Text

Response to NRC Request for Information Per 10CFR50.54(f) Re Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident Emergency Preparedness - Phase 2 Staffing Assessment
	ML15301A838
Person / Time
Site:	Turkey Point
Issue date:	09/28/2015
From:	Summers T; Florida Power & Light Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	L-2015-254
	Download: ML15301A838 (34)
	v • d • e

0SEP 2 8 2015 FPL.

L-2015-254 i=P~o10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-25 1 Response to NRC 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.

Emergency Preparedness - 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, ML12053A340.

(2) FPL letter, M. Kiley (FPL) to NRC (L-2012-208), "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," Accession No ML12144A158, May 10, 2012.

(3) FPL Letter, M. Kiley (FPL) to NRC (L-2012-247) Clarification of 60-Day Response to March 12, 2012 10 CFR 50.54(f) Request for Information, dated June 05, 2012, ML12172A288.

(4) NEI 12-0 1, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012, ML12110A204.

(5) NRC Letter, "U.S. Nuclear Regulatory Commission Review of NEI 12-01, 'Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,' Revision 0, dated May 2012," dated May 15, 2012, ML12131A043.

(6) FPL Letter, M. Kiley (FPL) to NRC (L-2013-15 1), "Response to NRC 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, Emergency Preparedness - Phase 1 Staffing Assessment," dated April 26, 2013, ML On March 12, 2012, the NRC staff issued Reference i to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 5 of Reference 1 contains the specific Requested Actions, Requested Information, and Required Response associated with Recommendation 9.3 for Emergency Preparedness - Staffing. In accordance with 10 CFR 5 0.54(f), addressees were requested to submit a written response to the information requests within 90 days.

0 Florida Power & Light Company

/j*

9760 S.W. 344I1 Street Homestead, FL 33035

In accordance with Reference 1, Enclosure 5, Florida Power and Light Company (FPL) submitted for Turkey Point Units 3 and 4, an alternative course of action for performing the requested actions and providing the requested information (Reference 2). Enclosure 1 of Reference 2 described the alternative course of action and schedule for responding to the Emergency Preparedness - Staffing, Requested Information.

By Reference 3, FPL provided clarification of the Turkey Point Units 3 and 4 outage dates noted in the Reference 2 response.

The Reference 4 guideline was developed by the Nuclear Energy Institute (NEI) for the performance of communications and staffing assessments associated with a response to a beyond design basis external event. This NEI guideline was endorsed by the NRC in Reference 5.

Reference 6 provided the FPL Turkey Point Phase 1 Staffing Assessment Report.

The Enclosure to this letter provides the FPL Turkey Point Units 3 and 4 Phase 2 Staffing Assessment Report, which was developed in accordance with the guidance of Reference 4.

As discussed in the Enclosure, FPL determined that the implementation of the Diverse and Flexible Mitigation Capability (FLEX) strategies does not require changes to the Turkey Point Emergency Plan.

The Enclosure also contains the non-Safeguards Information (SGI) Turkey Point responses to staffing assessment questions related to use of security personnel during a beyond design basis event. The SGI response is submitted under a separate transmittal protected in accordance with 10 CFR 73.22, "Protection of Safeguards Information: Specific Requirements."

If you have any questions or require additional information, please contact Mr. Mitch Guth, Licensing Manager at 305 246-6698.

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

Executed on September28, 2015 Sincerely, Thms! Sumrs Site Vice President Turkey Point Nuclear Plant Attachment Enclosure cc:

USNRC Regional Administrator, Region II USNRC Project Manager, Turkey Point Nuclear Plant USNRC Senior Resident Inspector, Turkey Point Nuclear Plant

Enclosure Fukushima NEI 12-01 Phase 2 Staffing Assessment Report

TURKEY POINT NUCLEAR PLANT UNITS 3 AND 4 FUKUSHIMA RESPONSE NEI112-01 PHASE 2 STAFFING ASSESSMENT REPORT SEPTEMBER 24, 2015 Prepared: ________________

Date:_9/24/15 Reviewed: ______________

Date:_9/25/15 Aproved PKna p*C

~Dave Stobau~~ghT Owner,AN'vd*

Date:

9/25/15 Prepared for NextEra by Energy Compliance Consultants, LLC

Table of Contents Introduction 2........

Staffing Assessment Process Overview.......................................................................... 3 NEI 12-0 1 Phase 2 Assessment Results.......................................................................... 4 Phase 2 Staffing Assessment Details............................................................................. 5 Assumptions......................................................................................................... 5 Methodology.......................................................................................................

8 Security Considerations........................................................................................... 8 Strategy Resource Loading........................................................................................ 9 Appendix 1 - Staffing Tables.................................................................................... 12 NEI 12-01 Phase 2 Analysis Non-Hurricane BDBEE...................................................... 13 Other On-Shift Assignments Used During Analysis........................................................ 13 NEI 10-05 TABLE I - On-shift Positions Turkey Point.................................................... 14 NEI 10-05 TABLE 2 - Plant Operations & Safe Shutdown................................................ 16 12-0 1 Phase 20OSA applicable to Turkey Point Units 3&4 (non-Hurricane response)................... 17 Table 2A - Procedure Task Timing...........................................

