ML16201A146

License Amendment Request for Approval of Changes to the Three Mile Island Nuclear Station Emergency Plan Related to Staffing

ML16201A146
Person / Time
Site:	Crane
Issue date:	07/15/2016
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML16201A306	List: ML16201A146 TMI-16-073, Attachment 3C - Fire Requiring Evaluation of the Control Room and Plant Shutdown from Remote Location, (Appendix R Fire)
References
TMI-16-073
Download: ML16201A146 (80)

Text

Exelon Generation TMl-16-073 July 15, 2016 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289 Three Mile Island Nuclear Station, Unit 2 Facility Possession-Only License No. DPR-73 NRC Docket No. 50-320 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50.54(q)

Subject:

License Amendment Request for Approval of Changes to the Three Mile Island Nuclear Station Emergency Plan Related to Staffing Pursuant to 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests an amendment to Renewed Facility Operating License No. DPR-50 for the Three Mile Island Nuclear Station (TMI). Exelon also maintains the emergency planning responsibilities for TMI, Unit 2, which is owned by First Energy Corporation, through a service agreement.

Specifically, Exelon is requesting changes to the Radiological Emergency Plan Annex for TMI. The proposed changes involve on-shift emergency response staffing modifications as described in Table TMI 2-1, "Minimum Staffing Requirements for TM/ Station." The proposed changes would decrease the Radiation Protection technician staffing from three (3) to two (2) technicians, remove two (2) Maintenance technicians currently assigned to the "Repair and Corrective Action" function, and eliminate the on-shift Operations Support Center (OSC) Director position. An evaluation of the proposed changes pursuant to 1 O CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," determined that the proposed changes result in a reduction in effectiveness of the TMI Emergency Plan and therefore require prior NRC approval.

The proposed changes have been reviewed considering the requirements of 10 CFR 50.47, "Emergency plans," paragraph (b), 1 O CFR 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and other applicable emergency preparedness NRC guidance documents. The review determined that the proposed changes to Table TMI 2-1 involve a reduction in effectiveness of the TMI Emergency Plan since the changes would reduce on-shift emergency response staffing levels.

U.S. Nuclear Regulatory Commission License Amendment Request On-Shift Emergency Response Staffing Changes Docket Nos. 50-289 and 50-320 July 15, 2016 Page 2 Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 1 O CFR 50.92, "Issuance of amendments."

The proposed changes have been reviewed by the TMI Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program.

There are no regulatory commitments contained in this submittal. provides an evaluation of the proposed changes, including a detailed description, technical and regulatory evaluations including a no significant hazards consideration, and an environmental consideration. Attachment 2 provides mark-ups of the existing Emergency Plan pages depicting the proposed changes to the TMI Emergency Plan and Attachment 3 includes the affected re-typed pages of the Emergency Plan. Attachments 4 and 5 contain supporting TMI on-shift staffing technical basis and post-accident shielding evaluation information, respectively. Attachment 6 includes information related to the initial review of the proposed changes by the Pennsylvania Emergency Management Agency.

Exelon is requesting approval of the proposed license amendment by July 15, 2017. Once approved, Exelon is requesting that the amendment be implemented within 90 days.

In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and the supporting attachments to the designated State Official.

If you have any questions regarding this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 151h day of July 2016.

