Text

Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 2 Staffing Assessment
	ML15196A038
Person / Time
Site:	South Texas
Issue date:	07/02/2015
From:	Gerry Powell; South Texas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NOC-AE-15003255
	Download: ML15196A038 (25)
	v • d • e

Nuclear Operating Company South Texas ProlectElectric GeneratingStation PO. Box 289 Wadsworth, Texas 77483 V July 2, 2015 NOC-AE-15003255 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f)

Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 2 Staffing Assessment

References:

1. Letter from A. Capristo, STPNOC, to NRC Document Control Desk, "Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 2 Staffing Assessment", November 25, 2014 (NOC-AE-1 4003189)

2. Letter from E.J. Leeds, NRC, to All Power Reactor Licensees, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", March 12, 2012 (ML12053A340)

On November 25, 2014, South Texas Project Nuclear Operating Company (STPNOC) submitted the Phase 2 Staffing Assessment to the NRC (Reference 1) in response to the 10 CFR 50.54(f) request for information regarding Near-Term Task Force (NTTF)

Recommendation 9.3 for Emergency Preparedness programs (Reference 2). Following this submittal, STPNOC performed a revalidation of the assessment results using the final validated FLEX Support Guidelines (FSGs) and any applicable new procedures that were not complete when the staffing assessment tabletop was performed. This letter and enclosures present the results of this revalidation.

STPNOC performed the revalidation of the staffing assessment results between'April 13, 2015 and April 21, 2015. The results of the revalidation showed that effectively implementing the STP diverse and flexible coping (FLEX) strategies requires two maintenance personnel per unit. One instrumentation and control (I&C) technician and one electrician are currently included in the minimum staffing requirements in the STP Emergency Plan. In order to effectively implement STP's FLEX strategies with two maintenance personnel in each unit, a mechanic and either an additional I&C technician or an electrician are needed.

STI: 34118032

NOC-AE-1 5003255 Page 2 of 3 While these two individuals are not part of the minimum on-shift staff required by the STP Emergency Plan, they are currently procedurally obligated to be onsite to staff those positions at all times to support the STP Integrated Maintenance Team. provides updated responses to the NTTF Recommendation 9.3 requested information items 1, 2, and 6 based on the results of the revalidated Phase 2 Staffing Assessment report for STP. The revised task implementation timeline for implementing FLEX strategies is provided in Enclosure 2. A revised FLEX strategy timeline and a timeline of key plant operator and maintenance activities are provided in Enclosures 3 and 4 as additional supporting information for the implementation timeline.

A summary of the revised commitments for the Phase 2 Staffing Assessment is included in .

If there are any questions regarding this letter, please contact Wendy Brost at (361) 972-8516.

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

Executed on 0l7- 1 Z, o01 tbate G. T. Powell Site Vice President web

Enclosures:

1. Updated Response to Requested Information: NTTF Recommendation 9.3 -

Staffing, Requested Information Items 1, 2, and 6

2. Revised Task Implementation Timeline from Phase 2 Staffing Assessment Revalidation (Attachment 1)

3. Timeline of Key Plant Operator and Maintenance Activities

4. Revised Integrated FLEX Strategy Timeline

5. List of Commitments

NOC-AE-1 5003255 Page 3 of 3 cc:

(Paper Copy) (Electronic Copy)

Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission Steve Frantz, Esquire 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission Lisa M. Regner Lisa M. Regner Tony Brown Senior Project Manager U.S. Nuclear Regulatory Commission NRG South Texas LP One White Flint North (08H04) John Ragan 11555 Rockville Pike Chris O'Hara Rockville, MD 20852 Jim von Suskil NRC Resident Inspector CPS Enerqy U. S. Nuclear Regulatory Commission Kevin Polio P. O. Box 289, Mail Code: MN116 Cris Eugster Wadsworth, TX 77483 L. D. Blaylock Crain Caton & James, P.C.

Peter Nemeth City of Austin Cheryl Mele John Wester Texas Dept. of State Health Services Richard A. Ratliff Robert Free

Enclosure 1 NOC-AE-15003255 Enclosure 1 Updated Response to Requested Information:

NTTF Recommendation 9.3 - Staffing, Requested Information Items 1, 2, and 6

Enclosure 1 NOC-AE-1 5003255 Page 1 of 5 Updated Response to Requested Information:

NTTF Recommendation 9.3 - Staffing, Requested Information Items 1, 2, and 6 STPNOC's revised responses to Requested Information Items 1, 2, and 6 from the 10 CFR 50.54 (f) letter related to Near-Term Task Force Recommendation 9.3, Staffing are included below (Reference 1).

1. Requested Item 1 Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the Discussion section of Reference 1, Enclosure 5.

The Phase 2 Staffing Assessment revalidation concluded that, ideally, two maintenance personnel are needed in each unit to setup the Operations Support Center (OSC) for emergency response functions, connect hoses and Motor Control Center (MCC) cables and support plant operators with damage assessments for the FLEX procedure for initial plant assessments and equipment staging (Reference 2), and other activities as needed.