............................... 17 NEI 10-05 TABLE 3 - Firefighting.......................................................................... 20 NEI 10-05 TABLE 4 - Radiation Protection & Chemistry................................................. 21 NEI 10-05 TABLE 4 - Radiation Protection & Chemistry................................................. 22 NEI 10-05 TABLE 5 - Emergency Plan Implementation.................................................. 23 Table 5A - E-Plan Implementation Timeline................................................................ 24 Security Appendix................................................................................................ 25 Table of Figures and Tables Figure 1 PTN ELAP On-Shift Staffing........................................................................... 4 Table 1 Turkey Point Nuclear Plant Minimum On-Shift Staffing.............................................. 3 Table 2 Staffing Analysis Team................................................................................... 5 Table 3 FSG Staffing Assessment Conducted During V&V Walksdown.................................... 10 Table 4 FSG Staffing Assessment Conducted by SMEs....................................................... 11

Introduction This report documents the results of an assessment of the capability of Turkey Point Units 3 & 4 (PTN) minimum on-shift staff and augmented Emergency Response Organization (ERO) to respond to a beyond design basis external event (BDBEE). The analysis was performed in parallel with the PTN FLEX validation process to identity potential issues with FLEX strategies, resource staffing, and human factors. The assumptions for the scenario are based on accepted industry guidance and postulate that the BDBEE involves a large-scale external event that results in:

A. an extended loss of AC power (ELAP)

B. an extended loss of the ultimate heat sink (UHIS)

C. an impact to all units (all units are in operation at the time of the event)

D. impeded access to the units by off-site responders as follows:

0 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months post event - No site access. (Initial Phase) 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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).(Transition Phase) 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.(Final Phase)

The assessment was performed using guidance in NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communication Capabilities" and NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" to determine the response of on-shift and augmented resources to an Extended Loss of Power (ELMP) incident affecting all units at a site.

The assessment addresses Phase 2 of the analysis applicable to implementation of FLEX strategies for prolonged loss of offsite power applicable to multi-unit sites during the initial and transition phases of the event using the methodology, process and documentation of NEI 10-O5, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities."

FLEX Support Guidelines (FSGs) and Emergency Operating Procedure (EOP) revisions were reviewed for staffing requirements in accordance with NEI 12-0 1, page 4, Section 1.3.1.2:

"In accordance with the Order, each licensee must develop new strategies for mitigating the effects of beyond-design-basis external events. To ensure accurate results, the staffing assessment for response functions related to NTTF Recommendation 4.2 must be based on actions delineated in the procedures and guidelines developed in response to the Order. Once the site-specific actions associated with the new response strategies are defined (e.g., 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 assessment considers required actions performed during the Initial and Transition Phases of an ELMP (first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ). Evaluation of the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of response is acceptable in accordance with NEI 12-01, page 13, Section 3.1 and NEI 12-06, page 59, Section 12.1:

"It is recognized that, following successful implementation of Transition Phase coping strategies, there is a third phase characterized by the ability to cope indefinitely; this is referred to as the Final Phase.

The Final Phase would involve the use of equipment and consumables transported to the site from offsite locations, including ongoing replacement and replenishment as needed. The demands placed upon the ERO during this phase are not significantly different than those associated with Transition Phase coping; therefore, this phase is not included in a staffing assessment."

"On-site resources will be used to cope with the first two phases of the casualty for a minimum of the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the event."

2

Staffing Assessment Process Overview The NEI 12-01 Phase 2 Staffing Assessment was developed in parallel with the PTN FLEX Validation and Verification (V&V) process to ensure consistency between both efforts. The staffing assessment also addressed the ability of the on-shift staff to perform any required emergency response functions prior to the delayed arrival of the augmented Emergency Response Organization (ERO).

The Phase 2 staffing assessment requires that the ELAP scenario be evaluated based on the minimum staffing in the Emergency Plan (NEI 12-01) and the supplemental staff allowed by the minimum administrative staffing procedures (NEI 12-06). Turkey Point Radiological Emergency Plan, Table 2-2a, Rev 61, documents the approved minimum Emergency Plan on-shift staff. Table 1 below summarizes the available personnel, including shared resources for a multi-unit event, used for performance of the NEI 12-01 Phase 2 staffing assessment.

Table 1 Turkey Point Nuclear Plant Minimum On-Shift Staffing Turkey Point Nuclear Plant On-Shift Staffing Capabilities Position On-shift Shift Manager (SRO) 1 Unit Supervisor (SRO) Note 1 2

Reactor Operator (RO) 3 Shift Technical Advisor (STA) Note 4 1

Nuclear Operator/Senior Nuclear Plant Operator (SNPO) 2 Nuclear Operator/Nuclear Turbine Operator (NPO) 2 Assistant Nuclear Plant Operator (ANPO) 1 Radiation Protection Technician 1

Rad/Chemistry Technician 1

Fire Brigade Note 2 3

Security Note 3 Sec Plan Total:

17 Note 1:

Shift Communicator is an assigned responsibility of a shift SRO.

Note 2:

The table includes the Operations Field Supervisor as Fire Brigade Leader and two Nuclear Systems Operators (NSO)

Note 3:

For the purposes of FLEX response, Security personnel are included in the staffing study. Security personnel participated in Validation and Verification of appropriate FSGs. A description of the planned use of affected Security Officers to support implementation of designated FLEX strategies is provided as an Appendix to this report.

Note 4:

The STA is an additional on-shift SRO.

3

NE! 12-01 Phase 2 Assessment Results Using NEI 10-05, 12-0 1 and 12-06 guidance, the minimum on-shift staff, as defined in the PTN Emergency Plan, performed all actions required by operating and emergency plan procedures in the first hour period relying only on installed structures, systems and components. Once the General Emergency and the ELAP condition was declared, FLEX Support Guidelines (FSGs) and applicable attachments were successfully implemented by on-shift resources during the first six (6) hours and augmented responders from six (6) to twenty-four (24) hours.

Figure 1 provides a synopsis of the on-shift staffing assignments during the first six (6) hours of the event. Staffing requirements, task performance times and human factors were validated during the V&V process. All FSGs were evaluated for staffing requirements through walkthroughs or tabletop analysis. Figure 1 also shows that the minimum staffing is robust enough to support an earlier cooldown should two CSTs survive the event.

