CP-201500549, Submittal of Phase 2 Staffing Assessment Regarding Recommendation 9.3 (Staffing) and Updated Commitments Regarding Recommendation 9.3 (Communications and Staffing)

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Submittal of Phase 2 Staffing Assessment Regarding Recommendation 9.3 (Staffing) and Updated Commitments Regarding Recommendation 9.3 (Communications and Staffing)
ML15161A318
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/01/2015
From: Flores R, Madden F
Luminant Generation Co, Luminant Power
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201500549, TAC ME8686, TAC ME8687, TXX-15084
Download: ML15161A318 (32)
v • d • e


Text

W Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 rafael.flores@luminant.com Glen Rose, TX 76043 Luminant T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201500549 REF 10 CFR 50.54(f)

Log # TXX-15084 June 1, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 And 50-446, Submittal of Phase 2 Staffing Assessment Regarding Recommendation 9.3 (Staffing) and Updated Commitments Regarding Recommendation 9.3 (Communications and Staffing)

(TAC NOS. ME8686 and ME8687)

REFERENCES:

1. Luminant Power Letter TXX-12096 dated June 5, 2012, Response to Request for Information Regarding Recommendation 9.3 (Phase 2 Staffing)

(ML12177A055)

2. Luminant Power Letter TXX-14067 dated May 15, 2014, Revised Response to Request for Information Regarding Recommendation 9.3 (Phase 2 Staffing)

(ML14143A400)

3. Luminant Power Letter TXX-14107 dated October 30, 2014, Updated Response to Request for Information Regarding Recommendation 9.3 (Communications and Staffing)

Dear Sir or Madam:

References 1 and 2 provided Luminant Generation Company LLC's (Luminant Power) responses to an NRC letter entitled, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident" (ML12053A340). Luminant Power is submitting the Phase 2 staffing assessment (Attachment 2 to this letter) as committed to in References 1 and 2. Attachment 1 of this letter also provides an updated status for the three regulatory commitments previously discussed in Reference 2.

Reference 3 provided an updated response to five conumTitments / enhancements (communications and staffing) related to an NRC 10CFR50.54(f) request for information (ML12053A340). The status for these five commitments / enhancement is updated as described in Attachment 1 to this letter.

Attachment 1 includes eight updated regulatory commitments and one new regulatory commitment.

P U. S. Nuclear Regulatory Commission TXX-15084 Page 2 of 2 06/01/2015 If you have any questions regarding this submittal, please contact Carl B. Corbin at 254-897-0121 or carl.corbin@luminant.com.

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

Executed on June 1, 2015.

Sincerely, Luminant Generation Company LLC Rafael Flores ed W. Madden-Director, External Affairs Updated Regulatory Commitments Related to Recommendation 9.3 of the Near Term Task Force Report CPNPP Phase 2 Staffing Assessment c- William M. Dean, Director, Office of Nuclear Reactor Regulation Marc L. Dapas, Region IV Jessica A. Kratchman, NRR/JLD/PMB Balwant K. Singal, NRR Stephen A. Monarque, NRR Resident Inspectors, Comanche Peak

Attachment 1 to TXX-15084 Page 1 of 2 Updated Regulatory Commitments Related to Recommendation 9.3 of the Near Term Task Force Report Commitment Scheduled Completion Comments Commitment Description Number Date Conduct and provide results for an onsite and augmented staffing 4 months prior to This commitment is completed by assessment considering functions related to NTTF beginning of 2RF15 submittal of letter TXX-15084 Recommendation 4.2. [Phase 2 staffing assessment for Staffing 4392932 refueling outage Request 1] (est. June 2015)

Provide a schedule of the time needed to implement changes 4 months prior to This commitment is completed by associated with the Phase 2 staffing assessment. [for Staffing beginning of 2RF15 submittal of letter TXX-15084. New Request 2] 4392952 refueling outage commitment 5061030 provides schedule (est. June 2015) to implement changes associated with Phase 2 staffing assessment Identify changes associated with the Phase 2 staffing assessment 4 months prior to This commitment is completed by that have been made or will be made to your emergency plan beginning of 2RF15 submittal of letter TXX-15084. New regarding the on-shift or augmented staffing changes necessary to refueling outage commitment 5061030 provides schedule respond to a loss of all AC power, multi-unit event, including any 4392956 (est. June 2015) to implement changes associated with new or revised agreements with offsite resource providers [for Phase 2 staffing assessment Staffing Request 6].

A supplemental method to the PA system capability for emergency 4508353 June 1, 2015 This commitment / enhancement is notification to the plant staff will be implemented as required to now being tracked as gap # 11 in Section support emergency notification to essentially 100% of plant staff 9 of the CPNPP Phase 2 Staffing within 30 minutes. Assessment (Attachment 2 to TXX-15084) (see new commitment 5061030 below), therefore commitment number 4508353 is being closed.

Plant modification to the Intraplant Sound-Powered Telephone 4509320 June 1, 2015 This plant modification is complete (this System to enhance protection from external events will be commitment is complete) implemented as required to support essential communications for event response.

Attachment 1 to TXX-15084 Page 2 of 2 Updated Regulatory Commitments Related to Recommendation 9.3 of the Near Term Task Force Report Commitment Scheduled Completion Conments Commitment Description Number Date Integrate the expanded response capability into existing 4630659 Prior to The scheduled due date has been augmented Emergency Response Organization (ERO) processes Implementation of revised from June 1, 2015 to prior to (i.e., the ability to transition from a single-unit to a multi-unit Order EA-12-049 in implementation of order EA-12-049 expanded response capability). 2RF15 Refueling outage (Fall 2015)

Develop plans/procedures that address the use of expanded 4630672 Prior to The scheduled due date has been response capability in the on-site/near-site primary and alternate Implementation of revised from June 1, 2015 to prior to emergency response facilities (e.g., OSC and TSC) for declared Order EA-12-049 in implementation of order EA-12-049 emergency events that involve more than one-unit at multi-unit 2RF15 Refueling sites. This should include the relocation of expanded response outage (Fall 2015) capability to the alternate emergency response facility, should the primary emergency response facility be rendered inoperable.

Identify and Integrate into the ERO notification /activation 4630681 June 1, 2015 This commitment / enhancement is protocol those non-ERO response personnel (e.g., Operations and now being tracked as gap # 5 in Section Maintenance) necessary to support expanded response capability 9 of the CPNPP Phase 2 Staffing functions. Assessment (Attachment 2 to TXX-15084) (see new commitment 5061030 below), therefore commitment number 4630681 is being closed.

