Text

FLEX Strategies Phase 2 Staffing Assessment
	ML16159A235
Person / Time
Site:	Duane Arnold
Issue date:	06/03/2016
From:	Vehec T; NextEra Energy Duane Arnold
To:	; Document Control Desk
References
	NG-16-0120
	Download: ML16159A235 (41)
	v • d • e

, I NEXTeraM*

ENERGY~

DUANE ARNOLD June 3, 2016 NG-16-0120 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Op. License No. DPR-49

Subject:

FLEX Strategies Phase 2 Staffing Assessment

References:

1. NRG Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012(ML12054A736)

2. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities (ML12125A412)

On March 12, 2012, the Nuclear Regulatory Commission (NRG) issued an order (Reference 1) to all power reactor licensees, including NextEra Energy Duane Arnold, LLC's, (hereafter, NextEra Energy Duane Arnold). Reference 1 was immediately effective and directs NextEra Energy Duane Arnold to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1. Reference 2 is industry guidance document NEI 12-01 for determining the response of on-shift and augmented resources to an Extended Loss of Power (ELAP).

Please find as Enclosure 1 to this letter, a copy of NextEra Energy Duane Arnold's Phase 2 Staffing Assessment Report for a Beyond Design Basis External Event (BDBEE) for NextEra Energy Duane Arnold per NEI 12-01.

The assessment was conducted using Emergency Operating Procedures (EOPs) and Severe Accident Management Procedures (SAMPs).

This letter contains no new commitments nor does it revise any existing commitments.

NextEra Energy Duane Arnold, LLC, 3277 DAEC Road, Palo, IA 52324

Document Control Desk NG-16-0120 Page 2 of 2 Should you have any questions regarding this matter, please contact Mike Davis, Licensing Manager at (319) 851-7032.

