ML20120A618

Supplement to License Amendment Request to Revise Emergency Plan

ML20120A618
Person / Time
Site:	South Texas
Issue date:	04/29/2020
From:	Capristo A South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-20003732
Download: ML20120A618 (36)

Text

fi Nuclear Operating Company South Texas Project Electric Generating Station P.O. BHX289 Wadamrlh, Texas 77483 April 29, 2020 NOC-AE-20003732 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 & 2 Docket No. STN 50-498, 50-499 Supplement to License Amendment Request to Revise South Texas Project ElectricGeneratinfl Station(STPEGS) EmerflencvPI

References:

1. Letter; A. Capristo to NRC Document Control Desk, "License Amendment Request to Revise South Texas Project Electric Generating Station (STPEGS) Emergency Plan";

March 30, 2020; (NOC-AE-2003712) (ML20090B745).

2. Meeting Summary; D. Galvin; "April 21, 2020, Teleconference Regarding NRC Observations on the March 30, 2020, License Amendment Request to Revise the Emergency Plan STP Nuclear Operating Company South Texas Project, Units 1 and 2, Dockets 50-498 and 50-499"; 4/15/2020; ML20107J548.

By Reference 1, STP Nuclear Operating Company (STPNOC) requested approval of a license amendment to revise the South Texas Project Electric Generating Station (STPEGS)

Emergency Plan. By Reference 2, the NRC provided a list of discussion topics regarding Reference 1 during the acceptance review. STPNOC is providing this Supplement in response to the topics provided in Reference 2. The Supplement is provided in the Enclosure and Attachments to this letter.

There are no commitments in this letter.

If there are any questions or if additional information is needed, please contact Ali Albaaj at (361) 972-8949 or me at (361) 972-7697.

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

Executed on A^Ktt Z^ 2^^<

Aldo Capristo Executive VP and CAO aa

Enclosure:

Supplement to License Amendment Request to Revise South Texas Project Electric Generating Station (STPEGS) Emergency Plan : Task Analysis for Non-Minimum Augmenting Positions Removed from the ERO : ERO Positions Disposition STI:35014293

NOC-AE-20003732 Page 2 of 2 cc:

Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511 STI: 35014293

Enclosure NOC-AE-20003732 Page 1 of 6 ENCLOSURE Supplement to License Amendment Request to Revise South Texas Project Electric Generating Station (STPEGS) Emergency Plan

Enclosure NOC-AE-20003732 Page 2 of 6 NRC Issues/Potential Supplemental Information #1 Section 3.4, "ERO [emergency response organization] Task Analysis," of the application should be revised to only identify non-minimum augmenting (support) ERO positions that are currently identified in the current STPEGS Emergency Plan and provide any justification for the elimination or moving those positions to emergency plan implementing procedures.

STPNOC Response STPNOC developed two additional documents using the ERO task analyses. Attachment 1, Task Analysis for Non-Minimum Augmenting Positions Removed from the ERO details how the tasks assigned to each of the non-minimum augmenting staff positions being removed from the ERO were dispositioned. During the creation of this document, it was identified that a non-minimum augmenting (support) position titled Security Coordinator was inadvertently omitted from the table on page 26 of Enclosure 1 provided in the original License Amendment Request (LAR) submittal. STPNOC is adding Security Coordinator as an EOF support position retained in implementing procedures. Additionally, IT Technician was incorrectly listed in the table on page 25 of Enclosure 1 provided in the original LAR submittal, when Communications System Supervisor should be the listed title. , ERO Positions Disposition, shows a direct cross-reference for the proposed emergency plan minimum and non-minimum (support) augmenting ERO positions to the current emergency plan ERO positions (including augmentation time requirements) and how they were dispositioned. This cross-reference is provided for information regarding title changes.

NRC Issues/Potential Supplemental Information #2 Section 3.6, "Approved to Current E-Plan Comparison Analysis," of the application identifies nine reduction in effectiveness changes that were made by the licensee in previous revision of the STPEGS Emergency Plan. Is STPEGS requesting the NRC to approve plan changes that have already been implemented by licensee as not constituting a reduction in effectiveness?

STPNOC Response STPNOC is not requesting the NRC to approve plan changes that have already been implemented.

In Section 3.6 of Enclosure 1 provided in the original LAR, STPNOC stated that changes involving Reductions in Effectiveness (RIEs) were identified. These RIEs were in fact potential RIEs that were evaluated under 10 CFR 50.54(q). To satisfy change review requirements of Reg Guide 1.219, Revision 1, differences between the content of those NRC-approved documents and the current STPEGS Emergency Plan were evaluated to determine whether any RIEs were introduced by iterative changes made to what was originally approved by the NRC.

The information provided in Section 3.6 of Enclosure 1 provided in the original LAR submittal was developed and included as part of a comprehensive analysis of all STP current Emergency Plan content. The analysis identified nine changes that, without context or the original effectiveness evaluations (which are only required to be retained for 3 years from the date of implementation), could be considered a reduction in effectiveness. The history of these nine changes were assessed to document that they were not reductions in effectiveness and were

Enclosure NOC-AE-20003732 Page 3 of 6 appropriate for the proposed Emergency Plan. Each potential RIE evaluated was found to not be a reduction in effectiveness.

NRC Issues/Potential Supplemental Information #3 Section E, "Notification Methods and Procedures," of the proposed STPEGS Emergency Plan states:

During emergencies that may require the implementation of protective actions, the general public will be alerted by the PNS [Prompt Notification System], which consists of systems and methods as detailed in the FEMA (Federal Emergency Management Agency) PNS Design Report.

More detail is needed in the proposed Section E of the STPEGS Emergency Plan to address licensee requirements in Section IV.D.3 to Appendix E of 10 CFR Part 50. Simply referencing a FEMA Alert and Notification System Design Report is inadequate as previously discussed by NRC staff with industry.