Complete the gaps identified in Section 9 of the CPNPP Phase 2 5061030 Prior to This is a new commitment in TXX-Staffing Assessment (Attachment 2 to TXX-15084) Implementation of 15084. It also incorporates actions Order EA-12-049 in previously tracked by commitments 2RF15 Refueling 4508353 and 4630681.

outage (Fall 2015)

Attachment 2 to TXX-1 5084 Page 1 of 28 LUMINANT POWER COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 AND 2 NEI 12-01 PHASE 2 STAFFING ASSESSMENT Revision 0 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT I

Attachment 2 to TXX-15084 Page 2 of 28 Table of Contents 1 Introduction .................................................................................................................................. 3 2 Analysis O verview ....................................................................................................................... 4

" Staffing Analysis Scope ................................................................................................. 4 M ethodology .................................................................................................................... 5 3 Analysis Sum m ary ...................................................................................................................... 5 4 Assum ptions ................................................................................................................................ 6

" NEI 12-01 Assum ptions ......................................................................................... 6

  • NEI 10-05 Assum ptions ................................................................................................ 7 5 Event Staffing Analysis ............................................................................................................ 8

" M inim um O n-Shift Staffi ng ............................................................................................ 8

  • Scenario O verview ......................................................................................................... 9
  • Staffi ng Analysis Sum m ary ............................................................................................ 9 6 FLEX Response Analysis .......................................................................................................... 17 S FLEX Detaills .................................................................................................................... 17 0 On-Site Staff Ability to Move Back-up Equipment ........................................ 18
  • FLEX Analysis Sum m ary .............................................................................................. 18 7 Program Controls ....................................................................................................................... 20

" Em ergency Response Drills & Exercise Program ........................................................ 20 Training ............................................................................................................................

T 20 8 Security Consideration .............................................................................................................. 20 9 Identified Issues ......................................................................................................................... 21 10 References .................................................................................................................................... 22 Attachm ent 1, NEI 10-05 Tables ........................................................................................... 24 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 2

Attachment 2 to TXX-15084 Page 3 of 28

1. Introduction In May, 2012, NEI published NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities". These guidelines provide criteria to assist with the preparation of assessments used to determine the required staff needed to respond to a Beyond Design Basis External Event (BDBEE) that affect multiple units at a site, and the identification of enhancements that could provide a means to power equipment needed to communicate with on-site and offsite personnel during an extended loss of AC power event. These assessments were necessary for responding to certain information requests contained in US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated March 12, 2012.

As discussed in SECY-1 1-0137, "Prioritizationof Recommended Actions to be taken in Response to Fukushima Lessons Learned', dated October 3, 2011, responses to the information requests will be used to inform possible future regulatory actions. A 2-phase approach was used to respond to the information requests associated with staffing.

The Phase 1 staffing assessment, performed in response to the Letter was submitted by April 30, 2013, considered all requested functions except those related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2. This Phase 2 staffing assessment considers the requested functions related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2.

Recommendation 4.2 requires a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase requires the use of installed equipment and resources to maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.

Additionally, the event analyzed impedes site access such that for the first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> no personnel from off-site can access the site, from 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> there is limited site access and after 24+ hours there is improved site access.

Section IV.A.9 of 10 CFR 50, Appendix E, states that nuclear power reactor licensees shall perform "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 Nuclear Energy Institute (NEI) On-Shift ERO Staffing Task Force developed NEI 10-05, "Assessmentof On-Shift Emergency Response OrganizationStaffing and Capabilities"to establish a standard methodology for performing analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency. Licensees used this methodology to meet the requirement of 10 CFR 50, Appendix E, Section IV.A.9 in a manner acceptable to the US Nuclear Regulatory Commission (NRC) staff. This was Comanche Peak Nuclear Power Plant's (CPNPP) first On-Shift Staffing Assessment (OSSA), conducted in June 2012. The methodology provided in this guidance was used to perform the Phase 1 and Phase 2 OSSAs.

This report provides the Phase 2 staffing assessment results for CPNPP Units 1 and 2.

3 PEAK PHASE 2 ON-SHIFT STAFFING 2 ON-SHIFT COMANCHE PEAK ASSESSMENT 3 COMANCHE PHASE STAFFING ASSESSMENT

Attachment 2 to TXX-15084 Page 4 of 28

2. Analysis Overview Staffing Analysis Scope All sites with one or more operating units are required to perform a Phase 2 staffing assessment no later than four months prior to the beginning of the second refueling outage (as used within the context of NRC Order EA-12-049). The Phase 2 assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2.

Licensees of multi-unit sites have two options for providing the Phase 2 staffing assessment:

  • Provide one Phase 2 staffing assessment applicable to all on-site units. This assessment should be provided four months prior to the first occurrence of a second refueling outage at the site (i.e., the first "second refueling outage"). This option may be used by sites that will employ essentially identical mitigation strategies for all on-site units.
  • Provide two or more Phase 2 staffing assessments as applicable to the different on-site units. Each assessment should be provided four months prior to the occurrence of the second refueling outage of the unit to which the assessment is applicable. This option may be used by all sites that will employ different mitigation strategies for on-site units.

CPNPP Unit 1 and Unit 2 staffing assessments were performed using the guidance of the first option to conduct one assessment applicable to both units. The intent of this assessment was to perform the following:

1. Evaluate the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, evaluate Transition Phase actions which must be performed prior to the end of the "no site access" time period.
  • Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.
  • Transition Phase - Implementation of strategies involving the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling. Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.
2. Evaluate the ability of the on-shift staff to implement the Station Blackout (SBO) coping strategies in place before Extended Loss of AC Power (ELAP) is declared.
3. Evaluate the EOPs and FSGs for responding to an ELAP affecting both units. (Note: Draft FSGs and draft EOPs, revised for FLEX implementation, were used.)
4. Evaluate whether the ability of the on-shift staff to perform any required emergency response functions would be degraded or lost prior to the arrival of the augmented ERO.
5. Consistent with the site access assumption, evaluate the ability of the on-shift staff and augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" time period.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 4

Attachment 2 to TXX-15084 Page 5 of 28 The staffing level determined as a result of the Phase 2 assessment will be verified and validated in the process used to reasonably assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed. Validation will be performed at a date after the submittal of the staffing assessment report per NEI guidance "FLEX Beyond Design Basis Validation Process" dated July 18, 2014. Necessary corrective actions will be tracked using the CPNPP corrective action program if the validation determines the assumed resources cannot complete a time sensitive action within the constraints identified in the Overall Integrated Plan (OIP) per NRC Order EA-12-049.

Methodology A tabletop assessment was performed to determine what operational and emergency response actions were procedurally required during an ELAP. Representatives from CPNPP Operations, Maintenance, Radiation Protection, Chemistry, Procedures, Engineering, Training, Security, and Emergency Preparedness met with an industry consultant in a tabletop exercise in February 2014.

The participants reviewed the assumptions and applied procedural guidance, including draft FLEX Support Guidelines (FSGs) for coping with a BDBEE using minimum on-shift staffing. 1 Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step. Because the FSGs were not yet finalized, the results of the assessment are preliminary and will require validation prior to FLEX implementation. All gaps identified will be addressed through the CPNPP corrective action program.

The team reviewed the tasks of each member of the minimum on-shift staff in responding to the ELAP and constructed a timeline (Table 5.2) recording the tasks and the approximate time at which they were performed following the event. Task duration was recorded in half-hour intervals. In reviewing on-shift staffing tasks, the team was alert to identify instances where staff members were assigned conflicting tasks or collateral duties that would distract from their ability to fulfill Emergency Plan responsibilities.

