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

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

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

LR-N14-0141 JUN 16.2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

References:

Salem Generating Station Units 1 and 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311 Salem Generating Station's Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment

1.

NRC letter, "Request for Information Pursuant to Title 10 of the Code of Fedral Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012

2.

PSEG letter LR-N12-0143, "PSEG Nuclear LLC's 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident: dated March 12, 2012," dated May 10, 2012

3.

NEI 12-01, "Guideline for Assessing Beyond-Design-Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012

JUN 1 6 ?014 Page 2 LR-N14-0141

Background

10 CFR 50.54(f)

4.

NRC letter to NEI, "U.S. Nuclear Regulatory Commission Review of NEI 12-01, 'Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,' Revision 0, Dated May 2012," dated May 15, 2012

5.

PSEG letter LR-N13-0083, "Salem Generating Station's Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness-Staffing, Requested Information Items 1, 2, and 6 -

Phase 1 Staffing Assessment," dated April 26, 2013

6.

NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 On March 12, 2012, the NRC staff issued a request for information pursuant to 10 CFR 50.54(f), regarding the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident (Reference 1 ). Enclosure 5 of Reference 1 contains the specific Requested Actions, Requested Information, and Required Response associated with Recommendation 9.3 for Emergency Preparedness - Staffing. In accordance with Reference 1, Enclosure 5, PSEG Nuclear LLC (PSEG) submitted a 60-day response letter (Reference 2) to describe its course of action for performing the requested actions and providing the requested information. Consistent with the actions described in Reference 2, the Phase 2 responses to the NTTF Recommendation 9.3:

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

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

JUN 1 6 "014 Page 3 LR-N14-0141 10 CFR 50.54(f) to this letter provides the Phase 2 staffing assessment report for SGS Units 1 and 2. In accordance with Reference 2, Enclosure 1, this letter provides the response to the following information requests:

Reference 1, Enclosure 5, Staffing, Requested Information Item 1 Reference 1, Enclosure 5, Staffing, Requested Information Item 2 Reference 1, Enclosure 5, Staffing, Requested Information Item 6 Requested Information Item 1 It is requested that addressees provide an assessment of the on site and augmented staff needed to respond to a large scale natural event meeting the conditions described in the Discussion section (Reference 1, Enclosure 5). This assessment should include a discussion of the on site and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:

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

4. 2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-1, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.

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

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

Response to Requested Information Item 1 provides the requested Phase 2 staffing assessment. Response to the specific items included in Requested Information Item 1 is as follows The Phase 2 assessment concludes that the minimum complement of on-shift staff allowed by the current PSEG Emergency Plan, combined with two additional on-shift personnel to support site-wide (i.e., Hope Creek and SGS) equipment hauling and debris removal, are capable of responding to the Phase 2 scenario.

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

JUN *1 6 ?014 Page 4 LR-N14-0141 1 0 CFR 50.54(f) response functions prior to the delayed arrival of the augmented Emergency Response Organization (ERO).

Based on the results of this assessment, PSEG will establish administrative controls to ensure the availability of the two on-shift individuals assigned to the functions of site-wide equipment hauling and debris removal in support of FLEX strategy implementation.

The staffing assessment determined that personnel were not prevented from timely performance of their functions due to collateral duties. There are no conflicts or overlaps in functions or tasks required to be performed by on-shift operations and support personnel.

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

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

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

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

There are no regulatory commitments contained in this letter.

JUGI 16,U14 Page 5 LR-N14-0141 1 0 CFR 50.54(f)

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

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

Executed on __ C-./_t_,-+-/_1___:'1 (Date)

Sincerely, Jf.:**

Site Vice President Salem Generating Station : Salem Generating Station - Fukushima Response NEI 12-01 Phase 2 Staffing Assessment Report cc:

Mr. E. Leeds, Director of Office of Nuclear Reactor Regulation Mr. W. Dean, Administrator, Region I, NRC Mr. J. Lamb, Project Manager, NRC NRC Senior Resident Inspector, Salem Mr. P. Mulligan, Manager IV, NJBNE Salem Commitment Tracking Coordinator PSEG Corporate Commitment Coordinator

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

SALEM GENERATING STATtON FUKUSHIM'A RESPONSE.

NEI12

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

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

Table of Contents

1.

Executive Summary............................................................................................................... 1

2.

Introduction............................................................................................................................ 1

3.

Staffing Assessment Process Overview................................................................................ 2

4.