STPNOC Response STPNOC is revising Section E.2 of Enclosure 2 of the proposed STPEGS Emergency Plan provided in the original LAR submittal to provide adequate detail regarding the FEMA Alert and Notification System Design Report. Below is the revised Section E.2 of the proposed Emergency Plan that was provided in Enclosure 2 of the original LAR submittal.

The alert and notification systems (ANSs) used to alert and notify the general public within the plume exposure pathway EPZ and methods of activation are described. This description includes the administrative and physical means, the E.2 time required for notifying and providing prompt instructions to the public within the plume exposure pathway EPZ, and the organizations or titles/positions responsible for activating the system.

In the event public notification is required, both transient and resident populations within the ten-mile EPZ will be initially notified through the Prompt Notification System (PNS) and by the Matagorda County officials.

• The general public (resident and transient population) are notified of an Unusual Event through press releases, radio broadcasts, and other news media.

• The general public are notified of Alert or higher declarations through news advisories and/or Emergency Alert System messages prepared by Matagorda County Emergency Management officials.

During emergencies that may require the implementation of protective actions, the general public will be alerted by the PNS, which consists of the following primary and backup subsystems.

Primary subsystems:

• IPAWS-WEA (Integrated Public Alert Warning System) - (Wireless Emergency Alerting)

• IPAWS-EAS (Emergency Alert System)

Enclosure NOC-AE-20003732 Page 4 of 6

• IPAWS-NET (Internet Services)

Backup subsystems:

• Autodial

• Route Alerting

• National Weather Service / All Hazards Radios

• Emergency Alert System The primary subsystems act as parallel, simultaneous systems using IPAWS. The secondary, backup subsystems are used if the primary subsystems are unavailable.

The Matagorda County Sheriffs Office maintains a 24-hour capability to receive, authenticate, and disseminate notifications/warnings to the public within the Stations Plume Exposure Pathway Emergency Planning Zone. Authenticated notifications are disseminated to the public within about fifteen minutes of receipt from the State or County, if required by the emergency classification.

Additional notification and information will be provided to the transient and resident populations as well as the general public within the ten-mile EPZ through the Emergency Alert System. The NOAA weather alert radio channel and local radio stations are the local sources for information regarding public emergency response actions.

STPEGS is responsible for maintenance and routine testing in accordance with the PNS Design Report.

NRC Issues/Proposed Changes #1 Elimination of one of two Shift Managers - Basis was previously used by the staff to approve the extension of command and control in the technical support center/emergency operations facility (TSC/EOF) from 60 minutes to 90 minutes. As such, proposed changes undercuts NRC basis for approving recently approved ERO changes.

STPNOC Response STPNOC is supplementing Section 3.2.1 of Enclosure 1 of the original LAR submittal to add additional statements to ensure clarity regarding the positional title change of the second Shift Manager to an SRO.

The proposed Emergency Plan does not eliminate the second Shift Manager. The second Shift Manager is changed to a dedicated on-shift SRO (dedicated meaning it is not one of the technical specification SRO positions required for plant operations). Qualification requirements for the dedicated on-shift SRO are equivalent to the Shift Manager regarding the EP functions of Command & Control and Emergency Classification, which include the training and evaluation criteria for ERO Key Position requirements, thus there is no impact on the existing capability or timeliness to perform this function. This title change would provide administrative shift staffing flexibility consistent with operations technical specification staffing requirements based on unit operating mode(s).

Enclosure NOC-AE-20003732 Page 5 of 6 NRC Issues/Proposed Changes #2 Elimination of maintenance technicians/maintenance supervision from on shift - Basis was used previously by the staff to approve the extension of engineering support in the TSC from 60 minutes to 90 minutes. As such, proposed changes undercuts NRC basis for approving recently approved ERO changes.

STPNOC Response In a previous License Amendment Request (LAR) dated July 31, 2017, STPNOC requested a 90 minute response time for minimum augmenting members of the ERO that provide the functional area of Engineering (i.e., Mechanical, Electrical, and Nuclear Engineer). While dispositioning this extension for augmentation time, STPNOC took credit for on-shift maintenance staff (i.e., Mechanical, I&C, and two Electrical Technicians) being available to provide troubleshooting and minor repairs during an emergency. STPNOC is now requesting maintenance staff to be minimum augmenting members of the ERO (60 minute response time for the Mechanical and Electrical Technician, 90 minute response time for the I&C Technician) while maintaining 90 minute augmentation times for ERO members in the functional area of Engineering. STPNOC believes that this request continues to meet the planning standard of 10 CFR 50.47(b)(2) and the requirements of Section IV.A to Appendix E of 10 CFR Part 50.

The robust nature of the STP 3-train safety system reduces the likelihood of repair activities needed to restore or maintain safety system functionality compared to plant designs with only two such trains. The proposed Emergency Plan provides maintenance technicians at 60 minutes who have the necessary training and expertise to troubleshoot and initiate any such repairs. Additionally, the proposed Emergency Plan provides for a maintenance supervisor (Maintenance Coordinator) at 60 minutes. The Maintenance Coordinator has expertise and experience with directing emergent troubleshooting and repair activities during plant operations.

The Maintenance Coordinator will also provide the maintenance technicians with supervision while supporting the operations crew with analysis, troubleshooting, and repair planning necessary to maintain or restore safety system functionality.

In addition to the considerations made in the LAR dated July 31, 2017, such as the improvements in plant monitoring, training, and Emergency Operating Procedures (EOPs), STP has several design and process considerations which support a 90 minute response time for the Nuclear, Mechanical and Electrical Engineer ERO positions in conjunction with a 60 minute response time for the Mechanical and Electrical Technician and a 90 minute response time for the I&C Technician.

1. STP OSC is a dedicated facility that does not require setup prior to activation, therefore no maintenance personnel are required to complete this task.