The assessment team used the guidance of NEI 10-05 to determine ifthe number and composition of the on-shift staff was sufficient to implement the Emergency Plan, Initial Phase actions, and, with the assistance from augmented staff, Transition Phase actions intended to maintain or restore core cooling, containment integrity, and spent fuel pool makeup for both units. The NEI 10-05 data tables (Table 5.1) were modified to include tasks associated with FLEX strategies.

3. Analysis Summary The assessment concluded that the on-shift staff as defined in the current CPNPP Emergency Plan and augmented ERO alone are not adequate, and that additional shift personnel as currently required by CPNPP procedure ODA-102, "Conduct of Operations, Attachment 8A Minimum Shift Crew Composition" are necessary to implement existing and planned BDBEE and ELAP strategies on both units simultaneously while continuing to perform required Emergency Planning tasks without unacceptable collateral duties.2 Additionally, the process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established. 3 These gaps were captured and will be addressed through the CPNPP corrective action program.

1 GAP #1 - The staffing assessment was not performed with the final approved versions of FLEX Support Instructions (FSI's).

2 GAP #2 - Site Administrative Procedures and the site Emergency Plan are not aligned as to the minimum shift staffing levels.

3 GAP #3 - The process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 5

Attachment 2 to TXX-15084 Page 6 of 28

4. Assumptions NEI 12-01 Assumptions for Staffing Analysis The set of standard assumptions that were used in the development of this report:
1. A large-scale external event occurs that results in:
  • all on-site units affected
  • extended loss of AC power 0 impeded access to the units
2. All on-site reactors are operating at full power and are successfully shut down.
3. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.
4. The event impedes site access as follows:

A. Post event time: 6 hours6.944444e-5 days <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. Personnel were limited to the minimum complement allowed by the site procedure ODA-102, "Conduct of Operations, Attachment 8A Minimum Shift Crew Composition." This would be the minimum on-shift complement present during a backshift, weekend or holiday. Augmented ERO staff assistance was not credited until six hours following the event.2 2 GAP #2 - Site Administrative Procedures and the site Emergency Plan are not aligned as to the minimum shift staffing levels.

ASSESSMENT 6 COMANCHE PEAK COMANCHE PHASE PEAK PHASE 2 ON-SHIFT STAFFING 2 ON-SHIFT STAFFING ASSESSMENT 6

Attachment 2 to TXX- 15084 Page 7 of 28 NEI 10-05 Applicable Assumptions In accordance with this guidance, the following assumptions and limitations apply to the Phase 2 OSSA:

1. On-shift personnel can report to their assigned response locations within the timeframes sufficient to allow for performance of assigned actions.
2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.
3. 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.

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

4. Performance of the on-site security organization's function is regularly analyzed through other station programs and was not evaluated in the OSSA, unless a role or function from another major response area was 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 was therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.

Communications methods will be different, i.e. Satellite phones instead of dedicated phone lines. Satellite phones require clear view of southern sky and therefore the communicator must go outside or set up an outside antenna. As such the communication to the State, Counties and the NRC will be done in series as each phone must be dialed separately. The satellite phones have simple usage cards with each phone and the use is similar to the use of a Cellular phone within the capability of the communicator.

7. The task of performing a peer check had minimal impact on the ability to perform other assigned functions/tasks, and was therefore an acceptable collateral duty for all positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.
8. The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).

ON-SHIFT STAFFING ASSESSMENT 7 COMANCHE PEAK COMANCHE PHASE PEAK PHASE 22 ON-SHIFT STAFFING ASSESSMENT 7

Attachment 2 to TXX- 15084 Page 8 of 28

5. Event Staffing Analysis
  • Minimum On-Shift Staffing The shift staffing requirements for CPNPP are listed in the Table 5.1 below (Reference 3). The methodology of NEI 12-01 requires that only personnel required to be on-shift complement can be credited in the staffing analysis.

Table 5.1 Minimum On-shift Staffing Functional Area Task On-Shift Position Station Operations Overall command of both units Emergency Shift Manager (SM)

Plan implementation Station Operations Unit 1 supervision Unit Supervisor (US) #1 Station Operations Unit 2 supervision Unit Supervisor (US) #2 Station Operations Engineering oversight in the Control Room Shift Technical Advisor (STA)

Station Operations Manipulation of Unit 1 controls Reactor Operator (RO) #1 Station Operations Manipulation of Unit 1 controls Reactor Operator (RO) #2 Station Operations Manipulation of Unit 2 controls Reactor Operator (RO) #3 Station Operations Manipulation of Unit 2 controls Reactor Operator (RO) #4 Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #1 needed Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #2 needed Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #3 needed Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #4 needed Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #5 needed Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #6 needed Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #7 needed Chem/ Radiochemistry support Perform Station Chemistry actions as directed by the Emergency Chemistry Technician (Chem) #1 Coordinator.

First Aid Team Chem/ Radiochemistry support Perform actions as directed by the Emergency First Aid Team Member (Chem) #2 Coordinator. Provide First Aid Station Radiation Surveys and Protective Actions Radiation Protection Technician (RP) #1 Protection Station Radiation Surveys and Protective Actions Radiation Protection Technician (RP) #2 Protection Station Perform local equipment manipulations as Mechanical Maintenance (MM) #1 Maintenance needed Station Perform local equipment manipulations as Electrical Maintenance (EM) #1 Maintenance needed Station Perform local equipment manipulations as l&C Maintenance (IC)#1 Maintenance needed Station Maintenance Emergency Communicator I&C Maintenance (IC)#2 ASSESSMENT 8 COMANCHE PHASE PEAK PHASE COMANCHE PEAK 2 ON-SHIFT STAFFING 2 ON-SHIFT STAFFING ASSESSMENT 8

Attachment 2 to TXX-1 5084 Page 9 of 28

  • Scenario Overview The BDBEE assumes a loss of off-site power combined with a failure of the emergency diesel generators to load. All remaining power is supplied by the station batteries. The loss of AC power to emergency buses initially results in the declaration of a Site Area Emergency (EAL SS4.1). When it becomes apparent that power will be unavailable for a prolonged period, the event classification is escalated to a General Emergency (EAL SG1.1).

CPNPP utilizes a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase utilizes installed equipment and resources to monitor, maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase uses offsite resources to sustain those functions indefinitely. Portable and off-site equipment location and operation during the Transition and Final Phases is addressed through the FSI's.

ECA-0.0 A/B (Unit 1 & 2 "Loss of All AC Powe&' procedures) are the governing procedures for the BDBEE. Battery life to support instrumentation, with load shedding as prescribed in ECA 0.0 A/B and FSI-4.0 A/B, is at least 12 hrs. Valve and breaker operation were performed locally by Nuclear Equipment Operators (NEO). ABN-601, "Response to a 138/345KV System Malfunction," provides Operations personnel additional guidance in response to the SBO event.