Respectfully,

~~~

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Evaluation of Proposed Changes

2) Emergency Plan Mark-up Pages - Three Mile Island Nuclear Station

3) Re-typed Emergency Plan Pages - Three Mile Island Nuclear Station

4) EP-AA-1009, Addendum 1, Three Mile Island On-shift Staffing Technical Basis

5) Three Mile Island - Unit 1, Postaccident Shielding Evaluation

6) Pennsylvania Emergency Management Agency Review of Impact on FEMA-Approved Emergency Plan

U.S. Nuclear Regulatory Commission License Amendment Request On-Shift Emergency Response Staffing Changes Docket Nos. 50-289 and 50-320 July 15, 2016 Page 3 cc:

w/ Attachments Regional Administrator - NRC Region I NRC Senior Resident Inspector - Three Mile Island Nuclear Station Project Manager, NRR - Three Mile Island Nuclear Station Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA R.R. Janati, Commonwealth of Pennsylvania

License Amendment Request EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request for Approval of Changes to the Three Mile Island Nuclear Station Emergency Plan Related to Staffing 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 1 of 22 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests an amendment to Renewed Facility Operating License No. DPR-50 for the Three Mile Island Nuclear Station (TMI). Exelon also maintains the emergency planning responsibilities for TMI, Unit 2, which is owned by First Energy Corporation, through a service agreement.

Specifically, Exelon is requesting changes to the Radiological Emergency Plan Annex for TMI.

The proposed changes involve on-shift emergency response staffing modifications as described in Table TMI 2-1, "Minimum Staffing Requirements for TMI Station." The proposed changes would decrease the Radiation Protection Technician (RPT) staffing from three (3) to two (2) technicians, remove two (2) Maintenance technicians currently assigned to the Repair and Corrective Action function, and eliminate the on-shift Operations Support Center (OSC) Director position. An evaluation of the proposed changes pursuant to 10 CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," determined that the proposed changes result in a reduction in effectiveness of the TMI Emergency Plan and therefore require prior NRC approval.

The proposed changes have been reviewed considering the requirements of 10 CFR 50.47, "Emergency plans," paragraph (b), 10 CFR 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and other applicable emergency preparedness NRC guidance documents. The review determined that the proposed changes to Table TMI 2-1 would involve a reduction in effectiveness of the TMI Emergency Plan since the changes would reduce on-shift emergency response staffing.

The proposed changes would result in the removal of three positions from the Emergency Response Organization (ERO) on-shift minimum staffing, the removal of the requirement that five members of the minimum on-shift staff be qualified Maintenance personnel, and the elimination of the OSC Director position as a collateral duty for the on-shift minimum staff during the initial 60 minutes following an emergency declaration.

The proposed changes align the TMI ERO on-shift minimum staff with the Exelon fleet standard ERO, allowing more consistent application of operating experience and process improvements from other fleet sites. In addition, these changes will provide additional flexibility in staffing ERO positions, such as the fire brigade, with qualified personnel from Operations or Maintenance.

In accordance with 10 CFR 50.54(q)(4), changes to a licensee's Emergency Plan that reduce the effectiveness of the plan as defined in 10 CFR 50.54(q)(1)(iv), may not be implemented without prior NRC approval and are submitted as a License Amendment Request (LAR) in accordance with 10 CFR 50.90.

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 2 of 22 2.0 DETAILED DESCRIPTION Revision 3 of the General Public Utility (GPU) Nuclear Corporation Emergency Plan for TMI, Unit 1, dated January 1981, includes the approved ERO staffing for TMI, Unit 1. Revision 3 of the Emergency Plan was evaluated under NUREG-0746, "Emergency Preparedness Evaluation for TMI-1," dated December 10, 1980, and Supplement 1 to NUREG-0746, dated May 29, 1981.

Supplement 1 concluded that the TMI, Unit 1 Emergency Plan provided an adequate planning basis.

As documented in NUREG-0746, the minimum on-shift staffing for the onsite ERO consisted of a total of 18 positions, with "9 positions associated with Operations, 5 with Maintenance, and 4 with radiation/chemistry." The Maintenance and Radiation/Chemistry complements are maintained in the current Emergency Plan for TMI via the following:

Current Onsite ERO Position Current Staffing Mechanical Maintenance (Repair and Corrective Action) 1 Electrical Maintenance (Repair and Corrective Action) 1 Maintenance Technician (Fire Brigade, Repair and Corrective Action as collateral duty) 2 Shift Maintenance Foreman (Fire Brigade Leader, OSC Director as collateral duty) 1 Radiation Protection Technician (Off-site Dose Assessment) 1 Radiation Protection Technician (In-Plant Surveys, In-Plant Protective actions as collateral duty) 2 Chemistry Technician (Chemistry) 1 Subsequent to the 1981 NRC evaluation, TMI has revised the on-shift staffing requirement under 10 CFR 50.54(q) such that the total on-shift minimum staff includes a total of 20 personnel. The two (2) additional positions are: one (1) Licensed Operator to act as Fire Brigade Advisor in accordance with the TMI Fire Hazards Analysis Report (FHAR), and one (1) position to ensure that the Communicator function is staffed by an individual with no collateral duties.

Exelon is proposing the following changes to the TMI Emergency Plan on-shift minimum staffing requirements:

Eliminate one (1) RPT - The current on-shift ERO minimum staff for Radiation Protection (RP) consists of one (1) RPT assigned to the task of Off-site Dose Assessment, and two (2) RPTs assigned to the task of In-Plant Surveys. The requested change would eliminate one (1) RPT currently assigned to In-Plant Surveys.

Eliminate two (2) Maintenance technicians (Repair and Corrective Actions) - The current on-shift ERO includes two (2) Maintenance technicians assigned to the task of "Repair and Corrective Actions." The requested change would eliminate these two positions. These positions will continue to be filled by four (4) additional License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 3 of 22 ERO members as a collateral duty.

In support of these changes, Exelon is also proposing that the TMI Emergency Plan be revised to remove the requirement that five (5) members of the ERO on-shift staff be Maintenance personnel.

Finally, Exelon is proposing the deletion of the on-shift position of OSC Director. This position is currently a collateral duty, and is assigned to a member of the minimum on-shift staff. The on-shift position is staffed on an interim basis until relieved by a member of the augmented ERO OSC minimum staff qualified in the OSC Director position. The OSC is required to be staffed and activated within 60 minutes of event classification at the Alert or higher level. The augmented OSC position is required to be staffed to support OSC activation.

3.0 TECHNICAL EVALUATION

The evaluation of the proposed changes is discussed below.

A. Elimination of One Radiation Protection Technician Impact on Emergency Planning Function Current on-shift staffing includes three (3) RPTs. TMI is proposing that one (1) RPT be eliminated from the on-shift minimum staff.

10 CFR 50.54(q) establishes that all holders of a nuclear power reactor operating license must follow and maintain in effect Emergency Plans which meet the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." In accordance with 10 CFR 50.47(b)(2), a licensee must provide "...adequate staffing to provide initial facility accident response in key functional areas [that] is maintained at all times," and ensure that "timely augmentation of response capabilities is available...."

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Table B-1 specifies the minimum staffing requirements for the ERO:

The Major Functional Area of "Radiological Accident Assessment and Support of Operational Accident Assessment" is fulfilled on-shift by a one (1) RPT on-shift and one RPT augmented at 30 minutes to perform the "Major Task of In-plant Surveys."

The Major Functional Area of "Protective Actions (In-Plant)" is fulfilled by two (2)

RPTs, with the provision that these positions "may be provided by shift personnel assigned other functions."

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 4 of 22 The Major Functional Area of "Radiological Accident Assessment and Support of Operational Accident Assessment." The NUREG specifies that this position is fulfilled by one (1) individual with Senior Health Physics (HP) expertise, to be augmented within 30 minutes.

The approved TMI Emergency Plan provides for staffing of these functions with two (2)

RPTs assigned to "In-plant Survey" tasks and one (1) on-shift member of RP staff qualified to perform "Offsite Dose Assessment." The "Major Function of Protective Actions" (In-Plant) is assigned as a collateral duty.

As documented in NUREG-0746, "Emergency Preparedness Evaluation for TMI-1," the approved minimum shift for the onsite emergency organization is, "9 positions associated with operations, 5 with maintenance, and 4 with radiation/chemistry," for a total of 18 positions." The three (3) on-shift RPTs, along with the on-shift Chemistry technician, constitute the four (4) positions associated with radiation/chemistry. This change would eliminate one of the three (3) RPTs.

The following discussion addresses each of the Major Tasks assigned to the on-shift RPTs within the Functional Area of "Radiological Accident Assessment and Support of Operational Accident Assessment":

Offsite Dose Assessment 10 CFR 50 Appendix E, Section IV.A.4, states in part that:

"The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, and a description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities."

10 CFR 50.47(b)(9) states that, "Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use."

For TMI, the on-shift task of off-site dose assessment is performed by a RPT utilizing a computer program. Application of this program to determine projected dose involves input of data obtained from computer Plant Parameter Display System (PPDS) screens. Dose projections can be promptly performed to support completion as required by plant procedures. The rapid determination of dose assessment allows the assigned RPT for this task time to support the ERO with radiological assessment, decision-making, and radiological leadership during an emergency event. The Technical Support Center (TSC) and Emergency Operations Facility (EOF) minimum staff complements include individuals License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 5 of 22 trained in the performance of off-site dose assessment utilizing the computerized dose assessment method. Both the TSC and EOF are activated within 60 minutes of a classification at the Alert or higher, thereby allowing transfer of this responsibility from the on-shift RPT.

In-plant Surveys As required by 10 CFR 50, Appendix E, Section IV.A.9, TMI performed a staffing assessment in accordance with the guidance in Interim Staff Guidance (ISG) NSIR/DPR-ISG-01, "Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities." A review of the existing TMI procedures during this assessment determined that there are no procedurally directed in-plant survey actions that are required in response to the analyzed design basis events. In addition, no RP coverage is required to perform expected operator actions for these events. The only task requiring RPT coverage was firefighting in response to a fire requiring the evacuation of the Main Control Room (MCR) or an Engineered Safeguards Actuation System (ESAS) room fire. In both cases, the accident analysis does not result in an off-site release or in-plant radiological consequences.

During an emergency, RP personnel may be required to establish boundaries for contaminated areas and elevated dose rate areas to control access. However, electronic access control is used to limit any access to the Radiologically Controlled Areas (RCAs) while specific area boundaries are being established.

TMI Updated Final Safety Analysis Report (UFSAR) Section 11.A, "Postaccident Shielding Analysis," documents a shielding evaluation that identified the necessary action to be taken for providing additional shielding in vital areas in which equipment may be unduly degraded by the large radiation fields in a post-accident environment and in which personnel may receive excessive exposures. Based upon the shielding analysis results and the modifications identified in the analysis, there are no areas that are expected to require operator access under post-accident conditions that would require RPT coverage. The shielding analysis is included in Attachment 5.

RPT support functions associated with the Functional Area of Protective Actions (In-plant),

such as access control, personnel monitoring, and dosimetry now require less dedicated support time since they are covered by plant process enhancements such as newer technology and tools. The improved technology and tools use available equipment such as portal monitors, self-alarming dosimeters, and an automated access control point. All onsite ERO members expected to be dispatched into the plant for evaluation, operations, or repair activities are radiation-worker qualified and understand and are trained on how to use the available tools. The following discussion addresses each of the Major Tasks assigned to the on-shift RPTs within the Functional Area of Protective Actions (In-Plant):

Access Control Access to the RCA is controlled electronically. The electronic access control system provides for the user to electronically sign Radiation Work Permits (RWPs) to self-authorize License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 6 of 22 access to the RCA and self-issuance of an electronic dosimeter in addition to the assigned Dosimeter of Legal Record (DLR) that is always worn. Access to the RCA is controlled electronically without interface with an RPT. Manual RWP logging is available as a backup access control method.

RWPs are in place, and active for use with setpoints for dose and dose rate that reflect expected conditions. In an emergency, when expected conditions would likely change, electronic dosimeter set points can be adjusted via a network computer in the RCA access control program once the on-shift RPTs have determined actual dose rates. If dose rates are unknown, continuous RPT assistance will be required. Additionally, RPTs can modify the setpoints on electronic dosimetry that is maintained in the fast-activation mode.

In accordance with applicable Exelon procedures for controlling access into high and locked high radiation areas," an individual entering a High Radiation Area (HRA) or a Locked High Radiation Area (LHRA), is required to receive a briefing in accordance with the applicable procedures, and must be equipped with one or more of the following:

A radiation monitoring device which continually indicates the radiation dose rate in the area.

A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a pre-set integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate levels in the area have been established and personnel made aware of them.

An RP individual qualified in RP procedures with a radiation dose rate device, which is responsible for positive control over the activities in the area and shall perform periodic radiation surveillances at the frequencies specified in the RWP.

During emergency conditions when personnel must enter HRAs to perform immediate actions, they are not required to be informed of area dose rates prior to entry as long as they are provided a qualified RP individual to maintain positive control over the activities.

This coverage is provided by the on-shift complement of RPTs. Operations personnel are not qualified to perform self-monitoring in these areas. Access entry points to HRAs are controlled by lock-and-key. Operations maintains high radiation area keys under the control of the Shift Manager for needed access under emergency conditions.

Personnel monitoring Personnel are issued DLRs that are continuously worn for monitoring. No RPT support is needed for issuance of DLRs to on-shift emergency workers. Electronic dosimeters are self-issued through the electronic access control system. The electronic dosimeters are self-reading, alarming dosimeters that provide readout of accumulated dose and ambient dose rate. No RPT support is needed for issuance of electronic dosimeters since issuance and use of the electronic dosimeters are part of radiation worker training. Dose rate instruments are also available to support personnel monitoring.

