ONS-2015-077, Response to March 12, 2012, Request for Information, Per 1CFR50.54(f) Regarding Recommendation of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency..
| ML15176A343 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 06/17/2015 |
| From: | Batson S Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ONS-2015-077 | |
| Download: ML15176A343 (44) | |
Text
Scott L. Batson f DUKE Vice President
_ ENERGY. Oconee NuclearStation Duke Energy ON01VP I 7800 RochesterHwy Seneca, SC 29672 ONS-2015-077 o: 864.873.3274
- f. 864.873. 4208 Scott.Batson@duke-energy.com June 17, 2015 ATTN: Document Control Desk 10 CFR 50.54(f)
U.S. Nuclear Regulatory Commission Washington, DC 20555 Duke Energy Carolinas, LLC (Duke Energy)
Oconee Nuclear Station, Units 1, 2 and 3 Docket Numbers 50-269, 50-270, 50-287 Renewed License Numbers DPR-38, DPR-47, and DPR-55
Subject:
Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 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
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, dated March 12, 2012 (ADAMS Accession No. ML12053A340)
- 2. Duke Energy's 60 day response to March 12, 2012 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 May 9, 2012 (ADAMS Accession No. ML12132A377)
- 3. NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012
- 4. Duke Energy's Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Staffing Assessment, dated April 30, 2013 (ADAMS Accession No. ML13127A192
- 5. NRC Letter, Response regarding Licensee Phase 1 staffing submittals associated with Near-Term Task Force Recommendation 9.3 related to the Fukushima Dai-ichi Nuclear Power Plant accident (ADAMS Accession No. ML13233A183), dated October 23, 2013 Ladies and Gentlemen, 49-t On March 12, 2012, the NRC staff issued a Request for Information pursuant to 10 CFR 50.54(f) Regarding Recommendations 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (Reference 1). Enclosure 5 of Reference 1 contains the
ONS-2015-077
,*" Jne 17, 2015 age 2 specific Requested Actions, Requested Information, and Required Response associated with Recommendation 9.3 for Emergency Preparedness - Staffing. Reference 1 also made provisions to provide an alternative course of action and establish different response dates.
Accordingly, Duke Energy submitted an alternative course of action by letter dated May 9, 2012 (Reference 2) and provided a schedule for responding to the requested Information related to Emergency Preparedness staffing. By letter dated April 30, 2013 (Reference 4) the Phase 1 staffing assessment was provided for Oconee Nuclear Station (ONS).
The NRC staff provided their review of the ONS Phase 1 staffing assessment in letter dated October 23, 2013 (Reference 5). The NRC review confirmed that the onsite minimum staff is sufficient to support required plant actions and emergency plan functions, without the assignment of collateral duties that would impact the performance of assigned emergency plan functions. As a result, the NRC staff concluded that the ONS Phase 1 staffing submittal adequately addresses the response strategies needed to respond to an event that results in a multi-unit Station Blackout.
The Attachment to this letter provides the Phase 2 Staffing Assessment Report for ONS in accordance with Nuclear Energy Institute (NEI 12-01) "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," (Reference 3).
There are no new or revised regulatory commitments associated with this letter.
If any further information is needed please contact David Haile at (864) 873-4742, I declare under penalty of perjury that the foregoing is true and correct. Executed on June 17, 2015.
Sincerely, Scott L. Batson Vice President Oconee Nuclear Station
Attachment:
Oconee Nuclear Station, NEI 12-01 Phase 2 Staffing Assessment Report
QNS-2015-077 Juine 17, 2015 Page 3 cc (with enclosure):
Mr. Victor McCree, Regional Administrator U.S. Nuclear Regulatory Commission - Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 Mr. William Dean, Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop O-13H16 Rockville, MD 20852-2738 Mr. James R. Hall, Project Manager (ONS)
(by electronic mail only)
U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8B1 Rockville, MD 20852 Mr. Jeffery Whited (by electronic mail only)
U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop O-8B1A Rockville, MD 20852 Mr. Eddy Crowe NRC Senior Resident Inspector Oconee Nuclear Station
Attachment to ONS-2015-077 Oconee Nuclear Station Units 1, 2, and 3 Oconee Nuclear Station, NEI 12-01 Phase 2 Staffinq Assessment Report
~DUKE
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V-Oconee
- ,*,,*Nuclear SStation (ONS)
NEI 12-01, Phase 2 - Staffing Assessment Report Revision 0
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report TABLE OF CONTENTS 1 EXECUTIVE
SUMMARY
............................................................................................ 3 1.1 O n-shift E R O A nalysis .................................................................................... 3 1.2 Expanded ER O A nalysis ................................................................................. 4 2 INTRO DUCTIO N ...................................................................................................... 4 3 PHASE 2 STAFFING ANALYSIS
SUMMARY
6 3.1 On-Shift Staffing Task Analysis Results ........................................................... 6 3.2 On-Shift Staffing Time Motion Study (TMS) Results ........................................ 6 3.3 Augmented and Expanded ERO Assessment Results ..................................... 7 3.4 List of A nalysis R esults ................................................................................... 7 4 SCOPE OF THE ELAP ERO STAFFING ASSESSMENT .......................................... 9 5 ASSUMPTIONS OF THE ELAP ERO STAFFING ASSESSMENT ........................... 10 6 ON-SHIFT ERO RESPONSE CAPABILITY ............................................................. 14 6.1 ELAP Event Description and Initial Conditions ............................................. 14 6.2 On-Shift Staffing Analysis Results Tables ...................................................... 15 6.3 ELAP On-Shift Staffing Task Timetable ........................................................ 24 7 AUGMENTED AND EXPANDED ERO RESPONSE ANALYSIS .............................. 27 7.1 ERO Notification and Response during an ELAP ........................................... 28 7.2 Expanded Response Functions for Phase 1 Staffing Assessment ................. 34 Attachm ent 1: List of References ......................................................................................... 39 : Waterfall Depiction of ERO Minimum Shift Staffing Tasks, T im e 0 -360 Minutes ..................................................................................... 41 Page 2
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report EXECUTIVE
SUMMARY
Using the methodology of (Nuclear Energy Institute) NEI 12-01 Revision 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, this report presents the results of an assessment of the capability of the Oconee Nuclear Station (ONS) on-shift staff and augmented Emergency Response Organization (ERO) to respond to a beyond design basis external event (BDBEE). The assumptions for the NEI 12-01 Phase 2 scenario postulate that the BDBEE involves a large-scale external event that results in:
A. An extended loss of all AC power (ELAP)
B. An extended loss of ultimate heat sink (UHS)
C. Impact on all units (all three units are in operation at the time of the event)
D. Impeded access to the station by off-site responders as follows:
- 0 to 6 Hours Post Event - 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.
- 6 to 24 Hours Post Event - 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).
a 24+ Hours Post Event - 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.
A team of subject matter experts from Operations, Maintenance, Security, Radiation Protection, Chemistry, Emergency Preparedness and industry consultants performed tabletop exercises in March and April 2015 for the on-shift portion of the assessment.
The participants reviewed the assumptions and applied existing procedural guidance, including applicable draft FLEX Guidelines (FGs) for coping with a BDBEE using minimum on-shift staffing. Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step to account for both the task and time motion analyses of NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities.
Analysis result items are listed in Section 3.4 and have been entered into the corrective action program.
1.1 On-shift ERO Analysis The on-shift ERO analysis concluded that the current ONS on-shift staffing present for the "no site access" 6-hour time period is sufficient to perform the EOP, FG and emergency response tasks. However, shift personnel are not yet trained to perform the FG tasks.
Note - the Acronym SPOC is used in this report to refer to a team of Maintenance support personnel assigned to 24 hr coverage, 7 days a week. Recent merger changes also use a synonymous term of FIN 24 for the same team.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 1.2 Expanded ERO Analysis The expanded ERO analysis concluded that the current ONS augmenting ERO is sufficient to fill positions for the expanded ERO functions. Thus, the ERO resources and capabilities necessary to implement Transition Phase coping strategies performed after the end of the "no site access" 6-hour time period do exist in the current program.
2 INTRODUCTION In March 2012, the Nuclear Regulatory Commission (NRC) issued a §50.54(f) request for information regarding recommendations from the near-term task force review of insights from the Fukushima Dai-lchi accident (see Reference 5). Enclosure 5 of the
§50.54(f) letter related to Emergency Preparedness and contained requests involving performance of staffing assessments. The actions for the staffing assessment are summarized as follows:
It is requestedthat addresseesassess their currentstaffing levels and determine the appropriatestaff to fill all necessarypositions for respondingto a multi-unit event during a beyond design basis naturalevent and determine if any enhancements are appropriategiven the considerationsof Near-Term Task Force (NTTF)
Recommendation 9.31.
A two-phased approach was established by the industry to respond to the information requests contained in the §50.54(f) letter associated with staffing.
Additionally, NEI developed a technical report (NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities) that includes the recommended criteria for use in performing the staffing assessment for a beyond design basis external event. The criteria presented in the NEI 12-01 technical report provide for documenting the organizational capabilities that will facilitate simultaneous performance of accident mitigation and repair actions following a beyond design basis external event.
Note - Use of the term ELAP throughout this report also assumes a loss of the ultimate heat sink as part of the event.
2.1 Phase I Staffing Assessment The objective of the Phase 1 staffing assessment was to evaluate the on-site and augmented staff needed to respond to a large-scale external event at a multi-unit site meeting the conditions described in the NEI 12-01 assumptions, NOT including staffing needed to implement actions that address NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049). That is, the Phase 1 staffing assessment considered the requested functions except those related to Fukushima NTTF Recommendation 4.2.
The ONS Phase 1 staffing assessment was submitted to the NRC on 4/30/13. NRC letter, "Response Regarding Licensee Phase 1 Staffing Submittals Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-lchi Nuclear Power Plant Accident," dated 10/23/13, provided regulatory approval of the Phase 1 staffing report.