NEI 12-01 Phase 2 Assessment Results............................................................................... 4

5.

NEI 12-01 Phase 2 Actions................................................................................................... 5

6.

Staffing Assessment Details.................................................................................................. 5 6.1 Assumptions................................................................................................................... 6 6.1.1 NEI 12 Assumptions for Staffing Assessment................................................. 6 6.1.2 NEI 10 Applicable Assumptions....................................................................... 7 6.1.3 NEI 12-06 Assumptions........................................................................................... 7 6.1.4 Plant Specific Assumptions..................................................................................... 9 6.2 Methodology................................................................................................................... 9 6.3 Security Considerations................................................................................................ 11

7.

Strategy Resource Loading................................................................................................. 11

8.

Conclusions......................................................................................................................... 14

9.

References.......................................................................................................................... 14

10. Table of Acronyms............................................................................................................... 15

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

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

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

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

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

Salem G NEI 12-0 consider (first 24 the abilit during th

3. Staf Draft str (SGS Un analysis the on-s delayed The Pha the mini with the (consiste impleme enerating St 01 Phase 2 S rs required hours). Co ty to receiv he final pha ffing Asses rategies inc nits 1 and 2 s by a multi-shift staff to arrival of th ase 2 staffin mum staffin supplemen ent with NE ent the strat tation Staffing Asse actions pe onsistent w e and deplo ase (24+ ho ssment Pro cluding FSG 2, and HCG

-discipline t perform an he augmen ng assessm ng in the PS ntal staff all EI 12-06). T tegies cons essment Re rformed du ith NEI 12-0 oy offsite re ours followin ocess Ove Gs for respo GS) were ev team. The ny required nted Emerge ment require SEG Emerg owed by m Table 3-1 id sidered in th port 2

ring the init 01 and NEI esources ar ng the ELA erview onding to an valuated du staffing ana emergency ency Respo es that the gency Plan minimum ad dentifies the his staffing tial and tran I 12-06, nea re consider AP).

n ELAP affe uring the NE alysis also y response onse Organ ELAP scen (consisten ministrative e personne assessmen nsition phas ar-normal s red to be es ecting all on EI 12-01 Ph addressed e functions p nization (ER nario be eva nt with NEI e staffing pr el that were nt.

ses of an E site access stablished n-site units hase 2 staff the ability prior to the RO).

aluated usin 12-01) alon rocedures used to ELAP and fing of ng ng

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 3

1 One Unit Supervisor assigned to each unit.

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

3 This position is staffed by a dedicated Equipment Operator.

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

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

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

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

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

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

Table 3-1 PSEG Nuclear LLC Emergency Plan, Rev 28 On-Shift Staffing Emergency Response Organization Supplemental Administrative Staff (NEI 12-06)

Position On-shift On-Shift Shift Manager (SM) 1 Control Room Supervisor (SRO) 1 2

Field Supervisor/Initial Operations Support Center (OSC) Coordinator 1

Shift Technical Advisor (STA) 1 Reactor Operator (RO) 2 Plant Operator (RO) 2 Control Room Communicator 2 2

Equipment Operator (EO) 5 Radwaste Operator 3 (EO) 1 Radiation Protection (RP)

Technician 4 4

Chemistry Technician 5 2

Shift Maintenance Supervisor 1

Scheduled I&C Technician 8 2

Shift Electrician 8 2

Total:

28 Fire Department 6 5

Rescue Operations/First Aid 7 2

Security Sec plan MM resources9 2

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 4

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

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

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

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

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

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

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 5

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

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

Table 6-1 Phase 2 Assessment Participants Personnel (Position/Title)

Number Organization/Department Senior Reactor Operator (SRO) 2 Fukushima Team (formerly licensed at SGS)

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

Nuclear Equipment Operator (NEO) 1 Operations Radiation Protection Technician 1

RP Chemistry Superintendent 1

Chemistry EP Manager 1

EP Fire Department Supervisor 1

Site Protection Maintenance Supervisor 1

Maintenance EP Specialist 2

EP Consulting, LLC

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 6

6.1 Assumptions The extended loss of AC power event was evaluated using the following assumptions, consistent with NEI 12-01, NEI 12-06, and applicable assumptions from NEI 10-05.

