ML22242A132

Submittal of Emergency Plan Document Change

ML22242A132
Person / Time
Site:	Indian Point
Issue date:	08/30/2022
From:	Fleming J Holtec Decommissioning International
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
HDI-IPEC-22-063
Download: ML22242A132 (61)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 HOLTE C - - - - - - - - - - - - - - - - - - - - - - - - - -

Telephone (856) 797-0900 oe OMM I SS I ON I NG I NTERNAT I ONAL Fax (856) 797-0909 HDI-IPEC-22-063 10 CFR 50.4 (b)(5) 10 CFR 50.54 (q)(5)

August 30, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Indian Point Nuclear Generating Unit Nos. 1, 2, and 3 Docket Nos.50-003, 50-247, and 50-286 Provisional Operating License No. DPR-5 Renewed Facility License No. DPR-26 Renewed Facility Operating License No. DPR-64

Subject:

Submittal of Emergency Plan Document Change In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.4(b)(5)(iii), Holtec Decommissioning International, LLC (HDI), on behalf of Indian Point Energy Center (IPEC),

hereby submits the Emergency Plan document change entitles Indian Point Energy Center On-Shift Staf"ng Analysis Revision 22-01 as required by 10 CFR 50.54(q)(5) and 10 CFR 50, Appendix E, Section V.

The On-shift Staf"ng Analysis revision was revised to an incipient fire brigade and does not result in a change to Table B-1 of the IPEC Emergency Plan. The On-shift Staf"ng Analysis revision does not affect compliance with 10 CFR 50.47. The revision has been evaluated in accordance with 10 CFR 50.54(q) and does not decrease the effectiveness of the Emergency Plan.

The evaluation and the Indian Point Energy Center On-Shift Staf"ng Analysis Revision 22-01 are provided in the Enclosure. This letter and the enclosed evaluation constitute the summary of analysis required to be submitted by 10 CFR 50.54(q)(5).

This letter contains no new regulatory commitments.

If you have any questions or need further information, please contact Mr. Walter Wittich, IPEC Licensing at 914-254-7212.

Sincerely, Jean A. Fleming Digitally signed by Jean A. Fleming Date: 2022.08.30 11:06:53 -04'00' Jean A. Fleming Vice President, Licensing, Regulatory Affairs and PSA Holtec Decommissioning International, LLC

Enclosure:

Indian Point Energy Center On-Shift Staf"ng Analysis Revision 22-01 and Evaluation

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

HOLTE C - - - - - - - - - - - - - - - - - - - - - - - - - -

Telephone (856) 797-0900 oe OMM I SS I ON I NG I NTERNAT I ONAL Fax (856) 797-0909 cc: NRC Senior Project Manager, NRC NMSS NRC Region l Regional Administrator NRC Senior Regional Inspector, Indian Point Energy Center New York State Liaison Officer Designee, NYSERDA New York State (NYS) Public Service Commission

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104

HOLTE C - - - - - - - - - - - - - - - - - - - - - - - - - -

Telephone (856) 797-0900 oe OMM I SS I ON I NG I NTERNAT I ONAL Fax (856) 797-0909 Enclosure to HDI-IPEC-22-063 Indian Point Energy Center On-Shift Staf"ng Analysis Revision 22-01 and Evaluation

NON-QUALITY RELATED ON-SHIFT DOCUMENT IPEC-EP Rev. 22-01 STAFFING ANALYSIS INFORMATION USE 22-01 INDIAN POINT ENERGY CENTER ON-SHIFT STAFFING ANALYSIS (PHASE 1)

Rev 22-01 August 1 , 2022 Prepared by: Paul Bowe 7 2u?.. z..