The strategy employed in the event analyzed was to establish core cooling by natural circulation and to perform a plant cooldown using the steam-driven auxiliary feedwater pump. The Steam Generator Atmospheric Relief Valves (ARVs) have safety related air accumulators capable of supplying air to the valves for a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, therefore within the minimum staffing response time the ARV will have to be taken to local manual control to control the Reactor Coolant System temperature. The Auxiliary Feedwater Flow Control Valves have safety related air accumulators for 30 minutes. Therefore within the minimum staffing response time, AFW flow will have to be controlled manually from the TDAFW Pump room. Because no condenser vacuum existed due to the loss of AC power, heat removed from the steam generators was achieved by venting steam directly to the atmosphere thereby continually depleting the feedwater supply.

Table 5.2 illustrates this strategy by providing a timeline of each position during the event. This table lists the major activities (by position) in increments for the first seven hours of the event. Table 5.6 lists the major activities as directed by the FSI's and typically performed by the Augmented or Expanded ERO. FSI steps performed by on-shift personnel are noted.

Staffing Analysis Summary Table 5.3 provides the results to the BDBEE transient using installed plant and portable equipment and the available staffing complement. The on-shift staff performed actions required by operating and emergency plan procedures in the 6-hour period, relying only on installed structures, systems and components available in the Initial Phase of the response. Some preparation activities, as identified in the FSI's, are performed by shift personnel.

Additionally, the subject matter experts also identified the following potential impediments to implementation and/or assumptions that need to be validated:

  • Specific guidance to direct RP actions in response to a BDBEE needs to be developed."

4GAP #4 - There is insufficient procedural guidance available to support RP response to a BDBEE.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 9

Attachment 2 to TXX-15084 Page 10 of 28 Table 5.2 On-Shift Staff Actions (Within the first seven hours)

Resources Tasks byTmem 1 0-10 1 10-20 1 20-30 1 30-4a I 40-50 1 50-60 1 60.75 1 75.00 T 001V5 M  % 102 120.1501 1 140.19n I M8.Ufl I 2A0..300 I jI0.5 250421 I

  • Task 3 Is intermittent communication. It was concluded that this resource could perform collateral duties (Tasks 3 and 18)

I LUL

  • UIIIuaI:,) III I" I aUIU LU I, IUIF. ORIUIIIUIIUUII* III I dUIUN iJ I tb.r L.IU.11,1 I 10 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT COMACHEPEA PHSE 2ON-HIF STFFIN ASESSENT10

Attachment 2 to TXX-1 5084 Page 11 of 28 Task # Table 5.3 Task Listing Start Time End Time Task Description T+ min T+ __ mmin

1. Emergency Coordinator (Control Room) 0 420
2. Engineering Oversight (Control Room) 0 420
3. Emergency Plan Communicator (Control Room) 10 420
4. ECA-0.0A/FSI Implementation/Unit I Monitoring and Control (Control Room) 0 420
5. ECA-0.0B/FSI Implementation/Unit 2 Monitoring and Control (Control Room) 0 420
6. ABN-601 Restore Unit I Diesel Generators and Restore from Unit 1 6.9 KV Bus Fault (Field Activities) 0 60
7. ABN-601 Restore Unit 2 Diesel Generators and Restore from Unit 2 6.9 KV Bus Fault (Field Activities) 0 60
8. ABN-601 Unit 1 Secondary System Shutdown, Break Vacuum Unit I Main Condenser, Unit I Main Generator Hydrogen Vent and 10 60 Argon Purge (Field Activities) 120 150 ABN-601 Unit 2 Secondary System Shutdown, Break Vacuum Unit 2 Main Condenser, Unit 2 Main Generator Hydrogen Vent 10 60 and Argon Purge (Field Activities) 120 150
10. ECA-0.OA Isolate Unit IRCP Seals (Field Activities) 10 20
11. ECA-0.OB Isolate Unit 2 RCP Seals (Field Activities) 10 20
12. ABN-601 Restoration of XSTl, Restoration of XST2 or XST2A, Restoration of 345 KV Transformer Feeder Line, SOP-614 A/B 10 120 Alternate Power Generator Operation (Field Activities)
13. Perform repair and corrective actions as assigned 10 180
14. Assist NEO with ABN-601 Unit 1 Secondary System Shutdown, Break Vacuum Unit 1 Main Condenser, Unit 1 Main Generator 10 150 Hydrogen Vent and Argon Purge Implementation (Field Activities)
15. Assist NEO with ABN-601 Unit 2 Secondary System Shutdown, Break Vacuum Unit 2 Main Condenser, Unit 2 Main Generator 10 150 Hydrogen Vent and Argon Purge Implementation (Field Activities)
16. Radiation Protection Coverage for ECA-0.OA Isolate Unit I RCP Seals (Field Activities) 10 20
17. Radiation Protection Coverage for ECA-0.OB Isolate Unit 2 RCP Seals (Field Activities) 10 20
18. EPP-203 Emergency Notification System Communicator with NRC (Control Room) 10 Duration
19. ECA-0.OA Unit 1 DC Load Shed (Field Activities) 60 120
20. ECA-0.OB Unit 2 DC Load Shed (Field Activities) 60 120
21. ABN-601 Unit 1 Non-i E DC Load Shed (Field Activities) 60 90
22. ABN-601 Unit 2 Non-1E DC Load Shed (Field Activities) 60 90
23. ECA-0.OA Isolate Unit 1 CST (Field Activities) 20 30
24. ECA-0.OB Isolate Unit 2 CST (Field Activities) 20 30
25. ECA-0.OA Isolate Instrument Air to Unit I Main Steam Isolation Valves (Field Activities) 50 60
26. ECA-0.OB Isolate Instrument Air to Unit 2 Main Steam Isolation Valves (Field Activities) 50 60
27. ECA-0.OA Establish Local Control Unit I Turbine Driven AFW Flow Control Valves (Field Activities) 30 50 60 Duration ECA-0.OB Establish Local Control Unit 2 Turbine Driven AFW Flow Control Valves (Field Activities) 30 50 28.

60 Duration

29. ECA-0.OA Isolate Ventilation Chilled Water to Unit 2 Containment (Field Activities) 90 105
30. ECA-4.0B Isolate Ventilation Chilled Water to Unit 2 Conta2n(Cnt (Field Activities) 90 105
31. FSI-4.0 Defeat Source Range High Voltage for Unit I and Unit 2 (Control Room) 240 270
32. ECA-0.OA Establish Local Control Unit 2 Atmospheric Relief Valves (Field Activities) 210 Duration
33. ECA-0.0B Establish Local Control Unit 2 Atmospheric Relief Valves (Field Activities) 210 Duration
34. FSI-5.0 Block Open Fuel Building Doors/Deploy Spent Fuel Pool Makeup Spray Nozzles (Field Activities) 300 420
35. Assist NEO with FSI-5.0 Block Open Fuel Building Doors/Deploy Spent Fuel Pool Makeup Spray Nozzles (Field Activities) 300 420 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 11

Attachment 2 to TXX-1 5084 Page 12 of 28 Task # Table 5.3 Task Listing Start Time End Time Task Description T+__ min T+__ min

36. FSI-4.0A Unit 1 DC Load Shed (Field Activities) 240 300
37. FSI-4.0B Unit 2 DC Load Shed (Field Activities) 240 300
38. FSI-4.OA/B Open Block Open Unit I and Unit 2 UPS and Battery Room Doors 300 330
39. Monitor Sound Powered Headset for Unit I and Unit 2 Field Communications (Control Room) 20 Duration
40. Assist NEC with ECA-0.OA Establish Local Control Unit I Atmospheric Relief Valves (Field Activities) 210 300
41. Assist NEC with ECA-0.OB Establish Local Control Unit 2 Atmospheric Relief Valves (Field Activities) 210 300
42. Assist NEC with ECA-0.OA Establish Local Control Unit I Atmospheric Relief Valves (Field Activities) 210 Duration
43. Assist NEC with ECA-0.0B Establish Local Control Unit 2 Atmospheric Relief Valves (Field Activities) 210 Duration Notes:
  • Control Room tasks associated with ECA-O.OA/B and FSIs (e.g. depressurize steam generators, etc.) have not been specifically defined in this task list.