Sincerely,

~~~~

T. A. Vehec Vice President, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure cc: Regional Administrator, USNRC, Region Ill Resident Inspector, USNRC, Duane Arnold Energy Center Project Manager, USNRC, Duane Arnold Energy Center

Enclosure 1 to NG-16-0120 Duane Arnold Energy Center FLEX Strategies Phase 2 Staffing Assessment 38 Pages to follow

DUANE ARNOLD ENERGY CENTER FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Review and Approval Prepared by Paul Brozenich Signature on file Date - - - - - - -

Reviewed by Tim Holt Signature on file Date - - - - - - -

Reviewed by Mark Fritz Signature on file Date - - - - - - -

Reviewed by Tom Rohe Signature on file Date - - - - - - -

Approved by Ron Lingle Signature on file Date - - - - - -

1

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Table of Contents Executive Summary *.*..****.*..***.*.*.**.***.*...*.****...*..**.*.*.*.*******...**.*.**..***.*...*..**** 3 Introduction ...*......**.....................**.*.*............*.............**.*...............*.........*.** 5 Staffing Assessment Process Overview*.**.**.*....*...********.*.**..*...*.**.*.*....******.**** 6 NEI 12-01 Phas*e 2 Assessment Results .*.********.*..**.*.*.*..*.*..********.**.*....***.....**. 7.

Phase 2 Staffing Assessment Details *********.*.**.**...*.*.*********.****...******.*.***.******** 8 Assumptions *.......***.*..*.**.*........*.*............................****.*.........*...........*......... 9 Methodology .***.*.****..*.*.*.*.****.**.***********.*.*.**....*.*.**.*.*.**.******.****.*.*.**....*..**** 13 Security Considerations .*.*****.**.**.*.********....*.*.***..**.*.*..*.*.*********.*..*.*.****.*.*...* 16 Strategy Resource Loading ....*.*.*.*******.*.*.*.*..*.**.****.*.*. : .**.******....*.*.*.*****.*..*** 21 Appendix 1 Staffing Tables **.*...*******.*.*.*.*.**.*.******.*.*..*.*******...*.**...*****..*.*..*.. 24 2

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Executive Summary This report documents the results of an assessment of the capability of the Duane Arnold Energy Center (DAEC) minimum on-shift staff and augmented Emergency Response Organization (ERO) to respond to a beyond design basis external event (BDBEE). The assumptions for the scenario are based on accepted industry guidance and postulate that the BDBEE involves a large-scale external natural event that results in:

A. An extended loss of AC power (HAP)

B. An extended loss of the ultimate heat sink (LUHS)

C. Unit in operation at the time of the event D. Impeded access to the unit by off-site responders as follows:

- Oto 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 tran-sportation 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 of the minimum on-shift staffing was performed by a team of DAEC subject matter experts from Operations, Radiation Protection, Security, Emergency Preparedness, and the FLEX project team. The team performed the staffing assessment on March 23-24 2016.

The participants reviewed the assumptions and applied existing procedural guidance, including applicable draft Severe Accident Management Procedures (SAMPs) for coping with a BDBEE using minimu*m on-shift staffing. Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step to account for both the task and the time duration analyses of NEI 10-05, Assessment of On-Shift Emergency Response Organization and Capabilities.

The on-shift staffing analysis concluded that there were no task overlaps for the activities that were assigned to the on-shift personnel. However, SAMP task training was not complete at the time of this assessment. Training will be delivered to E-plan on-shift staff and applicable qualifications applied and maintained to implement the FLEX strategies. These training 3

FUKUSHTh1A RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER activities are tracked by AR 1744135-24. No additional shift staffing is necessary to implement the mitigating strategies for DAEC. The evaluation utilized the minimum E-plan .on-shift staff from Operations, Radiation Protection, Chemistry, Fire Brig~de and Security to accomplish all applicable event response tasks.

4

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Introduction This report documents a preliminary staffing assessment for a Beyond Design Basis External Event for Duane Arnold Energy Center. The assessmen*t 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 (ELAP). The assessment addresses Phase 1 and 2 of the analysis applicable to implementation of existing and preliminary FLEX strategies for prolonged loss of offsite power initial and transition phases of the event, utilizing the methodology of NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities." The procedures, at the time of the assessment, were in a draft development state. When the procedures are finalized, a review will be conducted to ensure inputs to this staffing analysis remain valid.

The assessment was conducted using draft Severe Accident Management Procedures (SAMPs) and Emergency Operating Procedure (EOP) revisions. Use of these procedures is acceptable in accordance with NEI 12-01:

"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 ELAP (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, Section 3.1 and NEI 12-06, Section 12.1:

"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 (Phase 3). 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."

5

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER "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."

Staffing Assessment Process Overview Draft strategies for responding to an ELAP and draft Severe Accident Management Procedures (SAMPs) were evaluated during the NEI 12-01 Phase 2 Staffing Assessment by a multi-disciplined team .. 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). DAEC Radiological Emergency Plan Table B-1, Revision 37 documents the approved minimum Emergency Plan on-shift staff. Table 1 below summarizes the available personnel.

Table 1-DAEC on - Shift Staffing Line On-Shift Position Generic On-Title Shift

1. Operations Shift Manager (OSM) SRO 1

2. Control Room Supervisor (CRS) SRO 1 3 Shift Technical Advisor (STA) SRO 1

4. Nuclear Station Operating Engineer (NSOE) RO 1

5. Assistant Nuclear Station Operating Engineer(ANSOE) RO (FBL) 1

6. Extra Assistant Nuclear Station Operating Engineer (EANSOE) RO 1

7. Second Assistant Nuclear Station Operating Engineer (SANSOE) AO 1

8. Nuclear Station Auxiliaries Operator (NSAO) AO 1