The evaluations were completed in order to determine the resources needed and the estimated duration of each task associated with the strategy. This analysis identified that the two most resource limiting FLEX strategies for a non-hurricane event are:

0-FSG-99 Attachments 3 and 18 Staging, Installation, Operation and Re-Energization of Unit 3/4 480V Buses with FLEX 480V DG 0 -FSG-99 Attachment 4 Staging, Installation and Operation of the FLEX Well Pump Figure I PTN ELAP On-Shift Staffing r*^A vycelirrgaI Sq S

I I t I I I ERo (1c)

I I I I I II I I I I I I I I I I I I I I I I IsDTA I1CST)

See Table2Afor

___________spIcific activities No conflicts or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during this analysis.

4

Phase 2 Staffing Assessment Details The Phase 2 staffing assessment for PTN was conducted in parallel with the PTN FLEX Validation and Verification process using the guidance of NEI 12-0 1, NEI 12-06 and NEI 10-05. Following the integrated review of Validation and Verification activities, the FLEX team conducted the final review of the staffing plan.

The following personnel were present to complete the final review.

Table 2 Staffing Analysis Team Personnel (Position/Title)

Organization/Department Sergio Chaviano FLEX Team Leader Joe McGuiness FLEX V&V Leader Richard Tucker SRO/Operations/FLEX Lead Paul Banaszak Engineering FLEX Lead Adam Law Operations FLEX V&V Lead Bruce Beisler Engineering FLEX V&V Lead Duane Hutchinson Radiation Protection Brad Scott Chemistry Don Harker Energy Compliance Consultants Dave Stobaugh Energy Compliance Consultants Nikki Knapp Energy Compliance Consultants Assumptions The extended loss of AC power (ELAP) event was evaluated using the following assumptions, consistent with NEI 12-01, NEI 12-06 and applicable assumptions from NEI 10-05.

NEI 12 Assumptions for Staffing Assessment:

1.

A large-scale external event occurs that results in:

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

2.

Initially, all on-site reactors are operating at full power and are successfully shut down.

3.

A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.

4.

The event impedes site access as follows:

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

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

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

5.

On-shift personnel are limited to the minimum complement allowed by the site emergency plan.

Additional administrative staff are designated as supplemental to the emergency plan minimum staff

6.

All equipment credited in current coping strategies remains available for use.

5

NEI 10 Applicable Assumptions:

7.

On-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.

8.

The on-shift staff possesses the necessary Radiation Worker qualifications to obtain emergency dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.

9.

Personnel assigned to the major response area of Plant Operations & Safe Shutdown meet the requirements and guidance established by NRC regulations and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown. Staff performance within this area is not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.

10.

On-site security organization: Performance of this function is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.

11.

Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.

12.

The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.

13.

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.

14.

The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday). For purposes of this analysis, and consistent with NEI 12-01 assumption #4, 360 minutes (6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ) will be used as the time period for the conduct of on-shift ERO response actions.

NEI 12-06 Assumptions

15.

Prior to the event the reactor has been operating at 100 percent rated thermal power for at least 100 days or has just been shut down from such a power history as required by plant procedures in advance of the impending event. (Severe weather, tornado, hurricane, etc.)

16.

At the time of the postulated event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level for the appropriate plant condition. All plant equipment is either normally operating or available from the standby state as described in the plant design and licensing basis.

17.

No specific initiating event is used. The initial condition is assumed to be a loss of off-site power (LOOP) at a plant site resulting from an external event that affects the off-site power system either throughout the grid or at the plant with no prospect for recovery of off-site power for an extended period. The LOOP is assumed to affect all units at a plant site.

18.

All installed sources of emergency on-site ac power and SBO Alternate ac power sources are assumed to be not available and not imminently recoverable.

19.

Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles are available.

20.

Normal access to the ultimate heat sink is lost, but the water inventory in the UHS remains available and robust piping connecting the UHlS to plant systems remains intact. The motive force for UHlS flow, i.e.,

pumps, is assumed to be lost with no prospect for recovery.

21.

Fuel for FLEX equipment stored in structures with designs which are robust with respect to seismic events, floods and high winds and associated missiles, remains available.

6

22.

Permanent plant equipment that is contained in structures with designs that are robust with respect to seismic events, floods, and high winds, and associated missiles, are available.

23.

Other equipment, such as portable AC power sources, portable back up DC power supplies, spare batteries, and equipment for 50.54(hh)(2), may be used provided it is reasonably protected from the applicable external hazards per Sections 5 through 9 and Section 11.3 of this guidance.

24.

Installed electrical distribution system, including inverters and battery chargers, remain available provided they are protected consistent with current station design.

25.

No additional events or failures are assumed to occur immediately prior to or during the event, including security events.

26.

On-site staff is at site administrative minimum shift staffing levels per Section 2 of this guidance. All personnel on-site are available to support site response.

Plant Specific Assumptions

27.

Plant Instrument Air is not available during the assessment period.

28.

RCS makeup will be required within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Initial RCS makeup and boration is provided by injecting the accumulators. The charging pumps provide subsequent RCS makeup and boration.

29.

Station batteries-The 125V DC and 120V Vital AC buses remain available for 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months after deep load shed. However, the 480 Volt Diesel Generators are online and providing power prior to hour 8.1

30.

The radio repeater system is not available. Talk-around channel is available.

31.

Plant public address system is unavailable.

32.

In the most restrictive case, only one Condensate Storage Tank is available with 233,075 gallons. It will provide feed to the turbine driven feed pumps for approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .2

33. Initial actions to stage hoses and nozzles within the Spent Fuel Pool Building are actions are required within 2.7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . Establishing SFP cooling is not required before 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . 3

34.

The DC Inverter and Control Rooms do not exceed design temperature limits for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .4

35.

Fire Protection System is not available during the assessment period.

36.

All equipment credited in current coping strategies remains available for use.

37.

During the ELAP, plant personnel are able to enter the RCA without processing through the RP Control Point.

38.

Security requirements maybe relaxed and managed during the ELAP conditions consistent with regulatory guidance and the Security Plan.

39.

The EOF is located approximately 26 miles from the site and is available as a staging facility. The EOF has a back-up electrical generator.

SJune 2015 Draft FTP page 20 2 bid page 67 3 Ibid page 43 SIbid page 63 7

Methodoloev The assessment of on-shift staffing was performed using NEI 12-01, NEI 12-06 and NEI 10-05 in parallel with PmN's FLEX Validation and Verification process. FLEX Support Guidelines requiring implementation during the first six hours of an ELAP were evaluated through timed walkthroughs. Staffing levels used during the walkthroughs are incorporated into the Phase 2 Staffing Analysis. A team of subject matter experts separately evaluated FSGs that were not part of the V & V process for required staffing levels and implementation timelines.