2. Task analysis and EOP procedural actions for design basis and select emergency plan events validate required Operations and EP response tasks for the first 60 minutes do not require support from maintenance personnel. As an example, in the case of a Station Blackout event, emergency procedures only rely upon on-shift Operations personnel to complete tasks for the first 60 minutes, including required vital bus load shed actions to assure coping times are achieved.

Enclosure NOC-AE-20003732 Page 6 of 6 The robust STP design and the resources represented by the Electrical and Mechanical maintenance technicians and supervision at 60 minutes, demonstrate that this initial phase of an event will not involve a need for detailed engineering analysis. Therefore, the augmentation of the one Electrical Engineer, one Mechanical Engineer, and one Nuclear Engineer to the TSC within 90 minutes of declaration of an Alert or higher emergency classification will provide the required support for the engineering functions.

Attachment 1 NOC-AE-20003732 Page 1 of 22 ATTACHMENT 1 Task Analysis for Non-Minimum Augmenting Positions Removed from the ERO

Attachment 1 NOC-AE-20003732 Page 2 of 22

1. INTRODUCTION This analysis provides summary and detailed tables that list and evaluate the disposition of the tasks assigned to each of the non-minimum augmenting positions being removed from the Emergency Response Organization (ERO).

The task analysis was performed as follows:

• Identify the individual tasks assigned to the ERO positions contained in current Emergency Plan and Implementing Procedures.

• Disposition tasks to ERO positions in the proposed Emergency Plan.

o If an ERO position was eliminated, generic tasks (such as reporting to facility or keeping logs) were considered eliminated with the position as non-RIEs.

o If an ERO position was eliminated, non-generic tasks are verified as performed by a remaining ERO position.

• Reviewed to ensure that re-assignment of tasks did not result in an overburdening of a remaining position.

2.

SUMMARY

The current Emergency Plan specifies two IT Technician 90 minute minimum augmenting positions (one is located in the TSC and one is located in the EOF) and one Communications System Supervisor non-minimum position for the IT function. The proposed Emergency Plan has made two changes to the positions that perform the IT function:

1. The TSC IT Technician position has been removed (see Submittal Enclosure 1 Section 3.2.8).

2. The EOF IT Technician and the Communications System Supervisor positions have been merged and re-titled as the IT Coordinator 90-minute minimum augmenting position.

All tasks assigned to the below non-minimum augmenting (support) ERO positions contained in the current Emergency Plan and implementing procedures continue to be performed by the remaining ERO positions in the proposed Emergency Plan:

Non-Minimum Augmenting Staff Determined to be Removed TSC EOF

• Assistant TSC Manager

• Deputy EOF Director

• Assistant Ops Manager

• EOF Liaison

• Assistant Rad Manager

• Engineering Assistant

• Engineering Supervisor

• Site Public Affairs Coordinator

• Chem/Radiochemical Manager

• Radiological Staff

• Operations Communicator

• Administrative Staff

• Rad Status Board Keeper

• Records Supervisor

• Administrative Staff

• Support Orientation Coordinator OSC

• Communications System Supervisor

• Resource Coordinator

• Employee Support

• Security Coordinator

• EOF Director Admin Assistant

• Mechanical Maintenance Planner

• Technical Staff

• Electrical Maintenance Planner

• Assistant Licensing Director

Attachment 1 NOC-AE-20003732 Page 3 of 22

• I&C Maintenance Planner

• Public Affairs Specialist

• Chemistry Discipline Lead

• Radiological Status Board Keeper

• OSC Communicator

• Procurement/Resources Supervisor

• Materials Handler

• Federal Response Agency Liaison

• Materials Engineer

• Purchaser The ERO task analysis indicates that the capability to perform the Emergency Plan functions is maintained and continues to be met without task overlap or overburden to any remaining ERO position.

Attachment 1 NOC-AE-20003732 Page 4 of 22 Notes: The current Emergency Plan and implementing procedures were used to identify specific tasks related to the planning standards and functions.

For purposes of general task categorization, the function associated with each task below is determined from those listed in NUREG-0654 Revision 2 Table B-1. Additional categorization is possible by alignment to planning standard functions as given in IMC 0609 Appendix B dated 09/22/15, but is not necessary for this review.

TSC Assistant TSC Manager Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks are 10 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Task performed by other Manage facility emergency response activities Supervision / Task performed by TSC Manager position Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Emergency Classifications / Task performed by TSC Task performed by other Assist with emergency classification Manager, Engineering Coordinator, Operations positions Coordinator and TSC RP Coordinator Task performed by other Communications / Task performed by EOF S/C Support completion of the ENF to State and County authorities position Communicator Ensure flow of information within and between the emergency Task performed by other Communications / Task performed TSC Manager response facilities position Task performed by other Supervision / Task performed by TSC Manager and Ensure minimum staff is available (facility staffed) positions TSC Administrative Assistant Task performed by other Maintain status and information boards/displays General / Task performed by TSC Status Board Keeper position Supervision / All facility staff support relocations.

Task performed by other Support facility relocation Specific task assigned to Engineering Coordinator, positions Operations Coordinator and Maintenance Coordinator.

Task performed by other Provide support and logistics for site assembly activities Protective Action / Task performed by OSC personnel positions Task performed by other Coordinate site evacuation Protective Action / Task performed by TSC Manager position Task performed by other Supervision / Task performed by Operations Support first aid activities positions Coordinator and RP Coordinator Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 5 of 22 Engineering Supervisor Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks are 6 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Task performed by other Supervision / Task performed by Engineering Manage assigned group emergency response activities position Coordinator Prioritize and authorize requests for external assistance Task performed by other Supervision / Task performed by TSC Manager (technical, craft, admin, etc.) position Task performed by other Determine current/projected staff needs Supervision / Task performed by TSC Manager position Supervision / All facility staff support relocations.

Task performed by other Specific task assigned to Engineering Coordinator, Support facility relocation positions Operations Coordinator and Maintenance Coordinator to assure they are familiar with process.

