L-PI-13-102, License Amendment Request (LAR) to Revise Staff Augmentation Times in the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plan

License Amendment Request (LAR) to Revise Staff Augmentation Times in the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plan

ML13358A405
Person / Time
Site:	Prairie Island
Issue date:	12/20/2013
From:	Davison K Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-13-102
Download: ML13358A405 (183)

Text

Xc /Energy Prairie Island Nuclear Generating Plant 1717 Wakonade Drive East Welch, MN 55089 December 20, 2013 L-PI-13-102 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Docket Numbers 50-282 and 50-306 Renewed License Nos. DPR-42 and DPR-60 License Amendment Request (LAR) to Revise Staff Augmentation Times in the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plan Pursuant to 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), proposes revisions to the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, Emergency Plan that increase the staff augmentation times for certain Emergency Response Organization (ERO) functions from 30 minutes and 60 minutes to 90 minutes. The proposed changes result in an increase in activation time of the PINGP Emergency Response Facilities (ERFs).

An increase in activation time is considered a reduction in effectiveness. Therefore, in accordance with 10 CFR 50.54(q)(4), NSPM requests NRC review and approval of the proposed Emergency Plan changes. Additional proposed changes include formally defining "facility activation" and editorial changes to clarify Plan sections discussing the response times for the Monticello Radiation Protection Support Group (RPSG) and other segments of the Monticello and Prairie Island Offsite Emergency Response Organization.

The proposed changes are necessary to address concerns regarding ERO personnel response delays related to demographic changes and security improvements since the Emergency Plan was last approved by the NRC in the area of staffing. The increases in staff augmentation times are justified by an on-shift staffing analysis performed to meet the requirements of 10 CFR 50 Appendix E.IV.A.9. The on-shift staffing analysis supporting this proposed change assumes an increase in the on-shift staff for the major tasks of offsite dose assessment and in-plant surveys in Table 1 of the Emergency Plan. The staffing analysis also justifies removal of the collateral duties of the on-shift staff for the major tasks of repairs and corrective action and radiation protection. The

Document Control Desk Page 2 on-shift staffing analysis, along with the implementation of additional on-shift staff, provides assurance that appropriate staff is available for effective emergency response.

With implementation of the proposed changes, the PINGP Emergency Plan will continue to meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50 Appendix E, and the planning standards in 10 CFR 50.47(b). to this letter provides NSPM's evaluation of the proposed changes. to Enclosure 1 provides marked-up pages of the affected Emergency Plan. Attachment 2 to Enclosure 1 provides clean copy pages of the affected Emergency Plan with revision bars in the right-hand margin. Enclosure 2 to this letter provides the Prairie Island Augmentation Staffing Analysis (the on-shift staffing analysis) that supports the proposed changes in augmentation times.

NSPM evaluated the proposed changes in accordance with 10 CFR 50.92 and concluded that the changes involve no significant hazards consideration. Additionally, NSPM has determined that the proposed amendment does not authorize a significant change in the types or total amounts of effluent release or result in any significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed amendment meets the categorical exclusion requirements of 10 CFR 51.22(c)(9) and an environmental impact assessment need not be prepared. In accordance with 10 CFR 50.91, NSPM is notifying the State of Minnesota of this LAR by transmitting a copy of the letter and enclosures to the designated State Official.

NSPM requests NRC approval of this change within one calendar year of the submittal date. Upon NRC approval, NSPM requests 90 days to implement the associated changes.

Please contact Lynne Gunderson at 612-396-0173 with any questions or if additional information is required.

Document Control Desk Page 3 Commitment Summary:

This letter makes no new commitments and no revisions to existing commitments.

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

Executed on December 20, 2013.

J).v l~"-' ~u<J ?':).-<~

~Davison Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosures cc: Administrator, Region Ill, USNRC Project Manager, PINGP, USNRC Resident Inspector, PINGP, USNRC State of Minnesota

ENCLOSURE 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS 1 AND 2 Evaluation of the Proposed Changes License Amendment Request (LAR) for Revision to Staff Augmentation Times in the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plan 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Proposed Changes 2.2 Reason for the Proposed Changes 2.3 PINGP Emergency Plan Background

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes 3.2 On-Shift Staffing and Functional Analyses 3.3 Supporting Information 3.4 Conclusions

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination

6.0 REFERENCES

ATTACHMENTS:

1. Marked-Up Pages of Emergency Plan Sections 1.0, 2.0, 5.0, and 6.4.2

2. Clean Copy Pages of Emergency Plan Sections 1.0, 2.0, 5.0, and 6.4.2 Page 1 of 19 NSPM Revision to Staff Augmentation Times 1.0

SUMMARY

DESCRIPTION Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), proposes revisions to the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, Emergency Plan. Completion of an on-shift staffing analysis of the Emergency Response Organization (ERO) determined that changes can be made to increase the staff augmentation times for certain ERO response functions from 30 minutes and 60 minutes to 90 minutes. The on-shift staffing analysis is provided in Enclosure 2 of this License Amendment Request (LAR). Additional changes are proposed to add a definition for Facility Activation and editorial clarifications of expected response time for the Monticello Radiation Protection Support Group (RPSG) and other segments of the Monticello and Prairie Island Offsite Emergency Response Organization during an emergency.

The increase in the staff augmentation response times results in an increase in facility activation times for the NSPM Emergency Response Facilities (ERFs). Therefore, the changes in staff augmentation response times are considered a reduction in Emergency Plan effectiveness as defined in 10 CFR 50.54(q)(1)(iv). In accordance with 10 CFR 50.54(q)(4), changes to a licensee's emergency plan that reduce the effectiveness of the plan may not be implemented without prior Nuclear Regulatory Commission (NRC) approval and are submitted as license amendment requests (LAR) in accordance with 10 CFR 50.90.

2.0 DETAILED DESCRIPTION 2.1 Proposed Changes Brief descriptions of the associated Emergency Plan proposed changes are provided below along with a discussion of the justification for each change. The specific wording changes are provided in Attachments 1 and 2 to this enclosure as marked-up and clean copy Emergency Plan pages, respectively.

a. Section 1.0, Definitions, is revised to add definition 1.10 for Facility Activation.

PINGPs Emergency Plan currently does not define facility activation time nor does it have an approved alternative from the NRC definition. This change defines PINGPs emergency response facility activation time by adding this definition and by defining in Section 5.3 that activation time is measured from the time of emergency declaration. The definition is acceptable because it aligns with NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, (Reference 4) and NRC Inspection Procedure (IP) 71114.01, Exercise Evaluation, (Reference 1). NUREG-0654,Section II.B.5, defines the measurement of augmentation time from the declaration of the emergency (clock start). The Inspection Procedure allows activation times to Page 2 of 19 NSPM Revision to Staff Augmentation Times either be defined by licensee commitments or, in the absence of an approved alternative, the NRCs expectation.

b. The third paragraph in Section 2.0, Scope and Purpose, is revised to update the expected time that plant staff will be augmented by other segments of the Monticello and Prairie Island Offsite Emergency Response Organization. The time of approximately 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will be changed to 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. This time is revised to be consistent with Note 2 of Table 1 in the Prairie Island Emergency Plan, which states that Monticello Radiation Protection Group (RPG) will arrive within approximately two to three hours to augment and relieve the Prairie Island RPG of offsite surveys. This change is acceptable as it aligns the Offsite Emergency Response Organization response time with the response time described in Table 1, Note 2.

c. The second paragraph of Section 5.3, Plant Emergency Organization, is revised to reflect the 90 minute augmentation response and incorporates the new definition of Facility Activation as being measured from the time of emergency declaration. This change is acceptable based on both the new on-shift staffing analysis performed to support the change from 30 minute and 60 minute responders to 90 minute responders and the NUREG-0654 and IP guidance for measurement of Facility Activation.

d. Table 1, Guidance for Augmentation of Plant Emergency Organization, is changed extensively as shown in Attachments 1 and 2 of this enclosure. The proposed changes are summarized below:

- The 30 minute and 60 minute capability columns are removed and replaced with the 90 minute capability column.

- Major Functional Area of Notification/Communication is changed:

- Under the Major Task of Notify State, Local and Federal Personnel and Maintain Communication, Position Title or Expertise of the Shift Emergency Coordinator (SEC), the 30 minute and 60 minute capabilities are removed and the 90 minute capability is set at three (3).

- Major Functional Area of Radiological Accident Assessment and Support of Operational Accident Assessment under Position Title or Expertise is changed:

- Under the Major Task of Offsite Dose Assessment, the Chemistry Technician is added as a Position Title or Expertise. One (1)

Chemistry Technician position is added to the on-shift staff and the 30 minute capability is removed. The 90 minute capability will be based on the Radiological Emergency Coordinator (REC) position, described below.

Page 3 of 19 NSPM Revision to Staff Augmentation Times

- Under the Major Task of Offsite Dose Assessment, Position Title or Expertise of the (REC), the 30 minute capability is removed (replaced with the new on-shift Chemistry Technician) and the 90 minute capability is set to one (1).

- Under the Major Task of Offsite Surveys, the Radiation Protection (RP) Specialist Position, the 30 minute and 60 minute capabilities are removed and the 90 minute capability is set to four (4).

- Under the Major Task of In-plant Surveys, the Plant Operators and/or RP Specialist adds one (1) position on-shift for a total of two (2) on-shift positions. Additionally, the 30 minute and 60 minute capabilities are removed and the 90 minute capability is set to one (1).

- Major Functional Area of Plant System Engineering, Repair and Corrective Actions is changed:

- Under the Major Task of Technical Support, Position Title or Expertise of Core/Thermal, the 30 minute capability is removed.

The 90 minute capability is set to one (1).

- Under the Major Task of Repair and Corrective Actions, Mechanical Maintenance, the on-shift minimum of one (1) as a collateral duty position is removed, the 60 minute capability is removed, and the 90 minute capability is set to one (1).

- Under the Major Task of Repair and Corrective Actions, Electrical Maintenance, the on-shift minimum of one (1) as a collateral duty is removed, the 30 minute and 60 minute capability are removed, and the 90 minute capability is set at two (2).

- Under the Major Task of Repair and Corrective Actions, Instrument Control, the 30 minute capability is removed, and the 90 minute capability is set to one (1).

- Major Functional Area of Protective Actions (In-Plant), is changed:

- For positions of Radiation Protection Specialist and/or Plant Operators, the on-shift minimum of one (1) and two (2) as collateral duties are removed, the 30 minute and 60 minute capabilities are removed, and the 90 minute capability is set to three (3).

- For the TOTAL number of positions, the on-shift capability increases from 18 to 20, the 30 minute and 60 minute capability totals (9 and 15) are removed, and the 90 minute capability total is set to 23.

- The last portion of Note (3) that states, during the first hour of the emergency, is deleted.

The above proposed changes to Table 1 of the PINGP Emergency Plan are acceptable as demonstrated by the on-shift staffing analysis performed out to 90 minutes. The on-shift staffing analysis is attached as Enclosure 2 of this LAR.

Page 4 of 19 NSPM Revision to Staff Augmentation Times

e. Table 2, Primary and Secondary Responsibilities of Plant Emergency Organization, is revised regarding Offsite Dose Assessment. Offsite Dose Assessment has been changed to a primary rather than a secondary responsibility for the Chemistry Technician. The Table is proposed to indicate P rather than S. The proposed change is acceptable as demonstrated by the on-shift staffing analysis performed out to 90 minutes and with the addition of one Chemistry Technician on-shift staff position. The on-shift staffing analysis is provided in Enclosure 2 of this LAR.

f. Section 5.3.3, Plant Shift Organization, Section G, Radiation Protection Specialist, is revised to change the number of Radiation Protection Specialists (RPS) onsite at all times from two to three. This change is acceptable as demonstrated by the on-shift staffing analysis performed out to 90 minutes with the addition of one RP Specialist on-shift staff position. The on-shift staffing analysis is attached as Enclosure 2 of this LAR.

g. Section 5.3.3, Plant Shift Organization, Section H, Chemistry Technician, is revised as follows:

- The number of Chemistry Technicians onsite at all times is changed from one to two.

- The text is clarified that one Chemistry Technician is responsible for chemistry and radiochemistry.

- The text is clarified that the second Chemistry Technician performs the dose assessment function until relieved by the augmented ERO.

These changes are acceptable as demonstrated by the on-shift staffing analysis performed out to 90 minutes with the addition of one Chemistry Technician on-shift staff position. The on-shift staffing analysis is attached as Enclosure 2 to the LAR.

h. In Section 5.4, EOF Organization, the second paragraph discusses the time period at which the EOF will be staffed and ready to assume emergency responsibilities from the TSC. This text is revised from about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of notification to 90 minutes of the Classification of an ALERT or higher.

Additionally, the last sentence of this paragraph is deleted. These changes are acceptable as demonstrated by the on-shift staffing analysis, which includes two additional on-shift staff. The on-shift staffing analysis is attached as Enclosure 2 to the LAR.

i. Section 5.6.2, Monticello Radiation Protection Group Support, is revised to be consistent with Note 2 of Table 1 in the Emergency Plan, which states that Monticello Radiation Protection Group (RPG) will arrive within approximately two to three hours to augment and relieve the Prairie Island RPG of offsite surveys.

This change is acceptable as it aligns the Monticello RPG response with that described in Table 1, Note 2.

Page 5 of 19 NSPM Revision to Staff Augmentation Times

j. In Section 6.4.2, Radiological Surveys, the third paragraph describes Radiological Survey Team activation during normal working hours and off hours.

This paragraph will be revised to eliminate the discussion of normal working and off hours activation. The paragraph will describe that the teams will be activated and respond within 90 minutes of declaration of the emergency. This change is acceptable as demonstrated by the on-shift analysis. On-shift personnel are capable of performing surveys until relieved by the 90 minute responders.

2.2 Reason for Proposed Changes The proposed change is needed to address concerns regarding ERO staff augmentation personnel capability to respond safely to the site in 30 minutes or 60 minutes. Area demographic changes and site security improvements driven by post-September 11, 2001, requirements have impacted emergency responder transit times to the ERFs resulting in challenges in meeting the augmentation times established in the last Emergency Plan that the NRC reviewed in the area of staffing (Revision 2).

In 2011, the Commission amended 10 CFR Part 50 Appendix E, Section IV.A, Organization, (i.e., Enhanced Emergency Preparedness new rule making) to address concerns regarding the assignment of tasks or responsibilities to on-shift ERO personnel that would potentially overburden them and prevent the timely performance of their emergency plan functions. The final rule better ensures sufficient on-shift staff by limiting the assignment of responsibilities that the on-shift ERO members would likely perform concurrently with their assigned emergency plan functions. NRC Staff guidance (Reference 3) recommends that a staffing analysis be performed to ensure the on-shift staff can carry out their assigned emergency response functions until the augmenting ERO arrives. NEI 10-05 (Reference 2), Section 2.14, Changes to ERO Response Times, supports the use of the staffing analysis methodology to address modifications to augmentation times. The rule change and the issuance of staffing analysis guidance documents (References 2 and 3) provided a good opportunity for NSPM to reevaluate the PINGP ERO on-shift, 30 minute, and 60 minute capability commitments to determine if a change to 90 minute capability was appropriate.

Area Demographics The area surrounding PINGP experienced significant population growth within the 10-mile Emergency Planning Zone (EPZ) since the last NRC approved Emergency Plan (Revision 2 in 1982) in the area of staffing. The table below provides a comparison of the areas approximate population in the EPZ since 1980.

Year 1980 1990 2000 2010 Population (approximate) 22,314 26,659 28,847 30,475 Percent Increase from previous -- 19.47% 8.21% 5.64%

10-year data point Page 6 of 19 NSPM Revision to Staff Augmentation Times As a result of increased population, it can be assumed commute times to the plant site from surrounding communities have increased. The impact that local population growth has on response time for ERO members depends on factors that vary widely with conditions ranging from time of the day to season of the year. Any increase in travel time without corresponding relaxation in facility activation time increases the perceived pressure to achieve timeliness, with a potential for reduction in driving safety for individuals responding to the emergency.

Security Enhancements Significant improvements have been made to the physical security of the PINGP site since September of 2011. Among these are vehicle delay barriers outside the plant Protected Area (PA) and relocation of the main employee parking lot farther from the facility. As a result, personnel transit time to the PA has increased by several minutes.

Additional security measures at the Site Access Facility (SAF) and the point of PA access may also add several minutes of delay, depending on the time of the day and the conditions of traffic on site. The delays from security changes may potentially impact ERO augmenting staff response times.

2.3 PINGP Emergency Plan Background PlNGP is a two unit plant site located on the west bank of the Mississippi River approximately 26 miles southeast of the Twin Cities metropolitan area in Minnesota.

The facility is owned and operated by NSPM. Each unit at PlNGP employs a two-loop pressurized water reactor designed and supplied by Westinghouse Electric Corporation.

The initial PlNGP application for a Construction Permit and Operating License was submitted to the Atomic Energy Commission (AEC) in April 1967. The Final Safety Analysis Report (FSAR) was submitted for application of an Operating License in January 1971. Unit 1 began commercial operation in December 1973 and Unit 2 began commercial operation in December 1974.

The PINGP was designed and constructed to comply with the licensee's understanding of the intent of the AEC General Design Criteria (GDC) for Nuclear Power Plant Construction Permits, as proposed on July 10, 1967. PINGP was not licensed to NUREG-0800, "Standard Review Plan (SRP)."

PINGP has four ERFs augmenting the on-shift staff: the Technical Support Center (TSC), the Operational Support Center (OSC), the Emergency Operations Facility (EOF) and the Joint Information Center (JIC). During an emergency, the Shift Manager initially assumes the responsibility as Emergency Director (ED). Emergency response by on-shift staff is directed by the ED from the control room (CR) until relieved by an augmenting staff with the subsequent activation of ERFs.

Page 7 of 19 NSPM Revision to Staff Augmentation Times PINGP uses four standard levels of emergency classification as described in NUREG-0654, Revision 1. Augmentation of the on-shift staff for an Unusual Event is optional and is left to the discretion of the ED. At the Alert or higher emergency classification levels, all of the ERFs are activated. The associated augmenting personnel are notified to report to their assigned facilities. A facility is declared activated by its respective manager once minimum required staffing has been achieved such that the facility is capable of performing its assigned functions.

The last PINGP Emergency Plan reviewed and approved by the NRC in the area of staffing was Revision 2. Revision 2 was approved by NRC Safety Evaluation Report (SER) dated December 27, 1982. As approved by NRC, the PINGP Emergency Plan, Revision 2, contained 30 minute and 60 minute augmentation time goals for minimum staffing positions and met the intent of the guidance of NUREG-0654, Revision 1. These time goals were shown in PINGP Emergency Plan, Revision 2, Figure 5-3, "Guidance for Augmentation of Onsite Emergency Organization." The Emergency Plan, Revision 2, Figure 5-3, provided the site commitment to meet the guidance for on-shift staffing and augmentation goals established in Table B-1 of NUREG-0654, Revision 1. In 1982 and today, activation of the TSC, the EOF, and the OSC occurs at the Alert (or higher) emergency. The JIC is currently activated at the Alert (or higher) level. Therefore, all ERFs are currently activated at the Alert (or higher) classification level.

The current revision of the Emergency Plan on the date of this submittal is Revision 49.

Revision 49 incorporates modifications made pursuant to the provisions of 10 CFR 50.54(q) including the revisions based on the staffing analyses performed to show compliance with the Enhanced Emergency Preparedness Rule Making published in the Federal Register on November 23, 2011.

This LAR does not correct past performance deficiencies related to staffing. Following an Alert on January 7, 2012, the following two self-revealed green findings with associated non-cited violations (NCV) of NRC requirements were identified:

• A Green Finding and associated NCV for failure to initiate Emergency Response Data System (ERDS) within the one hour as required by Appendix E: The ERDS system was placed into service at 80 minutes instead of the required 60 minutes. Attempts to activate began at 62 minutes, two minutes after the required time. It was determined that the connection failure was in the Beta testing of the new Virtual Private Network (VPN) and supporting software interfering with the ERDS modem. This has been corrected. Additionally, the ERDS activation was reassigned to the SEC, an on-shift position, to ensure it was performed in 60 minutes. ERDS activation by the SEC was evaluated in the compliance on-shift staffing analysis and was found acceptable. The function assignment is not changed by this LAR.

• A Green Finding and associated NCV for failure to follow and maintain the Emergency Plan in that five thirty-minute responders failed to augment in Page 8 of 19 NSPM Revision to Staff Augmentation Times a timely manner: Four RP Specialists and the REC failed to augment the on-shift staff in a timely manner during the Alert. NSPMs interim corrective measures in January 2012 included temporarily adding two RP Specialist on-shift, which increased the on-shift compliment to four. The failure of the REC position to augment in a timely manner was attributed to individual performance. In December 2012, the compliance on-shift staffing analysis justified that two on-shift RP Specialists were adequate to respond to scenarios until relieved by the augmented ERO. Subsequent drill performance provides assurance that the 30 minute and 60 minute augmented staffing can be met.

Therefore, performance deficiencies related to the January 7, 2012 Alert have been resolved by the site and this LAR is not correcting any outstanding performance deficiencies.

3.0 TECHNICAL EVALUATION

3.1 Proposed Changes As shown in Attachments 1 and 2 to this Enclosure, this LAR proposes to:

A. Add a definition for Facility Activation (new Emergency Plan Section 1.10) and provide the time at which it is measured from (updated Emergency Plan Section 5.3). As stated in Section 2.0 of this LAR, these changes define PINGPs emergency response facility activation time. The definition aligns with NUREG-0654, Revision 1 (Reference 4) and NRC Inspection Procedure 71114.01 (Reference 1). This change is not supported by the analyses described in 3.2 nor the technical improvements described in 3.3.

B. Revise Section 2.0 to be consistent with Note 2 of Table 1 in the Prairie Island Emergency Plan, which states that Monticello Radiation Protection Group (RPG) will arrive within approximately two to three hours to augment and relieve the Prairie Island RPG of offsite surveys. This change is made for consistency within the Emergency Plan and is not supported by the analyses described in 3.2 or the technical improvements described in 3.3.