One I&C technician and one electrician are included in the minimum staffing requirements in the STP Emergency Plan. In order to effectively implement STP's FLEX strategies with two maintenance personnel in each unit, a mechanic and either an additional instrumentation and control (I&C) technician or an electrician are needed.

The mechanic and second electrician or I&C technician, hereafter referred to as the two additional maintenance personnel, are not included in the minimum staffing requirements in our Emergency Plan (Reference 3). They are two of the 'double-asterisk' positions listed in Table B-1 of NUREG-0654 (Reference 4) that could be covered by shift personnel assigned other functions. While these two individuals are not part of the minimum on-shift staff as required by the STP Emergency Plan, these two maintenance personnel are currently procedurally obligated to be onsite at all times to support the station Integrated Maintenance Team (IMT).

Enclosure 1 NOC-AE-15003255 Page 2 of 5 MINIMUM STAFFING RE QUIREMENTS (STPEG S)

(InducngC ap ability for Additional Staffing MAJOR POSITIWN UNIT 1 UNIT 2 WSITE AVAILABLE AVAILABLE 75 FUNCTIONAL TITLE W-SHWT 4 WNSH-IFT* WNSH-FT 60 MINUTE S

MINUTES #

AREA Shift Techmical i*

Advisor Nuclear Plant S yrte Eighner Engmerimg Elechicl -1 Mehatnical Eilgineer ---- 1 Ergireer Rawa"te 1*

Opeiator ____

RepaiManechmical 11 Canctive Maftaname Actioxs Electcal 1"* AND 1 1 Meaintenanie - l*ND-1 I&C Teclrniian 1 -

Figure 1: Excerpt from STP Emergency Plan, Table C-1 Beyond the minimum staffing requirements in the Emergency Plan, the two additional maintenance personnel credited for implementing the STP FLEX strategies are currently procedurally obligated to be on-shift as part of the IMT. The minimum staffing for the IMT is defined in Section 5.4.1.2 of the IMT Guideline (Reference 5):

0 One Mechanical Maintenance Craft 0 One Electrical Maintenance Craft and Two I&C Maintenance Craft or 0 Two Electrical Maintenance Craft and One I&C Maintenance Craft As stated in this guideline, these minimum staffing levels shall be maintained at all times.

To ensure that these minimum staffing levels for the IMT are maintained, STPNOC has entered an action into the STP Condition Reporting database to add a note to this guideline stating that these minimum staffing levels must be maintained in order to implement FLEX strategies. This action is listed as a commitment in Enclosure 5.

Additionally, a training bulletin was issued to instruct IMT personnel to divide themselves between the two units and report to the respective unit's control room in order to support the FLEX strategies during an external event.

The current minimum on-shift staff, the two additional IMT maintenance personnel, and the augmented Emergency Response Organization (ERO) are sufficient for executing all required initial and any necessary transition phase actions for the FLEX strategies without the assignment of collateral duties that would adversely affect the ability to execute required Emergency Plan functions. No change to the Emergency Plan on-shift staffing level or augmented ERO is required.

Enclosure 1 NOC-AE-15003255 Page 3 of 5 As part of the STP Phase 2 Staffing Assessment report (Reference 6), a detailed timeline was developed based on a tabletop discussion and review of the on-shift response to the postulated beyond-design-basis external event (BDBEE) extended loss of alternating current (AC) power (ELAP). This timeline was updated during the assessment revalidation and is included in Enclosure 2. On-shift and augmented staff response was determined based upon the tabletop team members' review of applicable plant procedures and the current revisions of the diverse and FLEX Support Guidelines (FSGs). All onsite resources required for implementing the initial and transition phase FLEX mitigating strategies and the Emergency Plan are identified in the timeline.

This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:

a. How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NRC NTTF Recommendation 4.2.

No changes were made to this response based on the results of the revalidated Phase 2 Staffing Assessment.

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

No changes were made to this response based on the results of the revalidated Phase 2 Staffing Assessment. No changes were identified to the required minimum staffing levels identified in the STP Emergency Plan.

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

The Phase 2 Staffing Assessment revalidation concluded that effectively implementing STP's FLEX strategies requires one additional mechanic and either an I&C technician or an electrician. These two additional maintenance personnel are needed to assist in connecting hoses and cables and assisting Plant Operators. They are currently procedurally obligated to be onsite at all times to support the STP IMT.

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

With the addition of a mechanic and either an I&C technician or an electrician, the current minimum on-shift staff is sufficient to support implementation of the FLEX mitigating strategies for STP Units 1 and 2 without the assignment of collateral duties that would adversely affect the ability to execute required Emergency Plan functions.

In order to avoid a potential collateral duty for the Radiation Protection Technician (RPT) during a BDBEE and ELAP for a multi-unit event, the Chemistry Technician must retain the ability to perform on-site surveys for use during extreme emergency events. This requirement is listed as a commitment from the initial Phase 2 Staffing Assessment (Reference 6) in Enclosure 5.

