Text

Attachments 1 & 2: Palisades Nuclear Station On-Shift Staffing Analysis, Revision 4 and Analysis Summary for Changes in Site Emergency Plan, Rev. 29 and On-Shift Staffing Analysis, Rev. 4
	ML17269A183
Person / Time
Site:	Palisades
Issue date:	09/04/2017
From:	; Entergy Nuclear Operations
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML17269A182	List: ML17269A183; PNP 2017-057, Supplement to Submittal of Palisades Nuclear Plant Site Emergency Plan, Rev. 29;
References
	PNP 2017-057
	Download: ML17269A183 (97)
	v • d • e

Attachment 1 Palisades Nuclear Station On-shift Staffing Analysis, Revision 4 93 Pages Follow

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES NUCLEAR STATION ON-SHIFT STAFFING ANALYSIS Revision 4 August 17, 2017 Prepared by:

lJ~e1

¥. J 7-t 1 William Cable' I

Date Peer Review: ~

$ -/7 Daniel Malone I

Date Approved by: ~

8'-/7-'7 Daniel Malone I

Date

PALISADES ON-SHIFT STAFFING ANALYIS REPORT TABLE OF CONTENTS I.

INTRODUCTION................................................................................................................................. 4 II.

ANALYSIS SUMMARy....................................................................................................................... 4 A.

Emergency Plan Minimum Staffing...................................................................................... 6 B.

Other Commitments to Shift Staffing................................................................................... 7 C.

Staffing Exceptions and Time Motion Studies (TMS)....................................................... 7 D.

Emergency Plan Tasks Not Analyzed................................................................................. 8 III.

ANALYSIS PROCESS........................................................................................................................ 9 IV.

ACCIDENT SCENARIOS................................................................................................................. 10 A.

Accident Selection................................................................................................................ 10 B.

Accident Scenarios included in the Analysis.................................................................... 10 C.

Accident Scenarios not included in the Analysis............................................................. 11 V.

GENERAL ASSUMPTIONS AND LIMITATIONS......................................................................... 12 A.

Notes and Assumptions applicable to all accidents in Palisades Staffing Analysis:.. 12 B.

NEI 10-05 Rev 0 Assumptions........................................................................................... 13 VI.

APPENDIX A - ANALYZED EVENTS AND ACCIDENTS........................................................... 15 VII.

APPENDIX B - ON-SHIFT STAFFING ANALYSIS..................................................................... 17 PALISADES A.

B.

C.

D.

E.

F.

G.

H.

I.

J.

K.

Accident Analysis #1 - Design Basis Threat (DBT)........................................................ 17 Design Basis Accident Analysis #2 - Control Rod Ejection........................................... 23 Design Basis Accident Analysis #3 - Small Line Break Outside Containment as described in FSAR 14.23..................................................................................................... 29 Design Basis Accident Analysis #4 - Main Steam Line Break Inside Containment..35 Design Basis Accident Analysis #5 - Loss of Coolant Accident................................... 41 Design Basis Accident Analysis #6 - Fuel Handling Accident...................................... 47 Design Basis Accident Analysis #7 - Waste Tank Rupture........................................... 53 Accident Analysis #8 - Aircraft Probable Threat............................................................. 59 Accident Analysis #9 - Control Room Fire Requiring Evacuation and Remote Shutdown............................................................................................................................... 65 Accident Analysis #10 - Station Blackout......................................................................... 71 Accident Analysis #11 - LOCAlGeneral Emergency with Release and PAR............. 77 PageZ

PALISADES ON-SHIFT STAFFING ANALYIS REPORT L.

Accident Analysis #15 - Steam Generator Tube Rupture with Concurrent Loss of Off-site Power........................................................................................................................ 83 VIII.

APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS...... 89 IX.

OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED.......................... 92 A.

Overlap Requiring Compensatory Measures................................................................... 92 X.

CORRECTIVE ACTIONS................................................................................................................. 92 A.

Corrective Actions and Compensatory Measures........................................................... 92 XI.

REFERENCES................................................................................................................................... 93 XII.

STAFFING ANAL YIS TEAM............................................................................................................ 93 PALISADES Page 3

PALISADES ON-SHIFT STAFFING ANALYIS REPORT I.

INTRODUCTION This document is a revision to the Palisades Nuclear Station On-shift Staffing Analysis (OSA) report dated August 28, 2015. This revision adds parenthetical references to personnel in the minimum on-shift staff positions of Nuclear Plant Operators (NPO) #5 and #6.

Throughout this analysis, reference to NPO #5 and #6 is intended to include the option that these positions may be filled by a fire brigade qualified person who is also minor maintenance qualified; or alternately by 2 persons per required NPO, one fire brigade qualified and the other minor maintenance qualified. This change aligns the On-shift Staffing Analysis within the Palisades Emergency Plan (E-Plan) with E-Plan Figure 5-2, Plant Staffing and Augmentation Requirements.

This revision continues to satisfy the requirements of 10 CFR 50 Appendix E Section IVA9, which states that nuclear power 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. This analysiS examined the capability of the minimum staff listed in Figure 5-2 of the E-plan to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-Plan.

II.

ANALYSIS

SUMMARY

The OSA team determined that an on-shift staff of fifteen (15) is able to cope with the spectrum of analyzed events, as described in Section IV of this report, until augmenting Emergency Response Organization (ERO) staff arrives. The on-shift staff consists of individuals necessary to support each of the emergency plan functional areas or tasks:

Emergency Direction and Control Plant Operations and Safe Shutdown (SSD)

Fire Fighting (FB)

Accident Assessment Radiation Protection and Chemistry Notification/Communication Technical Support Access Control and Accountability NEI 10-05 states it is acceptable for certain function to be assigned to personnel already assigned other functions/tasks. These include Repair and Corrective Action, Rescue Operations and First Aid.

PALISADES Page 4

PALISADES ON-SHIFT STAFFING ANALYIS REPORT The minimum on-shift staffing identified by this analysis is reflected in Table 1, "On-Shift Positions", for each analyzed event. This is intended to identify the analyzed tasks performed by each on-shift ERO staff member based on the findings of the OSA.

PALISADES PageS

PALISADES ON-SHIFT STAFFING ANALYIS REPORT A.

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 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.

Position Licensing Basis E-Plan Functional Area On-Shift Staffing Requirement Analysis Results 50.54m Emergency Direction and Shift Manager (SM)

E-Plan Figure 5-2 Control 1

50.54m Control Room Supervisor (CRS)

E-Plan Figure 5-2 SSD 1

Shift Technical Advisor (STA)

E-Plan Figure 5-2 Technical Support 1

50.54m SSD Control Room Operator (RO #1)

E-Plan Figure 5-2 1

50.54m Control Room Operator (RO #2)

E-Plan Figure 5-2 SSD 1

Nuclear Plant Operator (NPO #1)

E-Plan Figure 5-2 SSD 1

Nuclear Plant Operator (NPO #2)

E-Plan Figure 5-2 FB 1

Nuclear Plant Operator (NPO #3)

E-Plan Figure 5-2 FB 1

Nuclear Plant Operator (NPO #4)

E-Plan Figure 5-2 FB 1

Nuclear Plant Operator (NPO #5)

E-Plan Figure 5-2 1

(or other task-qualified FB personnel)

Nuclear Plant Operator (NPO #6)

E-Plan Figure 5-2 (or other task-qualified FB 1

personnel)

Communicator E-Plan Figure 5-2 Communications Notifications 1

Chemistry Technician E-Plan Figure 5-2 Accident 1

Assessment/Chemistry RP#1 E-Plan Figure 5-2 Radiation Protection 1

RP#2 E-Plan Figure 5-2 Radiation Protection 1

Security Contingency Access Control and Per Security Security PlantE-Pian Figure Accountability Contingency Plan 5-2 TOTAL 15 PALISADES Page 6

PALISADES ON-SHIFT STAFFING ANALYIS REPORT B.

Other Commitments to Shift Staffing No additional station commitments were identified conflicting with this staffing analysis.

C.

Staffing Exceptions and Time Motion Studies (TMS)

1.

2.

3.

PALISADES The primary responsibility for the on-shift Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. As noted in the Site Emergency Plan, the on-shift Chemistry Technician may also be required to support the on-shift Radiation Protection Technician implement tasks to support the Major Functional Area of Protective Actions (In-plant).

While the capability to perform these tasks are specified in the Emergency Plan, this analysis did not identify the need to utilize the on-shift Chemistry Technician to perform any of these Radiation Protection related tasks. It is recognized, however, that the Shift Manager will prioritize and utilize the on-shift staff as needed. It is therefore acceptable to assign the Chemistry Technician the E-Plan function of dose assessment. No further analysis or TMS is required.

The Shift Manager is assigned the responsibility to make site specific event notifications to the Duty Plant Manager, Operations Manager, and Resident Inspector. These notifications by phone are considered communications that are approximately one minute in length and are deemed acceptable in accordance with NEI 10-05 Section 3.2.2 (6)(a)(14) due to the short duration of the notifications. Additionally, these notifications are collectively evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills and are not deemed as impacting the Shift Managers ability to maintain oversight of the event or perform other required emergency plan tasks. In accordance with the guidance of NEI 10-05, Line 14 of NEI Table 5 contained in Section VII of this report does not reflect the performance of these short duration notifications. No further analysis or TMS is required.

Station staff are required to maintain continuous communications with the notification source during an aircraft threat in accordance with 10CFR50.54(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. The analysis of this event identified that the on-shift chemistry technician has no other aSSigned tasks in response to this event and would be available if needed to perform this task during the event. No further analysis or TMS is required.