C. Revise ERO staff augmentation times from 30 minutes and 60 minutes to 90 minutes. The proposed change to 90 minute response time capability revises text in Tables 1 and 2 and in Sections 5.3, 5.3.3.G, 5.3.3.H, 5.4, and 6.4.2 of the Emergency Plan. All of the changes are acceptable based on the On-shift staffing analysis and functional analysis discussed in Section 3.2 below and fully supported by the staffing analysis provided in Enclosure 2. Finally, these changes are also supported by improvements in technology since the last NRC approval of the Emergency Plan (Revision 2). The improvements in technology Page 9 of 19 NSPM Revision to Staff Augmentation Times increase the capabilities of the on-shift staff. The improvements are described in Section 3.3 below.

D. Revise Section 5.6.2, Monticello Radiation Protection Group Support, to be consistent with the expected response from Monticello as noted in Table 1, note (2). This change is made for consistency within the Emergency Plan and is not supported by the analyses described in 3.2 or the technical improvements described in 3.3.

3.2 On-Shift Staffing and Functional Analysis The requirements in 10 CFR 50 Appendix E and in 10 CFR 50.47 (b) establish emergency planning standards that require 1) adequate staffing; 2) satisfactory performance of key functional areas and critical tasks; and 3) timely augmentation of the response capability. The proposed change will increase the time for the ERO personnel to respond to their assigned duties, which increases the time for ERF activation. The increase in staff augmentation times necessitates a greater emphasis on the capabilities of on-shift personnel to demonstrate that no degradation or loss of function will result due to the increase in augmentation times. Therefore, NSPM performed an on-shift staffing analysis to ensure the on-shift staff is capable of carrying out assigned emergency plan functions until augmenting responders arrive.

For the proposed changes in staff augmentation times it was demonstrated by table top exercise that the on-shift staff could perform the required functions until augmenting staff arrived at 90 minutes from the declared Alert or higher Emergency Classification. If degradation or loss of function was identified during the tabletop, the conflict was documented in the on-shift staffing analysis and resolved in a functional analysis. The on-shift staffing analysis demonstrated no degradation or loss of function as long as two on-shift staff positions were added in the area of radiological accident assessment.

The on-shift staffing analysis that supports this proposed increase in staff augmentation response time is described in Section II of Enclosure 2 of this LAR. The analysis was performed to meet the requirements discussed in the Enhanced Emergency Preparedness Rulemaking published in the Federal Register on November 23, 2012 and the new rule itself (10 CFR 50 Appendix E.IV.A.9). Additionally, the methodology described in NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, (Reference 2) was used to perform the analysis. The NEI 10-05 guidance was endorsed by the NRC in NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, (Reference 3) as an acceptable means of performing staffing analyses for compliance with the Enhanced Emergency Preparedness Rulemaking. The analysis performed for this LAR was based on the on-shift staffing analysis performed to demonstrate compliance with the new rule.

A functional analysis was also performed. The results of the on-shift staffing analysis for completion of functions associated with the 30 minute and 60 minute responders were tabulated and all conflicts dispositioned. The functional analysis and dispositions of the Page 10 of 19 NSPM Revision to Staff Augmentation Times conflicts are documented in Section III, Functional Analysis, Tables E through H of .

The on-shift staffing analysis in Enclosure 2 concluded that with the addition of two personnel on-shift, the 30 minute and 60 minute staff augmentation times could be extended to 90 minutes with no loss of function (i.e., functions could still be performed successfully and without conflicts). The report concluded the following positions must be added to the on-shift staff to support the increase in staff augmentation time to 90 minutes:

1. The addition of a one Chemistry Technician (a total of 2 for the position following LAR implementation) to resolve the conflict between chemistry sampling and dose assessment. The second Chemistry Technician will assume responsibility for dose assessment and allow the first Chemistry Technician to continue with chemistry sampling and communication responsibilities. This additional position allows the 30 minute REC position to be extended to 90 minute capability.

2. The addition of one RP Specialist (now a total of 3 for the position following LAR implementation) to resolve the conflict between required survey functions. The third RP Specialist on-shift will provide needed support for surveys in assembly areas as well as in-plant locations. With this addition to the on-shift staff, the remaining RP Specialists can be extended to 90 minute capability.

The report also concluded that two additional functions were no longer needed on-shift.

These on-shift functions are the mechanical maintenance and the electrical maintenance functions. The on-shift staffing analysis concluded these functions could be extended to 90 minutes without loss of function.

Therefore, the on-shift staffing analysis demonstrates that the proposed increase in augmentation response times, along with the increase in on-shift staff, ensures the PINGP Emergency Plan will continue to meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50 Appendix E, and the planning standards of 10 CFR 50.47(b).

3.3 Supporting Information Improvements in technology have enabled the on-shift staff to assess plant conditions quickly and efficiently, and with less distraction. The improvements help minimize the impact on the performance of the major tasks that may result from the proposed change in augmentation times. The following describes technological advancements that have occurred since the last NRC approval of the Emergency Plan (Revision 2) in 1982. The technology advancements result in increased capabilities of on-shift personnel.

Emergency Response Computer System (ERCS)

The ERCS provides a means for personnel to quickly monitor critical plant parameters from a single workstation. The ERCS software collects and Page 11 of 19 NSPM Revision to Staff Augmentation Times processes selected field data for display to plant personnel. This data is displayed in a concise and consistent format on displays in the CR, TSC, EOF and Backup EOF. This information, in its multiple forms, is used to assist personnel in the proper implementation of Emergency Procedures during an accident condition. The system also provides CR personnel with access to relevant information to assist them during operational transients.

The ERCS software is composed of three distinct but fully integrated software packages: the Plant Monitoring System (PMS), the Safety Assessment System (SAS), and the Emergency Response Data System (ERDS).

The design criteria for the ERCS were based on the requirements of NUREG-0737, Supplement 1, regarding the need for a Safety Parameter Display System (SPDS) and the upgrading of ERFs. The requirements specified for the SPDS are met or exceeded by a system of displays provided by the ERCS. The parameters on the SPDS displays are provided by the SAS software. Emergency Response Facilities upgrade requirements are met by providing the ERCS driven displays in the CR, TSC, EOF, and the Backup EOF. Regulatory Guide 1.97 information is provided by the ERCS to all the display locations. The Plant Process Computer System (PPCS) requirements are met by application programs as part of the PMS.

Dose Assessment Dose assessment is currently performed by on-shift Chemistry Technicians using the RASCAL dose model rather than manual calculation methods. The RASCAL application is available on any local area network (LAN) computer or ERF dose assessment computer. Specifically designed ERCS displays have been developed for obtaining the necessary plant, radiological effluent, area radiation monitor, and meteorological information that is used by the Chemistry Technician in RASCAL.

The improvements to the dose assessment program require minimal user interface to produce results quickly. Radiological dose assessment has benefited from technological advances that make its use simpler and less time consuming.

Radiological Work Control Enhancements in electronic controls of Radiation Work Permits and dosimetry permit real time assessment and dose control for radiation workers. This limits the need for direct monitoring by RP Specialists.

Page 12 of 19 NSPM Revision to Staff Augmentation Times Automated Call-out Systems Enhancements in automated call-out and paging systems have resulted in streamlined processes for activation of the ERO. A single phone call initiates rapid notification of all ERO members in lieu of individual sequenced phone calls.

Improvements Summary The improvements in technology since the last approval of the Emergency Plan (Revision 2) have resulted in an increase in the on-shift efficiencies. In aggregate, these improvements support the proposed change in augmentation times by ensuring that major functions and tasks are completed more efficiently with fewer burdens on the CR staff. Therefore, the technology improvements also support that there would be no significant degradation or loss of any functional task as a result of the proposed increase in augmentation times.

3.4 Conclusions The proposed changes continue to support all of the functional areas of the Emergency Plan, continue to ensure the protection of the health and safety of the public and site personnel, and will not present a significant burden to the on-shift personnel. Although the ERO staffing augmentation response time is being increased, resulting in an increased ERF activation time, the emergency response functions identified in the Emergency Plan will continue to be performed by the on-shift staff until relieved by augmented ERO responders and will not result in a reduction of the capability of the ERO to effectively respond to the emergency. Therefore, the proposed increase in augmentation response times, along with the increase in on-shift staff, ensures the PINGP Emergency Plan will continue to meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50 Appendix E, and the planning standards of 10 CFR 50.47(b).

4.0 REGULATORY ANALYSIS

4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of Federal Regulations 50.47(b)(1) and (2):

(b) The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:

(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and Page 13 of 19 NSPM Revision to Staff Augmentation Times each principal response organization has staff to respond and to augment its initial response on a continuous basis.

(2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

The existing Emergency Plan includes onsite and offsite emergency response plans that meet the requirements listed above. This LAR proposes to increase the current staff augmentation response times from 30 minute and 60 minutes to 90 minutes.

Implementation of two on-shift staff positions supports this change. With the addition of the on-shift staff, the Emergency Plan will continue to have onsite and offsite emergency response plans that meet 10 CFR 50.47(b).

Title 10 Code of Federal Regulations 50.54(q):

(q) Emergency Plans (1)(iv) Reduction in effectiveness means a change in an emergency plan that results in reducing the licensees capability to perform an emergency planning function in the event of a radiological emergency.

(2) A holder of a license under this part, or a combined license under part 52 of this chapter after the Commission makes the finding under § 52.103(g) of this chapter, shall follow and maintain the effectiveness of an emergency plan that meets the requirements in Appendix E to this part and, for nuclear power reactor licensees, the planning standards of

§ 50.47(b).

(4) The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in Appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b).

The existing PINGP Emergency Plan meets the planning standards of 10 CFR 50.47(b) and 10 CFR 50 Appendix E as required by 10 CFR 50.54(q)(2). This LAR proposes to Page 14 of 19 NSPM Revision to Staff Augmentation Times increase the current staff augmentation response times from 30 minutes and 60 minutes to 90 minutes. Implementation of two additional on-shift staff positions allows for the response time increase. This proposed change to 90 minutes is considered a reduction in effectiveness as defined in 10 CFR 50.54(q)(1)(iv) and requires submittal based on 10 CFR 50.54(q)(4). Therefore, NSPM is submitting this LAR pursuant to 10 CFR 50.90.

With the addition of the on-shift staff, the Emergency Plan will continue to meet the requirements of 10 CFR 50.54(q)(2) by maintaining the effectiveness of the Emergency Plan such that it meets the requirements of 10 CFR 50 Appendix E, and the planning standards of 10 CFR 50.47(b).

Title 10 Code of Federal Regulations Part 50 Appendix E:

A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

A.9 By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

The existing PINGP Emergency Plan includes a description of the organization, including definition of authorities, responsibilities and duties of individuals. The current Emergency Plan (Revision 49) is in compliance with the new rule (10 CFR 50 Appendix E.IV.A.9). This LAR proposes to increase the current staff augmentation response times from 30 minute and 60 minutes to 90 minutes. A staffing analysis has been performed to demonstrate continued compliance with 10 CFR 50 Appendix E.IV.A.9. The staffing analysis and implementation of two additional on-shift staff positions demonstrate acceptability of this increase in staff augmentation times.

The proposed changes to the Emergency Plan will continue to describe the authorities, responsibilities and duties of these individuals. Therefore, with the changes proposed in the LAR, the requirements of 10 CFR 50 Appendix E continue to be met.

NUREG-0654/FEMA-REP-1, Revision 1 (Reference 4)

NUREG-0654/FEMA-REP-1, Revision 1,Section II.B.5 states:

"Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift Page 15 of 19 NSPM Revision to Staff Augmentation Times staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

NUREG-0654 states general guidance concerning the onsite emergency organization to allow licensees some flexibility in the number of on-shift staff required by emergency plans for response to emergency events. NUREG-0654 guidance recommends that there be, in addition to on-shift personnel, 30-minute and 60-minute responders. The augmented ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing them to focus more fully on plant operations.

NUREG-0654 also provides the guidance that augmentation time be measured from the declaration of the emergency.

The current PINGP Emergency Plan staffing in Table 1 meets the intent of NUREG-0654, Table B-1. This LAR proposes to increase the current staff augmentation response times from 30 minutes and 60 minutes to 90 minutes. The proposed changes have been evaluated in a staffing analysis performed to meet 10 CFR 50 Appendix E.IV.9, using the methodology of NEI 10-05 (Reference 2), which was endorsed by NRC in NSIR/DPR-ISG-01 (Reference 3). The proposed changes to the Emergency Plan are based on the on-shift staffing analysis but continue to meet the intent of NUREG-0654, Table B-1 (i.e., continues to cover the emergency functional areas in Table B-1). Additionally, the LAR proposes to measure Facility Activation time (i.e., augmentation time) from the time of declaration of the emergency. This change is in alignment with NUREG-0654,Section II.B.5.

Conclusion NSPM has evaluated the proposed change against the applicable regulatory requirements and acceptance criteria. The proposed Emergency Plan changes continue to assure that regulatory requirements and emergency planning standards associated with emergency response are met.

4.2 Precedent Entergy Nuclear Operations submitted a LAR in June 2013 for the Palisades Nuclear Plant to increase staff augmentation times (ADAMS Accession No. ML13176A405).

However, no regulatory decisions have been made regarding the Palisades LAR at time of this NSPM submittal. NSPM is not aware of any final regulatory decisions that have been made regarding LARs that increase staff augmentation times since the Enhanced Emergency Preparedness Rule Making was published in the Federal Register on November 23, 2012. The rule made changes to10 CFR 50 Appendix E.IV.A.9 and directed a detailed analysis be performed to ensure on-shift staffing was adequate to perform critical functions. Prior to the rule change, staff augmentation time increases were not justified using on-shift staffing analyses.

Page 16 of 19 NSPM Revision to Staff Augmentation Times 4.3 No Significant Hazards Consideration Determination In accordance with the requirements of 10 CFR 50.90, Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM),

requests an amendment to facility Renewed Operating Licenses DPR-42 and DPR-60, for the Prairie Island Nuclear Generating Plant (PINGP), Units 1 and 2, to revise the Emergency Plan. Completion of an on-shift staffing analysis of the Emergency Response Organization (ERO) determined that changes can be made to increase the staff augmentation times for certain ERO response functions from 30 minutes and 60 minutes to 90 minutes. NSPM proposes to revise the ERO staff augmentation response times in the PINGP Emergency Plan.

NSPM has evaluated the proposed amendment against the standards in 10 CFR 50.92 and has determined that the operation of the PINGP in accordance with the proposed amendment presents no significant hazards. NSPMs evaluation against each of the criteria in 10 CFR 50.92 follows.

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed increase in staff augmentation times has no effect on normal plant operation or on any accident initiator or precursors and does not impact the function of plant structures, systems, or components (SCCs). The proposed change does not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event. The ability of the emergency response organization to respond adequately to radiological emergencies has been demonstrated as acceptable through a staffing analysis as required by 10 CFR 50 Appendix E.IV.A.9.

Therefore, the proposed Emergency Plan changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not impact the accident analysis. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis. This proposed change increases the staff augmentation Page 17 of 19 NSPM Revision to Staff Augmentation Times response times in the Emergency Plan, which are demonstrated as acceptable through a staffing analysis as required by 10 CFR 50 Appendix E.IV.A.9. The proposed change does not alter or prevent the ability of the Emergency Response Organization to perform their intended functions to mitigate the consequences of an accident or event.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change is associated with the Emergency Plan staffing and does not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed change does not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed change. Safety analysis acceptance criteria are not affected by this proposed change. The revised Emergency Plan will continue to provide the necessary response staff with the proposed change. A staffing analysis and a functional analysis were performed for the proposed change on the timeliness of performing major tasks for the functional areas of Emergency Plan. The analysis concluded that an increase in staff augmentation times, with the addition of two on-shift positions, would not significantly affect the ability to perform the required Emergency Plan tasks. Therefore, the proposed change is determined to not adversely affect the ability to meet 10 CFR 50.54(q)(2), the requirements of 10 CFR 50 Appendix E, and the emergency planning standards as described in 10 CFR 50.47 (b).

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, the NSPM has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it does not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Page 18 of 19 NSPM Revision to Staff Augmentation Times

5.0 ENVIRONMENTAL CONSIDERATION

NSPM has determined that the proposed change would not revise a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement.

The proposed amendment does not involve (i) a significant hazards consideration, or (ii) authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) result in a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, NSPM concludes that pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NRC Inspection Manual, Inspection Procedure 71114.01, Exercise Evaluation, May 29, 2012.

2. NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," Revision 0, dated June 2011.

3. NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear*

Power Plants," Revision 0, November 2011.

4. NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, November 1980.

Page 19 of 19

ENCLOSURE 1, ATTACHMENT 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST License Amendment Request (LAR) for Revision to Staff Augmentation Times in the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plan (EP)

MARKED-UP PAGES OF EMERGENCY PLAN SECTIONS 1.0, 2.0, 5.0 AND 6.4.2 (38 pages follow)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 7 of 149 1.0 DEFINITIONS Listed below are some terms in this plan along with the definitions that should be applied to these terms when they are used in this plan.

1.1 Assessment Action - Actions taken during or after an accident to obtain and process information necessary to make decisions regarding emergency measures.

1.2 Corrective Actions - Emergency measures taken to terminate an emergency situation at or near the source in order to prevent or minimize a radioactive release, e.g., shutting down equipment, firefighting, repair and damage control, etc.

1.3 Emergency Action Level (EAL) - A predetermined, site-specific, observable threshold for a plant Initiating Condition (IC) that places the plant in a given emergency class. An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter (onsite or offsite); a discrete, observable event; results of analyses; entry into specific emergency operating procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

1.4 Emergency Class: - One of a minimum set of names or titles, established by the Nuclear Regulatory Commission (NRC), for grouping of normal nuclear power plant conditions according to (1) their relative radiological seriousness, and (2) the time sensitive onsite and off site radiological emergency preparedness actions necessary to respond to such conditions. The existing radiological emergency classes, in ascending order of seriousness, are called: Notification of Unusual Event (UE), Alert, Site Area Emergency (SAE), and General Emergency (GE).

1.5 Emergency Director (ED) - The Plant Manager or designee. This individual has overall responsibility and authority for managing the emergency effort within the plant. This person will also manage efforts external to the plant until the Emergency Operations Facility (EOF) Organization can relieve the ED of external tasks.

1.6 Emergency Manager (EM) - A designated member of site management. This person has the authority and responsibility for the management of (NSPM) Northern States Power Company - Minnesota overall response to an emergency. The EM will assume command and control at the Emergency Operations Facility and direct the NSPM response efforts.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 8 of 149 1.7 Emergency Planning Zones - a defined area around the plant to facilitate emergency planning by state and local authorities, to assure that prompt and effective actions are taken to protect the public in the event of a release of radioactive material. It is defined for:

1.7.1 Plume Exposure Pathway - a 10 mile radius around the plant where the principal exposure source is: (1) whole body exposure to gamma radiation from the plume and from deposited material; and (2) internal exposure from the inhaled radionuclides deposited in the body (Short Term Exposure).

1.7.2 Ingestion Exposure Pathway - a 50 mile radius around the plant where the principal exposure would be from the ingestion of contaminated water or foods such as milk or fresh vegetables (Long Term Exposure). The ingestion exposure pathway includes the plume exposure pathway.

1.8 Emergency Worker - Any individual involved in mitigating the consequences of an emergency situation and/or minimizing or preventing exposure to the offsite population. The emergency worker category includes emergency workers at the plant as well as individuals who are engaged in public service emergency activities -

firemen, policemen, medical support, and certain public officials. These are people who voluntarily place themselves as emergency workers.

1.9 Exclusion Area - The area surrounding the plant that is under direct Prairie Island Nuclear Generating Plant control. This includes the Corps of Engineering land north of plant and the islands located in the Mississippi River east of plant. It is sized such that any individual located on its boundary would not exceed 25 REM whole body or 300 REM thyroid from I-131 for two hours immediately following the design basis accident (approximately 2340 feet out to boundary).

1.10 Facility Activation - An Emergency Response Facility is activated when the minimum staff per Table 1 is available and the facility is ready to assume its assigned functions under the Emergency Plan and relieve the on-shift staff of those functions. (Although the facility may be ready, the on-shift relief may be postponed in the interest of completing critical tasks prior to turnover.)

1.101.11 Initiating Condition (IC): - One of a predetermined subset of nuclear power plant conditions when either the potential exists for a radiological emergency, or such an emergency has occurred.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 9 of 149 1.111.12 Northern States Power Company - Minnesota (NSPM) d/b/a Xcel Energy -

Operator of the Prairie Island Nuclear Generating Plant.

1.121.13 Protective Actions - Emergency measures taken before or after a release of radioactive materials in order to prevent or minimize radiological exposures to the population.

1.131.14 Protective Action Guides (PAG) - Projected dose to individuals, that warrants protective action prior to and/or following a radioactive release.

1.141.15 Recovery Actions - Actions taken after an emergency to restore the plant to normal.

1.151.16 Xcel Energy - Operating Utility of Northern States Power Company -

Minnesota.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 10 of 149 2.0 SCOPE AND PURPOSE In accordance with license conditions, 10CFR Part 50, and NRC guidance, the Northern States Power Company - Minnesota (NSPM) has developed and implemented a radiological emergency response plan for the Prairie Island Nuclear Generating Plant (PINGP) and a joint off-site plan for the PINGP and the Monticello Nuclear Generating Plant. As asset owner NSPM, and Xcel Energy, the operating utility, retain all owner obligations.

This Emergency Plan is applicable to Prairie Island Nuclear Generating Plant (PINGP),

Units 1 and 2.