For background information, refer to NRC staff report SECY-1 1-0093, entitled, Recommendations for Enhancing Reactor Safety in the 2 1st Century, dated July 12, 2011 [ADAMS ML111861807 - NTTF report]
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 2.2 Phase 2 Staffinq Assessment Sites with one or more operating units are required to perform a Phase 2 staffing assessment no later than four months prior to beginning of the second refueling outage (as used within the context of NRC Order EA-12-049) or 12/31/16, whichever comes first. In contrast to the Phase 1 staffing assessment, the Phase 2 staffing assessment considers the response functions related to Order EA-12-049.
The Phase 2 staffing assessment for response functions related to Order EA-12-049 must be based on the actions delineated in the procedures and guidelines developed in response to the Order to ensure accurate results. Once the site-specific actions associated with the new response strategies are defined (i.e., down to the procedure or guideline step level), the staffing needed to perform these actions can be assessed with the necessary level of accuracy.
The results of the Phase 2 assessment have been verified and validated to ensure adequacy and accuracy. In accordance with the requirements of 10 CFR 50, Appendix B, corrective actions and enhancements identified during the assessment are entered into the corrective action program. With regard to this assessment, analysis result items related to ERO staffing that constitute an unsatisfactory result in accordance with the specifications of NEI 10-05 or NEI 12-01 are entered into the corrective action program.
Draft Emergency Operating Procedure (EP) and FLEX Guidelines (FG) documents were used during the conduct of the staffing assessments. Prior to the ONS implementation date associated with Order EA-12-049 per the current refueling outage schedule, a review of this report will be performed based on the final validated FGs and any applicable new procedures not available when the staffing table tops were performed.
This report will be updated if the staffing assessment results change.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 3 PHASE 2 STAFFING ANALYSIS
SUMMARY
The on-shift ERO analysis concluded that current ONS on-shift staffing present for the "no site access" 6-hour time period is sufficient to perform the EP, FG and emergency response tasks. However, shift personnel are not yet trained to perform the FG tasks.
The expanded ERO analysis concluded that the current ONS augmenting ERO is sufficient to fill positions for the expanded ERO functions. Thus, the ERO resources and capabilities necessary to implement Transition Phase coping strategies performed after the end of the "no site access" 6-hour time period do exist in the current program.
3.1 On-Shift Staffing Task Analysis Results Refer to Section 6.2, On-Shift Staffing Analysis Results Tables, for documentation of the on-shift staffing task analysis results.
3.1.1 Unassigned Tasks The task analysis did not identify any unassigned tasks.
3.1.2 Performance Validation Note - Per NEI 10-05, a validated task is one that has a controlling method (i.e., a program or process) by which the capability to perform the task has been analyzed, such as within the Operations Training Program or the EP Drill Program.
The task analysis did not identify any EP or Emergency Plan tasks performed by the on-shift positions that were not validated.
The task analysis did identify that the performance of FG tasks is currently not incorporated into the operator or other applicable training program.
3.1.3 Potential Overlap The task analysis identified two potential task overlaps that were performed by the on-shift personnel in response to the ELAP event.
- The Communicator performed the tasks of State/Local notification (5/9) and NRC notifications (5/13) using the satellite phone. Per NEI 10-05 Table 3-1, personnel that perform continuous NRC communications and other tasks must be evaluated by time motion analysis.
" The Fire Brigade Leader performed the tasks of Contact with the National SAFER Resource Center (NSRC) (2/20) and State/Local notification (5/9) using the satellite phone. Per NEI 10-05 Table 3-1, personnel that perform State/Local notification (5/9) and other operations related tasks must be evaluated by time motion analysis.
(Note: The parentheticalreferences equates to (Table#/line#) in Section 6.2)
The Security Shift Supervisor performs security contingency plan and Emergency Plan tasks (personnel accountability) during the ELAP event. A representative of the ONS Security Department analyzed the Emergency Plan task assigned to SSS. It was concluded that performance of the Emergency Plan task did not cause an overlap with the Security Plan tasks. Tasks related to the Security Plan are not specifically documented in this analysis due to their security-sensitive nature. No security personnel credited in the Security Plan were assigned tasks associated with the implementation of mitigating strategies during the ELAP event.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 3.2 On-Shift Staffing Time Motion Study (TMS) Results Note - Time motion analysis data was developed during the task analysis using draft FGs and the informed judgment of the FLEX subject matter experts. In accordance with the methodology provided in NEI 10-05 informed judgment can be used for tasks where directly applicable operating experience is not available and actual timed performance is not practical.
Refer to Attachment 3, NEI 10-05 Appendix D and E On-Shift Staffing Analysis Results Tables, for additional documentation of the on-shift staffing time motion study results.
3.2.1 Unassigned Tasks The time motion analysis did not identify any unassigned tasks.
3.2.2 Overlap Resulting in Overburden The time motion analysis did not identify any task overlap that resulted in overburden of the position.
- The Communicator performed the tasks of State/Local notification (5/9) and NRC notifications (5/13) using the satellite phone. The State/local notification task was performed for the initial SAE notification from T=30 to T=60. NRC continuous communications began at T=75 following the attempt to activate ERDS (5/11).
Responsibility for follow-up State/local notification was then assigned to the Fire Brigade Leader. Communicator task performance was sequential and thus not an overlap.
" The Fire Brigade Leader performed the tasks of Contact NSRC (2/20) and State/Local notification (5/9) using the satellite phone. Follow-up State/local notifications were performed from T=90 to T=120, T=150 to T=180, T=210 to T=240, T=270 to T=300 and T=330 to T=360. Contact NSRC was performed from T=128 to T=138. Fire Brigade Leader task performance was sequential and thus not an overlap.
3.3 Augmented and Expanded ERO Assessment Results Refer to Section 7 for details of the expanded ERO functional staffing resources.
NEI 12-01 Table 3.1, less SAMG implementation, assumes a specified staffing consideration for one unit is multiplied by the number of units, then doubled in order to support expanded ERO staffing for two 12-hour shifts.
(Note: While ONS has three units, it only has two control rooms due to a shared control room for Units I and 2. A shared TSC and OSC supportsall three units)
Based on the NEI 12-01 assumption that the expanded ERO needs 2 Operations Superintendents per unit for 24/7 shift coverage, the analysis identified that augmented ERO personnel had only 5 of the 6 qualified Operations Coordinators assumed for ELAP.
Additionally, the expanded ERO analysis determined that agreements and company resources, and their logistics, have been implemented to allow the transportation of the expanded ERO and equipment to the station.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 3.4 List of Analysis Results The following items are the analysis results from this assessment that were documented in the corrective action program to ensure they don't potentially hinder station personnel from performing response tasks in a timely manner:
Analysis Result Item Description
- 1: Prior to the ONS implementation date associated with Order EA-12-049 per the current refueling outage schedule, a review of this report will be performed based on the final validated FGs and any applicable new procedures not available when the staffing tabletop reviews were performed. This report will be updated if the staffing assessment results change.
- 2: ONS has 5 Operations Superintendents credited in the ERO. The NEI 12-01 methodology assumes that 6 are needed in order to support 24/7 staffing of a three unit event.
- 3 ONS Drill and Exercise procedures do not currently include evaluation objectives or demonstration criteria for FLEX.
- 4 The position specific ERO response assessment confirmed that there were an adequate number of qualified personnel for the 2 most manpower intensive strategies, but it was unclear if all personnel had a method to be called in or were trained to self-report.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 4 SCOPE OF THE ELAP ERO STAFFING ASSESSMENT
- 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 that must be performed prior to the end of the "no site access" 6-hour time period.
- Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.
" Transition Phase - Implementation of strategies that involve 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, 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 applicable EOP actions and FG strategies for the ELAP event in place at the time of the assessment.
" Such actions include the shedding of non-essential battery loads, use of portable generators or batteries, opening room and cabinet doors, water/coolant conservation or makeup using portable equipment, etc.
" These actions do not include those associated with cross-tying AC power sources or electrical distribution busses between units for multi-unit sites (since all units are assumed affected).
- 3. Evaluate the existing EOPs and draft FGs for responding to an extended loss of AC power affecting all units.
- 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 augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" 6-hour time period.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 5 ASSUMPTIONS OF THE ELAP ERO STAFFING ASSESSMENT
- 1. The ELAP event occurs during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday). This analysis uses 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as the time period to conduct the on-shift ERO response actions.
See assumption 13.A below.
- 2. Only personnel required to be on-shift are credited in the staffing analysis. Interim minimum on-shift staffing reductions allowed by Technical Specifications and/or Technical Requirements Manual are not invoked for the study.
The on-shift personnel complement for this event includes the minimum required number and composition as described in the ONS Emergency Plan.
Function.al.Area- Major Tasks Emergency Positions
- 1. Plant Operations and Control Room Staff CR Supervisor (SRO) 3 Assessment of Control Room Operator (RO) 6 Operational Aspects (a) Non-Licensed Operator (NLO) 3
- 2. Emergency Conto Direction and Control Command and Control Ops Shift Manager (SM) 1 Licensee____ ____ ___ qperatrA3O/RO/NLIT
- 3. Notification & SRO 1 Local/State : ...........
Operator (SRO /kR O)Ni ........................
Communication Federal Dose Assessment RP Qualified Individual 1
- 4. Radiological Assessment In-plant Surveys RP Qualified Individual I Onsite Surveys RP Qualified Individual 1 Chemistry Chemistry Technician I1 Tech Support - OPs Shift Technical Advisor
- 5. Plant System Core Damage Shift Technical Advisor P)
Engineering, Repair, and .
EngnerigReaiandi__-_al__ Mainteance Corrective Actions Repair and Corrective Actions MaE Maintenance 2 IAE Maintenance 2
Fire Brigade Lead (SRO/NLO) 1
- 7. Fire Fighting (c) Fire Brigade Member (NLO) 4 Fire Brigade Member 5 (b, c)
- 8. 1S"Aid and Rescue -- MERT (d) 2
- 9. Site Access Control and Security & Accountability Security Shift Supervisor I Accountability Security Personnel (e)
Mihiimu #of Personnel:'31i (a) The control Room staff complement is reflective of 3 units in operation.