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 7 of 22 Automated whole body monitors provide contamination monitoring. All radiation workers are qualified to use the automated whole body monitors without RPT interface. In circumstances when the automated whole body monitors are not available, hand held friskers are used for personnel contamination monitoring. All radiation workers are qualified to use the hand held friskers without RPT interface.

Dosimetry Personnel are issued DLRs that are continuously worn for monitoring. No RPT support is needed for issuance of DLRs to on-shift emergency workers. As described above, electronic dosimeters are self-issued through the electronic access control system. No RPT support is needed for issuance of electronic dosimeters.

If a DLR is lost or damaged under emergency conditions, additional DLRs are staged for emergency issuance. Emergency issuance does not require an American National Standards Institute (ANSI) qualified RPT to perform. The on-shift complement of RPTs is knowledgeable of the location of replacement DLRs and, if required in an emergency, will issue replacement DLRs to the remainder of the on-shift ERO members.

If an electronic dosimeter is lost or damaged, additional electronic dosimeters are maintained for immediate issuance. This task does not require an ANSI qualified RPT to perform. The on-shift complement of RPTs that are ERO members are trained and knowledgeable on the location of the electronic dosimeters that are maintained in the fast-activation mode and the procedure for activating them. These personnel are responsible for assisting all on-shift ERO members in performing this task during an emergency.

RP coverage for repair, corrective actions, search and rescue, first-aid, and firefighting In accordance with applicable Exelon procedures, one (1) RPT is assigned to the MCR to support ongoing MCR Emergency Response Team (ERT) activities. The Shift Emergency Director establishes the priorities for all on-shift ERO members, and will direct RP resources as required to respond to plant conditions. This includes prioritizing support for repair, corrective actions, search and rescue, first-aid, and firefighting. Search and rescue and first-aid functions are assigned as collateral duties with support provided by personnel from Security, Operations, or RP, based upon the specific conditions requiring such a response.

TMI UFSAR Section 11.A, "Postaccident Shielding Analysis," documents a shielding evaluation that identified the necessary action to be taken for providing additional shielding in vital areas in which equipment may be unduly degraded by the large radiation fields in a post-accident environment and in which personnel may receive excessive exposures. Based upon the shielding analysis results and the modifications identified in the analysis, there are no areas that are expected to require operator access under post-accident conditions that would require RPT coverage. The Shielding Analysis is included in Attachment 5.

TMI assigns one (1) RPT to perform RP activities to support the Fire Brigade. The RPT responds as a fire support person and is not a fire brigade member. Having a member of RP support the Fire Brigade assures that proper radiological controls are License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 8 of 22 established in the fire area, as warranted.

Impact on On-shift Staffing Assessment Section IV.A and new Section IV.A.9 of 10 CFR 50, Appendix E states, in part, the following:

"The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan."

A staffing assessment was performed using the guidance provided in ISG NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities."

This assessment evaluated the following events:

Design Basis Threat (DBT) Ground Assault Aircraft Probable Threat Fire Requiring Evacuation of the Control Room and Plant Shutdown from Remote Location (Appendix R Fire)

Large Break Loss of Coolant Accident (LOCA)

Station Blackout, (SBO)

Steam Generator Tube Rupture Control Rod Ejection Accident Waste Gas Tank Rupture Fire in ESAS Room The required tasks for each event were assessed to determine if sufficient personnel are available on-shift to perform all of the tasks required by the applicable plant procedures and the Emergency Plan, without the need for any unacceptable collateral duties. This assessment concluded that the minimum on-shift of two (2) RPTs, as proposed, is sufficient to perform all required tasks prior to augmentation. The TMI on-shift staffing assessment is included in Attachment 4 of this submittal.

B. Eliminate Requirement for Maintenance Discipline On-shift 10 CFR 50.54(q) establishes that all holders of a nuclear power reactor operating license must follow and maintain in effect Emergency Plans which meet the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." In accordance with 10 CFR 50.47(b)(2), a licensee must provide "...adequate staffing to provide initial facility accident response in key functional areas [that] is maintained at License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 9 of 22 all times," and ensure that "timely augmentation of response capabilities is available...."

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Table B-1 specifies the minimum staffing requirements for the ERO. As documented in NUREG-0746, "Emergency Preparedness Evaluation for TMI-1," the approved minimum shift for the onsite emergency organization is, "9 positions associated with operations, 5 with maintenance, and 4 with radiation/chemistry," for a total of 18 positions. Subsequent to the 1981 NRC evaluation, TMI has revised the on-shift staffing requirement under 10 CFR 50.54(q) such that the total on-shift minimum staff includes a total of 20 personnel. The two (2) additional positions are one (1) Licensed Operator to act as Fire Brigade Advisor in accordance with the TMI Fire Hazards Analysis Report (FHAR),

and one (1) position to ensure that the Communicator function is staffed by an individual with no collateral duties.

Exelon is proposing that the requirement to include five (5) personnel associated with Maintenance in the minimum on-shift staff be eliminated. The basis for this change is provided in the following discussion.

The evaluation of the need to include Maintenance capability on-shift includes three (3) areas:

On-shift Staffing Assessment Actions Required by Emergency Operating Procedures (EOPs) and Abnormal Operating Procedures (AOPs)

Duties Currently Assigned to On-shift Maintenance Personnel Evaluations of these areas are provided below.

1. On-shift Staffing Assessment Section IV.A and new Section IV.A.9 of 10 CFR 50, Appendix E states, in part, the following:

A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 10 of 22 prevent the timely performance of their assigned functions as specified in the emergency plan.

A staffing assessment was performed using the guidance provided in ISG NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities." This assessment evaluated the following events:

Design Basis Threat (DBT) Ground Assault Aircraft Probable Threat Fire Requiring Evacuation of the Control Room and Plant Shutdown from Remote Location (Appendix R Fire)

Large Break Loss of Coolant Accident (LOCA)

Station Blackout, (SBO)

Steam Generator Tube Rupture Control Rod Ejection Accident Waste Gas Tank Rupture Fire in ESAS Room The required tasks for each event were assessed to determine if sufficient personnel are available on-shift to perform all of the tasks required by the applicable plant procedures and the Emergency Plan, without the need for any unacceptable collateral duties.

This assessment concluded that Maintenance qualifications were not required to perform any tasks in order for the minimum on-shift staff to respond to each of the scenarios analyzed, without the assignment of any unacceptable collateral duties. The assessment included "Repair and Corrective Action" tasks, as defined in NEI 10-05. In accordance with the guidance in NEI 10-05, a "Repair and Corrective Action" task consists of "action that can be performed promptly to restore a nonfunctional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete." Per NEI 10-05, the staffing assessment considered any site-specific planned/expected actions performed in-plant prior to the arrival of the augmented ERO. The assessment did not identify any actions that would not be performed by Operations personnel. The on-shift staffing assessment is provided as Attachment 4 of this submittal.

2. Actions Required by Emergency Operating Procedures and Abnormal Operating Procedures A review of procedures and tasks, including the activities directed by the normal plant operating procedures for a plant shutdown, as well as AOPs and EOPs was conducted.

The minimum on-shift staff was determined to be sufficient to perform all required actions without support from the two (2) on-shift Maintenance technicians targeted by this change. The necessary timeframe for performing manual actions as well as the training required to perform the tasks was considered. Other Operator actions that may be required in the first 60 minutes of the event would be to align equipment for repair.

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 11 of 22 This has also been evaluated under the Non-Licensed Operator (NLO) training program and no additional tasks are required. Based on this review, eliminating the two (2)

Maintenance "Technician Repair and Corrective Action" ERO responders would have no effect on the performance of associated tasks during the early part of an event and maintains the effectiveness of the ERO on-shift response.

3. Duties Currently Assigned to On-shift Maintenance Personnel The duties currently assigned to the on-shift Maintenance personnel include:

Current Position Current Duties Mechanical Maintenance Technician Repair and Corrective Actions Electrical / I&C Technician Repair and Corrective Actions Shift Maintenance Supervisor Fire Brigade Team Leader Maintenance Technician (Mechanical/Electrical/I&C)

Fire Brigade Member Maintenance Technician (Mechanical/Electrical/I&C)

Fire Brigade Member An evaluation of these duties concluded that Maintenance qualifications are not required to execute the associated tasks during the first 60 minutes post-event.

The evaluations of these duties are as follows:

Repair and Corrective Actions - As defined in the On-shift staffing assessment guidance (Attachment 4), a "Repair and Corrective Action" task consists of an action that can be performed promptly to restore a nonfunctional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete. As noted under the evaluations of the on-shift staffing assessment results and actions required by EOPs and AOPs, these evaluations did not identify any actions that would not be performed by Operations personnel. Other Operator actions that may be required in the first 60 minutes of the event would be to align equipment for repair. The capability of Operations personnel to perform these actions has been evaluated under the NLO training program.

Fire Brigade Team Leader - The TMI FHAR, as well as applicable Exelon procedures have been reviewed. The applicable requirements are limited to the position-specific Fire Brigade Team Leader training and periodic drill requirements. TMI has no requirement that the Fire Brigade Team Leader be a Shift Maintenance Supervisor or have maintenance-specific qualifications.

A staffing assessment was performed pursuant to changes to Emergency Preparedness (EP) regulations in 10 CFR 50.47, "Emergency Plans," and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"

published in the Federal Register on November 23, 2011 (i.e., 76FR72560). Using the guidance provided in ISG NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 12 of 22 Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," this assessment did not identify any concurrent tasks for the Fire Brigade Team Leader in the event of a fire.

Based upon the requirements of the TMI FHAR and the results of the on-shift staffing assessment, the position of Fire Brigade Team Leader does not require Maintenance qualifications and can be filled by any qualified individual who is not assigned to another ERO position.

Fire Brigade Member - The TMI FHAR, as well as applicable Exelon procedures have been reviewed. The applicable requirements for the position of Fire Brigade member are limited to the position-specific Fire Brigade training and periodic drill requirements.

TMI has no requirement that the Fire Brigade members have maintenance-specific qualifications.

A staffing assessment was performed pursuant to changes to Emergency Preparedness (EP) regulations in 10 CFR 50.47, "Emergency Plans," and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"

published in the Federal Register on November 23, 2011 (i.e., 76FR72560). Using the guidance provided in ISG NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," this assessment did not identify any concurrent tasks for the Fire Brigade members in the event of a fire. Based upon the requirements of the TMI FHAR and the results of the on-shift staffing assessment, the position of Fire Brigade member does not require Maintenance qualifications and can be filled by any qualified individual who is not assigned to another ERO position.

C. Eliminate Two Maintenance Technicians from Repair and Corrective Actions Impact on Emergency Planning Function 10 CFR 50.54(q) establishes that all holders of a nuclear power reactor operating license must follow and maintain in effect Emergency Plans which meet the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." In accordance with 10 CFR 50.47(b)(2), a licensee must provide "adequate staffing to provide initial facility accident response in key functional areas [that] is maintained at all times," and ensure that "timely augmentation of response capabilities is available...."

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Table B-1 specifies the minimum staffing requirements for the ERO. The functional area of "Repair and Corrective Actions" is fulfilled on-shift by a total of two (2) positions, one (1) Mechanical Maintenance/Radwaste Operator and one (1) Electrical Maintenance/I&C technician that "may be provided by shift personnel assigned other functions," along with two (2) positions augmented at 30 minutes. TMIs Emergency Plan License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 13 of 22 currently satisfies this requirement with two (2) Maintenance technicians, as well as four individuals who are assigned to other functions. TMI is proposing the removal of the two (2)

Maintenance technicians from the minimum on-shift complement. The remaining staffing of four (4) individuals who are assigned to other functions exceeds the staffing requirements as specified in Table B-1.

The following discussion addresses each of the Major Tasks assigned to the two (2) on-shift Maintenance technicians within the "Functional Area of Repair and Corrective Action":

Repair and Corrective Action 10 CFR 50.54(q) establishes that all holders of a nuclear power reactor operating license must follow and maintain in effect emergency plans which meet the planning standards in 1o CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." In accordance with 10 CFR 50.47(b)(2), a licensee must provide "adequate staffing to provide initial facility accident response in key functional areas [that] is maintained at all times," and ensure that "timely augmentation of response capabilities is available."

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Table B-1 specifies the minimum staffing requirements for the ERO. The functional area of "Repair and Corrective Actions" is fulfilled on-shift by a total of two (2) personnel that also "may be provided by shift personnel assigned other functions." Current on-shift staffing includes two (2) Maintenance technicians who are specifically assigned to perform the functions of "Repair and Corrective Action." TMI is proposing that these positions be eliminated from the on-shift minimum staff. Exelon has concluded that this change is acceptable, based upon the following:

A staffing assessment was performed pursuant to changes to EP regulations in 10 CFR 50.47, "Emergency Plans," and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," published in the Federal Register on November 23, 2011 (i.e., 76FR72560). Using the guidance provided in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," this assessment concluded that these two (2) positions were not required to perform any tasks in order for the minimum on-shift staff to respond to each of the scenarios analyzed, without the assignment of any unacceptable collateral duties.

In accordance with the guidance in NEI 10-05, a "Repair and Corrective Action" task consists of: "An action that can be performed promptly to restore a nonfunctional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete." Per NEI 10-05, the staffing assessment considered any site-specific planned/expected actions License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 14 of 22 performed in-plant prior to the arrival of the augmented ERO. The assessment did not identify any actions that would require the support of qualified Maintenance personnel.