In any emergency situation at Prairie Island, the initial response to activate the Emergency Plan is accomplished by the plant staff and, if needed, immediate actions may be required by local support agencies. The plant, during initial stages of the emergency situation, must function independently coordinating both onsite and offsite activities. It is expected that within approximately 1 2 to 2 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the plant staff will be augmented by other segments of the overall Monticello & Prairie Island (MT & PI) Offsite Emergency Response Organization (EOF staff, Monticello Field Teams and other company support staff). The augmented response organization will assume those tasks external (offsite) to the plant, thus allowing the plant staff to be responsible for all onsite activities. This plan covers the actions and responsibilities of the PINGP Emergency Organization and the Emergency Operations Facility Organization.

The purpose of the plan is to describe the following:

2.1 Organization and actions within the plant to control and limit the consequences of an accident.

2.2 Organization and actions controlling site and offsite activities in the event of an uncontrolled release of radioactive material. This includes notification of and coordination with required offsite support agencies.

2.3 Identifying and evaluating the consequences of accidents that may occur and affect the public and plant personnel.

2.4 Describing the protective action levels and actions that are required to protect the public and plant personnel in the event of an accident.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 11 of 149 2.5 Consideration necessary for the purpose of reentry and short-term recovery.

2.6 Arrangements required for medical support in the event of injury.

2.7 Arrangements required for fire fighting support in the event of major fires requiring outside support.

2.8 The training necessary to assure adequate response to emergencies.

The Emergency Plan is dependent upon various standing plant operating, abnormal operating, emergency operating, plant safety, radiological control and security procedures and the Emergency Plan Implementing Procedures for the implementation of the plants response to the spectrum of emergency situations.

PINGP has procedures in place that implement on-site protective actions and personnel accountability during security events that are appropriate for plant and environmental conditions.

Coordination between plant, state, local and tribal authorities is defined in the Minnesota and Wisconsin state emergency operations plans, Goodhue, Dakota and Pierce county emergency plans and the Prairie Island Indian Communitys emergency plan. Goodhue, Dakota and Pierce Counties have, formulated for their respective areas, individual evacuation plans which are included in the respective state plans.

Monticello & Prairie Island (MT & PI) offsite response is detailed in the Corporate Nuclear Emergency Plan.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 17 of 149 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES 5.1 Normal Site Organization The normal site organization is comprised of the plant organization and several other site support organizations. The normal site organization can be accessed on the Prairie Island web page. Responsibilities and authorities of the various functional groups are delineated in plant Administrative Work Instructions.

5.2 Normal Plant Organization The normal plant operating crew is staffed and qualified to perform all actions that may be necessary to initiate immediate protective actions and to implement the emergency plan and is designated as the responsible group for such actions. The normal plant organization can be accessed on the Prairie Island web page.

The Plant Manager has overall responsibility for the safe, efficient operation of the plant and for compliance with operating license requirements. The Plant Manager SHALL select, train and supervise a qualified staff.

The Shift Manager reports directly to the Assistant Operations Manager who reports directly to the Operations Manager who reports directly to the Plant Manager. The Shift Manager is responsible for the direction and coordination of the Shift Supervisors on his/her shift to perform operations in accordance with the administrative controls and operating procedures. The Shift Manager coordinates activities with other plant groups as required to maintain the safe operation of the plant.

The Shift Supervisor reports to the Shift Manager. The Shift Supervisor is the single focal point for directing and coordinating the operations group, maintenance group and the plant security activities during his/her shift. The Shift Supervisor SHALL assume the primary management responsibility for the safe operation of the plant under all conditions during his/her shift. The responsibility and authority of the Shift Supervisor SHALL be to maintain the broadest perspective of operational conditions affecting the safety of the plant as a matter of highest priority at all times when on duty in the Control Room.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 18 of 149 5.3 Plant Emergency Organization A plant emergency organization is designated to augment the normal operating crew. Provisions have been made for rapid assignment of plant personnel to the plant emergency organization during emergency situations. The Prairie Island Plant Emergency Organization is shown in Figure 1.

Various areas of responsibility are assigned to segments of the plant staff during emergency situations as depicted in Table 1 and Table 2. Table 1 shows the personnel available on-shift and the capability for additional personnel within 30 minutes and 60 minutes of notification. Table 1 follows the guidance established by Table B-1 in NUREG 0654.to augment the on-shift staff within 90 minutes.

Augmentation will be measured from the time of Declaration to Facility Activation.

5.3.1 Direction and Coordination During the initial stages of an emergency condition at Prairie Island Nuclear Generating Plant, the Emergency Director has overall coordinating authority for Northern States Power Company - Minnesota (NSPM). The Emergency Director alone has the authority and responsibility to immediately initiate any emergency actions, including providing protective action recommendations to offsite authorities responsible for implementing offsite emergency measures.

When the Emergency Operations Facility (EOF) Organization is activated, the Emergency Manager (EM) and EOF staff will relieve the Emergency Director of all offsite responsibilities as soon as practical and assume the responsibility for the management of NSPMs overall response to the emergency. The Emergency Director can then direct the plants efforts towards management of the onsite responsibilities.

The Shift Supervisor, of the affected unit, until properly relieved, SHALL remain in the Control Room at all times during accident situations, to direct the activities of control room operators.

Twenty-four (24) hour coverage for the Emergency Director position is provided by the Duty Shift Manager who assumes the responsibility of the interim Emergency Director at the onset of any emergency condition. If necessary, the Shift Supervisor of the unaffected unit may function as an alternate Emergency Director backing up the Shift Manager.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 19 of 149 Figure 1 Prairie Island Plant Emergency Organization EMERGENCY EMERGENCY DIRECTOR MANAGER (IN EOF)

SHIFT EMERGENCY ASSEMBLY POINT COMMUNICATOR COORDINATOR OPERATIONAL TECHNICAL RADIOLOGICAL SECURITY WORK MANAGEMENT OPERATIONS SUPPORT CENTER SUPPORT CENTER EMERGENCY GROUP LEADER LEADER GROUP LEADER COORDINATOR COORDINATOR COORDINATOR ENGINEERING CHEMISTRY &

OPERATIONS GROUP LEADER HEALTH PHYSICS SECURITY FORCE GROUP SUPPORT ENGINEERING SUPPORT MAINTENANCE LOGISTICS GROUP LEADER SUPPORT LEADER ELECTRICAL MECHANICAL MAINTENANCE MAINTENANCE I&C GROUP

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 20 of 149 Table 1 Guidance for Augmentation of Plant Emergency Organization Capability for Additions Major Functional Area Major Tasks Position Title or Expertise On-Shift 30 min 60 90 min Plant Operations and Shift Manager/ED 1 Shift Supervisor (SRO): Unit Supervisors 2 - -

Assessment of Control Room Reactor Operational Aspects Reactor Operators (RO): 4 - -

Auxiliary Operators: 6 - -

Notification/ Notify State, local Shift Emergency Communication and Federal Communicator: 1 1 23 personnel &

maintain communication Radiological Accident Emergency Operations Emergency Manager Assessment and Facility (EOF) (as per duty roster): - - 1 Support of Director Operational Accident Assessment Offsite Dose Chemistry Technician /

Assessment Radiological -1 1 -1 Emergency Coordinator (REC):

Offsite Surveys Radiation Protection Specialist: - 2 2 4 (2)

Onsite Surveys Radiation Protection Specialist: 1 - 1 (out-of-plant)

In-plant Surveys Plant Operators and/or Radiation Protection Specialist: 1 2 (1,3) 1 1

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 21 of 149 Table 1 Guidance for Augmentation of Plant Emergency Organization Capability for Additions Major Functional Area Major Tasks Position Title or Expertise On-Shift 30 min 60 90 min Chemistry/

Radiochemistry Chemistry Technician: 1 - 1 Plant System Technical Support Shift Technical Advisor 1 - -

Engineering, Core/Thermal: - 1 -1 Repair and Electrical: - - 1 Corrective Actions Mechanical: - - 1 Repairs and Mechanical Maintenance: 1(1) - 1 Corrective Actions Rad Waste Operator: - - 1 Electrical Maintenance: 1(1) 1 12 Instrument Control: - 1 -1 Protective Actions Radiation Radiation Protection Specialist 1 1 23 (In-Plant) Protection: and/or Plant Operators: 2(1,3) - -

a. Access Control

b. HP Coverage for repair, corrective actions, search and rescue, first-aid &

firefighting

c. Personnel monitoring

d. Dosimetry

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 22 of 149 Table 1 Guidance for Augmentation of Plant Emergency Organization Capability for Additions Major Functional Area Major Tasks Position Title or Expertise On-Shift 30 min 60 90 min Fire Fighting Fire Brigade Local Support per F5 Rescue Operations and First Aid 2(1) Local Support Site Access Control Security, firefighting Security Personnel: As per and Personnel communications, Security Accountability personnel Plan accountability TOTAL 1820 9 1523 (1)

May be provided by shift personnel assigned other functions.

(2)

Monticello RPG will arrive within approximately 2-3 hours to augment and relieve the Prairie Island RPG of offsite surveys.

(3)

Chemistry Technicians are cross-trained in Radiation Protection and chemistry/radiochemistry. The non-licensed plant operators are fully trained to conduct post-accident in-plant surveys, during the first hour of the emergency.

The above table was developed in accordance with 10 CFR 50 Appendix E. This staffing analysis is documented in F3-1.1, Emergency Plan On-Shift Staffing Analysis.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 23 of 149 Table 2 Primary and Secondary Responsibilities of Plant Emergency Organization Shift Technical Advisor Chemistry Technician Radiation Protection Emerg Director Assem Pt Coord Operations Grp P = Primary TSC Coord OSC Coord Shift Supv Fire Brigade Maintenance Admin Servs S = Secondary Security Specialists Engineers SEC REC I&C Plant Operations P P P Emerg Direction & Control P Notification and Comm S P S S S Offsite Dose Assessment S P SP P Offsite Surveys S P P Onsite (Out-of-Plt) Surveys S P S P In-Plant Surveys S P S P P Chem-Radiochemistry S P P P Protective Action P P Recommendations Over-exposure Authorization P P Technical Support S P S P P Repair and Corrective Actions S S P P P P P S Radiation Protection S P P P Fire Fighting S P P S First-Aid S P P P P S S Search & Rescue P P S S P P S S Site Access Control S P Accountability S S P Logistics Support S P

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 24 of 149 The Shift Manager SHALL be relieved of the Emergency Director responsibilities when the designated Emergency Director arrives onsite.

The Plant Manager or Designee SHALL be the designated Emergency Director and will be available with a pager on a twenty-four (24) hour basis.

When the Plant Manager is unavailable, (e.g., out of town), the designated Emergency Director responsibility will be passed onto another Plant Manager designee who is a member of senior plant management. Specific personnel assignments to the Emergency Director position are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The Shift Manager SHALL start the tasks assigned to the Emergency Director, (e.g., notification, activating onsite centers, etc.). These tasks SHALL be accomplished promptly and cannot wait for the designated individual to arrive at the plant site.

The Emergency Directors responsibilities are as follows:

A. Activation of onsite emergency organization -

1. Direct the activation of the onsite emergency response centers and monitor their habitability, and

2. Coordinate response of the plant onsite emergency organization.

B. Personnel accountability - During a plant evacuation the Emergency Director SHALL account for all personnel onsite within thirty minutes of the Site Area or General Emergency requiring the evacuation so that a search for missing personnel can be conducted. A continuous personnel accountability SHALL be maintained throughout the emergency. This responsibility may be delegated to a designated individual with assistance from the security force.

C. Radiological monitoring - The Emergency Director SHALL direct radiological monitoring of all personnel onsite and at the onsite assembly area, for contamination and/or excessive exposure. This responsibility may be delegated to the Radiation Protection Specialists or to a qualified operations member.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 25 of 149 D. Exposure - The Emergency Director SHALL be responsible to authorize overexposures in excess of the normal limits (this responsibility may not be delegated).

E. Radiation Survey Teams - The Emergency Director SHALL direct the Radiation Survey Teams to obtain the necessary onsite and offsite samples and/or radiation surveys. This responsibility may be delegated to the Radiological Emergency Coordinator.

F. Offsite Dose Projections - The Emergency Director SHALL be responsible to project dose rates to the offsite population. This responsibility may be delegated to the Radiological Emergency Coordinator.

G. Protective Action - The Emergency Director SHALL be responsible for authorizing offsite Protective Action Recommendations (this responsibility may not be delegated and is relinquished to the Emergency Manager when the EOF is activated and operational).

H. Notification - The Emergency Director SHALL be responsible to ensure that the necessary offsite notifications are initiated and completed. This responsibility may be delegated to the Shift Emergency Communicator (SEC). The SEC may designate offsite communications to a qualified Communicator.

1. Immediate (within 15 minutes)

The initial notification message to State, local and tribal authorities, from the plant, SHALL contain the following information:

a Class of emergency b Whether radioactivity is being released and in what form (liquid or gas) c Potentially affected populace and area, if any d Necessity of protective measures e Brief description of the event Other information, i.e., meteorological data, etc., are available to these authorities via the follow-up notification messages.

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2. Subsequent Messages The plant will continue to provide updating information to offsite authorities. As soon as possible after the initial notification of an Alert, Site Area, or General Emergency, as much of the following information that is known and appropriate will be forwarded to offsite authorities:

a Location of incident b Name and telephone number of caller c Date/time of incident d Class of emergency e Type of release (airborne, liquid, surface spill) and estimated duration f Estimate of noble gas, iodine, and particulate release rates g Prevailing weather conditions (wind speed, wind direction, temperature, atmospheric stability class, precipitation, if any) h Actual or projected dose rates at site boundary i Projected dose rate and integrated dose at 2, 5 and 10 miles and the Sectors affected.

j Survey results of offsite dose rates or any surface contamination k Plant emergency response actions in progress l Request for onsite support from offsite support organizations m Prognosis for worsening or termination of event based on plant information To provide ease in supplying the aforementioned information, a standardized form is used and incorporated into the implementing procedures.

I. Protracted Emergency Shift Coverage - The Emergency Director, with assistance from and coordination with other group Managers and Supervisors, SHALL ensure that work force requirements for all subsequent work shifts are determined and the necessary personnel are scheduled for the specific time period.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 27 of 149 5.3.2 Plant Emergency Organization Coordinators A. Technical Support Center Coordinator The Technical Support Center (TSC) Coordinator SHALL be responsible for the general activation, operation and coordination of activities in the Technical Support Center (TSC). Specific personnel assignments to the TSC Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the TSC Coordinator are:

1. Establish and verify radiological monitoring for the TSC;

2. Assist personnel performing the accountability check;

3. Coordinate activities of plant and non-plant personnel located in the TSC;

4. Periodically update personnel located in the TSC with appropriate information;

5. Maintain any necessary status boards;

6. Ensure technical guidance is provided to the Emergency Director and Control Room Operators on plant operations;

7. Establish or ensure that communications are established between all onsite emergency facilities and the EOF.

8. Ensure the Emergency Response Data System data link is established with the NRCs emergency center.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 28 of 149 B. Operational Support Center Coordinator The Operational Support Center Coordinator SHALL be responsible for the general activation, operation, and coordination of activities in the Operational Support Center (OSC). Specific personnel assignments to the OSC Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the OSC Coordinator are:

1. Establish and verify radiological monitoring for the OSC and the Control Room;

2. Coordinate activities of plant personnel located in the OSC to support plant operations as requested by the Control Room and TSC.

3. Assist personnel performing the accountability check in the OSC and the Control Room.

4. Maintain the communication systems in the OSC. A person may be designated to act as a communicator.

5. Periodically update personnel located in the OSC with appropriate information.

6. Control the use of equipment located in the emergency locker.

C. Assembly Point Coordinator The Assembly Point Coordinator SHALL be responsible for the general operation of the assembly area. Specific personnel assignments to the Assembly Point Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the Assembly Point Coordinator are:

1. Verify that radiological monitoring has been established for the Assembly Point.

2. Coordinate activities of all personnel (plant and non-plant) located at the Assembly Point.

3. Assist the Emergency Director in performing the accountability check, as necessary.

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4. Maintain the communication systems. A person may be designated as the communicator, if necessary.

5. Control the use of equipment located in the Emergency Locker.

6. Update all personnel with appropriate information when directed by the Emergency Director.

7. Provide instructions to personnel when they are released from the assembly point for reentry or transport offsite.

D. Radiological Emergency Coordinator The Radiological Emergency Coordinator (REC) SHALL be responsible for radiological accident assessment, onsite and offsite.

The REC should report to the Technical Support Center when the TSC is activated. Upon activation of the EOF, the Radiation Protection Support Supervisor will assume responsibility for the offsite activities. The offsite survey teams will initially be comprised of individuals from the Prairie Island Plant. Upon activation of the EOF, the offsite survey teams will be comprised of individuals from the Monticello Nuclear Generating Plant. The REC should transfer the responsibility for offsite accident assessment to the Radiation Protection Support Supervisor at the EOF. Specific personnel assignments to the Radiological Emergency Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the REC are:

1. Offsite dose assessment

2. Formulating offsite protective action recommendations

3. Offsite surveys

4. Onsite surveys

5. Chemistry

6. Radiochemistry

7. Onsite Radiation Protection for:

a Access Control b Damage control and repair c Search and rescue d First-aid e Personnel monitoring and decontamination f Dosimetry

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E-PLAN EP EMERGENCY PLAN REV: XX Page 30 of 149 5.3.3 Plant Shift Organization The following groups comprise the plants shift organization. Brief descriptions of their emergency responsibilities are included.

A. Operations Group The Operations Group consists of the Operations Manager, Asst.

Operations Manager, Shift Managers, Shift Technical Advisors, Shift Supervisors, and all operators.

The Operations Group SHALL have responsibility for:

1. Plant Operations and assessment of operational aspects of the emergency.

2. Rad Waste equipment operation

3. Emergency radiation surveys

4. Short term damage control and repair for electrical, mechanical, and I&C equipment.

B. Security Group The Security Group consists of the Security Manager, the Security Staff, and the contract Security Force.

The Security Force SHALL:

1. Carry out the plant security and Access Control program.

2. Maintain strict personnel accountability onsite.

3. Assist communications efforts when necessary.

4. Assist in first aid treatment.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 31 of 149 C. Shift Manager The Shift Manager (SM) SHALL be onsite continuously. The Shift Manager SHALL assume overall coordination and control in the Control Room and provide direction as necessary to the Shift Supervisor.

The Shift Manager SHALL:

1. Assume the duties of the interim Emergency Director until relieved by the designated Emergency Director. Portions of the E-Plan implementation may be delegated to other members of the plant staff as the condition of the plant dictate.

2. Assess the emergency condition, event evaluation, and safety related aspects of the plant.

D. Shift Technical Advisors Provide technical and engineering support in the area of accident assessment.

E. Shift Emergency Communicator (SEC)

The Shift Emergency Communicator (SEC) SHALL be onsite continuously. The SEC is responsible for initial notification to the offsite agencies and maintaining communications during emergency conditions. The SEC may designate offsite communications to a qualified Communicator.

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1. When the EOF Organization is activated and the EOF is functional, communications with the offsite agencies and personnel will be maintained by the EOF personnel.

NOTE:

2. As the emergency organization is activated, additional communicators from TSC support personnel should augment the plant staff to assist in communication efforts.

F. Fire Brigade The Fire Brigade should consist of:

1. Brigade Chief - Unit 1 Turbine Building APEO or as designated by the Shift Manager.

2. Assistant Chief - Any Qualified APEO.

Usually the APEO from the affected building SHALL fulfill the NOTE: duties of the Brigade Chief in his absence.

3. Fire Fighters - BOP Operators.

4. Runner - As designated to accompany fire department, operate equipment, bring additional equipment to fire scene.

The Fire Brigade SHALL be responsible for firefighting and primary responders for Search and Rescue, as necessary.

The Red Wing Fire Department should provide emergency assistance and SHALL be called immediately on report of fire. Other plant personnel on site may be called on for emergency work or called to plant for emergency service.

G. Radiation Protection Specialist The Radiation Protection Organization consists of two three Radiation Protection Specialists (RPS) onsite at all times. The RPS is responsible for conducting routine and special surveys, maintaining Access Control, writing RWPs and providing job coverage as required. Qualified operations personnel on-shift are also trained to perform radiation surveys during emergency conditions.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 33 of 149 H. Chemistry Technician One Two Chemistry Technicians is are onsite at all times. The One Chemistry Technician is responsible for chemistry, and radiochemistry, dose assessments, and offsite dose projections. The second Chemistry Technician performs the dose assessment function until relieved by the augmented ERO. The Chemistry Technicians is are also cross-trained to support the Radiation Protection Specialist functions described in Section G above.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 34 of 149 5.3.4 Plant Emergency Staff Augmentation Groups A. Maintenance Group The Maintenance Group consists of all mechanical maintenance personnel, all plant electricians and I&C Specialists. The onsite Emergency Organization includes the Maintenance Manager, who should report to the Technical Support Center (TSC); and the Maintenance Supervisors (mechanical, electrical and I&C), and designated Electricians who should report to the Operational Support Center (OSC). The mechanical, electrical and I&C maintenance staff in the OSC can be further augmented or decreased as emergency conditions dictate.

The Mechanical, Electrical, and I&C Maintenance Group SHALL have responsibility for:

1. Supporting the repair and corrective actions for the mechanical, electrical, and I&C systems in support of emergency response and recovery actions.

2. Supporting the Search and Rescue effort.

B. Radiation Protection Group and Chemistry Group The Radiation Protection and Chemistry Groups consists of the Radiation Protection Manager & Chemistry Manager and all members of the Radiation Protection and Chemistry Groups. Radiation Protection and Chemistry Managers and other designated group members should report to the Technical Support Center. Other Radiation Protection Specialists and Chemistry Technicians should report to the Operational Support Center.

The responsibilities of the Radiation Protection and Chemistry Groups are:

1. Offsite Dose Assessment

2. Offsite Surveys

3. Onsite Surveys

4. Chemistry

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5. Radiochemistry

6. Radiation Protection for:

a Access Control b Damage control and repair c Search and rescue d First aid e Fire fighting f Personnel monitoring and decontamination g Dosimetry C. Engineering Group The Engineering Group consists of Systems, Programs, Design and Equipment Reliability.