(b) May be filled by an individual filling another position provided they are qualified to do the collateral functional.
(c) The Fire Brigade requirement of ten members is met by using five personnel from Operations (including the Fire Brigade Leader) and five personnel from either SPOC, Radiation Protection, Chemistry or Security (SLC 16.13.1).
(d) The Medical Emergency Response Team (MERT) can be filled by any qualified technician.
(e) Per Duke Energy ONS Security Plan.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffimg Analysis Report
- 3. On-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions. The following are the assumed locations of the on shift personnel:
- Operations Shift Manager (SM) ............................................................. SM Office
- Shift Technical Advisor (STA) ................................................ Work Control Center
" U1 Control Room Supervisor (CRS1) .............................................. Control Room
- U2 Control Room Supervisor (CRS2) .............................................. Control Room
" U3 Control Room Supervisor (CRS3) .............................................. Control Room
" Communicator (COM) ............................................................ Work Control Center
" U1 At the Controls RO (OATC1) ...................................................... Control Room
" U1 Balance of Plant RO (BOP1) ...................................................... Control Room
- U2 At the Controls RO (OATC2) .............. ....................................... Control Room
- U2 Balance of Plant RO (BOP2) ...................................................... Control Room
- U3 At the Controls RO (OATC3) ...................................................... Control Room
" U3 Balance of Plant RO (BOP3) ...................................................... Control Room
- U1 Nuclear Equipment Operator #1 (AO1) ....................................... Control Room
" U1 Nuclear Equipment Operator #2 (A04) ................................... Turbine Building
" U2 Nuclear Equipment Operator #1 (A02)....................................... Control Room
" U2 Nuclear Equipment Operator #2 (A05)................................... Turbine Building
" U3 Nuclear Equipment Operator #1 (A03)....................................... Control Room
- U3 Nuclear Equipment Operator #2 (A06) ................................... Turbine Building
- Nuclear Equipment Operator- Outside (A07) ............................. Turbine Building
- Fire Brigade Lead (FBL) ........................................................ Work Control Center
- Mechanical Technician #1 (Mechl) .............................................. Turbine Building
- Mechanical Technician #2 (Mech2) .............................................. Turbine Building
" I&E Technician #1 (IAE1) ............................................................. Turbine Building I&E Technician #2 (IAE2) ............................................................. Turbine Building
- RP Technician #1 (RP1) .............................................................. Turbine Building
- RP Technician #2 (RP2) ............................................................. Auxiliary Building
- RP Technician #3 (RP3) ............................................................. Auxiliary Building
- Chemistry Technician (Chem) ......................................................... Warehouse #3 e Security Shift Supervisor (SAS) ...................................................................... SAS
- ME RT # 1 (ME RT 1) ......................................................................................... PA P
- ME RT #2 (ME RT2) ......................................................................................... PA P Note: Auxiliary Operator (AO) is equivalent to Non-Licensed Operator (NLO)
- 4. Equipment credited in current coping strategies remains available for use including the FLEX equipment connections and system interfaces.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report
- 5. The total loss of AC power affecting all three units assumes the following:
- Appendix "R" emergency lighting is available during the period of power loss and operators can carry flashlights.
- If a security emergency diesel generator (EDG) exists, consider it unavailable..
- The Public Address System is not powered.
- Plant operations radios are available throughout the event (using installed and spare batteries).
- Satellite phones are available throughout the event.
- ERDS and ERFIS communications capabilities are lost as a result of the 25 mile telecommunications blackout range.
- Power operated door locks can be overridden by key or other mechanism.
- 6. The Standby Shutdown Facility (SSF) will be activated, as it is robust per the guidance of NEI 12-06.
- 7. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.
- 8. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiological Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a RP Technician.
- 9. The on-site security organization is able to satisfactorily perform tasks related to Site and Protected Area Access Controls. 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.
The use of Security personnel for any mitigation actions must be in accordance with NEI guidance. (Refer to Attachment 1 Reference #4)
- 10. Individuals holding the position of RP Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.
- 11. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization or the NRC.
- 12. The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions.
Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.
- 13. For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase, and any required Transition Phase, coping actions. Thus, adequate core cooling is maintained throughout the 6 six hour duration.
No core damage occurs and no entry into Severe Accident Management Guidelines (SAMGs) is required.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report
- 14. 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. It is assumed that those Emergency Plan functions performed by the augmented ERO will be delayed for the 6-hour period (e.g., offsite field monitoring).
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.
- 15. All offsite facilities and staging areas are available including those located within the 25 mile telecommunications blackout range.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 6 ON-SHIFT ERO RESPONSE CAPABILITY This section of the assessment documents the ability of the on-shift ERO to implement emergency procedures and coping strategies performed prior to the end of the "no site access" 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time period.
6.1 ELAP Event Description and Initial Conditions A large-scale external event occurs that results in a loss of off-site power combined with a failure of the emergency and SBO diesel generators to load. The scope of the event includes the following conditions:
° an extended loss of ultimate heat sink (LUHS) occurs
- all three units are impacted (all units are in operation at the time of the event)
- station access is impeded Initially, all three reactors are operating at full power. Upon the loss of AC power, all reactors are successfully shut down.
This event results in a Site Area Emergency (SAE) Emergency Classification Level (ECL) based on Emergency Action Level (EAL) [4.5.S.1], Loss of all AC. The scenario is designed such that restoration of any AC power source is not possible before the arrival of ERO personnel (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).
Initial Conditions All three units are at 100% power at equilibrium, middle of core life.
Scenario Events An offsite electrical transient occurs resulting in a loss of all offsite power.
No Emergency Diesel Generators (EDGs) can be synchronized to any unit AC bus, resulting in a multi-unit Loss of all AC power. For ONS this equates to a loss of power to the Emergency busses from any power source (e.g., loss of Keowee Hydro, Lee Combustion turbine, etc.).
Adequate core cooling is maintained throughout the 6-hour duration. No core damage occurs and no entry into SAMG is required.
No abnormal radiological conditions exist during this event.
Note - refer to Attachment 1 for a list of procedures used to assess the tasks performed during the ELAP scenario.
The Standby Shutdown Facility (SSF) is operable during the time period under analysis.
Page 14
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report.
6.2 On-Shift Staffinq Analysis Results Tables TARILF I - On-Shift Positions Extended Loss of All Power (ELAP'I Emergency Plan Augmentation Unanalyzed Time Motion Study Line On-shift Position Reference Elapsed Time (min) Role in Table#/Line# Task? (TMS) Required?
2/1 5/1
- 1. Operations Shift Manager (SM) Figure B-8a 360 5/3 No No 5/5 5/8
- 2. Shift Technical Advisor (STA) Figure B-8a 360 2 /2 No No 2 / 3EOP No
- 3. U1 Control Room Supervisor (CRS1) Figure B-8a 360 2 / 3 FG Yes Yes 2 / 4 EOP No
- 4. U2 Control Room Supervisor (CRS2) Figure B-8a 360 2 / 4 FG Yes Yes 2 / 4EOP No
- 5. U3 Control Room Supervisor (CRS3) Figure B-8a 360 2 / 5 FG Yes Yes 5/9
- 6. Communicator (COM), Figure B-8a 360 5 /11 No Yes 5/13 2 /7 EOP No
- 13. U1 Nuclear Eq. Operator #1 (AO1) Figure B-8a 360 2/13 FG Yes Yes
- 14. U1 Nuclear Eq. Operator #2 (A04) Figure B-8a 360 2 / 14 No No 2 /I15EOP No
- 15. U2 Nuclear Eq. Operator #1 (A02) Figure B-8a 360 2 /15 FG Yes Yes
- 16. U2 Nuclear Eq. Operator #2 (A05) Figure B-8a 360 2 / 16 No No 2 /17 EOP No
- 17. U3 Nuclear Eq. Operator #1 (A03) Figure B-8a 360 2 / 17 FG Yes Yes
- 18. U3 Nuclear Eq. Operator #2 (A06) Figure B-8a 360 2 / 18 No No Page 15
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report -
Emergency Plan Augmentation . Unanalyzed Time Motioný Study Line On-shift Position Reference Elapsed Time (min) Role in Table#/Line# Task? (TIVIS) Required?
- 19. Outside Nuclear Eq. Operator (A07) Figure B-8a 360 2 / 19 No No
- 20. Fire Brigade Leader (FBL) Figure B-8a 360 2.FrriaLed65 FLFgr 8 2/ /20 9 EPFG Yes No Yes Yes
- 21. IAE Technician #1 (IAE1) Figure B-8a 360 2 / 21 Yes Yes
- 22. IAE Technician #2 (IAE2) Figure B-8a 360 2 / 22 Yes Yes
- 23. Mechanical Technician #1 (Mechl) Figure B-8a 360 2 / 23 Yes Yes
- 24. Mechanical Technician #2 (Mech2) Figure B-8a 360 2 / 24 Yes Yes
- 25. RP Technician #1 (RP1) Figure B-8a 360 N/A N/A N/A
- 26. RP Technician #2 (RP2) Figure B-8a 360 N/A N/A N/A
- 27. RP Technician #3 (RP3) Figure B-8a 360 4/6 No No
- 28. Chemistry Technician (Chem) Figure B-8a 360 N/A N/A N/A
- 29. Security Shift Supervisor (SAS) Figure B-8a 360 5 / 15 No No
- 31. MERT #2 (MERT2) Figure B-8a 360 N/A N/A N/A Note: NEI 10-05 requirements for Time Motion Study analysis following the identification of potential task overlap are satisfied by evaluating the timing and duration of the activities by subject matter experts during the task analysis table top. See Section 3.2.