6.1.1 NEI 12 Assumptions for Staffing Assessment

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

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

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

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

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

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

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

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 7

6.1.2 NEI 10 Applicable Assumptions

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

6.1.3 NEI 12-06 Assumptions

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

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 8

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

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 9

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

6.1.4 Plant Specific Assumptions

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

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

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

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

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

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 10 Using only the on-shift positions entered in Appendix 1, Table 1, the following Appendix 1 tables were completed by entering the shift position that fills a described role, or performs a specific function or task:

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

Table 2A, Procedure Task Timing (Hurricane Response)

Table 2B, Procedure Task Timing (Tornado Response)

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

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

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

The assessment was conducted using the following process:

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

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

Salem Generating Station NEI 12-01 Phase 2 Staffing Assessment Report 11 6.3 Security Considerations Mitigation strategies for a BDBEE do not require the use of Security Department personnel to perform duties unrelated to their security roles, e.g., the SGS mitigation strategies do not rely on Security Officers to perform any collateral duties such as equipment hauling or debris removal.

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

Table 7-1 FLEX Support Guideline (FSG) Resource Requirements FSG Description Resources Duration Notes FSG-1 RCS Long Term RCS Inventory Control (Service Water to 13 Charging Pump)

EO (4)

RO (2) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Contingency Action FSG-2 Alternate Aux Feedwater Suction Source (align to HCGS FP Tank)

EO (2)

SP (2) 55 minutes Time sensitive -

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

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

extend battery capacity FSG-5 Initial Assessment and Flex Equipment Staging Vent generator H2 (both units)

SP (1) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Task completed in series by one person Att 1, Part 1

Restore 125 vdc Battery Chargers EO (2)

EM (1) 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Time sensitive -

battery charger restoration Att 1, Part 2

Restore 230 vac MCCs EO (2) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> N/A Att 2 Debris Removal and Equipment Transport for Salem MM (2) 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Performed in conjunction with HCGS debris removal and deployment (HCGS - 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />)

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

bus restoration Att 2 Energize the A 460/230 bus.

EO (2) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Time sensitive -

bus restoration Att 3 Debris removal and pump deployment (UHS)

MM (2) 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Time sensitive -

S/G Inventory Att 3 UHS pump hookup and SW header pressurized Sec (1)

EO (2)

MM(2) 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Time sensitive -

S/G Inventory (augmented resources used)

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

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

EO (4) 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Contingency Action FSG-9 Low Decay Heat Temperature Control EO (2)

RO (2) 30 minutes Contingency Action FSG-10 Passive RCS Injection Isolation RO (2) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> N/A FSG-11 Alternate Spent Fuel Pool Makeup and Cooling (Makeup from Fresh/Fire Protection)

EO ( 2) 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Not required during initial or transition phase

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

14

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

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

9. References
1. NRC letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, March 12, 2012
2. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide, Revision 0, August 2012
4. NEI 10-5, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0, June 2011
5. PSEG Nuclear LLC Emergency Plan Revision 28
6. OP-SA-112-101-1001 Revision 3, Shift Turnover Responsibilities (Attachment 18)
7. OP-HC-112-101-1001 Revision 18, Shift Turnover Responsibilities (Attachment 5)
8. FP-AA-012 Revision 2, Fire Protection Organization, Duties and Staffing
9. OP-AA-101-111 Revision 4, Roles and Responsibilities of On-Shift Personnel

15

10. Table of Acronyms Acronym Definition AC Alternating Current AFW Auxiliary Feed Water AOP Abnormal Operating Procedure BDBEE Beyond-Design-Basis External Event B/O Blackout BOP Balance of Plant CFST Critical Function Status Tree CT Chemistry Technician DC Direct Current DG Diesel Generator ELAP Extended Loss of AC Power EM Electrical Maintenance EO Equipment Operator EOP Emergency Operating Procedure EP Emergency Plan ERO Emergency Response Organization (on shift and supplemental)

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

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

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

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

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

Plant Operator PO1 Unit 1 Balance of Plant (BOP)

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

Plant Operator PO2 Unit 2 Balance of Plant (BOP)

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

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

RP Technician RP2 RP Support (ORPT)

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

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

Action Required?

1.

Shift Manager/SM PSEG Nuclear LLC - EP, Figure 3-1 T2/L1 T5/L1 T5/L2 T5/L3 T5/L5 T5/L6 T5/L7 T5/L9 T5/L13 No

2.

Control Room Supervisor - U1 (SRO1)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L2 No

3.

Control Room Supervisor - U2 (SRO2)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L3 No

4.

