Text

Letter Regarding Entergy'S Response to the March 12, 2012, Information Request, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing
	ML13246A077
Person / Time
Site:	Indian Point
Issue date:	04/30/2013
From:	Ventosa J; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-13-070
	Download: ML13246A077 (57)
	v • d • e

a Entergy Enter-qy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President NL-13-070 April 30, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Entergy's Response to the March 12, 2012, Information Request, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 (Phase 1 Staffing Assessment)

Indian Point Unit Numbers 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCE:

1. NRC letter to Entergy, Request for Information Pursuantto Title 10 of the Code of FederalRegulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichiAccident, dated March 12, 2012 (ML12053A340)

2. Entergy letter to NRC, Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, dated May 11, 2012 (NL-12-054)

3. Nuclear Energy Institute (NEI) 12-01, Guideline for Assessing Beyond-Design-BasisAccident Response Staffing and Communications Capabilities,Revision 0, dated May 2012

4. NRC Order Number EA-12-049, Order to Modify Licenses with Regard to Requirements for Mitigation Strategiesfor Beyond-Design-BasisExternal Events, dated March 12, 2012 (ML12054A735)

5. NEI 10-05, Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities,Revision 0, dated June 2011

Dear Sir or Madam:

On March 12, 2012, the NRC staff issued 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 7A 0CfS cm 3 oC Pa/ \

4 NL-13-070 Docket Nos. 50-247 and 50-286 Page 2 of 4 Reference 1, Enclosure 5, Entergy Nuclear Operations, Inc. (Entergy) submitted an alternative course of action for performing the requested actions and providing the requested information (Reference 2).

Reference 2 described the alternative course of action and schedule for responding to the Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6.

Enclosure 1 to this letter provides the Indian Point Energy Center (IPEC) Phase 1 Staffing Assessment Report. The IPEC Phase 1 Staffing Assessment Report follows the assessment process described in References 3 and 5.

In accordance with Reference 2, this letter provides the response to Reference 1, Enclosure 5, Staffing, Requested Information Items 1, 2, and 6.

Response to Reauested Information Item 1:

It is requested that addresseesprovide an assessment of the onsite and augmented staff needed to respond to a large scale naturalevent meeting the conditions describedin the Discussionsection (Reference 1, Enclosure 5). This assessment should include a discussion of the onsite and augmented staff available to implement the strategiesas discussed in the emergency plan and/or describedin plant operatingprocedures. 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 repairlocations at each reactoras describedin the Order regardingthe NRC NTTF Recommendation 4.2. It is requested that considerationbe given to the major functionalareas of NUREG-0654, Table B-I, such as plant operations and assessment of operationalaspects, emergency direction and control, notification/communication,radiologicalaccident assessment,and supportof operationalaccident assessment,as appropriate.

New staff or functions identified as a result of the assessment.

" Collateralduties (personnelnot being prevented from timely performance of their assigned functions).

Enclosure 1 provides the IPEC on-shift staffing assessment conducted pursuant to Reference 2. A detailed timeline based upon the existing loss of alternating-current (AC) power was performed based upon operations' review of the applicable station procedures. The focus of the timeline was to identify all resources, both operators and support organizations that would be required to execute each task.

The data from the operations' timeline, as well as the review of radiation protection and chemistry resource requirements, was analyzed by applying the methodology specified in Reference 5 to evaluate the capability of the minimum on-shift staffing complement to execute the actions specified for operations, radiation protection, and chemistry and the required emergency plan responsibilities.

NL-13-070 Docket Nos. 50-247 and 50-286 Page 3 of 4 Based upon the minimum shift staffing, as specified in the IPEC Emergency Plan, the required minimum shift staffing of 26 is sufficient to support the required plant actions, as well as the emergency plan functions, without the assignment of collateral duties that would adversely affect the ability to execute the emergency plan functions.

The tables describing the required minimum staffing, the operations' timeline, and the Reference 5 staffing analysis tables for IPEC are included in Enclosure 1.

As described in Enclosure 1, development of the guidance to support the mitigation strategies required by Reference 4 must be completed in order to determine the applicable staffing requirements to address back-up equipment. Entergy will perform this assessment as part of the Phase 2 staffing assessment by November 3, 2014, as previously identified in Reference 2.

The staffing assessment provided in Enclosure 1 determined that no new staff or functions have been identified as a result of the Phase 1 assessment.

The staffing assessment provided in Enclosure 1 determined that the existing on-shift staff is sufficient to implement the existing loss of all AC power, multi-unit event response strategies, while supporting performance of the required emergency planning duties without unacceptable collateral duties.

Response to Requested Information Item 2:

Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate,please include in the schedule the time to implement the changes. provides the IPEC on-shift and augmented staffing assessment for the loss of all AC power, multi-unit event. Entergy will identify any appropriate modifications to the IPEC Emergency Plan Drill and Exercise Program upon completion of the mitigation strategies and associated guidance being developed in response to Reference 4 (November 3, 2014).

Response to Requested Information Item 6:

Identify changes that have been made or will be made to your emergency plan regardingthe 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 resourceproviders (e.g., staffing, equipment, transportation,etc.).

As described in Enclosure 1, the existing on-shift staff is sufficient to implement the existing loss of all AC power strategies at both units. No changes to the emergency plan on-shift staffing have been identified.

Also as described in Enclosure 1, the existing augmented emergency response organization (ERO) provides sufficient staffing to satisfy the expanded capability functions defined in Reference 3, Table 3.1. No changes to the emergency plan augmented ERO staffing have been identified.

As described in Enclosure 1, the existing agreements with offsite resource providers were determined to be adequate and no new or revised agreements are required.

The Phase 1 Staffing Assessment results for IPEC require the establishment of procedural controls to activate the expanded response capability. Entergy will incorporate instructions into applicable fleet or

NL-13-070 Docket Nos. 50-247 and 50-286 Page 4 of 4 site guidance for IPEC to activate the expanded response capability and to integrate this capability into the existing augmented ERO structure based upon the following conditions as described in Reference 3:

Loss of all offsite and all on-site power sources to AC emergency busses at more than one unit, or

Plant parameters or conditions require implementation of severe accident management strategies for more than one unit.

These changes will be implemented by March 5, 2014.

The new commitments contained in this submittal are summarized in the Attachment to this letter. If you have any questions concerning the content of this letter, please contact Mr. Robert Walpole, Manager, Licensing at (914) 254-6710.

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

Respectfully, JAV/sp

Enclosure:

Indian Point Energy Center Nuclear Energy Institute 12-01 Phase 1 Staffing Assessment

Attachment:

Indian Point Energy Center List of Regulatory Commitments cc: Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL Mr. William M. Dean, Regional Administrator, NRC Region 1 NRC Resident Inspectors Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ENCLOSURE TO NL-13-070 INDIAN POINT ENERGY CENTER NUCLEAR ENERGY INSTITUTE 12-01 PHASE 1 STAFFING ASSESSMENT ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286

ENTERGY INDIAN POINT ENERGY CENTER NEI 12-01 PHASE 1 STAFFING ASSESSMENT

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment Table of Contents 10 EXECUTIVE SUM M ARY ................................................................................. 2 2 .0 S CO PE .................................................................................................................... 2 3.0 EMERGENCY PLAN MINIMUM STAFFING ................................................. 5 4.0 BEYOND DESIGN BASIS EXTERNAL EVENT (BDBEE) ............................. 6 5.0 EMERGENCY PLAN IMPLEMENTATION .................................................... 12 6.0 ON-SHIFT STAFFING INITIAL PHASE COPING STRATEGIES AND CAPABILITY [RFI#1, lb, lc] .......................................................................... 13 7.0 TRANSITION PHASE STRATEGIES AND CAPABILITY ............................ 15 8.0 AUG M EN TED ERO ........................................................................................ 15 8 .1 ER O R esponse ..................................................................................................... 15 8.2 ERO Notification ............................................................................................. 16 8.3 ERO Notification with Degraded Communications Capabilities (RFI#3) ..... 16 8.4 Augmented ERO Site Access (RFI#4) ............................................................. 17 8.5 Expanded ERO ................................................................................................. 20 9.0 ON-SITE STAFF'S ABILITY TO MOVE BACK-UP EQUIPMENT [RFI#1a] ....28 10.0 STAFFING ASSESSMENT COMPLETION OF NEI 10-05 STYLE TABLES ....29 11.0 CHANGES / INTERIM ACTIONS TO SUPPORT PHASE 1 STAFFING A SSESSM EN T (RFI#5) ................................................................................... 31 12.0 IMPLEMENTATION SCHEDULE TO CONDUCT ONSITE AND AUGMENTED STAFFING ASSESSMENT (RFI #2) ..................................... 33 13.0 NEI 12-01 PHASE 1 STAFFING ASSESSMENT

SUMMARY

[RFI#1, #6] ........ 33 14.0 REFEREN CES ................................................................................................ 35 15.0 ATTA CHM EN TS ............................................................................................ 35 ATTACHMENT 1 - NEI 10-05 STYLE STAFFING TABLES FOR IPEC ........................ 37 ATTACHMENT 2 - ENHANCEMENTS ........................................................................ 49 NEI 12-01 Phase 1 Report 2013 April 2013 April Page Page 11 of of 49 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment 1.0 EXECUTIVE

SUMMARY

This report provides responses to the March 12, 2012, Nuclear Regulatory letter, Request for Information Pursuantto Title 10 of the Code of FederalRegulations 50.54(fW Regarding Recommendations2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insightsfrom the Fukushima Dai-IchiAccident," as committed in the Entergy letter to NRC, Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Plan for completing Emergency Communication and Staffing Assessments, dated May 11, 2012 (NL-12-054). The staffing assessment completion date of March 29, 2013 and submittal date of April 30, 2013 is in accordance with the Regulatory Commitment in the Entergy 60-day response letter. (ML12144A157).