Page 16
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report TABLE 2 - Plant Operations & Safe Shutdown Extended Loss of All Power (ELAP)
Minimum Operations Crew (Three Units - Two Control Rooms)
Controlling Line On-Shift Position Task Description Method Operations Shift Manager Plant and crew oversight (AD-OP-ALL-I 000) Ops Training (SM)
Direct OATC1 to perform immediate actions (EP/1/A/1800/001, Steps 3.1-3.5)
Transfer to the Blackout Tab and verify AP/25 in progress (AP/25)
Perform steps 1-6 and direct OATC1 to perform step 7, Enclosure 5.32, Load Shed of Inverters (EP/1 /1800/001, Blackout tab, Steps 1-7)
Read EP/1/A/1800/001 Blackout Tab Steps 8-41 Direct step 34, Enclosure 5.44, Parallel Actions for SBO (EP/01 Blackout tab Step 34) Ops Training Direct A05 to emergency purge generator H2 (EP/001, Blackout tab, Step 28)
Supervisor Direct BOP1 to cooldown RCS to 240-250' F (EP/001, Blackout tab, Steps 192-194) 3.U Control Room Initiate initial assessment and FLEX equipment staging per FG/O/A/1900/005 (EP/001, Blackout (CRS1) tab, Step 35, IAAT)
Dispatch FBL to contact NSRC (FG/005, Step 4.1-4.2)
Direct Mechl &2, IAEI &2 to perform debris removal and perform FG/005 Enclosures 5.5, SPOC Supervisor Actions for ELAP, and 5.7, staging FLEX mitigation strategies pump at intake Direct OATC1 to perform in plant Ul damage assessment (FG/005, Enclosure 5.1) N/V Verify all units in MODE 1-4 (FG/005, Step 4.7) (None In Place)
Direct AO1 to perform UI external damage assessment (FG/005, Enclosure 5.1)
Direct staging FLEX equipment for ELAP (FG/005, Section 4A)
Direct OATC2 to perform immediate actions (EP/2/A/1 800/001, Steps 3.1-3.5)
Transfer to the Blackout Tab and verify AP/25 in progress (AP/25)
Power PSW - Step 1 RNO 7 realizes no power to PSW (U2 Encl 5.42)
Perform steps 1-6 and direct OATC2 to perform Enclosure 5.32, Load Shed of Inverters Ops Training (EP/2/1800/001, Blackout tab, Steps 1-7)
Supervisor Read EP/2/A/1800/001 Blackout Tab Steps 8-41 4.U2 Control Room Direct (CRS2) Direct step BOP234, to Enclosure cooldown 5.44, Parallel RCS to Actions 240-250' for SBOBlackout F (EP/001, (EP/01 Blackout tab, Stepstab192-194)
Step 34)
Direct OATC2 to perform in plant U2 damage assessment (FG/005, Encl 5.2)
Direct A02 to perform U2 external damage assessment (FG/005, Encl 5.2) N/V Direct Section 4B Unit 2, staging FLEX equipment for flood events (FG/005, Section 4B Unit 2) (None In Place)
Direct AO1, A02 and RP1 to initiate and align Alternate Spent Fuel Cooling to Boggs Box (FG/005, Section 4A, Step 20) 1 Page 17
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Controlling Line On-Shift Position Task Description Method Direct OATC3 to perform immediate actions (EP/3/A/1800/001, Steps 3.1-3.5)
Transfer to the Blackout Tab and verify AP/25 in progress (AP/25)
Perform steps 1-6 and direct OATC to perform Enclosure 5.32, Load Shed of Inverters (EP/3/1800/001, Blackout tab, Steps 1-7) Ops Training U3 Control Room Supervisor Read EP/3/A/1 800/001 Blackout Tab Steps 8-41 (CRS3) Direct Enclosure 5.44, Parallel Actions for SBO (EP/01 Blackout tab Step 34)
Direct BOP3 to C/D RCS to 240-250° F (EP/001, Blackout tab, Steps 192-194)
Direct OATC3 to perform in plant U3 damage assessment (FG/005, Encl 5.3) N/V Direct A03 to perform U3 external damage assessment (FG/005, Encl 5.3) (None In Place)
Direct section 4a, staging phase 2 FLEX equipment for ELAP events (FG/005, Section 4A)
- 6. Communicator (COM) N/A N/A Perform manual actions (EP/001, Steps 3.1-3.5)
Dispatch AO1 to manually start Ul TDEFDWP (EP/001, Rule 3, Steps 1-17)
Verify cross-tie with alternate unit is desired and dispatch A04 to cross tie EFW for U1 (EP/001, Rule 3, Step 18)
Read step to establish SG feed from PSW (EP/001, Rule 3, Step 22) Ops Training Direct AO1 to load shed inverters (EP/001, Step 7)
Perform restoration of power (EP/01 Blackout tab Encl 5.38)
Direct A04/5 to open atmospheric dump bypass valves (EP/001, Encl 5.24, Step 1)
Perform step 34, parallel actions for SBO (EP/001, Encl 5.44)
Perform Ul in plant damage assessment (FG/005, Encl 5.1) N/V (None In Place)
Initiate SSF EOP AP/0/A/1700/025 (EP/001, Step 3.5 RNO)
Verify an RO is staged to perform AP/25 at SSF (AP/25, through Step 4.3)
Feed SG with ASW and seals with RC makeup pump from SSF (AP/25) Ops Training
- 8. Ul BOP (BOP1) Direct A04 to isolate PDW (AP/25, Step 4.24)
Cooldown RCS to 240-250' F (EP/001, Blackout tab, Steps 192-194)
Direct IAE1 and MECH1 to prepare the Dedicated Submersible Pump for installation in Unit 2 N/V CCW piping per AM/0/A/1 300/059 (AP/25, Step 4.23) (None In Place)
Perform manual actions (EP/001, Steps 3.1-3.5)
Dispatch A02 to manually start U2 TDEFDWP (EP/001, Rule 3, Steps 1-17)
Verify cross-tie with alternate unit is desired and dispatch A05 to cross tie EFW for U2 (EP/001, Rule 3, Step 18)
- 9. U2 ATC RO (OATC2) Read step to establish SG feed from PSW (EP/001, Rule 3, Step 22) Ops Training Direct A02 to load shed inverters (EP/001, Step 7)
Direct A06/7 to open atmos dump bypass valves (EP/001, Encl 5.24, Step 1)
Determine SSF Status (EP/001 Blackout tab Step 27)
Perform restoration of power (EP/01 Blackout tab Encl 5.38)
Perform step 34, parallel actions for SBO (EP/001, Encl 5.44)
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Controlling Line On-Shift Position Task Description Method Perform U2 in plant damage assessment (FG/005, Encl 5.2) N/V (None In Place Initiate SSF EOP AP/0/A/1700/025 (EP/001, Step 3.5 RNO)
- 10. U2 BOP (BOP2) Verify an RO is staged to perform AP/25 at SSF (AP/25, through Step 4.3) Ops Training Feed SG with ASW and seals with RC makeup pump from SSF (AP/25)
Cooldown RCS to 240-2500 F (EP/001, Blackout tab, Steps 192-194)
Perform manual actions (EP/001, Steps 3.1-3.5)
Dispatch A03 to manually start U3 TDEFDWP (EP/001, Rule 3, Steps 1-17)
Verify cross-tie with alternate unit is desired and dispatch A06 to cross tie EFW for U3 (EP/001, Rule 3, Step 18)
Read step to establish SG feed from PSW (EP/001, Rule 3, Step 22) Ops Training Direct A03 to load shed inverters (EP/001, Step 7)
Determine SSF Status (EP/001 Blackout tab Step 27)
Perform restoration of power (EP/01 Blackout tab Encl 5.38)
Perform step 34, parallel actions for SBO (EP/001, Encl 5.44)
Perform U3 in plant damage assessment (FG/005, Encl 5.3) N/V (None In Place)
Initiate SSF EOP AP/0/A/1 700/025 (EP/001, Step 3.5 RNO)
- 12. U3 BOP (BOP3) Verify an RO is staged to perform AP/25 at SSF (AP/25, through Step 4.3) Ops Training Feed SG with ASW and seals with RC makeup pump from SSF (AP/25)
Cooldown RCS to 240-250' F (EP/001, Blackout tab, Steps 192-194)
Perform manual start U1 TDEFDWP (EP/001 Encl 5.26)
Load shed inverters (EP/001, Encl 5.32)
U1 Nuclear Eq. Operator #1 Open U3 atmospheric dump block bypass valves (EP/001, Encl 5.24, Step 1) Ops Training (AO1) Perform SSF plant actions for U1 (AP/25, Encl 5.3 A)
Perform U1 external damage assessment (FG/005, Encl 5.1) NN Initiate and align Alternate Spent Fuel Cooling to Boggs Box (FG/1-2/A/1900/011) (None In Place)
Cross tie EFW for U2 (EP/001, Rule 3, Step 18)
- 14. U1 Nuclear Eq. Operator #2 Open atmospheric dump block bypass valves (EP/001, Encl 5.24 Step 1) Ops Training (A04) Isolate PDW (AP/25, Step 4.24)
Divert SSF diesel service water discharge to yard drain (AP/25, Step 4.34)
Perform manual start U2 TDEFDWP (EP/001, Encl 5.26)
U2 Nuclear Eq. Operator #1 Load shed inverters (EP/001, Encl 5.32) Ops Training
- 15. (A02) Perform SSF plant actions for U2 (AP/25, Encl 5.3 B)
Perform U2 external damage assessment (FG/005, Encl 5.2) NN Initiate and align Alternate Spent Fuel Cooling to Boggs Box (FG/1 -2/A/1 900/011) (None In Place)
Page 19
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Controlling Line On-Shift Position Task Description Method Cross tie EFW for U2 (EP/001, Rule 3, Step 18)
- 2 Open atmospheric dump block bypass valves (EP/001, Encl 5.24 Step 1)