9. Nuclear Station Plant Equipment Operator (NSPEO) AO Radwaste Operator (FBM) 1

10. Health Physics Technician #1 RP 1

11. Health Physics Technician #2 RP 1

12. Chemistry Technician CT 1

13. Shift Communicator SC 1

14. Security watchman (FBM) FBM 1

15. Maintenance #1 FBM 1

16. Maintenance #2 FBM 1 Security Sec plan SRO- Senior Reactor Operator, RO-Reactor Operator, AO- Auxiliary Operator, FBL-Fire Brigade Leader, FBM-Fire Brigade Member, SC-Shift Communicator 6

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER The DAEC FIRE PROTECTION PROGRAM FP-AB-100 identifies Fire Brigade staffing as being composed of the Assistant Nuclear Station Operating Engineer (RO) as the Fire Brigade Leader, Maintenance (2), Security, (1) and the Radwaste operator (1).

NEI 12-01 Phase 2 Assessment Results No conflicts or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during this analysis. Transition Phase actions were requir~d within the first six hours of the event.

Using NEI 12-01 and NEI 12-06 guidance, the minimum on-shift staff (as defined in the DAEC Emergency Plan B "Emerg~ncy Response Organization" Rev 37, Table B-1) performed all actions required by operating and emergency plan procedures in the first phase relying only on installed structures, systems and components in the initial phase of the response. After the ELAP condition was declared, functional draft Severe Accident Management Procedures (S~MPs) and applicable attachments were successfully implemented. They were performed using on-shift resources during the first six (6) hours and augmented responders from six (6) to twenty-four {24) hours as necessary for relief.

DAEC's phase 2 FLEX response relies upon the use of portable equipment. An evaluation of the SAMPs was conducted for the scenario. Validation & Verification (V & V} of the FLEX portable equipment deployment was conducted prior to the table top evaluation. The V & V was completed to determine the resources needed and estimated durations of each task associated with the strategy. The staffing assessment used the total number of resources identified and task durations to ensure DAEC can respond to an ELAP. The primary response to an ELAP event at DAEC is with installed equipment in phase one and portable equipment in phase 2.

A review of draft SAMPs was conducted to determine the resources needed and estimated durations of each task associated with the strategy. The total number of resources identified and task duration were then used to identify the two most resource limiting FLEX strategies.

This analysis identified that the two most resource limiting FLEX strategies are:

SAMP 724, FLEX Damage Assessment and Portable Equipment Deployment

SAMP 722, FLEX Repowering Battery Chargers from FLEX 480 VAC DG There were no required staffing or Emergency Plan changes identified during this assessment.

7

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Phase 2 Staffing Assessment Details The Phase 2 staffing assessment for DAEC was conducted on March 24 and 25, 2016 with a Simulator Validation Scenario on March 25, 2016, using the guidance of NEI 12-01, NEI 12-06 and NEI 10-05.

The following personnel were present to complete the assessment:

Table 2 - Staffing Analysis Team Personnel (Position/Title) Number Organization,/Department Senior Reactor Operator (SRO} 1 Operations Reactor Operator (RO} 1 Health Physics Foreman 1 Radiation Protection EP Coordinator 1 Emergency Preparedness EP Manager 1 FLEX Program Owner 1 Program Engineering Security Shift Supervisor 1 Security Fukushima Project Personnel 3 Fukushima Project Simulator Scenario Personnel SRO 1 Operations RO 2 Operations Instructor 1 Operations Training Fukushima Project Personnel 5 Fukushima Project 8

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Ass*umptions The extended loss of AC power event was evaluated using the following assumptions, consistent with NEI 12-01, NEI 12-06 and applicable assumptions from NEI 10-05.

NEI 12-01-Assumptions for Staffing Assessment:

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

extended loss of AC power

impeded access to the unit

2. Initially, the reactor is operating at full power and is 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. Rost-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 and Fire Protection Program.

9

FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER NEI 10 Applicable Assumptions:

1. On-shift personnel can report to their assigned response locations within

timeframes sufficient to allow for performance of assigned actions,

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

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

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

5. Individuals holding the position of radiation Protection technician or chemistry technician are qualified to perform the range of tasks expected of their position.

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

7. The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions.

8. The analyzed events occur during off-normal work hours at a time when most 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.

10

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER NEI 12-06 Assumptions

1. 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.

2. At the time ofthe 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.

3. No specific initiating event is used. The initial condition is assumed to be a loss of off-site power (LOOP) at the 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.

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

5. Cooling and makeup water inventories contained in systems or structures with designs that are robust with respect to for the applicable hazard(s) are available

6. Normal access to the ultimate heat sink is lost, but the water inventory in the UHS remains available and robust piping connecting the UHS to plant systems remains intact. The motive force for UHS flow, i.e., pumps, is assumed to be lost with no prospect for recovery.

7. Fuel for FLEX equipment stored in structures with designs which are robust for the applicable hazard (s) remains available.

8. Permanent plant equipment that is contained in structures with designs that are robust for the applicable hazard(s) is available.