Reactor Operator - U1 OATC (RO1)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L4 No

5.

Plant Operator - U1 BOP (PO1)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L5 No

6.

Reactor Operator - U2 OATC (RO2)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L6 No

7.

Plant Operator - U2 BOP (PO2)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L7 No

8.

Shift Technical Advisor (STA)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L8 No

9.

CR Communicator (CM1)

(Equipment Operator)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L15 T5/L8 No Note 1

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

Action Required?

10.

CR Communicator (CM2)

(Reactor Operator)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L16 T5/L8 T5/L12 No Note 1

11.

Equipment Operator (EO1)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L9 No

12.

Equipment Operator (EO2)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L10 No

13.

Equipment Operator (EO3)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L11 No

14.

Equipment Operator (EO4)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L12 No

15.

Equipment Operator (EO5)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L13 No

16.

Equipment Operator - Radwaste Operator (EO6)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L14 No

17.

RP Technician (RP1)

PSEG Nuclear LLC - EP, Figure 3-1 T4/L1 No

18.

RP Technician (RP2)

PSEG Nuclear LLC - EP, Figure 3-1 T4/L3 No

19.

Shift Maintenance Supervisor (SMS)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L17 No

20.

Scheduled I&C Technician (IC1)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L18 No

21.

Shift Electrician (EM1)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L19 No

22.

Site Protection (SP2)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L20 No

23.

Site Protection (SP3)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L21 No

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

Action Required?

24.

Site Protection (SP4)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L22 No Note 2

25.

Site Protection (SP5)

PSEG Nuclear LLC - EP, Figure 3-1 T2/L23 No

26.

Maintenance Mechanic (MM1)

N/A T2/L24 Yes Note 3

27.

Maintenance Mechanic (MM2 -

HCGS)

N/A T2/L25 Yes Note 3

28.

Security PSEG Nuclear LLC - EP, Figure 3-1 T5/L14 No Notes:

Note 1 - No conflict; Table 2 and Table 5 functions are the same.

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

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

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

1.

Shift Manager Shift Manager Operator Training

2.

Shift Supervisor Control Room Supervisor - U1 (SRO1)

Operator Training

3.

Shift Supervisor Control Room Supervisor - U2 (SRO2)

Operator Training

4.

Reactor Operator (OATC)

Reactor Operator - U1 (RO1)

Operator Training

5.

Reactor Operator (BOP)

Plant Operator - U1 (PO1)

Operator Training

6.

Reactor Operator (OATC)

Reactor Operator - U2 (RO2)

Operator Training

7.

Reactor Operator (BOP)

Plant Operator - U2 (PO2)

Operator Training

8.

Shift Technical Advisor Shift Technical Advisor (STA)

Operator Training

9.

Auxiliary Operator Equipment Operator (EO1)

Operator Training

10.

Auxiliary Operator Equipment Operator (EO2)

Operator Training

11.

Auxiliary Operator Equipment Operator (EO3)

Operator Training

12.

Auxiliary Operator Equipment Operator (EO4)

Operator Training

13.

Auxiliary Operator Equipment Operator (EO5)

Operator Training

14.

Auxiliary Operator Equipment Operator (EO6)

Operator Training

15.

Auxiliary Operator Control Room Communicator (CM1)

EP Training

16.

Reactor Operator Control Room Communicator (CM2)

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

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

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

17. Shift Maintenance Supv Shift Maintenance Supervisor (SMS)

EP/Maintenance Training

18. I&C Technician Scheduled I&C Technician (IC1)

I&C Training

19. Electrician Shift Electrician (EM1)

Electrical Mnt Training

20. Fire Brigade Site Protection (SP2)

Fire Brigade Training

21. Fire Brigade Site Protection (SP3)

Fire Brigade Training

22. Fire Brigade Site Protection (SP4)

Fire Brigade Training

23. Fire Brigade Site Protection (SP5)

Fire Brigade Training

24. Maintenance Maintenance Mechanic (MM1)

Maintenance Training

25. Maintenance Maintenance Mechanic (MM2)

(HCGS)

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

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

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

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-1 Step 1-9 Post Trip Actions SRO1 SRO2 RO1 PO1 RO2 PO2 x

S1-OP-SO-AF-0001 S2-OP-SO-AF-0001 Identify AF source.