- 16. U2 Nuclear Eq. Operator Check Service Air Diesel Compressor (EP/001, Enclosure 5.44, step 2) Ops Training (AO5) Emergency purge generator hydrogen (EP/001, Encl 5.17)
Lower SG pressure with ADVs (EP/001, Blackout tab, Step 196)
Perform manual start U3 TDEFDWP (EP/001, Encl 5.26)
Load shed inverters (EP/001, Encl 5.32) Ops Training
- 17. U3 Nuclear Eq. Operator #1 Perform SSF plant actions for U3 (AP/25, Encl 5.3 C)
Perform U3 external damage assessment (FG/005, Encl 5.3) (None In Place)
Cross tie EFW for U3 (EP/001, Rule 3, Step 18)
U3 Nuclear Eq. Operator #2 Open atmospheric dump block bypass valves (EP/001, Encl 5.24 Step 1)
- 18. Perform Pump - Submersible - Emergency SSF Water Supply - Installation And Removal Ops Training (AO6) (AM/0/A/1300/059)
Lower SG pressure with ADVs (EP/001, Blackout tab, Step 196)
Open U2 atmospheric dump block bypass valves (EP/001, End 5.24, Step 1)
- 19. Outside OperatorNuclear (A07) Eq. Check U1/2/3- turbine Refill EWST IAAT EWST shafts<60k are stopped
((EP/001,((EP/001, EnclosureEnclosure 5.44, step5.44, 12))step 5)) Ops Training Lower SG pressure with ADVs (EP/001, Blackout tab, Step 196)
____ ____________________(None In Place)
Other (non-Operations) Personnel Controlling Line On-Shift Position Task Description Method Prepare the Dedicated Submersible Pump for installation in U2 CCW piping (AM/O/A/1300/059) N/V
- 21. IAE Technician #1 (IAE1) Perform debris removal and Enclosure 5.5, SPOC supervisor actions for ELAP, and Enclosure (None In Place) 5.7, staging FLEX mitigation strategies at intake (FG/005 Steps 4.5 and Encl 5.5 and Encl 5.7)
IAE Technician #2 (IAE2) Prepare the Dedicated Submersible Pump for installation in U2 CCW piping (AM/0/A/1300/059) N/V
- 22. Perform debris removal and Enclosure 5.5, SPOC supervisor actions for ELAP, and Enclosure (None In Place) 5.7, staging FLEX mitigation strategies at intake (FG/005 Steps 4.5 and Encl 5.5 and Encl 5.7)
Mechanical Technician #1 Prepare the Dedicated Submersible Pump for installation in U2 CCW piping (AM/0/A/1300/059) N/V
- 23. (Mechl) Perform debris removal and Enclosure 5.5, SPOC supervisor actions for ELAP, and Enclosure 5.7, staging FLEX mitigation strategies at intake (FG/005 Steps 4.5 and Encl 5.5 and Encl 5.7) (None In Place)
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Controlling Line On-Shift Position Task Description Method Mechanical Technician #2 Prepare the Dedicated Submersible Pump for installation in U2 CCW piping (AM/O/A/1300/059) N/V
- 24. (Mech2) Perform debris removal and Enclosure 5.5, SPOC supervisor actions for ELAP, and Enclosure (None In Place) 5.7, staging FLEX mitigation strategies at intake (FG/005 Steps 4.5 and End 5.5 and End 5.7)
- 25. RP Technician #1 (RP1) Initiate and align Alternate Spent Fuel Cooling to Boggs Box (FG/1 -2/A/1 900/011) N/V (None In Place)
- 26. RP Technician #2 (RP2) N/A N/A
- 27. RP Technician #3 (RP3) N/A N/A
- 28. Chemistry Technician (CT) N/A N/A N/A N/A
- 29. (SSS) Shift Supervisor Security
- 30. MERT #1 (MERT1) N/A N/A
- 31. MERT#2 (MERT2) N/A N/A TABLE 3 - Firefighting Extended Loss of All Power (ELAP)
Controlling Line Performed By Task Description Method 1 Fire Brigade Leader N/A N/A (FBL)
- 2. Fire Brigade Member #1 N/A N/A (A04)
- 3. Fire Brigade Member #2 N/A N/A (AO5)
- 4. Fire Brigade Member #3 N/A N/A (A06)
- 5. Fire Brigade Member #4 N/A N/A (A07)
- 6. Fire Brigade Member #5 N/A N/A (MECH1)
- 7. Fire Brigade Member #6 N/A N/A (MECH2)
- 8. Fire Brigade Member #7 N/A N/A (IAE1)
- 9. Fire Brigade Member #8 N/A N/A (IAE2)
- 10. Fire Brigade Member #9 N/A N/A
_(RP2)
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report TABLE 4 - Radiation Protection and Chemistry Extended Loss of All Power (ELAP)
Performance Time Period After Emergency Declaration (minutes)
- Position Performing Function/Task -,0-30 30-60 60-90 90-120 120-150 150-180 180-210 21'0-240 240-300 300-330 330-360 1 In-Plant Survey On-Shift Position:
- 2. On-Site Radiological Survey On-Shift Position:
Personnel Monitoring On-Shift Position:
Job Coverage On-Shift Position:
Offsite Radiological Assessment On-Shift Position:
- 6. Other RP: Obtain Back-up Met Data X X X X X On-Shift Position: RP3
- 7. Sampling On-Shift Position:
Other Chem - Describe On-Shift Position:
Note: Line 6 RP3 tasks to obtain back-up met data each took 10 minutes to perform. See timeline for specific time intervals.
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ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report TABLE 5 - Emergency Plan Implementation Extended Loss of All Power (ELAP)
Line Function/Task On-Shift Position Controlling Method JPM#: SRO-001, 002, 003, 006A, 007A, 008, 013, 014, 015, SM 017,018,019,020
- 1. Declare the Emergency Classification Level (ECL)
D.1.2 The correct Event Classification Level was formally declared within 15 minutes.
- 2. Approve Offsite Protective Action Recommendations N/A N/A - GE not declared for EPAP event at ONS in first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
- 4. Approve extension to allowable dose limits N/A N/A - Not applicable to ELAP event Notification and direction to on-shift staff B.1 Demonstrate the ability of the normal staff complement
- 5. (e.g., to assemble, evacuate, etc.) SM to perform the functions of the onshift ERO. [includes 8 demonstration criteria]
E.1.2 The ERO group page(s) was (were) initiated within 15
- 6. ER notification N/A, ERO self- minutes of event declaration.
activation credited E.1.3 The Nuclear ERO Call-out System was initiated within 15 minutes of the event declaration.
- 7. Abbreviated NRC notification for Design Basis Threat event N/A N/A - Not applicable to ELAP event
COM E.2.3 State / local notifications were performed within 15
- 9. Perform State/local notifications FBL minutes requiringofnotification.
the declaration or change in conditions
- 10. Complete NRC event notification form N/A E.4.2 The NRC form was completed accurately.
.Activate ERS F.3.2 ERDS initiated within one hour of an Alert or higher declaration.
- 12. Offsite radiological assessment N/A N/A - Not applicable to ELAP event for ONS E.4.1 The NRC was notified via Event Notification System (ENS) immediately after completing State / local
- 13. Perform NRC notifications COM notification and within one hour of event classification.
E.4.2 A communicator was assigned to maintain an open line over the ENS circuit when requested by the NRC.
- 14. Perform other site-specific event notifications N/A N/A - Not applicable to FLAP event for ONS (e.g., INPO, ANI, etc.)
SC-1402, CAS/SAS Operator
- 15. Personnel accountability SAS J.2.2 All unaccounted-for individuals were identified by name I _within 30 minutes of announcing Site Assembly.
Note: Line #3, #8 and #9 includes initial and follow-up State/local notifications.
Page 23
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 6.3 ELAP On-Shift Staffing Task Timetable
'Time P Duration ition(s) .
.PT+mins .... Action* , ,; : ý. ,I (min) 0 Complete loss of station AC power event occurs CRS1I oCR2 Direct OATC1/2/3 to perform manual actions CRS3 (P/*/A/1 800/001, Steps 3.1-3.5)
OATC1 0 OATC2 Perform manual actions (EP/001, Steps 3.1-3.5) 2 OATC3 BOP1 1 BOP2 Initiate SSF EOP AP/0/A/1 700/025 (EP/001, Step 3.5 RNO) 1 BOP3 BOPi BOP2 Verify an RO is staged to perform AP/25 at SSF BOP3 (AP/25, through Step 4.3)
CRS1 2 CRS2 Transfer to the Blackout Tab and verify AP/25 in progress (AP/25) 1 CRS3 3 CRS2 Power PSW - Step 1 RNO 7 realizes no power to PSW (U2 Encl 5.42) 3 3 OATC1 OATC2 Dispatch AO1/2/3 to manually start U1/2/3 TDEFDWP OATC3 (EP/001, Rule 3, Steps 1-17)
AO1 5 A02 Perform manual start U1/2/3 TDEFDWP (EP/001, Encl 5.26) 8 A03 OATC1 OATC2 Verify cross-tie with alternate unit is desired and dispatch A04/5/6 to 5OATC3 cross tie EFW for U1/2/3 (EP/001, Rule 3, Step 18)
OATC3 A04 Attempt to perform cross-tie with alternate unit 6 AO5 (EP/001, Rule 3, Step 18 20 A06 Note - Recalled to CR when TDEFDWP is determined to not start.