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

The Shift Manager is assigned the task of notifying the off-shift ERO of the emergency. A Time Motion Study (TMS) was conducted to ensure the Shift Manager could perform the concurrent tasks of maintaining emergency direction and control while notifying the ERO of the event using Everbridge. The TMS demonstrated the Shift Manager was able to maintain Emergency Direction and Control during the approximate two minutes it took to notify the ERO using Everbridge.

Additionally, the task of ERO notification is routinely evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills.

5.

The Palisades Emergency Response Data System (EROS) link to the NRC is operated continuously and does not require activation following 'a declared emergency. The task of EROS activation is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

6.

NRC event notifications required due to the declaration of an Emergency Classification in accordance with 10 CFR 50.72 is made verbally using the Emergency Notification System. A written event notification form is not generated by on-shift staff for this notification. Formal written notifications to the NRC as may be required by 10 CFR 50.72 resulting from any of the analyzed events may be generated by the augmented staff. The task of completing the NRC event notification form is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

D.

Emergency Plan Tasks Not Analyzed PALISADES

1.

Repair and Corrective Action - Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by shift personnel assigned other functions. 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 lockoutltagout controls to complete.

In accordance with NE11 0-05 section 2.5, the analysis included a review of repair and corrective action tasks. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

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 Palisades, Nuclear Plant Operators (and other task-qualified staff that may substitute for NPOs) are trained to perform the actions associated with this functional area. Actions (e.g., reset breakers, valve manipulation) directed by the Control Room Supervisor to mitigate the event per procedures were performed by the Nuclear Plant Operators (or other task-qualified staff that may substitute for NPOs) in this analysis. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed PageS

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

2.

Rescue Operations and First Aid: In accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response although neither task was required during the evaluated scenarios. Per the guidance of NUREG-0654, Table B-1, rescue operations and first aid may be performed by shift personnel assigned other functions. The on-shift Radiation Protection staff members are trained and available to perform first aid and the station Fire Brigade staff are trained and available to perform search and rescue if needed. Rescue operations and first aid response are acceptable collateral duties per the guidance of NEI 10-05.

III.

ANALYSIS PROCESS The initial staffing analysis (Revision 0) was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments. Additionally, members of the Security staff provided input to the analysis.

The team members performing reviews to Revision 1 of the staffing analysis are identified in Section XII of this report. Revision 1 of this report was based on input, reviews and concurrence from station personnel from the same departments as those participating in the original analysis. The review process for the administrative changes included in Revision 2, 3 and 4 was limited to an independent peer review and final review and concurrence by the station EP Manager as documented on the report cover page.

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 Figure 5-2, 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 evaluated 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 Section VIII, APPENDIX B - ON-SHIFT STAFFING ANALYSIS. Note that NSIR DPR-ISG-01 states that only DBA accidents "which would result in an emergency declaration" should be evaluated in the staffing assessment. Each of Palisades DBA's were evaluated and classified according to its FSAR Chapter 14 description. If the accident description alone did not result in a classification, the projected accident Exclusion Area Boundary (EAB) dose was utilized to determine if an EAL threshold would be exceeded within the first 60 minutes using the Abnormal Radiation Level EAL thresholds. In cases where several projected doses were provided or 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.

PALISADES Page 9

PALISADES ON-SHIFT STAFFING ANALYIS REPORT IV.

ACCIDENT SCENARIOS A.

Accident Selection

1.

The OSA scenarios were chosen using the guidance of NEI 10-05 and NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants." The evaluation considered the station Design Basis Accidents (DBA) described in the USAR along with additional scenarios specified by the guidance documents. The scenarios considered were:

Design Basis Threat (DBT) ground assault Control Rod Ejection Accident Main Steam Line Break Accident Loss of Coolant Accident, (LOCA)

Fuel Handling Accident Aircraft Probable Threat Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire)

Station Blackout, (SBO)

LOCAIGeneral Emergency with release and PAR LOCA with entry into Severe Accident Management Small Line Break Outside Containment Waste Gas Accident Steam Generator Tube Rupture (SGTR)

Dropped Cask Appendix R Fire B.

Accident Scenarios included in the Analysis PALISADES

1.

Design Basis Threat (DBT) as described in NEI 10-05 The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

2.

Control Rod Ejection Accident as described in FSAR 14.16 This event assumes the reactivity insertion from the control rod ejection results in an overpower trip. The thermal-hydraulic analysis for this event is performed for only a few seconds. The remaining consequences of this event are covered by the small break LOCA analysis as noted in Chapter 14.17.2 of the FSAR.

3.

Main Steam Line Break (MSLB) Inside Containment as described in FSAR 14.14 This event assumes a double-ended guillotine break of a Main Steam Line inside containment with a loss of offsite power. Release information was not available in the FSAR, however, to determine if a radiation based EAL condition would be met in the first 60 minutes of the event. Emergency declaration was based on the loss of offsite power.

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Loss of Coolant Accident as described in FSAR 14.17.

This event is defined by a large rupture of the PCS cold leg piping between the PCP and the reactor vessel for the PCS loop containing the pressurizer. This event also includes a loss of offsite power and failure of 1 diesel generator.

5.

Fuel Handling Accident (FHA) as described in 14.19.

The FHA is assumed to occur in containment two days after shutdown. An Alert emergency declaration was assumed to be declared due to the event.

6.

Aircraft Probable Threat (SO.S4hh)

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

<30 minutes).

7.

Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire) as described in NEI 10-05.

A fire occurs in the main control room requiring the evacuation and the procedure implemented to shutdown from the remote shutdown panels.

8.

Station Blackout as described in NEI 10-0S.

A loss of all offsite AC power occurs and the failure of the emergency diesel generators to start. The SM determines power cannot be restored and declares a SAE on EAl5S1.1.

9.

LOCAIGeneral Emergency (GE) with release and PAR as described in NEI 10-0S.

The unit immediately enters a condition requiring the declaration of a General Emergency with indication of a radiological release that results in a dose that exceeds the Environmental Protection Agency's Protective Action Guides beyond the site boundary, necessitating Protective Actions Recommendations.

10.

Small Line Break Outside Containment as described in FSAR 14.23.

This analysis assumes a charging line break resulting in a 160 gpm primary coolant leak outside containment.

11.

Waste Gas Accident as described in FSAR 14.21.

This event assumes the rupture of a waste gas decay tank. EAL AA 1.1 conditions are assumed to be met based on expected stack high range monitor readings.

12.

Steam Generator Tube Rupture as described in FSAR 14.15 This event analyzes the response of a failure of a steam generator U-tube combined with a loss of offsite power.

C.

Accident Scenarios not included in the Analysis PALISADES

1.

LOCA with entry into Severe Accident Management Guidelines (SAMG) as described in NEI 10-

05.

NEI 10-05 Section 2.11 states that the analYSis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators. Palisades SAMGs are Page 11

PALISADES ON-SHIFT STAFFING ANALYIS REPORT guided by the TSC. All on-shift actions prior to off-site augmentation are performed by Licensed and Non-licensed operators. No additional analysis is required.

2.

Dropped Cask as described in FSAR 14.11.

Analyzed dropped cask events were identified as events that would only occur with the availability of additional station staff above and beyond those represented by station minimum staff and are outside the bounds of this analysis. Additionally, it was determined that no emergency declaration would be expected for this event.

3.

Appendix R Fire The team concluded the Control Room and Cable Spreading Room fires to be the most limiting fire events for resources and therefore a staffing analysis for the additional Appendix R fire scenario is not required. A review of operating procedures indicated that a fire in either of these rooms involves essentially the same operator actions, so the analysis considers only the Control Room fire in identifying required operator actions.

The emergency plan and fire brigade responsibilities are the same for all fire events although the Control Room fire and the Cable Spreading Room fire also require the additional actions to support a remote plant shutdown. Station Fire Protection, Appendix R, and Operations staff were used to validate these fire events as being the most man-power intensive.

v.

GENERAL ASSUMPTIONS AND LIMITATIONS A.

Notes and Assumptions applicable to all accidents in Palisades Staffing Analysis:

1.

2.

3.

4.

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

Palisades has 60 minute emergency responders when augmented while the ERO is offsite. This analysis was conducted assuming a 90 minute response of the augmented ERO to allow the use of this analysis for a possible future extension in ERO augmentation times. No specific emergency response tasks requiring the augmented ERO were identified prior to the 90 minutes following the emergency declaration.

The OSA team determined there are no time critical RP and Chemistry tasks and that task performance is directed and prioritized by the Shift Manager. The time RP or Chemistry is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration.

Since the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.

All crews have one individual filling the SM and one individual filling the STA roles therefore the analysis did not consider using a dual-role individual.

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT B.

NEI 10-05 Rev 0 Assumptions

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

13.

14.

PALISADES 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 noted above, this analysis assumed a 90 minute augmentation time.

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.

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.

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

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

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.

Personnel assigned plant operations and SSO 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.

In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain safe shutdown were done by a member of the on-shift staff as defined in the unit's Tech Specs.

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.

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

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

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

All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIR/OPR-ISG-01]

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 duty to a designated on-shift responder.

Page 13

15.

16.

17.

18.

19.

20.

21.

22.

PALISADES PALISADES ON-SHIFT STAFFING ANALYIS REPORT 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.

DBA (postulated accident, Condition IV event, or limiting fault) is considered as "Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation. As a result, a greater number and variety of actions would need to be implemented by plant personnel."

Unless otherwise specified in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, or by the USAR initial conditions of a DBA analysis, it was assumed that the unit was in Mode 1, Power.

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.

The Staffing Analysis used DBA analysis assumptions, inputs, timing of events, plant protective response, and specified manual operator actions and their timing, as documented in the FSAR.

In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began 15-minutes after the initiating event.

Severe Accident Management Guideline (SAMG) - this analysis assumed the accident progressed to conditions requiring a severe accident response; it did not include determining specific failures and the accident sequence.

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

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT VI.