A review of procedures and tasks, including the activities directed by the normal plant operating procedures for a plant shutdown, as well as AOPs and EOPs was performed. The minimum shift staff was determined to be sufficient to perform all required actions without support from the two on-shift maintenance technicians targeted by this change. The necessary timeframe for performing manual actions as well as the training required to perform the tasks was considered. Other operator actions that may be required in the first 60 minutes of the event would be to align equipment for repair. This has also been evaluated under the NLO training program and no additional tasks are required. Based on this review, eliminating the two (2)

Maintenance Technician Repair and Corrective Action ERO responders has no effect on the performance of associated tasks during the early part of an event and maintains the effectiveness of the ERO on-shift response.

Impact on On-shift Staffing Assessment Section IV.A and new Section IV.A.9 of 10 CFR 50, Appendix E states, in part, the following:

A. Organization The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

A staffing assessment was performed using the guidance provided in ISG NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities."

This assessment evaluated the following events:

Design Basis Threat (DBT) Ground Assault Aircraft Probable Threat Fire Requiring Evacuation of the Control Room and Plant Shutdown from Remote Location (Appendix R Fire)

Large Break Loss of Coolant Accident (LOCA)

Station Blackout, (SBO)

Steam Generator Tube Rupture Control Rod Ejection Accident License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 15 of 22 Waste Gas Tank Rupture Fire in ESAS Room The required tasks for each event were assessed to determine if sufficient personnel are available on-shift to perform all of the tasks required by the applicable plant procedures and the Emergency Plan, without the need for any unacceptable collateral duties. This assessment concluded that assigning the Mechanical Maintenance and Electrical Maintenance on shift positions as collateral duties to four members of the minimum on-shift ERO staff, is sufficient to perform all required tasks prior to augmentation. The TMI on-shift staffing assessment is included in Attachment 4 of this submittal.

D. Delete the OSC Director from TMI On-shift Minimum Staff (Collateral duty - no staff reduction)

Impact on Emergency Planning Function 10 CFR 50.54(q) establishes that all holders of a nuclear power reactor operating license must follow and maintain in effect emergency plans which meet the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." In accordance with 10 CFR 50.47(b)(2), a licensee must provide "... adequate staffing to provide initial facility accident response in key functional areas [that] is maintained at all times," and ensure that "timely augmentation of response capabilities is available...."

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Table B-1 does not specify an on-shift staffing requirement for the OSC Director position. TMI is proposing to delete the OSC Director position as an on-shift collateral duty, based upon the following:

The TMI OSC is activated within 60 minutes of the classification of an Alert or higher. The OSC is not staffed prior to this point. There are no tasks directed to be performed by the OSC prior to facility activation. In accordance with Exelon procedural requirements, control of the Equipment Operators is maintained by the MCR until the OSC is activated. In addition, the OSC Director, the OSC Maintenance, Chemistry, and RP staffs, and the OSC Group Leads are 60-minute augmentation positions. The absence of an on-shift OSC Director position as a collateral duty for a member of the minimum on-shift complement will not adversely impact the ability to staff and activate the OSC in a timely manner and is not required in order to support response to the emergency. Therefore, TMI concludes that this change will not reduce the effectiveness of the Emergency Plan.

Impact on On-shift Staffing Assessment Section IV.A and new Section IV.A.9 of Appendix E states, in part, the following:

A. Organization License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 16 of 22 The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

A staffing assessment was performed using the guidance provided in ISG NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities." This assessment evaluated the following events:

Design Basis Threat (DBT) Ground Assault Aircraft Probable Threat Fire Requiring Evacuation of the Control Room and Plant Shutdown from Remote Location (Appendix R Fire)

Large Break Loss of Coolant Accident (LOCA)

Station Blackout, (SBO)

Steam Generator Tube Rupture Control Rod Ejection Accident Waste Gas Tank Rupture Fire in ESAS Room The required tasks for each event were assessed to determine if sufficient personnel are available on-shift to perform all of the tasks required by the applicable plant procedures and the Emergency Plan, without the need for any unacceptable collateral duties. TMI currently assigns the OSC Director position as a collateral duty for a member of the on-shift minimum ERO staff. As noted above, the TMI OSC is staffed and activated within 60 minutes of the classification of an Alert or higher. There are no tasks directed to be performed by the OSC prior to facility activation. Exelon procedures stipulate that control of the Equipment Operators is maintained by the MCR until the OSC is activated. In addition, the OSC Director, The OSC Maintenance, Chemistry, and RP staffs, and the OSC Group Leads are 60-minute augmentation positions and have no assigned tasks for any of the events reviewed by the staffing assessment. Therefore, TMI concludes that this change will have no impact on the on-shift staffing assessment.

E. Impact of Proposed Changes on State Emergency Plan Exelon reviewed the proposed changes to the TMI Emergency Plan with representatives from the Pennsylvania Emergency Management Agency (PEMA) and the Pennsylvania Bureau of Radiation Protection (BRP).

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 17 of 22 Based upon this preliminary review of the proposed changes, no objections to these changes were identified, and there is no indication, at this point, that these changes would adversely impact the ability of the Commonwealth of Pennsylvania to implement its Emergency Plan. Exelon recognizes that any final decisions regarding the potential impact on the Commonwealth's Plan and its implementation will be based upon PEMA's and BRP's review of the formal license amendment request once submitted to the NRC. Attachment 6 of this submittal provides additional information related to the Commonwealth's initial assessment of the proposed TMI on-shift ERO staffing changes.

Summary Based upon the evaluation provided above, and the impact of each proposed change on the applicable Major Functions and the on-shift staffing assessment (Attachment 4), Exelon concludes that the proposed changes will not impact the capability of the on-shift ERO to perform the required functions in a timely manner, consistent with the applicable regulatory requirements and Emergency Plan commitments.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met.

10 CFR 50.54(q) 10 CFR 50.54(q) establishes requirements that all holders of a nuclear power reactor operating license must follow and maintain in effect emergency plans which meet the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." 10 CFR 50.47 of 10 CFR, "Emergency plans," sets forth emergency plan requirements for nuclear power plant facilities.

10 CFR 50.47(b)

(b) The onsite and, except as provided in paragraph (d) of this section, offsite emergency response plans for nuclear power reactors must meet the following standards:

(1) Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 18 of 22 (2) On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

10 CFR 50, Appendix E Section IV.A.4, states in part that:

"The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

4. Identification, by position and function to be performed, of persons within the licensee organization who will be responsible for making offsite dose projections, and a description of how these projections will be made and the results transmitted to State and local authorities, NRC, and other appropriate governmental entities."

Section IV.A and new Section IV.A.9 of 10 CFR 50, Appendix E states, in part:

"The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. Specifically, the following shall be included:

9. By December 24, 2012, for nuclear power reactor licensees, a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan."

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," provides guidance and acceptance criteria to provide a basis for NRC licensees, State and local governments to develop radiological emergency plans and improve emergency preparedness.

Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," provides guidance related to emergency preparedness and specifically to making changes to emergency response plans.

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 19 of 22 NRC Regulatory Issue Summary (RIS) 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," which provides guidance to (1) clarify the meaning of a "decrease in effectiveness," as stated in 10 CFR 50.54(q); (2) clarify the process for evaluating proposed changes to emergency plans; (3) provide a method for evaluating proposed changes to emergency plans; and (4) provide clarifying guidance on the appropriate content and format of applications submitted to the NRC for approval prior to implementation.

NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," provides guidance for addressing emergency planning requirements for nuclear power plants. This guidance is based on changes to Emergency preparedness regulations 10 CFR 50.47 and 10 CFR 50 Appendix E, that were published in the Federal Register (FR) on November 23, 2011 (i.e., reference 76FR 72560). The guidance should be used by licensees and applicants for implementing changes to onsite EP programs based on the revised emergency preparedness requirements and by NRC for reviewing the adequacy of the revised onsite emergency preparedness programs.

In addition, Exelon also reviewed draft NUREG-0654, Revision 2 (NUREG-0654/FEMA-REP-1, Revision 2), "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated May 2015 and draft RIS 201X-XX, "License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation" (ML15338A291) in support of this submittal.

Exelon has evaluated the proposed changes against the applicable regulatory requirements and guidance criteria. The proposed Emergency Plan changes for TMI continue to assure that regulatory requirements and emergency planning standards associated with emergency response are met.

4.2 Precedent There is precedent within the Exelon fleet supporting the proposed change. The NRC issued Amendment No. 191 for Clinton Power Station (ML101900030) dated September 21, 2010, for approving a reduction in the number of on-shift RPTs, as well as the use of Operations personnel to perform the tasks assigned to Maintenance under the on-shift "Repair and Corrective Actions" task.

In addition, Exelons Braidwood, Byron, Dresden, LaSalle, and Quad Cities stations perform all of the on-shift RP functions with a staff of two (2) RPTs, and assign the on-shift "Repair and Corrective Action" function as a collateral duty for members of the on-shift minimum staff.

4.3 No Significant Hazards Consideration License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 20 of 22 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to the following licenses:

DPR-50 and DPR Three Mile Island Nuclear Station, Units 1 and 2, respectively Exelon also maintains the emergency planning responsibilities for TMI, Unit 2, which is owned by First Energy Corporation, through a service agreement.

The requested amendments to the licenses support changes to the TMI Emergency Plan based upon completion of a supporting evaluation of onsite Emergency Response Organization (ERO) staffing that determined that one (1) Radiation Protection Technician (RPT) and two (2)

Maintenance technicians are no longer necessary to support the "Major Functions and Tasks" assigned to the minimum on-shift ERO, and Exelon proposes to remove these positions from the TMI Emergency Plan. In addition, this evaluation has concluded that personnel with Maintenance-specific qualifications are not required to perform these Functions and Tasks.

Finally, Exelon has also concluded that the collateral duty of the Operations Support Center (OSC) Director is not required prior to the initial staffing and activation of the OSC.

The proposed changes have been reviewed considering the applicable requirements of 10 CFR 50.47, 10 CFR 50 Appendix E, and other applicable NRC guidance criteria. Exelon has evaluated the proposed changes to the TMI Emergency Plan and determined that the changes do not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92, "Issuance of amendment," is provided below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes to the TMI Emergency Plan do not increase the probability or consequences of an accident. The proposed changes do not impact the function of plant Structures, Systems, or Components (SSCs). The proposed changes do not affect accident initiators or accident precursors, nor do the changes alter design assumptions.

The proposed changes do not alter or prevent the ability of the onsite ERO to perform their intended functions to mitigate the consequences of an accident or event. The proposed changes remove onsite ERO positions no longer credited or considered necessary in support of Emergency Plan implementation.

Therefore, the proposed changes to the Emergency Plan do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 21 of 22 The proposed changes have no impact on the design, function, or operation of any plant SSCs. The proposed changes do not affect plant equipment or accident analyses. The proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed changes do not introduce failure modes that could result in a new accident, and the proposed changes do not alter assumptions made in the safety analysis. The proposed changes remove onsite ERO positions no longer credited or considered necessary in support of Emergency Plan implementation.

Therefore, the proposed changes to the Emergency Plan do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public.

The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes. Margins of safety are unaffected by the proposed changes to the ERO minimum on-shift staffing.

The proposed changes are associated with the Emergency Plan staffing and do not impact operation of the plant or its response to transients or accidents. The proposed changes do not affect the Technical Specifications. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by these proposed changes.

The proposed changes to the Emergency Plan will continue to provide the necessary onsite ERO response staff.

Therefore, the proposed changes to the Emergency Plan do not involve a significant reduction in a margin of safety.

4.4 Conclusions In conclusion, based on the considerations discussed above: 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, 2) such activities will be conducted in compliance with the Commission's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

License Amendment Request On-Shift Emergency Response Staffing Docket Nos. 50-289 and 50-320 Page 22 of 22

5.0 ENVIRONMENTAL CONSIDERATION

The proposed changes are limited to changes to the TMI Emergency Plan. Exelon has determined that the proposed changes would not revise a requirement with respect to installation or use of a facility or component located within the restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, or (ii) authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) result in a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for a categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, Exelon concludes that pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants," Revision 0, November 2011.

6.2 NEI 10-05, Revision 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," dated June 2011.

6.3.

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, Washington, DC, November 1980.

6.4 10 CFR 50.47, "Emergency plans."

6.5 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities."

6.6 Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011.

6.7 Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," dated November 2011.

ATTACHMENT 2 Emergency Plan Mark-up Pages - Three Mile Island Nuclear Station Emergency Plan Annex EP-AA-1009 Pages TMI 2-2 TMI 2-5 TMI 2-6 TMI 2-7 TMI 5-8