Print Name Date Approval: Matt Johnson Print Name IPEC Page 1

IPEC ON-SHIFT STAFFING ANALYIS REPORT TABLE OF CONTENTS Section Title Page I. INTRODUCTION................................................................................................................... 3 II. ANALYSIS

SUMMARY

......................................................................................................... 4 A. Emergency Plan Minimum Staffing ............................................................................ 5 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 IPEC OSA ............................................... 12 B. NEI 10-05 Rev 0 Assumptions ................................................................................. 12 VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS .................................................... 15 VII. APPENDIX B - U2 ON-SHIFT STAFFING ANALYSIS ........................................................ 16 A. Design Basis Accident Analysis #2 - Fuel Handling Accident .................................. 16 B. Design Basis Accident Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling ....................................................................................... 22 C. Design Basis Accident Analysis #5 - General Emergency with Radioactive Release and PAR ................................................................................. 27 VIII. APPENDIX B - COMMON CONTROL ROOM SHIFT STAFFING ANALYSIS .................... 33 A. Design Basis Accident Analysis #1 - Design Basis Threat (DBT) ............................ 33 B. Design Basis Accident Analysis #3 - Aircraft Probable Threat ................................. 38 IX. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS...... 44 A. ERO Notification (Everbridge activation) .................................................................. 44 X. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ....................... 49 A. Overlap Requiring Compensatory Measures. .......................................................... 49 XI. REFERENCES.................................................................................................................... 49 XII. STAFFING ANALYIS TEAM................................................................................................ 49 IPEC Page 2

IPEC ON-SHIFT STAFFING ANALYIS REPORT I. INTRODUCTION On January 9, 2017, Entergy, the Attorney General of the State of New York, and Riverkeeper, Inc. (among other related corporate and governmental entities) entered into a settlement agreement regarding the continued operation of Indian Point Energy Center (IPEC) Unit 2 and Unit 3. Under the agreement, Unit 2 will shut down by April 30, 2020, and Unit 3 will shut down by April 30, 2021, subject to operating extensions through, but not beyond, 2024 and 2025, respectively, under circumstances specified in the agreement. By letter dated February 8, 2018, Entergy certified to the NRC that it has decided to permanently cease power operations at Unit 2 and Unit 3 by April 30, 2020, and April 30, 2021, respectively. Entergy will supplement the February 8, 2018 letter certifying the reactor-specific cessation dates in accordance with Title 10, Code of Federal Regulations (CFR) 50.82(a)(1)(i) and 10 CFR 50.4(b)(9). Once fuel was permanently removed from each reactor vessel, ENO submitted a written certification to the NRC, in accordance with 10 CFR 50.82(a)(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9). Upon docketing of these certifications, the 10 CFR Part 50 licenses no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel, as specified in 10 CFR 50.82(a)(2). In the permanently defueled condition, the Final Safety Analysis Report (FSAR) credible accidents (postulated accidents) are reduced via the 10 CFR 50.59 process. In order to address the transition from an operating facility to a permanently defueled facility, changes are required to maintain the effectiveness of the Emergency Plan and to properly reflect the conditions of the facility.

This report details the preliminary analysis of the proposed on-shift staffing following shutdown of Units 2 and 3, incorporating anticipated changes to the on-shift staffing and postulated accidents to address IPECs post-zirc fire and permanently defueled conditions. Specifically, it reassigns some on-shift tasks to align with proposed changes to Unit 2 and 3 on-shift staffing and the resulting changes to Emergency Plan Implementing Procedures (EPIPs) and reduces the fire brigade from a five-member team to an individual incipient fire brigade. This analysis will be updated and formal Time Motion Studies (TMS) will be conducted, as necessary, following development and validation of procedures that address IPECs permanently shut down and defueled conditions.

This analysis evaluates the ability of the proposed minimum on-shift staff to implement all emergency tasks as applicable to the permanently defueled conditions. This revision continues to satisfy the requirement of 10 CFR 50 Appendix E Section IV.A.9 for Units 1, 2 and 3, 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 IPEC Page 3

IPEC ON-SHIFT STAFFING ANALYIS REPORT Organization Staffing and Capabilities. To support reduced staffing following permanent cessation of power operations and permanent removal of fuel from Units 2 and 3, the proposed on-shift staffing was evaluated in conjunction with the postulated accidents that will be applicable in the permanently shutdown and defueled condition and assumed corresponding changes to procedures. This analysis examined the capability of the minimum staff listed in Table B-1 of the IPEC Emergency Plan (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 analysis determined that a total on-shift staff of six (6) (excluding the required Incipient Fire Brigade) for IPEC units 1, 2 and 3 is required to respond to the accidents reviewed. This consists of three (3) individuals at Unit 2 and three (3) individuals at Unit 3.