Energy Compliance Consultants, LLC modified NEI 10-05 forms to document the results of the analysis. Each on-shift position in the Emergency Plan and any additional supplemental administrative on-shift position was entered in Appendix 1, Table 1. For position titles with more than one position holder, a unique sequential number was assigned to each position. The site emergency plan reference that describes the requirement for the position to be on-shift was then entered into column 3 of Appendix 1, Table 1. Using only the on-shift positions entered in the table, the following Appendix 1 tables were completed by entering the shift position that fills a described role, or performs a specific function or tasks:

Table 2 - Minimum Operations Crew Necessary to Implement ONOPs, EOPs and FSGs Table 2A - Procedural Implementation Timeline of activities corresponding to Table 2 Table 3 - Firefighting (not applicable for this event analysis)

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

Specific site procedures and FLEX V&V results referenced during assessment of this postulated event are provided in Table 2A. Personnel resources needed to perform initial and transition phase response actions identified fr'om the EOP, ONOP, or FSG procedures during the FLEX V&V were reviewed and documented. The team determined when other on-shift resources, such as the RP, Chemistry Technician, Security, would be required and identified the time required to perform their expected emergency plan functions. This information was documented on the applicable tables in Appendix 1 of this report. Finally, the on-shift resources and their actions were summarized in the tables using the.NEL 10-05 documentation process in Appendix 1, Table 1.

Security Considerations Security personnel will be used as a supplemental resource since they are available and on site at the time of the event. This will ensure that all strategies are implemented in the required period and mitigate the potential consequences of the event. See the Security Appendix for more details.

Security support would be necessary during Phase 1 and Phase 2 (Initial Phase and Transition Phase). Planned mitigation strategies require the use of Security Officers to perform duties unrelated to their assigned roles. Security responsibilities include debris removal, moving FLEX Equipment into position, and supporting the assembly of electrical cable and hose~runs.

The staffing assessment has verified that the designated security personnel do not have non-security-related task assignments that would prevent them from performing their mitigating strategy implementation duties (i.e., no assigned collateral duties). Response training for security personnel will be developed and provided in accordance with the guidance contained in NET 12-06.

8

Security personnel will be supporting implementation of the following event mitigation procedures and guidelines if only minimum staffing is available in Phase 1:

a.

Damage Assessment and Debris Removal

b.

0-FSG-99 Attachment 3/18 Staging, Installation, Operation and Re-Energizing Unit 3/4 480V Buses with FLEX 480V Diesel Generator

c.

0-FSG-99 Attachment 4-Well Pump Functional and Providing Water to Surviving CST The site is not considering the use of security personnel for other beyond design basis events that are not characterized by the conditions outlined within the guidance document.

Notwithstanding the uncertainties associated with a beyond-design-basis event, the estimated duration for use of security personnel is bounded by the moment at which the senior licensed operator in the Control Room determines that an event has occurred, or plant condition are present, which will require implementation of FLEX Support Guidelines and the arrival of the augmented ERG staff. Allowing for some margin in the arrival times of ERG personnel, and the need to do job briefings and turnovers, the release of security personnel from mitigating strategy duties should occur during the period of approximately 6 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the initiating event.

The actions that will allow for dismissal of security personnel from duties associated with implementation of mitigating strategies would be the arrival of a sufficient number of augmented ERG personnel. Once dismissed, security personnel may resume their normal duties. Appropriate procedures and guidelines will contain instructions to the effect that, absent an overriding safety consideration, security personnel will receive priority consideration for mitigating strategy duty relief by the augmented ERG.

The use of security personnel was determined via a tiered approach to minimize the impact to security response capability. The selection of personnel considered assigned functions and potential impacts to the protective strategy.

The assignments were made such that security personnel with the least impact to the protective strategy were reassigned first. The assignments shown in Figure 1 reflect the selection rationale - least to greater impact.

Strategy Resource Loading V&V or analysis each FSG was conducted, the evaluation determined the resources needed and estimated duration of each task associated with the strategy. Adequate margin for all tasks was demonstrated during the analysis.

FSGs for contingency actions or beyond 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months were excluded from the analysis. Per Figure 1 and Table 1, the NSO abbreviation as used in Table 3 and Table 4 includes the NSO, SNPO, NPO and ANPO designations.

9

Table 3 FSG Staffing Assessment Conducted During V&V Walksdown 0-FSG-99, Preparation of Unit 3 480V Load Centers and MCCs to Receive FLEX Power 0-FSG-99, Staging, Installation, Operation and Re-Energization of Unit 3 480V Buses with FLEX 480V DG 1 I*U 0-FSG-99 0-FSG-99 0-FSG-99 0-FSG-99, Staging, Installation and Operation of the FLEX Well Pump, FLEX Well Water to Charging Pump Oil Coolers 7, Preparation of Unit 4 480V Load Centers and MCCs to Receive FLEX Power 8, Staging, Installation, Operation and Re-Energization of Unit 4 480V Buses with FLEX 480V DC 1 FS 3 NSO 2 SEC 1 CT I ES 2 NSO 2 SEC I CT 2 NSO 1 NSO I ES 3 NSO 2 SEC

'Jn-*niu Minimum Staff On-Shift Minimum Staff On-Shift Minimum Staff On-Shift Minimum Staff On-Shift Minimum Staff On-Shift Minimum Staff 0-FSG-04 ELAP DC Bus Load Shed 0-FSG-05 ATTACHMENT 4 Initial SEP Hose Routing O-FSG-06 Alternate CST Makeup 0-FSG-99, Unit 3 RCS Inventory / Boration Control O-FSG-99 0, Refueling Plan for Diesel Powered FLEX Equipment 0-FSG-99 9, Unit 4 RCS Inventory!/ Boration Control 0-FSG-99 IAttachmnent 1, Response To AFW Pump Trip 0-FSG-99, Manual Operation of Unit 3 Steam Dump to Atmosphere (SDTA) Valves 0-FSG-99 0 Manual Operation of Unit 4 Steam Dump to Atmosphere (SDTA) Valves 2 NSO On-Shift Minimum Staff 2 NSO 2 NSO 2 NSO 2 ERO On-Shift Minimum Staff On-Shift Minimum Staff ERO ERO EiRO ERO ER~O 2 NSO 1 NSO 1 NSO or 1 IC 1 NSO or IIlC 10