APPENDIX A - ANALYZED EVENTS AND ACCIDENTS Event Event Summary Description Plant Reference Event ECl Analysis Type of Event Mode1 Document(s)

Required?

1 DBT Land and/or 1

NE11 0-0S Site Area Yes waterborne HOSTI LE Emergency ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

2 DBA Control Rod Ejection 1

FSAR 14. 16 Site Area Yes Emergency 3

DBA Small Line Break 1

FSAR 14.23 Site Area Yes Outside Containment Emergency 4

DBA Main Steam Line Break 1

FSAR 14.14 Unusual Yes Inside Containment Event (due with LOOP (bounding to LOOP) for steam piping failures)

S DBA LOCA 1

FSAR 14.17 Site Area Yes Emergency 6

DBA Fuel Handling Accident S

FSAR 14.19 Alert Yes 7

DBA Waste Tank Rupture 1

FSAR 14.21 Alert Yes 8

Assumed Aircraft Probable 1

10CFRSO.S4hh(1)

Alert Yes for Threat analysis RG 1.214 purpose 9

Assumed Control Room 1

10CFRSO Alert Yes for Evacuation and Appendix R Analysis Remote Shutdown (fire Purpose in main control room)

Procedure ONP-2S.2 10 Assumed Station Blackout 1

10CFRSO.63 Site Area Yes for Emergency analysis purpose 11 Assumed LOCA - General 1

ISG IV.C General Yes for Emergency with Emergency Analysis radiological release Purpose and PAR 12 Assumed LOCA with entry into 1

ISG IV.C General No" for severe accident Emergency Analysis procedures.

Purpose PALISADES Page 15

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Event Event Summary Description Plant Reference Event Eel Analysis Type of Event Model Document(s)

Required?

13 Assumed Appendix R Fire 1

ISG IV.C Alert No" for Analysis Purpose 14 DBA Dropped Cask 1

FSAR 14.11 None No" 15 DBA Steam Generator Tube 1

FSAR 14.15 Alert Yes Rupture with concurrent LOOP 1 Plant mode per FSAR or assumed for analysis purpose 2 SAMG is written to be implemented by the TSC. NEllO-OS Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators. Palisades does not include maintenance qualified to perform maintenance job tasks in minimum staffing and any response actions would be performed by operators.

3 Appendix R Fire is bound by the Control Room Fire and Remote Shutdown.

4 No emergency declaration is expected for this event.

PALISADES Page 16

PALISADES ON-SHIFT STAFFING ANALYIS REPORT VII.

APPENDIX B - ON-SHIFT STAFFING ANALYSIS A.

Accident Analysis #1 - Design Basis Threat (DBT)

PALISADES

1.

Accident Summary Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat.

This analysis concluded that sufficient staff was available to simultaneously implement both the emergency plan and the security plan. The conclusion that sufficient staff was available to implement the security plan was based on security staff personnel not being assigned collateral duties that would prevent the timely performance of their assigned functions. As noted in the analysis assumptions detailed in Section V.B.11 of this report and NEI 10-05 Section 3.1 items 12, the security organization is assumed to be able to satisfactorily perform all tasks related to Site and Protected Area Access Controls, under all event or accident conditions.

2.

Accident Specific Assumptions Made The Palisades DBT for this analysis assumes a land based threat although a waterborne threat was also considered to determine if it was a more man-power limiting event. This analysis identified that a change to the mode of the attack did not impact the staffing analysis or identify the assignment of any additional collateral duties for on-shift personnel that would prevent the timely performance of their assigned functions as specified in the emergency plan.

This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

Assume at power in Mode 1 Security notifies the Shift Manager of condition of hostile action occurring within the protected area (Security code RED)

Assume all non-security staff is located inside the protected area at their normal work station when the event occurs.

Assume all systems function and the core remains covered. No fuel damage and no release.

3.

Procedures for Accident Response AOP-44 Rev. 0, Response to Attack on Palisades EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4, Rev. 52, Operations Organization, Responsibilities and Conduct Page 17

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 1 DBT Securirl Threat Line On-shift Augmentation Role in Unanalyzed TMS Basis Document Elapsed Time Table #1 Position (min)*

Line #

Task?

Required?

T2/L 1 T5/L1 Emergency Plan T5/L3 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 Advisor Figure 5-2 60 T5/L7 No No 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 FIgure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 N/A No No Figure 5-2 14 RP#1 Emergency Plan 60 N/A No No Figure 5-2 15 RP#2 Emergency Plan 60 N/A No No Figure 5-2 Security Contingency 16 Security Plan I Emergency N/A N/A No No Plan Figure 5-2 PALISADES Page 18

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 1 DBT Security Threat Minimum O~erations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position rrask Analysis

~ontrolling Method 1

Shift Manager Shift Manager Licensed Operator Training Program 2

Unit Supervisor CRS Licensed Operator Training Program 3

Shift Technical Advisor STA Licensed Operator Training Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator Training

1 Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator Training

2 Program 6

~uxiliary Operator #1 Nuclear Plant Operator #1 Non-Licensed Operator Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line #

Generic Title/Role On-Shift Position Task Analysis Controlling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 19

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 1 DBT Security Threat Line Performed by Task Analysis ContrOlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for flreflghtlng, first aid or search & rescue.

PALISADES Page 20

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 1 DBT Securi~ Threat L

Position Performing Performance Time Period After Emergency Declaration (minutes)

I Function I Task N

0-5 5-10 10-15 15-20 ~0-25 ~5-30 30-35 35-40 140-45 145-50 50-55 55-60 60-65 65-70-75-80- 85-90 E

70 75 80 85 1

In-Plant Survey: N/A 2

On-site Survey: N/A I

I I

3 Personnel Monitoring: W8 I

4 Job Coverage: N/A 5

Offsite Rad Assessment:

W8 6

Other site specific RP (describe): N/A 7

Chemistry Function task

~1 (describe)

N/A 8

Chemistry Function task

~2 (describe)

N/A No chemistry or RP job function tasks for the conditions described in the DBT assumptions. RP and Chemistry take cover as directed.

PALISADES Page 21

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 1 DBT Securi~ Threat Line' Function I Task On-Shift Task Analysis Controlling Method Position 1

Declare the emergency classification level Shift Manager Emergency Planning Training (ECl)

Program / EP Drills 2

Approve Offsite Protective Action N/A N/A Recommendations 3 IApprove content of State/local notifications Shift Manager Emergency Planning Training Program 4

IApprove extension to allowable dose N/A N/A Notification and direction to on-shift staff Licensed Operator Training Program 5

(e.g., to assemble, evacuate, etc.)

Shift Manager Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning Training Program 7

~bbreviated NRC notification for DBT event STA Licensed Operator Training Program 8

Complete State/local notification form Shift Manager Emergency Planning Training Program 9

Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11

!Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A 13 Perform NRC notifications Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security

~ecurity Training Program / EP Drills PALISADES Page 22

PALISADES ON-SHIFT STAFFING ANALYIS REPORT B.

Design Basis Accident Analysis #2 - Control Rod Ejection PALISADES

1.

Accident Summary This event assumes the reactivity insertion from the control rod ejection results in an overpower trip. The thermal-hydraulic analysis for this event is performed for only a few seconds. The remaining consequences of this event are covered by the small break LOCA analysis as noted in Chapter 14.17.2 of the FSAR.

2.

Accident Specific Assumptions Made Reactivity insertion - overpower trip.

The thermal-hydraulic analysis for this event is performed for only a few seconds. The remaining consequences of this event are covered by the small break LOCA analysis in Chapter 14.17.2 The analysis assumes 14.7% of the fuel fails due to ONB considerations.

100% of the activity released from the damaged fuel is instantaneously released to the containment atmosphere, from which leakage to the environment occurs.

Radioactivity is transported to the secondary system through a 0.3 gpm primary to secondary leak in each steam generator.

EAB worst 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months dose containment release is within acceptable limits.

3.

Procedures for Accident Response EOP-4.0 Rev. 22, Loss of Coolant Accident Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly AOMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 23

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 2 Control Rod Ejection Accident Line On-shift Augmentation Role in Unanalyzed TMS Basis Document Elapsed Time Table #1

Position (min)*

Line #

Task?

Required?

T2/L1 T5/L1 Emergency Plan T5/L3 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No IAdvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 FiQure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan T5/L9 12 Communicator Figure 5-2 60 T5/L 13 No No 13 Chem Tech Emergency Plan 60 T5/L 12 No Yes FiQure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I Emergency N/A N/A No No Plan Figure 5-2 PALISADES Page 24

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANAL YSIS # 2 Control Rod Ejection Accident Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position trask Analysis Controlling Method 1

Shift Manager Shift Manager Licensed Operator

~raining Program 2

Unit Supervisor CRS Licensed Operator

~raining Program Shift Technical Advisor STA Licensed Operator 3

~raining Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 ITraining Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2

Training Program 6

~uxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # lGeneric Title/Role On-Shift Position Task Analysis Controlling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 25

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANAL YSIS # 2 Control Rod Eiection Accident Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accIdent does not Include the need for flrefightrng, first aId or search & rescue.

PALISADES Page 26

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 2 Control Rod Eiection Accident L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function t Task

~=

N 5-10 10-15 15-20 ~0-25 ~5-30 30-35 35-40 ~0-45 ~5-50 50-55 55-60 60-65 65-70-75-80-85-90 E

0-5 70 75 80 85 1

In-Plant Survey: NtA 2

On-site Survey: RP#2 X

X X

3 Personnel Monitoring:

NtA 4

Job Coverage: RP#1 X

X X

~oes to CR for job suppor!