PO1 PO2 x

FSG-2 Align AFW source (flood water)

EO1 EO2 x

FSG-2 Monitor and control Aux Feed EO1 EO2 x

EP-EP-102 Enter Emergency Plan SM CM1 CM2 SMS x

x EOP-CFST-1 Monitoring CFSTs STA x

EOP-LOPA-1 Step 10 Deenergize SECs PO1 PO2 EO3 EO4 x

EOP-LOPA-1,step 10.1 Perform B/O coping actions, includes initial 125vdc load shed.

PO1 PO2 EO5 EO6 x

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-1 Steps12-14 Vital Power restoration RO1 RO2 x

EOP-LOPA-1 Steps12-15 Start Diesel Generators EO3 EO4 IC1 EM1 x

EOP-LOPA-1, step 18 Align charging pump suction Prioritized by SM as resources are available EOP-LOPA-1, step 19 Service water isolation Prioritized by SM as resources are available EOP-LOPA-1, step 21-23 SI Initiation and reset RO1 RO2 x

EOP-LOPA-1, step 24 Remove control power from MDAFP Prioritized by SM as resources are available EOP-LOPA-1, step 25 Restore Off-site power Per AB-LOOP-1 PO1 PO2 x

EOP-LOPA-1, step 27 Isolate RCP seals EO3 EO4 x

EOP-LOPA-1, step 28 Isolate S/G RO1 RO2 x

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-1, step 29 ELAP declaration SM SRO1 SRO2 x

EOP-LOPA-4 Step 1 Implement FSG-4 FSG-4 Perform the Deep Load shed.(1.5 hr completion time)

EO5 EO6 x

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

FSG-5 Att 2 Energize Flex 480 VAC bus, EO5 EO6 x

FSG-5 Att 2 Energize the A 460/230 bus.

EO5 EO6 x

FSG-5 Vent generator H2 SP4 x

FSG-5 Att 3 Initiate Att 3 (SW),

debris removal and pump deployment (UHS)

ERO Augment MM1 MM2(HCGS) x FSG-5 Att 3 UHS pump hookup and SW header pressurized ERO Augment Sec (1)

Ops (2)

Maint (2) x FSG-3 Low Pressure AF Prioritized by SM as resources are available

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-4 Step 12-13 Depressurize S/Gs RO1 RO2 x

EOP-LOPA-4 Step 16.1 Initiate FSG-8 FSG-8 Att 1 Section 2.3 Alternate RCS boration from Boric Acid Storage Tank.

RO1 RO2 EO1 EO2 x (Periodic)

FSG-10 Isolate accumulators RO1 RO2 x

FSG-5 Att. 1 Part 2 Energize remaining 230 VAC busses.

EO3 EO4 x

EOP-LOPA-4 Step 16.5 S/G depressurization for Long Term Cooling RO1 RO2 x

EOP-LOPA-4 Step 20 Return to Step 3 RO1 RO2 FSG-5 Fuel Flex Generators Augment EO (1) x x

x x

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

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

Task completion time estimate

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

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

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-1 Step 1-9 Post Trip Actions SRO1 SRO2 RO1 PO1 RO2 PO2 x

S1-OP-SO-AF-0001 S2-OP-SO-AF-0001 Identify AF source.

PO1 PO2 x

FSG-2 Align AFW source Feed Steam Generators (HCGS FP Tank)

EO1 EO2 SP2 SP3 x

(55 minute task)

FSG-2 Align AFW source and monitor fire pump (FP crosstie)

SP5 x

FSG-5 Att 7 Monitor and control AFW EO1 EO2 x

EP-EP-102 Enter Emergency Plan SM CM1 CM2 SMS x

x EOP-CFST-1 Monitoring CFSTs STA x

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-1 Step 10 Deenergize SECs PO1 PO2 EO3 EO4 x

EOP-LOPA-1,step 10.1 Perform B/O coping actions, includes initial 125vdc load shed.

PO1 PO2 EO5 EO6 x

EOP-LOPA-1 Steps12-14 Vital Power restoration RO1 RO2 x

EOP-LOPA-1 Steps12-15 Start Diesel Generators EO3 EO4 IC1 EM1 x

EOP-LOPA-1, step 18 Align charging pump suction Prioritized by SM as resources are available EOP-LOPA-1, step 19 Service water isolation Prioritized by SM as resources are available EOP-LOPA-1, step 21-23 SI Initiation and reset RO1 RO2 x

EOP-LOPA-1, step 24 Remove control power from MDAFP Prioritized by SM as resources are available

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-1, step 25 Restore Off-site power Per AB-LOOP-1 PO1 PO2 x

EOP-LOPA-1, step 27 Isolate RCP seals EO3 EO4 x

EOP-LOPA-1, step 28 Isolate S/G RO1 RO2 x

EOP-LOPA-1, step 29 ELAP declaration SM SRO1 SRO2 x

EOP-LOPA-4 Step 1 Implement FSG-4 FSG-4 Perform the Deep Load shed.(1.5 hr completion time)

EO5 EO6 x

FSG-5 Att 2 Debris removal and towing.