This report provides responses to Enclosure 5, Recommendation 9.3 Staffing, Requested Information Items 1, 2, and 6. This response includes the results of the Phase 1 staffing assessment, as described in NEI 12-01, Guidelinefor Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilitiesand Emergency Plan implementation using the guidance of NEI-10-05, Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities.The report also includes a discussion of any changes planned in response to the Phase 1 assessment and the associated implementation schedule.

The Phase 1 staffing assessment concluded that the current minimum on-shift staffing as defined in the Indian Point Energy Center (IPEC) Emergency Plan 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. The Phase 1 assessment also identifies the staffing necessary to support the Expanded Response Capability for the beyond design basis external event (BDBEE) as defined for the Phase 1 assessment.

The Phase 1 assessment did, however, identify the need to establish guidance to activate the Expanded Response Capability and to integrate this capability into the existing augmented ERO structure. The need to establish this guidance is noted in Attachment 2.

2.0 SCOPE In response to the Fukushima Dai-lchi accident, US Nuclear Regulatory Commission (NRC) issued a letter, "Requestfor Information Pursuantto Title 10 of the Code of Federal Regulations50.54Wf) Regarding Recommendations2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insightsfrom the Fukushima Dai-IchiAccident,"dated March 12, 2012.

The information requests related to Emergency Preparedness (EP) are contained in April 2013 Page 2 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment Enclosure 5, "Recommendation 9.3: Emergency Preparedness" of this §50.54(f) Letter.

Within this enclosure are two Requested Actions (Communications and Staffing). Both Requested Actions involve performance of an assessment. The action for the staffing assessment is summarized below:

It is requested that addresseesassess their currentstaffing levels and determine the appropriatestaff to fill all necessarypositionsfor responding to a multi-unit event during a beyond design basis naturalevent and determine if any enhancements are appropriategiven the considerationsof Near-Term Task Force (NTTF) Recommendation 9.3.

Per the Entergy letter to NRC, Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Planfor completing Emergency Communication and Staffing Assessments, dated May 11, 2012, the April 30, 2013 submittal is required to provide the requested information for Phase 1 (all functions except those related to NTTF Recommendation 4.2) of the Staffing Assessment (Enclosure 5, Recommendation 9.3 Staffing, Information Request Nos. 1, 2, and 6). Specifically, these items are:

(1) Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in section 4.0. 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:

1.a How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NRC Near-Term Task Force (NTTF)

Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-i, 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.

1.b New staff or functions identified as a result of the assessment.

1.c Collateral duties (personnel not being prevented from timely performance of their assigned functions).

(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.

49 NEI 12-01 Phase I Report April 2013 April 2013 Page 3 Page 3 of of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment (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.).

While NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planningfor NuclearPower Plantsand NEI 10-05 address a SBO affecting a single-unit site, and one unit on a multi-unit site, they do not consider the scenario of an extended loss of AC power affecting all units on a multi-unit site. Licensees of multi-unit sites should perform an assessment of this scenario using the assumptions listed in NEI 12-01 and the methodology provided in NEI 10-05. In particular, the assessment should determine the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumptions, any Transition Phase actions that must be performed prior to the end of the "no site access" time period.

Phase I of the staffing assessment includes the Initial and Transition Phases of the approach for mitigating a BDBEE. In this assessment, the BDBEE is an external event causing multi-unit extended loss of AC power (ELAP) or extended SBO that result in:

All on-site units affected

Extended loss of AC power

" Impeded access to the units The Initial Phase assessment of the on-shift staffing is to determine the ability of the on-shift staff to implement Initial Phase coping strategies needed to respond to a large-scale external event causing multi-unit extended loss of AC power (ELAP). The Initial Phase requires the minimum on-shift staff to use installed equipment and resources to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling. The normal Emergency Response Organization (ERO) response time is 60 minutes, however, this assessment assumes no augmented ERO or support arrives for the first six (6) hours after the event occurred due to impediments preventing site access.

The Transition Phase will be accomplished using portable equipment stored on-site.

The strategies for this phase must be capable of maintaining core cooling, containment, and spent fuel pool cooling capabilities (following their restoration, if applicable) from the time they are implemented until they can be supplemented by offsite resources in the final phase which will be accomplished using the portable equipment stored on-site and augmented with additional equipment and consumables obtained from off-site.

NEI 12-01 Phase 1 Report 2013 April 2013 April Page 4 Page of 49 4 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment 2.1 Methodology A tabletop was used to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation during a six (6) hour SBO coping period and during the 6 to 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period with limited augmented staff. In cases where multiple tasks were assigned to an individual in their role, the team evaluated timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements. A team of Emergency Planning and Operations personnel completed the assessment of the on-shift staffs response to the SBO Initial Phase (6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ). Security, Radiation Protection, and Chemistry also provided input for their expected response to a station blackout. The guidance of NEI 10-05 was used to determine if the number and composition of the on-shift staff is sufficient to implement the emergency plan and implement mitigation strategies and repair or corrective actions intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling for both units.

IPEC has a total of 26 staff members on shift for both units including one individual available to perform actions in Unit 1 if needed. The on-shift staff consists of individuals necessary to support each of the emergency plan functional areas or tasks per NUREG-0654 and the IPEC Emergency Plan Table B-1.

3.0 EMERGENCY PLAN MINIMUM STAFFING The IPEC Emergency Plan establishes the licensing basis for the on-shift staffing complement. Only personnel required to be on-shift are credited in the staffing for the initial 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of the event. The following table indicates the on-shift personnel necessary to perform the required emergency planning functions.

On-Shift On-Shift E-Plan E-Plan Staffing Staffing Position Functional Area Functional Area Analysis Analysis U2 staff U3 staff Results Results U2 U3 Safe Shutdown Emergency Shift Manager /Emergency Direction and 1 1 (SM) Direction and Control Control Control Room Plant Plant Supervisor Operations/Safe Operations/Safe 1 1 (CRS) Shutdown Shutdown Shift Technical Technical Technical 1 1 April 2013 Page 5 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment Advisor (STA) Support Support Plant Plant Reactor Operations/Safe Operations/Safe 2 2 Operators Shutdown Shutdown Plant Auxiliary Operations/Safe plant Operations/Fire 54 Operators Shutdown/Fire Brigade Brigade Auxiliary Communicator / Notifications for both 1 Operator units Auxiliary Safe Shutdown 1 Operator Unit 1 Safe.Shutdown Fire Brigade 1 SRO Leader Chemistry/Offsite 1 Chemistry Chemistry/Offsite Dose Assessment Dose Assessment Radiation Radiation Radiation Protection Protection Protection Per Security Contingency Access Control and Accountability Plan Security 13 1 13 Emergency plan tasks of repair and corrective action, first aid and rescue operations are provided by personnel assigned other functions as allowed by Nureg-0654 Table B-1 and NEI 10-05. The Shift Manager provides emergency direction and control and plant operations and assessment of operational aspects.

4.0 BEYOND DESIGN BASIS EXTERNAL EVENT (BDBEE!

4.1 General Assumptions and Limitations 4.1.1 NEI 12-01 Assumptions Common to Both Assessments (Staffing and Communications)

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

a. all onsite units affected

b. extended loss of AC power

c. impeded access to the units April 2013 Page 6 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment

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 road way obstructions, use different travel routes, mobilize alternate transportation capabilities, 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 capabilities.

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and greater than or equal to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Apil21Pge7o49NI1-1Pae1Rpr April 2013 Page 7 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment 4.1.2 NEI 12-01 Assumptions for Staffing Assessment

1. 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.

2. The NEI 12-01, Phase 1 staffing assessment considered the applicable actions from the SBO coping strategies in place at the time of the assessment.

a. 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.

b. These actions do 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. Following the accident at Fukushima Dai-Ichi, the Institute of Nuclear Power Operations (INPO) issued three Event Reports (referred to as 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 of those IER improvement actions already implemented at the time of the assessment (e.g., incorporated into plant procedures).

4. Sites with existing strategies for responding to an extended loss of AC power affecting all on-site units should consider those actions in their NEI 12-01, Phase 1 staffing assessment.

4.1.3 Other Assumptions for Staffing Assessment

1. For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase, and any Transition Phase, coping actions during the 0-6 hour period.

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

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

NEI 12-01 Phase 1 Report April 2013 April 2013 Page 8 Page of 49 8 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment 4.1.4 NEI 10-05 Applicable Assumptions to Support Methodology 1 On-Shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.

2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.

3. It is assumed that personnel assigned to the major response area of Plant Operations & Safe Shutdown meet the requirements and guidance established by NRC regulations. 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. 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 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 event occurs 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). The ERO augmentation time is based on the time of event declaration until the time of turnover of the function/responsibility.

April 2013 Page 9 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment Specifically, any time needed by the augmenting ERO to acquire materials or prepare for turnover is accounted for. Facility activation includes the turnover of functions from the on shift staff.

4.2 Sequence of Events 4.2.1 Beyond Design Basis External Event (BDBEE): Station Blackout (SBO)

A large-scale external event occurs that results in:

- All on-site units affected

- Extended loss of AC power

- Impeded access to the units

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

" The event consists of a loss of offsite power and a failure of all emergency AC power sources resulting in a Station Blackout (Loss of all AC power). All of the emergency diesel generators (EDGs) experience a catastrophic failure, resulting in a complete loss of all AC power.

Both units experience the extended loss of AC power, there is no "unaffected" unit.