These tasks have been assessed and Control Room staff is sufficient to perform the actions within required timelines without detracting from monitoring and control activities.

  • Extended Loss of AC Power (ELAP) is declared within four hours of loss of all AC power to both units. Once ELAP is declared, actions and resources to recover on-site AC power sources are no longer required.
  • Analysis has been truncated at seven hours based on the assumption that additional resources become available and time-sensitive activities have been completed or resources have been assigned.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 12

Attachment 2 to TXX-1 5084 Page 13 of 28 Table 5.4 Augmented staff in the OSC per EPP-205, "Activation and Operation of the OperationsSupport Center(OSC),"

OSC Manager OSC One individual assigned from the ERO ERDC Team Coordinator OSC One individual assigned from the ERO Rad Status Board Recorder OSC One individual assigned from the ERO SOE Board Recorder OSC One individual assigned from the ERO Chemistry Coordinator OSC One individual assigned from the ERO Team Communicator OSC One individual assigned from the ERO ERDC Electrician OSC One individual assigned from the ERO ERDC Mechanic OSC One individual assigned from the ERO ERDC I&C Technician OSC One individual assigned from the ERO First Aid Team OSC One individual assigned from the ERO Chemistry Technician OSC One individual assigned from the ERO On-site Monitoring Team OSC One individual assigned from the ERO Rad Pro Coordinator OSC One individual assigned from the ERO Clerk Manager OSC One individual assigned from the ERO Operations Personnel OSC As assigned by Operations personnel Radiation Protection Personnel OSC As assigned by Radiation Protection personnel Table 5.5 3 Expanded staff in the OSC, for dual unit response Unit In-Plant Team Coordination OSC

  • One additional individual per unit; individuals should not be assigned other functions.

Non-Licensed Operators (NEO's) OSC

  • Two additional individuals per unit to assist with implementation of repair and corrective actions.

Mechanical Maintenance Repair and Corrective Action OSC

  • Two additional individuals per unit to implement repair and corrective actions.

Electrical Maintenance Repair and Corrective Action OSC

  • Two additional individuals per unit to implement repair and corrective actions.

I&C Repair and Corrective Action OSC

  • Two additional individuals per unit to implement repair and corrective actions.

Implementation of SAM Strategies OSC

  • Number and composition of personnel capable of simultaneous implementation of any 2 SAM strategies at each unit. Operations and RP personnel are called out by department management.

GAP #3 - The process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 13

Attachment 2 to TXX-15084 Page 14 of 28 Table 5.6 Staff Actions performed via FSI's (With the Augmented and Expanded Staff available)

Procedure FLEX Support Instructions (FSI's) were not finalized at the time of the

  1. tabletop. (GAP #1)

FSI-5.0 Block Open FB Doors to Establish Ventilation (Shift Task #35) T+6 hours-6.5 NEO 6 Complete by 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> hours FSI-5.0 Establish Control Room Ventilation (Open Rack Doors, Back Door, Missile Door, T+6 hours-30 CR Staff (Based on Temperature)

Establish % lighting) minutes (30 minutes after exceeding pre-established temperatures for both Units)

FSI-5.0 Block open Unit 1 TDAFWP Room Door (Shift Task #27) T+4 hours NEO 5 Complete by 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 0 min AFW 1 Performed by on-shift personnel FSI-5.0 Block open Unit 2 TDAFWP Room Door (Shift Task #28) T+4 hours NEO 7 Complete by 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 0 min AFW 2 Performed by on-shift personnel FSI-5.0 Clear Debris Route I or 2 FLEX Bldg to AAP T+6 hours Augmented Staff Complete by 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> (To support Phase 2 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (2 personnel) 480 VAC Generator deployment)

FSI-5.0 Clear Debris AAP to Staging Area Al (Also includes A2) T+7.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Augmented Staff Complete by 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> (To support Phase 2 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (2 personnel) 480 VAC Generator deployment)

FSI-5.0 Clear Debris Route from AAP to Unit 2 DG FOST Fueling Station T+9 hours Augmented Staff Complete by 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> (To support FLEX 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (2 personnel) equipment fueling)

FSI-5.0 Clear Debris Route from AAP to Unit 1 SG AFW FLEX Pump parking area T+9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Augmented Staff One for each unit (Contingency) 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (2 personnel)

FSI-5.0 Clear Debris Route from Staging Area Al to West North-South Road T>1 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Augmented Staff Complete before Staging West Side Tank 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (2 personnel) Pumps (must clear 3.3 or 3.4)

FSI-5.0 Clear Debris Route from Unit 1SG AFW FLEX Pump parking around to West T>10.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Augmented Staff Complete before Staging West Side Tank Side Tanks 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (2 personnel) Pumps (must clear 3.3 or 3.4)

FSI-5.0 Clear Debris Route Southeast Corner of Perimeter road to SSI T>12.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Augmented Staff Complete before placing Multipurpose Pump 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (2 personnel) in service FSI-5.0 Step Perform damage assessments T>6 hours Augmented Staff Complete within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 40 hours (2 personnel)

FSI-5.0 Move FLEX Equipment to Staging Areas (Diesel Fuel Transfer Equipment) T+9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Augmented Staff Complete to support all other equipment 45 minutes (2 personnel) placement FSI-5.0 Move FLEX Equipment to Staging Areas (UPS Room 12 KW Generators) T>12 hours Augmented Staff Complete prior to establishing forced 30 minutes (2 personnel) ventilation at 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 14

Attachment 2 to TXX-1 5084 Page 15 of 28 Table 5.6 Staff Actions performed via FSI's (With the Augmented and Expanded Staff available)

FSI-5.0 Move FLEX Equipment to Staging Areas (SG AFW Pumps) T > 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> Augmented Staff Contingency for TDAFWP Failure 30 minutes (2 personnel)

FSI-5.0 Move FLEX Equipment to Staging Areas (West Side Tanks Multipurpose Pumps) T>10 hours Augmented Staff Contingency ifWest Side Tanks Available 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (2 personnel) Complete prior to CST empty at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FSI-5.0 Move FLEX Equipment to Staging Areas (SSI Multipurpose Pump) T>12 hours Augmented Staff Complete prior to CST empty at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 1 hour (2 personnel)