Enclosure 1 NOC-AE-1 5003255 Page 4 of 5

2. Requested Item 2 Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate please include in the schedule the time to implement the changes associated with the Phase 2 staffing assessment.

The additional maintenance personnel needed to support FLEX strategies are currently procedurally obligated to be onsite at all times to support the STP IMT.

3. Requested Item 6 Identify changes associated with the Phase 2 staffing assessment that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all AC power, multi-unit event, including any new or revised agreements with offsite resource providers (e.g.,

staffing, equipment, transportation, etc.).

No changes to the Emergency Plan on-shift staffing are needed.

The on-shift staff required by the Emergency Plan along with an additional mechanic and either an I&C technician or an electrician can implement the Emergency Plan and ELAP strategies at STP Units 1 and 2 during the first six-hour "no site access" period. The two additional maintenance personnel are currently procedurally obligated to be on-site at all times per the IMT guideline, and a note will be added to this guideline to ensure the required minimum staff for the IMT is maintained. This action has been entered into the STP condition reporting database and is listed as a commitment in Enclosure 5.

The Phase 2 Staffing Assessment determined the number and composition of staff required to satisfy the expanded response capability functions defined in Table 3.2 of NEI 12-01 and verified that we have sufficient qualified ERO personnel to provide 24-hour coverage for these functions. The results of the Phase 2 Staffing Assessment did not indicate that new or revised agreements are necessary (Reference 6). No changes to the ERO personnel or agreements with offsite resource providers are required based on the results of the assessment revalidation.

Enclosure 1 NOC-AE-15003255 Page 5 of 5 References

1. Letter from E.J. Leeds, NRC, to All Power Reactor Licensees, "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", March 12, 2012 (ML12053A340)

2. STPNOC FLEX Support Guideline Procedure, OPOP12-ZO-FSGO5, "Initial Assessment and FLEX Equipment Staging", Revision 0 (STI 34094661)

3. South Texas Project Electric Generating Station Emergency Plan

4. NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants", Revision 1

5. STPNOC Guideline, IMT-0001, "Integrated Maintenance Team Guideline", Revision 1 (STI 33763812)

6. Letter from A. Capristo, STPNOC, to NRC Document Control Desk, "Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

- Phase 2 Staffing Assessment", November 25, 2014 (NOC-AE-14003189)

Enclosure 2 NOC-AE-15003255 Enclosure 2 Revised Task Implementation Timeline from Phase 2 Staffing Assessment Revalidation (Attachment 1)

Enclosure 2 NOC-AE-15003255 Page 1 of 7 Revised Task Implementation Timeline from Phase 2 Staffing Assessment Revalidation Revisions to the initial Phase 2 Staffing Assessment timeline include revised times for the initiation, performance and completion of some activities and the addition of the two maintenance personnel who are on-site to support the STP Integrated Maintenance Team (mechanic and electrician or I&C technician).

The Phase 2 Staffing revalidation determined that, ideally, two maintenance personnel are needed in each unit to setup the Operations Support Center (OSC) for emergency response functions, connect hoses and Motor Control Center (MCC) cables and support plant operators with damage assessments and other activities as needed.

Unit Position Time Mrs) Task Collateral Duty?

1 Shift Manager (Ul SM) 1. 0.0-0.5 1. Assume duties of Emergency Director. Classify event as Site Area No Emergency. Block open Control Room door to kitchen.

2. 0.5-1.0 2. Upgrade event to General Emergency. Make Protective Action Recommendations (PARs).

3. 1.0-6.0 3. Contact National SAFER Response Center (NSRC). Continue executing the duties of Emergency Director until relieved by augmented ERO.

2 Shift Manager (U2 SM) 1. 0.0-6.0 1. Assess Unit 2 status. Assist Unit Supervisor as needed. No Communicate with Unit 1 as required.

I Unit Supervisor (Ul US) 1. 0.0-6.0 1. Direct and supervise performance of Emergency Operating No Procedures (EOPs) and Fukushima Support Guidelines (FSGs) in Unit 1.

2 Unit Supervisor (U2 US) 1. 0.0-6.0 1. Direct and supervise performance of Emergency Operating No Procedures (EOPs) and Fukushima Support Guidelines (FSGs) in Unit 2.

1 Reactor Operator 1 (U1 RO1) Perform OPOP05-EO-ECOO and FSG actions as directed throughout No event including the following :

1. 0.0-0.5 1. Perform post-trip immediate actions. Dispatch U1 Plant Operator (PO) to strip sequencers.

2. 0.5-1.0 2. Monitor primary system parameters. Establish hand switch lineup.

3. 1.0-3.0 3. Support plant cooldown. Monitor primary system parameters.

4. 3.0-6.0 4. Stabilize plant at 405 psig secondary pressure.

5. 7.5-8.0 5. Isolate accumulators.

Enclosure 2 NOC-AE-1 5003255 Page 2 of 7 Task Collateral Duty?

