26

10. References
1. Letter from E. J. Leeds (NRC) and M. R. Johnson (NRC), to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendation 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 D. L. Skeen (NRR) to Susan Perkins-Grew (NEI) dated May 15, 2012, U.S.

Nuclear Regulatory Commission Review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, May 2012

3. EOP-0.OA/B, "Reactor Trip Or Safety Injection," Revision 8
4. ABN-601A/B, "Response To A 138/345KV System Malfunction," Revision 11
5. ABN-602 "Response To A 6900/480 Volt System Malfunction," Revision 8
6. ECA-0.OA/B, "Loss Of All AC Power," Revision 6
7. ECA-0.OA/B, "Loss Of All AC Power," Revision 4
8. ECA-TP-11-001A/B, "Loss Of All AC Power Recovery Without SI and with APG,"

Revision 1

9. SOP-614A/B, "Alternate Power Generator Operation," Revision 12
10. SAG-6, "Severe Accident Management Guidance - Control Containment Conditions,"

Revision 2

11. SAG-8, "Severe Accident Management Guidance - Flood Containment," Revision 2
12. EPP-201, "Assessment Of Emergency Action Levels Emergency Classification And Plan Activation," Revision 12
13. EPP-303, "Operation of Computer Based, Emergency Dose Assessment System,"

Revision 13

14. EPP-304, "Protective Action Recommendations," Revision 13
15. EPP-314, "Evacuation and Accountability," Revision 9
16. Letter from Luminant to Nuclear Regulatory Commission, "Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, 90-Day Response to March 12, 2012 Information Request Regarding Recommendation 9.3 of the Near-Term Task Force,"

dated June 7, 2012

17. NSIR/DPR ISG-01, "Interim Staff Guidance Emergency Planning for Nuclear Power Plants," Revision 0, November 2011

Enclosure to TXX-13081 Page 20 of 26

18. NEI 10-05, Revision 0, June 2011, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities"
19. NEI 12-01, Revision 0, May 2012, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities"
20. Luminant Generation Company, LLC's 60-Day Response, dated May 10, 2012, to NRC Letter "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012

Enclosure to TXX-1 3081 Page 21 of 26 ATTACHMENT 1 STAFFING ASSESSMENT TABLES

Enclosure to TXX- 13081 Page 22 of 26 Attachment 1 Staffing Assessment Tables TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Role in Uanyz TMe (min) Table#/Line# Task? Required?

T2/L1 T5/L1 T5/L3 T5/L4 CPNPP Emergency Plan N/A T5/L5 1 Shift Manager Table 1.1 T5/L8 No No T5/L16 T5/L16 T5/L17 T5/L18

______________________T5/1,19 2 Unit Supervisor CPNPP Emergency Plan N/A T2/L2 No No Table 1.1 Shift Technical CPNPP Emergency Plan 3 Advisor (STA) Table 1.1 N/A T2/L3 No No 4 Reactor Operator #1 CPNPP Emergency Plan N/A T2/L4 No No Table 1.1 5 Reactor Operator # 2 CPNPP Emergency Plan N/A T2/L5 No No Table 1.1 6 Station Operator# CPNPP Emergency Plan N/A T2/L6 No No Table 1.1 7 CPNPP Emergency Plan N/A T2/L7 No No 7 Station Operator #2 Table 1.1 8 Station Operator #3 CPNPP Emergency Plan N/A T2/L8 No No I_ Table 1.1 9 Station Operator #4 CPNPP Emergency Plan N/A T2/L9 No No Table 1.1 10 Chem Technician #1 CPNPP Emergency Plan N/A T2/L10 No No Table 1.1 T4/L3 11 Chem Technician #2 CPNPP Emergency Plan N/A T2/L11 No No Table 1.1 T4/L4 12 RP Technician #1 CPNPP Emergency Plan N/A T2/L12 No No Table 1.1 T4/Ll 13 RP Technician #2 CPNPP Emergency Plan N/A T2/L13 No No Table 1.1 T4/L2 CPNPP Emergency Plan T2/L14 Table 1.1 T5/L6 14 Communicator N/A T5/L9 No No (I&C Technician # 2) T5/L13 T5/L20 T5/L21 15 Mechanic CPNPP Emergency Plan N/A T2/L15 No No Table 1.1 16 Electrician CPNPP Emergency Plan N/A T2/L16 No No Table 1.1 17 I&C Technician #1 CPNPP Emergency Plan N/A T2/L17 No No Table 1.1

Enclosure to TXX-13081 Page 23 of 26 Attachment 1 Staffing Assessment Tables (cont.)