Upon activation of the onsite emergency organization, Systems and Programs Engineering Managers and designated engineers assigned to the emergency organization should report to the Technical Support Center. Other designated engineers may be requested to further augment engineering support in the TSC.

The Engineering Group SHALL have responsibility for:

1. Providing technical support for plant system engineering on electrical/mechanical systems.

2. Providing technical support for operating radioactive waste control systems.

3. Providing core parameter analysis to determine current core status.

4. Providing plant parameter trending and analysis utilizing the Emergency Response Computer System (ERCS).

5. Projecting possible loss of key equipment and its consequences.

6. Providing technical support for emergency repairs and corrective actions on electrical/mechanical systems.

7. Update TSC staff of potential problems and developments.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 36 of 149 D. Logistics Support Group The Logistics Support Group consists of Business Support Group (Administration Services and Document Control), Plant Services, and Site Materials.

Business Support Group SHALL supply logistical support in their area of expertise. Personnel in these areas may be called in to provide support for emergency response on an as needed basis.

Site Materials SHALL provide assistance in retrieving the parts necessary for an emergency response.

Plant Services SHALL support an emergency response by providing necessary assistance by the Nuclear Plant Service Attendants.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 37 of 149 5.4 EOF Organization The EOF (Emergency Operations Facility) Organization consists of a Direction and Control Group and three subordinate groups. The EOF Organization is staffed by personnel from the sites Engineering and Project Management groups and Prairie Island Training Center staff. The Prairie Island EOF Organization is shown in Figure 2.

The EOF should be staffed and ready to assume its emergency responsibilities from the TSC within about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of notification90 minutes of Classification of an ALERT or higher. Transfer of these responsibilities from the TSC to the EOF will be coordinated between the TSC and EOF and depend on the status of the TSCs emergency response. Actual transfer of offsite emergency response responsibilities to the EOF should occur within 60 to 90 minutes of notification.

5.4.1 EOF Direction and Control The Emergency Manager is responsible for overall direction and control of NSPMs emergency response effort. Designated members of management staff the Emergency Manager position in the EOF. Specific personnel assignments to the Emergency Manager position are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory. The Emergency Manager relieves the Emergency Director of the following responsibilities:

A. Off-site dose projections and coordination and direction of the utility off-site radiological monitoring teams.

B. Authorization of emergency classification changes. The Emergency Director retains the primary responsibility for re-classifications and makes recommendations to the Emergency Manager who has the responsibility to review and authorize the new classification.

C. Authorization of offsite Protective Action Recommendations.

D. Communications with off-site authorities including Federal, State, Local and Tribal authorities and MT & PI Offsite executive management located at the Minnesota State Emergency Operations Center.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 38 of 149 Figure 2 Prairie Island EOF Organization

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E-PLAN EP EMERGENCY PLAN REV: XX Page 39 of 149 Other responsibilities of the Emergency Manager include:

A. Coordinate the emergency response efforts of other offsite support personnel assisting the plant organization.

B. Obtain and coordinate the services of outside consultants and vendors.

C. Advise utility management on matters related to emergency response efforts and needed resources to support the effort.

5.4.2 EOF Technical Support Group The EOF Technical Support Group consists of select personnel from the sites Engineering and Project Management groups and Training Center staff. The Technical Support Supervisor is staffed by senior personnel and reports to the Emergency Manager. The Technical Support Group is responsible for trending critical parameters, engineering evaluation in support of the TSC Engineering Group, technical assessment and advising the Emergency Manager on technical matters related to the event.

5.4.3 EOF Radiation Protection Support Group The EOF Radiation Protection Support Group is staffed by select personnel from the Training Center, plant Radiation Protection and Chemistry Groups and Emergency Plan Group. The Radiation Protection Support Supervisor position is staffed by senior personnel qualified in radiation assessment and reports to the Emergency Manager. The Radiation Protection Support Group includes plant Chemistry personnel for off-site dose projection and EOF Count Room operation and Nuclear Plant Service Attendants who function as sample couriers and drivers for off-site radiological monitoring teams. Radiation Protection Support Group responsibilities include:

A. Direction and coordination of the utility off-site radiological monitoring teams.

B. Off-site dose projection.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 40 of 149 C. EOF Count Room activation and operation.

D. EOF habitability, personnel monitoring and decontamination (as necessary).

E. Communications with state assessment groups on matters related to dose projections and off-site protective action recommendations.

F. Staffing the Health Physics Network (HPN) and communications with the NRC (as necessary).

The Radiation Protection Support Supervisor advises the Emergency Manager on matters related to actual or potential radiological impact on the environment, off-site protective action recommendations, and EOF habitability.

5.4.4 EOF General Support Staff The EOF General Support Staff consists of the EOF Coordinator, emergency communicators, administrative and security support personnel.

The EOF Coordinator position is staffed by senior Training Center or site Engineering and Project Management personnel and reports to the Emergency Manager. The EOF Coordinator is responsible for activation and operation of the EOF and assists the Emergency Manager with administrative duties. The emergency communicators, EOF Security Coordinator and Administrative Staff report to the EOF Coordinator. The emergency communicators are responsible for communications with offsite agencies as directed by the Emergency Manager. The Administrative Staff is responsible for emergency document control, recording and document distribution at the EOF. An EOF Coordinator Assistant is responsible for general logistics support and assisting the EOF Coordinator. The EOF Security Coordinator reports to the EOF Coordinator. Responsibilities of EOF Security include EOF access and dosimetry issuance to EOF personnel.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 41 of 149 5.5 Recovery Organization The establishment of the Recovery Organization will be dependent upon the nature and severity of the event or plant conditions. In general terms, an Unusual Event or Alert may be terminated without establishing a special Recovery Organization while a Site Area Emergency or General Emergency will probably necessitate the establishment of a Recovery Organization. The Recovery Organization will manage the overall recovery or post-accident outage plans as work is done to return the plant to a normal operational or shutdown status.

The Recovery Manager is mainly responsible for management of the recovery phase and will perform their initial tasks as directed by the Emergency Manager.

The Recovery Manager will report to the Emergency Operations Facility and begin to prepare for the transition to Recovery, as necessary. If Recovery is imminent, the Recovery Manager will establish a recovery or post-accident outage organization following the sites plant event recovery protocols.

5.6 Augmentation of Plant and EOF Emergency Organizations 5.6.1 Offsite Support Response The emergency response plan for Prairie Island NGP is designed to be initially implemented independent of any offsite support. However, the onsite effort will be augmented with offsite support resources as described in the MT & PI Offsite Nuclear Emergency Plan.

It is the purpose of the offsite support organization to augment the onsite response effort with offsite support resources as soon as practical and as needed by the Prairie Island Site staff. Such areas of support include:

Government Agency Interface, Logistics Support, News Media Interface and Utility Executive Management Interface.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 42 of 149 5.6.2 Monticello Radiation Protection Group Support The Monticello Nuclear Generating Plant is located approximately 100 miles northwest of Prairie Island NGP. The Monticello Radiation Protection and Chemistry Groups are available for supporting the Prairie Island Radiation Protection Group with personnel and equipment during any emergency condition at Prairie Island. Designated individuals from the Monticello plant would arrive at Prairie Island in approximately two to three hours with all the equipment necessary to assume responsibility for offsite monitoring. The Prairie Island Radiation Protection Group may then dedicate their activities to onsite responsibilities. The Monticello Radiation Survey Teams will be under the control of the Radiation Protection Support Supervisor (RPSS), as directed by the Emergency Manager, as soon as the EOF has been activated.

5.6.3 Westinghouse Support Westinghouse emergency assistance is available on a twenty-four hour per day, seven day per week basis. Westinghouse will activate all appropriate features of the Westinghouse Emergency Response Plan to support the plant needs. When activated, the Westinghouse Emergency Response Plan becomes a functioning organization, comprised of individuals with unique technical, managerial and communication skills and experience, necessary to:

A. Make an early assessment of the situation B. Provide early assistance to the utility C. Mobilize appropriate Westinghouse critical skills and functions D. Initiate timely, accurate communications to involved and interested parties A Site Response Team may be dispatched to the site to obtain a first hand assessment of actual conditions and establish communications from the site to the Westinghouse response center, as deemed necessary.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 43 of 149 5.6.4 Local Support Services A. Fire Fighting The Red Wing Fire Department will provide assistance in the event of a fire occurring at the plant. The duties and responsibilities of the Plant Fire Brigade, insuring complete coordination with the Fire Department, are covered in the Operations Manual, Section F5, Fire Fighting.

B. Hospital and Medical Support Medical support and treatment for non-radiological injuries is provided by the Mayo Clinic Health System, both of which are located in Red Wing, Minnesota. Radiological related injuries are treated at the medical center which is the primary treatment facility. Emergency plans have been prepared, and training of medical center personnel is accomplished on an annual basis.

Regions Hospital in St. Paul, Minnesota is designated as the definitive care center for Prairie Island Nuclear Generating Plant.

Regions Hospital may be used for radiation casualties, severe burn casualties, and other non-radiation injuries with use of an appropriate medical air transport service.

C. Ambulance Service The Red Wing Ambulance Service will provide service to the Prairie Island Nuclear Generating Plant. Training and participation in drills ensures that personnel involved in the transportation of radiation victims are knowledgeable in use of proper procedures and handling methods. Procedures are covered in the Operations Manual, Section F4, Medical Support and Casualty Care.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 44 of 149 5.7 Coordination with Governmental Response Organizations 5.7.1 Minnesota Division of Homeland Security and Emergency Management (HSEM)

The Minnesota Division of Homeland Security and Emergency Management has the responsibility for notification and coordination of Minnesota State Agencies in the event of a major emergency at Prairie Island.

The MN HSEM is notified by Prairie Island NGP. In the event of an emergency situation at the plant, the MN duty officer will immediately call the MN Department of Health, the Governors Authorized Representative and other state agencies with emergency assignments to coordinate the implementation of any emergency procedures. The state agencies responsible for emergency procedures have established a system of twenty-four hour communications.

5.7.2 Minnesota Department of Health (MDH)

The Minnesota Department of Health (MDH) is responsible for providing radiological expertise in the State Emergency Operations Center in conjunction with the MN HSEM.

The Minnesota Department of Health will interpret data and participate in recommending protective actions to the Governors Authorized Representative.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 45 of 149 5.7.3 Wisconsin Emergency Management The Wisconsin Emergency Management (WEM), has the responsibility for notification and coordination of Wisconsin state agencies in the event of a major emergency at Prairie Island NGP.

In the event of an emergency situation at the plant, Prairie Island NGP will notify the WEM duty officer who will notify the Wisconsin Department of Health Services (Radiation Protection Section) and other state agencies with emergency assignments, to coordinate the implementation of any emergency procedures. The state agencies responsible for emergency procedures have established a system of twenty-four hour communications.

5.7.4 Wisconsin Department of Health Services (DHS)

The Wisconsin Department of Health Services (DHS) is responsible to prevent exposure to ionizing radiation in amounts which are detrimental to health according to nationally accepted standards.

The Wisconsin DHS, Radiation Protection Section, is responsible for coordination of radiation response activities in the State of Wisconsin. In the event of an emergency at Prairie Island NGP, DHS, Radiation Protection Section will be concerned with monitoring the air and water about the plant to assure that the public is not exposed to levels of radioactive pollutants potentially detrimental to public health. DHSs facilities are located in Madison, Wisconsin.

Due to the distance and time required for the Wisconsin Radiation Protection Response Team to arrive at the affected area, the State of Minnesota Department of Health, will provide mutual support to Wisconsin, as spelled out in the letter of agreement in the Wisconsin State emergency operations plan.

5.7.5 Goodhue, Dakota and Pierce County Sheriffs The Sheriffs Departments will notify all necessary local civil support groups in the event of an accident. The Sheriff is responsible for protection of the general public and can provide personnel and equipment for evacuation, relocation and isolation.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 46 of 149 5.7.6 Goodhue, Dakota, Pierce County and City of Red Wing Emergency Management The Goodhue, Dakota, Pierce County and City of Red Wing Emergency Management Organizations have the responsibility for notification and providing direction to residents in the event of a major emergency that affects their respective area of responsibility.

5.7.7 Prairie Island Indian Community The Prairie Island Indian Community has an Emergency Operations Plan that includes the description of tribal responsibilities during a nuclear plant declared event. The Prairie Island Nuclear Generation Plant conducts emergency notifications to the Treasure Island Casino security dispatch center who, in turn, notifies appropriate members of the Prairie Island Indian Community and their organization.

5.7.8 Minnesota State Patrol The Minnesota (MN) State Patrol has the responsibility to protect the general public by providing personnel and equipment to re-route traffic in the event of an emergency situation. Plans have been made for re-routing federal and state highways. Signs and equipment required for re-routing will be stored in the areas where they would be needed to facilitate highway closings. The MN Department of Transportation would be notified by the MN State Patrol to erect the signs.

5.7.9 Minnesota Department of Transportation The MN Department of Transportation will assist the MN State Patrol in blocking and re-routing traffic around the plant site. In addition to the necessary personnel; vehicles, signals, and barriers for setting up and maintaining detour routes are available.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 47 of 149 5.7.10 Canadian Pacific Railway-CP Railway (Soo Line)

In an emergency situation, CP Rail will make every reasonable effort to expedite unblocking the road/railroad crossing near Prairie Island NGP.

The dispatcher will also provide routing assistance during an emergency at Prairie Island NGP.

5.7.11 Burlington Northern Santa Fe (BNSF) Railway The dispatcher will provide routing assistance during an emergency at Prairie Island NGP as per the Minnesota State emergency operations plan.

5.7.12 Department of the Army, Corps of Engineers, Lock & Dam #3 The Corps of Engineers at Lock & Dam #3 will be notified by the Minnesota Duty Officer of an emergency at Prairie Island NGP. The Lock and Dam personnel will notify all tows within radio range of impending evacuations and assist in evacuation of personnel at the Lock and Dam.

A complete description of response capabilities, organizational resources, activation plans, designations of NOTE: emergency operations centers and letters of agreement are available in Minnesota and Wisconsins state emergency operations plans.

5.7.13 Nuclear Regulatory Commission (NRC)

The basic responsibilities of the NRC are to monitor, assess, and, if necessary, direct the utility to take actions to protect the health and safety of the public. For a radiological incident at a commercial power plant, the NRC is the Lead Federal Agency (LFA). The LFA is responsible for coordinating all Federal onscene actions. The NRC will coordinate Federal assistance to States and local organizations.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 48 of 149 A principal role of the LFA is to assist the State in interpretation and analysis of technical information as a basis for making decisions about protective actions. This assistance will begin early in an incident from the NRC Operations Center in Rockville, MD, and later, from the utilitys emergency operations facility on scene. The NRC is an independent reviewer of the actions the utility is taking to correct the initiating and related problems. The NRC will assess actual or potential offsite impacts as well, and will make an independent evaluation of Protective Action Recommendations, if necessary. As the LFA, the NRC has the responsibility for coordinating the release of Federal information to the media and others. The NRC will conduct most public information activities from the utilitys Joint Information Center (JIC). The NRC also will keep the White House and Congress informed on all aspects of the event.

The NRC is responsible for giving the best possible advice at a given time to the States and will not limit its involvement to presenting a series of options.

The NRC also administers the Price-Anderson Act to ensure that the public that is affected by the event has adequate financial assistance to address most emergency needs.

5.7.14 Department of Energy (DOE)

Among its responsibilities as a support agency, DOE will coordinate the offsite radiological monitoring and assessment for the Lead Federal Agency (LFA) and the State during the initial phases of the emergency. It will maintain a common set of offsite radiological data and provide an appropriate interpretation of the data to the LFA and the State. DOE will manage the Federal Radiological Monitoring and Assessment Center (FRMAC), which is a multi-agency facility. DOE will conduct environmental monitoring, including air, ground, and water.

Their immediate objective is to rapidly dispatch a Radiological Assistant Program (RAP) Team to the scene to assess the hazard to the public and make recommendations to the authorities for the protection of the public.

The Planning Chief in the State EOC is the designated Minnesota authority to request RAP assistance, as stated in the Minnesota state plan, and the Wisconsin DH, Radiation Section, is the designated Wisconsin authority to request RAP assistance for Wisconsin, as stated in the Wisconsin state plan.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 64 of 149 6.4.2 Radiological Surveys The Radiation Protection Group SHALL be responsible for all radiological surveys and personnel monitoring both onsite and offsite. The non-licensed operators of the Operations Group are also trained to conduct post-accident in-plant surveys during the first hour of the emergency. The Emergency Director has the responsibility for directing all radiation safety during the emergency.

The Radiation Protection Specialists may be divided into three emergency Radiation Survey Teams. Two teams are assigned offsite duties such as radiation surveys, air samples, or liquid sampling. The two offsite survey teams will conduct a search for the plume and obtain dose rates, and iodine, particulate or gaseous samples at pre-designated sample locations.

Plume exposure pathway maps with pre-designated sample locations are contained in the emergency survey kits. The third team is assigned duties onsite such as radiation surveys, sampling (airborne or liquid) and sample analysis using the equipment available onsite and/or the EOF Count Room facility. Silver zeolite adsorbers are used to collect airborne iodine samples, both onsite and offsite. Silver zeolite adsorbers eliminate the problem of entrapped noble gases on the iodine adsorber, allowing a much lower detection sensitivity. Iodine samples may be analyzed in the EOF Counting Room.

The Radiation Survey Teams are activated via the ERO Auto Dial System and/or the ERO Pager Network or the telephone system. If the emergency occurs during normal working hours, the teams will be activated and respond within 10 minutes. If the emergency occurs during off hours, the The teams will be activated and respond within thirty ninety (3090) minutes of declaration. Designated Emergency Lockers contain emergency survey kits, which include portable instruments, battery operated air samplers, liquid sampling equipment, and communication equipment.

After the initial offsite surveys are completed, the teams assigned offsite duties may be relieved by Monticello Radiation Protection Specialists who will continue to perform any offsite surveys assigned by the Emergency Manager. The Prairie Island Survey Team members may concentrate their efforts and resources to onsite responsibilities.

ENCLOSURE 1, ATTACHMENT 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT LICENSE AMENDMENT REQUEST License Amendment Request (LAR) for Revision to Staff Augmentation Times in the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plan (EP)

CLEAN COPY PAGES OF EMERGENCY PLAN SECTIONS 1.0, 2.0, 5.0 AND 6.4.2 (38 pages follow)

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 7 of 149 1.0 DEFINITIONS Listed below are some terms in this plan along with the definitions that should be applied to these terms when they are used in this plan.

1.1 Assessment Action - Actions taken during or after an accident to obtain and process information necessary to make decisions regarding emergency measures.

1.2 Corrective Actions - Emergency measures taken to terminate an emergency situation at or near the source in order to prevent or minimize a radioactive release, e.g., shutting down equipment, firefighting, repair and damage control, etc.

1.3 Emergency Action Level (EAL) - A predetermined, site-specific, observable threshold for a plant Initiating Condition (IC) that places the plant in a given emergency class. An EAL can be: an instrument reading; an equipment status indicator; a measurable parameter (onsite or offsite); a discrete, observable event; results of analyses; entry into specific emergency operating procedures; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.

1.4 Emergency Class: - One of a minimum set of names or titles, established by the Nuclear Regulatory Commission (NRC), for grouping of normal nuclear power plant conditions according to (1) their relative radiological seriousness, and (2) the time sensitive onsite and off site radiological emergency preparedness actions necessary to respond to such conditions. The existing radiological emergency classes, in ascending order of seriousness, are called: Notification of Unusual Event (UE), Alert, Site Area Emergency (SAE), and General Emergency (GE).

1.5 Emergency Director (ED) - The Plant Manager or designee. This individual has overall responsibility and authority for managing the emergency effort within the plant. This person will also manage efforts external to the plant until the Emergency Operations Facility (EOF) Organization can relieve the ED of external tasks.

1.6 Emergency Manager (EM) - A designated member of site management. This person has the authority and responsibility for the management of (NSPM) Northern States Power Company - Minnesota overall response to an emergency. The EM will assume command and control at the Emergency Operations Facility and direct the NSPM response efforts.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 8 of 149 1.7 Emergency Planning Zones - a defined area around the plant to facilitate emergency planning by state and local authorities, to assure that prompt and effective actions are taken to protect the public in the event of a release of radioactive material. It is defined for:

1.7.1 Plume Exposure Pathway - a 10 mile radius around the plant where the principal exposure source is: (1) whole body exposure to gamma radiation from the plume and from deposited material; and (2) internal exposure from the inhaled radionuclides deposited in the body (Short Term Exposure).

1.7.2 Ingestion Exposure Pathway - a 50 mile radius around the plant where the principal exposure would be from the ingestion of contaminated water or foods such as milk or fresh vegetables (Long Term Exposure). The ingestion exposure pathway includes the plume exposure pathway.

1.8 Emergency Worker - Any individual involved in mitigating the consequences of an emergency situation and/or minimizing or preventing exposure to the offsite population. The emergency worker category includes emergency workers at the plant as well as individuals who are engaged in public service emergency activities -

firemen, policemen, medical support, and certain public officials. These are people who voluntarily place themselves as emergency workers.

1.9 Exclusion Area - The area surrounding the plant that is under direct Prairie Island Nuclear Generating Plant control. This includes the Corps of Engineering land north of plant and the islands located in the Mississippi River east of plant. It is sized such that any individual located on its boundary would not exceed 25 REM whole body or 300 REM thyroid from I-131 for two hours immediately following the design basis accident (approximately 2340 feet out to boundary).

1.10 Facility Activation - An Emergency Response Facility is activated when the minimum staff per Table 1 is available and the facility is ready to assume its assigned functions under the Emergency Plan and relieve the on-shift staff of those functions. (Although the facility may be ready, the on-shift relief may be postponed in the interest of completing critical tasks prior to turnover.)