Reactor Operator I (U2 RO1) Perform OPOP05-EO-ECOO and FSG actions as directed throughout No event including the following :

1. 0.0-0.5 1. Perform post-trip immediate actions. Dispatch PO to strip sequencers.

2. 0.5-1.0 2 Monitor primary system parameters. Establish hand switch lineup.

3. 1.0-3.0 3. Support plant cooldown. Monitor primary system parameters.

4. 3.0-6.0 4. Stabilize plant at 405 psig secondary pressure.

5. 7.5-8.0 5. Isolate accumulators.

Reactor Operator 2 (U1 R02) Perform OPOP05-EO-ECOO and FSG actions as directed throughout No event including the following

1. 0.0-0.5 1. Dispatch PO to restore steam generator (SG) Power-Operated Relief Valve (PORV) control to the Control Room; Dispatch PO to cross-connect SGs

2. 0.0-1.0 2. Establish SG PORV pressure control.

3. 0.5-1.0 3. Commence plant cooldown to 405 psig secondary pressure.

4. 3.0-6.0 4. Stabilize plant at 405 psig secondary pressure.

Reactor Operator 2 (U2 R02) Perform OPOP05-EO-ECOO and FSG actions as directed throughout No event including the following

1. 0.0-0.5 1. Dispatch PO to restore SG PORV control to the Control Room; Dispatch PO to cross-connect SGs

2. 0.0-1.0 2. Establish SG PORV pressure control

3. 0.5-1.0 3. Commence plant cooldown to 405 psig secondary pressure

4. 3.0-6.0 4. Stabilize plant at 405 psig secondary pressure 1 Plant Operator 1 (U1 P01) 1 1. 0.0-0.5 1. Transfer station blackout (SBO) switches. Perform load shedding per No site emergency procedure OPOP05-EO-ECOO (Reference 1)

2. 0.5-2.0 2. Perform deep load shedding per FSG-04 (Reference 2)

3. 2.0-3.0 3. Continue performing actions in FSG-04 and support Isolation Valve Cubicle (IVC) operations as necessary

4. 3.0-4.0 4. Perform electrical lineup and start FLEX diesel generator (DG)

5. 4.0-4.5 5. Load initial FLEX power to lighting panels onto FLEX DG as power becomes available

6. 4.5-5.0 6. Energize A-Train battery charger and exhaust fan

7. 5.0-5.5 7. Energize C-Train battery charger and exhaust fan

8. 5.5-6.0 8. Load communications equipment onto FLEX DG if available

9. 7.0-7.5 9. Align breakers for accumulator isolation 1 Typically Electrical Auxiliary Building (EAB) watch Operator

Enclosure 2 NOC-AE-15003255 Page 3 of 7 Collateral Unit Position Time (Hrs) Task Clter?

2 Plant Operator 1 (U2 PO1) 1 1. 0.0-0.5 1. Transfer SBO switches. Perform load shedding per site emergency No procedure OPOP05-EO-EC00 (Reference 1).

2. 0.5-2.0 2. Perform deep load shedding per FSG-04 (Reference 2).

3. 2.0-3.0 3. Continue performing actions in FSG-04 and support IVC operations as necessary.

4. 3.0-4.0 4. Perform electrical lineup and start FLEX DG.

5. 4.0-4.5 5. Load initial FLEX power to lighting panels onto FLEX DG as power becomes available.

6. 4.5-5.0 6. Energize A-Train battery charger and exhaust fan.

7. 5.0-5.5 7. Energize C-Train battery charger and exhaust fan.

8. 5.5-6.0 8. Load communications equipment onto FLEX DG, if available.

9. 7.0-7.5 9. Align breakers for accumulator isolation.

Plant Operator 2 (U1 P02)2 1. 0.0-0.5 1. Cross-connect Auxiliary Feedwater (AFW) in Unit 1 IVC No

2. 0.5-1.5 2. Align RWST and Volume Control Tank (VCT) charging and Reactor Coolant Pump (RCP) seal valves and verify spent fuel pool (SFP) level and temperature

3. 1.5-2.5 3. Perform Addendum 17 of FSG-05 (Reference 3) to support FLEX cable installation

4. 2.5-4.0 4. Perform valve lineup for PDP from FSG-05, Addendums 5 and 6

5. 4.0-4.5 5. Start and control Chemical and Volume Control System (CVCS)

Positive Displacement Pump (PDP)

6. 4.5-7.0 6. Support IVC operations as necessary

7. 7.0-8.0 7. Support Maintenance installing hoses and swapping spectacle flange for Reactor Coolant System (RCS) Makeup 2 Plant Operator 2 (U2 P02)2 1. 0.0-0.5 1. Cross-connect AFW in IVC. No

2. 0.5-1.5 2. Align RWSTNCT charging and RCP seal valves and verify SFP level and temperature.

3. 1.5-2.5 3. Perform Addendum 17 of FSG-05 to support FLEX cable installation

4. 2.5-4.0 4. Perform valve lineup for PDP from FSG-05, Addendums 5 and 6

5. 4.0-4.5 5. Start and control CVCS PDP.