FSI-5.0 Move FLEX Equipment to Staging Areas (Control Room 12 KW Generators) T>12 hours Augmented Staff Complete prior to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to support Control 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (2 personnel) Room Ventilation Requires Pettibone to place on TB 830 Deck FSI-5.0 Move FLEX Equipment to Staging Areas (FLEX Pump to Fill SFPs) T>10 hours Augmented Staff Complete prior to makeup to SFP prior to 15 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (2 personnel) hours FSI-5.0 Align RCS HP Boration FLEX Pumps (Unit 1) T< 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Augmented Staff Complete prior to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 2 hours (2 personnel)NEO Mechanic FSI-5.0 Align RCS HP Boration FLEX Pumps (Unit 2) T< 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Augmented Staff Complete prior to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br /> 2 hours (2 personnel)NEO Mechanic FSI-5.0 Establish UPS Room Forced Ventilation T>12 hours Augmented Staff Complete prior to 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 2 hours (3 personnel)

FSI-5.0 Engineering Assistance in Evaluating Available Water T > 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Augmented Staff Complete within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Supplies/Structures/Components 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> (2 personnel)

FSI-4.0A First DC Load Shed (Shift Task #36) 30 min NEO 2 Must be completed at 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Performed by on-shift personnel FSI-4.OB First DC Load Shed (Shift Task #37) 30 min NEO 4 Must be completed at 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> Performed by on-shift personnel FSI-4.OA Open UPS/Battery Room Doors Attachment (Unit 1 and Unit 2 ) (Shift Task #38) 30 min NEO 4 Must be complete at 5.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> - 1 person for both Units Performed by on-shift personnel FSI-4.OA Defeat SR HV Cutout (Shift Task #31) 10 min Prompt Team I&C Performed by on-shift personnel FSI-4.0B Defeat SR HV Cutout (Shift Task #31) 10 min Prompt Team I&C Performed by on-shift personnel FSI-4.OA Disable Both Trains of SSPS (After SI Reset) (Shift Task #4 &5) 10 min RO 3 Performed by on-shift personnel 15 COMANCHE PEAK COMANCHE PHASE PEAK PHASE 22 ON-SHIFT STAFFING ASSESSMENT ON-SHIFT STAFFING ASSESSMENT 15

Attachment 2 to TXX-1 5084 Page 16 of 28 Table 5.6 Staff Actions performed via FSI's (With the Augmented and Expanded Staff available)

FSI-4.OB Disable Both Trains of SSPS (After SI Reset) (Shift Task #4 & 5) 10 min RO 4 Performed by on-shift personnel FSI-4.0A Remove Two Batteries From Service (Shift Task #36) 15 min NEO 2 Performed by on-shift personnel FSI-4.0B Remove Two Batteries From Service (Shift Task #37) 15 min NEO 4 Performed by on-shift personnel FSI-4.OA Transport/Connect Phase 2 480 VAC FLEX generator T+9 hours Augmented Staff Must be complete prior to placing battery 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (5 personnel) chargers in service 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FSI-4.0A Align 25 KV Loop for 480 VAC FLEX generator 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Augmented Staff Must be complete prior to placing battery (1 personnel) chargers in service 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FSI-4.0A Place Battery Chargers/Battery Exhaust Fans in Service T+9 hours Augmented Staff Must have 480 VAC FLEX Generator in 30 min (1 personnel) service Must be complete at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FSI-4.0B Place Battery Chargers/Battery Exhaust Fans in Service T+9 hours Augmented Staff Must have 480 VAC FLEX Generator in 30 min (1 personnel) service Must be complete at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FSI General Support miscellaneous activities for FSI implementation (e.g., diesel fueling T+6 Augmented Staff Activities required to be performed for activities, Phase 3 equipment inspections/connections, flooding inspections) (10 personnel) duration of limited site access (-24 hours)

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 16 to TXX-15084 Page 17 of 28

6. FLEX Response Analysis
  • FLEX Details The focus of this "expanded response capability" at CPNPP is to enable the performance of unit-specific accident assessment and mitigation functions across multiple units.

The methods to notify and augment the ERO were described in the Phase 1 Staffing Analysis Report submitted to the NRC on April 30, 2013. The report was submitted as an Enclosure to CPNPP letter TXX-1 3081 entitled "Revised Phase 1 Staffing Assessment Submitted in Response to Request for Information Pursuantto 10 CFR 50.54(o Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights" (ADAMS Accession No. ML13128A077). The report also addressed site access for the augmented ERO. 5 Expanded ERO The positions for the Expanded Response were identified in the Phase 1 staffing assessment referenced above. Emergency Plan Procedures and associated training has not been completed. 6 There were no new skills identified through the assessment that had to be developed.

Work Location for the Expanded ERO If access to designated emergency response facilities is not possible, ERO members are trained to report to the alternate location. In the event the Expanded ERO is utilized, current facilities would be crowded. 7 GAP #5 - Identify and Integrate into the ERO notification/activation protocol those non-ERO response personnel (e.g., Operations and Maintenance) necessary to support expanded response capability functions.

6 GAP #6 - Training for the expanded ERO has not been completed.

GAP #7 - Facility plans to house the Expanded ERO have not been completed.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 17 to TXX- 15084 Page 18 of 28 0 On-Site Ability to Move Back-up Equipment US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated March 12, 2012, states in part:

The following functions are requested to be assessed:

How on-site staff will move back-up equipment (e.g., pumps, generators) from alternate on-site storage facilities to repair locations at each reactor as described in the Order regarding the NTIF Recommendation 4.2.

Following the guidance in the draft FSI's, FSI-5, Step 11, personnel were directed to move FLEX equipment to designated spaces. When discussed in the tabletop, it was identified that the skills and proficiency to move and set up equipment were within the skill levels of personnel assigned to the ERO rosters. To strengthen the response, an individual to assess the specific skill sets necessary will evaluate and assign as needed. 8

  • FLEX Analysis Summary The assessment considered the number and qualifications of personnel required for simultaneous implementation of the two FSG strategies for each unit that require the greatest number of staff to implement. Due to unit similarities, the most labor intensive FSG strategies are the same for Unit 1 and Unit 2.

The FLEX Support Instructions (FSI's), in their present state of completion, were used to support the tabletop analysis of actions taken in response to the BDBEE.

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

The assessment considered the number and qualifications of SAMG implementation personnel required for simultaneous implementation of the two most task intensive SAMG strategies on both units. Two strategies were evaluated:

  • Control Containment Conditions SAG-6

" Flood Containment SAG-8 GAP #8 - A position needs to be identified that can assess the knowledge and skills necessary for the on-shift, augmented and expanded staff to implement the procedures and tasks necessary to respond to a BDBEE.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 18 to TXX-1 5084 Page 19 of 28 Implementation of the Control Containment Conditions SAG-6 strategy requires the following resources.

Table 6.1 Resource Number per Unit Function Augmented Staff 2 Implement EDMG A.4-1 for RWST Makeup as needed Augmented Staff 2 Implement EDMG A.4.7 for Portable

+ Spray if Containment is breached.

1 common for Fire protection water source RP Technician 1 Monitor Dose rates.

Implementation of the Flood Containment SAG-8 Strategy requires the following resources.