" The BDBEE occurs such that restoration of any AC power source is not possible before the arrival of the augmented ERO personnel. (e.g., 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months )

The event results in a Site Area Emergency based on EAL SSI.1

On-shift personnel respond to the initiating events in accordance with Plant procedures. The initial response relies upon the turbine driven auxiliary boiler feedwater pump (TDAFWP) taking suction from the condensate storage tank (CST) and feeding a steam generator (SG) for decay heat removal. Containment status is confirmed by verifying position or by manually closing valves and isolating the reactor coolant pump (RCP) seal leakage. The spent fuel pool (SFP) is not challenged for the initial 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

4.2.2 The following procedures were referenced during the event review:

Common Procedures O-AOP-SEC-3, Event Contingency Actions O-SOP-ESP-002, Emergency Contingency Plan O-SOP-ESP-003, Contingency Plan Strategy Attachments IP-EP-11S, Emergency Plan Forms April 2013 Page 10 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment IP-EP-120, Emergency Classification IP-EP-210, Central Control Room IP-EP-410, Protective Action Recommendation Unit 2:

2-E-0, Reactor Trip or Safety Injection 2-ECA-0.0, Loss of All AC Power 2-AOP-DC1, Loss of DC Panel 2-AOP-1B1-1, Loss of Power to Instrument Bus 2-SOP-ESP-001, Local Equipment Operation and Contingency Actions 2-SOP-4.3.1, Spent Fuel Pit Cooling 2-AOP-SFP.1, Loss of Spent Fuel Pit Cooling 2-SACRG-1, Severe Accident Control Room Guide Unit 3:

3-E-0, Reactor Trip or Safety Injection 3-ECA-0.0, Loss of All AC Power 3-AOP-DC1, Loss of DC Panel 3-AOP-1B1-1, Loss of Power to Instrument Bus 3-SOP-ESP-001, Local Equipment Operation and Contingency Actions 3-SOP-4.3.1, Spent Fuel Pit Cooling 3-AOP-SFP.1, Loss of Spent Fuel Pit Cooling 3-SACRG-1, Severe Accident Control Room Guide 4.2.3 Severe Accident Management Guideline (SAMG)

The overall strategy at IPEC is to maintain both units in hot standby and to remove decay heat by feeding the SG using TDAFWP with condensate from the CST. Both units use CST for decay heat removal. Each CST has inventory sufficient to support TDAFWP operation and remove decay heat from the unit for greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . On this success path, the core is cooled and the SAMG entry condition on the core exit temperature is never met for the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period prior to the full ERO on site.

It is therefore concluded that the on shift ERO would not be called upon to perform SAMG activities, based on a loss of core cooling for the event analyzed for this report prior to the assistance of the greater ERO. Procedures 2/3-ECA-0.0, Loss of All AC Power, however, direct the operator to 0-SOP-ESP-002, Emergency Contingency Plan, for some contingency actions that do not require AC power.

Page 11 of 49 NEI 12-01 Phase 1 Report April 2013 April 2013 Page 11 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment 5.0 EMERGENCY PLAN IMPLEMENTATION 5.1 On-shift Staff ERO Responsibilities Each unit has an Operations staff of one Shift Manager (SM), one Control Room Supervisor (CRS), one Shift Technical Advisor (STA) and two Reactor Operators (ROs).

Unit 2 has five Nuclear Plant Operators (NPOs), Unit 3 has four NPOs, and Unit 1 has one NPO that is a safe shutdown operator for Unit 2. IPEC has an NPO assigned to each shift that is the dedicated communicator for both units. Since both units are affected, this analysis assumes the U2 SM assumes the Emergency Director (ED) function and the Communicator NPO assumes the function of notifications. The ROs and NPOs, except the communicator, are available in each unit to perform plant operations as directed by the CRS using emergency operations procedures, abnormal operations procedures, and other procedures containing actions applicable to a station blackout. Two RP Technicians and two Chemistry Technicians are on shift and may perform tasks as directed by the Shift Manager in either unit. One Chemistry Technician is assigned the task of dose assessment if a release should occur. The U3 Shift Manager is available to assist the ED with other communications such as contacting the CEC and coordinating request for resources.

5.2 Classification For the assessment tabletop, the U2 Shift Manager assumed the role of ED and declared a Site Area Emergency based on EAL SS1.1. The ED then directed a protected area evacuation and directed all on-shift staff to card into an accountability card reader and Security to perform accountability. Card readers are assumed operable based on Security backup battery power. The tabletop demonstrated that the Shift Manager is capable of performing the Emergency Director function with no collateral duties.

After approximately 3 to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the ED declared a General Emergency based on EAL SG1.1 and determined a Protective Action Recommendation (PAR). The GE declaration may be expected to be made earlier if the ED receives information that on-site and off-site power restoration will not be possible within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

5.3 Notification IPEC communication/notification systems have battery backup on loss of power. The NPO Communicator made the State and local notifications and notified the ERO using ERON (Emergency Response Organization Notification). It is assumed ERO members in the 25-mile radius do not receive the notification due to a 25 mile radius power outage.

ERO members outside the 25 mile radius are assumed to receive the notification because the equipment implementing the ERON process is located outside the affected areas. Additionally, ERO members are trained to automatically respond to their assigned facilities or a designated staging area when made aware of an area-wide loss-of-grid (e.g., by direct observation, media reports, word-of-mouth, etc.). The April 2013 Page 12 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment Communicator notified and maintained an open line with the NRC. An additional notification was made to the Corporate Duty Manager. The U3 SM may assist the U2 SM or Communicator with making other communications such as coordinating requests for support from the Corporate Emergency Center (CEC). The tabletop demonstrated that the Communicator is capable of performing the notification function without collateral duties.

Satellite phones are available in the Control Room and available for the Communicator to use to make notifications when the backup batteries are depleted. Each Control Room has multiple satellite phones available to make offsite notifications, NRC notification and other notifications.

5.4 Communication The telephone system has battery backup and may be used (if available) until the batteries are depleted. As noted in section 5.3, satellite phones are available as a backup to the telephone system. Power is lost to the plant paging system in a SBO. Hand-held radios with talk-around capability are available for in-plant communications. The ED will use radios to communicate with the on-shift staff outside of the control room and with security. For purposes of this assessment, it was assumed the minimum on-shift staff (including security) were the only personnel on site.

5.5 Accident Assessment A release is not expected since core cooling is maintained by decay heat removal using TDAFWP to feed the SG and the atmospheric dump valve (ADV) to control the cool-down rate. One of the two Chemistry Technicians is assigned the role of dose assessor if a release should occur. Effluent sampling is not available due to the loss of power. One of the two RP technicians is available to perform on-site and site boundary surveys to detect for an unmonitored release. RP and Chemistry are capable of performing their function, except for sampling, with no collateral duties.

5.6 The station emergency lighting batteries are rated for 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Flashlights with spare batteries are available to provide portable lighting for the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months duration. Food and water is available for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months duration.

6.0 ON-SHIFT STAFFING INITIAL PHASE COPING STRATEGIES AND CAPABILITY

[RFI#1, 1b, 1c]

6.1 The assessment utilized a "no site access" period of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months per the assumptions in NEI 12-01 Section 2.2. During this 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period, the on-shift staff used installed plant equipment to respond to the event. The overall strategy at IPEC is to maintain both units in hot standby and to remove decay heat by feeding the SGs using TDAFWP with condensate from a seismic qualified source (CST). Both units have a CST for decay heat April 2013 Page 13 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment removal. The CRS in each unit directs the actions of the procedures to mitigate the event. Each unit has 2 ROs and 5/4 NPOs to carry out the actions as directed by the CRS.

" Core Cooling - Using the existing IPEC PRA/MAAP analyses which assume an available CST volume of 360,000 gallons at the start of the event, the SG(s) can be supplied with water for approximately 46 hours5.324074e-4 days 0.0128 hours 7.60582e-5 weeks 1.7503e-5 months of TDAFWS operation. With the above strategies and capabilities, the estimated Core Cooling coping time is in excess of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . (Ref. Response to IER 11-4 Recommendation #1)

With respect to ADV operation, installed nitrogen supplies will support at least 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months of ADV operation (i.e., two ADVs for IP2 and one ADV for IP3) based on the licensing basis calculations that conservatively assume minimum required N2 bottle pressure and 35 full strokes of the ADV. The licensing basis calculation points out that this assumed number of strokes is conservatively high, since plant cool down requires minimal ADV manipulation in the field.

(Ref. Response to IER 11-4 Recommendation #1)

Instrumentation indications for essential parameters remain available for an estimated range of 2.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 5.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for U2 and 3.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 5.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for U3. Per the INPO IER 11-4 Recommendation 2 response, these times could be extended to the 4 to 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months range, or possibly longer, by implementing additional load shedding and/or series sequencing of batteries early in the event. Once batteries are depleted, indication is available locally for SG pressure and CST level. The on-shift staff is capable of maintaining core cooling using available battery power and manual operation of the TDAFWP and ADV.

Containment - The on-shift staff can maintain containment integrity for the first 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months of the SBO. U2 procedure 2-ECA-0.0, Loss of All AC Power, and U3 procedure 3-ECA-0.0, Loss of All AC Power, provides direction to manually close isolation valves. Due to RCP seal leakage and loss of forced containment cooling, containment pressure and temperure will slowly rise. Based on the above, conainment pressure and temperature are not projected to approach design limits in the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months into the event.

" Spent Fuel Pool Cooling - The Spent Fuel Pool is not challenged in the initial 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period. Per IPEC's response to IER 11-04, the limiting case is 20 days after shutdown. U2 SFP time to boil is 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months and will reach 10 ft. above the fuel in 58 hours6.712963e-4 days 0.0161 hours 9.589947e-5 weeks 2.2069e-5 months . U3 SFP time to boil is 9.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months and will reach 10 ft. above the fuel in 51 hours5.902778e-4 days 0.0142 hours 8.43254e-5 weeks 1.94055e-5 months . No action is required to maintain 10 ft. above the fuel for at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Procedure 0-SOP-ESP-002, Emergency Contingency Plan, provides instructions for SFP makeup using fire hose stations or using a portable pump.