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR 2.1.4 OSC Director An on-shift Maintenance Team Leader shall fill the Operations Support Center (OSC)

Director position until relieved by the ERO OSC Director. This position reports to the Shift Emergency Director until control of the OSC is transferred to the TSC.

2.1.54 The following functions will be performed by trained members of the normal shift complement:

1. Firefighting Specific personnel on each shift (Site Fire Brigade) are trained in firefighting to ensure such capability will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. The Fire Brigade, under the direction of the Fire Brigade Team Leader or another individual designated by him, shall respond to all confirmed fire alarms or as directed by the Control Room and report to the location of the fire with assigned equipment. During the normal work week, additional qualified firefighting personnel will, as necessary, be obtained from the normal on-site organization. Assistance will be requested from local fire departments through the county dispatcher / appropriate local dispatch system.

2. First Aid and Search and Rescue Medical emergencies and search and rescue operations will be the responsibility of the First Aid and Search and Rescue Teams. Specific personnel on each shift are trained in first aid techniques to ensure such assistance will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Assistance will be requested from outside medical support personnel or organizations as deemed necessary.

TMI 2-2

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR TABLE TMI 2-1: Minimum Staffing Requirements for TMI Station Functional Area Major Tasks Emergency Positions Minimum Staffing Full Augmentation Shift Size (a)60 Minute Augmentation Other On-Call

1. Plant Operations/Safe Shutdown and Assessment of Operational Aspects Control Room Staff Shift Manager Control Room Supervisor Control Reactor Operator Auxiliary Operator 1

1 2

2

2. Emergency Direction and Control Command and Control /

Emergency Operations Shift Emergency Director (CR)

Station Emergency Director (TSC)

Corporate Emergency Director (EOF) 1(b) 1 1

3. Notification &

Communication Emergency Communications Plant Shift Personnel (CR)

TSC Director (TSC)

EOF Director (EOF)

State/Local Communicator ENS Communicator HPN Communicator 1

1 1

1 (EOF) 1 (TSC) 1 (EOF) 1 (TSC) 1 (EOF) 1 (TSC)

Plant Status Operations Communicator (CR/TSC) 2 In-Plant Team Control Damage Control Comm. (CR/TSC/OSC) 3 Technical Activities Technical Communicator (TSC) 1 Governmental EOC Communicator (EOF)

State EOC Liaison (d)

(PEMA)

Regulatory Liaison (EOF) 1 1

1

4. Radiological Accident Assessment and Support of Operational Accident Assessment Offsite Dose Assessment RP Personnel (CR)

Dose Assessment Coordinator (EOF)

Dose Assessor (EOF)

Radiation Controls Coordinator (TSC) 1 1

1 1

Offsite Surveys Environmental Coordinator (EOF)

Field Team Communicator (EOF)

Field Team Personnel (h) 1 4

1 (c)

Onsite Surveys Field Team Personnel (h) 2 (c)

In-plant Surveys RP Technicians or equivalent 21 (c)

Chemistry Chemistry Personnel 1

1 (c)

RP Supervisory Radiation Protection Manager (TSC)

Radiation Protection Manager (EOF) 1 1

TMI 2-5

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR TABLE TMI 2-1: Minimum Staffing Requirements for TMI Station (Contd)

Functional Area Major Tasks Emergency Positions Minimum Staffing Full Augmentation Shift Size (a)60 Minute Augmentation Other On-Call

5. Plant System Engineering, Repair and Corrective Actions Technical Support STA / Incident Assessor(i)

(CR)

Technical Manager (TSC)

Core/Thermal Hydraulics Engineer(TSC)

Mechanical Engineer (TSC)

Electrical Engineer (TSC)

SAMG Decision Maker (TSC)

SAMG Evaluator (TSC)

Operations Manager (TSC)

Radiation Controls Engineer (TSC) 1 1

1 1

1 1(b) 2(b) 1 1

Repair and Corrective Actions(k)

Mechanical Maintenance (l) (OSC)

Electrical Maintenance / I&C (l)

(OSC)

Maintenance Manager (TSC)

OSC Director (OSC)

Assistant OSC Director (OSC)

OPs Lead & Support Personnel (OSC) 1/2(b) 1/2(b) 1(b) 1 1

(c)

(c) 1 (c)

Accident Analysis Technical Support Manager (EOF)

Operations Advisor (EOF)

Operations Assistant (EOF)

Technical Advisor (EOF) 1 1

1 1

6. In-Plant Protective Actions Radiation Protection RP Technicians, or equivalent 2(b) 4 (c)

7. Fire Fighting Fire Brigade(e) 6

8. First Aid and Rescue Operations Plant Personnel 2(b)

(c)

9. Site Access Control and Personnel Accountability Security & Accountability Security Team Personnel Security Coordinator(q)

(TSC/ EOF)

(f)

(f) 2

10. Resource Allocation and Administration Logistics / Administration Logistics Manager (EOF)

Logistics Coordinator (TSC) 1 1

Administrative Coordinator (EOF)

Clerical Staff (TSC/OSC/EOF)

Events Recorder (EOF) 1 (c) 1 Computer Specialist (EOF) 1 TMI 2-6

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR TABLE TMI 2-1: Minimum Staffing Requirements for TMI Station (Contd)

Functional Area Major Tasks Emergency Positions Minimum Staffing Full Augmentation Shift Size (a)60 Minute Augmentation (g)Other On-Call

11. Public Information Media Interface Corporate Spokesperson (JIC)

Rad Protection Spokesperson (JIC)

Technical Spokesperson (JIC) 1 1

1 Information Development Public Information Director (JIC)

News Writer (JIC) 1 1

Media Monitoring and Rumor Control Media Monitoring Staff (JIC)

Rumor Control Staff (JIC(

(c)

(c)

Facility Operation and Control JIC Director (JIC)

JIC Coordinator (JIC)

Administrative Coordinator (JIC)

Events Recorder (JIC)

Clerical Support (JIC)

Access Control (JIC) 1 1

1 1

(c) 1 TOTAL (Non-Collateral):

20 17 30 3

34+

Legend:

(a) Response time is based on optimum travel conditions.

(b) May be provided by personnel assigned other functions. Personnel can fulfill multiple functions.

(c) Personnel numbers depend on the type and extent of the emergency.

(d) Staffing of the County EOC Liaison position is not required based on agreements with offsite agencies; however, every effort will be made to dispatch an Exelon Nuclear representative upon request from County EOC Director.

(e) Fire Brigade per FSAR / TRM, as applicable. Includes one NSO for oversight in addition to the 5 Fire Brigade members per TMI Fire Plan.

(f) Function performed by on-shift security personnel.

(g) The following Emergency Public Information Organization personnel will be designated minimum staffing (on-call) positions, but are not subject to the 60-minute response time requirement: Corporate Spokesperson, Public Information Director and JIC Director.

(h) Each Field Monitoring Team consists of a qualified Lead and Driver, trained in plume monitoring and air sample collection, as appropriate to designated task.

Qualified on-shift personnel may also be mobilized, if required based on event, to support initial field monitoring requirements.

(i) Refer to Section 2.1.3 for description of on-shift STA/Incident Assessor staffing requirements.

(j) TSC Security Coordinator position will be staffed by TMI Security personnel. The EOF Security Coordinator position will be staffed by Corporate personnel.

(k) Must include one Senior Maintenance Technician on-shift.

(l) This function shall be one dedicated maintenance technician with two additional technicians that can be filled by personnel assigned other functions (i.e., Fire Brigade) one of which may be a non-licensed operator.

TMI 2-7

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR 5.3.1 First Aid and Medical Equipment A first aid facility is designed to support a wide range of immediate care requirements ranging from simple first aid to procedures requiring a physician.

Small kits placed throughout the plant provide the most readily available first aid. These kits contain items typically needed to care for minor injuries. Typical contents can be referenced in Table TMI 5-1. The next level of first aid equipment is found at first aid stations. The medical staff can also provide Advanced Life Support and routine trauma care.

5.3.2 Damage Control Equipment The TMI plant site is extensively equipped to conduct preventive maintenance and repairs on mechanical, structural, electrical, and instrumentation and controls equipment found in the plant. Operational policy requires that a minimum maintenance crew be assigned to the onsite shift organization at all times. Each individual assigned to the maintenance crew is qualified and certified to perform the tasks associated with his craft in the working environment of a nuclear plant.

In addition to the equipment and materials required for normal maintenance, other items are available to handle extraordinary maintenance jobs that might arise in damage control. Selection of damage control equipment inventory is based upon (a) mitigating the consequences of flooding, (b) personnel rescue, (c) checking the uncontrolled flow of fluids from process systems, and (d) elimination of electrical hazards. Typical equipment available for damage control can be found in Table TMI 5-1.

5.3.3 Radiation Protection Equipment The TMI plant site maintains an inventory of protective clothing, respiratory equipment, survey instruments and supplies to provide adequate contamination control for all personnel expected to be onsite who might be affected in the event of an emergency.

The supplies are maintained, updated, inventoried and calibrated, as appropriate, on a regular basis in accordance with applicable procedures. Storage locations of emergency supplies can be found in the site implementing documents. Typical equipment available can be found in Table TMI 5-1.

TMI 5-8

ATTACHMENT 3 Re-typed Emergency Plan Pages - Three Mile Island Nuclear Station Emergency Plan Annex EP-AA-1009 Pages TMI 2-2 TMI 2-5 TMI 2-6 TMI 2-7 TMI 5-8

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR 2.1.4 The following functions will be performed by trained members of the normal shift complement:

1. Firefighting Specific personnel on each shift (Site Fire Brigade) are trained in firefighting to ensure such capability will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

The Fire Brigade, under the direction of the Fire Brigade Team Leader or another individual designated by him, shall respond to all confirmed fire alarms or as directed by the Control Room and report to the location of the fire with assigned equipment. During the normal work week, additional qualified firefighting personnel will, as necessary, be obtained from the normal on-site organization. Assistance will be requested from local fire departments through the county dispatcher /

appropriate local dispatch system.

2. First Aid and Search and Rescue Medical emergencies and search and rescue operations will be the responsibility of the First Aid and Search and Rescue Teams. Specific personnel on each shift are trained in first aid techniques to ensure such assistance will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Assistance will be requested from outside medical support personnel or organizations as deemed necessary.

TMI 2-2

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR TABLE TMI 2-1: Minimum Staffing Requirements for TMI Station Functional Area Major Tasks Emergency Positions Minimum Staffing Full Augmentation Shift Size (a)60 Minute Augmentation Other On-Call

1. Plant Operations/Safe Shutdown and Assessment of Operational Aspects Control Room Staff Shift Manager Control Room Supervisor Control Reactor Operator Auxiliary Operator 1

1 2

2

2. Emergency Direction and Control Command and Control /

Emergency Operations Shift Emergency Director (CR)

Station Emergency Director (TSC)

Corporate Emergency Director (EOF) 1(b) 1 1

3. Notification &

Communication Emergency Communications Plant Shift Personnel (CR)

TSC Director (TSC)

EOF Director (EOF)

State/Local Communicator ENS Communicator HPN Communicator 1

1 1

1 (EOF) 1 (TSC) 1 (EOF) 1 (TSC) 1 (EOF) 1 (TSC)

Plant Status Operations Communicator (CR/TSC) 2 In-Plant Team Control Damage Control Comm. (CR/TSC/OSC) 3 Technical Activities Technical Communicator (TSC) 1 Governmental EOC Communicator (EOF)

State EOC Liaison (d)

(PEMA)

Regulatory Liaison (EOF) 1 1

1

4. Radiological Accident Assessment and Support of Operational Accident Assessment Offsite Dose Assessment RP Personnel (CR)

Dose Assessment Coordinator (EOF)

Dose Assessor (EOF)

Radiation Controls Coordinator (TSC) 1 1

1 1

Offsite Surveys Environmental Coordinator (EOF)

Field Team Communicator (EOF)

Field Team Personnel (h) 1 4

1 (c)

Onsite Surveys Field Team Personnel (h) 2 (c)

In-plant Surveys RP Technicians or equivalent 1

(c)

Chemistry Chemistry Personnel 1

1 (c)

RP Supervisory Radiation Protection Manager (TSC)

Radiation Protection Manager (EOF) 1 1

TMI 2-5

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR TABLE TMI 2-1: Minimum Staffing Requirements for TMI Station (Contd)

Functional Area Major Tasks Emergency Positions Minimum Staffing Full Augmentation Shift Size (a)60 Minute Augmentation Other On-Call

5. Plant System Engineering, Repair and Corrective Actions Technical Support STA / Incident Assessor(i)

(CR)

Technical Manager (TSC)

Core/Thermal Hydraulics Engineer(TSC)

Mechanical Engineer (TSC)

Electrical Engineer (TSC)

SAMG Decision Maker (TSC)

SAMG Evaluator (TSC)

Operations Manager (TSC)

Radiation Controls Engineer (TSC) 1 1

1 1

1 1(b) 2(b) 1 1

Repair and Corrective Actions Mechanical Maintenance (OSC)

Electrical Maintenance / I&C (OSC)

Maintenance Manager (TSC)

OSC Director (OSC)

Assistant OSC Director (OSC)

OPs Lead & Support Personnel (OSC) 2(b) 2(b) 1 1

(c)

(c) 1 (c)

Accident Analysis Technical Support Manager (EOF)

Operations Advisor (EOF)

Operations Assistant (EOF)

Technical Advisor (EOF) 1 1

1 1

6. In-Plant Protective Actions Radiation Protection RP Technicians, or equivalent 2(b) 4 (c)

7. Fire Fighting Fire Brigade(e) 6

8. First Aid and Rescue Operations Plant Personnel 2(b)

(c)

9. Site Access Control and Personnel Accountability Security & Accountability Security Team Personnel Security Coordinator(q)

(TSC/ EOF)

(f)

(f) 2

10. Resource Allocation and Administration Logistics / Administration Logistics Manager (EOF)

Logistics Coordinator (TSC) 1 1

Administrative Coordinator (EOF)

Clerical Staff (TSC/OSC/EOF)

Events Recorder (EOF) 1 (c) 1 Computer Specialist (EOF) 1 TMI 2-6

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR TABLE TMI 2-1: Minimum Staffing Requirements for TMI Station (Contd)

Functional Area Major Tasks Emergency Positions Minimum Staffing Full Augmentation Shift Size (a)60 Minute Augmentation (g)Other On-Call

11. Public Information Media Interface Corporate Spokesperson (JIC)

Rad Protection Spokesperson (JIC)

Technical Spokesperson (JIC) 1 1

1 Information Development Public Information Director (JIC)

News Writer (JIC) 1 1

Media Monitoring and Rumor Control Media Monitoring Staff (JIC)

Rumor Control Staff (JIC(

(c)

(c)

Facility Operation and Control JIC Director (JIC)

JIC Coordinator (JIC)

Administrative Coordinator (JIC)

Events Recorder (JIC)

Clerical Support (JIC)

Access Control (JIC) 1 1

1 1

(c) 1 TOTAL (Non-Collateral):

17 30 3

34+

Legend:

(a) Response time is based on optimum travel conditions.

(b) May be provided by personnel assigned other functions. Personnel can fulfill multiple functions.

(c) Personnel numbers depend on the type and extent of the emergency.

(d) Staffing of the County EOC Liaison position is not required based on agreements with offsite agencies; however, every effort will be made to dispatch an Exelon Nuclear representative upon request from County EOC Director.

(e) Fire Brigade per FSAR / TRM, as applicable. Includes one NSO for oversight in addition to the 5 Fire Brigade members per TMI Fire Plan.

(f) Function performed by on-shift security personnel.

(g) The following Emergency Public Information Organization personnel will be designated minimum staffing (on-call) positions, but are not subject to the 60-minute response time requirement: Corporate Spokesperson, Public Information Director and JIC Director.

(h) Each Field Monitoring Team consists of a qualified Lead and Driver, trained in plume monitoring and air sample collection, as appropriate to designated task.

Qualified on-shift personnel may also be mobilized, if required based on event, to support initial field monitoring requirements.

(i) Refer to Section 2.1.3 for description of on-shift STA/Incident Assessor staffing requirements.

(j) TSC Security Coordinator position will be staffed by TMI Security personnel. The EOF Security Coordinator position will be staffed by Corporate personnel.

TMI 2-7

THREE MILE ISLAND STATION ANNEX EXELON NUCLEAR 5.3.1 First Aid and Medical Equipment A first aid facility is designed to support a wide range of immediate care requirements ranging from simple first aid to procedures requiring a physician.

Small kits placed throughout the plant provide the most readily available first aid. These kits contain items typically needed to care for minor injuries. Typical contents can be referenced in Table TMI 5-1. The next level of first aid equipment is found at first aid stations.