Table 6.2 Resource Number per Unit Function Augmented 2 Implement EDMG A.4-1 for RWST Staff Makeup as needed Augmented 2 Implement EDMG A.4-6 Containment Staff Flooding with Portable Pump.

Augmented Removing blank flange from Staff 2 Containment spray line for EDMG A.4-6 Containment flooding with Portable Pump.

ThcnMonitor Dose rates.

Implementation of strategies SAG-6 and SAG-8 simultaneously would require the following personnel resources:

  • 21 Augmented Staff
  • 4 RP Technicians Based on evaluations performed, implementation of SAMG strategies, SAG-6 and SAG-8, are not anticipated within the first twenty four hours following the event under any circumstances. All emergency response facilities are expected to be staffed and activated by that time, therefore no staffing limitations will be encountered.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 19 to TXX-15084 Page 20 of 28

7. Program Controls

" Emergency Response Drills & Exercise Program NEI 12-01, states that 'a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. In particular, standard objectives and extent-of-play may need to be revised to clarify the expected demonstration of functions that are dependent upon the type of scenario event or accident (i.e., within or beyond design basis, and number of affected units). For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit. 9

  • Training The FSI's at CPNPP were in draft at the time of the tabletop assessment. Once the training has been established, the requisite knowledge necessary to perform the tasks required by the FSI's by on-shift, augmented and expanded staff can be determined.1°
8. Security Considerations Security Coping strategies were reviewed and determined to be able to support the tasks of debris removal and Flex equipment staging during the initial phase of the response. The task of communication to the plant site for the response to the emergency will be incorporated into the appropriate security procedure".

9GAP #9 - Current CPNPP drill and exercise procedures do not include evaluation objectives or demonstration criteria for dual unit events or expanded ERO activities.

10 GAP #10 - Training was not performed with the final approved versions of FLEX Support Instructions (FSI's).

GAP #11 - Update the applicable security procedure for communication to the plant site.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 20 to TXX-1 5084 Page 21 of 28

9. Identified Issues The assessment team noted the following issues during the course of the staffing analysis.

Table 9.1 GAP # Description Condition Report #

1 The staffing assessment was not performed with the final approved AI-CR-2013-versions of FLEX Support Instructions (FSI's). 003355-5 CR-201 5-004563 CR-2015-004566 Site Administrative Procedures and the site Emergency Plan are not

2. aligned as to the minimum shift staffing levels. CR-2015-004567 The process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been AI-CR-2013-established. 003355-30 There is insufficient procedural guidance available to support RP AI-CR-2013-response to a BDBEE. 003355-10 Identify and Integrate into the ERO notification/activation protocol those non-ERO response personnel (e.g., Operations and Maintenance) AI-CR-2013-necessary to support expanded response capability functions. 003355-14 AlI-C R-00201 3-003355-16
6. Training for the expanded ERO has not been completed.

AI-CR-2013-Facility plans to house the Expanded ERO have not been completed. 003355-17 7.

A position needs to be identified that can assess the knowledge and

8. skills necessary for the on-shift, augmented and expanded staff to AI-CR-2013-implement the procedures and tasks necessary to respond to a BDBEE. 003355-18 Current CPNPP drill and exercise procedures do not include evaluation
9. objectives or demonstration criteria for dual unit events or expanded AI-CR-2013-ERO activities. 003355-19 AI-CR-2013-003106-32 Al-CR-2013-
10. Training was not performed with the final approved versions of FLEX 012473-1 Support Instructions (FSI's). EV-CR-2015-003357-1 EV-CR-2015-003357-2
11. Update the applicable security procedure for communication to the plant AI-CR-2013-site. 003355-31 Identify new or revised agreements with offsite providers (e.g. City of Granbury, City of Cleburne, Oncor Distribution, Department of Public
12. Safety) (This issue is not specifically discussed in the sections above 003355-32 but addresses Commitment 4392956 in letter TXX-14067 dated May 15, 2014)

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 21 to TXX-1 5084 Page 22 of 28 REFERENCES

1. Letter from E. J. Leeds (NRC) and M. R. Johnson, (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident
2. Letter from D. L. Skeen (NRR) to Susan Perkins-Grew (NEI) dated May 15, 2012, U.S. Nuclear Regulatory Commission Review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, May 2012
3. ODA-102, "Conduct of Operations, Attachment 8A Minimum Shift Crew Composition", Revision 27
4. EOP-0.OA/B, "ReactorTrip Or Safety Injection", Revision 8
5. ABN-601, "Response To A 138/345KV System Malfunction", Revision 12
6. ABN-602 "Response To A 6900/480 Volt System Malfunction", Revision 8
7. ECA-0.OA/B, "Loss Of All AC Power", Revision 8
8. ECA-TP-1 1-001A/B, "Loss Of All AC Power Recovery Without SI Required and APG Supplying Power", Revision 1
9. SOP-614A/B, "AlternatePower GeneratorOperation", Revision 13/12
10. FSI-4.OA/B, "DC Bus Load Management and Phase 2 480 VAC Generator Alignment", Revision Draft
11. FSI-5.0, "InitialAssessment and FLEX Equipment Staging", Revision Draft
12. SAG-6, "Severe Accident Management Guidance - Control Containment Conditions", Revision 2
13. SAG-8, "Severe Accident Management Guidance - Flood Containment",

Revision 2

14. EPP-201, "Assessment Of Emergency Action Levels Emergency Classification And Plan Activation", Revision 12
15. EPP-303, "Operation of Computer Based, Emergency Dose Assessment System", Revision 13
16. EPP-304, "ProtectiveAction Recommendations", Revision 21
17. EPP-314, "Evacuationand Accountability', Revision 9 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 22 to TXX-15084 Page 23 of 28
18. NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities",Revision 0.
19. Letter from Luminant to Nuclear Regulatory Commission, "ComanchePeak Nuclear PowerPlant, Docket Nos. 50-445 and 50-446, 90-Day Response to March 12, 2012 Information Request RegardingRecommendation 9.3 of the Near-Term Task Force"Letter dated June 7, 2012.
20. NSIR/DPR ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants, Revision 0, November 2011
21. NEI 10-05, Revision 0, June 2011, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities
22. NEI 12-01, Revision 0, May 2012, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities
23. Luminant Generation Company, LLC's 60-Day Response, dated May 10, 2012, to NRC Letter Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near Term Task Force Review of Insights from the Fukushima Dia-ichi Accident, dated March 12, 2012 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 23 to TXX-1 5084 Page 24 of 28 NEI 10-05 TABLE 1 ON-SHIFT POSITIONS On-shift Augmentation Role in Unanalyzed TMS Line Position Source Reference Elapsed Time Table#/Line# Task? Required Poiton(min)  ?