6. 4.5-7.0 6. Support IVC operations as necessary.

7. 7.0-8.0 7.- Support Maintenance installing hoses and swapping spectacle flange for RCS Makeup.

2 Typically Mechanical Auxiliary Building (MAB) watch Operator

Enclosure 2 NOC-AE-15003255 Page 4 of 7 Unit Position Time (Hrs) Task Collateral Duty?

I State and County Communicator (XOI)3 1. 0.0-1.0 1. Perform state and county notifications No

2. 1.0-1.5 2. Assist in performing deep load shedding for Unit 1 per FSG-04

3. 1.5-2.0 3. Perform state and county follow-up notifications

4. 2.5-3.0 4. Perform state and county follow-up notifications

5. 3.0-3.5 5. Transfer satellite telephone to Unit 1 Control Room per FSG-05

6. 3.5-4.0 6. Perform state and county follow-up notifications

7. 4.5-5.0 7. Perform state and county follow-up notifications

8. 5.5-6.0 8. Perform state and county follow-up notifications

9. 6.0-7.0 9. Turn over Communicator duties to augmented ERO NRC Communicator (X02) 4 1. 0.0-0.5 1. Perform ERO callout and Emergency Notification System (ENS) No

2. 0.5-6.0 communications

2. Perform ENS communications Maintenance I (Ml)5 1. 0.0-0.5 1. Perform setup of the Unit 1 Operations Support Center (OSC) No

2. 0.5-2.0 2. Assist Operator in Unit 1 IVC

3. 2.0-3.0 3. Connect cables to Unit 1 MCC E1A2 per FSG-05

4. 3.0-4.0 4. Connect cables to Unit 1 MCC El C2 per FSG-05

5. 4.0-5.0 5 Connect cables to Unit 1 MCC EIA4 per FSG-05

6. 5.0-6.0 6. Connect cables to Unit 1 MCC El B4 per FSG-05

7. 6.0-7.0 7. Connect cables to Unit 1 MCC E1C4 per FSG-05 2 Maintenance 2 (M2) 5 1. 0.0-0.5 1. Perform setup of the Unit 2 OSC No

2. 0.5-2.0 2. Assist Operator in Unit 2 IVC

3. 2.0-3.0 3. Connect cables to Unit 2 MCC E2A2 per FSG-05

4. 3.0-4.0 4. Connect cables to Unit 2 MCC E2C2 per FSG-05

5. 4.0-5.0 5 Connect cables to Unit 2 MCC E2A4 per FSG-05

6. 5.0-6.0 6. Connect cables to Unit 2 MCC E2B4 per FSG-05

7. 6.0-7.0 7. Connect cables to Unit 2 MCC E2C4 per FSG-05 Maintenance 3 (M3) 6 1. 1.0-2.0 1. Connect SG Makeup pump hoses per FSG-05 (in Unit 1) No

2. 2.0-7.0 2. Assist in connecting MCC cables

3. 7.0-8.0 3. Connect hoses and swap spectacle blind for RCS Makeup per FSG-05 2 Maintenance 4 (M4) 6 1. 1.0-2.0 1. Connect SG Makeup pump hoses per FSG-05 (in Unit 2) No

2. 2.0-7.0 2. Assist in connecting MCC cables

3. 7.0-8.0 3. Connect hoses and swap spectacle blind for RCS Makeup per FSG-05 3 Plant Operator in either unit 4 Reactor Operator 5 These tasks can be performed by a mechanic, electrician, or I&C technician 6 These tasks can be performed by a mechanic, electrician, or I&C technician

Enclosure 2 NOC-AE-15003255 Page 5 of 7 Position Time (Hrs) Task Collateral Unit

__ Duty?

I Senior Radiation Protection Technician 1. 0.0-6.0 1. Assume duties of Acting Radiological Manager in Unit 1 Control No (SRPT) Room Radiation Protection Technician 1 (RPT1) 1. 0.0-0.5 11. Support opening/blocking doors to access Control Room No

2. 0.5-6.0 2. Provide access control for Unit 1 MAB and job coverage for operators or maintenance as needed 2 Radiation Protection Technician 2 (RPT2) 1. 0.0-0.5 1. Support opening/blocking doors to access Control Room No

2. 0.5-6.0 2. Provide access control for Unit 2 MAB and job coverage for operators or maintenance as needed Chemistry Technician (CT1) 1. 0.0-1.0 1. Secure secondary sample panel valve lineups No

2. 1.0-6.0 2. Perform site surveys.

I Fire Brigade I (FB1 )7 1. 0.0-1.0 1. Check and attempt local start of Unit 1 Emergency DGs and No Technical Support Center (TSC) DG, fail closed the Main Steam Isolation Valves (MSIVs) per FSG-04

2. 1.0-1.5 2. Provide support to plant operator(s) in Unit I IVC

3. 1.5-3.0 3. Depressurize Main Generator if required and assess plant conditions per FSG-05

4. 3.0-4.5 4. Continue IVC support including aligning valves for using FLEX SG makeup pump

5. 4.5-6.0 5. Prepare for fill of FLEX DG Fuel Oil Storage Tank (FOST) per FSG-19 (Reference 4)

6. 6.5-7.5 6. Fill Unit 1 FLEX DG FOST.