Table 4 FSG Staffing Assessment Conducted by SMEs O -FSG-03 0-FSG-11 0-FSG-1 1 0-FSG-99 3-FSG-01 FSG-08 3-FSG-0J9 3-FSG-10 4-FSG-01 4 -FSG-08

!4-FSG-09 4-FSG-10 Initial Assessment And Flex Equipment Staging

/

1 RO 3 NSO 3 SEC Alternate Low Pressure Feedwater 2 RO 2 NSO 2 MM Alternate SFP Makeup And Cooling 2 NSO ATTACHMENT 1 Staging, Installation And Operation Of The 5 ERO FLEX SFP Pump 1 NSO IRP, Staging, Installation And Operation Of The 6KW 1 1 ERO DG Sets____________I Alternate RCS Inventory Control l RO I NSO Alternate RCS Boration I RO 1iNSO Low Decay Heat Temperature Control 1 RO 1iNSO Passive RCS Injection Isolation 1 RO 1 NSO Alternate RCS Inventory Control 1 RO 1 NSO

-Alternate RCS Boration 1 RO I NSO Low Decay Heat Temperature Control 1 RO 1 lNSO Passive RCS Injection Isolation 1 RO 1 NSO ERO ERO ERO ERO ERO ERO ERO ERO ERO ERO UnShift Minimum Staff ll

Appendix 1 - Staffing Tables 12

NEI 12-01 Phase 2 Analysis Non-Hurricane BDBEE Position Designation Assignment Shift Manager SM Shift Manager/Emergency Director U~nit Supervisor SRO1 Unit 3 Shift Supervisor/Shift Communicator Unit Supervisor SRO2 Unit 4 Shift Supervisor/Shift Communicator Shift Technical Advisor STA Shift Technical Advisor Field Supervisor FS Fire Brigade Leader Reactor Control Operator RO1 Unit 3 Operator At Controls (OATC)

Reactor Control Operator RO2 Unit 3&4 Balance of Plant (BOP)

Reactor Control Operator RO3 Unit 4 Operator At The Controls (OATC)

Senior Nuclear Plant Operator SNPO1 Auxiliary Building Inside (I/S 105)

Senior Nuclear Plant Operator SNPO2 Auxiliary Building Outside (O/S 105)

Nuclear Plant Operator NPO1 Unit 3 Turbine Deck Operator (NPO 105)

Nuclear Plant Operator NPO2 FB Member/Unit 4Turbine Deck Operator (FBM1)

Assistant Nuclear Plant Operator AINPO 1 FB Member/ANPO (FBM2)

Nuclear Systems Operator NSO1 FB Member/ (FBM3)

Nuclear Systems Operator NSO2 FB Member/ (FBM4)

Other On-Shift Assignments Used During Analysis Position Designation Assignment RIP Technician RP1 RIP Support, Operations Support Rad/Chemistry Technician CT1 Chemistry Sampling & Analysis/Dose Assessment,

____________Operations Support Security SEC1 Debris Removal, Equipment Transport, Other as assigned

_____________by Operations personnel Security SEC2 Debris Removal, Equipment Transport, Other as assigned

____________by Operations personnel Security SEC3 Debris Removal, Equipment Transport, Other as assigned

___________by Operations personnel 13

Extended Loss of all AC Power (ELAP) non-Hurricane BDBEE NEI 10-05 TABLE 1 - On-shift Positions Turkey Point Line On-shift Position Emergency Plan Reference Roble /ine AcinRqrd?

1.

Shift Manager (SM)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L1 No T5/L1 T5/L2 T5/L3 T5/L5

2.

Unit Supervisor - U3 (SRO 1)

Turkey Point Nu61ear REP Table 2-2a, Rev 61 T2/L2 No

3.

Unit Supervisor-U4 (SR02)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L3 No T5/L6 T5/L7 T5/L8 T5/L9 T5/L12

4.

Shift Technical Advisor (STA)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L4 No

5.

Field Supervisor/Fire Team Leader (FS)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L5 No

6.

Reactor Operator-U30OATC (RO1)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L6 No

7.

Reactor Operator - U3&4 BOP (RO2)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L7 No

8.

Reactor Operator - U40OATC (R03)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L8 No

9.

Senior Nuclear Plant Operator (SNPO1)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L9 No

10.

Senior Nuclear Plant Operator (SNPO2)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L 10 No

11.

Nuclear Plant Operator (NPO1)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L11 No

12.

Nuclear Plant Operator (NPO2)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2iL12 No

13.

Assistant Nuclear Plant Operator (ANPO 1)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L1 3 No

14.

Assistant Nuclear Plant Operator (NSO1)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L14 No

15.

Assistant Nuclear Plant Operator (NSO2)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L15 No

16.

RP Technician (RP1)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L17 No 14

Line On-shift Position Emergency Plan Refer'ence Roble#/ine AcinRqrd?

17.

Chemistry Technician (CT1)

Turkey-Point Nuclear REP Table 2-2a, Rev 61 T2iL18 No

18.

CAS Operator (SEC4)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T5/L14 No

19.

Security Shift Supervisor (SEC5)

Turkey Point Nuclear REP Table 2-2a, Rev 61 T2/L17 No T5/L5 Notes:

OATC - Operator At The Controls BOP - Balance Of Plant

Action Required-Used to document any JTA or TMS needed to qualify personnel for EP duties 15

NEI 10-05 TABLE 2 - Plant Operations & Safe Shutdown Two Units - One Control Room Minimum Operations Crew Necessary to Implement ONOPs,EOPs and FSGs, Task Performance Line Generic Title/Role On-Shift PositionVadton

1.