9. Other equipment, such as portable AC power sources, portable back up DC power supplies: spare batteries, and LOLA equipment, may be used as on-site FLEX equipment provided it is reasonably protected from the applicable external hazards per NEI 12-06 Sections 5 through 9 and Section 11.3, and has predetermined hookup strategies with appropriate procedures/guidance and the equipment is stqred in a relative close vicinity of the site.

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

11

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER

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

12. The fire protection system ring header as a water source is acceptable only if the header is robust for the applicable hazard(s).

Plant Specific Assumptions .

1. Plant Instrument Air is not assumed to be available during the assessment period.

2. RCS Inventory:

a) *, Reactor Coolant inventory losses are limited to nornial system leakage (identified and unidentified), recirculation pump seal leakage of 18 gpm per seal at Operating pressure, and losses due to HPCI, RCIC and SRV operation.

3. Station batteries Following Station Blackout Procedure AOP 301.1 load shed will provide power for the listed durations:

a) lDl Division 1, 125VDC station battery will continue to provide power for at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months following load shed b) 1D2 Division 2, 125VDC battery will continue to provide power for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months following load shed.

c) 1D4 250VDC station battery will continue to provide power for at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months following load shed.

4. Plant communications will be available as follows:

a) The plant public address system is available in the reactor building and control building for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

b) A total of 24 hand held radios with a capacity of 8-12 hours under anticipated load, are stored in the control building and are. functional.

c) Portable Satellite phones are functional in the control room, TSC, EOF, OSC.

d) A portable 120VAC generator supplies power for charging portable communications radios and satellite phone batteries.

5. The Suppression Pool is initially the source of makeup water to the Reactor.

12

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER a) A portable diesel pump supplies water from the Circulating water pit to the Reactor following transition from RCIC. Circulating water pit inventory is sufficient for core cooling until Phase 3.

6. Station Batteries and inverters supply plant instrumentation.

7. Spent Fuel Pool Makeup or Spray equipment staging actions are desired before impediments to access could occur.

8. An Alternative Security Approach is implemented at DAEC to aid response to the beyond-design-basis external event.

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

10. During the ELAP, plant-personnel are allowed to enter the Radiological Controlled Area without processing through the Radiological Protection control point.

11. The Emergency Off-Site Facility is located approximately 15 miles from the site and is available as a staging facility. The EOF is provided with a backup diesel generator.

METHODOLOGY An assessment of on-shift staffing was performed using NEI 12-01, NEI 12-06 and NEI 10-05 guidance. Subject matter_ experts were assembled to provide analysis support. The assessment was conducted via a tabletop procedural analysis using DAEC procedures to determine iftasks have been sufficiently analyzed for performance by the minimum on-shift staff as designated in the Emergency Plan as allowed by NEI 12-06. The following provides a summary of the process that was used.

Each on-shift position from Emergency Plan Section 'B' Emergency Response Organization TABLE B-1 and any additional administrative on-shift position were entered in NEI 10-05 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, NEI 10-05 Table 1. Firefighting was not applicable for this assessment. 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:

NEI 10-05 Table 2 - Minimum Operations Crew Necessary to Implement AOPs and EOPs, SAMPs or SAMGs if applicable.

13

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER

Table 2B - Procedural Implementation Time line of activities corresponding to Table 2

NEI 10-05 Table 3-Fire Fighting (not applicable for this event analysis)

NEI 10-05 Table 4-:Radiation Protection & Chemistry Time Line of Activities

NEI 10-05 Table 5-Emergency Plan Implementation

Table 5A-E-Plan Implementation Time Line Following completion of each of the above tables, each on-shift position assigned to the associated table was lo.cated on Appendix 1, NEI 10-05 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 ofthis report.

The On-Shift Staffing Assessment (OSA) was conducted using the following process:

1. Selection of_ the multi-disciplined work group

2. Scheduling the tabletop at the DAEC Operations support Center (OSC) to allow ready access to required procedures and administrative documents

3. Conduct of a pre-jolJ briefing outlining the requirements of NEI 12-01, NEI 12-06 and NEI 10-05

4. Review of the event initial conditions and assumptions*

5. Performance of the tablet~p procedural analysis

6. Documentation of the results of the tabletop by Fukushima project group using the NEI 10-05 forms modified to extend to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This review provided the team with a basic understanding of the event and resulting emergency classifications. The SRO reviewed EOP, AOP and SAMP actions and identified them to the team.

The procedures for FLEX strategies are in draft status which is adequate for a staffing assessment. When the procedures are finalized a review of the staffing assessment will be performed to ensure that the staffing assessment results have not changed. This activity is tracked by AR 2126130.

Resources needed to perform the initial and transition phase response actions were identified from the EOP, AOP, or SAMP procedures and documented. The team determined when other on-shift resources, such as the RP or Chemistry Technician, would be required and identified 14

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER the time required to perform expected emergency plan functions. This information was documented on the applicable tables in this report. Finally, the on-shift resources and their actions were summarized in the tables using the NEI 10-05 documentation process in Appendix 1, NEI 10-05 Table 1. One scenario, ELAP with loss of Ultimate Heat Sink was reviewed.

15