The medical staff can also provide Advanced Life Support and routine trauma care.

5.3.2 Damage Control Equipment The TMI plant site is extensively equipped to conduct preventive maintenance and repairs on mechanical, structural, electrical, and instrumentation and controls equipment found in the plant. In addition to the equipment and materials required for normal maintenance, other items are available to handle extraordinary maintenance jobs that might arise in damage control. Selection of damage control equipment inventory is based upon (a) mitigating the consequences of flooding, (b) personnel rescue, (c) checking the uncontrolled flow of fluids from process systems, and (d) elimination of electrical hazards. Typical equipment available for damage control can be found in Table TMI 5-1.

5.3.3 Radiation Protection Equipment The TMI plant site maintains an inventory of protective clothing, respiratory equipment, survey instruments and supplies to provide adequate contamination control for all personnel expected to be onsite who might be affected in the event of an emergency.

The supplies are maintained, updated, inventoried and calibrated, as appropriate, on a regular basis in accordance with applicable procedures. Storage locations of emergency supplies can be found in the site implementing documents. Typical equipment available can be found in Table TMI 5-1.

TMI 5-8

ATTACHMENT 4 EP-AA-1009, Addendum 1, Three Mile Island On-shift Staffing Technical Basis

EP-AA-1009 Addendum 1 Revision 2 THREE MILE ISLAND STATION ON-SHIFT STAFFING TECHNICAL BASIS

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear TABLE OF CONTENTS

1.0 INTRODUCTION

...................................................................................................... 2

SUMMARY

...................................................................................... 2 2.1.

Emergency Plan Minimum Staffing................................................................. 3 3.0 ANALYSIS PROCESS.............................................................................................. 5 4.0 SCENARIO SELECTION AND ATTRIBUTES.......................................................... 6 4.1.

Severe Accident Mitigation Guidelines (SAMG).............................................. 7 4.2.

Station Blackout.............................................................................................. 7 5.0 ACCIDENT SCENARIOS......................................................................................... 8 5.1. DBAs not evaluated under the Staffing Assessment....................................... 9 6.0 GENERAL ASSUMPTIONS AND LIMITATIONS..................................................... 10 6.1.

RP and Chemistry:......................................................................................... 1 O 6.2.

Repair and Corrective Action:........................................................................ 1 O 6.3.

Rescue Operations and First Aid:................................................................... 11 6.4.

1 OCFR50.54(hh) Aircraft Threat..................................................................... 11 6.5.

Site Specific Event Notifications..................................................................... 12 6.6.

ERO Response Time - Evaluation of 90 Minutes........................................... 12 6.7.

Emergency Plan Legacy Staffing Functions................................................... 12 6.8.

NEI 10-05 General Assumptions.................................................................... 15

7.0 CONCLUSION

......................................................................................................... 17 8.0 ATTACHMENTS...................................................................................................... 18

9.0 REFERENCES

........................................................................................................ 19 July 2016 Page 1 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear

1.0 INTRODUCTION

An On-Shift Staffing Analysis (OSA) was conducted at Three Mile Island (TMI). This OSA satisfies the requirement of Section IV.A.9 of 1 O CFR 50, Appendix E, which states that nuclear power reactor licensees shall perform "a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan." A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" and EP-AA-130, "10 CFR 50, On-Shift Staffing Assessment". This analysis examined the ability of the minimum staff listed in Table TMI 2-1 of the Three Mile Island Station Emergency Plan Annex (EP-AA-1009, Rev 19) to perform all of the actions necessary to respond to each of the event scenarios specified in NEI 10-05, as well as implement all of the required actions required by the Emergency Plan. The analysis considered both Unit 1 and the permanently shutdown Unit 2.

This analysis was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Radiation Protection and Emergency Preparedness (EP) departments. Additionally, personnel from Engineering, Security, and Chemistry provided input to the analysis.

SUMMARY

The OSA team determined that an on-shift staff of twenty (20) is required to support all of the Emergency Plan functions for the scenarios evaluated in the staffing assessment. The on-shift staff consists of individuals necessary to support each of the following Emergency Plan Functional Areas:

Plant Operations & Safe Shutdown Fire Fighting Radiation Protection & Chemistry Emergency Plan Implementation July 2016 Page 2 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear NEI 10-05 states it is acceptable for certain functions to be assigned to personnel already assigned other functions/tasks. These include Repair and Corrective Action, Rescue Operations and First Aid.

The On-Shift Staffing Assessment identified gaps between the technical bases identified through this assessment and the current staffing practices. These gaps were identified and corrected using the station's Corrective Action Program (TMI IR 1425128)., Three Mile Island On-Shift Staff provides the on-shift assessment results presented in the NUREG 0654, Table B-1 format. Attachment 3, NEI 10-05 Appendix B Staffing Tables for Three Mile Island Station contains the final NEI 10-05 Assessment tables providing the results of each scenario assessment.

2.1.

Emergency Plan Minimum Staffing Per 10 CFR 50.54 (q)(1)(iii), Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV of appendix E to this part and, for nuclear power reactor licensees, the planning standards of§ 50.47(b).

The following table indicates the result of the NEI 10-05 staffing analysis of on-shift personnel to perform the required emergency planning functions and the licensing basis requirement for each on-shift position.

July 2016 Page 3 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Table 1 - Three Mile Island On-Shift Staff Position Licensing Basis Reqt Shift Manager I 10 CFR 50.54(m)

Emergency Director Unit Supv (SRO) 10 CFR 50.54(m)

STA (SRO)

NEI 0654 R0#1 (SSD) 10 CFR 50.54(m)

Fire Safe Shutdown RO #2 (SSD) 10 CFR 50.54(m)

Fire Safe Shutdown R0#3 Fire Protection Program (Support FB)

EO #1 (SSD)

Safe Shutdown EO #2 (SSD)

Safe Shutdown Fire Brigade Leader Fire Protection Program Fire Brigade #1 Fire Protection Program Fire Brigade #2 Fire Protection Program Fire Brigade #3 Fire Protection Program Fire Brigade #4 Fire Protection Program RP Tech #1 Emergency Plan RP Tech #2 Emergency Plan RP Tech #3 Emergency Plan Chem Tech Emergency Plan EP Communicator Emergency Plan Mechanical Maintenance Emergency Plan l&C/Elec Maintenance Emergency Plan July 2016 Page 4 of 98 E-Plan Staffing Function Area Assessment Results Plant Operations 1

& Safe Shutdown Plant Operations 1

& Safe Shutdown Plant System 1

Enoineerino Plant Operations 1

& Safe Shutdown Plant Operations 1

& Safe Shutdown Plant Operations 1

& Safe Shutdown Plant Operations 1

& Safe Shutdown Plant Operations 1

& Safe Shutdown Fire Fighting 1

Fire Fighting 1

Fire Fighting 1

Fire Fighting 1

Fire Fighting 1

Radiological 1

Assessment Radiological 1

Assessment Radiological 1

Assessment Radiological 1

Assessment Notification and 1

Communication Repair& CA 1

Repair& CA 1

TOTAL 20 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear 3.0 ANALYSIS PROCESS This analysis was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Radiation Protection and Emergency Preparedness (EP) departments. Additionally, personnel from Chemistry, Engineering and Security provided input to the analysis.

The emergency response to each event was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures.

Each scenario was reviewed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for Emergency Plan implementation as described in the Emergency Plan Annex, EP-AA-1009, Table 2-1, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, the team assessed timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements.

The results of the analysis for each of the scenarios are included in Attachment 3, NEI 10-05 Appendix B Staffing Tables for Three Mile Island Station.

Note that NSIR DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants" states that only OBA accidents "which would result in an emergency declaration" should be evaluated in the staffing assessment. Each of TMl's DBA's were evaluated and classified according to its UFSAR Chapter 14 description. If the accident description alone did not result in a classification, the projected accident dose rate at the site boundary was utilized to determine if an EAL threshold would be exceeded within the first 90 minutes using the Abnormal Rad Level EAL thresholds. In cases where several projected dose rates were provided or July 2016 Page 5 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear release data was not detailed significantly to determine an EAL, the assessment used the radiological consequences associated with the realistic case in accordance with NEI 10-05.

4.0 SCENARIO SELECTION AND ATTRIBUTES The OSA scenarios were chosen using the guidance of NEI 10-05 and NSIR/DPR-ISG-01. The evaluation considered the station Design Basis Accidents along with 4 additional scenarios specified by the guidance documents. The scenarios consisted of:

Design Basis Threat (DBT) ground assault Aircraft Probable Threat Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire)

Large Break Loss of Coolant Accident, (LOCA)

Station Blackout, (SBO)

Main Steam Line (MSL) Break Accident Steam Generator Tube Rupture Control Rod ejection accident Fuel Handling Accident Waste Gas Tank Rupture Fire in ESAS Room Feedwater Line Break Accident Reactor Coolant Pump Shaft Seizure The results of the analysis for each of the scenarios are included in Attachment 2, NEI 10-05 Scenario Tables. The selection of OBA accidents for inclusion in this assessment was based in part on the guidance contained in NSIR DPR-ISG-01 which states that only OBA accidents "which would result in an emergency declaration" should be evaluated in the staffing assessment. Each of TM l's DBAs were evaluated and classified according to its UFSAR description. Additionally, the projected accident dose rate at the site boundary was considered in classification. In cases where several projected dose rates were provided, the assessment used the July 2016 Page 6 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear radiological consequences associated with the realistic case in accordance with NEI 10-05.

Each scenario was assessed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for Emergency Plan implementation as described in the Emergency Plan Annex, EP-AA-1009, Table 2-1, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, the team considered task prioritization and duration to ensure that they could be performed by the individual in series within any specified time requirements.

4.1.

Severe Accident Mitigation Guidelines (SAMG)

NEI 10-05 guidance required one scenario to evaluate implementation of the Severe Accident Mitigation Guidelines. The Large Break Loss of Coolant Accident was chosen for this purpose at TMI. The analysis of the ability to implement severe accident management guidelines focused on the reasonably expected initial mitigation actions that would be performed by on-shift personnel other than licensed and non-licensed operators consistent with NEI 10-05 guidance.

4.2.

Station Blackout TMI elected to evaluate a Station Blackout as part of this analysis as recommended in NEI 10-05. It was assumed that designated station equipment (e.g., blackout diesel generators, SBO dedicated source) were available as credited in the Station Blackout Analysis. This assumption is consistent with the NEI 10-05 position that unplanned/unexpected actions that address equipment failures are contingent in nature and cannot be specified in advance.

July 2016 Page 7 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear 5.0 ACCIDENT SCENARIOS Except as noted, all scenarios assume the plant is operating with minimum staff at full power and no abnormal conditions exist.

Design Basis Threat-A HOSTILE FORCE breaches the Protected Area fence, but is neutralized with no adverse consequences to plant safety.

Aircraft Probable Threat - Notification is received from the NRC that a probable aircraft threat exists(> 5 minutes, < 30 minutes).

Fire Requiring Control Room Evacuation - A fire occurs in the Control Room requiring the room to be evacuated and Remote Shutdown procedures to be implemented.

Design Basis Loss of Coolant Accident - A OBA LOCA occurs with all automatic actions occurring as designed and expected. Concurrent with the LOCA, the unit experiences a radiological release. The classification for this scenario is stipulated to be a General Emergency per NEI 10-05 guidance. After the notifications are complete, it is assumed that the SAMGs are required to be implemented. A review of the SAMGs associated with the initial site-specific Candidate High Level Actions concluded that no actions would require on-shift personnel other than Licensed and Non-Licensed Operators.

Station Blackout - A loss of all offsite AC power occurs coincident with the trip of the unit. Both Unit 1 emergency diesel generators fail to start. Operator successfully starts SBO diesel generator.

Steam Generator Tube Rupture - Double-ended Steam Generator Tube Rupture occurs (leak exceeds charging pump capacities). Unit TRIP occurs on Low Reactor Coolant System Pressure.

Control Rod Ejection Accident - The most reactive control rod assembly is suddenly and violently ejected from reactor vessel from the rod insertion limit position. Reactor Protection System actuates a reactor trip and an automatic July 2016 Page 8 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Safety Injection. Containment and RCS indications are consistent with a loss of coolant accident.

Waste Gas Tank Rupture - Rupture of a waste gas tank resulting in the release of its radioactive contents to the Auxiliary Building environment.

Fire in the ESAS Room - A fire in the ESAS Room occurs requiring the shift to implement contingency procedures to ensure plant control is maintained while simultaneously fighting the fire. This is the most manpower limiting Appendix R fire.

5.1.

DBAs not evaluated under the Staffing Assessment Main Steam Line Break - The postulated accident is a sudden, complete severance of one main steam line outside containment with subsequent release of steam and water containing fission products to the intermediate building and the turbine building. This OBA would not result in classification from plant conditions or resultant dose.

Feedwater Line Break - The postulated accident is a sudden, circumferential break downstream of the outermost isolation valve. This OBA would not result in classification from plant conditions or resultant dose.

Reactor Coolant Pump Shaft Seizure - The postulated accident is indication of reactor coolant pump shaft seizure resulting in loss of the Reactor Coolant Pump.

This OBA would not result in classification from plant conditions or resultant dose.

Fuel Handling Dropped Fuel Assembly - The postulated event involves the drop of a fuel assembly on top of the reactor core, resulting in clad damage. NRC EPFAQ 2013-008 concluded this accident did not need to be evaluated under this analysis.

July 2016 Page 9 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear 6.0 GENERAL ASSUMPTIONS AND LIMITATIONS 6.1.

RP and Chemistry:

TMI utilized the analysis approach described by NEI 10-05 to identify all tasks assigned to on-shift radiation protection and chemistry technicians. Required tasks were plotted on a timeline considering task duration and priority. There were no overlapping times identified for TMI. It should be noted that there were no time critical activities identified in station procedures for the scenarios reviewed. Tasks would be identified and prioritized by the Emergency Director. Station procedure EP-AA-112-1 OO-F-01, Shift Emergency Director Checklist, contains a generic step requiring one RP technician to be assigned to support shift activities. This includes any access control or RP coverage tasks as identified in station procedures and documented in each staffing assessment scenario evaluation.