Shift Manager Shift Manager (SM)

Operator/FLEX Training

2.

Shift Supervisor Unit Supervisor - U3 (SRO1)

Operator/FLEX Training

3.

Shift Supervisor Unit Supervisor - U4 (SRO2)

Operator/FLEX Training

4.

Shift Technical Advisor Shift Technical Advisor (STA)

Operator/FLEX Training

5.

Field Supervisor Field Supervisor/FTL (FS)

Operator/FLEX Training

6.

Reactor Operator (OATC)

Reactor Operator -U30OATC (ROl1)

Operator/FLEX Training

7.

Reactor Operator (BOP)

Reactor Operator - U3&4 BOP (RO2)

Operator/FLEX Training

8.

Reactor Operator (OATC)

Reactor Operator - U40OATC (RO3)

Operator/FLEX Training

9.

Auxiliary Operator Senior Nuclear Plant Operator (SNPO1)

Operator/FLEX Training

10.

Auxiliary Operator Senior Nuclear Plant Operator (SNPO2)

Operator/FLEX Training

11.

Auxiliary Operator Nuclear Plant Operator (NPO1)

Operator/FLEX Training

12.

Auxiliary Operator Nuclear Plant Operator (NPO2)

Operator/FLEX Training

13.

Auxiliary Operator Assistant Nuclear Plant Operator (ANPO1)

Operator/FLEX Training

14.

Auxiliary Operator Assistant Nuclear Plant Operator (NSO1)

Operator/FLEX Training

15.

Auxiliary Operator Assistant Nuclear Plant Operator (NSO2)

Operator/FLEX Training Notes:

See Table 2A for AOP/EOP/FSG actions Other (non-Operations) Personnel Necessary to Implement ONOPs, EOPs, and FSGs Task Performance Line Generic Title/Role On-Shift Position Vldto

16.

Security Supervisor Security Shift Supervisor(SEC5)

Security/FLEX Training

17.

RP Technician RP Technician (RP 1)

RP/FLEX Training

18.

Chemistry Technician Rad/Chemistry Technician (CT 1)

Chemistry/FLEX Training

19.

Security Security Guard (SEC 1)

Security/FLEX Training

20.

Security Security Guard (SEC2)

Security/FLEX Training

21.

Security Security Guard (SEC3)

Security/FLEX Training

[Notes:

See Table 2A for AOP/EOP/FSG actions

Task Performance Validation-Identifies how personnel gain EP proficiency 16

12-01 Phase 20OSA applicable to Turkey Point Units 3&4 (non-Hurricane response)

Table 2A - Procedure Task Timing Performance Time After Procedure Implementation Procedure Step/Actions 1~~

.LTIlilUl*

IIUIil 1

Procedure Task 0-10-20-Resource 1

0 3

3/4-EOP-ECA-0.0

Verify Reactor and Turbine trip SM

Verify A/B EDG status SROl

Bus Striping SRO2 STA RO 1 RO2 RO3 NPO1 NPO2 3/4-EOP-ECA-0.0 Put Equipment Switches in PULL-TO-LOCK RO2 3/4-EOP-ECA-0.0 Local Isolate Seal Injection Flowpath SNPOI 3/4-EOP-ECA-0.0 Check if ELAP is in progress Declare General Emergency and ELAP Initiate Phase A Isolation SM SRO1 SRO2 3/4-EOP-ECA-0.0 Branch to 0- FSG-4 DC Load Shed and SM FSG -5 Initial Assessment and FLEX SRO1 E EC.0-Equipment Staging SRO2 3/4 - EPEA00Check S/G Status SRO1 SRO2 RO1 RO3 3/4 - EOP-ECA-0.0 Check DC Bus Loads - Vent H2 from Generator (Attachment 3)

NPOI1 RO1 RO1 RO3 SNPOI ANPOI ERO (2) 17

Procedure Task Resource 10-20-

3.

40-50 0.

20 30 40 60 2 3 456 7)8t)!t9, ['q 10 11)2)1 i,14)15i~

16 I 17 18!¸ 19)2 l 21)22i t*i 23 )

24 3/4 - EOP-ECA-0.0 Commence RCS Cooldown 2 CST will start cooldown hour 4 1 CST available cooldown not before hour 9

RO1 RO3 2 NSO or 2 IC i______i__1ii~Ij-3/4 - EOP-ECA-0.0 Check Plant Conditions RO I

ELAP in Progress RO3

___________Sdeessuizatont I220_____________

si________

3/4 -*EOP-dCA-0.0uConarolnSto 220ApRO1 3/4 EOPECA-.0 Cntro S/GSDTAROIR3

+ -

I- -

r,-

I I t

1 1

I t-1 I I I--

I-+

+

.,I-I

, I I

I I

1 I

3/4 - EOP-ECA-0.0 Check SI Signal Status, Phase A and CNMT and CR Vent Isolation RO1 RO3 I

f I

I NPO I NPO2 SEC1 SNPC2 SEC32 SEC5 SEC I SEC2 SEC3

-Ii SEC5

]I, L I il IILIiJI I I I,:

J,,

,IEIIIIII I-I--f -f-I--f-I--f SNPO2 NSO2 I

1 I

1 1

I I¸ I

1 i

i I

I i

i

[

i 1

i i qi I i

NPOI NPO2 II I ii I I / /I I ! ! I l I ! I Ii I fI !Il I I Ii 1 1 4--f-f 4-4-f-I-

-r A

L.

A..

J FS SNPO2 ANPOI NSOI NPO1 CT1 SEClI SEC2

+

4 4

+- f I

4-f 4--f-4-l l-l-

I -+-+-

SNPO1 SNPO2 NSO2 CT1 SEC I SEC2 SEC3 t

I 1

I...

. I I

1 I

i f

I I

I i

I 18

I "1"

,5.