T2/ L1 T5/ Li T5/ L2 CPNPP E-Plan T5/L3 1 Shift Manager TABLE 1.1 N/A T5/L5 No No T5/1L7 T5/1L8 T5/L10 2 Unit Supervisor CPNPP E-Plan N/A T2/L2 No

  1. 1 TABLE 1.1 No Unit Supervisor ODA-102, Aft. 8A 3 Minimum Shift Crew N/A T2/L3 No No Composition Shift Technical 4N/A CPNPP E-Plan T2/L4 No .No Advisor TABLE 1.1 Reactor 5N/A CPNPP E-Plan T2/L5 No No Operator #1 TABLE 1.1 Reactor 6N/A CPNPP E-Plan T2/L6 No No Operator #2 TABLE 1.1 Reactor ODA-102, Aft. 8A Operator #3 Minimum Shift Crew N/A T2/L7 No No Composition Reactor ODA-102, Aft. 8A 8 Minimum Shift Crew N/A T2/L8 No No Operator #4 Composition Nuclear CPNPP E-Plan 9 Equipment N/A T2/L9 No No Operator #1 TABLE 1.1 Nuclear CPNPP E-Plan 10 Equipment N/A T2/L10 No No Operator #2 TABLE 1.1 Nuclear CPNPP E-Plan 11 Equipment N/A T2/L11 No No Operator #3 TABLE 1.1 Nuclear CPNPP E-Plan 12 Equipment N/A T2/L12 No No Operator #4 TABLE 1.1 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 24 to TXX-1 5084 Page 25 of 28 NEI 10-05 TABLE 1 ON-SHIFT POSITIONS On-shift Augmentation Role in Unanalyzed TMS Line Position Source Reference Elapsed Time Table#ILine# Task? Required (min)  ?

Nuclear ODA-102, Aft. 8A 13 Equipment Minimum Shift Crew N/A T2/L13 No No Operator #5 Composition Nuclear ODA-102, Aft. 8A 14 Equipment Minimum Shift Crew N/A T2/L14 No No Operator #6 Composition Nuclear ODA-102, Aft. 8A 15 Equipment Minimum Shift Crew N/A T2/L15 No No Operator #7 Composition 16 Chemistry CPNPP E-Plan N/A T2/L20 No No Technician TABLE 1.1 T4/L5 17 RP Technician CPNPP E-Plan N/A T2/L21 No No 1 TABLE 1.1 T4/L2 18 RP Technician CPNPP E-Plan N/A T2/L22 No No 2 TABLE 1.1 T4/L3 Security CPNPP E-Plan 19 Supervisor TABLE 1.1 N/A T2/L25 No No T5/L 15 20 Security CPNPP E-Plan N/A T2/L24 No No Officers TABLE 1.1 T2/L 16 CPNPP E-Plan T5/L6 21 Communicator N/A No No TABLE 1.1 T5/L13 T5/L14 CPNPP E-Plan 22 Mechanic N/A T2/L18 No No TABLE 1.1 CPNPP E-Plan 23 Electrician N/A T2/L17 No No TABLE 1.1 CPNPP E-Plan 24 I&C Technician N/A T2/L19 No No TABLE 1.1 First Aid team CPNPP E-Plan T2/L23 Member TABLE 1.1 T4/L6 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 25 to TXX-1 5084 Page 26 of 28 NEI 10-05 TABLE 2 PLANT OPERATIONS & SAFE SHUTDOWN Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 1 Shift Manager Shift Manager Operations & EP Training 2 Unit Supervisor #1 Unit Supervisor Operations & EP Training 3 Unit Supervisor #2 Unit Supervisor Operations & EP Training 4 Shift Technical Advisor STA Operations & EP Training 5 Reactor Operator #1 Reactor Operator Operations & EP Training 6 Reactor Operator #2 Reactor Operator Operations & EP Training 7 Reactor Operator #3 Reactor Operator Operations & EP Training 8 Reactor Operator #4 Reactor Operator Operations & EP Training 9 Station Operator #1 NEO Operations & EP Training 10 Station Operator #2 NEO Operations & EP Training 11 Station Operator #3 NEO Operations & EP Training 12 Station Operator #4 NEO Operations & EP Training 13 Station Operator #5 NEO Operations & EP Training 14 Station Operator #6 NEO Operations & EP Training 15 Station Operator #7 NEO Operations & EP Training Other Personnel Necessary to Implement AOPs, EOPs, SAMGs, or FSIs Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 16 Emergency Communicator I&C Tech Maintenance & EP Training 17 Electrician Electrician Maintenance & EP Training 18 Mechanic Mechanic Maintenance & EP Training 19 I&C Technician I&C Tech Maintenance & EP Training 20 Chemistry Technician Chemistry Tech Chemistry & EP Training 21 RP Technician RP Tech RP & EP Training 22 RP Technician RP Tech RP & EP Training 23 First Aid First Aid Team Safety Training Member 24 Security Officer Security Officer Security Training 25 Security Supervisor Security Supervisor Security Training NEI 10-05 TABLE 3 FIREFIGHTING Line Performed By Task Analysis Controlling Method 1 N/A N/A COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 26 to TXX-15084 Page 27 of 28 NEI 10-05 TABLE 4 RADIATION PROTECTION & CHEMISTRY PerformanceTimePeriod After Emergency Declaration (minutes) ______

Line Position 0- 10 20- 30- 40- 50- 60- 75 105- 120- 150- 180- 240- 300- 360-performing 10 20 30 40 50 60 75 90 105 120 150 180 240 300 360 420

, Function/ Task

1. In-Plant Survey On-Shift Position:

2, On-Site Survey On-Shift Position:

RP Technician 1 3, Personnel Monitoring On-Shift Position:

RP Technician 2 4 Job Coverage On-Shift Position:

5 Chemistry function/task #1 -

Describe:

On-Shift Position:

Chemistry Technician 6 Chemistry function/task #2 -

Describe:

On-Shift Position:

First Aid Team Member COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 27 to TXX-15084 Page 28 of 28 NEI 10-05 TABLE 5 IIC I:M0tDfMV DI AM IIDI :MI=:TATI'AM Line Function/Task On-Shift Position Task Analysis Controlling Method 1 Declare the Emergency Shift Manager Operations Training and Classification Level (ECL) EP Training/Drill Program 2 Approve Offsite Protective Action Shift Manager Operations Training and Recommendations EP Training/Drill Program 3 Approve content of State/local Shift Manager Operations Training and notifications EP Training/Drill Program 4 Approve extension to allowable N/ A - no radiological dose limits release 5 Notification and direction to on- Operations Training and shift staff (e.g., to assemble, Shift Manager EP Training/Drill Program evacuate, etc.)

6 ERO notification Communicator Maintenance Training and EP Training/Drill Program 7 Abbreviated NRC notification for Shift Manager Operations Training and DBT event EP Training/Drill Program 8 Complete State/local notification Shift Manager Operations Training and Form EP Training/Drill Program 9 Perform State/local notifications Communicator Maintenance Training and EP Training/Drill Program 10 Complete NRC event notification Shift Manager Operations Training and form EP Training/Drill Program I Activate ERDS TSC ERF Computer EP Training/ Drill Program Operator________________

Training and 12 Offsite rOperations radiological assessment Shift Technical Advisor EP Training/Drill Program 13 Perform NRC notifications Communicator Maintenance Training EP Training/Drill and Program 14 Perform other site-specific event ommunicator Maintenance Training and notifications (e.g., INPO, ANI, etc.) EP Training/Drill Program 15 Personnel accountability Security Security Training and EP Training/Drill Program COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 28

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