6.2 The on-shift staff is capable of implementing all Initial Phase coping strategies.

Available staffing is sufficient to implement the actions of the EOPs, AOPs, and SOPs April 2013 Page 14 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment timely when directed by the CRS and without collateral duties. The NPOs performed non-time critical tasks in series when necessary and were able to timely perform all their assigned functions. The staff performing plant operations is not assigned any other emergency plan function or task for the conditions of the SBO. Therefore, the performance of Initial Phase coping strategies does not impact the ability of the on-shift staff to perform any required emergency response function. Emergency response function would not be degraded or lost prior to the arrival of the augmented ERO.

7.0 TRANSITION PHASE STRATEGIES AND CAPABILITY 7.1 On-shift Staff Transition Phase Coping Actions The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore functions until they can be accomplished with resources brought from off site.

This assessment did not identify any Transition Phase action that must be completed by the on-shift staff within the no-access 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period. The response to SBO was assessed by first reviewing the response procedures. The on-shift staff was capable of performing all required task of the Initial Phase using installed equipment and procedures. It is assumed SAMG entry conditions based on core exit temperatures are not met in the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

7.2 Augmented ERO Transition Phase Coping Actions The following tasks are assumed to be performed by the augmented staff within the 6-24 hour period after limited ERO members arrive:

1. [U2/U3] Align hoses from fire protection hose stations to makeup to the spent fuel pool per O-SOP-ESP-002, Emergency Contingency Plan.

2. [U2/U3] Take readings locally at instruments using a digital multi-meter for critical parameters (i.e., core exit temperature).

Both tasks may be performed by the augmented ERO in the 6-24 hour time period.

Makeup to the SFP is not necessary in the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period following the SBO. Core exit temperature instrument reading may be necessary when lowering SG pressure.

8.0 AUGMENTED ERO 8.1 ERO Response Emergency Response Organization members are instructed to respond, to their assigned Emergency Response Facility (ERF) or, if that facility is inaccessible, to the alternate facility. In support of this requirement, training material FCBT-EP-RESP, Entergy ERO Responsibilities, and FCBT-EP-ERO ROLES, ERO Roles and Responsibilities provides April 2013 Page 15 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment information to direct the actions individuals should take if they become aware of an area-wide grid disturbance or significant natural disaster (e.g., earthquake, tornado, flood). The normal ERO augmentation expectation is 60 minutes.

8.2 ERO Notification IPEC has four (4) qualified ERO teams, with a team on call 24/7, to respond to any Alert or higher emergency declared by the Shift Manager. EN-EP-801, Emergency Response Organization, list the expectations and responsibilities of ERO members. To facilitate a timely and effective response, the following procedure sections apply:

Section 5.2.2 Respond promptly to actual emergencies, pager tests and off-hours/unannounced drills when available, regardless of whether on-call or not. ERO members not on-call are expected to respond unless they are unavailable.

If an area-wide loss of grid occurred that degraded the capability to notify the ERO to respond, IPEC has communicated the expectation to the ERO to ensure that "ERO members are trained to automatically respond to their assigned facilities or a designated staffing area when made aware of an area-wide loss-of-grid (e.g., by direct observation, media reports, work-of-mouth, etc.)."

If a loss of telephone or internet services were to occur, satellite phones in the control room may be used to activate the ERO. Procedure IP-EP-210, Central Control Room, provides detailed instructions on how to mobilize/activate the ERO using the Emergency Response Organization Notification (ERON) system, including backup methods.

8.3 ERO Notification with Degraded Communications Capabilities (RFI#3)

Requested Information#3: Identify how the augmented staff would be notified given degradedcommunications capabilities.

Entergy provided a response to RFI #3 in Entergy's 90-Day Response to the March12, 2012, Information Request, Action Planfor Completing Emergency Communication and Staffing Assessments dated June 8, 2012 (NL-12-075)

This section provides additional information to the response.

NEI 12-01 Section 4.4 offers two potential options to promote timely staff augmentation by the ERO:

NEI 12-01 Phase I Report April 2013 April 2013 Page 16 Page of 49 16 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment

ERO members can be notified of the emergency using a method that would be operable under the assumed event conditions (e.g., satellitepagers),

AND/OR

ERO members are trained to automatically respond to their assigned facilities or a designated staging area when made aware of an area wide loss-of-grid (e.g., by direct observation, media reports, word-of-mouth, etc.).

IPEC has chosen to implement option #2. In the 90-Day response letter, stated:

Initialexpectations have been communicated to the Emergency Response Organization(ERO) to respond to their assigned emergency responsefacilities when made aware of an area-wide loss-of-grid that results in degraded communications capability. This will be included in the ERO annual requalificationtrainingprogram by December 12, 2012.

ERO members were made aware of the expectation by an email sent to all ERO members on 05/16/2012 via ERON with the requirement to acknowledge receipt for tracking purposes. This action is documented in the corrective action program LO-HQNLO-2011-00138 CA-24. The message that went out included the information to go to their alternate facility if unable to report to the primary facility.

The expectation was also included in the following training material:

" FCBT-EC-RESP, Entergy Nuclear Emergency Response Organization Responsibilities

" FCBT-EP-EROROLES, ERO Roles and Responsibilities 8.4 Augmented ERO Site Access (RFI4#4)8.4.1 Requested lnformation#4: Identify the methods of access (e.g., roadways,navigable bodies of water and dockage, airlift, etc.) to the site that are expected to be available after a widespread large scale naturalevent.Entergy provided a response to RAI #4 in Entergy's 90-Day Response to the March12, 2012, Information Request, Action Planfor Completing Emergency Communication and Staffing Assessments dated June 8, 2012 (NL-12-075).

This section provides additional information to the responsePer the assumptions of NEI 12-01, the event impedes site access as follows:

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 ofdifferent travel routes, mobilize alternate transportationcapabilities(e.g., private resourceproviders or public sectorsupport) etc.

8.4.2 IPEC assumes that limited augmented ERO resources will be available at six hours post-event time to full ERO staffing at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . In the event that the site cannot 2013 Page 17of49 NEI 12-01 Phase I Report April 2013 April Page 17 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment be accessed via the roadways, EOF personnel will report to the alternate EOF in White Plains, NY. The staging area for the TSC/OSC personnel is the Centennial Hose Company in Peekskill, NY.

8.4.3 The EP Manager reviewed the Emergency Plan Letters of Agreement and interviewed State and County officials to confirm the assistance provided to IPEC.

The following agreements are in place for assistance and/or services:

Memorandum of Understanding with local fire departments (Buchanan Engine Company 1, Verplanck Fire Protection Association, Montrose Fire Department)

Westchester County Fire and Emergency Medical Services Responses &

Mutual Aid Plan

Memorandum of Understanding with NY State Police

Memorandum of Understanding with Consolidated Edison to restore power (FERC NUC-0001 requirements)

" Memorandum of Understanding with local hospitals (Hudson Valley Hospital Center, Phelps Memorial Hospital Center)

" Memorandum of Understanding with DOE - Radiation Emergency Assistance

Agreement with NY State Office of Emergency Management

" Purchase Order with Bottini Fuel, HO Penn A. Alternate Transportation - Primary Method In the event the site cannot be accessed via the roadways, IPEC has verbal agreement with the State of New York Office of Emergency Management that in the event of restricted site access following a BDBEE, they will provide resources such as a helicopter as priorities allow transporting ERO personnel from an alternate location to the site. It is also recognized that the New York State Police as part of NYS Empire Shield located at Fort Hamilton in Brooklyn, NY, has National Guard resources available to provide support if needed. This support may include the facilitation of boat transport up the Hudson River from the Alternate EOF to the IPEC site. The staging area for the TSC / OSC is located close enough to the site that transportation by foot is a viable method to access the site.

Based on the this strategy, sufficient ERO personnel will be available at six hours post-event time to support the on-shift staff in completing the required coping strategies, including Transition Phase strategies.

April 2013 Page 18 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment B. Time Estimates of Alternate Transportation The following are time estimates of available access methods discussed above to the IPEC site. Aviation resources available from State Police and Division of Military and Naval Affairs are located at Islip, Albany, and Rochester. Seating capacity ranges from 8 to 36 persons. One or more of the methods are expected to be available after a widespread large scale natural event:

Transportation times are estimates

1. Albany to Westchester by air - <30 minutes, or may come from another location

2. Islip to Westchester by air - <30 minutes

3. Westchester Airport to IPEC 15 minutes

4. Post Event - NYS Empire Shield 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

5. Brooklyn to Tarrytown by boat 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

6. Tarrytown to IPEC by boat - 30 minutes - 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

7. Walking time from Centennial Hose Company - <1 hour C. Provisions for Restoring Site Access The Shift Manager/Emergency Director may contact the State or county Emergency Operations Center to request actions to clear impediments to allow ERO access to the site after he/she is made aware of impediments.

Additional logistics support is available from the Entergy Corporate Emergency Center (CEC) located at the headquarters in Jackson, MS. Once notified that a station is in a declared emergency and station blackout, the CEC should be activated using EN-EP-601, Corporate Emergency Center Operations. The purpose of the CEC is to provide site support to an Entergy station(s) during declared emergencies, recovery operations, severe weather events, or off-normal events. The CEC serves as the central command area for coordinating fleet resources. The CEC coordinates requests for additional equipment and materials, and support services/resources from Entergy sites or corporate headquarters, contractors, vendors, or other outside agencies. The CEC has resources to contract helicopter services, tree trimming services, etc. as necessary to provide ERO site access.

The CEC is located in Jackson, MS and outside of the 25 mile radius of any Entergy station. It is assumed it would be fully functional to support IPEC in an extended SBO. IPEC control room and the CEC have satellite communication capability. The CEC activates and operates in accordance with EN-EP-601.

NEI 12-01 Phase 1 Report 2013 April 2013 April Page 19of49 Page 19 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment 8.5 Expanded ERO 8.5.1 The current IPEC augmented ERO would be challenged to effectively respond to a BDBEE that resulted in an extended loss of AC power 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 emergency response functions. The focus of this "expanded response capability" at IPEC should be to enable the performance of unit-specific accident assessment and mitigation functions.