1.11 Initiating Condition (IC): - One of a predetermined subset of nuclear power plant conditions when either the potential exists for a radiological emergency, or such an emergency has occurred.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 9 of 149 1.12 Northern States Power Company - Minnesota (NSPM) d/b/a Xcel Energy -

Operator of the Prairie Island Nuclear Generating Plant.

1.13 Protective Actions - Emergency measures taken before or after a release of radioactive materials in order to prevent or minimize radiological exposures to the population.

1.14 Protective Action Guides (PAG) - Projected dose to individuals, that warrants protective action prior to and/or following a radioactive release.

1.15 Recovery Actions - Actions taken after an emergency to restore the plant to normal.

1.16 Xcel Energy - Operating Utility of Northern States Power Company - Minnesota.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 10 of 149 2.0 SCOPE AND PURPOSE In accordance with license conditions, 10CFR Part 50, and NRC guidance, the Northern States Power Company - Minnesota (NSPM) has developed and implemented a radiological emergency response plan for the Prairie Island Nuclear Generating Plant (PINGP) and a joint off-site plan for the PINGP and the Monticello Nuclear Generating Plant. As asset owner NSPM, and Xcel Energy, the operating utility, retain all owner obligations.

This Emergency Plan is applicable to Prairie Island Nuclear Generating Plant (PINGP),

Units 1 and 2.

In any emergency situation at Prairie Island, the initial response to activate the Emergency Plan is accomplished by the plant staff and, if needed, immediate actions may be required by local support agencies. The plant, during initial stages of the emergency situation, must function independently coordinating both onsite and offsite activities. It is expected that within approximately 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, the plant staff will be augmented by other segments of the overall Monticello & Prairie Island (MT & PI) Offsite Emergency Response Organization (EOF staff, Monticello Field Teams and other company support staff). The augmented response organization will assume those tasks external (offsite) to the plant, thus allowing the plant staff to be responsible for all onsite activities. This plan covers the actions and responsibilities of the PINGP Emergency Organization and the Emergency Operations Facility Organization.

The purpose of the plan is to describe the following:

2.1 Organization and actions within the plant to control and limit the consequences of an accident.

2.2 Organization and actions controlling site and offsite activities in the event of an uncontrolled release of radioactive material. This includes notification of and coordination with required offsite support agencies.

2.3 Identifying and evaluating the consequences of accidents that may occur and affect the public and plant personnel.

2.4 Describing the protective action levels and actions that are required to protect the public and plant personnel in the event of an accident.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 11 of 149 2.5 Consideration necessary for the purpose of reentry and short-term recovery.

2.6 Arrangements required for medical support in the event of injury.

2.7 Arrangements required for fire fighting support in the event of major fires requiring outside support.

2.8 The training necessary to assure adequate response to emergencies.

The Emergency Plan is dependent upon various standing plant operating, abnormal operating, emergency operating, plant safety, radiological control and security procedures and the Emergency Plan Implementing Procedures for the implementation of the plants response to the spectrum of emergency situations.

PINGP has procedures in place that implement on-site protective actions and personnel accountability during security events that are appropriate for plant and environmental conditions.

Coordination between plant, state, local and tribal authorities is defined in the Minnesota and Wisconsin state emergency operations plans, Goodhue, Dakota and Pierce county emergency plans and the Prairie Island Indian Communitys emergency plan. Goodhue, Dakota and Pierce Counties have, formulated for their respective areas, individual evacuation plans which are included in the respective state plans.

Monticello & Prairie Island (MT & PI) offsite response is detailed in the Corporate Nuclear Emergency Plan.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 17 of 149 5.0 ORGANIZATIONAL CONTROL OF EMERGENCIES 5.1 Normal Site Organization The normal site organization is comprised of the plant organization and several other site support organizations. The normal site organization can be accessed on the Prairie Island web page. Responsibilities and authorities of the various functional groups are delineated in plant Administrative Work Instructions.

5.2 Normal Plant Organization The normal plant operating crew is staffed and qualified to perform all actions that may be necessary to initiate immediate protective actions and to implement the emergency plan and is designated as the responsible group for such actions. The normal plant organization can be accessed on the Prairie Island web page.

The Plant Manager has overall responsibility for the safe, efficient operation of the plant and for compliance with operating license requirements. The Plant Manager SHALL select, train and supervise a qualified staff.

The Shift Manager reports directly to the Assistant Operations Manager who reports directly to the Operations Manager who reports directly to the Plant Manager. The Shift Manager is responsible for the direction and coordination of the Shift Supervisors on his/her shift to perform operations in accordance with the administrative controls and operating procedures. The Shift Manager coordinates activities with other plant groups as required to maintain the safe operation of the plant.

The Shift Supervisor reports to the Shift Manager. The Shift Supervisor is the single focal point for directing and coordinating the operations group, maintenance group and the plant security activities during his/her shift. The Shift Supervisor SHALL assume the primary management responsibility for the safe operation of the plant under all conditions during his/her shift. The responsibility and authority of the Shift Supervisor SHALL be to maintain the broadest perspective of operational conditions affecting the safety of the plant as a matter of highest priority at all times when on duty in the Control Room.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 18 of 149 5.3 Plant Emergency Organization A plant emergency organization is designated to augment the normal operating crew. Provisions have been made for rapid assignment of plant personnel to the plant emergency organization during emergency situations. The Prairie Island Plant Emergency Organization is shown in Figure 1.

Various areas of responsibility are assigned to segments of the plant staff during emergency situations as depicted in Table 1 and Table 2. Table 1 shows the personnel available on-shift and the capability for additional personnel to augment the on-shift staff within 90 minutes. Augmentation will be measured from the time of Declaration to Facility Activation.

5.3.1 Direction and Coordination During the initial stages of an emergency condition at Prairie Island Nuclear Generating Plant, the Emergency Director has overall coordinating authority for Northern States Power Company - Minnesota (NSPM). The Emergency Director alone has the authority and responsibility to immediately initiate any emergency actions, including providing protective action recommendations to offsite authorities responsible for implementing offsite emergency measures.

When the Emergency Operations Facility (EOF) Organization is activated, the Emergency Manager (EM) and EOF staff will relieve the Emergency Director of all offsite responsibilities as soon as practical and assume the responsibility for the management of NSPMs overall response to the emergency. The Emergency Director can then direct the plants efforts towards management of the onsite responsibilities.

The Shift Supervisor, of the affected unit, until properly relieved, SHALL remain in the Control Room at all times during accident situations, to direct the activities of control room operators.

Twenty-four (24) hour coverage for the Emergency Director position is provided by the Duty Shift Manager who assumes the responsibility of the interim Emergency Director at the onset of any emergency condition. If necessary, the Shift Supervisor of the unaffected unit may function as an alternate Emergency Director backing up the Shift Manager.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 19 of 149 Figure 1 Prairie Island Plant Emergency Organization EMERGENCY EMERGENCY DIRECTOR MANAGER (IN EOF)

SHIFT EMERGENCY ASSEMBLY POINT COMMUNICATOR COORDINATOR OPERATIONAL TECHNICAL RADIOLOGICAL SECURITY WORK MANAGEMENT OPERATIONS SUPPORT CENTER SUPPORT CENTER EMERGENCY GROUP LEADER LEADER GROUP LEADER COORDINATOR COORDINATOR COORDINATOR ENGINEERING CHEMISTRY &

OPERATIONS GROUP LEADER HEALTH PHYSICS SECURITY FORCE GROUP SUPPORT ENGINEERING SUPPORT MAINTENANCE LOGISTICS GROUP LEADER SUPPORT LEADER ELECTRICAL MECHANICAL MAINTENANCE MAINTENANCE I&C GROUP

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 20 of 149 Table 1 Guidance for Augmentation of Plant Emergency Organization Capability for Additions Major Functional Area Major Tasks Position Title or Expertise On-Shift 90 min Plant Operations and Shift Manager/ED 1 Shift Supervisor (SRO): Unit Supervisors 2 -

Assessment of Control Room Reactor Operational Aspects Reactor Operators (RO): 4 -

Auxiliary Operators: 6 -

Notification/ Notify State, local Shift Emergency Communication and Federal Communicator: 1 3 personnel &

maintain communication Radiological Accident Emergency Operations Emergency Manager Assessment and Facility (EOF) (as per duty roster): - 1 Support of Director Operational Accident Assessment Offsite Dose Chemistry Technician /

Assessment Radiological 1 1 Emergency Coordinator (REC):

Offsite Surveys Radiation Protection Specialist: - 4 (2)

Onsite Surveys Radiation Protection Specialist: 1 1 (out-of-plant)

In-plant Surveys Plant Operators and/or Radiation Protection Specialist: 2 (1,3) 1

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 21 of 149 Table 1 Guidance for Augmentation of Plant Emergency Organization Capability for Additions Major Functional Area Major Tasks Position Title or Expertise On-Shift 90 min Chemistry/

Radiochemistry Chemistry Technician: 1 1 Plant System Technical Support Shift Technical Advisor 1 -

Engineering, Core/Thermal: - 1 Repair and Electrical: - 1 Corrective Actions Mechanical: - 1 Repairs and Mechanical Maintenance: - 1 Corrective Actions Rad Waste Operator: - 1 Electrical Maintenance: - 2 Instrument Control: - 1 Protective Actions Radiation Radiation Protection Specialist - 3 (In-Plant) Protection: and/or Plant Operators: - -

a. Access Control

b. HP Coverage for repair, corrective actions, search and rescue, first-aid &

firefighting

c. Personnel monitoring

d. Dosimetry

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 22 of 149 Table 1 Guidance for Augmentation of Plant Emergency Organization Capability for Additions Major Functional Area Major Tasks Position Title or Expertise On-Shift 90 min Fire Fighting Fire Brigade Local Support per F5 Rescue Operations and First Aid 2(1) Local Support Site Access Control Security, firefighting Security Personnel: As per and Personnel communications, Security Accountability personnel Plan accountability TOTAL 20 23 (1)

May be provided by shift personnel assigned other functions.

(2)

Monticello RPG will arrive within approximately 2-3 hours to augment and relieve the Prairie Island RPG of offsite surveys.

(3)

Chemistry Technicians are cross-trained in Radiation Protection and chemistry/radiochemistry. The non-licensed plant operators are fully trained to conduct post-accident in-plant surveys.

The above table was developed in accordance with 10 CFR 50 Appendix E. This staffing analysis is documented in F3-1.1, Emergency Plan On-Shift Staffing Analysis.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 23 of 149 Table 2 Primary and Secondary Responsibilities of Plant Emergency Organization Shift Technical Advisor Chemistry Technician Radiation Protection Emerg Director Assem Pt Coord Operations Grp P = Primary TSC Coord OSC Coord Shift Supv Fire Brigade Maintenance Admin Servs S = Secondary Security Specialists Engineers SEC REC I&C Plant Operations P P P Emerg Direction & Control P Notification and Comm S P S S S Offsite Dose Assessment S P P P Offsite Surveys S P P Onsite (Out-of-Plt) Surveys S P S P In-Plant Surveys S P S P P Chem-Radiochemistry S P P P Protective Action P P Recommendations Over-exposure Authorization P P Technical Support S P S P P Repair and Corrective Actions S S P P P P P S Radiation Protection S P P P Fire Fighting S P P S First-Aid S P P P P S S Search & Rescue P P S S P P S S Site Access Control S P Accountability S S P Logistics Support S P

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 24 of 149 The Shift Manager SHALL be relieved of the Emergency Director responsibilities when the designated Emergency Director arrives onsite.

The Plant Manager or Designee SHALL be the designated Emergency Director and will be available with a pager on a twenty-four (24) hour basis.

When the Plant Manager is unavailable, (e.g., out of town), the designated Emergency Director responsibility will be passed onto another Plant Manager designee who is a member of senior plant management. Specific personnel assignments to the Emergency Director position are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The Shift Manager SHALL start the tasks assigned to the Emergency Director, (e.g., notification, activating onsite centers, etc.). These tasks SHALL be accomplished promptly and cannot wait for the designated individual to arrive at the plant site.

The Emergency Directors responsibilities are as follows:

A. Activation of onsite emergency organization -

1. Direct the activation of the onsite emergency response centers and monitor their habitability, and

2. Coordinate response of the plant onsite emergency organization.

B. Personnel accountability - During a plant evacuation the Emergency Director SHALL account for all personnel onsite within thirty minutes of the Site Area or General Emergency requiring the evacuation so that a search for missing personnel can be conducted. A continuous personnel accountability SHALL be maintained throughout the emergency. This responsibility may be delegated to a designated individual with assistance from the security force.

C. Radiological monitoring - The Emergency Director SHALL direct radiological monitoring of all personnel onsite and at the onsite assembly area, for contamination and/or excessive exposure. This responsibility may be delegated to the Radiation Protection Specialists or to a qualified operations member.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 25 of 149 D. Exposure - The Emergency Director SHALL be responsible to authorize overexposures in excess of the normal limits (this responsibility may not be delegated).

E. Radiation Survey Teams - The Emergency Director SHALL direct the Radiation Survey Teams to obtain the necessary onsite and offsite samples and/or radiation surveys. This responsibility may be delegated to the Radiological Emergency Coordinator.

F. Offsite Dose Projections - The Emergency Director SHALL be responsible to project dose rates to the offsite population. This responsibility may be delegated to the Radiological Emergency Coordinator.

G. Protective Action - The Emergency Director SHALL be responsible for authorizing offsite Protective Action Recommendations (this responsibility may not be delegated and is relinquished to the Emergency Manager when the EOF is activated and operational).

H. Notification - The Emergency Director SHALL be responsible to ensure that the necessary offsite notifications are initiated and completed. This responsibility may be delegated to the Shift Emergency Communicator (SEC). The SEC may designate offsite communications to a qualified Communicator.

1. Immediate (within 15 minutes)

The initial notification message to State, local and tribal authorities, from the plant, SHALL contain the following information:

a Class of emergency b Whether radioactivity is being released and in what form (liquid or gas) c Potentially affected populace and area, if any d Necessity of protective measures e Brief description of the event Other information, i.e., meteorological data, etc., are available to these authorities via the follow-up notification messages.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 26 of 149

2. Subsequent Messages The plant will continue to provide updating information to offsite authorities. As soon as possible after the initial notification of an Alert, Site Area, or General Emergency, as much of the following information that is known and appropriate will be forwarded to offsite authorities:

a Location of incident b Name and telephone number of caller c Date/time of incident d Class of emergency e Type of release (airborne, liquid, surface spill) and estimated duration f Estimate of noble gas, iodine, and particulate release rates g Prevailing weather conditions (wind speed, wind direction, temperature, atmospheric stability class, precipitation, if any) h Actual or projected dose rates at site boundary i Projected dose rate and integrated dose at 2, 5 and 10 miles and the Sectors affected.

j Survey results of offsite dose rates or any surface contamination k Plant emergency response actions in progress l Request for onsite support from offsite support organizations m Prognosis for worsening or termination of event based on plant information To provide ease in supplying the aforementioned information, a standardized form is used and incorporated into the implementing procedures.

I. Protracted Emergency Shift Coverage - The Emergency Director, with assistance from and coordination with other group Managers and Supervisors, SHALL ensure that work force requirements for all subsequent work shifts are determined and the necessary personnel are scheduled for the specific time period.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 27 of 149 5.3.2 Plant Emergency Organization Coordinators A. Technical Support Center Coordinator The Technical Support Center (TSC) Coordinator SHALL be responsible for the general activation, operation and coordination of activities in the Technical Support Center (TSC). Specific personnel assignments to the TSC Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the TSC Coordinator are:

1. Establish and verify radiological monitoring for the TSC;

2. Assist personnel performing the accountability check;

3. Coordinate activities of plant and non-plant personnel located in the TSC;

4. Periodically update personnel located in the TSC with appropriate information;

5. Maintain any necessary status boards;

6. Ensure technical guidance is provided to the Emergency Director and Control Room Operators on plant operations;

7. Establish or ensure that communications are established between all onsite emergency facilities and the EOF.

8. Ensure the Emergency Response Data System data link is established with the NRCs emergency center.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 28 of 149 B. Operational Support Center Coordinator The Operational Support Center Coordinator SHALL be responsible for the general activation, operation, and coordination of activities in the Operational Support Center (OSC). Specific personnel assignments to the OSC Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the OSC Coordinator are:

1. Establish and verify radiological monitoring for the OSC and the Control Room;

2. Coordinate activities of plant personnel located in the OSC to support plant operations as requested by the Control Room and TSC.

3. Assist personnel performing the accountability check in the OSC and the Control Room.

4. Maintain the communication systems in the OSC. A person may be designated to act as a communicator.

5. Periodically update personnel located in the OSC with appropriate information.

6. Control the use of equipment located in the emergency locker.

C. Assembly Point Coordinator The Assembly Point Coordinator SHALL be responsible for the general operation of the assembly area. Specific personnel assignments to the Assembly Point Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the Assembly Point Coordinator are:

1. Verify that radiological monitoring has been established for the Assembly Point.

2. Coordinate activities of all personnel (plant and non-plant) located at the Assembly Point.

3. Assist the Emergency Director in performing the accountability check, as necessary.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 29 of 149

4. Maintain the communication systems. A person may be designated as the communicator, if necessary.

5. Control the use of equipment located in the Emergency Locker.

6. Update all personnel with appropriate information when directed by the Emergency Director.

7. Provide instructions to personnel when they are released from the assembly point for reentry or transport offsite.

D. Radiological Emergency Coordinator The Radiological Emergency Coordinator (REC) SHALL be responsible for radiological accident assessment, onsite and offsite.

The REC should report to the Technical Support Center when the TSC is activated. Upon activation of the EOF, the Radiation Protection Support Supervisor will assume responsibility for the offsite activities. The offsite survey teams will initially be comprised of individuals from the Prairie Island Plant. Upon activation of the EOF, the offsite survey teams will be comprised of individuals from the Monticello Nuclear Generating Plant. The REC should transfer the responsibility for offsite accident assessment to the Radiation Protection Support Supervisor at the EOF. Specific personnel assignments to the Radiological Emergency Coordinator are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory.

The responsibilities of the REC are:

1. Offsite dose assessment

2. Formulating offsite protective action recommendations

3. Offsite surveys

4. Onsite surveys

5. Chemistry

6. Radiochemistry

7. Onsite Radiation Protection for:

a Access Control b Damage control and repair c Search and rescue d First-aid e Personnel monitoring and decontamination f Dosimetry

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 30 of 149 5.3.3 Plant Shift Organization The following groups comprise the plants shift organization. Brief descriptions of their emergency responsibilities are included.

A. Operations Group The Operations Group consists of the Operations Manager, Asst.

Operations Manager, Shift Managers, Shift Technical Advisors, Shift Supervisors, and all operators.

The Operations Group SHALL have responsibility for:

1. Plant Operations and assessment of operational aspects of the emergency.

2. Rad Waste equipment operation

3. Emergency radiation surveys

4. Short term damage control and repair for electrical, mechanical, and I&C equipment.

B. Security Group The Security Group consists of the Security Manager, the Security Staff, and the contract Security Force.

The Security Force SHALL:

1. Carry out the plant security and Access Control program.

2. Maintain strict personnel accountability onsite.

3. Assist communications efforts when necessary.

4. Assist in first aid treatment.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 31 of 149 C. Shift Manager The Shift Manager (SM) SHALL be onsite continuously. The Shift Manager SHALL assume overall coordination and control in the Control Room and provide direction as necessary to the Shift Supervisor.

The Shift Manager SHALL:

1. Assume the duties of the interim Emergency Director until relieved by the designated Emergency Director. Portions of the E-Plan implementation may be delegated to other members of the plant staff as the condition of the plant dictate.

2. Assess the emergency condition, event evaluation, and safety related aspects of the plant.

D. Shift Technical Advisors Provide technical and engineering support in the area of accident assessment.

E. Shift Emergency Communicator (SEC)

The Shift Emergency Communicator (SEC) SHALL be onsite continuously. The SEC is responsible for initial notification to the offsite agencies and maintaining communications during emergency conditions. The SEC may designate offsite communications to a qualified Communicator.

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E-PLAN EP EMERGENCY PLAN REV: XX Page 32 of 149

1. When the EOF Organization is activated and the EOF is functional, communications with the offsite agencies and personnel will be maintained by the EOF personnel.

NOTE:

2. As the emergency organization is activated, additional communicators from TSC support personnel should augment the plant staff to assist in communication efforts.

F. Fire Brigade The Fire Brigade should consist of:

1. Brigade Chief - Unit 1 Turbine Building APEO or as designated by the Shift Manager.

2. Assistant Chief - Any Qualified APEO.

Usually the APEO from the affected building SHALL fulfill the NOTE: duties of the Brigade Chief in his absence.

3. Fire Fighters - BOP Operators.

4. Runner - As designated to accompany fire department, operate equipment, bring additional equipment to fire scene.

The Fire Brigade SHALL be responsible for firefighting and primary responders for Search and Rescue, as necessary.

The Red Wing Fire Department should provide emergency assistance and SHALL be called immediately on report of fire. Other plant personnel on site may be called on for emergency work or called to plant for emergency service.

G. Radiation Protection Specialist The Radiation Protection Organization consists of three Radiation Protection Specialists (RPS) onsite at all times. The RPS is responsible for conducting routine and special surveys, maintaining Access Control, writing RWPs and providing job coverage as required. Qualified operations personnel on-shift are also trained to perform radiation surveys during emergency conditions.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 33 of 149 H. Chemistry Technician Two Chemistry Technicians are onsite at all times. One Chemistry Technician is responsible for chemistry and radiochemistry. The second Chemistry Technician performs the dose assessment function until relieved by the augmented ERO. The Chemistry Technicians are also cross-trained to support the Radiation Protection Specialist functions described in Section G above.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 34 of 149 5.3.4 Plant Emergency Staff Augmentation Groups A. Maintenance Group The Maintenance Group consists of all mechanical maintenance personnel, all plant electricians and I&C Specialists. The onsite Emergency Organization includes the Maintenance Manager, who should report to the Technical Support Center (TSC); and the Maintenance Supervisors (mechanical, electrical and I&C), and designated Electricians who should report to the Operational Support Center (OSC). The mechanical, electrical and I&C maintenance staff in the OSC can be further augmented or decreased as emergency conditions dictate.