Task performed by other Protective Action / Task performed by OSC RP Provide support and logistics for site evacuation activities position Supervisor Recovery / Key positions determine who supports Task performed by other Develop recovery plans development of recovery plan based on type and positions magnitude of each event Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 6 of 22 Assistant Operations Manager Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks are 11 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Task performed by other Manage facility emergency response activities Supervision / Task performed by TSC Manager position Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Task performed by other Supervision / Task performed by Operations Assist with emergency classification position Coordinator Task performed by other Supervision / Several facility supervisors and Determine current/projected staff needs positions coordinators are task with assuring appropriate staffing Task performed by other Supervision / Task performed by Operations Support facility relocation position Coordinator Task performed by other Assessment / Task performed by Operations Monitor status of the Emergency Operations Procedures positions Coordinator and Engineering Coordinator Task performed by other Assessment / Task performed by Operations Determine and direct site response priorities position Coordinator Coordinate between CR, OSC and TSC to set OSC Team task Task performed by other Repair Team Activities / Task performed by Operations priorities position Coordinator Communicate the activities of Ops personnel dispatched out of Task performed by other Communications / Task performed by Operations the CR to the OSC position Coordinator Direct/support site assembly, accountability and search & Task performed by other Protective Action / Task performed by Operations rescue activities position Coordinator Task performed by other Protective Action / Task performed by Operations Support first aid activities position Coordinator Recovery / Task eliminated with position, key positions Task performed by other Develop recovery plans determine who supports development of recovery plan positions based on type and magnitude of each event Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 7 of 22 Operations Communicator Task Disposition Summary Conclusion Capability to perform the Emergency Plan function associated with the task is 1 task performed by other ERO position.

maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Communicate on assigned communication line and provide Task performed by other Communications / Task performed by Operations information to facility staff position Coordinator Assistant Radiological Manager Task Disposition Summary Conclusion 2 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks are 9 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Task performed by other Manage assigned group emergency response activities Supervision / Task performed by TSC RP Coordinator position Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Task performed by other Direct/coordinate facility relocation Supervision / Task performed by TSC Manager position Monitor, evaluate and communicate conditions involving any Task performed by other Assessment / Task performed by TSC RP Coordinator release of radioactivity position Task performed by other Record/review radiological sampling and survey data Assessment / Task performed by TSC RP Coordinator position Task performed by other Protective Action / Task performed by TSC RP Provide support and logistics for site assembly activities position Coordinator Task performed by other Coordinate site evacuation Protective Action / Task performed by TSC Manager position Task performed by other Radiation Protection / Task performed by TSC RP Evaluate the need for and ensure proper use of KI position Coordinator Task performed by other Radiation Protection / Task performed by TSC RP Ensure approved emergency exposure controls are issued position Coordinator Ensure habitability is established and maintained for occupied Task performed by other Radiation Protection / Task performed by TSC RP onsite areas position Coordinator

Attachment 1 NOC-AE-20003732 Page 8 of 22 Radiological Status Board Keeper Task Disposition Summary Conclusion 2 administrative tasks eliminated with position. Tasks moved to other remaining ERO positions are consistent and compatible with their existing tasks.

2 tasks moved to other ERO positions.

Capability to perform the Emergency Plan functions associated with the tasks are maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Communicate on assigned communication line and provide key Task Moved Communications / Task moved to TSC RP Coordinator information to facility staff Administration / Task moved to TSC Status Board Maintain status and information boards/displays Task Moved Keeper Administrative Staff Task Disposition Summary Conclusion 1 administrative task eliminated with position. Task moved to other remaining ERO position is consistent and compatible with their existing tasks.

2 tasks performed by other ERO positions.

Capability to perform the Emergency Plan function associated with the tasks is 1 task moved to other ERO position. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Respond as directed when notified of an event (sign in, get N/A when Position Eliminate N/A when position eliminated materials, etc.)

Prepare for facility activation (rooms, work area, equipment, Task performed by other Administration / Task performed by TSC Status Board etc.) position Keeper Administration / Task moved to TSC Administrative Provide administrative support for facility operation Task Moved Assistant Task performed by other Administration / Task performed by TSC Administrative Distribute forms, reports, etc. as needed position Assistant

Attachment 1 NOC-AE-20003732 Page 9 of 22 Chemistry/Radiochemistry Manager Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Task eliminated from ERO as an operational tasks performed by the normal organization per NUREG-0654 R2.

10 tasks performed by other ERO positions.

Capability to perform the Emergency Plan functions associated with the tasks are 1 task eliminated as an ERO activity. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Supervision / Chem/Rad Chem Manager had no Task performed by other subordinate staff in the TSC, although the position was Manage assigned group emergency response activities position matrixed to OSC Chem lead, which shared control of the Chemistry Technicians under the OSC hierarchy.

Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Communications / Task performed by EOF S/C Perform offsite emergency notifications to State and County Task performed by other Communicator. EOF and staff activated concurrent with authorities position TSC at Alert ECL in proposed E-Plan and process now goes directly from CR to EOF Communications / Task performed by EOF S/C Task performed by other Communicator. EOF and staff activated concurrent with Support completion of the ENF to State and County authorities position TSC at Alert ECL in proposed E-Plan and process now goes directly from CR to EOF Provide event data and plant information to the NRC via the Task performed by other Communications / Task performed by dedicated ENS ENS positions Communicator present on shift and throughout event Supervision / All facility staff will support relocation.

Task specifically performed by TSC Manager, Task performed by other Support facility relocation Engineering Coordinator, Operations Coordinator, positions Maintenance Coordinator to ensure appropriate familiarization training of task.

Monitor, evaluate and communicate conditions involving any Task performed by other Assessment / Task performed by TSC RP Coordinator release of radioactivity position Assessment / Per NUREG-0654 R2 Chemistry/Rad Chemistry function is no longer required. The need for Record/review chemical sampling and analysis Task Eliminated immediate reactor coolant sampling has been reduced due to the variety of plant indications of fuel damage.