NEI 12-01 Table 3.1 lists the emergency response functions identified by the NEI Beyond Design Basis Event Response Staffing Study Task Force as meeting expanded response requirements. NEI 12-01 Table 3.1 further provides key roles and staffing considerations for each expanded response function and specifies the staffing necessary to support the simultaneous deployment of emergency repair and corrective action teams to each affected unit.

The personnel required for implementation of strategies for a BDBEE may vary depending upon several factors. However, the process should facilitate a flexible response strategy that can be applied in a graded approach by the ERO personnel on a unit/priority specific basis (i.e., the extent/type of BDBEE and associated event challenges would correspond to the expansion/contraction of the expanded ERO and the assignment of unit specific expanded ERO response functions and unit specific resources).

NEI 12-01 Table 3.1 was compared to the recommended ERO staffing listed in EN-EP-801, Emergency Response Organization and the IPEC ERO roster at the time of the assessment data collection. This method identified expanded ERO candidates from the existing ERO to perform the functions identified in Table 3.1 regardless of the BDBEE event.

The IPEC TSC and OSC are co-located which eliminates the need for a separate Maintenance Coordination function as noted in NEI 12-01 Table 3.1. The Table 3.1 expanded response functions of Maintenance Coordination and Unit In-Plant Team Coordination are combined in the co-located TSC/OSC as a Mechanical Coordinator and an Electrical/l&C Coordinator. The Mechanical Coordinator and Electrical/l&C Coordinator coordinate the work activities of the teams performing or supporting repair and corrective action for their discipline.

of 49 NEI 12-01 Phase I Report April 2013 April 2013 Page 20 Page 20 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment 8.5.2 Table 8-1 Expanded Response Functions for IPEC Phase 1 Staffing TABLE 8-1 Expanded IPEC ERO Position ERO Available to Response Key Roles and Staffing Performing this Implement Coping IPECpERF Function from Considerations Function and Available Strategies for 2 Reporting NEI 12-01, Staff Resources units? Location Table 3.1 Unit Response

Overall cognizance of the Emergency Plant This requires a new TSC Coordination activities related to Manager (EPM) position for a multi-implementation of repair unit event to allow and corrective actions, and

IPEC maintains 4 the EPM to maintain implementation of qualified Emergency the TSC oversight Transition Phase coping Plant Managers and 4 and TSC Manager to and Severe Accident TSC Managers manage TSC overall Management (SAM)

May be filled by EPM operation.

strategies for an assigned or TSC Manager unit N+2

One individual per unit; Filled by existing individuals should not be EPMs or TSC assigned other functions Managers Operations e Provides coordination of Operations Coordinator Operations TSC Coordination Operations staff and

IPEC maintains 4 Coordinators support for an assigned qualified Operations N+1 unit Coordinator

- One individual per unit; individuals should not be assigned other functions Maintenance 9 Provides coordination of

N/A (See section 8.5.1 N/A TSC Coordination Maintenance staff and paragraph 5) support for an assigned unit e One individual per unit; individuals should not be assigned other functions Engineering e Provides coordination of Engineering Coordinator Engineering TSC Coordination Engineering staff and Coordinators support for an assigned

IPEC maintains a N+1 unit. minimum of 4

One individual per unit; qualified Engineering April 2013 Page 21 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment TABLE 8-1 Expanded IPEC ERO Position ERO Available to Response Key Roles and Staffing Performing this Implement Coping IPECpERF Fnction 120 1Considerations Function and Available Strategies for 2 Lotin NEI 12-01, Staff Resources units? Location Table 3.1 individuals should not be Coordinators assigned other functions.

Engineering

One team for each unit to Engineers Mech. Engineer TSC Assessments perform engineering N+1 assessments in support The ERO requires a Elec/I&C Engineer repair and corrective minimum of 4 N+1 actions. Mechanical Engineers, Reactor Engineer

Team composition (i.e., 4 Electrical/l&C N+1 number and represented Engineers and 4 disciplines) as described in Reactor Engineers on the emergency plan. the ERO. Duty concurrent eTeam may include Asseeng personnel responsible for Assessments performing other functions for the same assigned unit.

Evaluation of e One team for each unit to SAMG Evaluator / SAMG Evaluator TSC Severe Accident evaluate selection of SAM Operations N+1 Management strategies; team performs Coordinator /

(SAM) evaluations not done by Engineering Ops Coordinator Strategies Control Room personnel. Coordinator N+1Nao

Team composition (i.e.,

number and represented disciplines) as described in Eng. Coordinator governing site programs, N+1 procedures and guidelines.

9 Team may include personnel responsible for Duty concurrent performing other with ERO position functions for the same responsibilities assigned unit.

Unit In-Plant

Overall cognizance of on- Mechanical Coordinator Mechanical OSC Team site and in-plant teams / Coordinators April 2013 Page 22 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment TABLE 8-1 Expanded IPEC ERO Position ERO Available to

Response

Function from Key Roles and Staffing Performing this Implement CoigIPEC ERF Coping Reporting Function fr- m Considerations Function and Available Strategies for 2 Lortin NEI 12-01, Staff Resources units? Location Table 3.1 Coordination performing or supporting Electrical/l&C N+1 repair and corrective Coordinator actions for an assigned Electrical/I&C unit. IPEC maintains a Coordinators

One individual per unit; minimum of 4 N+1 individuals should not be qualified Mechanical assigned other functions. Coordinators and 4 (Note: See section 8.5.1) qualified Electrical/I&C Coordinatorsi/team of each.

Non-Licensed e Two individuals per unit Non-Licensed Operators 4 OSC Operators to assist with (NLO) implementation of repair and corrective actions.

Should not include members of the on-shift staff.

Mechanical

Two individuals per unit No maintenance 4 OSC Maintenance to implement repair and positions on shift.

Repair and corrective actions.

Corrective

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

Electrical. e Two individuals per unit No maintenance 4 OSC Maintenance to implement repair and positions on shift.

Repair and corrective actions.

Corrective

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

April 2013 Page 23 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment TABLE 8-1 Expanded IPEC ERO Position ERO Available to

Response

FunionsfKey Roles and Staffing Performing this Implement CoigIPEC CopingRe ERF r Considerations Function and Available Strategies for 2 NEI 12-01, Staff Resources units? Location Table 3.1 I&C Repair and 9 Two individuals per unit No maintenance 4 OSC Corrective to implement repair and positions on shift.

Action corrective actions.

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

Implementation

Number and composition The TSC/OSC U2: OSC of SAMG of personnel capable of implements the 7 NPOs Strategies simultaneous SAMG. 2 Mechanics implementation of any 2 Unit 2 2 Security Officers SAM strategies at each Strategy #1 - 5 people 1 RP unit. Strategy #2 - 7 people U3:

Unit 3 7 NPOs Strategy #1 - 5 people 2 Mechanics Strategy #2 - 7 people 2 Security Officers (See discussion in 1 RP section 8.5.6)

RP Techs

Number needed to support (See discussion in 8 OSC implementation of any 2 section 8.5.3) extended loss of AC power coping strategies per unit.

Determine this number by reviewing strategies for each unit

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

Number of on-site RP Technicians performing April 2013 Page 24 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment TABLE 8-1 Expanded IPEC ERO Position ERO Available to

Response

Function from Key Roles and Staffing Performing this Implement CoigIPEC ERF Coping Reporting Considerations Function and Available Strategies for 2 NEI 12-01, Staff Resources units? Location Table 3.1 other emergency plan functions that would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams 8.5.3 On-Site Radiation Protection Technicians The IPEC process for providing an expanded response capability will include provisions for a minimum number of available Radiation Protection (RP)

Technicians following a BDBEE to support performance of emergency plan functions and expanded response capability.

Per NEI 12-01, the equation is used to determine the required number of on-site RP Technicians (RPTs):

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.

NEI 12-01 Phase 1 Report April 2013 April 2013 Page 25 Page of 49 25 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment For IPEC U2 & U3:

RPTCOP = 2 RP Technicians (Assume no core damage, no leakage, no release)

RPTRCA = 4 RP Technicians (2 per Unit)

RPTNC = 2 RP Technician (Surveys)

RPTT = 8 RP Technicians RPTCOP - FLEX equipment and procedures are not in place at this time to evaluate coping strategy implementation. Entry into SAMG on core exit temperature was not required.

Provisions to obtain additional RP Techs For IPEC, the complement of RP Technicians specified in the augmented ERO per the Emergency Plan is eight 60 minute responders. Therefore, sufficient RP Technicians are anticipated to be available from site resources to support the initial staffing of the Expanded Capability. Additional RP Technician resources are available from other Entergy sites.

Should additional RP Technicians be required, the Corporate Duty Manager, if the CEC is not activated, or the Corporate Emergency Center (CEC) will contact the other Entergy sites to obtain additional RP staff (Entergy or Contract personnel) to support IPEC. Procedure EN-EP-601, Corporate Emergency Center Operations, describes the conduct of the CEC. The CEC may contact INPO to coordinate request for assistance from other utilities or vendors per the Nuclear Power Plant Emergency Response Voluntary Assistance Agreement.

8.5.4 Administrative Support Personnel IPEC has a pool of support staff that responds to the all-call ERO notification of an Alert or higher emergency. The normal assignments from this group are 1 to the Central Control Room, 1 to the OSC, 3 to the EOF, and I to the JIC. Additional administrative staff members respond to the ERO call-out and are available for assignment if additional administrated support is needed for the expanded ERO.

No additional Administrative Support personnel other than those already assigned to respond are required.

8.5.5 Work Areas for Personnel Performing Expanding Response Functions

The EOF is located in the Indian Point Energy Center, just inside the Main Facility Gate. Walkdowns of these areas identified sufficient space is available in adjacent offices conference rooms, and classrooms to support the role of the expanded response functions.