SProcedure Task Resource 0-10-20-10 20 30 3040-s 50 60 21 3 14 5

6 NPO1 NPO2 ERO (1)

(2RO (1 NSO 1ERO)

ERO (2 RO 2 NSO 2 MM)

ERO (5 ERO 1 NSO lRP)

ERO (2 NSO) 2 RO 2NSO 2 RO 2NSO 2R0 77 2NSO Notes:

Field communications performed using radios and/or satellite phones as available.

I Pre-Augmentation Post-Augmentation FLEX Strategy (FSG)

Estimated task duration and start time 19

NEI 10-05 TABLE 3 - Firefighting Task Analysis Line Performed By Controlling Method

1.

N/A N/A

2.

N/A N/A

3.

N/A N/A

4.

N/A N/A

5.

N/A N/A

]Notes:

Not required by scenario -Fire Brigade members available to support BDBEE response actions.I 20

NEI 10-05 TABLE 4 - Radiation Protection & Chemistry Performance Time Period After Event Initiation Line

~Position PerformingMiueHor LieFunction/Task 0-10 10-2 03 30-40 40-50 50-60 2

3 4

5 6

7 85 6

7 8

9

... 10

1.

In-Plant Survey On-Shift Position: RP1

2.

Out of Plant Survey On-Shift Position: RP1

3.

Personnel Monitoring

[

On-Shift Position:

4.

Job Coverage

5.

Offsite Radiological Assessment On-Shift Position:

6.

Other Site-Specific RP - Describe:

On-Shift Position:

7.

Chemistry function/task # 1 -

i Describe: Support FLEX 480V U3 DIG Activities On-Shift Position:

8.

Chemistry function/task #2 -

/

Describe: Support FLEX Well Pump Activities On-Shift Position:

Notes:

RP1 directed to survey main steam lines per EOP Guidance Estimated task completion and duration time 21

NEI 10-05 TABLE 4 - Radiation Protection &Chmtr LinePostio Perormng uncton/askPerformance Time Period After Event Initiation (hours)

L i e P s ti n P r o m i g1 1to n T s l

1 2

" 1 3 1 4 1 5 1 6

' 1 7 1 8

' 1 9 2 0

' 2 1

" 2 2 2 3

" 2 4

1.

In-Plant Survey I1*

I On-Shift Position: ERO

2.

Out of Plant Survey:

'1 On-Shift Position: ERO

3.

Personnel Monitoring

]

[

]

I

]

]((]

]1 On-Shift Position:

1II

4.

Job Coverage On-Shift Position: ERO

5.

Offsite Radiological Assessment I

II....

On-Shift Position: ERO I

t I

On-Shift Position:

7.

Chemistry function/task #1 -

[ I I Describe:...

___On-Shift Position: ERO

8.

Chemistry function/task #2 -

'i Describe:

___ On-Shift Position: ERO Notes:

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

Estimated task completion and duration time 22

NEI 10-05 TABLE 5 - Emergency Plan Implementation Line Function/Task On-Shift Position

1.

Declare the Emergency Classification Level (ECL)

SM

2.

Approve Offsite Protective Action Recommendations SM

3.

Approve content of State/local notifications SM

4.

Approve extension to allowable dose limits NiR

5.

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

SM SEC5

6.

ERO notification SRO2

7.

Complete State/local notification form SRO2

8.

Perform State/local notifications N,,te I SRO2

9.

Complete NRC event notification form SRO2

10.

Activate ERDS Note 2 N/A

11.

Offsite radiological assessment RP 1

12.

Perform NRC notifications Note I.

5 RO2

13.

Perform other site-specific event notifications (e.g., INPO, AMI, etc.) Note 3 N/A

14.

Personnel accountability SEC4 Notes: EAL - SSI (Site Area Emergency); SG1 (General Emergency)

Note 1 - On-site Notifications to State/local agencies and NRC performed using satellite communications equipment installed in the control room.

Note 2 - ERDS capability is unavailable due to BDBEE impact on communications infrastructure.

Note 3 - NRC Communications and other site-specific notifications assumed by EOF personnel once staffed and activated.

N/R - Not Required N/A - Not Applicable See Table 5A for E-Plan implementation timeline 23

Table 5A - E-Plan Implementation Timeline On-shift Time from Event Initiation (minutes)

FucinTs oiin 3

6 6 9

12 15 18 21 24 27 30 35 40 45 50 55 6

Declare the Emergency SM x

l l

Approve Offsite PARs SM Approve State/Local Notification Form SM x

Approve extension to allowable dose limits N/R Notification and direction to on-shift staff SM (e.g., to assemble, evacuate, etc.)

SEC5 ERO notification SRO2 Complete State/local notification form SRO2 xl l

Perform State/local notifications Note 5 RO2 xI Complete NRC event notification form SRO2*

Activate ERDS Note 2 N/A Offsite radiological assessment RP 1 Perform NRC notifications Note 1, 3 SRO2 Perform other site-specific event notifications N/A (e.g., INPO, ANT, etc.) Note 3 Personnel accountability SEC4 Notes:

Note 1 - On-site Notifications to State/local agencies and NRC performed using satellite communications equipment installed in the control room.

Note 2 - ERDS capability is unavailable due to BDBEE impact on communications infrastructure.

Note 3 - Initial NRC notification performed by site. Continuous NRC Communications and other site-specific notifications assumed by EOF personnel once staffed and activated.

N/R - Not Required N/A - Not Applicable Site Area Emergency declaration action completion time I

General Emergency declaration action completion time Estimated task completion and duration time 24

Security Appendix 25

Turkey Point Responses to Staffing Assessment Questions Related to Use of Security Personnel During a BDB Event Response Considerations for the industry analysis to address expanded activation using security personnel:

1.

How has the site evaluated the use of on-shift personnel (excluding security) to address staffing and the movement of equipment for a beyond design basis event in phases 1, 2, and 3 mitigating strategies?