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

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

FSG-5 Att 2 Energize the A 460/230 bus.

EO5 EO6 x

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 FSG-5 Vent the Main Generator SP4 x

FSG-5 Att 3 Initiate Att 3 (SW),

debris removal and pump deployment (UHS)

MM1 MM2(HCGS) x FSG-5 Att 3 UHS pump hookup and SW header pressurized ERO Augmentation Sec (1)

Ops (2)

Maint (2) x FSG-2 Shift Aux feed suction to SW EO (2) x FSG-3 Low Pressure AF Prioritized by SM as resources are available EOP-LOPA-4 Step 12-13 Depressurize S/Gs RO1 RO2 x

EOP-LOPA-4 Step 16.1 Initiate FSG-8 FSG-8 Att 1 Section 2.3 Alternate RCS boration from Boric Acid Storage Tank.

RO1 RO2 EO1 EO2 X (Periodic)

FSG-10 Isolate accumulators RO1 RO2 x

FSG-5 Att. 1 Part 2 Energize remaining 230vac busses.

EO3 EO4 x

Procedure Step/Actions Performance Time After Procedure Implementation Minutes - Hour 1 Hour Step Task Resource 0-10 10 20 20 30 3

0-4 0

4 0-5 0

5 0-6 0

2 3

4 5

6 7

8 9

1 0

1 1

1 2

1 3

1 4

15 1

6 1

7 1

8 1

9 2

0 2

1 2

2 2

3 2

4 EOP-LOPA-4 Step 16.5 S/G depressurization for Long Term Cooling RO1 RO2 x

EOP-LOPA-4 Step 20 Return to Step 3 RO1 RO2 FSG-5 Fuel Flex generators Augment EO (1) x x

x x

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

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

Task completion time estimate

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

1.

Not required by scenario N/A

2.

Not required by scenario N/A

3.

Not required by scenario N/A

4.

Not required by scenario N/A

5.

Not required by scenario N/A Notes: Fire Brigade response not required for this event.

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

1. In-Plant Survey On-Shift Position: RP1 X
2. Out of Plant Survey On-Shift Position: RP2
3. Personnel Monitoring On-Shift Position:

X (Control Point Coverage)

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

Describe:

On-Shift Position:

7. Chemistry function/task #1

- Describe:

On-Shift Position: CT1 Note 1

8. Chemistry function/task #2

- Describe:

On-Shift Position: CT1 Note 1 Notes:

Note 1 - The Phase 2 scenario did not result in the use of this on-shift position.

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

TABLE 4 - Radiation Protection & Chemistry Line Position Performing Function/Task Performance Time Period After Event Initiation (hours) 10-11 11-12 12-13 13-14 14-15 15-16 16-17 17-18 18-19 19-20 20-21 21-22 22-23 23-24

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

Describe:

On-Shift Position:

7. Chemistry function/task #1 -

Describe:

On-Shift Position: CT1

8. Chemistry function/task #2 -

Describe:

On-Shift Position: CT2 Notes:

Augmented resources available to support actions after T=6 hours. No response actions identified requiring support.

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

1.

Declare the Emergency Classification Level (ECL)

Shift Manager

2.

Approve Offsite Protective Action Recommendations Shift Manager

3.

Approve content of State/local notifications Shift Manager

4.

Approve extension to allowable dose limits Not Required

5.

Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

Shift Manager

6.

ERO notification Shift Manager Note 1

7.

Complete State/local notification form Shift Manager

8.

Perform State/local notifications CM1 CM2

9.

Complete NRC event notification form Shift Manager

10.

Activate ERDS Not Available

11.

Offsite radiological assessment Not Available Note 2

12.

Perform NRC notifications CM2

13.

Perform other site-specific event notifications (e.g., INPO, ANI, etc.)

Shift Manager

14.

Personnel accountability Security Notes: Note 1 - Self activation of ERO based on event (wide spread loss of grid)

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

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