" The TSC is located in the Unit 1 Super-heater Building 53' elevation.

Walkdowns of these areas identified sufficient space is available in adjacent April 2013 Page 26 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment offices and conference rooms to support the role of the expanded response functions.

" The OSC is located in the Unit 1 Super-heater Building 53' adjacent to the TSC. Walkdowns of these areas identified sufficient space is available in adjacent offices and conference rooms to support the role of the expanded response functions.

A TSC and OSC staging area is located at the Centennial Hose Firehouse in Peekskill, NY. The Alternate EOF is located on the 12th floor of the AT&T building at 440 Hamilton Avenue, White Plains, NY. Alternate facilities may be used if needed 8.5.6 Expanded ERO for SAMG Actions SAMG was reviewed for U2 and U3 to determine the strategies requiring the greatest number of staff. The strategies are the same for U2 and U3. Each unit requires an estimated 12 people to perform the 2 strategies simultaneously.

Unit 2

Strategy #1: SG depressurization and fill with pressurized fire header and the diesel contingency pump. Requires an estimated:

- 4 NPOs (1 at SG Atmospherics, 1 at diesel pump and hydrant, 1 at the SG feed regulating valves, and 1 to assist with moving the pump and laying out hoses)

- 1 Security officer.

Strategy #2: Flooding containment with portable pump. Requires an estimated:

- 3 NPOs (1 at pump & hydrant, 1 for valve lineup, and 1 to move pump and lay out hose)

- 2 Mechanics

- 1 Security

- 1 RP Unit 3 Strategy #1: SG depressurization and fill with pressurized fire header and the diesel contingency pump. Requires an estimated:

- 4 NPOs (1 at SG Atmospherics, 1 at diesel pump and hydrant, 1 at the SG feed regulating valves, and 1 to assist with moving the pump and laying out hoses)

- 1 Security officer.

NEI 12-01 Phase 1 Report April 2013 April 2013 Page 27 Page 27 ofof 49 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment Strategy #2: Flooding containment with portable pump. Requires an estimated:

- 3 NPOs (1 at pump & hydrant, 1 for valve lineup, and I to move pump and lay out hose)

- 2 Mechanics

- 1 Security

- 1 RP 8.6 Staffing the Expanded Response Functions NEI 12-01 states: A licensee should ensure the availability of a sufficient number of personnel to perform expanded response functions. This may be done in several ways, including:

Assign responsibilities to existing ERO positions. Per NRC Letter Staffing Information Request #1, the potential impacts from the assignment of new collateral duties should be assessed.

Establish provisions for calling out additional individuals from the existing augmented ERO staff (e.g., calling out 2 engineering teams at a 2-unit site).

Select and qualify additional personnel. Sources of additional staffing include site, corporate or contracted personnel. Site Security Department resources may also be considered.

" Consider the application of remote data access, meeting and other communications technologies to support the availability of required staffing Entergy will establish guidance to use suggestion #2 to fill the expanded ERO positions from call-out of the existing augmented ERO. The ERO consist of 4 qualified teams. All 4 teams will respond to the call -out and be available to fill the expanded ERO positions.

Two teams will be utilized to fill the ERO positions for 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months rotation duty. The other 2 teams will be used to fill the expanded ERO positions for 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months rotation. The expanded response position will be filled with ERO members qualified for the position but training drills have not included an expanded ERO or simultaneous mitigation strategies on both units.

9.0 ON-SITE STAFF'S ABILITY TO MOVE BACK-UP EOUIPMENT [RFI#.Ia]

9.1 US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of 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 functions are requested to be assessed:

April 2013 Page 28 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment How onsite staff will move back-up equipment (e.g., pumps, generators)from alternateonsite storagefacilities to repairlocations at each reactoras described in the Orderregardingthe NTTF Recommendation 4.2. It is requested that considerationbe given to the majorfunctional areasor NUREG 0654 Table B-i, such as plant operationsand assessment of operationalaspects,emergency direction and control,notification/communication,radiologicalaccident assessment,andsupport of operationalaccidentassessment,as appropriate.

Back-up equipment was not installed and associated procedures were not developed at the time of this assessment. The response to this request requires that the procedures to support the mitigating strategies, as described in the Order regarding the NTTF Recommendation 4.2, be developed to determine the applicable staffing. The schedule for the response to the order does not support the timing requirements of the Phase 1 staffing assessment.

This information will be provided in the Phase 2 Staffing Assessment. Refer to Entergy Letter (NL-12-054) to NRC Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Planfor Completing Emergency Communication and Staffing Assessments dated May 11, 2012 which contains the following commitments:

1. Conduct the onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. Scheduled completion date Oct 3, 2014.

2. Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. Scheduled completion date Nov. 3, 2014.

10.0 STAFFING ASSESSMENT COMPLETION OF NEI 10-05 STYLE TABLES 10.1 Refer to Attachment 1, NEI 10-05 Style Staffing Table for IPEC, for documentation of the on-shift staffing analysis results.

10.2 There were no potential overlap tasks identified. The most limiting positions were determined to be the Nuclear Plant Operators (NPO). The NPO tasks were assigned as shown in Table 10.1 below. Note the Communicator NPO is excluded from Table 10.1.

The Communicator does not have assigned collateral tasks.

of 49 NEI 12-01 Phase I Report April 2013 April 2013 Page 29 Page 29 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase I Staffing Assessment Table 10.1: IPEC NPO Utilization (Time in Minutes) 0-15 15-30 30-45 45-60 60-75 75-90 90-105 105-120 U2 NPO E

1 U2#2 NPO B BG G U2NPO cD A

3 ._... _ _._._._...

U2 NPO F

4 ..... _ _.._...._... _*

U2 NPO :

U3 NPO E

1 , _ _____ _

U3 NPO B G

2 _______

U3.NPO c D A

3 U3 NPO F

4 ___

49 NEI 12-01 Phase I Report 2013 April 2013 April Page 30 Page 30 ofof 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment 240- 255- 270- 285- 300- 315- 330- 345-255 270 285 300 315 330 345 360 U2 NPO

1 U2 NPO

2 G U2 NPO

A A:

3. ...

U2 NPO

4 _ _ _ .. _-

U2 NPO

5 U3 NPO

1 U2 NPO

2 __ _ __ _ __ _

U3 NPO#3 i A...A.

AA ______

U3 NPO F

4 .. .1 A. Monitor SFP level & temperature B. Attempt to start D/G C. Attempt to start App R D/G D. DC load shed E. Isolate RCP seal F. Monitor/Control TDAFWP locally, open rollup door G. Monitor/operate ADV H. Close doors SFB area I. Check CST level J. Verify valve positions/close Attachment K. Isolate CST from hotwell 10.3 The analysis did not identify any new or non-validated tasks or potential overlap of tasks that would require a Time Motion Study to be performed.

11.0 CHANGES I INTERIM ACTIONS TO SUPPORT PHASE 1 STAFFING ASSESSMENT (l(FI#51 11.1 Requested Information#S: Identify any interim actions that have been taken or are planned prior to the completion of the staffing assessment.

Entergy provided a response to RFI #S in Entergy's 90-Day Response to the Marchl2, 2012, InformationRequest, Action Planfor Completing Emergency Communication and Staffing Assessments dated June 8, 2012.

April 2013 Page 31 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment

This section provides additional information to the response.

11.2 Staffing Changes The existing on-shift staff is sufficient to implement the existing SBO strategies on both units, simultaneously, while supporting performance of the required Emergency Planning duties without unacceptable collateral duties. No staffing changes are required. The emergency plan will not be changed as a result of the on-shift or augmented staffing necessary to respond to a loss of all ac power.

1 1.3 Expanded Capability Staffing The existing augmented ERO provides sufficient staffing to satisfy the Expanded Capability functions as defined in NEI 12-01, Table 3.1. Additional staffing support is available from Entergy fleet resources (Arkansas Nuclear One, Grand Gulf, River Bend, Waterford, Palisades, Fitzpatrick, Vermont Yankee, and Pilgrim) as well as the Corporate organization at Jackson, Ms. Resources, including Operations, Maintenance, Instrumentation and Controls, Radiation Protection, and Engineering, are routinely shared during refueling outages. This experience, along with the common structure of Entergy's processes enables personnel shared between sites to support site-specific activities. Should the event require long-term staffing, additional resources are available from the remaining Entergy Nuclear sites, as well as the corporate office at Echelon in Jackson..

11.4 Emergency Plan and Procedure Changes Per NEI 21-01, Section 3.10, the capability for responding to a beyond design basis external event does not need to be described in the emergency plan. A licensee may, however, choose to incorporate implementing instructions for expanded response functions into emergency plan implementing procedures, and/or extended loss of AC power, SAM or other program documents.

Entergy will incorporate instructions into applicable fleet/site guidance to activate the Expanded Response Capability and to integrate this capability into the existing augmented emergency response organization structure based upon the following conditions, as described in NEI 12-01, Section 3.8:

Loss of ALL offsite and ALL on-site power sources to AC emergency busses at more than 1 unit, OR

Plant parameters or conditions require implementation of SAM strategies for more than 1 unit.

NEI 12-01 Phase 1 Report April 2013 April 2013 Page 32 Page of 49 32 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment 11.5 Emergency Response Drill and Exercise Program NEI 12-01 further 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.

Given that the BDBEE mitigating strategies, associated procedures, and modifications have not been implemented at this time, Entergy will not revise the drill and exercise program in response to the Phase 1 assessment. Entergy will identify any appropriate modifications to the Indian Point Energy Center (IPEC) Emergency Plan Drill and Exercise Program upon completion of the mitigation strategies and associated guidance being developed in response to NRC order EA 12-049 recommendation 4.2.