Turkey Point Response:

The site has evaluated the use of on-shift personnel (excluding security) to address staffing and the movement of equipment for a beyond design basis event in phases 1, 2 and 3 mitigating strategies in accordance with the NRC staff-endorsed guidance contained in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities.

NOTE - The Mitigating Strategies Order and NRC JLD-ISG-2012-01 refers to Phases 1, 2 and 3 as the Initial Phase, Transition Phase and Final Phase, respectively.

2.

All apparent immediate actions taken to address the condition without the use of security (e.g., the exhaustive use of other site personnel).

a.)

How is "immediately" defined for the use of security personnel to support the site event?

Turkey Point Response:

Immediately is defined as the moment at which the senior licensed operator in the Control Room determines that an event has occurred, or plant condition are present, which will require implementation of FLEX Support Guidelines (e.g., deployment of Initial Phase and/or Transition Phase mitigating strategies).

b.)

What are the other actions that may be taken before using 10 CFR 73.55(p)?

Turkey Point Response:

Through implementation of the appropriate procedures and guidelines, Control Room operators will select the appropriate mitigating strategies for responding to the post-event plant conditions, and direct the performance of the in-field/plant actions necessary to implement these strategies. Consistent with the goal of protecting public health and safety, implementation of strategies will utilize the on-site staff in such a way as to ensure that equipment retrieval, placement and operation occurs within the timeframes necessary to maintain safety functions.

1 of 5

Turkey Point Responses to Staffing Assessment Questions Related to Use of Security Personnel During a BDB Event Response

3.

Is the site considering the use of security personnel for other beyond design basis events that are not characterized by the conditions outlined within the guidance document? If so, what are these events and the associated rationale for using security personnel?

Turkey Point Response:

No; the site is not considering the use of security personnel for other beyond design basis events that are not characterized by the conditions outlined within the guidance document.

4.

Technical information concerning why the use of security personnel would address the condition.

Turkey Point Response:

The use of security personnel would address the condition because their availability as a response resource to the Control Room will help ensure that mitigating strategies are implemented within the timeframes necessary to maintain safety functions. Such implementation will preclude or minimize offsite radiological consequences, and thus contribute to the protection of public health and safety.

Security personnel will be su~pporting implementation of the following event mitigation procedures and guidelines:

0-FSG-05, INITIAL ASSESSMENT AND FLEX EQUIPMENT STAGING

5.

If security is used to meet staffing requirements and the placement of equipment, what phase(s) would require their support?

Turkey Point Response:

Security support would be necessary during Phase 1 and Phase 2 (Initial Phase and Transition Phase).

6.

The rationale concerning the use of security personnel:

a.)

How many security personnel are necessary to support the event?

Turkey Point Response:

Three (3) security personnel are necessary to support the event.

2 of 5

Turkey Point Responses to Staffing Assessment Questions Related to Use of Security Personnel During a BDB Event Response b.)

What security requirements in part or total are impacted by the use of the security personnel?

Turkey Point Response:

The below Staffing Assessment Table represents the response to part 1 of consideration 6b. Part 2, Safeguards Document Table, is submitted separately as Safeguards Information.

Staffing Assessment Table Position Mitigating Strategy Duty Operate pre-staged heavy equipment and perform debris removal. May also Auxiliary Responder #1 include assisting plant Operations with deployment of FLEX equipment as necessary.

Operate pre-staged heavy equipment and perform debris removal. May also Auxiliary Responder #2 include assisting plant Operations with deployment of FLEX equipment as necessary.

Operate pre-staged heavy equipment and perform debris removal. May also Auxiliary Responder #3 include assisting plant Operations with deployment of FLEX equipment as necessary.

3 of 5

Turkey Point Responses to Staffing Assessment Questions Related to Use of Security Personnel During a BDB Event Response c.)

What is the estimated duration for the use of security personnel?

Turkey Point Response:

Notwithstanding the uncertainties associated with a beyond-design-basis event, the estimated duration is bounded as stated below.

As noted earlier, the "start time" is the moment at which the senior licensed operator in the Control Room determines that an event has occurred, or plant condition are present, which will require implementation of FLEX Support Guidelines (e.g., deployment of Initial Phase and/or Transition Phase mitigating strategies).

With respect to the "end time," it is anticipated that the augmented ERO staff should be able to access the site at around 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following the event. Allowing for some margin in the arrival times of ERO personnel, and the need to do job briefings and turnovers, the release of security personnel from mitigating strategy duties should occur during the period of approximately 6 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the initiating event.

d.)

What are the duties that will be assigned to security personnel?

Turkey Point Response:

See response to question 6b, above. The staffing assessment has verified that the designated security personnel do not have non-security-related task assignments that would prevent them from performing their mitigating strategy implementation duties (i.e., no assigned collateral duties). Response training for security personnel will be developed and provided in accordance with the guidance contained in NEI 12-06.

e.)

What actions will be required to restore security to its normal posture?

Turkey Point Response:

The actions that will allow for dismissal of security personnel from duties associated with implementation of mitigating strategies would be the arrival of a sufficient number of augmented ERO personnel. Once dismissed, security personnel may resume their normal duties.

Appropriate procedures and guidelines will contain instructions to the effect that, absent an overriding safety consideration, security personnel will receive priority consideration for mitigating strategy duty relief by the augmented ERO.

4 of 5

Turkey Point Responses to Staffing Assessment Questions Related to Use of Security Personnel During a BDB Event Response

7.

Is the use of security personnel conducted via a tiered approach to minimize impact to security response capability? Use of security personnel should be sequenced such that security personnel whose reassignment will adversely impact security the least are reassigned first. (E.g., use security personnel who are performing administrative functions before those who are implementing the protective strategy.)

Turkey Point Response:

Yes; the use of security personnel was determined via a tiered approach to minimize the impact to security response capability. The selection of personnel considered assigned functions and potential impacts to the protective strategy.

The assignments were made such that security personnel with the least impact to the protective strategy were reassigned first. The assignments shown in the Table above (response to question 6b) reflect the selection rationale - least to greater impact.

5 of 5