With respect to Unit 1, only those areas that either store or process radioactive materials (the Fuel Handling Building and waste storage/process areas in the Chemical Systems Building and the Integrated Liquid Radwaste Systems Building) are considered in evaluating the radiological hazards for the IPEC Emergency Plan. As detailed in the Unit 1 Safety Analysis Report and Decommissioning Plan, there are limited operating systems remaining in Unit 1. The limited operating systems combined with the reduced radioactive source term would result in a limited potential impact to a radiological release resulting from an event at Unit 1. Additionally, all Unit 1 fuel is located on the Independent Spent Fuel Storage Facility (ISFSI) and there are no Emergency Action Levels specific to IPEC Unit 1 that would challenge the on-shift staffing above and beyond those considered in this analysis for Units 2 and 3. For any event that may challenge Unit 1, Unit 2 and 3 staff are available to provide support as needed. As such, the IPEC on-shift staff actions in response to the accidents evaluated for this staffing analysis are bounded by the permanently shutdown and defueled units (Units 2 and 3) and a separate evaluation of the NEI 10-05 required accidents for Unit 1 is not included in the analysis. There are minimal responsibilities specific to Unit 1. These responsibilities consist of conducting a limited scope building tour once per shift and the periodic monitoring of evaporator operation occurring approximately 2 to 3 times/week. These tasks are not time critical and do not impact the Unit 2 or 3 staff members ability to perform assigned Emergency Plan functions and/or tasks. Additionally, the limited Unit 1 tasks are not time critical and can be accomplished by the augmented ERO if required.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT Based on the permanent cessation of power operations and permanent removal of fuel from Units 2 and 3, the most limiting accident scenario reviewed for Units 2 and 3 was a Fuel Handling Accident (FHA) in the Spent Fuel Pool (SFP) that results in the need to declare a General Emergency with radiological release and Protective Action Recommendation (PAR).

The on-shift staff consists of individuals necessary to support each of the emergency plan functional areas or tasks:

Emergency Direction and Control Spent Fuel Pool Cooling Incipient 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.

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).

Only personnel proposed to be on-shift are credited in this analysis. For each unit (Unit 2 and 3), this proposed staffing consists of a Shift Manger; one (1) Non-Certified Operator (Nuclear Plant Operator); and one Radiation Protection (RP) Technician. An individual qualified as a Certified Fuel Handler (CFH) will perform or supervise fuel handling operations in the permanently shut down and defueled condition. The Shift Manager will be qualified as a CFH. The Shift Manager position requires additional qualification beyond the CFH training. Command and Control will remain with the Shift Manager, regardless of location.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT Additionally, shift Security personnel are assigned. The on-shift staffing utilized for this analysis was defined with the following considerations:

The Shift Manager performs as Emergency Director until properly relieved by a qualified position. After being relieved by another Command and Control position, the Shift Manager will provide assistance and direction to the Control Room staff as necessary.

Non-Certified Operator duties include providing technical support for plant systems, providing input on repair and corrective actions, and notifications as directed by the Shift Manager. These notifications include the following:

1) required notifications to the states and local organizations;

2) required notifications to the NRC; and

3) notifications to the ERO.

Non-Certified Operator duties include making repairs and corrective actions on plant equipment until augmented plant maintenance staff arrives and the incipient fire brigade member.

Shift RP Technician duties include conducting radiological accident assessment and support, offsite dose assessment, onsite in plant surveys, and chemistry and radiochemistry analysis.

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. These positions are included in Table 1 of each accident:

On-Shift On-Shift E-Plan E-Plan E-Plan Staffing Staffing Position U2 Functional Functional Requirement Analysis Analysis Area U2 Staff Area U3 Staff Results U2 Results U3 Shift Manager Emergency Direction and Control E-Plan Table B-1 1 1 (SM) (qualified as a Certified Fuel Handler)

Nuclear Plant E-Plan Table B-1 Non-Certified Operators 1 1 Operator (NPO)

Radiation E-Plan Table B-1 Radiation Protection 1 1 Protection (RP)

Security E-Plan Table B-1 Access Control and Accountability Per Security Contingency Plan Total 3 3 IPEC Page 6

IPEC ON-SHIFT STAFFING ANALYIS REPORT B. Other Commitments to Shift Staffing No additional shift staffing commitments were identified.