The Mechanical, Electrical, and I&C Maintenance Group SHALL have responsibility for:

1. Supporting the repair and corrective actions for the mechanical, electrical, and I&C systems in support of emergency response and recovery actions.

2. Supporting the Search and Rescue effort.

B. Radiation Protection Group and Chemistry Group The Radiation Protection and Chemistry Groups consists of the Radiation Protection Manager & Chemistry Manager and all members of the Radiation Protection and Chemistry Groups. Radiation Protection and Chemistry Managers and other designated group members should report to the Technical Support Center. Other Radiation Protection Specialists and Chemistry Technicians should report to the Operational Support Center.

The responsibilities of the Radiation Protection and Chemistry Groups are:

1. Offsite Dose Assessment

2. Offsite Surveys

3. Onsite Surveys

4. Chemistry

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 35 of 149

5. Radiochemistry

6. Radiation Protection for:

a Access Control b Damage control and repair c Search and rescue d First aid e Fire fighting f Personnel monitoring and decontamination g Dosimetry C. Engineering Group The Engineering Group consists of Systems, Programs, Design and Equipment Reliability.

Upon activation of the onsite emergency organization, Systems and Programs Engineering Managers and designated engineers assigned to the emergency organization should report to the Technical Support Center. Other designated engineers may be requested to further augment engineering support in the TSC.

The Engineering Group SHALL have responsibility for:

1. Providing technical support for plant system engineering on electrical/mechanical systems.

2. Providing technical support for operating radioactive waste control systems.

3. Providing core parameter analysis to determine current core status.

4. Providing plant parameter trending and analysis utilizing the Emergency Response Computer System (ERCS).

5. Projecting possible loss of key equipment and its consequences.

6. Providing technical support for emergency repairs and corrective actions on electrical/mechanical systems.

7. Update TSC staff of potential problems and developments.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 36 of 149 D. Logistics Support Group The Logistics Support Group consists of Business Support Group (Administration Services and Document Control), Plant Services, and Site Materials.

Business Support Group SHALL supply logistical support in their area of expertise. Personnel in these areas may be called in to provide support for emergency response on an as needed basis.

Site Materials SHALL provide assistance in retrieving the parts necessary for an emergency response.

Plant Services SHALL support an emergency response by providing necessary assistance by the Nuclear Plant Service Attendants.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 37 of 149 5.4 EOF Organization The EOF (Emergency Operations Facility) Organization consists of a Direction and Control Group and three subordinate groups. The EOF Organization is staffed by personnel from the sites Engineering and Project Management groups and Prairie Island Training Center staff. The Prairie Island EOF Organization is shown in Figure 2.

The EOF should be staffed and ready to assume its emergency responsibilities from the TSC within 90 minutes of Classification of an ALERT or higher. Transfer of these responsibilities from the TSC to the EOF will be coordinated between the TSC and EOF and depend on the status of the TSCs emergency response.

5.4.1 EOF Direction and Control The Emergency Manager is responsible for overall direction and control of NSPMs emergency response effort. Designated members of management staff the Emergency Manager position in the EOF. Specific personnel assignments to the Emergency Manager position are found in the MT & PI Nuclear Emergency Preparedness Telephone Directory. The Emergency Manager relieves the Emergency Director of the following responsibilities:

A. Off-site dose projections and coordination and direction of the utility off-site radiological monitoring teams.

B. Authorization of emergency classification changes. The Emergency Director retains the primary responsibility for re-classifications and makes recommendations to the Emergency Manager who has the responsibility to review and authorize the new classification.

C. Authorization of offsite Protective Action Recommendations.

D. Communications with off-site authorities including Federal, State, Local and Tribal authorities and MT & PI Offsite executive management located at the Minnesota State Emergency Operations Center.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 38 of 149 Figure 2 Prairie Island EOF Organization

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 39 of 149 Other responsibilities of the Emergency Manager include:

A. Coordinate the emergency response efforts of other offsite support personnel assisting the plant organization.

B. Obtain and coordinate the services of outside consultants and vendors.

C. Advise utility management on matters related to emergency response efforts and needed resources to support the effort.

5.4.2 EOF Technical Support Group The EOF Technical Support Group consists of select personnel from the sites Engineering and Project Management groups and Training Center staff. The Technical Support Supervisor is staffed by senior personnel and reports to the Emergency Manager. The Technical Support Group is responsible for trending critical parameters, engineering evaluation in support of the TSC Engineering Group, technical assessment and advising the Emergency Manager on technical matters related to the event.

5.4.3 EOF Radiation Protection Support Group The EOF Radiation Protection Support Group is staffed by select personnel from the Training Center, plant Radiation Protection and Chemistry Groups and Emergency Plan Group. The Radiation Protection Support Supervisor position is staffed by senior personnel qualified in radiation assessment and reports to the Emergency Manager. The Radiation Protection Support Group includes plant Chemistry personnel for off-site dose projection and EOF Count Room operation and Nuclear Plant Service Attendants who function as sample couriers and drivers for off-site radiological monitoring teams. Radiation Protection Support Group responsibilities include:

A. Direction and coordination of the utility off-site radiological monitoring teams.

B. Off-site dose projection.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 40 of 149 C. EOF Count Room activation and operation.

D. EOF habitability, personnel monitoring and decontamination (as necessary).

E. Communications with state assessment groups on matters related to dose projections and off-site protective action recommendations.

F. Staffing the Health Physics Network (HPN) and communications with the NRC (as necessary).

The Radiation Protection Support Supervisor advises the Emergency Manager on matters related to actual or potential radiological impact on the environment, off-site protective action recommendations, and EOF habitability.

5.4.4 EOF General Support Staff The EOF General Support Staff consists of the EOF Coordinator, emergency communicators, administrative and security support personnel.

The EOF Coordinator position is staffed by senior Training Center or site Engineering and Project Management personnel and reports to the Emergency Manager. The EOF Coordinator is responsible for activation and operation of the EOF and assists the Emergency Manager with administrative duties. The emergency communicators, EOF Security Coordinator and Administrative Staff report to the EOF Coordinator. The emergency communicators are responsible for communications with offsite agencies as directed by the Emergency Manager. The Administrative Staff is responsible for emergency document control, recording and document distribution at the EOF. An EOF Coordinator Assistant is responsible for general logistics support and assisting the EOF Coordinator. The EOF Security Coordinator reports to the EOF Coordinator. Responsibilities of EOF Security include EOF access and dosimetry issuance to EOF personnel.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 41 of 149 5.5 Recovery Organization The establishment of the Recovery Organization will be dependent upon the nature and severity of the event or plant conditions. In general terms, an Unusual Event or Alert may be terminated without establishing a special Recovery Organization while a Site Area Emergency or General Emergency will probably necessitate the establishment of a Recovery Organization. The Recovery Organization will manage the overall recovery or post-accident outage plans as work is done to return the plant to a normal operational or shutdown status.

The Recovery Manager is mainly responsible for management of the recovery phase and will perform their initial tasks as directed by the Emergency Manager.

The Recovery Manager will report to the Emergency Operations Facility and begin to prepare for the transition to Recovery, as necessary. If Recovery is imminent, the Recovery Manager will establish a recovery or post-accident outage organization following the sites plant event recovery protocols.

5.6 Augmentation of Plant and EOF Emergency Organizations 5.6.1 Offsite Support Response The emergency response plan for Prairie Island NGP is designed to be initially implemented independent of any offsite support. However, the onsite effort will be augmented with offsite support resources as described in the MT & PI Offsite Nuclear Emergency Plan.

It is the purpose of the offsite support organization to augment the onsite response effort with offsite support resources as soon as practical and as needed by the Prairie Island Site staff. Such areas of support include:

Government Agency Interface, Logistics Support, News Media Interface and Utility Executive Management Interface.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 42 of 149 5.6.2 Monticello Radiation Protection Group Support The Monticello Nuclear Generating Plant is located approximately 100 miles northwest of Prairie Island NGP. The Monticello Radiation Protection and Chemistry Groups are available for supporting the Prairie Island Radiation Protection Group with personnel and equipment during any emergency condition at Prairie Island. Designated individuals from the Monticello plant would arrive at Prairie Island in approximately two to three hours with all the equipment necessary to assume responsibility for offsite monitoring. The Prairie Island Radiation Protection Group may then dedicate their activities to onsite responsibilities. The Monticello Radiation Survey Teams will be under the control of the Radiation Protection Support Supervisor (RPSS), as directed by the Emergency Manager, as soon as the EOF has been activated.

5.6.3 Westinghouse Support Westinghouse emergency assistance is available on a twenty-four hour per day, seven day per week basis. Westinghouse will activate all appropriate features of the Westinghouse Emergency Response Plan to support the plant needs. When activated, the Westinghouse Emergency Response Plan becomes a functioning organization, comprised of individuals with unique technical, managerial and communication skills and experience, necessary to:

A. Make an early assessment of the situation B. Provide early assistance to the utility C. Mobilize appropriate Westinghouse critical skills and functions D. Initiate timely, accurate communications to involved and interested parties A Site Response Team may be dispatched to the site to obtain a first hand assessment of actual conditions and establish communications from the site to the Westinghouse response center, as deemed necessary.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 43 of 149 5.6.4 Local Support Services A. Fire Fighting The Red Wing Fire Department will provide assistance in the event of a fire occurring at the plant. The duties and responsibilities of the Plant Fire Brigade, insuring complete coordination with the Fire Department, are covered in the Operations Manual, Section F5, Fire Fighting.

B. Hospital and Medical Support Medical support and treatment for non-radiological injuries is provided by the Mayo Clinic Health System, both of which are located in Red Wing, Minnesota. Radiological related injuries are treated at the medical center which is the primary treatment facility. Emergency plans have been prepared, and training of medical center personnel is accomplished on an annual basis.

Regions Hospital in St. Paul, Minnesota is designated as the definitive care center for Prairie Island Nuclear Generating Plant.

Regions Hospital may be used for radiation casualties, severe burn casualties, and other non-radiation injuries with use of an appropriate medical air transport service.

C. Ambulance Service The Red Wing Ambulance Service will provide service to the Prairie Island Nuclear Generating Plant. Training and participation in drills ensures that personnel involved in the transportation of radiation victims are knowledgeable in use of proper procedures and handling methods. Procedures are covered in the Operations Manual, Section F4, Medical Support and Casualty Care.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 44 of 149 5.7 Coordination with Governmental Response Organizations 5.7.1 Minnesota Division of Homeland Security and Emergency Management (HSEM)

The Minnesota Division of Homeland Security and Emergency Management has the responsibility for notification and coordination of Minnesota State Agencies in the event of a major emergency at Prairie Island.

The MN HSEM is notified by Prairie Island NGP. In the event of an emergency situation at the plant, the MN duty officer will immediately call the MN Department of Health, the Governors Authorized Representative and other state agencies with emergency assignments to coordinate the implementation of any emergency procedures. The state agencies responsible for emergency procedures have established a system of twenty-four hour communications.

5.7.2 Minnesota Department of Health (MDH)

The Minnesota Department of Health (MDH) is responsible for providing radiological expertise in the State Emergency Operations Center in conjunction with the MN HSEM.

The Minnesota Department of Health will interpret data and participate in recommending protective actions to the Governors Authorized Representative.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 45 of 149 5.7.3 Wisconsin Emergency Management The Wisconsin Emergency Management (WEM), has the responsibility for notification and coordination of Wisconsin state agencies in the event of a major emergency at Prairie Island NGP.

In the event of an emergency situation at the plant, Prairie Island NGP will notify the WEM duty officer who will notify the Wisconsin Department of Health Services (Radiation Protection Section) and other state agencies with emergency assignments, to coordinate the implementation of any emergency procedures. The state agencies responsible for emergency procedures have established a system of twenty-four hour communications.

5.7.4 Wisconsin Department of Health Services (DHS)

The Wisconsin Department of Health Services (DHS) is responsible to prevent exposure to ionizing radiation in amounts which are detrimental to health according to nationally accepted standards.

The Wisconsin DHS, Radiation Protection Section, is responsible for coordination of radiation response activities in the State of Wisconsin. In the event of an emergency at Prairie Island NGP, DHS, Radiation Protection Section will be concerned with monitoring the air and water about the plant to assure that the public is not exposed to levels of radioactive pollutants potentially detrimental to public health. DHSs facilities are located in Madison, Wisconsin.

Due to the distance and time required for the Wisconsin Radiation Protection Response Team to arrive at the affected area, the State of Minnesota Department of Health, will provide mutual support to Wisconsin, as spelled out in the letter of agreement in the Wisconsin State emergency operations plan.

5.7.5 Goodhue, Dakota and Pierce County Sheriffs The Sheriffs Departments will notify all necessary local civil support groups in the event of an accident. The Sheriff is responsible for protection of the general public and can provide personnel and equipment for evacuation, relocation and isolation.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 46 of 149 5.7.6 Goodhue, Dakota, Pierce County and City of Red Wing Emergency Management The Goodhue, Dakota, Pierce County and City of Red Wing Emergency Management Organizations have the responsibility for notification and providing direction to residents in the event of a major emergency that affects their respective area of responsibility.

5.7.7 Prairie Island Indian Community The Prairie Island Indian Community has an Emergency Operations Plan that includes the description of tribal responsibilities during a nuclear plant declared event. The Prairie Island Nuclear Generation Plant conducts emergency notifications to the Treasure Island Casino security dispatch center who, in turn, notifies appropriate members of the Prairie Island Indian Community and their organization.

5.7.8 Minnesota State Patrol The Minnesota (MN) State Patrol has the responsibility to protect the general public by providing personnel and equipment to re-route traffic in the event of an emergency situation. Plans have been made for re-routing federal and state highways. Signs and equipment required for re-routing will be stored in the areas where they would be needed to facilitate highway closings. The MN Department of Transportation would be notified by the MN State Patrol to erect the signs.

5.7.9 Minnesota Department of Transportation The MN Department of Transportation will assist the MN State Patrol in blocking and re-routing traffic around the plant site. In addition to the necessary personnel; vehicles, signals, and barriers for setting up and maintaining detour routes are available.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 47 of 149 5.7.10 Canadian Pacific Railway-CP Railway (Soo Line)

In an emergency situation, CP Rail will make every reasonable effort to expedite unblocking the road/railroad crossing near Prairie Island NGP.

The dispatcher will also provide routing assistance during an emergency at Prairie Island NGP.

5.7.11 Burlington Northern Santa Fe (BNSF) Railway The dispatcher will provide routing assistance during an emergency at Prairie Island NGP as per the Minnesota State emergency operations plan.

5.7.12 Department of the Army, Corps of Engineers, Lock & Dam #3 The Corps of Engineers at Lock & Dam #3 will be notified by the Minnesota Duty Officer of an emergency at Prairie Island NGP. The Lock and Dam personnel will notify all tows within radio range of impending evacuations and assist in evacuation of personnel at the Lock and Dam.

A complete description of response capabilities, organizational resources, activation plans, designations of NOTE: emergency operations centers and letters of agreement are available in Minnesota and Wisconsins state emergency operations plans.

5.7.13 Nuclear Regulatory Commission (NRC)

The basic responsibilities of the NRC are to monitor, assess, and, if necessary, direct the utility to take actions to protect the health and safety of the public. For a radiological incident at a commercial power plant, the NRC is the Lead Federal Agency (LFA). The LFA is responsible for coordinating all Federal onscene actions. The NRC will coordinate Federal assistance to States and local organizations.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 48 of 149 A principal role of the LFA is to assist the State in interpretation and analysis of technical information as a basis for making decisions about protective actions. This assistance will begin early in an incident from the NRC Operations Center in Rockville, MD, and later, from the utilitys emergency operations facility on scene. The NRC is an independent reviewer of the actions the utility is taking to correct the initiating and related problems. The NRC will assess actual or potential offsite impacts as well, and will make an independent evaluation of Protective Action Recommendations, if necessary. As the LFA, the NRC has the responsibility for coordinating the release of Federal information to the media and others. The NRC will conduct most public information activities from the utilitys Joint Information Center (JIC). The NRC also will keep the White House and Congress informed on all aspects of the event.

The NRC is responsible for giving the best possible advice at a given time to the States and will not limit its involvement to presenting a series of options.

The NRC also administers the Price-Anderson Act to ensure that the public that is affected by the event has adequate financial assistance to address most emergency needs.

5.7.14 Department of Energy (DOE)

Among its responsibilities as a support agency, DOE will coordinate the offsite radiological monitoring and assessment for the Lead Federal Agency (LFA) and the State during the initial phases of the emergency. It will maintain a common set of offsite radiological data and provide an appropriate interpretation of the data to the LFA and the State. DOE will manage the Federal Radiological Monitoring and Assessment Center (FRMAC), which is a multi-agency facility. DOE will conduct environmental monitoring, including air, ground, and water.

Their immediate objective is to rapidly dispatch a Radiological Assistant Program (RAP) Team to the scene to assess the hazard to the public and make recommendations to the authorities for the protection of the public.

The Planning Chief in the State EOC is the designated Minnesota authority to request RAP assistance, as stated in the Minnesota state plan, and the Wisconsin DH, Radiation Section, is the designated Wisconsin authority to request RAP assistance for Wisconsin, as stated in the Wisconsin state plan.

PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMERGENCY PLAN NUMBER:

E-PLAN EP EMERGENCY PLAN REV: XX Page 64 of 149 6.4.2 Radiological Surveys The Radiation Protection Group SHALL be responsible for all radiological surveys and personnel monitoring both onsite and offsite. The non-licensed operators of the Operations Group are also trained to conduct post-accident in-plant surveys during the first hour of the emergency. The Emergency Director has the responsibility for directing all radiation safety during the emergency.

The Radiation Protection Specialists may be divided into three emergency Radiation Survey Teams. Two teams are assigned offsite duties such as radiation surveys, air samples, or liquid sampling. The two offsite survey teams will conduct a search for the plume and obtain dose rates, and iodine, particulate or gaseous samples at pre-designated sample locations.

Plume exposure pathway maps with pre-designated sample locations are contained in the emergency survey kits. The third team is assigned duties onsite such as radiation surveys, sampling (airborne or liquid) and sample analysis using the equipment available onsite and/or the EOF Count Room facility. Silver zeolite adsorbers are used to collect airborne iodine samples, both onsite and offsite. Silver zeolite adsorbers eliminate the problem of entrapped noble gases on the iodine adsorber, allowing a much lower detection sensitivity. Iodine samples may be analyzed in the EOF Counting Room.

The Radiation Survey Teams are activated via the ERO Auto Dial System and/or the ERO Pager Network or the telephone system. The teams will be activated and respond within ninety (90) minutes of declaration.

Designated Emergency Lockers contain emergency survey kits, which include portable instruments, battery operated air samplers, liquid sampling equipment, and communication equipment.

After the initial offsite surveys are completed, the teams assigned offsite duties may be relieved by Monticello Radiation Protection Specialists who will continue to perform any offsite surveys assigned by the Emergency Manager. The Prairie Island Survey Team members may concentrate their efforts and resources to onsite responsibilities.

ENCLOSURE 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS 1 AND 2 LICENSE AMENDMENT REQUEST License Amendment Request (LAR) to Revise Staff Augmentation Times in the Prairie Island Nuclear Generating Plant (PINGP) Emergency Plan PRAIRIE ISLAND AUGMENTATION STAFFING ANALYSIS (ON-SHIFT STAFFING ANALYSIS)

(42 pages follow)

Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 December 2013



PrairieIsland

AugmentationStaffing

Analysis

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TableofContents

I. PURPOSE 3 II. ANALYSIS METHODOLOGY 4

a. Event Determination 4

b. Conduct of On-shift Staffing Analysis 7

c. Event Summaries 9

i. Analysis #5 Accidental Release - Waste Gas Tank 9 ii. Analysis #6 Steam Generator Tube Rupture 17 iii. Analysis #9 Large Break LOCA with release and resulting PARs 26 III. FUNCTION ANALYSIS 36 IV. CONCLUSIONS 40 V. ACRONYM LIST 40



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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 I. PURPOSE On June 19, 2013, an On-shift Staffing Analysis (OSA) was performed at Prairie Island Nuclear Generating Plant (PINGP) to determine whether critical functions can be adequately performed by on-shift resources if augmentation times are revised from the current 30 and 60 minute requirement to 90 minutes. Table A lists the positions and response times reviewed for this analysis.

In November 2011, the NRC published revised Emergency Preparedness Regulations in the Federal Register (Reference 76 FR 72560) for 10 CFR 50 Appendix E.IV.A.9, that required for the first time that the on-shift staffing component identified in the site Emergency Plan be supported by a detailed staffing analysis. No specific guidance as to the methodology for performance of this detailed analysis was addressed in the regulation. NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, Revision 0, dated November 2011 (Reference 2 ), provided specific details as to the scenarios required to be analyzed and endorsed NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0, dated June 2011 (Reference 3) as an acceptable means of performing the required analysis. NEI 10-05 remains the only methodology endorsed at this time. Northern States Power Minnesota (NSPM) appropriately conducted and documented the analysis in Emergency Plan Implementing Procedure F.3-1.

Additionally, NEI 10-05, Section 2.14, Changes to ERO Response Times, supports the use of this methodology to address modifications to augmentation times.

Although developed to meet the requirements of 10 CFR 50, Appendix E, Section IV.A.9, the staffing assessment methodology may be used to evaluate proposed changes to on-shift staffing levels or augmented ERO response times. For example, an analysis could be performed with a desired response time for the augmenting ERO (e.g., 90 minutes), and the results then used to support the basis for changing a staffing or augmentation time commitment.

The analysis performed for this License Amendment Request was based on the current analysis that was performed to demonstrate compliance with 10 CFR 50 Appendix E.IV.A.9. The compliance analysis determined the staffing identified in Table A was sufficient to perform the required functions until augmented in accordance with existing Emergency Plan requirements.