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Security Considerations Existing emergency procedures do not require the use of Security Officers to perform duties unrelated to their assigned roles. However, planned mitigation strategies require Members of the Security Force (MSF) to perform duties unrelated to their assigned roles, (e.g., debris removal and equipment staging).

Security Officers will perform functions within their current roles such as monitoring, damage assessment and controlling sites access and providing compensating measures for any vital area doors that may need to remain open to facilitate room environmental conditions and hose and personnel passage.

To the extent practical; security posture and security functions will be relaxed to facilitate immediate onsite and offsite response to the emergency. No additional events or failures are assumed to occur prior to or during a BDBEE including security events.

In preparation for response to an ELAP and a LUHS an alternative security_approach has been developed. This alternative approach will enable event mitigation, while ensuring a level of protection appropriate for the circumstance. This approach is a site specific plan which includes elements such as establishing unassisted access for event mitigation and providing security personnel to assist with event mitigation. The site security department will be trained and prepared to implement the alternative approach when properly authorized. This training activity is tracked by AR 1744135-24.

Security personnel shall be the last group requested for assistance and the first group relieved once additional emergency response personnel arrive onsite. Security positions selected for reassignment to FLEX response activities are tiered and sequenced and consider position reassignment impacts to security responses under the protective strategy from the "least impactful". This is in line with the NRC guidance for an ELAP event for reassigning Security officers to FLEX response activities.

Site specific staffing assessments have estimated that 28 MSFs will be trained as FLEX Auxiliary Responders and will be responsible for debris removal from travel paths, transporting onsite portable equipment to staged locations, and assisting in deployment of hoses and cables. Of the possible 5 shift responders, 2 will be assigned per shift as FLEX Auxiliary Responders, -

available as needed for postulated beyond design basis events.

16

FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER DAEC responses to Staffing Assessment Questions Related to Use of Security Personnel during a BOB Event Response

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?

DAEC 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 Strategi~s Order and NRC JLD-ISG-2012-01 refers to' Phases 1, 2 and 3 as the Initial Phase, Transition Pbase 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?

DAEC Response:

Immediately is defined as the moment at which the senior license operator in the Control Room determines that an event has occurred, or plant conditions are present, which will require implementation of Severe Accident Management procedures (e.g., deployment of Initial Phase and/or Transition Phase Mitigating strategies).

17

FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER b.) What are the other actions that may be taken before using 10 CFR 73.SS(p)?

DAEC 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 and operation occurs within the timeframes necessary to maintain safety functions. *

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?

DAEC Response:

No; the site is not considering the use of Security personnel for other beyor:id design basis events that are not characterized by the conditions outlined within the

,guidance document.

4. Technical information concerning why the use of Security P.ersonnel would address the condition.

DAEC response:

The use of security personnel would address the condition because of their availability as a response resource to the Control Room and will help to 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.

[NOTE: No additional events or failures are assumed to occur immediately prior to or during the event including security events]

Security personnel will be supporting implementation of the following event mitigation procedures and guidelines:

SAMP 724- FLEX Damage Assessment and Portable Equipment Deployment 18

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER

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

DAEC 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 secu.rity personnel are necessary to support the event?

DAEC Response:

Two (2) security personnel are necessary to support the event.

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

DAEC Response: An Assessment Table below represents the response to 6b.

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

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

c.) What is the estimated duration for the use of security personnel?

DAEC Response:

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

19

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER

As noted earlier, the "start time" is the moment at which the senior licensed operator in the Control Room determines that an event has occurr~d or plant conditions are present, which will require implementation of Severe Accident Management Procedures (e.g.,

deployment of Initial Phase and/or Transition Phase mitigating strategies).

With respect to the "end time", it is anticipated that augmented ERO staff would 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, the need to do job briefings and turnovers, the release of security personnel from mitigating strategies 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?

DAEC 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 in accordance with the guidance in NEI 12-06.

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

DAEC 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.

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 20

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER that security personnel whose reassignment will adversely *impact security the least are reassigned first (e.g. use security personnel who are performing admini.strative functions before those who are implementing the protective strategy).