(Enhancement) 12.0 IMPLEMENTATION SCHEDULE TO CONDUCT ONSITE AND AUGMENTED STAFFING ASSESSMENT (RFI #2) 12.1 Provide an implementation schedule of the time needed to conduct the onsite and augmentedstaffing assessment.If any modifications are determined to be appropriate include in the schedule the time to implement the changes.

12.2 Attachment 1 provides the IPEC on-shift and augmented staffing assessment Phase 1 for the loss of all AC power, multi-unit event. No modifications were identified in the Phase 1 assessment.

12.3 Per the commitment made in Entergy's 60 day response to the March 12, 2012, NL 054 dated May, 11, 2012, the Phase 1 staffing assessment submittal date is April 30, 2013 and the Phase 2 staffing assessment will be completed by October 3, 2014 and submitted by November 3, 2014.

13.0 NEI 12-01 PHASE 1 STAFFING ASSESSMENT

SUMMARY

[RFI#1, #61 This assessment concluded that the current minimum on-shift staffing as defined in EP-Emergency Plan for Indian Point Energy Center, is sufficient to support the implementation of the current station blackout (SBO) strategies on Units 2 and 3, as well as the required Emergency Plan actions, with no unacceptable collateral duties.

The staffing assessment did not identify the need for any new staff or identify any new functions or tasks that have not been analyzed.

The Phase 1 assessment also identified the staffing necessary to support the Expanded Response Capability for the beyond design basis external event (BDBEE) as defined for April 2013 Page 33 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment the Phase 1 assessment. This staffing will be provided by the current site resources, supplemented by fleet resources, as necessary.

The existing on-shift staff and augmented ERO is sufficient to implement the existing SBO strategies on both units, simultaneously, while supporting performance of the required Emergency Planning duties without unacceptable collateral duties. No staffing changes are required. The emergency plan will not be changed as a result of the on-shift or augmented staffing necessary to respond to a loss of all ac power. No interim actions have been taken or are planned prior to the completion of the staffing assessment.

The Letters of Agreement in the Emergency Plan along with State and County Emergency Plans and Mutual Aid Agreements are sufficient to describe the support available to assist the sites should a BDBEE occur.

The assessment concluded that an action is required to establish guidance and controls to activate the Expanded Response Capability. Enhancements are identified in Attachment 2.

49 NEI 12-01 Phase 1 Report April 2013 April 2013 Page 34 Page 34 of of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center NEI 12-01 Phase 1 Staffing Assessment 14.0 REERENE 14.1 NEI 12-01, Rev 0, Guidelinefor Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities 14.2 NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities 14.3 NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planningfor Nuclear PowerPlants 14.4 NRC Letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Requestfor Information Pursuantto Title 10 of the Code of FederalRegulations 50.54W9 Regarding Recommendation 2.1,2.3, and 9.3, of the Near-Term Task Force Review of Insightsfrom the Fukushima Dai-ichi Accident 14.5 Entergy letter (NL-12-054) to the NRC dated May 11, 2012, Entergy's 60-Day Response to the March 12, 2012, Information Request,Action Planfor Completing Emergency Communication and Staffing Assessments 14.6 Entergy Letter (NL-12-075) dated June 8, 2012, Entergy's 90-Day Response to the March 12, 2012, Information Request, Action Planfor Completing Emergency Communication and Staffing Assessments 14.7 Entergy Letter (NL-12-142) dated October 31, 2012, Entergy Response to the March 12, 2012, Information Request Pursuantto 10 CFR 50.54(f) Regarding Recommendation 9.3 for Completing Emergency CommunicationAssessments.

14.8 Corrective Action Program Learning Organization LO-HQNLO-00138, Notifying Augmented Staff 14.9 Corrective Action Program CR-IP2-2011-3909, IPEC Response to IJPO IER Level 1 No.

11-4 14.10 IPEC-EP-12-01, Rev 14, IPEC Emergency Plan 15.0 ATTACHMENTS 15.1 Attachment 1, NEI 10-05 Style Staffing Tables for IPEC 15.2 Attachment 2 Enhancements NEI 12-01 Phase 1 Report 2013 April 2013 April Page Page 35 of 49 35 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 ATTACHMENT 1 NEI 10-05 STAFFING TABLES FOR ENTERGY INDIAN POINT ENERGY CENTER NEI 12-01 PHASE 1 STAFFING ASSESSMENT of 49 NEI 12-01 Phase 1 report April 2013 April 2013 Page 36 Page 36 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 ATTACHMENT 1 - NEI 10-05 STYLE STAFFING TABLES FOR IPEC Attachment 1 NEI 12-01 Phase 1 OSA Multi- Unit Extended Station Blackout (SBO)

1. Accident Summary:

A loss of all offsite AC power occurs coincident with the trip of the unit. All emergency diesel generators fail to start.

2. Accident Specific Assumptions:

The start and load manual actions for the SBO Diesel Generators are unsuccessful.

" NEI 10-05 Assumptions identified in Section 4.0.

" NEI 12-01 Assumptions identified in Section 4.0

3. Procedures Reviewed for Accident Response Include:

Procedures identified'in Section 4.2 49 NEI 12-01 Phase 1 report April 2013 April 2013 37 of Page 37 Page of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 IPEC TABLE 1- ON-SHIFT POSITIONS Multi-Unit Extended Station Blackout ..

LineOsit Basis Document Augmentation Role in Table Unanalyzed TMS

_Position ...... _ Elapsed Time # / Line # Task? Required?

U2 T2/L1 T5/L1 T5/L2 1 U2 SM E-Plan Table B-1 N/A T5/L3 No No T5/L5 T5/L8 T5/L,10 2 U2 CRS E-Plan Table B-1 N/A U2 T2/L2 No No 3 U1STA E-Plan Table B-1 N/A U2 T2/L3 No No 4 U2 RO #1 E-Plan Table B-1 N/A U2 T2/L4 No No 5 U2 RO #2 E-Plan Table B-1 N/A U2 T2/L5 No No 6 U2 NPO #1 E-Plan Table B-1 N/A U2 T2/L6 No No 7 U2 NPO #2 E-Plan Table B-1 N/A U2 T2/L7 No No 8 U2 NPO #3 E-Plan Table B-1 N/A N/A No No 9 U2 NPO #4 E-Plan Table B-1 N/A N/A No No 10 U2 NPO #5 E-Plan Table B-1 N/A N/A No No 11 U2 Chemistry E-Plan Table B-1 N/A T5/L12 No No 12 U2 RP E-Plan Table B-1 N/A T4/L2 No No N/A U3 T2/L1 13 U3 SM E-Plan Table B-1 T5/L14 No No 14 U3 CRS E-Plan Table B-1 N/A U3T2/L2 No No 15 U3 STA E-Plan Table B-1 N/A U3 T2/L3 No No 16 U3 RO #1 E-Plan Table B-1 N/A U3 T2/L4 No No 17 U3 RO #2 E-Plan Table B-1 N/A U3 T2/L5 No No 18 U3 NPO #1 E-Plan Table B-1 N/A U3 T2/L6 No No 19 U3 NPO #2 E-Plan Table B-1 N/A U3 T2/L7 No No 20 U3 NPO #3 E-Plan Table B-1 N/A U3 T2/L8 No No 21 U3 NPO#4 E-Plan Table B-1 N/A N/A No No 22 U3 Chemistry E-Plan Table B-1 N/A N/A No No 23 U3 RP E-Plan Table B-1 N/A T4/L4 No No 24 U1 NPO E-Plan Table B-1 N/A U2 T2/L8 No No 25 Communicator E-Plan Table B-1 N/A T5/L6 No No April 2013 Page 38 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase I Staffing Assessment Attachment 1 T5/L9 T5/L13 26 SRO FBL E-Plan Table B-1 (FB) N/A N/A No No Security Contingency 27 Security Plan / E-Plan Table B- N/A T5/L15 No No 1

49 NEI 12-01 Phase 1 report April 2013 April 2013 Page 39 of Page 39 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 IPEC TABLE 2 - UNIT 2 PLANT OPERATIONS & SAFE SHUTDOWN,..

Two Unit - Two Control Room Multi-Unit Extended Station Blackout Minimum Operations Crew Necessary to Implement AOPs and: EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis

______Controlling Method Shift Manager Licensed Operator 1 Shift Manager Shift__ManagerTraining Program 2 Unit Supervisor Control Room Supervisor Licensed Operator Unit__SupervisorTraining Program Shift Technical Advisor Shift Technical Advisor Licensed Operator 3

Shift_Technical __AdvisorTraining Program Reactor Operator #1 Licensed Operator 4 Reactor Operator #1 Training Program Reactor Operator #2 Reactor Operator #2 Licensed Operator 5

Training Program Nuclear Plant Operator #1 Non-Licensed Operator 6 *uxiliary Operator #1 Training Program Nuclear Plant Operator #2 Non-Licensed Operator 7 uxiliary Operator #2 Training Program 8 Auxiliary Operator #3 Ul Nuclear Plant Operator Non-Licensed Operator 8__uxiliaryOperator_#3_Training Program 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A IPEC TABLE 2- UNIT 3 PLANT OPERATIONS & SAFE SHUTDOWN Two0Unit - Two Control Room Multi-Unit Extended Station Blackout . ..

Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis

______ "_____"C ontrolling Method Shift Manager Shift Manager Licensed Operator 1

1___hiftManagerTraining Program Control Room Supervisor Licensed Operator 2 Unit Supervisor Training Program Shift Technical Advisor Shift Technical Advisor Licensed Operator 3

3__hftTehnicalAdisorTraining Program Reactor Operator #1 Licensed Operator 4 Reactor Operator #1 raining Program 49 NEI 12-01 Phase I report April 2013 April 2013 Page 40 of Page 40 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 Reactor Operator #2 Licensed Operator 5 Reactor Operator #2 rraining Program Nuclear Plant Operator #1 Non-Licensed Operator 6 uxiliary Operator #1 Training Program Nuclear Plant Operator #2 Non-Licensed Operator 7 Auxiliary Operator #2 Training Program Nuclear Plant Operator #3 Non-Licensed Operator 8 Auxiliary Operator #3 raining Program 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if applicable Line # Generic Title/Role On-Shift Position Task Analysis

__ __ EControlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 I&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A Fire Brigade (No firefighting activities included in this accident.)