5 Offsite Rad Assessment:

I/Included in Table 51 6

Other site specific RP (describe): NtA 7

Chemistry Function task 1#1 (describe) - NtA 8

Chemistry Function task 1#2 (describe) - Nt A RP#l and #2 will perform the above tasks as directed by the Shift Manager. Task are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 27

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 2 Control Rod Ejection Accident Line Function I Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager rrraining Program / EP (ECl)

Drills 2

~pprove Offsite Protective Action N/A N/A Recommendations 3

IApprove content of State/local notifications Shift Manager Emergency Planning rrraining Program 4

IApprove extension to allowable dose N/A N/A Licensed Operator 5

Notification and direction to on-shift staff Shift Manager Irraining Program /

(e.g., to assemble, evacuate, etc.)

Emergency Planning Irraining Program 6

ERO notification Shift Manager Emergency Planning Irraining Program 7

IAbbreviated NRC notification for DBT event N/A' Licensed Operator h"raining Program 8

Complete State/local notification form Shift Manager Emergency Planning l raining Program 9

Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11

~ctivate EROS N/A N/A 12 Offsite radiological assessment Chem Technician Emergency Planning Training Program 13 Perform NRC notifications Communicator Emergency Planning Training Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

15 Personnel Accountability Security

[Security Training Program EP Drills PALISADES Page 28

PALISADES ON-SHIFT STAFFING ANALYIS REPORT C.

Design Basis Accident Analysis #3 - Small Line Break Outside Containment as described in FSAR 14.23 PALISADES

1.

Accident Summary This analysis assumes a charging line break resulting in a 160 gpm primary coolant leak outside containment.

2.

Accident Specific Assumptions Made PCS activity of 1IJCi/gm DEI released to the Auxiliary Building atmosphere.

No reactor depressurization or trip was assumed to occur. An iodine spike was not assumed.

Leak isolation time assumed to be 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

3.

Procedures for Accident Response AOP-23 Rev. 0, Primary Coolant Leak EOP-4 Rev. 22, LOCA Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 29

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 3 Small Line Break Outside Containment Line On-shift Augmentation Role in Unanalyzed TMS Basis Document Elapsed Time Table #1 Position (min)*

Line #

Task?

Required?

T2/L 1 T5/L 1 Emergency Plan T5/L3 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8

Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 T5/L 12 No Yes Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I Emergency N/A T5/L 15 No No Plan Figure 5-2 PALISADES Page 30

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 3 Small Line Break Outside Containment Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 1

Shift Manager Shift Manager Licensed Operator Training Program 2

Unit Supervisor CRS Licensed Operator Training Program Shift Technical Advisor STA Licensed Operator 3

Training Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 rt"raining Program 6

Auxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 rt"raining Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # ~eneric Title/Role On-Shift Position

[Task Analysis

~ontrolling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 31

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANAL YSIS # 3 Small Line Break Outside Containment Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for flrefightlng. first aid or search & rescue.

PALISADES Page 32

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 3 Small Line Break Outside Containment L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function t Task N

0-5 5-10 10-15 15-20 ~0-25 ~5-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70-75-80-85-90 E

70 75 80 85 1

In-Plant Survey: NtA 2

On-site Survey: RP#2 X

X X

3 Personnel Monitoring:

NtA 4

~ob Coverage: RP#1 X

X X

I

~oes to CR for job support 5

Offsite Rad Assessment:

If/ncluded in Table 5) 6 Other site specific RP (describe): NtA 7

Chemistry Function task

~1 (describe) - NtA 8

Chemistry Function task 1#2 (describe) - Nt A

--~

-~-

RP#l and #2 will perform the above tasks as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 33

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 3 Small Line Break Outside Containment Line Function I Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager Irraining Program / EP (ECl )

Drills 2

Approve Offsite Protective Action N/A N/A Recommendations 3

Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4

Approve extension to allowable dose N/A N/A Licensed Operator 5

Notification and direction to on-shift staff Shift Manager Training Program /

(e.g., to assemble, evacuate, etc.)

Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning Irraining Program 7

~bbreviated NRC notification for DBT event N/A Licensed Operator Irraining Program 8

Complete Statellocal notification form Shift Manager Emergency Planning Irraining Program 9

Perform State/local notifications Communicator Emergency Planning Irraining Program 10 Complete NRC event notification form N/A N/A 11 Activate EROS N/A N/A 12 Offsite radiological assessment Chem Technician Emergency Planning

!Training Program 13 Perform NRC notifications Communicator Emergency Planning Training Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program EP Drills PALISADES Page 34

PALISADES ON-SHIFT STAFFING ANALYIS REPORT D.

Design Basis Accident Analysis #4 - Main Steam Line Break Inside Containment.

PALISADES

1.

Accident Summary This event assumes a double-ended guillotine break of a Main Steam Line inside containment with a loss of offsite power. Release information was not available in the FSAR to determine if a radiation based EAL condition would be met in the first 60 minutes of the event. Emergency declaration was based on the loss of offsite power.

2.

Accident Specific Assumptions Made MSL break assumes 0.3 gpm primary to secondary leak for the affected SG that flashes to steam and is released through the break area.

FSAR analysis assumes radionuclide releases from the primary coolant associated with 0.5% fuel failures.

The EAB worst 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months dose was noted in the FSAR as being within acceptable criteria but specific release information was not available to determine if a radiation based EAL condition was met in the first 60 minutes of the event. The event declaration was therefore made based on the loss of off-site power.

3.

Procedures for Accident Response EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications AOP-2 Rev. 0, Excessive Load ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct EOP-6.0 Rev.19, Excess Steam Demand Event Page 35

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1-ON-SHIFT POSITIONS Analysis # 4 Main Steam Line Break On-shift Augmentation Role in Table #

Unanalyzed TMS Line #

E-Plan Reference Elapsed Time I Line #

Position (min)

Task?

Required?

T2/L 1 T5/L 1 Emergency Plan T5/L3 1

Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/La 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 a

Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No OQerator#6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 T5/L 12 No Yes Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I Emergency N/A T5/L 15 No No Plan Figure 5-2 PALISADES Page 36

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 4 Main Steam Line Break Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position lTask Analysis

~ontrolling Method 1

Shift Manager Shift Manager Licensed Operator Irraining Program 2

Unit Supervisor CRS Licensed Operator Training Program 3

Shift Technical Advisor STA Licensed Operator Training Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 Training Program 6

Auxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position lTask Analysis

~ontrolling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A PALISADES Page 37

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 4 Main Steam Line Break Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for firefightlng, first aid or search & rescue.

PALISADES Page 38

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 4 Main Steam Line Break L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

0-5 5-10 10-15 15-20 20-25 ~5-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70-75-80-85-9C E

70 75 80 85 1

In-Plant Survey: N/A 2

On-site Survey: RP#2 X

X X

3 Personnel Monitoring: N/A 4

~ob Coverage: RP#1 is

~vailable to support job X

X X

coverage or surveys as required 5

Offsite Rad Assessment:

Table 5) 6 Other site specific RP (describe): N/A 7

Chemistry Function task

1 (describe)

N/A 8

Chemistry Function task

2 (describe)

N/A RP#1 and RP #2 will perform the above tasks as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 39

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Anal}tsis # 4 Main Steam Line Break Line #

Function I Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager Irraining Program / EP (ECl)

Drills 2

~pprove Offsite Protective Action N/A N/A Recommendations 3

fA,pprove content of State/local notifications Shift Manager Emergency Planning Training Program 4

~pprove extension to allowable dose N/A N/A Licensed Operator 5

Notification and direction to on-shift staff Shift Manager Training Program /

(e.g., to assemble, evacuate, etc.)

Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning

!rraining Program 7

Abbreviated NRC notification for DBT event N/A N/A 8

Complete State/local notification form Shift Manager Emergency Planning

!rraining Program 9

Perform State/local notifications Communicator Emergency Planning Irraining Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning

!rraining Program 13 Perform NRC notifications Communicator Emergency Planning Irraining Program Perform other site-specific event N/A 14 notifications (e.g., Duty Plant Manager, N/A INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program EP Drills PALISADES Page 40

PALISADES ON-SHIFT STAFFING ANALYIS REPORT E.

Design Basis Accident Analysis #5 - Loss of Coolant Accident.

PALISADES

1.

Accident Summary This event is defined by a large rupture of the PCS cold leg piping between the PCP and the reactor vessel for the PCS loop containing the pressurizer. This event also includes a loss of offsite power and failure of 1 diesel generator.

2.

Accident Specific Assumptions Made Large rupture of the PCS cold leg piping between the PCP and the reactor vessel for the PCS loop containing the pressurizer.

Rapid depressurization of the PCS, reactor trip signal but credit is taken for shut down by coolant voiding in the core. Experience DNB.

SIAS signal initiated Loss of offsite power and failure of 1 DIG Assumes loss of one ECCS train, one HPSI, one LPSI, all containment spray pumps and all containment fan coolers are operational.

3.

Procedures for Accident Response EOP-4.0 Rev. 22, Loss of Coolant Accident Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct AOP-23, Rev. 0, Primary Coolant Leak Page 41

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 5 Loss of Coolant Accident Line On-shift Augmentation Role in Table Unanalyzed TMS Position E-Plan Reference Elapsed Time

I Line #

Task?

Required?

(min)

T2/L1 T5/L1 T5/L2 1

Shift Manager Emergency Plan 60 T5/L3 No Yes Figure 5-2 T5/L5 T5/L6 T5/La 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 a Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 T5/L 12 No Yes Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I Emergency N/A T5/L 15 No No Plan Figure 5-2 PALISADES Page 42

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANAL YSIS # 5 Loss of Coolant Accident Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role pn-Shift Position

[Task Analysis

~ontrolling Method 1

Shift Manager Shift Manager Licensed Operator Ifraining Program 2

Unit Supervisor CRS Licensed Operator Ifraining Program Shift Technical Advisor STA Licensed Operator 3

Training Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 Training Program 6

fA,uxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role pn-Shift Position Task Analysis Controlling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A PALISADES Page 43

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANAL YSIS # 5 Loss of Coolant Accident Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for fireflghtmg, first aid or search & rescue.