DAEC 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 str;;itegy were reassigned first. The assignment shown in the Table above (response to question 6b) reflects the selection rationale; least to greater impact Strategy Resource Loading Selected SAMPs were reviewed to determine the resources needed and estimated durations of each task associated with the FLEX strategy. The resources and time frames have been incorporated into Table 2B for ELAP response.

21

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Strategy Resource Loading SAMP Description Resources Notes 708 Emergency RPV makeup with Ops (1) PDFP & hose trailer

.the Portable Diesel Fire Pump FBM (1) previously staged during deployment 715 Portable Diesel Fire Pump FBM (2) *Deploy PDFP & suction Operation hose connect 721 FLEX 480 VAC Diesel FBM (1) Starting PDG Generator Operation 722 FLEX Repowering Battery FBM (3) Cable run to Battery Chargers from FLEX 480 VAC Chargers DG 723 Flex Repowering MCC 1B32 FBM (2) or Cable run to 1B32 and from A FLEX 480 VAC ERO (2) breaker lineup Portable Diesel generator 724 FLEX Damage Assessment FBM (5) Damage assessment and Portable Equipment and deployment route Deployment selection '

724 FLEX Damage Assessment FBM (5) Debris removal from and Portable Equipment deployment routes and Deployment equipment staging areas 724 FLEX Damage Assessment FBM (2)* Deploy Cable trailer and Portable Equipment Deployment 724 FLEX Damage Assessment_ FBM (2) Deploy PDFP & stage and Portable Equipment Deployment 724 FLEX Damage Assessment FBM (2) Deploy & stage Hose and Portable Equipment trailer Deployment

-22

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Strategy Resource Loading SAMP Description Resources . Notes 708 Emergency RPV makeup with FBM (2) Connect 5" discharge the Portable Diesel Fire Pump hose to PDFP and run hose to turbine building 724 FLEX Damage Assessment FBM (2) Deploy portable

. and Portable Equipment 480VAC DG Deployment 722 FLEX Repowering Battery FBM (1) Battery Charger Chargers from Flex 480 VAC breaker Lineup DG 725 FLEX Alternate Power to FBM (2) or Deploy 120 VAC PDG Instrument AC ERO (2) & cable connection 727 FLEX Local Instrument Obtain Instrument Rack Readings Ops (1), or readings and Fluke ER0(1) measurements at Fo~boro panels 729 Flex Ventilation Of the Reactor Ops(1) or Opening of the refuel Building without AC Power FBM(1) floor Roof vent Damper and Opening Rx Bldg.

Airlock door 730 Flex Guidelines for RCIC use Ops(1) Operational Guideline during a BDBEE only 23

FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 - Staffing Tables NEI 12-01 Phase 2 Analysis On-Shift Personnel Assignments Used During Analysis Operations On-Shift Assignments Position Designation Assignment Shift Manager SM (SRO) Shift Manager/Site Emergency Coordinator Control Room Supervisor CRS (SRO) Control Room Command .and Control Control Room Operator RO#l Control Room Operator Control Room Operator R0#2 Control Room Operator NSPEO AO#l Auxiliary Operator NSPEO A0#2 Auxiliary Operator Shift Technical Advisor STA Crew Oversight Control Room Operator FBL(R0#3) Fire Brigade Leader Radwaste Operator FBM#2 Fire brigade Member Shift Communicator SC Communications EP communicator Other On-Shift Assignments Used During Analysis Designation - Assignment Position RP Technician RP#l RP Support RP Technician RP#2 RP Support Maintenance #1 FBM#3 Fire Brigade member Maintenance #2 FBM#4 Fire Brigade member Chemistry Technician CT1 Chemistry Sampling/Dose Assessment Security* FBM#S Fire Brigade Member Security Supervisor and SEC* Security Supervision/Control & Command and personnel per the security duties as assigned by the control room to plan include portable equipment staging support.

Security personnel numbers are safeguards information. Personnel are per the security plan.

Security SME during the staffing assessment verified security personnel would be available to perform the functions of controlling site access and compensatory measures for any doors or gates that need to remain open for support of portable equipment mobilization.

24

FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 Extended Loss of all AC Power (ELAP)

NEI 10-05 Table 1-DAEC on - shift Staffing Line On-Shift Position Emergency Plan Role In Table#/ Action Reference Line# Required

1. Shift Manager E Plan Table B-1 Table 2/Ll, Table Yes 5/L1,L2,L3,L5

2. Control Room Supervisor E Plan Table B-1 T2/L2 Yes

3. Reactor Operator #1 E Plan Table B-1 T2/L4 Yes

4. Reactor Operator #2 E Plan Table B-1 T2/L6 Yes

5. NSPEO #l(Auxiliary E Plan Table B-1 T2/L7 Yes Operator)

6. NSPEO #2(Auxiliary E Plan Table B-1 T2/L8 Yes Operator)

7. Shift Technical Advisor E Plan Table B-1 T2/L3, T5/L9 Yes

8. Reactor Operator #3 FBL E Plan Table B-1/Fire T2/L5 Yes plan

9. Health Physics Technician E Plan Table B-1 T2/L11, T4/Ll No RP#l

10. Health Physics Technician E Plan.Table B-1 T 2/L12, T4/L2 No RP#2

11. Chemistry Technician CTl E Plan Table B-1 Table 2/L13, T4/L3 No

12. Radwaste Operator E Plan Table B-1/Fire Table 2/L9 Yes FBM#2 Plan

13. Security watchman E Plan Table B-1/Fire Table 2/LlO Yes FBM#5 Plan

14. Shift Communicator E Plan Table B-1 Table 2/L16 No T5/L6,L7,L8,,L12

15. Maintenance #1 FBM#3 E Plan Table B-1/Fire Table 2/L14

Yes Plan

16. Maintenance #2 FBM#4 E Plan Table B-1/F,ire Table 2/L15 Yes Plan

17. Security (SEC) E Plan Table B-1 Table 5/L14 Yes Notes: Note 1-Training required for assigned SAMP support actions (see Table 2A).

25

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 NEI 10-05 Table 2 - Plant Operations & Safe Shutdown One Unit-One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, SAMPs or SAMGs if applicable Line Generic Title/Role On Shift Position Task Performance Validation

1. Shift Manager Operations Shift Manager {OSM) Operator Training

2. Control Room Supervisor Control Room Supervisor {CRS) Operator Training

3. Shift Technical Advisor Shift Technical Advisor (STA) Operator Training Nuclear Station Operating Engineer 4 Reactor Operator#l (NSOE) Operator Training Assistant Nuclear Station Operating 5 Reactor Operator#3 Engineer(ANSOE) FBL Operator Training Extra Assistant Nuclear Station Operating 6 Reactor Operator#2 Engineer (EANSOE) Operator Training Second Assistant Nuclear Station 7 Auxiliary Operator #1 Operating Engineer (SANSOE) Operator Training Nuclear Station Auxiliaries Operator 8 Auxiliary Operator #2 (NSAO) Operator Training Nuclear Station Plant Equipment Operator 9 Radwaste Operator (FBM) Operator Training Other (non-Operations) Personnel Necessary to Implement AOPs, EOPs, SAMPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation 10 Security Officers Security Officers (SEC) Security Training Note 1 11 RP Technician RP Technician (RP1) RP Training Note 1 12 RP Technician RP Technician (RP2) RP Training Note 1 13 Chemistry Technician Chemistry Technician (CT1) Chemistry/EP Training Note 1 14 Maintenance# 1 Fire Brigade Fire Brigade Training 15 Maintenance # 2 Fire Brigade Fire Brigade Training 16 Shift Communicator Shift Communicator EP Training Note 1: See Table 2A for FLEX training requirements; See Table 2B for applicable AOP/EOP/SAMP actions.