IEPC TABLE 3 - FIREFIGHTING Multi-Unit Extended Station Blackout Line Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Page 41 of49 NEI 12-01 Phase I report April 2013 April 2013 Page 41 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment I IPEC TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Multi-Unit Extended.Station Blackout..

L Position Performance Time Period After Emergency Declaration (minutes)*

I P e rfo rm in g . :. .......

N Function / Task 05 5 15 25 35 45 55 65 75 85m E 6+-hours o

0. 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey: As directed by SM

. U2!U3RP) 2 On-site Survey:

3 Personnel Monitoring: -

4 rob Coverage: As directed by SM

.U2/U3 RP 5 Offsite Rad Assessment:

(Included in Table 6 Other site specific RP (describe):

7 Chemistry Function task #1 (describe) As directed by SM U3 Chem 8 Chemistry Function task #2 (describe)

IPEC TABLE 4- RADIATION PROTECTION AND CHEMISTRY

".__ _ Multi-Unit Extended Station Blackout L Position Performance Time Period After., Emergency Declaration .(minutes)*... .

I Performing N Function /

90 100- 105- 110- 115- 120- 125- 130- 135- 140- 145-150- 155- 160- 165- 170- 175-E 6hask 6 + hours, 95 100 105 110 115 120 125 130 135 140 145 150 155 160 165 1710 175 180 NEI 12-01 Phase I report 2013 April 2013 April Page 42 Page of 49 42 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 1 In-Plant Survey: As directed by SM U2!U3 RP 2 On-site Survey:

3 Personnel Monitoring:

4 ob Coverage:

U2 RP As directed by SM 5 Offsite Rad Assessment:

(Included in Table 5 6 Other site specific RP (describe):

7 Chemistry Function task As directed by SM

1 (describe)

U3 Chem 8 Chemistry Function task

2 (describe)

IPEC TABLE 4- RADIATION PROTECTION AND CHEMISTRY Multi-Unit Extended Station Blackout L Position g.Performance Time Period After Emergency Declaration (minutes)*,

,IPerforming N Function / 180- 185- 190- 195- 200- 205- 210- 215- 220- 225- 230- 235- 240- 245- 250- 255- 260- 265-E Task 185 190 195 200 205 210 215 220 225 230 235 240 245 250 255 260 265 270 6 + hours 1 In-Plant Survey: As directed by SM U2/U3 RP April 2013 Page 43 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 2 On-site Survey: U2 X RP__E 3 Personnel Monitoring:

4 ob Coverage: As directed by SM U2/U3 UP_

5 Offsite Rad Assessment:

(Included in Table 6 Other site specific RP (describe):

7 Chemistry Function task #1 (describe) As directed by SM U3 Chem 8 Chemistry Function task #2 (describe) 49 NEI 12-01 Phase 1 report April 2013 April 2013 Page 44 of Page 44 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment 1 IPEC TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Multi-Unit Extended Station Blackout L Position Performance Time Period After Emergency Declaration (minutes) "

I Performing N Function / 270- 275- 280- 285- 290- 295- 300- 305- 310- 315- 320- 325- 330- 335- 340- 345- 350- 355-ETask 275 280 285 290 295 300 305 310 315 320 325 330 335 340 345 350 355 360 6 + hours 1 In-Plant Survey: As directed by SM U2jU3 RP 2 On-site Survey: As directed by SM U2 U3 RP 3 Personnel Monitoring:

4 ob Coverage: As directed by SM U21U3 RP 5 Offsite Rad Assessment:

(Included in Table 5

6 Other site specific RP (describe):

7 Chemistry Function task #1 As directed by SM (describe)

U3 Chem 8 Chemistry Function task #2 (describe) of 49 NEI 12-01 Phase 1 report April 2013 April 2013 Page 45 Page 45 of 49 NEI 12-01 Phase 1 report

Entergy Indian Point Energy Center Phase I Staffing Assessment Attachment 1 IPEC TABLE 5:- EMERGENCY PLAN IMPLEMENTATION Multi-Unit Extended Station Blackout ine# Function / Task On-Shift Task Analysis Controlling Position Method..

Declare the emergency classification U2 SM Emergency Planning Training 1level (ECL) Program / EP Drills rpprove2 Offsite Protective Action Recommendations ~U2 Emergency Planning Training SMEmrecPlnigTaig 2Recommendations Program / EP Drills 3 pprove content of State/local Emergency Planning Training notifications Program 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff Licensed Operator Training 5 U2 SM Program / Emergency Planning e.g., to assemble, evacuate, etc.) Training Program 6 ERO notification U3 SM Emergency Planning Training Program 7 Abbreviated vntN/A NRC notification for DBT N/A event Emergency Planning Training U2 SM Prgram 8 Complete State/local notification form Program Emergency Planning Training 9 Perform State/local notifications Communicator Prgram I Program Licensed Operator Training U2 SM PrOgram 10 Complete NRC event notification form Program 11 Activate ERDS (Note 1) N/A Emergency Planning Training (Note 2) Prgram 12 Offsite radiological assessment Program I

13 Perform NRC notifications Communicator Emergency Planning Training Program Perform other site-specific event Licensed Operator Training 14 notifications (e.g., Duty Plant Manager, U3 SM Program INPO, ANI, etc.)

Security Training Program / EP 15 Personnel Accountability Security Drills 2013 Page 46 of 49 NEI 12-01 Phase I Report April April 2013 Page 46 of 49 NEI 12-01 Phase 1 Report

Entergy Indian Point Energy Center Phase 1 Staffing Assessment Attachment I Note 1: ERDS at both units normally operates 24/7 and therefore does not require specific actions to activate the system. It is recognized, however, that the BDBEE may result in the loss of normal communication paths for ERDS. If ERDS capability is lost, critical information would be communicated directly to the NRC over other communication paths, such as satellite phones Note 2: U2 Chemistry will report to the U2 Control Room to assist the SM/ED as directed and be available if an unmonitored release is detected by onsite surveys. A release is not anticipated since core cooling, spent fuel pool cooling and containment are maintained during the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period of 49 NEI 12-01 Phase 1 Report April 2013 April 2013 Page 47 Page 47 of 49 NEI 12-01 Phase 1 Report

Entergy IPEC Phase I Staffing Assessment Attachment 2 ATTACHMENT 2 ENHANCEMENTS IDENTIFIED ENTERGY INDIAN POINT ENERGY CENTER NEI 12-01 PHASE 1 STAFFING ASSESSMENT NEI 12-01 Phase 1 Report 2013 April April 2013 Page 48 Page of 49 48 of 49 NEI 12-01 Phase 1 Report

Entergy IPEC Phase I Staffing Assessment Attachment 2 ATTACHMENT 2 - ENHANCEMENTS A. Activating the IPEC Expanded Response Capability Entergy will incorporate instructions into applicable fleet/site guidance to activate the Expanded Response Capability and to integrate this capability into the existing augmented emergency response organization structure based upon the following conditions, as described in NEI 12-01, Section 3.8:

" Loss of ALL offsite and ALL on-site power sources to AC emergency busses at more than 1 unit, OR

" Plant parameters or conditions require implementation of SAM strategies for more than 1 unit.

[Enhancement]

B. Drill and Exercise Program Given that the mitigating strategies, associated procedures, and modifications have not been implemented at this time, Entergy will not be revising the drill and exercise program in response to the Phase 1 assessment. Entergy will identify any appropriate modifications to the Indian Point Energy Center (IPEC) Emergency Plan Drill and Exercise Program upon completion of the mitigation strategies and associated guidance being developed in response to NRC order EA 12-049 recommendation 4.2. [Enhancement]

Page 49 of 49 NEI 12-01 Phase 1 Report April 2013 April 2013 Page 49 of 49 NEI 12-01 Phase 1 Report

ATTACHMENT TO NL-13-070 INDIAN POINT ENERGY CENTER LIST OF REGULATORY COMMITMENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKET NOS. 50-247 and 50-286

NL-13-070 Dockets 50-247 and 50-286 Attachment Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check One) SCHEDULED COMPLETION COMMITMENT ONE- DATE TIME CONTINUING (If Required)

ACTION COMPLIANCE Entergy will perform this assessment X November 3, 2014 (determine the applicable staffing requirements to address back-up equipment to support the mitigation strategies required by NRC Order Number EA-12-04) as part of the Phase 2 staffing assessment as previously identified in NL-12-054.

Entergy will identify any appropriate X November 3, 2014 modifications to the Indian Point Energy Center (IPEC) Emergency Plan Drill and Exercise Program upon completion of the mitigation strategies and associated guidance being developed in response to NRC Order Number EA-12-04.

Entergy will incorporate instructions into X March 5, 2014 applicable fleet/site guidance for IPEC to activate the expanded response capability and to integrate this capability into the existing augmented emergency response organization structure based upon the following conditions as described in Nuclear Energy Institute (NEI) 12-01, Revision 0, dated May 2012.

" Loss of all offsite and all on-site power sources to AC emergency busses at more than one unit, or

" Plant parameters or conditions require implementation of severe accident management strategies for more than one unit.

NL-13-070, Letter Regarding Entergy'S Response to the March 12, 2012, Information Request, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing

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SUBJECT:

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Enclosure:

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NL-13-070, Letter Regarding Entergy'S Response to the March 12, 2012, Information Request, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing

Text

SUBJECT:

REFERENCE:

Dear Sir or Madam:

Enclosure:

Attachment:

SUMMARY

SUMMARY

Response

Response

Response

SUMMARY

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