Provide analysis of core damage and fission product release Task performed by other Assessment / Task performed by Nuclear Engineer potential position Task performed by other Supervision / Task performed by OSC Team Coordinate OSC Team dispatch and control position Coordinator

Attachment 1 NOC-AE-20003732 Page 10 of 22 Assigned Tasks Disposition Function / Justification Task performed by other Protective Action / Task performed by TSC RP Provide support and logistics for site assembly activities position Coordinator Task performed by other Protective Action / Task performed by TSC RP Provide support and logistics for site evacuation activities position Coordinator Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated OSC Chemistry Lead Task Disposition Summary Conclusion Task eliminated from ERO as an operational task performed by the normal organization 1 task eliminated as an ERO activity.

per NUREG-0654 R2.

Assigned Tasks Disposition Function / Justification Assessment / Per NUREG-0654 R2 Chemistry/Rad Chemistry function is no longer required. The need for Participate with OSC Team dispatch and control Task Eliminated immediate reactor coolant sampling has been reduced due to the variety of plant indications of fuel damage.

Materials Handler Task Disposition Summary Conclusion 2 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks is 2 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Task performed by other Support Action / Task performed by TSC Administrative Arrange for equipment and supply resources positions Assistant and TSC Maintenance Coordinator Task performed by other Supervision / Task performed by TSC Maintenance Determine current/projected staff needs position Coordinator Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 11 of 22 Resource Coordinator Task Disposition Summary Conclusion Capability to perform the Emergency Plan function associated with the task is 1 task performed by other ERO position.

maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Task performed by other Support Action / Task performed by TSC Administrative Arrange for equipment and supply resources position Assistant and TSC Maintenance Coordinator Security Coordinator Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Tasks moved to other remaining ERO positions are consistent and compatible with their existing tasks.

3 tasks performed by other ERO positions.

Capability to perform the Emergency Plan functions associated with the tasks are 4 tasks moved to other ERO positions.

maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Task performed by other Supervision / Task performed by TSC Maintenance Coordinate ERO/facility shift turnover positions Coordinator and OSC Coordinator Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Task performed by other Supervision / Task performed by Shift Security Force Manage assigned group emergency response activities position Supervisor Respond as directed when notified of an event (sign in, get N/A when position eliminated General / Task eliminated with position materials, etc.)

Repair Team Activities / Task moved to TSC Security Participate with OSC Team dispatch and control Task Moved Coordinator Direct/support site, evacuation, assembly, accountability and Protective Action / Task moved to TSC Security Task Moved search & rescue activities Coordinator Protective Action / Task moved to TSC Security Provide support and logistics for site assembly activities Task Moved Coordinator Direct facility/site access controls activities Task Moved Supervision / Task moved to TSC Security Coordinator Task performed by other Support first aid activities Protective Action / Task performed OSC Coordinator position Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 12 of 22 OSC Communicator Task Disposition Summary Conclusion 1 administrative task eliminated with position. Capability to perform the Emergency Plan function associated with the task is 1 task performed by other ERO position. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Communicate on assigned communication line and provide Task performed by other Communications / Task performed by Team information to facility staff position Coordinator Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated Maintenance Planners Task Disposition Summary Conclusion No ERO tasks assignments. Support provided related to normal jobs activities, not ERO response actions.

Assigned Tasks Disposition Function / Justification Position shown in Current Plan Org Char - No tasks listed in plan or EPIPs. Responsibilities only involved normal job N/A N/A activities EOF Deputy EOF Director Task Disposition Summary Conclusion Tasks moved to other remaining ERO positions is consistent and compatible with their 4 administrative tasks eliminated with position. existing tasks.

27 tasks performed by other ERO positions. Task eliminated identified as a procedure error where process had been revised. Task 2 tasks moved to other ERO positions. is no longer applicable.

1 task eliminated as an ERO activity. Capability to perform the Emergency Plan functions associated with the tasks are maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Coordinate response activities with offsite response agencies Task performed by other Supervision / Task performed by EOF Manager (EM, ICP, Field Mon, etc.) position Task performed by other Interface with executive officers of station owners Supervision / Task performed by EOF Manager position Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Task performed by other Command and Control / Task performed by EOF Assume/maintain command and control position Manager

Attachment 1 NOC-AE-20003732 Page 13 of 22 Assigned Tasks Disposition Function / Justification Task performed by other Command and Control / Task performed by EOF Transfer command and control position Manager Task performed by other Manage facility emergency response activities Supervision / Task performed by EOF Manager position Task performed by other Manage assigned group emergency response activities Supervision / Task performed by EOF Manager position Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Task performed by other Coordinate integration of the NRC site team Supervision / Task performed by Licensing Advisor position Support State/County EOC Liaisons Task Moved Supervision / Task moved to Licensing Advisor Prioritize and authorize requests for external assistance Task performed by other Supervision / Task performed by EOF Manager (technical, craft, admin, etc.) position Approve equipment, supply, and logistics expenditures for Task performed by other Supervision / Task performed by EOF Manager response to the event position Task performed by other Emergency Classifications / Task performed by EOF Classify and declare emergencies position Manager Approve and direct offsite emergency notifications to State and Task performed by other Communications / Task performed by EOF Manager County authorities position Task performed by other Direct notifications and ENS communications with the NRC Communications / Task performed by EOF Manager position Ensure flow of information within and between the emergency Task performed by other Communications / Task performed by EOF Manager response facilities position Task performed by other Approve/review news releases General / Task performed by EOF Manager position Communications / Artifact from period where JIC was not activated for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Current process Perform media briefings and interviews Task Eliminated provides corporate and public information personnel prior to and immediately upon emergency declaration for briefings and interviews. Press not allowed in EOF.