26

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 TABLE 2A FLEX Training Requirements TABLE 2A FLEX Training Requirements Audience Lesson Training Setting an~

Approximate Duration ERO Decision Makers Basic FLEX on NANTEL CBT 1 Hour and Evaluators Licensecl Operators Non-Licensed Operators Fire Brigade Security Personnel Maintenance General Plant Staff Licensed Operators Advanced FLEX on NANTEL CBT 1 Hour Non-Licensed Operators Fire Brigade Security Personnel ERO Decision Makers and Evaluators Licensed Operators FLEX Site Specific Overview including CBT - 0.5 Hour Non-Licensed Operators OP-M-100-1005 Extreme Plant Fire Brigade Transient Response Rules Security Personnel ERO Decision Make.rs and Evaluators ERO Decision Makers HPCI I RHR logic Failures Class Room - 2.0 Hour and Evaluators Licensed Operators Licensed Operators RCIC Logic Failures Class Room -2.0 Hours ERO Decision Makers and Evaluators Licensed Operators Control of FLEX Equipment Out of Class Room -2.0 Hour Service Times Licensed operators AOP 301.1 Station Blackout , FLEX Class Room -2.0 Hours Non-licensed Operators Changes Simulator -2.0 Hours SRO/STA FLEX Coping Strategies Overview Class Room - 2.0 Hours ERO Decision Makers and Evaluators -

Licensed Operators . SAMP 724 Implementation Class Room - 2.0 Hours 27

FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER TABLE 2A FLEX Training Requirements Audience Lesson Training Setting and Approximate Duration ERO Decision Makers Emergency Management Guidelines, Class Room -4.0 Hours and Evaluators Activate/coordinate with the NSRC, SRO/STA Overview SAMP 719,TSG update ERO Shift Communicator Licensed Operators AOP 435, Loss Of Fuel Pool Cooling or Class Room 1.0 Hour Non-Licensed Operators Level, include SAMP 712, Spent Fuel Simulator 1.0 Hour Pool Makeup and Spray, SFPLI Mod traininQ Licensed Operators EOP 3, Secondary Containment Control, Class Room - 1.0 Hour ERO Decision Makers FLEX Changes and Evaluators Licensed operators SAMP 727, FLEX Local Instrument Class Room - 4.0 Hours Non-Licensed operators Readings SAMP 730, FLEX Guidelines for RCIC Use During a Beyond Design Basis External Event SAMP 729, FLEX Ventilation of the Reactor Building Without AC Power SAMP 731, FLEX Restoration of CV 4371A DW Valves N2 Supply Isolation (From 1T-128)

Security personnel Backhoe Qualification Class Room -8.0 Hours Practical -4 Hours Licensed Operators SEP 301.3, Operation of Hard Pipe Vent Class Room - 1.0 Hour Non-Licensed operators DLA-1 Hour Fire brigade SAMP 719, Emergency Refueling of Class room I Walk down -

1 RO qualified ANSOE Diesel Powered Equipment 16 Hours 1 NSPEO Qualified RW 2 Security SAMP 721, FLEX 480VAC Diesel .

2 maintenance Generator Operation SAMP 722, Repowering Battery Chargers from FLEX 480VAC DG SAMP 723, Repowering MCC 1B32 from 480VAC FLEX DG SAMP 724, FLEX Damage Assessment and Portable Equipment Deployment SAMP 725, FLEX Alternate Power to Instrument AC 28

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER TABLE 2A FLEX Training Requirements Audience Lesson Training Setting and Approximate Duration Fire Brigade SAMP 726, FLEX Adverse Combined with Fire Brigade Environmental Conditions training class room I walk 1 RO qualified ANSOE Guideline down on previous page 1 NSPEO Qualified RW SAMP 728, FLEX Replenishment of Water 2 Security Inventories 2 maintenance 29

FUKUSHIMA RESPONSE NEI 12-01PHA SE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER A end ix 1 Table 2B - Procedure Task Tim in , TSA-Time Sensitive Action Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Minutes Hour 0* 20

30

50- 240- 300- 360- 420-Step Task Resource 10 10-20 30 40 40-50 60 120 180 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 300 360 420 480 Station Blackout Event starts Minimum shift crew EOP-1 RPV Control Stabilize RPV Level, Pressure, Verify RX shutdown , Verify Isolations & CRS initiations R01 Control RPV level with RCIC. R02 x

SM EOP-1 RC/P Override open CV 4371 A Defeat 11 . Place CV-4371 A Group 3 Override Switch in Override 0 en , Confirm CV-4371A 0 ens ACP 1410.1 Parameter monitoring, Crew backup STA x EOP-1 RPV Cooldown with SRVs &RCIC <100F/Hr., to 150-200psig.

AOP 301 .1 step 11 Maintain RPV Pressure 150-200psig initiate cooldown log (attachment 7&8)

ACP1410.1 Oversi ht SM x EPIP 1.1 Determine EAL Site Area Erner enc (General Emergency) SM x EPIP 1.2 Notifications Notify NRC SC x EPIP 1.3 Accountability AOP 301.1step1a Attachment 4 Open CR cabinet doors AOP 301.1 step 2a Attachment 1 essential switch gear rooms ventilation .

AOP 301 .1 step 2a Attachment 1 Security Support per Attachment 9 Doors AOP 301 .1 step 2b Attachment 5 Block open Control Room Doors Issue Rx Bldg. Key Block Open HPCI Room upper and lower doors &

AOP 301 .1 step 2c/2d notif Control Room Critical parameter monitoring RPV Pressure, Torus Temperature, RPV AOP 301 .1 step 3 Intermittent Task for R01 and R02 cooldown AOP 301.1 recheck Declare ELAP TSA SM x Direct Fire Brigade to Implement SAMP 724 Damage Assessment &

AOP 301.1 recheck Portable Equipment De lo ment SM x AOP 301 .1 recheck Activate SAFER SC x AOP 301 .1 step 5 implement Attachment 2 Main condenser and DG room instructions AOP 301 .1 step 7 Notify ITC Midwest of SBO AOP 301 .1 step 8 Place Bus transfer switches to manual AOP 301 .1step10 Implement Attachment 3 Essential switchgear Rooms instructions x AOP 301 .1 steps Bypass RCIC and HPCI High Area Temperature Isolations 10 a, b, c, d Perform Attachment 11 Secure MG set oil, Vent GEN AOP 301 .1step12 H2 AOP 301.1step13 Periodically check Voltage at H and I breaker 30

FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER A endix 1Table2B -Procedure Task Tim in , TSA-Time Sensitive Action Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Minutes Hour 0- 20 - 30- 50- 240- 300- 360- 420-Step Task Resource 10 10-20 30 40 40-50 60 120 180 300 360 420 480 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 AOP 301.1step14 Isolate Transformer deluge systems when Air Pressure is 50 #