7. 8.0-9.0 7. Start Unit I FLEX SG makeup pump per FSG-03 (Reference 5)

8. 9.0-9.5 8. Secure Unit 1 Turbine-Driven AFW (TDAFW) pump per FSG-09 (Reference 6) 2 Fire Brigade 2 (FB2) 1. 0.0-1.0 1. Check and attempt local start of Unit 2 Emergency DGs and TSC DG, No fail closed the MSIVs per FSG-04

2. 1.0-1.5 2. Provide support to plant operator(s) in Unit 2 IVC

3. 1.5-3.0 3. Depressurize Main Generator if required and assess plant conditions per FSG-05

4. 3.0-4.5 4. Continue IVC support including aligning valves for using FLEX SG makeup pump

5. 4.5-6.0 5. Prepare for fill of FLEX DG FOST per FSG-1 9

6. 6.5-7.5 6. Fill Unit 2 FLEX DG FOST

7. 8.0-9.0 7. Start Unit 2 FLEX SG makeup pump per FSG-03

8. 9.0-9.5 8. Secure Unit 2 TDAFW pump per FSG-09 7 Typically Turbine Generator Building (TGB) watch Operator

Enclosure 2 NOC-AE-15003255 Page 6 of 7 Collateral Unit Position Time (Hrs) Task uteal I Fire Brigade 3 (FB3) 8 1. 0.0-1.0 1. Perform AFW cross-connect lineup for Unit I No

2. 1.0-1.5 2. Perform Unit 1 breaker alignments in preparation for Addendum 17 of FSG-05

3. 1.5-2.5 3. Assist maintenance personnel in connecting hoses for Unit 1 SG makeup pump per FSG-05.

4. 2.5-3.5 4. Perform Unit 1 MCC load shedding per FSG-05

5. 3.5-4.0 5. Perform initial Unit 1 battery charger breaker alignments per FSG-04

6. 4.5-6.0 6. Prepare for fill of FLEX DG FOST per FSG-19

7. 6.0-6.5 7. Move portable radios and chargers from OSC break room to Unit 1 Control Room per FSG-05.

8. 6.5-7.5 8. Fill Unit 1 FLEX DG FOST per FSG-19

9. > 7.5 9. Continue filling Unit 1 FLEX DG FOST per FSG-19 every 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 2 Fire Brigade 4 (FB4) 1. 0.0-1.0 1. Perform AFW cross-connect lineup for Unit 2 No

2. 1.0-1.5 2. Perform Unit 2 breaker alignments in preparation for Addendum 17 of FSG-05

3. 1.5-2.5 3. Assist maintenance personnel in connecting hoses for Unit 2 SG makeup pump per FSG-05

4. 2.5-3.5 4. Perform Unit 2 MCC load shedding per FSG-05

5. 3.5-4.0 5. Perform initial Unit 2 battery charger breaker alignments per FSG-04.

6. 4.5-6.0 6. Prepare for fill of FLEX DG FOST per FSG-19

7. 6.0-6.5 7. Move portable radios and chargers from OSC break room to Unit 2 Control Room per FSG-05

8. 6.5-7.5 8. Fill Unit 2 FLEX DG FOST per FSG-19

9. > 7.5 9. Continue filling Unit 2FLEX DG FOST per FSG-19 every 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 2 Fire Brigade 5 (FB5) 1. 0.0-1.0 1. Assist maintenance personnel and plant operators and perform other No activities as directed by the Unit Supervisor or reactor operators

2. 1.0-1.5 2. Assist in performing deep load shedding for Unit 2 per FSG-04

3. 1.5-3.0 3. Assist maintenance personnel and plant operators and perform other activities as directed by the Unit Supervisor or reactor operators

4. 3.0-3.5 4. Transfer satellite telephone to Unit 2 Control Room per FSG-05

5. > 3.0 5. Assist maintenance personnel and plant operators and perform other activities as directed by the Unit Supervisor or reactor operators 8 Typically Yard Watch Operator

Enclosure 2 NOC-AE-1 5003255 Page 7 of 7 A

.4 Maintenance 5 (M5)9 1. > 6.0 1. Trailer mounted pumps and hose trailer activities. N/A Maintenance 6 (M6) 9 1. > 6.0-24.0 1. Trailer mounted pumps and hose trailer activities N/A

2. > 24.0 2. Connect NSRC generators to Engineered Safety Feature (ESF) buses.

1 Radiation Protection Technician 3 (RPT3) 1. > 6.0 1. Provide job coverage for Unit 1 FLEX makeup pump hose team N/A 2 Radiation Protection Technician 4 (RPT4) 1. > 6.0 1. Provide job coverage for Unit 2 FLEX makeup pump hose team N/A Radiation Protection Technician 5 (RPT5) 1. > 6.0 1. Conduct offsite and onsite surveys, provide job coverage N/A Radiation Protection Technician 6 (RPT6) 1. > 6.0 1. Conduct offsite and onsite surveys, provide job coverage N/A Note: see Enclosures 3 and 4 which supplement the information in this timeline.