The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Abnormal Operating Procedures (AOP), Emergency Operating Procedures (EOP), and Emergency Implementing Procedures (EIP). Any additional tasks directed by the Technical Support Center (TSC), Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures were not reviewed.

6.2.

Repair and Corrective Action:

Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by dedicated shift personnel or qualified shift personnel assigned other functions/tasks. Repair and corrective action is defined as:

An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of tag out controls to complete.

In accordance with NEI 10-05 section 2.5, the staffing analysis included a review of the maintenance and corrective action tasks. These tasks are allowed to be performed by personnel having other EP functions. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

July 2016 Page 10 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Unplanned/unexpected actions that address equipment failures. These actions are contingent in nature and cannot be specified in advance.

Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

At TMI, the repair and corrective action tasks are performed by plant equipment operators and maintenance personnel. Equipment operators at TMI are qualified to install jumpers, lift & land leads, and other tasks as directed by the plant operating procedures. There were no tasks identified that would require performance by non-operations personnel.

6.3.

Rescue Operations and First Aid:

In accordance with NEI 10-05 section 2.6, the analysis also included a review of the Rescue Operations and First Aid Responses. These functions are also allowed to be performed by personnel assigned other EP functions. Rescue Operations and First Aid include the tasks of locating missing personnel, removing them from hazardous areas, if needed, and providing necessary initial medical treatment. Personnel performing initial medical treatment are trained to the level of Red Cross Basic First Aid. At TMI, these functions are performed by the Fire Brigade Incident Commander and a Radiation Protection Technician.

6.4.

1 OCFR50.54(hh) Aircraft Threat The analysis included a review of the implementation of the requirement to maintain continuous communications with the notification source during an aircraft threat in accordance with 1 OCFR50.54(hh) and Reg Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. This review identified that there are sufficient personnel on-shift to perform this action during the aircraft event. Specifically, a Reactor Operator, the Radiation Protection technicians and the Chemistry personnel were all available to fill this function.

July 2016 Page 11 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear 6.5.

Site Specific Event Notifications The requirements for additional corporate specific notifications were reviewed and identified. Exelon procedure OP-AA-106-101, "Significant Event Reporting" permits delegation of the Event Notifications to the Duty Station Manager or Corporate Nuclear Duty Officer (NDO). The initial notification to the Duty Station Manager constitutes a simple and brief communication in accordance with NEI 10-05 section 3.1.13 and does not require further assessment.

6.6.

ERO Response Time - Evaluation of 90 Minutes As stated in NEI 10-05, section 2.14, the staffing assessment methodology may be used to evaluate proposed changes to on-shift staffing levels or augmented ERO response times. The TMI staffing assessment evaluation utilized an ERO response time of 60 minutes. However, the assessment team reviewed the identified emergency response functions and actions through the first 90 minutes following the declaration.

It was determined the on-shift operations staff would have no additional actions or require additional staff in implementing actions to mitigate and stabilize the accident within the additional 30 minutes. Note that the analysis methodology did not require any assumptions of additional equipment failures to complicate the event.

Additionally, RP and Chemistry staff would be able to continue to support and prioritize activities during the additional 30 minutes until the augmented staff arrives.

This is indicated on Table 4 of the scenario assessments for RP and Chemistry. The Fire Brigade would continue to be available to support plant activities as required by the scenario.

6.7.

Emergency Plan Legacy Staffing Functions Repair and Corrective Action - Functional Area 5 was revised to both clarify the existing requirements for Repair and Corrective Action (R&CA) personnel and to identify and maintain the legacy application of these requirements. TMI Emergency Plan Annex Table 2-1 stipulates the following for R&CA:

July 2016 Page 12 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Maintenance/RadWaste<nl (OSC)

Electrical Maintenance / l&C <nl (OSC)

OSC Director 1 (f) I 3 1 (f) I 3 1

Exelon Nuclear Note (n) states in part, a total of six personnel, in addition to two (2) Auxiliary Operators listed under Control Room Staff, are available to support shift repair I corrective actions: Two (2) additional Auxiliary Operators; three (3) Maintenance personnel; and One (1) Senior Maintenance Technician....

Note (f) states that these positions can be filled by personnel assigned other functions.

The OSC Director position is filled by a Maintenance Supervisor, who also is the Fire Brigade Leader. For clarity, TMI has revised the annotation of the R&CA functions on Table 2-1.

Maintenance/RadWaste<nl (OSC)

Electrical Maintenance / l&C (nl (OSC)

OSC Director Note (a) states the position can be filled by personnel assigned other functions.

NU REG 0654 and NEI 10-05 discuss the R&CA functions as a collateral duty that can be performed by persons assigned other positions. However, in order to maintain the existing total number of on-shift staff at TMI, two of the positions are annotated without having the ability to perform concurrent functions. This was done to maintain the current staffing numbers at TMI such that there would not be a reduction in staff resulting from this assessment. This was not done as a result of any identified need to have dedicated Maintenance Techs as part of the assessment results.

The TMI Staffing Assessment results still maintain the legacy requirements for six (6)

Repair and Corrective Action persons plus an OSC Director, just as before.

However, four (4) of R&CA and the OSC director are now annotated as being filled by personnel assigned other functions. These positions were shared by members of the Fire Brigade. Historically, the Fire Brigade function did not contain the assigned July 2016 Page 13 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear number of personnel since these members were already accounted for under R&CA function. Following the guidance of NEI 10-05, it was decided to account for the specific number of Fire Brigade members under the Fire Brigade function instead of accounting for them under the R&CA function, and to annotate under the R&CA function that these positions can be assigned to personnel filling other functions.

This revision is appropriate because it continues to allow the same personnel to fill both the Fire Brigade and R&CA positions, as is the present practice, while preventing the Fire Brigade from being assigned concurrent duties such as Safe Shutdown, STA or EP Communicator. This revision had no impact on the total on-shift staffing numbers or the historical dedication of ERO personnel, but rather allowed the flexibility for the R&CA function to be a shared function, which is consistent with both NU REG 0654 and NEI 10-05.

Note that TMI exceeds the industry norm for personnel supporting the Repair and Corrective Action function. The revision to the Table 2-1 R&CA Function was intended to 1) provide additional clarity on appropriate utilization of on-shift personnel since the Fire Brigade numbers were added to Table 2-1, 2) maintain current station staffing levels, and 3) establish the basis that these R&CA persons had no actions or tasks in the Staffing Assessment.

Security Supervisor - The function of Security Supervisor was removed from Table 2-

1. The Security Supervisor is staffed per the requirements of the TMI Security Plan.

Deleting this position does not reduce the requirement to staff this position and the annotation is consistent with NU REG 0654. Note that the function of Accountability is still maintained on Table 2-1.

Shift Communicator - Section 2.1.2 of the TMI Emergency Plan annex describes the position of the Emergency Communicator. At TMI, Reactor Operators and Maintenance (l&C) personnel are both qualified as Shift Communicators. TMl's practice has been to have the flexibility to utilize either of these staff to perform the Shift Communicator function. The TMI table 2-1 is being revised to state this position is filled by Plant Personnel who is not assigned any other EP function. The annotation of which department performs this function is removed.

July 2016 Page 14 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Additionally, the Emergency Annex section 2.1 was revised to remove reference to specific departments filling the shift communicator function. The Staffing Assessment determined that one communicator is sufficient to fill this function as long as the communicator has no other concurrent EP responsibilities. The table reflects one person assigned to this position but does not alter or change the option to utilize other qualified personnel to perform the task if requested.

6.8.

NEI 10-05 General Assumptions

1.

Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task. As discussed in NEI 10-05, the evaluation was extended to 90 minutes to support future licensing actions.

2.

On-shift personnel complement was limited to the minimum required number and composition as described in the site emergency plan. If the plan commitments allow for different minimum staffing levels (e.g., a variance between a normal dayshift and a backshift), the staffing with the smallest total number of personnel was used for the analysis.

3.

Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.

4.

The event occurred during off-normal work hours where the ERO was offsite and all required minimum on-shift positions were filled.

5.

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

6.

On-shift staff had necessary Radiation Worker qualification to obtain normal dosimetry and enter the radiological control area (RCA) (but not locked high or very high radiation areas) without the aid of a RP technician.

July 2016 Page 15 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear

7.

Personnel assigned plant operations and SSD met the requirements and guidance (analyzed through other programs such as operator training) and were not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

8.

In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain safe shutdown was performed by a member of the on-shift staff.

9.

Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

10.

Individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.

11. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.

12. Communications, briefings, and peer checks are acceptable collateral duties.

13.

The Staffing Analysis specified the resources available to perform "Repair and Corrective Actions" and "Rescue Operations and First Aid" but these may be assigned as collateral duties to a designated on-shift responder.

14.

For assessment purposes, NRC notifications were treated as a continuous action per 10CFR50.72(c)(3) and 73.71(b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.

15.

Unless otherwise specified in NSIR/DPR-ISG-01, Interim Staff Guidance -

Emergency Planning for Nuclear Power Plants, or by the initial conditions of a OBA analysis, it was assumed that the unit was in Mode 1.

July 2016 Page 16 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear

16.

DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to prevent safe shutdown or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.

17.

The Staffing Analysis used OBA analysis assumptions, inputs, timing of events as documented in the UFSAR.

18.

In cases where a OBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began at the time of declaration of the initiating event.

19. Severe Accident Management Guideline (SAMG) - It is sufficient to simply assume that the accident progressed to conditions requiring a severe accident response; it did not include determining specific failures and the accident sequence.

20.

SAMG - The actions analyzed included those that implement the initial site-specific actions assuming the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent challenge to containment integrity.

7.0 CONCLUSION

The report documents the completion of the TMI On-Shift Staffing Assessment per NEI 10-05. The analysis concluded the following:

The results of the On-Shift Staffing Assessment concluded that 20 persons are required. The staffing required by EP-AA-1009, Table TMI 2-1 of the Emergency Plan Annex reflects the required staff to perform all of the EP and operational actions required to respond to each NEI 10-05 scenario in addition to legacy staff commitments currently identified in the Emergency Plan.

It is important to note that this assessment specifically addressed the ability of the Site minimum staffing to support required EP and Operations functions for the July 2016 Page 17 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear scenarios analyzed. Table 2-1 does not address functions or tasks that are outside of the procedures utilized in the evaluated scenarios. For example, additional personnel may be required on-shift to support some offsite functions unrelated to this assessment (e.g., routine switchyard, waste treatment plant, intake structure operations). Additional staffing may be required through station administrative procedures to accomplish these tasks. reflects the results of the staffing assessment as well as including the legacy staff commitments from the current Emergency Plan.

8.0 ATTACHMENTS 8.1, Three Mile Island On-Shift Staff 8.2, NEI 10-05 Appendix A Analyzed Events and Accidents 8.3, NEI 10-05 Appendix B Staffing Tables for Three Mile Island Station 8.4 A, Design Basis Threat (DBT) Ground Assault 8.5 B, Aircraft Probable Threat 8.6 C, Fire requiring evacuation of the Control Room and plant shutdown from remote location (Appendix R Fire)

8. 7 D, Large Break Loss of Coolant Accident (LOCA) 8.8 E, Station Blackout (SBO) 8.9 F, Steam Generator Tube Rupture 8.10 G, Control Rod Ejection 8.11 H, Deleted 8.12 1, Waste Gas Tank Rupture 8.13 J, Fire in ESAS Room July 2016 Page 18 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear

9.0 REFERENCES

9.1 NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Rev O 9.2 NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants.

9.3 EP-AA-1000, Exelon Nuclear Standardized Radiological Emergency Plan, Rev. 21 9.4 EP-AA-1009, Exelon Nuclear Radiological Emergency Plan Annex For Three Mile Island Station, Rev 19 July 2016 Page 19 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Three Mile Island On-Shift Staff Functional Area Major Tasks Emergency Positions Minimum

1.

2.

3.

4.

5.

6.

7.

8.

9.

Shift Size Plant Operations/Safe Control Room Staff Shift Manager Shutdown and Shift Supervisor Assessment of Nuclear Station Operator (bl Operational Aspects Non Licensed Operator(bJ Emergency Direction Command and Control Shift Emergency Director and Control Notification and Emergency Plant Shift Personnel Communication Communications Radiological Offsite Dose RP Personnel Assessment Assessment In-Plant Surveys RP Personnel Chemistry Chemistry Personnel Plant System Technical Support STA or Incident Assessor Engineering Repair and Corrective Repair and Corrective Mech Maintenance<e>

Action Actions<0 l&C/Electrical Maintenance<e>

OSC Director In Plant Protective Radiation Protection RP Personnel Actions Fire Fighting Fire Brigade1c1 First Aid and Rescue Plant Personnel Operations Site Access Control and Security and Security Team Personnel Personnel Accountability Accountability Total:

(a) May be provided by personnel assigned other functions.

(b) Safe Shutdown per Fire Protection Report or per Tech Specs.

(c) Fire Brigade per UFSAR/Technical Specifications, as applicable. Includes one NSO for oversight in addition to the 5 Fire Brigade members per TMI Fire Plan.

(d) Function performed by on-shift security personnel.

1 1

2 2

1\\8) 1 1

2 1

1 1 ( 2(a))

1 ( 2(a))

1<a) 21a1 6

2ta1 (d) 20 (e) This function shall be one dedicated maintenance technician with two additional technicians that can be filled by personnel assigned other functions (i.e., Fire Brigade) one of which may be a non-licensed operator.