Determine current/projected staff needs Task Moved Supervision / Task moved to EOF Manager Task performed by other Activate the facility (facility activated) Communications / Task performed by EOF Manager position Task performed by other Direct preparations and brief personnel Supervision / Task performed by EOF Manager position Ensure minimum staff is available and prepared to activate the Task performed by other Administration / Task performed by EOF Manager facility position Direct/support site assembly, accountability and search & Task performed by other Supervision / Task performed by EOF Manager rescue activities position

Attachment 1 NOC-AE-20003732 Page 14 of 22 Assigned Tasks Disposition Function / Justification Task performed by other Radiation Protection / Task performed by EOF Approve use of KI position Manager Task performed by other Approve offsite Protective Action Recommendations Protective Action / Task performed by EOF Manager position Task performed by other Radiation Protection / Task performed by EOF Approve emergency exposures position Manager Task performed by other Protective Action / Task performed by EOF RP Coordinate the monitoring of site evacuees position Coordinator Task performed by other Emergency Classifications / Task performed by EOF Terminate the emergency event position Manager Recovery / Key positions determine who supports Task performed by other Develop recovery plans development of recovery plan based on type and positions magnitude of each event Task performed by other Authorize and direct BDB/extreme measures Supervision / Task performed by EOF Manager position Task performed by other Coordinate security activities Supervision / Task performed by EOF Manager position Task performed by other Conduct facility briefs and updates Administration / Task performed by EOF Manager position Maintain event logs, forms and records N/A when position eliminated Administration / Task eliminated with position Restore work area equipment and materials N/A when position eliminated Administration / Task eliminated with position EOF Director Admin Assistant Task Disposition Summary Conclusion No ERO tasks assignments. Support provided related to normal jobs activities, not ERO response actions.

Assigned Tasks Disposition Function / Justification Position shown in Current Plan Org Char - No tasks listed in plan or EPIPs. Responsibilities only involved normal job N/A N/A activities

Attachment 1 NOC-AE-20003732 Page 15 of 22 EOF Liaison Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Task moved to other remaining ERO position is consistent and compatible with their existing tasks.

4 tasks performed by other ERO positions.

Capability to perform the Emergency Plan functions associated with the tasks are 1 task moved to other ERO position. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Task performed by other Interface with executive officers of station owners Communications / Task performed by EOF Manager position Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Provide event notification/information to industry groups (INPO, Task performed by other Communications / Task performed by Media Relation ANI, etc.) position Staff Ensure flow of information within and between the emergency Task performed by other Communications / Task performed by EOF Manager response facilities position Communicate on assigned communication line and provide Task Moved Communications / Task moved to Licensing Advisor information to facility staff Recovery / Key positions determine who supports Task performed by other Develop recovery plans development of recovery plan based on type and positions magnitude of each event Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 16 of 22 Engineering Assistant Task Disposition Summary Conclusion 4 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks are 3 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Perform offsite emergency notifications to State and County Task performed by another Communications / Task performed by S/C authorities position Communicator Task performed by another Assessment Action / Task performed by EOF Perform event detection and assessment activities position Operations Advisor Recovery / Key positions determine who supports Task performed by other Develop recovery plans development of recovery plan based on type and positions magnitude of each event Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated Restore work area equipment and materials N/A when position eliminated N/A when position eliminated Technical Staff Task Disposition Summary Conclusion No ERO tasks assignments. Support provided related to normal jobs activities, not ERO response actions.

Assigned Tasks Disposition Function / Justification No tasks listed in plan or EPIPs. Responsibilities only involved N/A N/A normal job activities

Attachment 1 NOC-AE-20003732 Page 17 of 22 Site Public Affairs Coordinator Task Disposition Summary Conclusion 5 administrative tasks eliminated with position. Task moved to other remaining ERO position is consistent and compatible with their existing tasks.

1 task performed by other ERO position.

Capability to perform the Emergency Plan function associated with the task is 1 task moved to other ERO position. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Manage assigned group emergency response activities N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Task performed by other Media Information / Task performed by JIC Senior Staff Develop news releases, statements and messages position Writer Coordinate distribution of news releases, statements and Communications / Task moved to EOF Administrative Task Moved messages Assistant Communications / Spokesperson will update EOF Provide input for facility briefs and updates N/A when position eliminated Manager on JIC and public information matters Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated Restore work area equipment and materials N/A when position eliminated N/A when position eliminated Public Affairs Specialist Task Disposition Summary Conclusion Task moved to other remaining ERO position is consistent and compatible with their existing tasks.

1 task moved to other ERO position.

Capability to perform the Emergency Plan function associated with the task is maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Coordinate distribution of news releases, statements and Communications / Task moved to EOF Administrative Task Moved messages Assistant Assistant Licensing Director Task Disposition Summary Conclusion No ERO tasks assignments. Support provided related to normal jobs activities, not ERO response actions.

Assigned Tasks Disposition Function / Justification No tasks listed in plan or EPIPs. Responsibilities only involved N/A N/A normal job activities

Attachment 1 NOC-AE-20003732 Page 18 of 22 Radiological Staff Task Disposition Summary Conclusion No ERO tasks assignments. Support provided related to normal jobs activities, not ERO response actions.

Assigned Tasks Disposition Function / Justification No tasks listed in plan or EPIPs. Responsibilities only involved N/A N/A normal job activities Radiological Status Board Keeper Task Disposition Summary Conclusion Task moved to other remaining ERO position is consistent and compatible with their existing tasks.

1 task moved to other ERO position.

Capability to perform the Emergency Plan function associated with the task is maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Administrative / Task moved to EOF Status Board Maintain status and information boards/displays Task Moved Keeper Administrative Staff Task Disposition Summary Conclusion Task moved to other remaining ERO position is consistent and compatible with their 2 tasks performed by other ERO positions. existing tasks.