References

1. STPNOC Procedure, OPOP05-EO-ECOO, "Loss of All AC Power" (STI 34116305)

2. STPNOC Fukushima Support Guideline, OPOP12-ZO-FSGO4, "ELAP DC Bus Load Shed / Management" (STI 34093163)

3. STPNOC Fukushima Support Guideline, OPOP12-ZO-FSGO5, "Initial Assessment and FLEX Equipment Staging" (STI 34094661)

4. STPNOC Fukushima Support Guideline, 0POP12-ZO-FSGO19, "480V FLEX Diesel Generator Operation" (STI 34097351)

5. STPNOC Fukushima Support Guideline, OPOP12-ZO-FSGO3, "Alternate Low Pressure Feedwater" (STI 34091767)

6. STPNOC Fukushima Support Guideline, OPOP12-ZO-FSG09, "Low Decay Heat Temperature Control" (STI 34094692) 9 Task can be performed by the maintenance personnel onsite as part of the IMT or by maintenance staff arriving onsite with the augmenting ERO

Enclosure 3 NOC-AE-1 5003255 Enclosure 3 Timeline of Key Plant Operator and Maintenance Activities

Enclosure 3 NOC-AE-1 5003255 Page 1 of 1 Timrefrom EventStart (in hours) 0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 5.5 6.0 6.5 7.0 7.5 8.0 8.5 9.0 S111 If il 1 1111 1 1 111 1 1 111 1 1111 1 li1111 1 1 lii I 111 ill1111li i

Transfer En ergize Energize Align PI ant Operator 1 SBO Continuewith FSG- Load light A-Train C-Train Load breakers (U1/U2 PO1) svitches, 04 and support IVC Electrical lin eup and pan els battery battery cornms. for Sl load shed Deep load shedding activities start FLEX DG

onto DG - charger _ charger . onto DG ac Ur, Plant Operator 2 Cros- Align CVCS and seal Perform Addendum 17 Start and (u1/u2 P02) con nect valves, check SFP level of FSG-05 for MCC control Support installing AFW and temperature power PDP valve lin eup CVCS PDP Support IVC operatio ns as necessary hoses for RCS makeup.

Fire Brigade 1/2 Attempt start on ESF Provide (FB1/FB2) an dTSC DGs, close IVC Assess plant con dition s and IVC support, align valvesfor SG Start FLEX SG makeup MSIVs support depressurize main generator makeup Prepare for fill of FLEX FOST Fill FOST pump Initial Fire Brigade 3/4 Breaker battery (FB3/FB4) align for Assist with SG makeup Perform MCC load chariger Relocate Continue filling DG FOST every6 Cross-conn ect AFW PSG-05 hose connections - shedding allinment Prepare for fill of FLEX FOST radios Fill FOST hours Transfer Assist Mainten ance Ass it with satellite S-Fire Brigade5 (FB5) personnel and Plant deep load Assist Mainten at ce personnel and phoneto Operators shedding Plant Operators CR Assist Maintenance personn el and Plant Operators t

Mai ntenance 1/2 Cabole in st all ati on: Cable installation: Cable installation: Cable installation: Cable installation:

(M1/M2) MCC EIA2/E2A2 (Unit MCC E1C2/E2C2 (Unit MCC E1A4/E2A4 (Unit MCC EIB4/E2B4 (Unit MCC E1C4/E2C4 (Unit Setup OSC Assistwith IVC operations I /Unit 2) 31Unit 2) S 1/Un it 2) 1/Unit 2) I/Unit 2)

Mai ntenance 3/4 (M3/M4) Connect SG makeup Install RCS makeup hoses Assst with cable installation hoses Transfer State an d County Perform State and Assst with satellite Commu nicatorlXOl) County deep load Perform State and County ph on eto Turn over duties to communications shedding communications CR Perform Statean d County communications EOF

Enclosure 4 NOC-AE-15003255 Enclosure 4 Revised Integrated FLEX Strategy Timeline

Enclosure 4 NOC-AE-15003255 Page 1 of 3 Revised Integrated FLEX Strategy Timeline The approximate completion times included below are derived from calculation STP-CP-0006, "ELAP Analysis with the South Texas Project RETRAN-3D Input Model" (Reference 1).

Event Approx. Comments Begin Phase I>- Instailled Plant Equipment Loss of All AC Power 0 Reactor/Turbine Trip 0 TDAFW Pump feeds D-Train SG 1 min Operators enter 0POP05-EO-ECO0, 2 min "Loss of All AC Power" RCP Seal Leakage increase to 4 min Reference calculation STP-CP-006, Rev. 1 approximately16.5 gpm per pump (Reference 1)

Establish SG PORVs control to Control 10 mi Room Initiates OPOP12-ZO-FSGO4, "ELAP DC Bus Load Shed/Management" (Reference 2).