CRS1 Perform/read steps 1-6 and direct OATC1/2/3 to perform load shed of 6 CRS2 6_____ CRS3 inverters during SBO (EP/*/1800/001, Blackout tab, Steps 1-7)
CRS3 OATC1 Read step to establish SG feed from PSW per Encl 5.45. (EP/001, 6__ 6 OATC2
_ OATC3 Rule 3, Step 22, No feed available, rule 3 no help at this point) 1 OATC3 BOPi 8 BOP2 Feed SG with ASW and seals with RC makeup pump from SSF Duration BOP3 (AP/25)
.. CRS1 12 CRS2 Read EP/*/A/1800/001 Blackout Tab Steps 8-41 21 CRS3 AO1 13 A02 Return to Control Room A03 OATC1 13 OATC2 Direct AO/2/3 to load shed inverters (EP/001, Step 7) 1 OATC3 AOl 13 A02 Load shed inverters (EP/001, Encl 5.32) 8 A03 14 OATC2 Direct A07 to open atmospheric dump block bypass valves 1 1(EP/001, Encl 5.24, Step 1)
Page 24
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report (Time P....
Position(s) Action D-a(min) 15 A07 Open U2 atmospheric dump block bypass valves 10 (U2 EP/001, Encl 5.24, Step 1) 10 15 SM Declare SAE based on 4.5.S.1 (RP/O/B/1000/001) 15 SM Provide notification and direction to on-shift staff (RP/0/B/1 000/002) Duration 21 AO2, Return to Control Room A03 21 OATC3 Direct AO1 to open U3 atmospheric dump block bypass valves I (U3 EP/001, Encl 5.24, Step 1) 21 A01 Open U3 atmospheric dump block bypass valves 10 (U3 EP/001, Encl 5.24, Step 1)
OATCl 21 OATC2 Determine SSF Status (EP/001 Blackout tab Step 27)
OATC3 25 A07 Return to Control Room 25 SOATCl OATC2 Read IAAT step for restoration of power, Enclosure 5.38 OATC3 (EP/01 Blackout tab, step 26, Encl 5.38)
A04 26 A05 Return to Control Room A06, 26 OATCl Direct A04 and A05 to open Ul atmospheric dump block bypass I valves (U1 EP/001, Encl 5.24, Step 1) 26 OATC2 Direct A06 to open U2 atmospheric dump block bypass valves 1 (U2 EP/001, Encl 5.24, Step 1) 26 AO4 A05 Open atmospheric dump block bypass valves (EP/001, Encl 5.24, 10 A06 Step 1) 27 SM Complete and approve content of ENF for initial SAE 2 (RP/O/B/1000/015A)
Direct IAE1 and MECH1 to prepare the Dedicated Submersible Pump 27 BOPI for installation in Unit 2 CCW piping per AM/0/A/1 300/059 2 (AP/25, Step 4.23) 29 IAE2 Prepare the Dedicated Submersible Pump for installation in Unit 2 120 MECH2 CCW piping (AM/O/A/1300/059) 29 SM Direct COM to perform initial SAE State/local notifications 1 (RP/O/B/1000/015A) 30 COM Perform initial SAE State/local notifications (RP/O/B/1 000/01 5A) 30 30 A02 30___ AO3----
SSF - Perform Unit 2 /3 plant actions (AP/25, End 5.3 B/C) 180 ais 2 E 30 SM Direct SAS to commence Assembly/Accountability (RP/O/B/1000/009) 1 31 AO1 Return to Control Room 31 AO1 SSF - Perform Unit 1 plant actions (AP/25, Encl 5.3 A) 180 31 SSS Perform Site Assembly/Site Accountability (RP/0/B/1 000/009) 30 33 CRSl CRS2 Direct step 34, Enclosure 5.44, Parallel Actions for SBO CRS3 (EP/01 Blackout tab Step 34) 34 OATC1 OATC2 Perform step 34, parallel actions for SBO (EP/001, Encl 5.44) 30 OATC3 (Encl performed in parallel with continued progress in BO tab)
A04 36 AO5 Return to Control Room A06 36 BOP1 Direct A04 to isolate PDW (AP/25, Step 4.24) 1 Page 25
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Time' Duration (T+mins) Position(s). Action (mri) 36 A04 Isolate PDW (AP/25, Step 4.24) Duration 36 A05 Check Service Air Diesel Compressor (EP/001, Enclosure 5.44, 15 Step 2) 36 A06 Perform Pump - Submersible - Emergency SSF Water Supply - 120 Installation And Removal (AM/0/A/1300/059) 39 A07 Check U1/2/3 turbine shafts are stopped (EP/001, Enclosure 5.44, 20 Step 5) 51 A05 Return to Control Room
'59 A07 Return to Control Room 59 A07 Refill EWST - IAAT EWST <60k (EP/001, Enclosure 5.44, step 12) 60 70 COM Activate ERDS (RP/005) 5 75 COM Perform NRC notifications (RP/0/B/1000/015A) Duration 77 RP3 Obtain Met data using backup method (sat phone call to NWS) and 10 report Met data to SM (AD-EP-ALL-0202) 87 SM Complete and approve content of ENF for follow-up #1 SAE 2 (RP/O/B/I1000/02) 89 SM Direct FBL to perform follow-up #1 SAE State/local notifications 1
_(RP/0/B/1 000/01 5A) 90 FBL Perform follow-up #1 SAE State/local notifications (RP0/1B/1 000/01 5A) 30 90 CRS1 Direct A05 to emergency purge generator hydrogen per I EP/*/A/1800/001, Encl 5.17 (EP/001, Blackout tab, Step 28) 91 A05 Emergency purge generator hydrogen (EP/*/A/1800/001, Encl 5.17) 60 114 A04 Divert SSF diesel service water discharge to yard drain (AP/25, Duration Step 4.34) 119 AO7 Return to Control Room CRS1 Direct BOP1/2/3 in SSF to cooldown RCS to 240-250' F (EP/001, 121 CRS2 CRS3 Blackout tab, Steps 192-194)
BOP1 126 BOP2 Cooldown RCS to 240-250° F (EP/001, Blackout tab, Steps 192-194) Duration BOP3 126 CRS1 Initiate FG/0/A/1 900/005 - go to Step 196 (EP/001, Blackout tab, 1 Step 35, IAAT) 127 CRS1 Dispatch FBL to contact NSRC (FG/005, Step 4.1-4.2) 1 128 FBL Contact NSRC with satellite phone (FG/005, Step 4.2) 10 137 RP3 Obtain Met Data using backup method (satellite phone call to NWS) 10 and report Met data to SM (AD-EP-ALL-0202) 147 SM Complete and approve content of SAE ENF for follow-up #2 SAE (RP/0/B/1000/02)
Direct FBL to perform follow-up #2 SAE State/local notifications 149 RP/0/B/1000/015A) 149 MAE1 Return to Control Room Direct MECH1, MECH2, IAE1, and IAE2 to perform debris removal and perform Enclosure 5.5, SPOC supervisor actions for ELAP, and Enclosure 5.7, staging FLEX mitigation strategies at intake (FG/005 Steps 4.5 and Encl 5.5 and Encl 5.7)
IAE IAE21 Perform debris removal and perform Enclosure 5.5, SPOC supervisor 150 50 MECHI IAE2 stacinfoEAanEnosr5.,saigFEmiiainDatn actions for ELAP, and Enclosure 5.7, staging FLEX mitigation Duration MECH2 strategies at intake (FG/005 Steps 4.5 and Encl 5.5 and Encl 5.7)
CRS1 150 CRS2 Direct OATCl/2/3 to perform in plant Ul/2/3 damage assessment 1 1CRS3 (FG/005, Encl 5.1/2/3)
Page 26
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Time,,, Positi6n(s)
Tim.. . .Duration Action (mn)
(Ttmins) I -"I 1 II ' lm n ,,
OATC1 151 OATC2 Perform U1/2/3 in plant damage assessment (FG/005, Encl 5.1/2/3) 30 OATC3 151 AO5 Return to Control Room 151 A07 Lower SG pressure with ADVs (EP/001, Blackout tab, Step 196) Duration 151 CRS1 Verify all units in MODE 1-4 (FG/005, Step 4.7) 1 156 A06 Return to Control Room 156 A06 Lower SG pressure with ADVs (EP/001, Blackout tab, Step 196) Duration 197 RP3 Obtain Met Data using backup method (satellite phone call to NWS) 10 and report Met data to SM (AD-EP-ALL-0202)
Complete and approve content of SAE ENF for follow-up #3 SAE 207 SM (RP/0/B/1000/002) 209 SM Direct FBL to perform follow-up #3 SAE State/local notifications 1 (RP/0/B/1000/015A) 210 FBL Perform follow-up #3 SAE State/local notifications (RP/0/B/1 000/01 5A 30 210 A02 Return'to Control Room 211 AO1 Return to Control Room CRS1 CRS 211 Direct AO1/2/3 to perform UL1/2/3 external damage assessment CRS3 (FG/005, Encl 5.1/2/3)
AO1 211 A02 Perform U1/2/3 external damage assessment (FG/005, Encl 5.1/2/3) 60 A03 257 RP3 Obtain Met Data using backup method (satellite phone call to NWS) 10 and report Met data to SM (AD-EP-ALL-0202) 267 SM Complete and approve content of SAE ENF for follow-up #4 SAE 2 (RP/0/B/1 000/002) 269 SM Direct FBL to perform follow-up #4 SAE State/local notifications 1 (RP/0/B/1000/015A) 268 CRS1 CRS2 Perform staging Phase 2FLEX equipment for ELAP events (FG/005, 10 8CRS3 Section 4A)
CRS3 270 FBL Perform follow-up #4 SAE State/local notifications (RP/0/B/1000/015A 30 AO1 271 A02 Return to Control Room AO3 Direct AO1, A02 and RP1 to initiate and align Alternate Spent Fuel
- 278 CRS2 Cooling-to Boggs Box per FG/1-2/A/1900/011 (FG/005, Section 4A, 1 Step 20) 279 AO1 A02 Initiate and align Alternate Spent Fuel Cooling to Boggs Box Duration RP1 (FG/1 -2/A/I 900/011) 317 RP3 Obtain Met Data using backup method (satellite phone call to NWS) 10 and report Met data to SM (AD-EP-ALL-0202) 327 SM Complete and approve content of SAE ENF for follow-up #5 SAE 2 (RP/O/B/I1000/002) 329 SM Direct FBL to perform follow-up #5 SAE State/local notifications I (RP/0/B/1000/015A) 330 FBL Perform follow-up #5 SAE State/local notifications (RP/0/B/1000/015A) 30 Page 27
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 7 AUGMENTED AND EXPANDED ERO RESPONSE ANALYSIS This section of the assessment documents the ability of the augmented and expanded ERO to implement Transition Phase coping strategies performed after the end of the "no site access" 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> time period. The expanded ERO is defined as the required augmented ERO for a multi-unit event.