The scenarios were then examined to determine dependence on augmented response. Those scenarios dependent on augmented response in less than 90 minutes were then selected for reanalysis (See Table C). Gaps identified in the June 2013 analysis requiring resolution to support augmentation relief to 90 minutes were designated in NEI 10-05 Table 1 as requiring additional Time Motion Study. In the June 2013 OSA, the time motion study was replaced by the proposed changes to the on-shift staffing resulting in a final on-shift staff increasing from 18 personnel to 20. Table B lists the proposed on-shift and 90 minute augmentation requirements resulting from the analysis. The proposed on-shift staffing in Table B is supported by the OSA analysis. The proposed 90 minute column is supported by the accompanying functional analysis.

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Table A - Current On-shift, 30 Minute and 60 Minute Augmentation Requirements Position Title On Shift 30 minute relief 60 minute relief Shift Manager/Emergency Director (ED) 1 Unit Supervisors 2 Reactor Operators 4 Aux Operators 6 Shift Emergency Communicator (SEC) 1 1 2 Emergency Manager 1 Rad Emergency Coordinator (REC) 1 Radiation Protection (RP) Specialist 2 4 6 Chemistry Technician 1 1 Technical Support - STA 1 Technical Support - Core/Thermal 1 Technical Support - Electrical 1 Technical Support - Mechanical 1 Mechanical Maintenance 1 Radiological (Rad) Waste Operator 1 Electrical Maintenance 1 1 Instrument Control 1 Total 18 9 15 Table B - Proposed On-shift and 90 Minute Augmentation Requirements Position Title On Shift 90 minute relief Shift Manager / ED 1 Unit Supervisors 2 Reactor Operators 4 Aux Operators 6 Shift Emergency Communicator (SEC) 1 3 Emergency Manager 1 Rad Emergency Coordinator (REC) 1 RP Specialist 3 9 Chemistry Technician 2 1 Technical Support - STA 1 Technical Support - Core/Thermal 1 Technical Support - Electrical 1 Technical Support - Mechanical 1 Mechanical Maintenance 1 Electrical Maintenance 2 Instrument Control 1 Rad Waste Operator 1 Total 20 23 II. ANALYSIS METHODOLOGY

a. Event Determination A review of PINGP F3-1.1, Emergency Plan On-shift Staffing Analysis, (i.e. the initial compliance OSA) was conducted to determine which events would require further on-shift staffing analysis to support a License Amendment Request (LAR) to extend existing 4



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 staff augmentation response times from 30 and 60 minutes to 90 minutes. The initial staffing analysis performed to demonstrate compliance with the current requirements identified a number of scenarios that the existing minimum staff resolved prior to any augmented relief. For those scenarios where the initial staffing analysis did not depend on augmented responders, repeating the analysis at this time was not required.

The following scenarios were determined to require further analysis to support the revised augmentation period:

Event # 5 - Accidental Release - Waste Gas Tank Event # 6 - Steam Generator Tube Rupture Event # 9 - Large Break LOCA with release and resulting PARs Table C summarizes the review of events required for this analysis.

Table C - Events Requiring Analysis To Support Extended ERO Augmentation

Response

Summary Description of Reference Analysis # Analysis Required?

Event or Accident Document(s) 1 Land and/or waterborne ISG IV.C The initial Compliance HOSTILE ACTION directed OSA did not require against the Protected Area by augmented personnel a HOSTILE FORCE. Assume response.

adversary characteristics defined by the Design Basis Threat (DBT).

2 Locked Pump Rotor USAR Chapter Event not classified, further 14.4.8 analysis not required.

3 Fuel Handling USAR Chapter The initial Compliance 14.5.1 OSA did not require augmented personnel response.

4 Accidental Release of USAR Chapter The initial Compliance Radioactive Liquids 14.5.2 OSA did not require augmented personnel response.

5 Accidental Release - Waste USAR Chapter Event requires further Gas Tank 14.5.3 analysis to support LAR.

6 Steam Generator Tube USAR Chapter Event requires further Rupture 14.5.4 analysis to support LAR.

7 Rupture of a Steam Pipe USAR Chapter Event not classified, further 14.5.5 analysis not required.

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Table C - Events Requiring Analysis To Support Extended ERO Augmentation

Response

Summary Description of Reference Analysis # Analysis Required?

Event or Accident Document(s) 8 Rupture of a Control Rod USAR Chapter Response actions and on-Drive Mechanism Housing 14.5.6 shift resources required for (RCCA Ejection) this event are comparable to those for Event #9.

However, Event #9 is more limiting due to additional actions and resources required to perform them.

Therefore, this event is bounded by Event #9.

9 Large Break LOCA with USAR Chapter Event requires further release and resulting PARs 14.6 analysis to support LAR.

10 Small Break LOCA USAR Chapter Response actions and on-14.7 shift resources required for this event are comparable to those for Event #9.

However, Event #9 is more limiting due to additional actions and resources required to perform them.

Therefore, this event is bounded by Event #9.

11 ATWS USAR Chapter The initial Compliance 14.8 (Not OSA did not require designated as augmented personnel Condition IV response.

Event) 12 Response actions for an ISG IV.C The initial Compliance aircraft probable threat in OSA did not require accordance with 10 CFR augmented personnel 50.54(hh)(1) and as response.

discussed in RG 1.214 13 Control room fire leading to ISG IV.C The initial Compliance evacuation and remote OSA did not require shutdown, as referenced in augmented personnel IN 95-48. response.

14 Station Blackout (Current ISG IV.C The initial Compliance Licensing Basis) OSA did not require augmented personnel response.

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Table C - Events Requiring Analysis To Support Extended ERO Augmentation

Response

Summary Description of Reference Analysis # Analysis Required?

Event or Accident Document(s) 15 Appendix R Fire Response ISG IV.C The initial Compliance OSA did not require augmented personnel response.

16 SAMG Response ISG IV.C The initial Compliance OSA did not require augmented personnel response.

b. Conduct of On-shift Staffing Analysis A multi-disciplined team of subject matter experts from PINGP was assembled on June 19, 2013, to provide input into the on-shift staffing analysis of the identified events.

This team consisted of two Senior Reactor Operators, a Chemistry Technician, a Radiological Emergency Coordinator (REC), and Emergency Planning staff and Consultants. The team provided analysis support as follows:

Table D - On-shift Staffing Analysis Team Team Member Subject Matter Expertise Senior Reactor Operator EOP actions (Licensed/Non-Licensed Operator action)

Abnormal Procedure actions (Licensed/Non-Licensed Operator action)

Operating Procedure actions (Licensed/Non-Licensed Operator action)

Emergency Director (E Plan) actions Chemistry Technician Chemistry Response actions RP Response actions Dose Assessment actions REC RP Response actions Dose Assessment actions Offsite Survey Team actions Emergency Planning Emergency Plan response actions Using the guidance in Reference 3, the team performed a tabletop procedural analysis of on-shift actions required for response to the events identified in Table C. This review was conducted by the team in the PINGP Emergency Operations Facility (EOF), which 7



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 enabled the team to have access to procedures and other support documents. Each event was analyzed separately and documented in the NEI 10-05 event analysis tables.

The on-shift staffing analysis was conducted by first reviewing the event described in Table C, providing the team with a basic understanding of the event and resulting emergency classification(s). The Shift Manager (SM)/Control Room Supervisor (CRS) reviewed EOP, AOP, and other operating procedure actions and identified them to the team. Specific resources and time needed to perform initial event response actions were identified and documented as per the guidance in NEI 10-05. The team determined when other on-shift resources, such as Chemistry or RP, would be required and identified the time required to perform expected actions. The Emergency Plan functions for the event were reviewed and assigned to the on-shift resource responsible for performance of the identified function and documented as per NEI 10-05. Finally, the on-shift resources and their actions were summarized in NEI 10-05, Table 1.

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013

c. Event Summaries

i. Analysis #5 Accidental Release - Waste Gas Tank Initial Conditions:

Time: Wednesday @ 2200 Unit 1 100% Power @ EOC RCS Temp 560 qF Tav RCS Pressure 2235 psig Sequence of Events:

2200 121 Gas Decay Tank Ruptures Vent Header Pressure drops Local indications of 121 Gas Decay Tank = 0 psig 2201 Alarms are received on the following rad monitors 1R0030 - Aux Building Vent Gas 1R0037 - Aux Building Vent Gas 1R0055 - Aux Building East Area Rad Monitor 2204 Operators enter EOP/AOPs 2205 Emergency Plan initiated 2210 Initial Emergency Classification determined 2215 ERO activation initiated 2235 Initial notification to offsite agencies initiated 9



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Analysis #5: Accidental Release - Waste Gas ECL: Alert TABLE 1 - On-shift Positions Augmentation

Rolein Unanalyzed TMS

Line OnshiftPosition EmergencyPlanReference ElapsedTime

Table#/Line# Task? Required?

(min)

1.  ShiftManager PINGPEPlan,Table1,Rev47 N/A T2/L1 NO NO

T5/L1

T5/L2

T5/L3

T5/L4

T5/L5

2.  UnitSupervisor(SRO#1) PINGPEPlan,Table1,Rev47 N/A T2/L2 NO NO

3.  UnitSupervisor(SRO#2) PINGPEPlan,Table1,Rev47 N/A T2/L3 NO NO

T5/L5

T5/L10

T5/L13

4.  ShiftTechnicalAdvisor(STA) PINGPEPlan,Table1,Rev47 N/A T2/L4 NO NO

5.  RPSpecialist(RO#2) PINGPEPlan,Table1,Rev47 N/A T2/L5 NO NO

6.  RPSpecialist(RO#4) PINGPEPlan,Table1,Rev47 N/A T2/L6 NO NO

7.  AuxiliaryOperator(AO#1) PINGPEPlan,Table1,Rev47 N/A T2/L7 NO NO

10



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Augmentation

Rolein Unanalyzed TMS

Line OnshiftPosition EmergencyPlanReference ElapsedTime

Table#/Line# Task? Required?

(min)

8.  ShiftEmergencyCommunicator(SEC) PINGPEPlan,Table1,Rev47 90 T5/L6 NO NO

T5/L8

T5/L9

T5/L11

T5/L14

9.  RPSpecialist(RP#1) PINGPEPlan,Table1,Rev47 90 T4/L3 NO NO

10.  RPSpecialist(RP#2) PINGPEPlan,Table1,Rev47 90 T4/L1 NO NO

11.  ChemistryTechnician PINGPEPlan,Table1,Rev47 90 T4/L5 NO NO

12.  CASOperator PINGPEPlan,Table1,Rev47 N/A T5/L15 NO NO

Notes: None

11



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013





TABLE 2 - Plant Operations & Safe Shutdown Analysis # 5 Two Units - One Control Room (Shared) Applicable to unit 1 Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable TaskPerformance

Line GenericTitle/Role OnshiftPosition

Validation

1.  ShiftManager ShiftManager OperatorTraining

2.  ShiftSupervisor UnitSupervisor-U1(SRO#1) OperatorTraining

3.  ShiftSupervisor UnitSupervisor-U2(SRO#2) OperatorTraining

4.  ShiftTechnicalAdvisor ShiftTechnicalAdvisor(STA) OperatorTraining

5.  ReactorOperator(BOP) ReactorOperator-U1BOP(RO#2) OperatorTraining

6.  ReactorOperator(BOP) ReactorOperator-U2BOP(RO#4) OperatorTraining

7.  AuxiliaryOperator AuxiliaryOperator(AO#1) OperatorTraining



Notes: SeeTable2AforAOP/EOPactions







12



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Prairie Island Timing Template - Table 2A Scenario: #5

Title:

Accidental Release - Waste Gas Procedure Step/Actions Performance Time (mins) After Procedure Implementation Assigned Proc/Step Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70 70-75 75-80 80-85 85-90 Resource Hi Rad Train A and B RO#2 X alarms ARG C47022 Verify alarms at panel RO#2 X

- 1R0030, 37 Verify automatic RO#2 X actions Notify RP RO#4 X C47048 1R-30 Dispatch AO RO#4 X Page SM, SS and SRO#1 X SEC to CR Verify automatic C4708 1R-37 RO#2 X actions Review ERCS and N/A notify SS of Area RO#2 X Alarm on 1R-55 Local evacuation of SRO#2 F3-9 X Aux Building CAS SM, STA and SEC SM N/A X respond to CR STA SM F3-2 Classify Event (Alert) X STA Assist SM with PINGP N/A SEC X 577 F3-5 Notify Offsite PINGP 580 Agencies and activate SEC X PINGP 1384 ERO NRC Notification Form PINGP 666 SRO#2 X Completion PINGP 1125 Perform Alert actions SM X PINGP 666 Notify NRC using ENS SRO#2 X Investigate source of N/A rad leak until Aux Bldg AO#1 X Evacuation 13



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 3 - Firefighting Analysis # 5



TaskAnalysis

Line PerformedBy

ControllingMethod

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



Notes:NoFireBrigaderesponserequiredforthisevent.





14



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 4 - Radiation Protection and Chemistry Analysis # 5 PerformanceTimePeriodAfterEmergencyDeclaration(minutes)

Line PositionPerformingFunction/Task 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1.  InPlantSurvey

   ReporttoOSCforfurtherdirection.

OnshiftPosition:RPSpecialist#2

2.  OutofPlantSurvey

                 

OnshiftPosition:RPSpecialist

3.  PersonnelMonitoring

 X

OnshiftPosition:RPSpecialist#1

4.  JobCoverage

                 

OnshiftPosition:

5.  OffsiteRadiologicalAssessment

     X

OnshiftPosition:ChemistryTechnician

6.  OtherSiteSpecificRPSpecialist-Describe:

                 

OnshiftPosition:

7.  Chemistryfunction/task#1-Describe:

                 

OnshiftPosition:ChemistryTechnician

8.  Chemistryfunction/task#2-Describe:

                 

OnshiftPosition:ChemistryTechnician





15



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 5 - Emergency Plan Implementation Analysis # 5



TaskAnalysis

Line Function/Task OnshiftPosition

ControllingMethod

1.  DeclaretheEmergency ShiftManager EP/OpsTrainingandEP

ClassificationLevel(ECL) DrillProgram

2.  ApproveOffsiteProtectiveAction ShiftManager EP/OpsTrainingandEP

Recommendations DrillProgram

3.  ApprovecontentofState/Local ShiftManager EP/OpsTrainingandEP

notifications DrillProgram

4.  Approveextensiontoallowable ShiftManager EP/OpsTrainingandEP

doselimits DrillProgram

5.  Notificationanddirectiontoon SRO#2/ShiftManager EP/OpsTrainingandEP

shiftstaff(e.g.,toassemble, DrillProgram

evacuate,etc.)

6.  EROnotification SEC EP/OpsTrainingandEP

DrillProgram

7.  AbbreviatedNRCnotificationfor N/A EP/OpsTrainingandEP

DBTevent DrillProgram

8.  CompleteState/Localnotification SEC EP/OpsTrainingandEP

form DrillProgram

9.  PerformState/Localnotifications SEC EPTrainingandEPDrill

Program

10.  CompleteNRCeventnotification SRO#2 EP/OpsTrainingandEP

form DrillProgram

11.  ActivateERDS SEC EP/OpsTrainingandEP

DrillProgram

12.  Offsiteradiologicalassessment N/A N/A

13.  PerformNRCnotifications SRO#2 EP/OpsTrainingandEP

DrillProgram

14.  Performothersitespecificevent SEC EP/OpsTrainingandEP

notifications(e.g.,INPO,ANI,etc.) DrillProgram

15.  Personnelaccountability CAS EP/SecurityTrainingand

EPDrillProgram



Notes: EALRA1.2-AlertClassification(Oneormoreplanteffluentmonitorsdetectanairborneor

liquidradioactivematerialreleasethatexceeds200timesthemonitoralarmsetpointfor15minutes

orlonger.) 



16



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013





ii. Analysis #6 Steam Generator Tube Rupture Initial Conditions:

Time: Wednesday @ 2100 Unit 2 100% Power RCS Temp 560 qF Tav RCS Pressure 2235 psig Sequence of Events:

2105 U2 Condenser air ejector radiation monitor, 2R0015, begins to increase 2106 Slight increase observed in 22 S/G level 2R0019 SG Blowdown Monitor reading 1,000 cpm and increasing Alarm received in Control Room Flash Tank Valves closed Discharge to River closed 2R0052, U2 MS B Steam Line Rad monitor reading 25 mR/hr and increasing Pressurizer level observed to be decreasing 2107 Control operators initiate actions to increasing pressurizer level and troubleshoot S/G tube leakage 2110 Rx manually trip on low pressurizer level SI initiated



17



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Analysis #6: Steam Generator Tube Rupture ECL: Alert TABLE 1 - On-shift Positions



Augmentation

Rolein Unanalyzed TMS

Line OnshiftPosition EmergencyPlanReference ElapsedTime

Table#/Line# Task? Required?

(min)

1.  ShiftManager PINGPEPlan,Table1,Rev47 N/A T2/L1 NO NO

T5/L1

T5/L2

T5/L3

T5/L4

T5/L5

2.  UnitSupervisor(SRO#1) PINGPEPlan,Table1,Rev47 N/A T2/L2 NO NO

T5/L5

T5/L10

T5/L13

3.  UnitSupervisor(SRO#2) PINGPEPlan,Table1,Rev47 N/A T2/L3 NO NO

4.  ShiftTechnicalAdvisor(STA) PINGPEPlan,Table1,Rev47 N/A T2/L4 NO NO

5.  ReactorOperator(RO#2) PINGPEPlan,Table1,Rev47 N/A T2/L5 NO NO

6.  ReactorOperator(RO#3) PINGPEPlan,Table1,Rev47 N/A T2/L6 NO NO

7.  ReactorOperator(RO#4) PINGPEPlan,Table1,Rev47 N/A T2/L7 NO NO

8.  AuxiliaryOperator(AO#1) PINGPEPlan,Table1,Rev47 N/A T2/L8 NO NO

18



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Augmentation

Rolein Unanalyzed TMS

Line OnshiftPosition EmergencyPlanReference ElapsedTime

Table#/Line# Task? Required?

(min)

9.  AuxiliaryOperator(AO#4) PINGPEPlan,Table1,Rev47 N/A T2/L9 NO NO

10.  AuxiliaryOperator(AO#6) PINGPEPlan,Table1,Rev47 N/A T2/L10 NO NO

11.  ShiftEmergencyCommunicator(SEC) PINGPEPlan,Table1,Rev47 90 T5/L6 NO NO

T5/L8

T5/L9

T5/L11

T5/L14

12.  RPSpecialist(RP#1) PINGPEPlan,Table1,Rev47 90 T4/L1 NO NO

T4/L4

13.  RPSpecialist(RP#2) PINGPEPlan,Table1,Rev47 90 T4/L4 NO NO

14.  ChemistryTechnician PINGPEPlan,Table1,Rev47 90 T4/L5 NO YES

T4/L7

Notes: ThetimemotionstudyidentifiedinLine14wassubsequentlyresolvedbytheadditionofanadditionalonshiftChemistry

Technician.

19



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 2 - Plant Operations & Safe Shutdown Analysis # 6 Two Units - One Control Room (Shared) Applicable to unit 2 Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable TaskPerformance

Line GenericTitle/Role OnshiftPosition

Validation

1.  ShiftManager ShiftManager OperatorTraining

2.  ShiftSupervisor UnitSupervisor-U1(SRO#1) OperatorTraining

3.  ShiftSupervisor UnitSupervisor-U2(SRO#2) OperatorTraining

4.  ShiftTechnicalAdvisor ShiftTechnicalAdvisor(STA) OperatorTraining

5.  ReactorOperator(BOP) ReactorOperator-U1BOP(RO#2) OperatorTraining

6.  ReactorOperator(OATC) ReactorOperator-U2OATC(RO#3) OperatorTraining

7.  ReactorOperator(BOP) ReactorOperator-U2BOP(RO#4) OperatorTraining

8.  AuxiliaryOperator AuxiliaryOperator(AO#1) OperatorTraining

9.  AuxiliaryOperator AuxiliaryOperator(AO#4) OperatorTraining

10.  AuxiliaryOperator AuxiliaryOperator(AO#6) OperatorTraining



Notes: SeeTable2AforAOP/EOPactions







20



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Prairie Island Timing Template - Table 2A Scenario: #6

Title:

Steam Generator Tube Rupture Procedure Step/Actions Performance Time (mins) After Procedure Implementation Assigned Proc/Step Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70 70-75 75-80 80-85 85-90 Resource Respond to radiation RO#3 C47022 monitor alarms; enter RO#4 X C4AOP2 tube leak procedure SRO#2 Page SM, STA, and N/A SRO#1 X SEC to control room RO#3 2E-0 Rx Trip/SI Response RO#4 X SRO#2 AO#4 2E-0, Att J MSR Isolation X AO#6 Verify Cat 1 Vent 2E-0, Att L AO#1 X Doors Closed SM F3-2 Review EALs X STA Assist with completion PINGP 577 of Event Notification SEC X form (State/County)

SM F3-2 Classify event X STA PINGP 580 Notify offsite agencies SEC X PINGP 1384 and activate ERO Complete NRC PINGP 666 Notification Form and SRO#1 X notify NRC RO#3 SGTR response RO#4 actions (includes reset X SRO#2 2E-3 of SI)

STA S/D diesels and AO#4 X

cooling water pumps AO#6 Attachment L (validate 2E-0 SI alignment/realign RO#2 X equipment)

Perform initial Alert Actions and plant PA SM X PINGP 1125 announcements Alert Actions - notify SM X 21



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Prairie Island Timing Template - Table 2A Scenario: #6

Title:

Steam Generator Tube Rupture Procedure Step/Actions Performance Time (mins) After Procedure Implementation Assigned Proc/Step Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70 70-75 75-80 80-85 85-90 Resource RP/Chem for onsite sampling and dose calculations RO#2 RO#3 Post-trip S/G RO#4 2ES-3.1 X cooldown actions SRO#2 STA SM 2ES-3.1, Step Sample S/G and RCS Chem X

4 for boron Tech







22



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 3 - Firefighting Analysis # 6



TaskAnalysis

Line PerformedBy

ControllingMethod

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



Notes:NoFireBrigaderesponserequiredforthisevent.