Decide if ELAP conditions are met 30 min The event prompts the declaration of a Site Area Emergency which is upgraded to a General Emergency when it is determined that power cannot be restored within four hours.

Strip ESF Load Sequencers 30 min Exiting requirement not related to the ELAP Operators complete cross-connecting 40 min To allow for symmetric RCS cooldown AFW to all four SGs Operators initiate SG depressurization 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Minimize RCP seal damage from high to -405 psig temperature water Ensures no nitrogen injection from 2-3 hours acuu lators SGs depressurized to -405 psig accumulators FLEX load shed completed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Ensures at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of battery life FLEX equipment lineups/connections 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months begin Time includes one hour delay for boron mixing under natural circulation flow conditions.

RCS Boron Concentration - 193 ppm 5.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months Safety Injection (SI) Accumulator boron ensures margin to criticality down to 3000F, Equilibrium Xenon. Reference STP-CP-006, Rev. 1 Utilize offsite resources as they > 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months become available End Phase 1

Enclosure 4 NOC-AE-15003255 Page 2 of 3 Event [Approx. Comments Begin Phase 2 - FLEX Equipment and Installed Plant Equipment FLEX DG started and power becomes <8 hours available to FLEX Equipment A-Train and C-Train battery chargers 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months begin charging batteries Initiate RCS Makeup 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months CVCS PDP is the primary makeup pump and Head Vents control RCS Pressure Power/close SI Accumulator valves 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months Allows continued cooldown Operations begins cooling RCS to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months

-315'F using SG PORVs SG Makeup pump lined-up and ready 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months Will be required to replace the TDAFW for use pump before terminating cooldown RCP Seal leakage terminated when 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months PSV-3200 resets RCS pressure drops to <135 psig Timing depends on SFP level.

SFP Makeup commenced using 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Reactor Makeup Water (RMW) pump Based on 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months to boil with design heat load in the SFP.

Includes one hour delay for boron mixing under natural circulation flow conditions RCS Boron concentration -511 ppm 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months Boron from RCS Makeup ensures margin to criticality down to 300'F when Xenon free.

TDAFW unavailable due to low SG 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months FLEX SG makeup pump required.

pressure Refuel FLEX DG Fuel Oil Storage Tank 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months Refuel FLEX DG FOST from ESF FOSTs (FOST) from ESF DG FOSTs RCS at -315 0 F. Open Rx Head Vents. 15 hours1.736111e-4 days 0.00417 hours 2.480159e-5 weeks 5.7075e-6 months Reactor Head fills, close Reactor Head 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months Vents 30 minutes later Cycle Pressurizer PORV to maintain RCS pressure between 80 psia and 90 22.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months psia.

Pressurizer level restored. Secure 23.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Plant is in a steady-state mode.

RCS Makeup pump.

Prepare to fill AFWST and RWST as ->24hours Requires moving trailer-mounted diesel-necessary 24husdriven pump(s) and hose trailers.

End Phase 2

Enclosure 4 NOC-AE-15003255 Page 3 of 3 EComments Begin Phase 3.- Equipment from NSRC, FLEX Equipment and Installed Plant Equipment Equipment begins to arrive from the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months NSRC Continue coping using Phase 1 and 2 > 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Activities may include connecting 4160V equipment and equipment from NSRC NSRC turbine generator to one ESF bus References

1. STPNOC Calculation, STP-CP-006, "ELAP Analysis with the South Texas Project RETRAN-3D Input Model", Revision 1, April 15, 2015 (STI 34064235)

2. STPNOC FLEX Support Guideline Procedure, OPOP12-ZO-FSGO4, "ELAP DC Bus Load Shed/Management", Revision 0 (STI 34093163)

Enclosure 5 NOC-AE-15003255 Enclosure 5 List of Commitments

Enclosure 5 NOC-AE-15003255 Page 1 of I List of Commitments The following table identifies the actions to which the STP Nuclear Operating Company (STPNOC) has committed. One new commitment has been added based on the results of the Phase 2 Staffing Assessment revalidation. Statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments.

Scheduled Due Condition Commitments Date Report Procedures and/or training programs will be revised to ensure that Chemistry Technicians Completed retain the ability to perform on-site surveys. April 30, 2015 12-11657-36 Action will be completed prior to the end of 2RE17.

Revise Section 5.4.1.2 of IMT-0001, "Integrated Maintenance Team Guideline" to note that the minimum staffing listed in this section must be September 3, 2015 12-11658-584 maintained in order to implement FLEX strategies

v t e Letter Sequence Supplement
TAC:MF5379, (Open)
Initiation Acceptance... Supplement, Supplement Administration Questions Answers Results Approval... Other: ML15231A035
MONTHYEAR2015-09-09 [Table View]

NOC-AE-15003255, Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 2 Staffing Assessment

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NOC-AE-15003255, Supplement to Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 2 Staffing Assessment

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