PALISADES Page 44

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 5 Loss of Coolant Accident L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

~0-25 ~5-30 30-35 35-40 140-45 145-50 50-55 55-60 60-65 65-70-75-80-85-90 E

0-5 5-10 10-15 15-20 70 75 80 85

~.

1 In-Plant Survey: N/A 2

On-site Survey: RP#2 X

X X

3 Personnel Monitoring: N/A 4

Job Coverage: RP#1 reports to the CR to provide RP support X

X X

(including in plant

~urveys) as directed by he SM.

5 Offsite Rad Assessment:

(Included in Table 5 6

IOther site specific RP (describe): N/A 7

Chemistry Function task

~1 (describe) N/A 8

Chemistry Function task

~2 (describe) N/A RP#1 and RP #2 will perform the above tasks as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 45

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 5 Loss of Coolant Accident Line Function I Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager Irraining Program / EP (ECl)

Drills 2

Approve Offsite Protective Action N/A Emergency Planning Recommendations Irraining Program 3

Approve content of State/local notifications Shift Manager Emergency Planning Irraining Program 4

Approve extension to allowable dose N/A Emergency Planning Irraining Program Notification and direction to on-shift staff (e.g.,

Licensed Operator Training 5

Shift Manager Program / Emergency o assemble, evacuate, etc.)

Planning Training Program 6

ERO notification Shift Manager Emergency Planning Training Program 7

~bbreviated NRC notification for DBT event N/A N/A 8

Complete State/local notification form fShift Manager Emergency Planning Training Program 9

Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate EROS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning

!rraining Program 13 Perform NRC notifications Communicator Emergency Planning Irraining Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer

~ecurity Training Program PALISADES Page 46

PALISADES ON-SHIFT STAFFING ANALYIS REPORT F.

Design Basis Accident Analysis #6 - Fuel Handling Accident PALISADES

1.

Accident Summary The fuel handling accident is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism, resulting in the dropping of a raised fuel assembly onto stored fuel bundles. The FHA is assumed to occur in containment two days after shutdown. An Alert emergency declaration was assumed to be declared due to the event.

2.

Accident Specific Assumptions Made An Alert is declared on the fuel handling event. Radiological release rates are not available to classify on the release.

Additional station personnel, including Operations and Health Physics Technicians, would normally be on-site during fuel movement activities. Additional station personnel were not required, however, to support initial response actions.

3.

Procedures for Accident Response AOP-34 Rev. 0, Fuel Handling Accident EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 47

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #6 - Fuel Handling Accident Line Augmentation Role in Table # Unanalyzed TMS On-shift Position E-Plan Reference Elapsed Time I Line #

(min)

Task?

Required?

T2/L1 T5/L 1 Emergency Plan T5/L3 1

Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No IAdvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8

Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 T5/L 12 No Yes Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I Emergency N/A T5/L 15 No No Plan Figure 5-2 PALISADES Page 48

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANAL YSIS # 6 - Fuel Handling Accident Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position

[Task Analysis

~ontrolling Method 1

Shift Manager Shift Manager Licensed Operator Irraining Program Unit Supervisor CRS Licensed Operator 2

ITraining Program Shift Technical Advisor STA Licensed Operator 3

ITraining Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 Training Program 6

~uxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # !Generic Title/Role

[On-Shift Position Task Analysis Controlling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 49

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 6 - Fuel Handlina Accident Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for firefightlng, first aid or search & rescue.

PALISADES Page 50

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #6 - Fuel Handling Accident L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

20-25 125-30 30-35 35-40 40-45 45-50 50-55 55-60 ~0-65 65-70-75-80-85-90 E

0-5 5-10 10-15 15-20 70 75 80 85

~

1 In-Plant Survey:

~

2 On-site Survey: RP#2 X

X X

3 Personnel Monitoring: N/A I

4 Job Coverage: RP#1 reports to the CR to provide RP support X

X X

(including in plant Isurveys) as directed by he SM.

5 Offsite Rad Assessment:

If/ncluded in Table 5 6

Other site specific RP (describe): N/A 7

Chemistry Function task 1#1 (describe) N/A 8

Chemistry Function task

2 (describe) N/A RP#1 and RP #2 will perform the above tasks as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 51

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #6 - Fuel Handlina Accident Line Function I Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager Training Program I EP (ECl )

Drills 2

!Approve Offsite Protective Action N/A N/A Recommendations 3

fA.pprove content of Statellocal notifications Shift Manager Emergency Planning

~raining Program 4

!Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g.,

Licensed Operator Training 5

o assemble, evacuate, etc.)

Shift Manager Program I Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning Irraining Program 7

IAbbreviated NRC notification for DBT event N/A N/A 8

Complete Statellocal notification form Shift Manager Emergency Planning Training Program 9

Perform Statellocal notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate EROS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning Training Program 13 Perform NRC notifications Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability lSecurity Officer Security Training Program PALISADES Page 52

PALISADES ON-SHIFT STAFFING ANALYIS REPORT G.

Design Basis Accident Analysis #7 - Waste Tank Rupture PALISADES

1.

Accident Summary This event assumes the rupture of a waste gas decay tank. EAl AAl.l conditions are assumed to be met based on expected stack high range monitor readings.

2.

Accident Specific Assumptions Made A rupture in the Waste Gas System or a rupture of the volume control tank would result in offsite doses well below the 10 CFR 100 limits, and would not present any undue risk to the health and safety of the public.

The release for this accident is similar to the small break lOCA outside containment.

Details are not provided to determine an EAl, therefore an assumption is made that EAl AAl.l conditions are met based on the stack high range monitor.

3.

Procedures for Accident Response HP-2.8 Rev. 25, Response to Unusual Radiological Occurrences EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 53

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1-ON-SHIFT POSITIONS Analysis #7 - Waste Tank Rueture Line Augmentation Role in Table # Unanalyzed TMS On-shift Position E-Plan Reference Elapsed Time I Line #

(min)

Task?

Required?

T2/L1 T5/L 1 Emergency Plan T5/L3 1

Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8

Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chern Tech Emergency Plan 60 T5/L 12 No Yes Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I Emergency N/A T5/L 15 No No Plan Figure 5-2 PALISADES Page 54

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 7 - Waste Tank Rupture Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 1

Shift Manager Shift Manager Licensed Operator Training Program Unit Supervisor CRS Licensed Operator 2

Training Program STA Licensed Operator 3

Shift Technical Advisor Training Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2

[rraining Program 6

Auxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1

[rraining Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # ~eneric Title/Role On-Shift Position jrask Analysis

~ontrolling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page SS

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 7 - Waste Tank Ruoture Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for fireflghtlng, first aid or search & rescue.

PALISADES Page 56

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #7 -Waste Tank RUJ!ture L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

~0-25 ~5-30

~0-45 ~5-50 50-55 55-60 ~0-65 65-70-75-80-85-90 I 0-5 5-10 10-15 15-20 30-35 35-40 70 75 80 85 E

I 1

In-Plant Survey:

I f3E1R I

2 On-site Survey: RP#2 X

X X

3 Personnel Monitoring: N/A 4

~ob Coverage: RP#1 reports to the CR to provide RP support X

X X

(including in plant Isurveys) as directed by he SM.

5 Offsite Rad Assessment:

iflncluded in Table 5 6

Other site specific RP (describe): N/A 7

Chemistry Function task 1#1 (describe) N/A 8

jChemistry Function task 1#2 (describe) N/A RP#1 and RP#2 will perform the above tasks as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 57

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #7 - Waste Tank RUDture Line Function I Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager ITraining Program / EP (ECl)

Drills 2

Approve Offsite Protective Action N/A N/A Recommendations 3

Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4

!Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g.,

Licensed Operator Training 5

o assemble, evacuate, etc.)

Shift Manager Program / Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning n-raining Program 7

~bbreviated NRC notification for DBT event N/A N/A 8

Complete State/local notification form Shift Manager Emergency Planning ITraining Program 9

Perform State/local notifications Communicator Emergency Planning ITraining Program 10 Complete NRC event notification form N/A N/A 11 Activate EROS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning ITraining Program 13 Perform NRC notifications Communicator Emergency Planning ITraining Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program PALISADES Page 58

PALISADES ON-SHIFT STAFFING ANALYIS REPORT H.

Accident Analysis #8 - Aircraft Probable Threat PALISADES

1.

Accident Summary The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 minutes, but less than 30 minutes from the site, and considers the dispersal of the site fire brigade away from target areas for firefighting.

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

2.

Accident Specific Assumptions Made The Shift Manager receives the call from the NRC of probable aircraft threat.

All non-security on-shift personnel are inside the protected area fence at their normal workstation.

Fire brigade personnel are included in Table 3, "Firefighting" to signify they are performing actions (relocation outside of the target area) specific to their assignment to the fire brigade and are not available to perform other tasks. While the inclusion of the fire brigade in Table 3 varies from the guidance of NEI10-05, Section 3.2.2 (4)(a), the addition more clearly identifies on-shift staff actions.

3.

Procedures for Accident Response AOP-44 Rev. 0, Response to Security Threats EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 59

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #8 - Aircraft Probable Threat Line Augmentation Role in Table Unanalyzed TMS

~n-shift Position Basis Document Elapsed Time 51 Line #

Task?

Required?