1 task moved to other ERO position. Capability to perform the Emergency Plan function associated with the tasks is maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Task performed by other Administration / Task performed by EOF Administrative Develop facility 24-hour staffing list position Assistant Prepare for facility activation (rooms, work area, equipment, Administration / Task moved to EOF Administrative Task Moved etc.) Assistant Task performed by other Administration / Task performed by EOF Administrative Provide administrative support for facility operation position Assistant

Attachment 1 NOC-AE-20003732 Page 19 of 22 Procurement/Resources Supervisor Task Disposition Summary Conclusion 4 administrative tasks eliminated with position. Capability to perform the Emergency Plan function associated with the tasks is 2 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Develop requests and coordinate external assistance Task performed by other Support / Task performed by EOF Technical Advisor (technical, craft, admin, etc.) position Task performed by other Support / Task performed by EOF Administrative Arrange for logistics support position Assistant Recovery / Key positions determine who supports Develop recovery plans N/A when position eliminated development of recovery plan based on type and magnitude of each event Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated Records Supervisor Task Disposition Summary Conclusion 4 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks are 2 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Task performed by other Administration / Task performed by EOF Administrative Provide administrative support for facility operation position Assistant Recovery / Key positions determine who supports Task performed by other Develop recovery plans development of recovery plan based on type and positions magnitude of each event Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated Restore work area equipment and materials N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 20 of 22 Support Orientation Coordinator Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Capability to perform the Emergency Plan functions associated with the tasks are 3 tasks performed by other ERO positions. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Develop requests and coordinate external assistance Task performed by other Support / Task performed by EOF Technical Advisor (technical, craft, admin, etc.) position Task performed by other Support / Task performed by EOF Administrative Arrange for logistics support position Assistant Recovery / Key positions determine who supports Task performed by other Develop recovery plans development of recovery plan based on type and positions magnitude of each event Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated Federal Response Agency Liaison Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Task eliminated was identified as not performed by utility personnel (responsibility of State agencies). Task no longer applicable.

2 tasks performed by other ERO positions.

Capability to perform the Emergency Plan function associated with the tasks is 1 task eliminated as an ERO activity.

maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Communications / Task performed by EOF Manager, Coordinate response activities with offsite response agencies Task performed by other EOF RP Coordinator and EOF Administrative (EM, ICP, Field Mon, etc.) positions Coordinator Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Ensure flow of information within and between the emergency Task performed by other Communications / Task performed by EOF Manager response facilities position Communicate on assigned communication line and provide Communications / FEMA Site Team communications Task Eliminated information to facility staff controlled through state and county agencies Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated

Attachment 1 NOC-AE-20003732 Page 21 of 22 Materials Engineer Task Disposition Summary Conclusion 3 administrative tasks eliminated with position. Capability to perform the Emergency Plan function associated with the task is 1 task performed by other ERO position. maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs N/A when position eliminated N/A when position eliminated Respond as directed when notified of an event (sign in, get N/A when position eliminated N/A when position eliminated materials, etc.)

Task performed by other Support / Task performed by EOF Administrative Arrange for logistics support position Assistant Maintain event logs, forms and records N/A when position eliminated N/A when position eliminated Communications System Supervisor Task Disposition Summary Conclusion Tasks moved to other remaining ERO position are consistent and compatible with their 1 task performed by other ERO position. existing tasks.

6 tasks moved to other ERO position. Capability to perform the Emergency Plan functions associated with the tasks are maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Perform position turnover when a shift change occurs Task Moved General Action / Task performed by IT Coordinator Respond as directed when notified of an event (sign in, get Task Moved General Action / Task performed by IT Coordinator materials, etc.)

Coordinate information and activities with offsite agency Task Moved Communications / Task performed by IT Coordinator personnel in the facility Activate the Alert Notification System Task Moved Communications / Task performed by IT Coordinator Monitor facility equipment (computer, communications, etc.) for Task performed by other Support / Task performed by IT Coordinator and proper operation position normal on-call IT Department support Maintain event logs, forms and records Task Moved Administration / Task performed by IT Coordinator Restore work area equipment and materials Task Moved Administration / Task performed by IT Coordinator Employee Support Task Disposition Summary Conclusion No ERO tasks assignments. Support provided related to normal jobs activities, not ERO response actions.

Assigned Tasks Disposition Function / Justification No tasks listed in plan or EPIPs. Responsibilities only involved N/A N/A normal job activities

Attachment 1 NOC-AE-20003732 Page 22 of 22 Purchaser Task Disposition Summary Conclusion Capability to perform the Emergency Plan function associated with the task is 1 task performed by other ERO position.

maintained by the ERO without task overlap or overburden.

Assigned Tasks Disposition Function / Justification Task performed by other Support / Task performed by EOF Administrative Arrange for logistics support position Assistant

Attachment 2 NOC-AE-20003732 Page 1 of 6 ATTACHMENT 2 ERO Positions Disposition

Attachment 2 NOC-AE-20003732 Proposed ERO Current ERO Title Response Title Response Disposition On-Shift Shift Manager N/A Shift Manager #1 N/A No Change SRO N/A Shift Manager #2 N/A Title Change Only ENS Communicator N/A ENS Communicator N/A No Change S/C Communicator N/A S/C Communicator N/A No Change STA N/A STA N/A Identified as dedicated position Lead RP Technician N/A Acting Rad Manager N/A No Change RPT #1 N/A RPT #1 N/A No Change RPT #2 N/A RPT #2 N/A No Change Onsite Field Monitoring Tech #1 N/A Moved to 60 minutes OSC Coordinator N/A Moved to 60 minutes I&C Technician N/A Moved to 90 minutes Electrician #1 N/A Moved to 60 minutes Electrician #2 N/A Position eliminated Mechanic N/A Moved to 60 minutes Security Force Supervisor N/A Security Force Supervisor N/A Identified as dedicated position 2 of 6