23



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 4 - Radiation Protection and Chemistry Analysis # 6 PerformanceTimePeriodAfterEmergencyDeclaration(minutes)

Line PositionPerformingFunction/Task 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85

5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1.  InPlantSurveysviaERCS

 X

OnshiftPosition:RPSpecialist#1

2.  OutofPlantSurvey

                 

OnshiftPosition:

3.  PersonnelMonitoring

                 

OnshiftPosition:

4.  JobCoverage

OnshiftPosition:RPSpecialist#1&RP     ReporttotheOSCforfurtherinstructions.

Specialist#2

5.  OffsiteRadiologicalAssessment

      X

OnshiftPosition:ChemistryTechnician

6.  OtherSiteSpecificRP-Describe:

                 

OnshiftPosition:

7.  Chemistryfunction/task#1-Describe:

X

SampleS/GandRCSforBoron            

(IdentifiedConflict)

OnshiftPosition:ChemistryTechnician

8.  Chemistryfunction/task#2-Describe:

                 

OnshiftPosition:





24



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 5 - Emergency Plan Implementation Analysis # 6



TaskAnalysis

Line Function/Task OnshiftPosition

ControllingMethod

1.  DeclaretheEmergency ShiftManager EP/OpsTrainingandEP

ClassificationLevel(ECL) DrillProgram

2.  ApproveOffsiteProtectiveAction ShiftManager EP/OpsTrainingandEP

Recommendations DrillProgram

3.  ApprovecontentofState/Local ShiftManager EP/OpsTrainingandEP

notifications DrillProgram

4.  Approveextensiontoallowable ShiftManager EP/OpsTrainingandEP

doselimits DrillProgram

5.  Notificationanddirectiontoon SRO#1/ShiftManager EP/OpsTrainingandEP

shiftstaff(e.g.,toassemble, DrillProgram

evacuate,etc.)

6.  EROnotification SEC EP/OpsTrainingandEP

DrillProgram

7.  AbbreviatedNRCnotificationfor N/A EP/OpsTrainingandEP

DBTevent DrillProgram

8.  CompleteState/Localnotification SEC EP/OpsTrainingandEP

form DrillProgram

9.  PerformState/Localnotifications SEC EPTrainingandEPDrill

Program

10.  CompleteNRCeventnotification SRO#1 EP/OpsTrainingandEP

form DrillProgram

11.  ActivateERDS SEC EP/OpsTrainingandEP

DrillProgram

12.  Offsiteradiologicalassessment N/A N/A

13.  PerformNRCnotifications SRO#1 EP/OpsTrainingandEP

DrillProgram

14.  Performothersitespecificevent SEC EP/OpsTrainingandEP

notifications(e.g.,INPO,ANI,etc.) DrillProgram

15.  Personnelaccountability N/A EP/SecurityTrainingand

EPDrillProgram



Notes: EALFA1-AlertClassification(ANYlossorANYPotentialLossofEITHERFuelCladorRCS.)

 



25



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 iii. Analysis #9 Large Break LOCA with release and resulting PARs Initial Conditions:

Time: Monday @ 2200 Unit 1 100% Power @ EOC RCS Temp 560qF Tave RCS Pressure 2235 psig Sequence of Events:

2200 Longitudinal crack develops on A Cold leg LB LOCA initiated (RCS leak rate > charging pump capacity) 2200:05 Rx trip and SI initiated based on low pressurizer pressure 2200:10 Avg CETC reading 950 qF 2200:15 B Train of SI fails Loss of Subcooling margin indicated 2200:30 Containment pressure = 33 psia 2201 Operators enter EOP/AOPs 2202 Emergency Plan initiated 2215 Initial Emergency Classification determined 2220 ERO activation initiated 2230 Initial notification to offsite agencies initiated 2235 Conditions degrade - Containment pressure drops from 15 lbs. to 0 lbs. -

reason unknown.

General Emergency Conditions exist Release occurs PARs required



26



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Analysis #9: Large Break LOCA with release & resulting PARS ECL: Site Area Emergency General Emergency TABLE 1 - On-shift Positions

  

Augmentation

Rolein Unanalyzed TMS

Line OnshiftPosition EmergencyPlanReference ElapsedTime

Table#/Line# Task? Required?

(min)

1.  ShiftManager PINGPEPlan,Table1,Rev47 T2/L1 No No

T5/L1

T5/L2

N/A

T5/L3

T5/L4

T5/L5

2.  UnitSupervisor(SRO#1) PINGPEPlan,Table1,Rev47 N/A T2/L2 No No

3.  UnitSupervisor(SRO#2) PINGPEPlan,Table1,Rev47 T2/L3 No No

T5/L5

N/A

T5/L10

T5/L13

4.  ShiftTechnicalAdvisor(STA) PINGPEPlan,Table1,Rev47 N/A T2/L4 No No

5.  ReactorOperator(RO#1) PINGPEPlan,Table1,Rev47 N/A T2/L5 No No

6.  ReactorOperator(RO#2) PINGPEPlan,Table1,Rev47 N/A T2/L6 No No

7.  AuxiliaryOperator(AO#1) PINGPEPlan,Table1,Rev47 N/A T2/L7 No No

8.  AuxiliaryOperator(AO#2) PINGPEPlan,Table1,Rev47 N/A T2/L8 No No

27



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Augmentation

Rolein Unanalyzed TMS

Line OnshiftPosition EmergencyPlanReference ElapsedTime

Table#/Line# Task? Required?

(min)

9.  AuxiliaryOperator(AO#3) PINGPEPlan,Table1,Rev47 N/A T2/L9 No No

10.  AuxiliaryOperator(AO#5) PINGPEPlan,Table1,Rev47 N/A T2/L10 No No

11.  ShiftEmergencyCommunicator(SEC) PINGPEPlan,Table1,Rev47 90 T5/L6 No No

T5/L8

T5/L9

T5/L11

T5/L14

12.  RPSpecialist(RP#1) PINGPEPlan,Table1,Rev47 90 T4/L1 No Yes

T4/L2

13.  RPSpecialist(RP#2) PINGPEPlan,Table1,Rev47 90 T4/L2 No Yes

T4/L3

14.  ChemistryTechnician PINGPEPlan,Table1,Rev47 90 T4/L5 No Yes

T4/L7

15.  CASOperator PINGPEPlan,Table1,Rev47 N/A T5/L15 No No

Notes: TheTimeMotionStudiesidentifiedinthisreportwereresolvedbytheadditionofoneadditionalRPSpecialistandoneChemistry

TechnicianasdescribedinSectionIIIofthisreport.

28



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 2 - Plant Operations & Safe Shutdown Analysis # 9 Two Units - One Control Room (Shared) Applicable to unit 1 Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable TaskPerformance

Line GenericTitle/Role OnshiftPosition

Validation

1.  ShiftManager ShiftManager OperatorTraining

2.  ShiftSupervisor UnitSupervisor-U1(SRO#1) OperatorTraining

3.  ShiftSupervisor UnitSupervisor-U2(SRO#2) OperatorTraining

4.  ShiftTechnicalAdvisor ShiftTechnicalAdvisor(STA) OperatorTraining

5.  ReactorOperator(OATC) ReactorOperator-U1OATC(RO#1) OperatorTraining

6.  ReactorOperator(BOP) ReactorOperator-U1BOP(RO#2) OperatorTraining

7.  AuxiliaryOperator AuxiliaryOperator(AO#1) OperatorTraining

8.  AuxiliaryOperator AuxiliaryOperator(AO#2) OperatorTraining

9.  AuxiliaryOperator AuxiliaryOperator(AO#3) OperatorTraining

10.  AuxiliaryOperator AuxiliaryOperator(AO#5) OperatorTraining



Notes: SeeTable2AforAOP/EOPactions







29



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Prairie Island Timing Template - Table 2A Scenario: #9

Title:

Large Break LOCA with release and resulting PARs Procedure Step/Actions Performance Time (mins) After Procedure Implementation Assigned Proc/Step Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70 70-75 75-80 80-85 85-90 Resource N/A Page SM, STA, and SRO#2 X SEC to control room 1E-0 RO#1 Rx Trip/SI Response RO#2 X SRO#1 1E-0, Att J AO#3 MSR Isolation X AO#5 1E-0, Att L Verify Cat 1 Vent AO#1 X Doors Closed F3-2 SM Review EALs X STA PINGP 577 Assist with completion of Event Notification SEC X form (State/County)

F3-2 SM Classify event X STA 1F-0 Monitor CSFTs in parallel with oversight STA X of EOPs PINGP 580 Notify offsite agencies SEC X PINGP 1384 and activate ERO PINGP 666 Complete NRC Notification Form and SRO#2 X notify NRC 1E-1 Response to loss of RO#1 RC or Secondary RO#2 X Coolant SRO#1 1E-0 Attachment L (validate SI alignment/realign RO#4 X equipment) 30



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Prairie Island Timing Template - Table 2A Scenario: #9

Title:

Large Break LOCA with release and resulting PARs Procedure Step/Actions Performance Time (mins) After Procedure Implementation Assigned Proc/Step Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70 70-75 75-80 80-85 85-90 Resource 1ES-1.2 Transfer to recirc RO#1 procedure steps RO#2 SRO#1 X AO#1 AO#2 F3-17.2 Monitor long term RO#2 X recirc procedure steps 1E-1 Response to loss of RO#1 RC or Secondary X SRO#1 Coolant S/D diesels and AO#3 X

cooling water pumps AO#5 PINGP 1125 Perform initial SAE Actions and plant PA SM X announcements/Plant Evacuation SAE Actions - notify RP/Chem for onsite sampling and dose SM X calculations and post evacuation monitoring EDCM-100 Chemistry complete Chem X

Dose Assessment Tech PINGP 1125 SAE Actions - RP to monitor assembly RP#1 X

area and Security RP#2 Building F3-9 Complete evacuation CAS X

accountability Operator F3-2 SM Review Classification X STA SM Classify GE X STA 31



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Prairie Island Timing Template - Table 2A Scenario: #9

Title:

Large Break LOCA with release and resulting PARs Procedure Step/Actions Performance Time (mins) After Procedure Implementation Assigned Proc/Step Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70 70-75 75-80 80-85 85-90 Resource Page SEC to report to Control Room (from SM X TSC)

PINGP 577 Complete Event SM X

Notification form STA PINGP 580 Notify offsite agencies SEC X PINGP 1125 Implement GE actions SM X of procedure



Indicates General Emergency Conditions Exist (Per methodology described in Reference 3, Section 2.10, Analysis of a General Emergency Response) 32



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 3 - Firefighting Analysis # 9



TaskAnalysis

Line PerformedBy

ControllingMethod

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



Notes:NoFireBrigaderesponserequiredforthisevent.





33



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 4 - Radiation Protection and Chemistry Analysis # 9 PerformanceTimePeriodAfterEmergencyDeclaration(minutes)

Line PositionPerformingFunction/Task 0 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85

5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1.  InPlantSurvey-SecurityBuilding

   X

OnshiftPosition:RPSpecialist#1

2.  OutofPlantSurvey X

   

OnshiftPosition:RPSpecialist (IdentifiedConflict)

3.  PersonnelMonitoring-AssemblyArea

   X

OnshiftPosition:RPSpecialist#2

4.  JobCoverage

                 

OnshiftPosition:

5.  OffsiteRadiologicalDoseAssessment

    X

OnshiftPosition:ChemistryTechnician

6.  OtherSiteSpecificRP-Describe:

                 

OnshiftPosition:

7.  Chemistryfunction/task#1-Describe:

X

ContainmentSampling    

(IdentifiedConflict)

OnshiftPosition:ChemistryTechnician

8.  Chemistryfunction/task#2-Describe:

                 

OnshiftPosition:





34



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 TABLE 5 - Emergency Plan Implementation Analysis # 9



TaskAnalysis

Line Function/Task OnshiftPosition

ControllingMethod

1.  DeclaretheEmergency ShiftManager EP/OpsTrainingandEP

ClassificationLevel(ECL) DrillProgram

2.  ApproveOffsiteProtectiveAction ShiftManager EP/OpsTrainingandEP

Recommendations DrillProgram

3.  ApprovecontentofState/Local ShiftManager EP/OpsTrainingandEP

notifications DrillProgram

4.  Approveextensiontoallowable ShiftManager EP/OpsTrainingandEP

doselimits DrillProgram

5.  Notificationanddirectiontoon SRO#2/ShiftManager EP/OpsTrainingandEP

shiftstaff(e.g.,toassemble, DrillProgram

evacuate,etc.)

6.  EROnotification SEC EP/OpsTrainingandEP

DrillProgram

7.  AbbreviatedNRCnotificationfor N/A EP/OpsTrainingandEP

DBTevent DrillProgram

8.  CompleteState/Localnotification SEC EP/OpsTrainingandEP

form DrillProgram

9.  PerformState/Localnotifications SEC EPTrainingandEPDrill

Program

10.  CompleteNRCeventnotification SRO#2 EP/OpsTrainingandEP

form DrillProgram

11.  ActivateERDS SEC EP/OpsTrainingandEP

DrillProgram

12.  Offsiteradiologicalassessment N/A N/A

13.  PerformNRCnotifications SRO#2 EP/OpsTrainingandEP

DrillProgram

14.  Performothersitespecificevent SEC EP/OpsTrainingandEP

notifications(e.g.,INPO,ANI,etc.) DrillProgram

15.  Personnelaccountability CAS EP/SecurityTrainingand

EPDrillProgram



Notes: EALFS1upgradedtoFG1-ThescenarioaspostulatedmeetsthedefinitionofaSiteArea

EmergencybasedontheFissionProductBarrierCriteria.Theextensionofthescenarioto

addressamajorreleasemeetstherequirementsforclassificationofaGeneralEmergency.

 



35



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013



III. FUNCTIONAL ANALYSIS The results of the staffing analysis for completion of functions associated with 30 and 60 minute responders are summarized in the tables below. Table E identifies by position, the results of the analysis for 30 minute responders. Table F provides a summary disposition for resolution of conflicts, if any, in order to extend the 30 minute response time to 90 minutes. Tables G and H provide summaries of analysis and dispositions for extension of 60 minute responder positions to 90 minutes.

Table E - Analysis of 30 Minute Responder Positions Position Title 30 minute relief responders Radiological Emergency Coordinator (REC) 1 A conflict for the Chemistry Technician in performing the on-shift dose assessment function and required chemistry sampling if the dose assessment function is not assumed by the REC at 30 minutes in accordance with the current augmentation criteria for the LOCA scenario. The REC also assumes responsibility for a site communication with the State of Wisconsin response personnel upon arrival. This communication is not identified as a conflict in the OSA because it is an assumed duty upon arrival. The extension of the commitment to 90 minutes would not be acceptable. The responsibility will be assumed by the Chemistry Technician assuming dose assessment responsibility. The additional responder is reflected in Table B of this report.

Radiation Protection 4 The June 2013 OSA for the LOCA scenario requires one additional on-shift RP Specialist responder to perform in-plant habitability. The additional responder is reflected in Table B of this report.

Technical Support - Core/Thermal 1 Function can be completed by the STA for the first 90 minutes without conflicts.

Electrical Maintenance 1 Function not required until after the 90 minute augmentation period.

Instrument Control 1 Function not required until after the 90 minute augmentation period.

Shift Emergency Communicator 1 Function can be performed by the Shift Emergency Communicator for 90 minutes without conflicts.



 

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Table F - Disposition of 30 Minute Responder Functions Function Performed by Performed by in Resolution in Current Revised Emergency Emergency Plan Plan Offsite Dose Assessment REC Chemistry A Second Chemistry Technician Technician will be added to the on-shift staff to perform chemistry sampling and State of Wisconsin communications.

With this addition, the REC position can be extended to 90 minute response.

Protective Actions RP Specialists RP Specialists An additional RP Specialist will be added to the current on-shift component to support the function prior to relief by the augmented ERO.

With this addition the remaining RP Specialists response positions can be extended to 90 minute response.

Core Thermal Nuclear STA The existing STA can continue Engineer to support the Core Thermal Function until relieved at 90 minutes without conflicts.

The Nuclear Engineer position can be extended to 90 minute response.

Repairs and Corrective Electrical Electrical The Electrical Maintenance Actions - Electrical Maintenance Maintenance position can be extended to 90 Maintenance minute response.

Repairs and Corrective Instrument Instrument and The IC Maintenance position Actions - IC and Control Control can be extended to 90 minute Technician Technician response.

Notification/Communication Communicator SEC The on-shift SEC can perform this function without conflicts until relieved by the augmented ERO.

The Communicator position can be extended to 90 minute response.



 

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Table G - Analysis of 60 Minute Responder Positions Position Title 60 minute responder Emergency Manager 1 Function can be performed by the Shift Manager for 90 minutes without any conflicts Radiation Protection 6 Function not required until after the 90 minute augmentation period.

On-shift Dose Assessment - Chemistry Technician 1 Current procedural requirements require chemistry sampling be performed within the first 90 minutes. The Chemistry Technician is also assigned as the on-shift dose assessor. These two functions cannot be supported with a single individual.

Technical Support - Electrical 1 Function not required until after the 90 minute augmentation period.

Technical Support - Mechanical 1 Function not required until after the 90 minute augmentation period.

Mechanical Maintenance 1 Function not required until after the 90 minute augmentation period.

Electrical Maintenance 1 Function not required until after the 90 minute augmentation period.

Shift Emergency Communicator 2 Function can be performed by the Shift Emergency Communicator for 90 minutes without conflicts.

Rad Waste Operator 1 Function not required until after the 90 minute augmentation period.

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 Table H - Disposition of 60 Minute Responder Functions Function Performed by Performed by in Resolution in Current Revised Emergency Emergency Plan Plan Command/Control Emergency Emergency The Emergency Manager Manager Manager position can be extended to 90 minute response.

Protective Actions RP Specialist RP Specialist The six RP Specialists can be extended to 90 minute response.

Chemistry Chemistry Chemistry A second on-shift Technician Technician chemistry technician will be added to perform required sampling.

Plant System Electrical Electrical The Electrical Engineering Engineering Engineering Engineering position can be extended to 90 minute response.

Plant System Mechanical Mechanical The Mechanical Engineering Engineering Engineering Engineering position can be extended to 90 minute response.

Repairs and Corrective Mechanical Mechanical The Mechanical Actions Maintenance Maintenance Maintenance position can be extended to 90 minute response.

Repairs and Corrective Rad Waste Rad Waste The Rad Waste Operator Actions Operator Operator position can be extended to a 90 minute response.

Repairs and Corrective Electrical Electrical The Electrical Maintenance Actions Maintenance Maintenance position can be extended to 90 minute response.



 

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Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 IV. CONCLUSIONS The June 2013 OSA concluded that with the addition of on-shift personnel, the 30 minute and 60 minute responder functions can be performed successfully and without conflicts. Additionally, the 30 minute and 60 minute responder augmentation requirement can be modified by the addition of on-shift personnel allowing for extension of TSC, OSC and EOF augmentation times to 90 minutes.

The following positions will be added to the shift as follows:

1. The addition of one on-shift Chemistry Technician to resolve the conflict between chemistry sampling and dose assessment. The second Chemistry Technician will assume responsibility for chemistry sampling and allow the first Chemistry Technician to continue with dose assessment responsibilities and assume the communications with the State of Wisconsin until augmented by the REC at 90 minutes.

2. The addition of one RP Specialist to resolve the conflict between required survey functions. The third RP Specialist on shift will provide needed support for surveys in assembly areas as well as in-plant locations as required.

The revised staffing proposed in Table B of this report meets the requirements in 10 CFR 50 Appendix E.IV.9 and the Planning Standards of 10 CFR 50.47(b).

V. REFERENCES

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

2. NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," Revision 0, dated June 2011.

VI. ACRONYM LIST ANI American Nuclear Insurers AO Auxiliary Operator AOP Abnormal Operating Procedure ARG Alarm Response Guide ATWS Anticipated Transient Without SCRAM (Safety Control Rod Axe Man)

Aux Auxiliary BOP Balance of Plant CAS Central Alarm Station CETC Core Exit Thermocouple CFR Code of Federal Regulations cpm counts per minute 40



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 CR Control Room CRS Control Room Supervisor CSFT Critical Safety Function Status Trees DBT Design Basis Threat E Plan Emergency Plan EAL Emergency Action Level ECL Emergency Classification Level ED Emergency Director ENS Emergency Notification System EOC End of Cycle EOF Emergency Operations Facility EOP Emergency Operating Procedures EP Emergency Preparedness ERCS Emergency Response Computer System ERDS Emergency Response Data System ERO Emergency Response Organization GE General Emergency IC Instrument and Control IN Information Notice INPO Institute of Nuclear Power Operations ISG Interim Staff Guidance LAR License Amendment Request LB LOCA Large Break Loss of Coolant Accident LOCA Loss of Coolant Accident min minute mins minutes MS Main Steam MSR Moisture Separator Reheater NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission OATC Operator at the Controls OSC Operational Support Center PAR Protective Action Recommendations psig pounds per square inch gauge PINGP Prairie Island Nuclear Generating Plant Rad Radiological RCCA Rod Cluster Control Assembly RCS Reactor Coolant System REC Radiological Emergency Communicator RG Regulatory Guide RO Reactor Operator RP Radiation Protection Rx Reactor SAE Site Area Emergency SEC Shift Emergency Communicator S/D Shutdown SG Steam Generator SGTR Steam Generator Tube Rupture 41



Augmentation Staffing Analysis Prairie Island Nuclear Plant Dec. 2013 SI Safety Injection SM Shift Manager SRO Senior Reactor Operator SS Shift Supervisor STA Shift Technical Advisor TMS Time Motion Study TSC Technical Support Center USAR Updated Safety Analysis Report



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