7.1 ERO Notification and Response durinc an ELAP Revision 2014-02 of the Oconee Nuclear Station Emergency Plan, dated October 2014, is established as the licensing basis for the augmented ERO staffing complement.
The minimum augmented ERO personnel complement is described in Figure B-8b of the Oconee Nuclear Station Emergency Plan and is provided in Table 7-1 below.
Capability for Position, Title or Additions*
Major Functional Area Major Task Expertise 45 min 75 min Emergency Direction and Station Manager 1 Control"*Sain aae Notification/ Notify Company Personnel, state, Communication County, federal Agencies and State Communicators 2 maintain communication EOF/Radiological Accident EOF Director (Emergency Assessment and Support Classification, Protective Action S and Off Site Agency Recommendation, Offsite Agency Support Interface, ENF Approval)
Accident Assessment Emergency Classification Dose Assessment and Protective Action EOF Plant Assessment EOF Offsite Dose Assessment/Protective Action AnAger Manager Radiological Assessment 2
Recommendations Recommendations Manager Offsite Notifications Offsite Agency Notifications Offsite Agency Communicator1 EOF Access Control #
TSC Dose Assessment/Protective Radiological Assessment 1 Action Recommendations OffSite Surveys Field Monitoring Teams (2) 4***
Onsite Surveys 1 In-Plant Surveys RP Qualified Individual 1 1 Chemistry/Radio Chemistry Rad/Chem Technician 1 Core/Thermal Hydraulics I Technical Support Electrical I T Mechanical I Plant System Engineering, Mechanical Maintenance I Repair-and -Corrective Mcaia aneac Action Repair and Corrective Actions Rad/Waste Operator I I&E Technician 2 Radiation Protection A. Access Control B. RP Coverage for Repair, Protective Actions (In Corrective Actions, Search and Plant) rescue, First Aid and Firefighting C. Personnel Monitoring D. Dosimetry E. On-Shift Dose Assessment Local7 Support Firefighting Fire Brigade Rescue Operations and MERT Team Local First-Aid Suoport Page 28
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Considerationis given to the fact that many of the Oconee Nuclear Site Emergency Response Organizationpersonnel do not live within a radius of the station which will allow a response time of 30 minutes or less under ideal conditions. factors such as weather conditions, road capacityand traffic density, and the distance to travel from residence to the emergency response facility, indicate a realisticresponse time from a few minutes to I hour and 15 minutes for most employees. Considerationis also given to personnel on shift who are qualified and sufficient in number to handle any emergency condition until response personnel begin to arrive on site.
- Management of Offsite Emergency response will be assumed by the EOF Directorwhen the Emergency OperationsFacilityis activated. Management of the Onsite Emergency Response is assumed by the Station manager/Alternateacting as the Emergency Coordinatorwhen the Technical Support Center and OperationalSupport Centers are activated.
The FieldMonitoring Teams will initiallyreport to the Body Burden Analysis (BBA) Room. If needed, the Field Monitoring Teams will dispatch from the Body Burden Analysis (BBA)
Room. Once the Emergency operationsFacility(EOF)Field Monitoring Coordinatoris ready he/she will assume control of the Field Monitoring teams. A FMT consists of one RP qualified individualand one vehicle driver.
- An electronic card readerin conjunction with a posted building security officer fulfills the function for controlling access to the EOF during emergencies.
7.1.1 General ERO Response
- 1. Implementing Strategy for the Expanded ERO The ERO augmentation process consists of an "all call/all come" expectation. When the ERO notification system is operable, all qualified ERO members are contacted and expected to report if fit for duty. In the absence of the call out system, all ERO members are trained to respond automatically per NSD-1 17, "Emergency Response Organization Staffing," Section 4.4.11, which states:
Following a large scale naturaldisasteron site, all ERO personnel should respond to their Emergency Response Facilityor their designatedalternate site, if their Emergency Response Facilityis inaccessible, as soon as safely possible.
This is not dependent upon receiving an initial ERO activation page or call.
NSD-1 17 Section 4.4 responsibilities were initially provided to the ERO members as electronic read training for the Duke Energy fleet that was sent to all ONS ERO members.
Review of the ONS ERO roster confirmed that sufficient numbers of qualified individuals are available to fill the positions in Table 7.2 with adequate depth to staff at least two 12-hour shifts, except for the Operations Coordination function.
Table 7.2 considers that 1 Operations Superintendent per unit, per shift, is needed, but ONS only has 5 Operations Superintendent on the ERO roster at the time of the assessment.
Page 29
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report
- 2. Response Timeliness for the Expanded ERO The ONS ERO augmentation process consists of an "all call/all come" expectation.
Callout of an expanded ERO is subsumed within the callout of the augmented ERO.
In the absence of the call out system, ERO members are trained to respond automatically per NSD-1 17, as described in the implementing strategy above.
- 3. Work Location for the Expanded ERO If access to the primary emergency response facilities is not possible, ERO members are trained to report to the alternate location. ONS has identified the alternate OSC and alternate TSC as the facilities to be utilized to support the expanded response capabilities. In addition, the Outage Control Center (OCC) and the Issaqueena Trail Facility (legacy ONS EOF) could be utilized as additional work areas should additional space be necessary for the performance of expanded response functions.
- 4. Transportation for the Expanded ERO The ONS §50.54(f) response stated that the following methods of access to the site are available:
" Roadway - There are several roadways into the Oconee region. If one path becomes impassable, detours using other roadways are viable. Major routes include:
> From the East or West using East Pickens Highway (SC Route 183)
> From the South using the Rochester Highway (SC Route 130)
" Water - ONS can be accessed from the water via Keowee Lake. Access to the Keowee Lake for personal watercraft or watercraft arranged for by Duke Energy can be made through any of six public access boat ramps. Access to the site from the Lake can be made from two docks located on site.
" Air - Access to ONS can be provided from staging areas and three designated onsite landing zones via helicopters arranged for by Duke Energy.
The ONS Emergency Plan contains specific Letters of Agreement for services and support from resource providers such as local counties, fire departments, law enforcement, and health care facilities to assist in Emergency Plan implementation.
- 5. ERO Drill & Exercise Program NEI 12-01 states that a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. In particular, standard objectives and extent-of-play may need to be revised to clarify the expected demonstration of functions that are dependent upon the type of scenario event or accident (i.e., within or beyond design basis, and number of affected units). For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit.
Current ONS drill and exercise procedures do not include evaluation objectives and demonstration criteria for beyond design basis events and expanded ERO activities.
As future guidance is expected from the NRC in this area, no further changes are necessary to the drill and exercise procedures at this time.
Page 30
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 7.1.2 Position Specific ERO Response
- 1. Radiation Protection Technicians (RPTs)
Following a beyond design basis external event, the on-site Radiation Protection (RP) Qualified Individuals will be available in sufficient numbers to support performance of assigned emergency plan functions and the expanded response capability.
The equation below was used to determine the required number of on-site RP Qualified Individuals for a BDBEE. This number consists of both on-shift and augmented ERO RP Qualified Individuals that perform on-site response functions for ONS.
The equation in NEI 12-01, section 3.5.1, is as follows:
RPTT = RPTcop + RPTRcA + RPTNc, where:
RPTT = Total required number of on-site RP Technicians.
RPTcoP = Number needed to support implementation of the 2 most limiting ELAP FLEX strategies. This is determined by reviewing the FG strategies for each unit.
RPTRCA = Number needed for repair and corrective action, equals two x number of units RPTNC = Number of on-site RP Technicians performing other emergency plan functions that would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams For ONS, the resultinq number of RPTs is:
RPT Number Category Required Comments RPTcop 5 RCS Inventory Stategy requires 3 RPTs SFP Makeup & Cooling requires 2 RPTs.
RPTRCA 6 2 times number of units (2x3).
RPTNC 3 Minimum # of RPTs required for ERO augmentation response for radiological assessment function.
Thus, the total number of on-site RPTs required for the expanded ERO is 23, which is based on the staffing needed to:
- 1) Support the two most limiting RP resource intense FG strategies, which do not require rotating shifts
= 5 RPTcop
- 2) Support operating on 12-hour shifts for other RP tasks
=2 shifts of RPTRCA and RPTNC
= 2 (6+3)
= 18 RPTRCA and NC
- 3) RPT-r =5 RPTcop + 18 RPTRCA and NC
= 23 RPTT Page 31
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 43 RPTs are available to support performance of assigned emergency plan functions and the expanded response capability (refer to Table 7-1).
Provisions exist for obtaining additional RPT resources from other stations within the Duke fleet and/ or through industry agreement with INPO as part of the INPO Emergency Resources Manual documented by letter of agreement dated September 2009.
- 2. Administrative Support Personnel NEI 12-01 states that a licensee should determine if current assignments and locations of administrative support personnel are adequate for implementation of the expanded response capability, and identify necessary changes.
The administrative support personnel who assist the augmented ERO members are not assigned critical response tasks. Augmented ERO personnel are capable of performing their assigned tasks and responsibilities without requiring administrative support.