Attachment 2 NOC-AE-20003732 Proposed ERO Current ERO Title Response Title Response Disposition On-Shift TSC Maintenance Coordinator 60 min Moved to 60 min from Shift / Title Change TSC Manager 90 min TSC Manager 90 min No Change Nuclear Engineer 90 min Nuclear Engineer 90 min No Change Electrical Engineer 90 min Electrical Engineer 90 min No Change Mechanical Engineer 90 min Mechanical Engineer 90 min No Change RP Coordinator 90 min Radiological Manager 90 min Title Change Only Security Coordinator 90 min Security Supervisor 90 min Title Change Only IT Technician 90 min Position eliminated TSC Offsite Communicator 90 min Position eliminated Operations Coordinator 90 min Operations Manager Support Moved to 90 min from Support / Title Change Engineering Coordinator Support Technical Manager Support Title Change Only I&C Engineer Support I&C Engineer Support No Change Administrative Assistant Support Administrative Manager Support Title Change Only Status Board Keeper Support Maintenance Communicator Support Title Change Only Security Manager Support Moved to EOF / Title Change Assistant TSC Manager Support Position eliminated Engineering Supervisor Support Position eliminated Assistant Ops Manager Support Position eliminated Maintenance Manager Support Position eliminated Operations Communicator Support Position eliminated Assistant Radiological Manager Support Position eliminated Administrative Staff Support Position eliminated Radiological Status Board Keeper Support Position eliminated Chemical/Radiochemical Manager Support Position eliminated 3 of 6

Attachment 2 NOC-AE-20003732 Proposed ERO Current ERO Title Response Title Response Disposition On-Shift OSC Mechanic 60 min Moved to 60 min from Shift Electrician 60 min Moved to 60 min from Shift RPT #1 60 min RPT #1 60 min No Change RPT #2 60 min RPT #2 60 min No Change RPT #3 60 min RPT #3 60 min No Change Onsite Field Monitoring Tech #1 60 min Moved to 60 min from Shift Mechanical Supervisor 90 min Mechanical Supervisor 90 min No Change Electrical Supervisor 90 min Electrical Supervisor 90 min No Change I&C Supervisor 90 min I&C Supervisor 90 min No Change I&C Technician 90 min Moved to 90 min from Shift RP Supervisor 90 min Radiological Coordinator 90 min Title Change Only RPT #4 90 min RPT #4 90 min No Change RPT #5 90 min RPT #5 90 min No Change RPT #6 90 min RPT #6 90 min No Change Onsite Field Monitoring Tech #2 90 min Position eliminated OSC Coordinator Support OSC Coordinator 90 min Moved to Support from 90 min Team Coordinator Support Assistant OSC Coordinator Support Title Change Only Ops Supervisor Support Operations Discipline Lead Support Title Change Only Materials Handler Support [EPIP] Position eliminated Chemistry Discipline Lead Support Position eliminated Resource Coordinator Support Position eliminated Security Coordinator Support Position eliminated OSC Communicator Support Position eliminated Electrical Maintenance Planner Support Position eliminated Mechanical Maintenance Planner Support Position eliminated I&C Maintenance Planner Support Position eliminated 4 of 6

Attachment 2 NOC-AE-20003732 Proposed ERO Current ERO Title Response Title Response Disposition On-Shift EOF EOF Manager 90 min EOF Director 90 min Title Change Only S/C Communicator 90 min Offsite Agency Communicator 90 min Title Change Only RP Coordinator 90 min Radiological Director 90 min Title Change Only Offsite Field Monitoring Tech #1 90 min Offsite Rad Monitor #1 90 min Title Change Only Offsite Field Monitoring Tech #2 90 min Offsite Rad Monitor #2 90 min Title Change Only Field Monitoring Driver #1 90 min Offsite Rad Monitor #3 90 min Title Change Only Field Monitoring Driver #2 90 min Offsite Rad Monitor #4 90 min Title Change Only Dose Assessor 90 min Dose Assessor #1 90 min Title Change Only HPN Communicator Support Dose Assessor #2 90 min Moved to Support from 90 min / Title Change IT Coordinator 90 min IT Technician 90 min Title Change Only Technical Advisor 90 min Technical Director Support Moved to 90 min from Support / Title Change Operations Advisor 90 min System Status Evaluator Support Moved to 90 min from Support / Title Change Field Monitoring Coordinator 90 min Offsite Field Team Supervisor Support Moved to 90 min from Support / Title Change Admin Coordinator 90 min Support Organization Director Support Moved to 90 min from Support / Title Change State of Texas EOC Liaison Support State of Texas Liaison Support No Change Matagorda County EOC Liaison Support Matagorda County Liaison Support No Change Licensing Advisor Support Licensing Director Support Title Change Only Status Board Keeper Support Status Board Keeper Support No Change Administrative Assistant Support Assistant Support Org Director Support Title Change Only Security Coordinator Support Moved from TSC / Title Change Access Control EOF Access Control Filled by LLEA Deputy EOF Director Support Position eliminated EOF Director Admin Assistant Support Position eliminated EOF Liaison Support Position eliminated Engineering Assistant Support Position eliminated Technical Staff Support Position eliminated Communications System Supervisor Support Position eliminated Site Public Affairs Coordinator Support Position eliminated Site Public Affairs Specialist Support Position eliminated Assistant Licensing Director Support Position eliminated Radiological Staff Support Position eliminated Radiological Status Board Keeper Support Position eliminated Administrative Staff Support Position eliminated Procurement/Resources Supervisor Support Position eliminated Records Supervisor Support Position eliminated Support Orientation Coordinator Support Position eliminated Federal Response Agency Liaison Support Position eliminated 5 of 6

Attachment 2 NOC-AE-20003732 Proposed ERO Current ERO Title Response Title Response Disposition On-Shift EOF (continued)

Materials Engineer Support Position eliminated Employee Support Support Position eliminated Purchaser Support Position eliminated 6 of 6