TABLE 2 - Plant Operations & Safe Shutdown Two Units - Two Control Rooms Minimum Operations Crew Necessary to Implement ABNs and EOPs, or SAMGs if applicable Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 1 Shift Manager Shift Manager Operations Training 2 Unit Supervisor Unit Supervisor Operations Training 3 Shift Technical Advisor STA Operations Training 4 Reactor Operator # 1 Control Operator Operations Training 5 Reactor Operator #2 Control Operator Operations Training 6 Station Operator #1 NEO Operations Training 7 Station Operator #2 NEO Operations Training 8 Station Operator #3 NEO Operations Training 9 Station Operator #4 NEO Operations Training Other (non-Operations) Personnel Necessary to Implement ABNs and EOPs, or SAMGs if applicable Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 10 Chem Technician # 1 Chem # 1 Craft Training 11 Chem Technician #2 Chem #2 Craft Training 12 RP Technician #1 RP#1 Craft Training 13 RP Technician #2 RP #2 Craft Training 14 Commumicator I&C #2 Craft Training 15 Mechanic MM EP Training 16 Electrician EM Craft Training 17 I&C Technician I&C #1 Craft Training TABLE 3 - Firefighting Line Performed By Task Analysis Controlling Method N/A Not applicable. A fire does not occur in this event.

Enclosure to TXX-13081 Page 24 of 26 Attachment 1 Staffing Assessment Tables (cont.)

TABLE 4 - Radiation Protection & Chemistry

ý Action in progress

Enclosure to TXX- 13081 Page 25 of 26 Attachment 1 Staffing Assessment Tables (cont.)

TABLE 5 - Emergency Plan Implementation Unit 1 & Unit 2 Emergency Plan Implementation (Site Area Emergency)

Procedure Step Activity Event Duration Performed by Remarks No. Time EPP-201 4.3.6 Declare Emergency 0 15 Shift Manager Classification Level EPP-304 4.1.2 Approve offsite PARs N/A N/A N/A EPP-203 4.1.2 Approve content of 15 30 Shift Manager state/local notifications Approve extension of NA NA Shift Manager allowable dose limits EPP-203 4.1.3 Notification and 15 30 Shift Manager direction to On-Shift Staff (e.g., to assemble, evacuate, etc.)

EPP-203 4.1.3 ERO notification 15 30 CR Communicator Abbreviated NRC NA NA NA N/A - from assumptions, no notification of DBT hostile actions during this event scenario EPP-203 4.1.2 Complete state/local 15 30 Shift Manager notification form EPP-203 4.1.2 Perform state/local 15 30 CR Communicator notifications EPP-203 4.1.4 Complete NRC event 30 60 Shift Manager notification form Activate ERDS NA NA N/A Activated by TSC staff, Augmented staff task EPP-303 4.1.4 Offsite radiological N/A N/A N/A assessment EPP-203 4.1.4 Perform NRC 30 60 CR Communicator notifications EPP-203 4.1.6 Perform other site- NA NA Activated by TSC staff, specific event N/A Augmented staff task notifications (e.g.,

INPO, ANI, etc.)

EPP-314 4.1.2 Personnel 15 30 Security accountability

Enclosure "co TXX-13081 Page 26 of 26 Attachment 1 Staffing Assessment Tables (cont.)

TABLE 5 - Emergency Plan Implementation (cont.)

Unit 1 & Unit 2 Emergency Plan Implementation (General Emergency)

EPP-201 4.4 Upgrade Emergency 60 1 Shift Manager Performed when crew is able Classification Level to to determine restoration of at GE least one safeguard bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely EPP-304 4.1.2 Approve offsite PARs 61 5 Shift Manager EPP-203 4.1.2 Approve content of 66 5 Shift Manager state & local government notifications EPP-203 4.1.3 Notification and 71 1 Shift Manager direction to on-shift staff (e.g., to assemble, evacuate, etc.)

EPP-203 4.1.2 Perform state & local 71 5 CR Communicator government notifications EPP-203 4.1.4 Perform NRC 76 Continuous CR Communicator notifications

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