(min)

T2/L 1 T5/L 1 Emergency Plan T5/L3 1

Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A T3/L1 No No Operator #2 Figure 5-2 8

Nuclear Plant Emergency Plan N/A T3/L2 No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A T3/L3 No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A T3/L4 No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A T3/L5 No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chern Tech Emergency Plan 60 T4/L7 No No Figure 5-2 14 RP#1 Emergency Plan 60 T4/L6 No No Figure 5-2 15 RP#2 Emergency Plan 60 No No Figure 5-2 Security 16 Security Contingency Plan N/A T5/L 15 No No II Emergency Plan FiQure 5-2 PALISADES Page 60

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #8 - Aircraft Probable Threat Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position rrask Analysis

~ontrolling Method 1

Shift Manager Shift Manager Licensed Operator Irraining Program Unit Supervisor CRS Licensed Operator 2

Irraining Program Shift Technical Advisor STA Licensed Operator 3

iT"raining Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 Training Program 6

~uxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line #

~eneric Title/Role pn-Shift Position rrask Analysis

~ontrolling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 61

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #8 - Aircraft Probable Threat Line Performed by Task Analysis Controlling Method 1

Nuclear Plant Operator #2 Fire Brigade Training 2

Nuclear Plant Operator #3 Fire Brigade Training 3

Nuclear Plant Operator #4 Fire Brigade Training 4

Nuclear Plant Operator #5 Fire Brigade Training 5

Nuclear Plant Operator #6 Fire Brigade Training This accident does not Include the need for firefightlng, first aid or search & rescue. The fire brigade IS required, however, to relocate to the Training Center and is therefore not available to perform other tasks.

PALISADES Page 62

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #8 - Aircraft Probable Threat L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

0-5 5-10 10-15 15-20 20-25 ~5-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-70-75-80-85-90 E

70 75 80 85

'~..s..:;.;_

1 In-Plant Survey: N/A 2

On-site Survey: N/A 3

Personnel Monitoring: N/A I

4

~ob Coverage: N/A 5

Offsite Rad Assessment:

Ilfncluded in Table 5 - NIA 6

Other site specific RP#1 &

RP#2: report to the CR X

X X

X 7

Chemistry Function task 1#1 : Support NRC open-X X

X X

line communications if needed 8

Chemistry Function task

2 (describe) - N/A

Times are estimated No specific RP or Chemistry tasks are performed for this event. At the on-set of this event, RP#1 and RP #2 report to the CR and follow Shift Manager directions. The Chemistry Technician is available to support NRC communications from the Control Room.

PALISADES Page 63

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #8 - Aircraft Probable Threat Line Function I Task*

On-Shift Position Task Analysis Controlling Method 1

Declare the emergency classification level Shift Manager Emergency Planning (ECl)

Irraining Program I EP Drills 2

Approve Offsite Protective Action N/A N/A Recommendations 3

Approve content of Statellocal notifications Shift Manager Emergency Planning Irraining Program 4

Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g.,

Licensed Operator Training 5

o assemble, evacuate, etc.)

Shift Manager Program I Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning Training Program 7

~bbreviated NRC notification for DBT event N/A N/A 8

Complete Statellocal notification form

~hift Manager Emergency Planning Training Program 9

Perform Statellocal notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11

~ctivate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A 13 Perform NRC notifications Communicator Emergency Planning Irraining Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security

~ecurity Training Program PALISADES Page 64

PALISADES ON-SHIFT STAFFING ANALYIS REPORT I.

Accident Analysis #9 - Control Room Fire Requiring Evacuation and Remote Shutdown PALISADES

1.

Accident Summary This event involves a large transient fire requiring evacuation of the Control Room. The event has the potential to include shorts and/or spurious signals producing potential LOCA pathways and/or incorrect system lineup for shutdown.

2.

Accident Specific Assumptions Made The Nuclear Control Operator will initiate a manual reactor trip prior to evacuating the control room.

The Shift Manager will make the plant announcement prior to evacuating the control room.

3.

Procedures for Accident Response AOP-40 Rev. 0, Fire Which Threatens Safety Related Equipment AOP-41 Rev. 0, Alternate Safe Shutdown Procedure EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4.0 Rev. 52, Operations Organization, Responsibilities and Conduct Page 65

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1-ON-SHIFT POSITIONS Analysis #9 - CR Evacuation & Remote SO Line Augmentation Role in Table Unanalyzed TMS On-shift Position Basis Document Elapsed Time 51 Line #

Task?

Required?

(min)

T2/L 1 T5/L 1 Emergency Plan T5/L3 1

Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A T3/L 1 No No Operator #2 Figure 5-2 8

Nuclear Plant Emergency Plan N/A T3/L2 No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A T3/L3 No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A T3/L4 No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A T3/L5 No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 N/A No No Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 N/A No No Figure 5-2 Security 16 Security Contingency Plan N/A N/A No No Emergency Plan Figure 5-2 PALISADES Page 66

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #9 - CR Evacuation & Remote SD Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 1

Shift Manager Shift Manager Licensed Operator Training Program Unit Supervisor CRS Licensed Operator 2

Training Program Shift Technical Advisor STA Licensed Operator 3

Training Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 Irraining Program 6

~uxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 Irraining Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line #

Generic Title/Role On-Shift Position Task Analysis Controlling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 67

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #9 - CR Evacuation & Remote SO Line Performed by Task Analysis Controlling Method 1

Nuclear Plant Operator #2 Fire Brigade Training 2

Nuclear Plant Operator #3 Fire Brigade Training 3

Nuclear Plant Operator #4 Fire Brigade Training 4

Nuclear Plant Operator #5 Fire Brigade Training 5

Nuclear Plant Operator #6 Fire Brigade Training PALISADES Page 68

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #9 - CR Evacuation & Remote SO L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

0-5 5-10 10-15 15-20 20-25 ~5-30 30-35 35-40 40-45 45-50 50-55 55-60 ~0-65 65-70-75-80-85-90 i E

70 75 80 85

~

1 In-Plant Survey: N/A I

2 On-site Survey: N/A I

3 Personnel Monitoring: N/A 4

~ob Coverage: RP#1 X

X X

X

~upport FB 5

Offsite Rad Assessment:

If/ncluded in Table 5 6

Other site specific RP (describe): N/A 7

Chemistry Function task 1#1 (describe) - N/A 8

Chemistry Function task 1#2 (describe) - N/A

Times are estimated PALISADES Page 69

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Ana!ysis #9 - CR Evacuation & Remote SO Line Function I Task*

On-Shift Position Task Analysis ContrOlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager

~raining Program / EP (ECl )

Drills 2

!Approve Offsite Protective Action N/A N/A Recommendations 3

[Approve content of Statellocal notifications

~hift Manager Emergency Planning trraining Program 4

[Approve extension to allowable dose N/A N/A Licensed Operator 5

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

Emergency Planning Iraining_ Program 6

ERO notification Shift Manager Emergency Planning Training Program 7

[Abbreviated NRC notification for DBT event N/A N/A 8

Complete Statellocal notification form Shift Manager Emergency Planning Training Program 9

Perform Statellocal notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11

~ctivate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A 13 Perform NRC notifications Communicator Emergency Planning

!Training Program 14 Perform other site-specific event notifications N/A N/A e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability N/A N/A PALISADES Page 70

PALISADES ON-SHIFT STAFFING ANALYIS REPORT J.

Accident Analysis #10 - Station Blackout PALISADES

1.

Accident Summary A loss of all offsite AC power occurs and the failure of the emergency diesel generators to start. The SM determines power cannot be restored and declares a SAE on EAlSS1.1.

2.

Accident Specific Assumptions Made At time T-O a loss of all AC power occurs No release occurs

3.

Procedures for Accident Response EOP-3 Rev. 15, Station Blackout Recovery AOP-26 Rev. 0, loss of Spent Fuel Pool cooling SOP-34 Rev. 29, Palisades Plant Computer (PPC) System EMG Emergency Management guideline Page 71

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1-ON-SHIFT POSITIONS Analysis #10 - Station Blackout Line Basis Augmentation Role in Table Unanalyzed TMS On-shift Position Document Elapsed Time 51 Line #

Task?

Required?

(min)

T2/L1 T5/L1 Emergency Plan T5/L3 1

Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8

Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A N/A No No O~erator#4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 No 12 Communicator Figure 5-2 T5/L 13 No 13 Chem Tech Emergency Plan 60 N/A No No Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 N/A No No Figure 5-2 Security Contingency 16 Security Plan I N/A T5/L 15 No No Emergency Plan FiQure 5-2 PALISADES Page 72

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #10 - Station Blackout Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # ~eneric Title/Role pn-Shift Position Task Analysis Controlling Method 1

Shift Manager Shift Manager Licensed Operator Training Program 2

Unit Supervisor CRS Licensed Operator Training Program 3

Shift Technical Advisor STA Licensed Operator

~raining Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1

~raining Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 ITraining Program 6

Auxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 ITraining Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line #

Generic Title/Role On-Shift Position rrask Analysis lControliing Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 73

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIRE FIGHTING Analysis #10 - Station Blackout Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for flrefightlng, first aid or search & rescue.

PALISADES Page 74

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #10 - Station Blackout L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

0-5 5-10 10-15 15-20 ~0-25 25-30 30-35 35-40 140-45 145-50 50-55 55-60 60-65 65-70-75-80-85-90 E

70 75 80 85 1

In-Plant Survey: N/A 2

On-site Survey: N/A 3

Personnel Monitoring: N/A 4

Job Coverage: RP#1 CR for job coverage and CR X

X X

X habitability 5

Offsite Rad Assessment:

IJncluded in Table 5 6

Other site specific RP (describe): N/A 7

Chemistry Function task 1#1 (describe) - N/A 8

Chemistry Function task

~2 (describe) - N/A

Times are estimated Chemistry does not have an assigned chemistry task for 580. Chemistry is available for dose assessment if a release occurs.

PALISADES Page 75

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #10 - Station Blackout Line Function I Task*

On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager Training Program / EP (ECl )

Drills 2

Approve Offsite Protective Action N/A N/A Recommendations 3

Approve content of State/local notifications IShift Manager Emergency Planning Training Program 4

Approve extension to allowable dose N/A N/A Licensed Operator 5

Notification and direction to on-shift staff IShift Manager Irraining Program /

(e.g., to assemble, evacuate, etc.)