AOP 301 .1 step 15b Install Defeat 1 RCIC lo press isolation Perform attachment 13 AOP 301 .1step19 DC Load Shed Assess damage to ERBs and debris select deployment routes, start SAMP 724 Section 1 debris removal Security Support for Fencing removal , Gates, North &South T Bldg .

SAMP 724 Section 1 Roll Up doors, Cable Trailer, PDFP and PDG Sta in SAMP 724 Debris Removal Prepare for equipment deployment (manually open FLEX Building SAMP 724 rollu doors SAMP 724 section 2.0 Deploy .Cable trailer to staging area SAMP 7221 .0 Security support for cable routing to 1A3 switch gear SAMP 7221 .0 SAMP 722 RP Support for Cable routing to 1A3 switch gear SAMP 722 Section 2.0 Cable layout for 1D12 SAMP 724 Section 3.0, Return to ERB for PDFP deployment; Deploy PDFP. FB#1 , FB#2, x SAMP 724 Section 3.0 Return to ERB for hose trailer; Deploy hose Trailer FB#1 , FB#2 x SAMP 708 Section 1.0 Hose Layout Hose Trailer to South T Bldg. Roll up door FB#1, FB#2 x SAMP 715 Section 1.1 Step Open RHR Inject valve and hose layout RHR to south T Bldg . Roll up 15 door A01 , FB #5 x SAMP 722 Sections 3.0, 4.0 Cable Route to 10120 & 1D43 SAMP 708 Section Start PDFP and pressurize hoses x Security support for PDFP Hose Routing South T building Roll up SAMP 7081 .0 Door SAMP 715 Section 1.0 Ready for Injection x SAMP 724 Section 2.0, Return to ERB for PDG ; Deploy, Stage, PDG SAMP 721 1.0, 2.0 x

SAMP 722 Section 2.0 1D12 Battery supplied by PDG SAMP 722 Sections 3.0 & 1D120 &1043 Batteries supplied by PDG 4.0 SAMP 708 Depressurize RPV for PDFP injection x SEP301 .3 Vent Containment x

SAMP 719 Transport Refueling trailer, Refuel portable Equipment 31

FUKUSHIMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER A end ix 1 Table 2B - Procedure Task Tim in , TSA-Time Sensitive Action Performance Time After Procedure Implementation Procedure Step/Actions Minutes - Hour 1 Minutes Hour 0* 20 30

50- 240* 300- 360- 420-Step Task Resource 10-20

40-50 120 180 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 10 30 40 60 300 360 420 480 SAMP 712,Attachment 1, Route 5" Fire Hose To Power Block access point performed with Ste 2 SAMP 708 Section 1.0 FB#1 , FB#2, x SAMP 712,Attachment 1, Contact Security to Open Roll-up Doors and remove barriers to run Ste 3 fire hose into the ower block Performed Earlier SAMP 712,Attachment 1, Connect 21/2" fire hose to wye adaptor Ste 4 Route 21/2" Hoses through accessible doors and stairwells to SFP SAMP 712,Attachment 1,

a. Secure hose along route Step 5

b. Secure hose to direct makeup into SFP SAMP 712 Attachment 1, Start PDFP & open discharge valve Ste 6 SAMP 712 Attachment 1, Confirm hoses secure and water flow into pool Ste 7 32

FUKUSHJMA RESPONSE NEI 12-01PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 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 require d by scenario - Fire Brigade members availa ble to suppo rt BDBEE response actions.

33

FUKUSHIMA RESPONSE NEJ 12-0 1PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 NEI 10-05 TABLE 4- Radiation Protection & Chemistry ELAP Response Performance Time Period After Event Initiation Position Minutes Hours Line Performing 0 20 40 Function/Task 2 3 4 5 6 10 10 20 30 40 50 60

1. Job Coverage On-Shift Position :

RP1

2. Job Coverage Job coverage and as neceStllllfY,;!ll'ji'J*

On-Shift Position:

high radiation RP2

3. Job Coverage On-Shift Position :

CT1 Position Performance Time Period After Event Initiation (hours)

Line Performing 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Function/Task

1. Job Coverage On-Shift Position: In Plant Surveys RP1

2. Job Coverage On-Shift Position:

RP2

3. Job Coverage On-Shift Position:

CT1 34

FUKUSHIMA RESPONSE NEI 12-0 l PHASE 2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 NEI 10-05 Table 5 - Emergency Pla n Implementati on Line Function /Task ON-Shift Posit ion

1. Declare th e Emergency Classification Level SM

2. Approve Offsite protective Action Recommendations SM

3. Approve Content of State/Local notifications SM

4. Approve extensi on to allowable dose Limits N/R

5. Notification and direction to on-shift staff {e .g. assemble, evacuate, etc.) SM SEC

6. ERO notifications SC

7. Complete State/Local notification form SC

8. Perform State/Local notifications SC

9. Complete NRC Event notification form STA

10. Activate EROS N/A

11. Offsite radiological assessment N/R

12. Perform NRC notifications SC

13. Perform other Site specific notifications {e .g. INPO, SAFER, etc.) SC

14. Personnel Accountabi lity SEC Notes: Note 1 - On-site Notifications to State/local agencies and NRC performed using battery powered communications equipment installed in the Control Room .

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

Note 3 - Radiological release does not exist, offsite radiological assessment is not required .

Note 4- 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 SA for E-Plan implementation time line 35

FUKUSHIMA RESPONSE NEI 12-0 1 PHASE 2 STAFFING ASSESSME T REPORT DUANE ARNOLD ENERGY CENTER Appendix 1 Table SA - E-Plan Implementation Ti meline On -shift Function/Task Position 3 6 9 12 15 18 21 24 27 30 35 Declare the Emergency SM x Approve Offsite PARs SM x Approve State/Local Notification Form SM x Approve extension to allowable dose N/R limits Notification and directi on to on-sh ift SM staff (e.g., to assemble, evacuate, x etc.)

ERO notification SC Complete State/l ocal notification fo rm SC Perform State/local notifications ote SC Complete NRC event notification form STA Activate EROS ote N/A Offsite radiolog ical assessment ote N/R Perform NRC notifications ote

SC Perform other site-specific event N/A notifications (e.g. , INPO, ANI , etc.) Note 4

Personnel accountability SEC 36

FUKUSHlMA RESPONSE NEI 12-0 1PHASE2 STAFFING ASSESSMENT REPORT DUANE ARNOLD ENERGY CENTER Table 5A Notes Notes: Note 1 - On-site Notifications to State/local agencies and NRC performed using portable battery powered satellite communications equipment installed in the control room.

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

Note 3 - Radiological release does not exist, offsite radiological assessment is not required .

Note 4 - Initial NRC notification performed by SC . Continuous NRC Communications provided by Shift Communicator 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 completion time General Emergency declaration completion time Estimated Task com letion and duration time 37