- 3. FG Implementers The assessment considered the number of personnel required for simultaneous implementation of the two FG strategies for each unit that require the greatest number of staff to implement. There are five (5) FG strategies for the site:
- 1) Maintain Instrumentation
- 3) RCS Injection
- 4) Containment Integrity
- 5) Spent Fuel Pool (SFP) Makeup & Cooling Based on the FG task analysis, the following two FLEX strategies have been selected:
Strate~gy #1 - Maintain instrumentation Implementation involves the following FG and personnel resources:
0 FG/020, Unit 2 FLEX Electrical Distribution Personnel Total Task Performed (deprtmnt)-~Task Performed (department) #
SPOC 6 Move Generator and_ Cable from FLEX Building (Non-concurrent task)
Deploy Cables (Non-concurrent task)
AO (2 per unit) 6 Make Connections, Breaker Alignment, Run Generator Total 12 Page 32
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Strateqy #3 - RCS Inventory/Long-term Subcriticality Implementation involves the following FG and personnel resources:
0 FG/001. Lono Term RCS Inventorv Control Personnel (deprtmet) Total
- Task Performed (department)
SPOC 6 Relocate Three Pumps and Hoses (Non-concurrent task)
Layout Hoses (Non-concurrent task)
AO 3 Operate Pumps AO 3 Valve Alignment RP 3 Job Coverage Total 15 A total of 27 (12+15) personnel are required for the simultaneous implementation of these two FLEX strategies.
Page 33
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report 7.2 Expanded Response Functions for Phase 1 Staffing Assessment Table 7-2a addresses NEI 12-01 Table 3.1, less SAMG implementation, and reflects a modeled staffing level to support the simultaneous deployment of emergency repair and corrective action teams to multiple affected units. The "Number Required" column basically assumes the staffing consideration for one unit, multiplied by the number of units, then doubled in order to support expanded ERO staffing for two 12-hour shifts. (Note: While ONS has three units, it only has two control rooms, due to a shared control room for Units 1 and 2. A shared TSC and OSC supports all three units) The "Number Available" column is the number of personnel qualified to the ERO position.
Table 7-2a Expanded vs. Augmented ERO Response Comparison Number Required Number Function Location Key Roles and Staffing Considerations ONS ERO Position (3 Units) Available
- Overall cognizance of the activities related to implementation of repair and corrective actions and implementation of Transition Unit Response TSC Phase coping and Severe Accident Management (SAM) strategies Emergency Coordinator 6 7 Coordination for an assigned unit.
a One individual per unit; individuals should not be assigned other functions.
a Provides coordination of Operations staff and support for an Operations TSC assigned unit. Operations Superintendent Coordination
- One individual per unit; individuals should not be assigned other functions.
- Provides coordination of Maintenance staff and support for an Maintenance OSC assigned unit.
Coordination O One individual per unit; individuals should not be assigned other Maintenance Manager functions.
- Provides coordination of Engineering staff and support for an Engineering TSC assigned unit. Engineering Manager Coordination
- One individual per unit; individuals should not be assigned other functions.
Page 34
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Number Required Number Function Location Key Roles and Staffing Considerations ONS ERO Position (3 Units) Available e One team for each unit to perform engineering assessments in support of repair and corrective actions. Tech Assistant to the EC 6 6 Engineering TSC/ 9Team composition (i.e., number and represented disciplines) as Elect Equipment Manager 6 15 Assessments OSC described in the Emergency Plan.
- Team may include personnel responsible for performing other functions for the same assigned unit.
Unit In-Plant e Overall cognizance of on-site and in-plant teams performing or Team OSC supporting repair and corrective actions for an assigned unit. OSO Manager 6 11 Coordination , One individual per unit; individuals should not be assigned other functions.
N Two individuals per unit to assist with implementation of repair and Non-Licensed OSC corrective actions. Non-Licensed Operators(a) 12 33 Operators e Should not include members of the on-shift staff.
Mechanical
- Two individuals per unit to implement repair and corrective actions.
Maintenance OSC 9 Staffing may include an on-shift individual (i.e., 2 individuals for a SPOC and Maintenance 12 24 Repair and unit composed of I on-shift and 1 augmented). Craft(b)
Corrective Action Electrical a Two individuals per unit to implement repair and corrective actions.
Maintenance OSC e Staffing may include an on-shift individual (i.e., 2 individuals for a SPOC and Maintenance 12 Repair and unit composed of 1 on-shift and 1 augmented). Craft (c)
Corrective Action 24 R Two individuals per unit to implement repair and corrective actions.
I&C Repair and OSC e Staffing may include an on-shift individual (i.e., 2 individuals for a Crand n12 Corrective Action Craft (c) unit composed of 1 on-shift and 1 augmented).
(a) ONS has 40 total qualified NLOs. 7 NLOs are accounted for as being on shift. (Multiple Assigned Job Status Report dated 4/20/2015)
(b) ONS has 26 total qualified Mechanical Maintenance. 2 MM is accounted for as being on shift. (Multiple Assigned Job Status Report dated 4/20/2015)
(c) ONS has 26 total qualified IAE Technicians. 2 IAE is accounted for as being on shift. (Multiple Assigned Job Status Report dated 4/20/2015)
Page 35
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report Table 7-2b addresses NEI 12-01 Table 3.2, Expanded Response Functions for Phase 2 Staffing Assessment, (FG implementation).
The number required column is the personnel resources for the implementation of the two most limiting FG tasks. The number available column is the number of personnel qualified to the position. These FG tasks do not require 24-hour coverage.
Table 7-2b Expanded ERO FLEX Resources Number Required Number Function Location Key Roles and Staffing Considerations ONS ERO Position (3 Units) Available 9 One team for each unit to evaluate selection of Transition Coping strategies; team performs evaluations not done by Control Room Evaluation of personnel Tech Assistant to the EC 6 6 Transition Phase EOF
- Team composition (i.e., number and represented disciplines) as Elect Equipment Manager 6 15 Coping Strategies described in governing site programs, procedures and guidelines Nuclear Engineer 6 7
- Team may include personnel responsible for performing other functions for the same assigned unit a Number and composition of personnel capable of simultaneous implementation of any two Transition Phase coping strategies at Reactor Operator 2 33 Implementation of each unit (see Section 7.1.2.3) Non Licensed Operator 12 71 Transition Phase OSC 9Should not include personnel assigned to other functions (e.g., SPOC and Maintenance Craft 6 26 Coping Strategies emergency repair and corrective actions); however, may include members of the on-shift staff and personnel responsible for RP Technician 3 44 implementation of SAM strategies Page 36
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report : References
- 1. EA-12-049, NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, 03/03/12
- 2. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0
- 3. NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Revision 0
- 4. NEI document to industry peers, Generic Basis for Responses to Staffing Assessment Questions Related to Use of Security Personnel During a BDB Event Response, 12/23/13
- 5. 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 03/12/12
- 6. B. C. Waldrep letter to U.S. Nuclear Regulatory Commission (NRC), " Duke Energy 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 05/09/12. (ML12132A377)
- 7. B. C. Waldrep letter to U.S. Nuclear Regulatory Commission (NRC), Duke Energy 90-Day Response "Emergency Preparedness Information Requested by 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-lchi Accident; dated March 12, 2012," dated 06/08/12.
- 8. Letter from L. Skeen (NRR) to S. Perkins-Grew (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 05/15/12
- 9. NRC letter, "Response Regarding Licensee Phase 1 Staffing Submittals Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident," dated 10/23/13
- 10. NRC letter, "Oconee Nuclear Station, Units 1, 2, and 3 -Interim Staff Evaluation Regarding Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0782, MF0783 and MF0784)", dated 2/10/14
- 11. ONS Emergency Plan, Rev 14-02
- 12. NSD-117, Emergency Response Organization Staffing, Rev 16
- 14. AP/O/A/1700/025, Standby Shutdown Facility Emergency Operating Procedure, Rev 061
- 15. AP/0/A/1700/047, External Flood Mitigation, Rev 14
- 16. EP/1/A/1800/001, Emergency Operating Procedure, Rev 040
- 17. EP/1/A/1800/001 L, EOP Rules & Appendix, Rev 040
- 18. EP/2/A/1 800/001, Blackout, Rev 041
- 19. FG/2/A/1900/001, Long term RCS Inventory Control, Rev 000 Page 37
ONS NEI 12-01 Phase 2 ELAP ERO Staffing Analysis Report : References
- 20. FG/0/A/1900/003, Alternative Low Pressure Emergency Feedwater, Rev 000
- 21. FG/0/A/1900/005, Initial Assessment and FLEX Equipment Staging, Rev 000
- 22. FG/1/A/1900/007, Unit 1 Alternate Monitoring of Essential Instrumentation, Rev 000
- 23. FG/2/A/1 900/007, Unit 2 Alternate Monitoring of Essential Instrumentation, Rev 000
- 24. FG/2/A/1900/008, Alternative RCS Boration, Rev 000
- 25. FG/2/A/1 900/009, Low Decay Heat Temperature Control, Rev 000
- 26. FG/2/A/1900/010, CFT IsolationNenting, Rev 000
- 27. FG/1 &2/A/1 900/011, Alternative Spent Fuel Pool Cooling, Rev 000
- 28. FG/2/A/1 900/014, Unit 2 Shutdown RCS Makeup, Rev 000
- 29. FG/2/A/1900/015, Containment Isolation and Closure, Rev 000
- 30. FG/2/A/1900/020, Unit 2 FLEX Electrical Distribution, Rev 000
- 32. AD-EP-ALL-0202, Emergency response Offsite Dose Assessment, Rev 000
- 33. PD-EP-ALL-0800, Drills and Exercises Program, Rev 0000
- 34. AD-EP-ALL-0801, Design and Development of Drills and Exercises, Rev 000
- 35. AD-EP-ALL-0802, Conducting Drills and Exercises, Rev 000
- 36. AD-EP-ALL-0803, Evaluation and Critique of Drills and Exercises, Rev 000
- 37. RP/0/B/1 000/001, Emergency Classification, Rev 003
- 38. RP/0/B/1 000/002, Control Room Emergency Coordinator Procedure, Rev 008
- 39. RPO/B/1000/015A, Offsite Communications from the Control Room, Rev 003 Page 38