Emergency Planning Irraining Program 6

ERO notification

~hift Manager Emergency Planning trraining Program 7

[Abbreviated NRC notification for DBT event N/A N/A 8

Complete State/local notification form Shift Manager Emergency Planning

!Training Program 9

Perform State/local notifications Communicator Emergency Planning Irraining Program 10 Complete NRC event notification form N/A N/A 11

[Activate EROS N/A N/A 12 Offsite radiological assessment N/A N/A 13 Perform NRC notifications Communicator Emergency Planning Irraining Program 14 Perform other site-specific event notifications N/A N/A e.g., Duty Plant Manager, INPO, ANI, etc.}

15 Personnel Accountability Security Security Training Program PALISADES Page 76

PALISADES ON-SHIFT STAFFING ANALYIS REPORT K.

Accident Analysis #11 - LOCAIGeneral Emergency with Release and PAR PALISADES

1.

Accident Summary (Assumed for Staffing Analysis Purpose)

The unit immediately enters a condition requiring the declaration of a General Emergency with indication of a radiological release that results in a dose that exceeds the Environmental Protection Agency's Protective Action Guides beyond the site boundary, necessitating Protective Actions Recommendations.

2.

Accident Specific Assumptions Made No transients other than LOCA are considered.

3.

Procedures for Accident Response EOP-4.0 Rev. 22, Loss of Coolant Accident Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct EI-6.13, Rev. 23, Protective Action Recommendations for Offsite Populations Page 77

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1-ON-SHIFT POSITIONS Analysis #11 - LOCAIGE with PAR Line Basis Augmentation Role in Table Unanalyzed TMS Required?

On-shift Position Document Elapsed Time 51 Line #

Task?

(min)

T2/L 1 T5/L 1 T5/L2 Emergency Plan T5/L3 1

Shift Manager 60 T5/L4 No Yes Figure 5-2 T5/L5 T5/L6 T5/L8 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8

Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 T5/L 12 No Yes Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I N/A T5/L 15 No No Emergency Plan Figure 5-2 PALISADES Page 78

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #11 - LOCAIGE with PAR Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis ContrOlling Method 1

Shift Manager Shift Manager Licensed Operator Training Program 2

Unit Supervisor CRS Licensed Operator Training Program Shift Technical Advisor STA Licensed Operator 3

~raining Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1

~raining Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2

~raining Program 6

~uxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1

~raining Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line #

Generic Title/Role On-Shift Position Task Analysis Controlling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 79

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #11 - LOCAIGE with PAR Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for flrefightlng, first aid or search & rescue.

PALISADES Page 80

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #11-LOCAIGE with PAR L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

~0-25 25-30 35-40 ~0-45 ~5-50 50-55 55-60 ~0-65 65-70-75-80-85-90 E

0-5 5-10 10-15 15-20 30-35 70 75 80 85 1

In-Plant Survey: RP#1 2

pn-site Survey: RP#2 X

X X

3 Personnel Monitoring:

4 Job Coverage: RP#1 reports to the CR to provide RP support X

X X

(including in plant

~urveys) as directed by he SM.

I 5

Offsite Rad Assessment:

See Table 5 6

Other site specific RP (describe): N/A 7

Chemistry Function task 1#1 (describe) N/A 8

Chemistry Function task 1#2 (describe) N/A RP#1 and #2 will perform the above task as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

Chemistry does not have an assigned chemistry task for LOCA. Chemistry is available for dose assessment.

PALISADES Page 81

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #11 - LOCAIGE with PAR Line Function I Task*

On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager

!Training Program / EP (ECl)

Drills 2

~pprove Offsite Protective Action Shift Manager Emergency Planning Recommendations

!Training Program 3

Approve content of State/local notifications Shift Manager Emergency Planning ITraining Program 4

Approve extension to allowable dose Shift Manager Emergency Planning ITraining Program Licensed Operator 5

Notification and direction to on-shift staff Shift Manager Training Program /

(e.g., to assemble, evacuate, etc.)

Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning Training Program 7

fA.bbreviated NRC notification for DBT event N/A Licensed Operator Training Program 8

Complete State/local notification form Shift Manager Emergency Planning Training Program 9

Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11

~ctivate EROS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning

!Training Program 13 Perform NRC notifications Communicator Emergency Planning ITraining Program Perform other site-specific event N/A 14 notifications (e.g., Duty Plant Manager, N/A INPO, ANI, etc.)

15 Personnel Accountability Security

~ecurity Training Program PALISADES Page 82

PALISADES ON-SHIFT STAFFING ANALYIS REPORT L.

Accident Analysis #15 - Steam Generator Tube Rupture with Concurrent Loss of Off-site Power PALISADES

1.

Accident Summary This event analyzes the response of a failure of a steam generator U-tube combined with a loss of offsite power.

2.

Accident Specific Assumptions Made Radiation monitor alarms on the MSLs, condenser air ejector discharge, SG blowdown line, fan room and plant stack before the reactor trip/turbine trip.

Following a reactor trip and turbine trip, the radioactive fluid is released through the steam generator safety or atmospheric dump valves as a result of the loss of normal AC power.

Doses are calculated for an event generated iodine spike, initial activity of 1 ~C I/gm and a spiking factor of 335 (GIS) and a pre-accident iodine spike 40 ~C I/gm (PIS).

Primary to secondary leakage rate of 432 gallons per day is assumed in the unaffected steam generator for the duration of the transient.

3.

Procedures for Accident Response EOP-5.0 Rev. 17, Steam Generator Tube Rupture Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct AOP-24 Rev. 0, SGT leak Page 83

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4.

Tables PALISADES TABLE 1-ON-SHIFT POSITIONS Analysis #15 - Steam Generator Tube Rupture Line Basis Augmentation Role in Table Unanalyzed TMS Required?

On-shift Position Document Elapsed Time 51 Line #

Task?

(min)

T2/L1 T5/L1 Emergency Plan T5/L3 1

Shift Manager 60 TS/L5 No Yes Figure 5-2 T5/L6 T5/La 2

Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3

Shift Technical Emergency Plan 60 T2/L3 No No

~dvisor Figure 5-2 4

Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5

Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6

Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7

Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure S-2 a

Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9

Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 60 T5/L9 12 Communicator Figure 5-2 T5/L 13 No No 13 Chem Tech Emergency Plan 60 T5/L 12 No Yes Figure 5-2 14 RP#1 Emergency Plan 60 T4/L4 No No Figure 5-2 15 RP#2 Emergency Plan 60 T4/L2 No No Figure 5-2 Security Contingency 16 Security Plan I N/A T5/L 15 No No Emergency Plan Figure 5-2 PALISADES Page 84

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #15 - Steam Generator Tube Rupture Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # !Generic Title/Role On-Shift Position iTask Analysis

~ontrolling Method 1

Shift Manager Shift Manager Licensed Operator Training Program 2

Unit Supervisor CRS Licensed Operator Training Program 3

Shift Technical Advisor STA Licensed Operator Training Program 4

Reactor Operator #1 Nuclear Control Operator Licensed Operator

1 Training Program 5

Reactor Operator #2 Nuclear Control Operator Licensed Operator

2 rrraining Program 6

Auxiliary Operator #1 Nuclear Plant Operator Non-Licensed Operator

1 rrraining Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line #

Generic Title/Role On-Shift Position Task Analysis Controlling Method 7

Mechanic N/A N/A 8

Electrician N/A N/A 9

I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 85

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #15 - Steam Generator Tube Rupture Line Performed by Task Analysis Controlling Method 1

N/A N/A 2

N/A N/A 3

N/A N/A 4

N/A N/A 5

N/A N/A This accident does not Include the need for flrefightlng, first aid or search & rescue.

PALISADES Page 86

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4-RADIATION PROTECTION AND CHEMISTRY Analysis #15 - Steam Generator Tube Rupture L

Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function I Task N

20-25 25-30 30-35 35-40 ~0-45 45-50 50-55 55-60 60-65 65-70-75-80-85-90 E

0-5 5-10 10-15 15-20 70 75 80 85 1

In-Plant Survey: N/A 2

IOn-Site Survey: RP#2 X

X X

3 Personnel Monitoring:

4

~ob Coverage: RP#1 reports to the CR to provide RP support X

X X

(including in plant surveys pnd job coverage) as

~irected by the SM.

5 Offsite Rad Assessment:

See Table 5 6

Other site specific RP (describe): N/A 7

Chemistry Function task

~1 (describe) N/A 8

~hemistry Function task 1#2 (describe) N/A RP#1 and #2 will perform the above tasks as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

Chemistry does not have an assigned chemistry task and is available for dose assessment.

PALISADES Page 87

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #15 - Steam Generator Tube Rupture Line Function I Task*

On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1

Shift Manager rrraining Program / EP (ECl )

Drills 2

Approve Offsite Protective Action N/A Emergency Planning Recommendations rrraining Program 3

Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4

Approve extension to allowable dose N/A Emergency Planning Training Program Licensed Operator 5

Notification and direction to on-shift staff Shift Manager Training Program /

(e.g., to assemble, evacuate, etc.)

Emergency Planning Training Program 6

ERO notification Shift Manager Emergency Planning Training Program 7

jAbbreviated NRC notification for DBT event N/A Licensed Operator Training Program 8

Complete State/local notification form Shift Manager Emergency Planning Training Program 9

Perform State/local notifications Communicator Emergency Planning

~raining Program 10 Complete NRC event notification form N/A N/A 11

~ctivate EROS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning rrraining Program 13 Perform NRC notifications Communicator Emergency Planning

~raining Program Perform other site-specific event N/A 14 notifications (e.g., Duty Plant Manager, N/A INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program PALISADES Page 88

PALISADES ON-SHIFT STAFFING ANALYIS REPORT VIII.

APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS A.

Dose Assessment

1. See Section 11.e.1 for the exception taken for the Chemistry Technician to perform dose assessment. No time motion study or corrective actions is required.

B.

ERO notification (Everbridge activation)

PALISADES TIME MOTION STUDY OF OVERLAPPING TASKS TASK 1: ACTIVATE THE ERO USING EVERBRIDGE JOB: SHIFT MANAGER TASK 2: EMERGENCY DIRECTION AND CONTROL JOB: SHIFT MANAGER PALISADES Page 89

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PURPOSE:

Perform a Time Motion Study to evaluate whether assigning the performance of ERO notification using Everbridge to the Shift Manager or STA can be justified as an acceptable overlap to the Shift Manager's primary emergency plan function of direction and control.

LOCATION:

NOTE The Time Motion Study may be completed during simulator training/evaluation or during EP drills Simulator (to use the "TRAINING" event code to avoid inadvertent ERO activation for an EMERGENCY event.)

Codes are site specific.

REQUIRED TOOLS/EQUIPMENT:

A.

Individual performing the procedure actions must be logged on to the computer being used.

B. PC with Internet 7.0 and internet access.

C. Instructions/codes for activating Everbridge in the TRAINING mode. [Staged Instruction sheet for activating Everbridge may be used in lieu of EN-EP-310, Emergency Response Organization Notification System)]

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Event: ALL Site: Palisades Function Responsibility (Task) 1.Notification 1.1 Initiate notification to the ERO via the ERON Program 2.Emergency 2.1 Maintain emergency Direction and direction and control of the Control event response.

Task Performer:

Bruce Bauer Name Function I Responsibility (Task) Analysis Template Position: Shift Manager Line #: 1 Action Step Retrieve the Everbridge instruction that contains the [TRAINING] Access code and Pass code.

(On the PC) Open ERO Notification System by clicking:

Start -+Nuclear Corporate Apps (ESM) -+ Nuclear Emergency Response (ESM) -+ ERON Enter Access code (XXXXX) and Pass code (XXXXX) and click the SUBMIT button Select the appropriate classification by clicking on it.

(Select ALERT or scenario ECl )

Answer "Yes" or "No" to Security EAL question, 'Was the event declared on a Security EAL?" [ Click on "NO"]

Select proper response action by clicking on it.

[Select "Activate All ERFs"}

Review the message that was generated in the User Message box at the bottom of the screen. Ensure the message contains the information to communicate to the ERO. Additional information can be added to the message by clicking in the User Message box and typing.

Once satisfied with the message content, click send notification button. [Click "Send Notification"]

Answer "YES" to send verification question, "Are you CERTAIN you want to send this message?" [Click "YES"]

If message was successfully sent, you will see a dialog box. [Click "Return"]

END OF INITIATE NOTIFICATION TO ERO TASK Oversight of the emergency response.

Initiate any emergency actions.

END OF EMERGENCY DIRECTION AND CONTROL TASK Position: _-=S:..:.h:..:.:iftc.:...:.:.M:.::a".n,-=a~ge~r,-

Job Title Date: 11/05/2012 Evaluator: _-=D:..=a".n:....:M.:..:.=.a=-=lo"-'n.:;e ____ Position: _-'E=P':--':'M::::a=::.n.:.:a:-=g.,.e.... r_

Name Job Title Date: 11/05/2012 PALISADES Duration 10 seconds 20 seconds 15 seconds 15 seconds 5 seconds 10 seconds 20 seconds 10 seconds 5 seconds 10 seconds 2 minutes (total time)

Maintained Throughout Initiated as required Page 91

PALISADES ON-SHIFT STAFFING ANALYIS REPORT IX.

OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A.

Overlap Requiring Compensatory Measures None X.

CORRECTIVE ACTIONS A.

Corrective Actions and Compensatory Measures None PALISADES Page 92

PALISADES ON-SHIFT STAFFING ANALYIS REPORT XI.

REFERENCES NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.

Palisades Emergency Plan, Rev 26 Palisades Nuclear Plant - License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times (TAC NO. MF2321; ML15055A106)

XII.

STAFFING ANAL VIS TEAM PALISADES The staffing analysis team consisted of plant and Entergy Corporate staff representing the following departments I organizations:

Fleet Emergency Preparedness Project Management Operations Training Security Chemistry Radiation Protection Regulatory Assurance Emergency Planning Engineering 0

Fire Protection 0

Appendix R Page 93 Analysis Summary for Changes in Site Emergency Plan, Revision 29, and On-shift Staffing Analysis, Revision 4 Description of Change:

The changes to the Site Emergency Plan (SEP) include:

1. A note was added to Figure 5-2, "Plant Staffing and Augmentation Requirements," for the position title of Nuclear Plant Operators. Up to two of the six on-shift Nuclear Plant Operator (NPO) positions may be filled by a fire brigade-qualified person who is also minor maintenance-qualified, or alternately by two persons per required NPO (Le., one fire brigade qualified and the other minor maintenance qualified).

2. Changed Reference Document 69, "Palisades Nuclear Station On-shift Staffing Analysis," from Revision 3 to Revision 4.

The Palisades Nuclear Station On-shift Staffing Analysis (OSA) was updated in Revision 4 to align with the Revision 29 update to Figure 5-2 of the SEP above. Specifically, the updates to the OSA include:

3. Updated the text in Section I, "Introduction," that throughout this analysis, references to NPO #5 and #6 are intended to include the option that these positions may be filled by a fire brigade-qualified person who is also minor maintenance-qualified, or, alternately, by two persons per required NPO (Le., one fire brigade-qualified and the other minor maintenance-qualified).

4. Added a parenthetical reference to other qualified personnel for NPO #5 and NPO #6 in the table in Section II.A.

5. Added a parenthetical reference to other qualified personnel in Section 11.0.1.

6. Added Revision 4 to the second paragraph of Section III.

7. Updated the Revision 4 report date in Section I, "Introduction."

Why is the Change Editorial?

Licensing Basis Affected?

Change #2 to the SEP is an editorial change to the revision number of the OSA in the listing of referenced documents.

Changes #6 and #7 to the OSA are considered editorial changes because they add references to the current version of the document and corresponding report date.

The Site Emergency Plan and the On-Shift Staffing Analysis, which is considered to be part of the Emergency Plan, are licensing basis documents.

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How is Compliance Maintained?

Justification That Change Does Not Reduce Effectiveness NPO collateral duties related to the major task of Repair and Corrective Actions continues to be performed by six NPOs, or other qualified personnel possessing the necessary training and expertise to perform minor maintenance actions as directed by the Control Room Supervisor to mitigate an event. Additionally, a five-person Fire Brigade continues to be maintained in accordance with Technical Specifications.

This staffing provides the same level of compliance with this section of 10 CFR 50.47(b) as accepted by the NRC in the latest Safety Evaluation Report (SER) related to this section of the Palisades SEP.

In Revision 23 of the Palisades Nuclear Plant Site Emergency Plan (SEP), two NPOs were added to the on-shift complement depicted in Figure 5-2 in support of the Major Functional Area of Plant Operations and Assessment of Operational Aspects. These positions were added to the on-shift complement for the specific purpose of meeting the Fire Brigade staffing requirements.

On April 22, 2015, the NRC issued Amendment No. 255 to the PNP Renewed Facility Operating License to extend certain emergency response organization (ERO) staff augmentation times. The amendment was issued in response to a PNP letter dated June 25, 2013, as supplemented by letters dated August 7, 2013, and February 13, July 16, and December 9, 2014, and was reflected in SEP Revision 26.

In the NRC's 2015 SER, credit was taken for the "availability of on-shift operators with the necessary training and expertise to perform minor maintenance actions as directed by the control room supervisor to mitigate an evenf' (Major Task "Repair and Corrective Actions" in Figure 5-2). As provided in NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," the repair and corrective actions major task 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 lockoutltagout controls to complete."

The NRC-endorsed guidance contained in NEI 10-05 also states: "Following the guidance contained in 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."

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Considering Revision 23 to the SEP and the 2015 SER, the SEP Revision 29 change to Figure 5-2 does not reduce the overall number of staff credited on-shift to respond to an emergency at PNP, but it does allow for each of up to two of the six on-shift NPO positions to be filled by a fire brigade-qualified person who is also minor maintenance qualified; or alternately by two persons per required NPO (Le., one fire brigade qualified and the other minor maintenance qualified). This change does not cause any of the major tasks identified in the emergency plan to be unassigned, eliminate any key positions identified in the plan, or reassign responsibilities to other key pOSitions resulting in an ERO member being assigned duties that could be expected to be performed concurrently rather than sequentially.

SEP Revision 23 added two NPOs to the on-shift complement. These positions were added to the on-shift complement to meet the Fire Brigade staffing requirements.

The changes to Figure 5-2 for SEP Revision 29 do not include a change to the Fire Fighting Major Functional Area. PNP continues to maintain a five-person Fire Brigade in accordance with Technical Specifications.

To further validate that other personnel could substitute for up to two NPOs as part of the required on-shift complement, Revision 3 of the Palisades Nuclear Station OSA was reviewed for any potential impact. The review did not reveal any responsibilities assigned to the two NPOs (NPOs #5 and #6 (as deSignated in the staffing analysis))

that could not be performed by the substitution of other task-qualified personnel during any evaluated accident scenario. The Palisades Nuclear Station On-Shift Staffing Analysis has been updated (Revision 4) to indicate that the positions of NPOs #5 and #6 can be filled by other personnel. This change will not reduce the capabilities of the on-shift complement or the resources available to the on-shift crew to carry out their emergency response duties in a timely manner.

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ML17269A183

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SUMMARY

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