(f)

One position is filled by a senior maintenance technician.

July 2016 Page 20of98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Analysis 1

2 3

4 5

July 2016 NEI 10-05 Appendix A Analyzed Events and Accidents Summary Description of Plant Reference ECL Analysis Event or Accident Mode Document(s)

Required?

Land and/or waterborne 1

Security Plan Site Area Yes HOSTILE ACTION directed Emergency against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

Aircraft Probable Threat (10 1

Security Plan Alert Yes CFR 50.54(hh)(1))

Fire requiring evacuation of the 1

Appendix R Fire Alert Yes Control Room and plant Analysis shutdown from remote location.

Large Break Loss of Coolant 1

UFSAR Section General Yes Accident. Assume General 14.2.2.3 & 14.2.2.5 Emergency Emergency declaration and a release that exceeds the EPA PAGs beyond the site boundary necessitates formation of Protective Action Recommendations.

This scenario will also require consideration of the on-shift staff to implement actions associated with the initial implementation of the severe accident management guidelines.

Station Blackout - Loss of all 1

UFSAR Section Alert Yes Off-Site and all On-site AC 8.5, 14.1.2.8 Power to emergency busses for 15 minutes or longer Page 21 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear 6

MSL Break Accident 3

7 Steam Generator Tube Rupture 1

8 Control Rod Ejection 1

9 Fuel Handling Accident 6

10 Waste Gas Tank Rupture 1

11 Fire in ESAS Room 1

12 Feedwater Line Break Accident 1

13 RCP Shaft Seizure 5

July 2016 Page 22of98 UFSAR Section None No 14.1.2.9 UFSAR Section General Yes 14.1.2.10 Emergency UFSAR Section Site Area Yes 14.2.2.2 Emergency UFSAR Section General No per 14.2.2.1 Emergency NRC EPFAQ 2013-008 UFSAR Section General Yes 14.2.2.6 Emergency Appendix R Fire Alert Yes Analysis UFSAR Section None No 14.2.2.9 UFSAR Section None No 14.1.2.6 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear July 2016 NEI 10-05 Appendix B Staffing Tables For Three Mile Island Station Page 23 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear A Design Basis Threat (DBT) Ground Assault

1.

Accident Summary:

A HOSTILE FORCE breaches the Protected Area fence, but is neutralized with no adverse consequences to plant safety.

2.

Accident Specific Assumptions:

Security response is per Station Security plan

3.

Procedures Reviewed for Accident Response Include:

July 2016 OP-TM-AOP-008, Security Threat/Intrusion OP-TM-EOP-001, Reactor Trip OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer OP-TM-108-111-1001, Site Inaccessibility Plan EP-AA-1009, Exelon Nuclear Radiological Emergency Plan Annex for Three Mile Island Station.

Page 24of98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis A TMI Exelon Nuclear This OSA is applicable to Analysis # 1 DBT as identified in Attachment 2.

TABLE 1 - On-shift Positions Emergency Augmentation Line On-shift Position Plan Elapsed Time Reference (min)

Shift Manager I Shift EP-AA-1009, N/A ED Table 2-1

1.

Control Room Supv EP-AA-1009, N/A

2.

(SRO)

Table 2-1

3.

STA (SRO)

EP-AA-1009, N/A Table 2-1 Unit Reactor Operator EP-AA-1009, N/A

4.

(RO #1)

Table 2-1 Aux Reactor Operator EP-AA-1009, N/A

5.

(RO #2)

Table 2-1

6.

R0#3 EP-AA-1009, N/A Table 2-1

7.

AO #1 (SSD)

EP-AA-1009, N/A Table 2-1

8.

AO #2 (SSD)

EP-AA-1009, N/A Table 2-1 Rad Pro Tech #1 EP-AA-1009, 60

9.

(RP #1)

Table 2-1 Rad Pro Tech #2 EP-AA-1009, 60

10.

(RP #2)

Table 2-1 Rad Pro Tech #3 EP-AA-1009, 60 11.

(RP #3)

Table 2-1

12.

Chem Tech EP-AA-1009, 60 Table 2-1 Fire Brigade Leader EP-AA-1009, N/A

13.

(Duty Maint Supv)

Table 2-1

14.

Fire Brigade (AO #3)

EP-AA-1009, N/A Table 2-1 July 2016 Page 25 of 98 Role in Unanalyzed Table#/Line#

Task?

T2 L1 No T5 L1 T5 L2 T5 L3 T5 L4 T5 L5 T5 L?

T5 LB T5 L10 T2 L2 No T2 L3 No T2 L4 No T2 L5 No No T2 L6 No T2 L?

No No No No No No No EP-AA-1009 Addendum 1 (Revision 2)

TMS Required?

No No No No No No No No No No No No No No

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Emergency Augmentation Role in Unanalyzed TMS Line On-shift Position Plan Elapsed Time Task?

Reference (min)

Table#/Line#

Required?

15.

Fire Brigade (AO #4)

EP-AA-1009, NIA No Table 2-1

16.

Fire Brigade (Maint #1)

EP-AA-1009, N/A No Table 2-1

17.

Fire Brigade (Maint #2)

EP-AA-1009, N/A No Table 2-1 Shift Communicator EP-AA-1009, NIA T5 L6 No

18.

Table 2-1 T5 L9 T5 L13

19.

Maintenance #4 EP-AA-1009, N/A No Table 2-1

20.

Maintenance #5 EP-AA-1009, N/A No Table 2-1 21.

Security EP-AA-1009, N/A No Table 2-1 Notes:

1. The Shift Communicator can be filled by any available qualified individual who is not assigned STA, Fire Brigade, SSD or Shift Emergency Director.

2. Augmentation Elapsed Time - Performance of a staffing analysis requires use of an assumed response (arrival) time for members of the augmented ERO. This time is the maximum acceptable number of minutes elapsed between an emergency declaration and the arrival of an ERO position-holder at a location necessary to relieve an on-shift ERO member. Per NEI 10-05, step 3.2.2.2.c, this is only required to be entered for RP and chemistry.

July 2016 Page 26 of 98 EP-AA-1009 Addendum 1 (Revision 2)

No No No No No No No

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear A TMI TABLE 2 - Plant Operations & Safe Shutdown Analysis #1 DST Applicable to site unit(s) # 1 One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if r bl app 1ca e Line Generic Title/Role On-Shift Position Task Performance Validation 1

Shift Manager Shift Manager Ops Training Program 2

Unit Supervisor Shift Supervisor Unit 1 Ops Training Program (SRO) 3 Shift Technical Advisor STA (SRO)

Ops Training Program 4

Reactor Operator #1 Unit Rx Operator (R0#1)

Ops Training Program 5

Reactor Operator #2 Aux Rx Operator (R0#2)

Ops Training Program 6

Auxiliary Operator #1 AO #1 (SSD)

Ops Training Program 7

Auxiliary Operator #2 AO #2 (SSD)

Ops Training Program 8

9 10 11 12 Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMG "f r bl SI app1ca e Line Generic Title/Role 13 Mechanic 14 Electrician 15 l&C Technician 16 Other July 2016 On-Shift Position n/a n/a n/a n/a Page 27of98 Task Performance Validation n/a n/a n/a n/a EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis A TMI TABLE 3 - Firefighting Line Performed By 1

n/a 2

n/a 3

n/a 4

n/a 5

n/a Notes

1. Fire Brigade not utilized for this scenario.

July 2016 Page 28 of 98 Exelon Nuclear Analysis # 1 DBT Task Performance Validation n/a n/a n/a n/a n/a EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis TABLE 4-Radiation Protection & Chemistry A TMI Exelon Nuclear Analysis # 1 DBT Position Performing Performance Time Period After Emergency Declaration (minutes)

Line 0-5-

10-15-Function/Task 5

10 15 20 1

In-Plant Survey On-Shift Position: NIA 2

On-Site Survey On-Shift Position: NIA 3

Personnel Monitoring On-Shift Position: NIA 4

Job Coverage On-Shift Position: NIA Offsite Radiological 5

Assessment On-Shift Position: NIA Other Site-Specific RP 6

Describe:

On-Shift Position: NIA Chemistry function/task 7

1. 1 - Describe:

On-Shift Position: N/A Chemistry function/task 8

1. 2 - Describe:

On-Shift Position: N/A July 2016 Page 29 of 98 20-25-30-35-40-45-50-25 30 35 40 45 50 55 55-60-65-70-75-80-60 65 70 75 80 85 EP-AA-1009 Addendum 1 (Revision 2) 85-90

TMI Station On-Shift Staffing Technical Basis A TMI TABLE 4 - Radiation Protection & Chemistry (Cont'd)

Notes:

Exelon Nuclear Analysis # 1 DBT

1.

The security posture is a station lockdown. Station personnel are required to shelter in place. Actions, as described below will occur as conditions permit.

2.

EP-AA-112-100-F-01, Step 1.10 -An RP tech is assigned to the MCR to support emergency response. This RP Tech will support Operations activities as necessary and as prioritized by the Shift Emergency Director. However, there are no specific actions for RP identified under this procedure step.

July 2016 Page 30 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis A TMI TABLE 5 - Emergency Plan Implementation Line Function/Task On-Shift Position 1

Declare the Emergency Shift Manager Classification Level (EGL)*

2 Approve Offsite Protective Shift Manager Action Recommendations*

3 Approve content of State/local Shift Manager notifications*

4 Approve extension to allowable Shift Manager dose limits*

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

6 ERO notification Shift Communicator 7

Abbreviated NRG notification Shift Manager for DST event 8

Complete State/local Shift Manager notification form 9

Perform State/local notifications Shift Communicator 10 Complete NRC event Shift Manager notification form 11 Activate EROS NA 12 Offsite radiological assessment NA 13 Perform NRG notifications Shift Communicator 14 Perform other site-specific NA event notifications (e.g., INPO, ANI, etc.)

15 Personnel accountability(1l NA 16 Other: Specify NA

• Shift Manager non-delegable duty July 2016 Page 31of98 Exelon Nuclear Analysis #1 DBT Task Performance Validation Ops Training Program Ops Training Program Ops Training Program Ops Training Program/

EP Drills and Exercises Ops Training Program Ops Training Program/

EP Drills and Exercises Ops Training Program Ops Training Program Ops Training Program/

EP Drills and Exercises Ops Training Program NA NA Ops Training Program/

EP Drills and Exercises NA NA NA EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis A TMI TABLE 5 - Emergency Plan Implementation Notes:

Exelon Nuclear Analysis #1 DBT 1. Accountability most likely will not be performed prior to augmentation due to a station lockdown; however, if the situation permits Security would be assigned this task.

July 2016 Page 32 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear 8 Aircraft Probable Threat

1.

Accident Summary:

Notification is received from the NRC that a probable aircraft threat exists (> 5 minutes, < 30 minutes).

The analysis does not include response actions taken during or after a crash.

2.

Accident Specific Assumptions:

Security response is per Station Security plan.

All non-security on-shift personnel are inside the protected area and at their normal work stations.

3.

Procedures Reviewed for Accident Response Include:

July 2016 OP-TM-AOP-008, Security Threat/Intrusion OP-TM-EOP-001, Reactor Trip OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer OP-TM-108-111-1001, Site Inaccessibility Plan EP-AA-1009, Exelon Nuclear Radiological Emergency Plan Annex for Three Mile Island Station.

Page 33 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis 8 TMI Exelon Nuclear This OSA is applicable to Analysis# 2 Air as identified in Attachment 2.

TABLE 1 - On-shift Positions Emergency Augmentation Line On-shift Position Plan Elapsed Time Reference (min)

Shift Manager I EP-AA-1009, NIA Shift ED Table 2-1

1.

2.

Control Room EP-AA-1009, NIA Supv (SRO)

Table 2-1

3.

STA (SRO)

EP-AA-1009, NIA Table 2-1

4.

Unit Reactor EP-AA-1009, NIA Operator (RO #1)

Table 2-1

5.

Aux Reactor EP-AA-1009, NIA Operator (RO #2)

Table 2-1 R0#3 EP-AA-1009, NIA

6.

Table 2-1

7. AO #1 (SSD)

EP-AA-1009, NIA Table 2-1

8.

AO #2 (SSD)

EP-AA-1009, NIA Table 2-1 Rad Pro Tech #1 EP-AA-1009, 60

9.

(RP #1)

Table 2-1 Rad Pro Tech #2 EP-AA-1009, 60

10. (RP #2)

Table 2-1 Rad Pro Tech #3 EP-AA-1009, 60

11. (RP #3)

Table 2-1

12. Chem Tech EP-AA-1009, 60 Table 2-1 Fire Brigade EP-AA-1009, NIA

13. Leader (Duty Maint Table 2-1 Supv)

July 2016 Page 34 of 98 Role in Unanalyzed TMS Table#/Line#

Task?

Required?

T2L1 No No T5L1 T5 L2 T5 L3 T5 L4 T5 L5 T5 LB T5L10 T2 L2 No No T2 L3 No No T2 L4 No No T2 L5 No No No No T2 L6 No No T2 L7 No No No No No No No No No No No No EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear Emergency Augmentation Role in Unanalyzed TMS Line On-shift Position Plan Elapsed Time Table#/Line#

Task?

Required?

Reference (min)

Fire Brigade EP-AA-1009, NIA No No

14. (AO #3)

Table 2-1 Fire Brigade EP-AA-1009, NIA No No

15. (AO #4)

Table 2-1 Fire Brigade EP-AA-1009, NIA No No

16. (Maint #1)

Table 2-1 Fire Brigade EP-AA-1009, NIA No No

17. (Maint #2)

Table 2-1 Shift EP-AA-1009, NIA T5 L6 No No

18. Communicator Table 2-1 T5 L9 T5L13

19. Maintenance #4 EP-AA-1009, NIA No No Table 2-1

20. Maintenance #5 EP-AA-1009, NIA No No Table 2-1 21. Security EP-AA-1009, NIA No No Table 2-1 Notes:

1. The Shift Communicator can be filled by any available qualified individual who is not assigned STA, Fire Brigade, SSD or Shift Emergency Director.

2. Augmentation Elapsed Time - Performance of a staffing analysis requires use of an assumed response (arrival) time for members of the augmented ERO. This time is the maximum acceptable number of minutes elapsed between an emergency declaration and the arrival of an ERO position-holder at a location necessary to relieve an on-shift ERO member. Per NEI 10-05, step 3.2.2.2.c, this is only required to be entered for RP and chemistry.

July 2016 Page 35 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis Exelon Nuclear 8 TMI TABLE 2 - Plant Operations & Safe Shutdown Analysis # 2 Air Applicable to site unit(s) #..1 One Unit - One Control Room Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if r bl app 1ca e Line Generic Title/Role On-Shift Position Task Performance Validation 1

Shift Manager Shift Manager Ops Training Program 2

Unit Supervisor Shift Supervisor Unit 1 Ops Training Program (SRO) 3 Shift Technical Advisor STA (SRO)

Ops Training Program 4

Reactor Operator #1 Unit Rx Operator (RO #1)

Ops Training Program 5

Reactor Operator #2 Aux Rx Operator (RO #2)

Ops Training Program 6

Auxiliary Operator #1 A0#1 Ops Training Program 7

Auxiliary Operator #2 A0#2 Ops Training Program 8

9 10 11 12 Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMG.f r bl SI app 1ca e Line Generic Title/Role 13 Mechanic 14 Electrician 15 l&C Technician 16 Other July 2016 On-Shift Position n/a n/a n/a n/a Page 36 of 98 Task Performance Validation n/a n/a n/a n/a EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis 8 TMI TABLE 3 - Firefighting Line Performed By 1

n/a 2

n/a 3

n/a 4

n/a 5

n/a Notes

1. Fire Brigade not utilized for this scenario.

July 2016 Page 37of98 Exelon Nuclear Analysis # 2 Air Task Performance Validation n/a n/a n/a n/a n/a EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis TABLE 4-Radiation Protection & Chemistry 8 TMI Exelon Nuclear Analysis # 2 Air Position Performing Performance Time Period After Emergency Declaration (minutes)

Line 0-5-

10-15-Function/Task 5

10 15 20 In-Plant Survey 1

On-Shift Position: NIA On-Site Survey 2

On-Shift Position: N/A Personnel Monitoring 3

On-Shift Position: N/A Job Coverage 4

On-Shift Position: N/A Offsite Radiological 5

Assessment On-Shift Position: N/A Other Site-Specific RP 6

Describe:

On-Shift Position: N/A Chemistry function/task 7

1. 1 - Describe:

On-Shift Position: N/A Chemistry function/task 8

1. 2 - Describe:

On-Shift Position: N/A July 2016 20-25-30-35-40-45-50-25 30 35 40 45 50 55 Page 38 of 98 55-60 60-65-70-75-80-85-65 70 75 80 85 90 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis 8 TMI TABLE 4-Radiation Protection & Chemistry (Cont'd)

Notes Per OP-TM-AOP-008 Security Threat/ Intrusion, all techs shelter and await further directions RP Techs RP#1 Exelon Nuclear Analysis # 2 Air o

EP-AA-112-100-F-O 1, Step 1.10 - An RP tech is assigned to the MCR to support emergency response. This RP Tech will support Operations activities as necessary and as prioritized by the Shift Emergency Director. However, there are no specific actions for RP identified under this procedure step.

Chemistry Tech - No Actions July 2016 Page 39 of 98 EP-AA-1009 Addendum 1 (Revision 2)

TMI Station On-Shift Staffing Technical Basis 8 TMI TABLE 5 - Emergency Plan Implementation Line Function/Task On-Shift Position 1

Declare the Emergency Shift Manager Classification Level (ECL)*

2 Approve Offsite Protective Shift Manager Action Recommendations*

3 Approve content of State/local Shift Manager notifications*

4 Approve extension to allowable Shift Manager dose limits*

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

6 ERO notification Shift Communicator 7

Abbreviated NRC notification NA for DBT event 8

Complete State/local Shift Manager notification form 9

Perform State/local notifications Shift Communicator 10 Complete NRG event Shift Manager notification form 11 Activate EROS NA 12 Offsite radiological assessment NA 13 Perform NRC notifications Shift Communicator 14 Perform other site-specific NA event notifications (e.g., INPO, ANI, etc.)

15 Personnel accountability NA 16 Other:

• Shift Manager non-delegable duty July 2016 Page 40 of 98 Exelon Nuclear Analysis # 2 Air Task Performance Validation Ops Training Program Ops Training Program Ops Training Program Ops Training Program/

EP Drills and Exercises Ops Training Program Ops Training Program/

EP Drills and Exercises NA Ops Training Program Ops Training Program Ops Training Program NA NA Ops Training Program NA NA EP-AA-1009 Addendum 1 (Revision 2)