C. Staffing Exceptions and Time Motion Studies (TMS)

No chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. Because the Chemistry Technicians was not identified as having any specific Chemistry-related emergency tasks during the scenarios evaluated for this analysis, the Chemistry Technician position is not included in the proposed post-shutdown on-shift staffing complement. No further analysis or TMS is required.

During fuel movement, additional Operations and RP personnel that are not part of the on-shift staff will be on site that, were a fuel handling accident to occur, will be able to respond to the event. Consequently, there are an adequate number of qualified personnel to perform plant surveys and dose assessment in the event of a fuel handling accident as discussed in Event 2. The task of accident/dose assessment will be performed as directed by the Shift Manager. It is acceptable to assign the RP Technician the emergency plan function of dose assessment. No further analysis or TMS is required.

Because IPEC will no longer be authorized to operate the reactors or place fuel into the reactor vessels, the Shift Technical Advisor position is unnecessary and is not included in the proposed post-shutdown on-shift staffing complement.

Because IPEC will no longer be authorized to operate the reactors or place fuel into the reactor vessels, the Safe Shutdown (SSD) task is not necessary and is not considered in this analysis.

The Shift Manager is assigned the responsibility to make some notifications such as 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 acceptable tasks for the Shift Manager. No further analysis or TMS is required.

Station staff is 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 there are sufficient personnel on-shift to perform this task during the event.

Specifically, nuclear plant operators or radiation protection technicians were all available to fill this function. No further analysis or TMS is required.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT The task of activating ERDS (Emergency Response Data System) is not required for this analysis. The ERDS requirement in Appendix E to 10 CFR Part 50 exempts all nuclear power facilities that are shut down permanently from the need to provide an ERDS interface with the NRC. Therefore, the ERDS link to the NRC is not required to be operational for Units 2 and 3 in the permanently shutdown and defueled condition.

Because of the reduced actions necessary to mitigate an emergency in the permanently defueled condition and the minimal actions of the Control Room positions in a permanently defueled condition, no Licensed Reactor Operator job tasks were noted as being required for any of the analyzed events. Because the Licensed Reactor Operators were not identified as having any specific emergency tasks during the scenarios evaluated for this analysis, the position is not included in the proposed post-shutdown on-shift staffing complement.

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

In accordance with NEI 10-05 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.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT At IPEC, Nuclear Plant Operators are trained to perform the actions associated with this functional area. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed.

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. Per the guidance of NUREG-0654, Table B-1, rescue operations and first aid may be performed by shift personnel assigned other functions. IPEC operators were previously trained to perform rescue operations and would perform the task should the need arise. Rescue operations were not required in any of the accident scenarios reviewed. Additionally, the Nuclear Plant Operators on shift are trained to Red Cross First Aid standards and meet the basic requirements to render first aid and CPR.

Rescue operations and first aid response are acceptable collateral duties per the guidance of NEI 10-05 and were not analyzed.

III. ANALYSIS PROCESS The analysis addressing permanent shutdown and defuel of Units 2 and 3 was developed by reviewing each scenario from Revision 1 to determine its applicability IPEC in a permanently shutdown and defueled condition and those plant actions and emergency plan implementation actions that would be required based on plant procedures prior to staff augmentation. These actions were then compared to the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel, ensuring that no actions were assigned to staff members that conflicted with either their proposed emergency plan role or operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, an evaluation of the timing of the tasks was conducted to ensure that they could be performed by the individual in series within any specified time requirements. The emergency response to each event was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures, with consideration given to anticipated emergency plan and procedure revisions, including elimination of procedures that would not be in place following permanent defuel.

The results of the analysis for each of the scenarios are included in Sections VII, 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 IPECs DBAs were evaluated and classified according to its FSAR Chapter 14 description. In a permanently shutdown and defueled condition, FSAR Chapter 14 will be revised to eliminate the DBAs that will not be applicable. Only those DBAs that will be applicable in a permanently shutdown and defueled condition were evaluated in this analysis.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT IV. ACCIDENT SCENARIOS A. Accident Selection The 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 FSAR along with additional scenarios specified by the guidance documents.

Based on the applicability in a permanently shut down and defueled condition, the following scenarios were considered:

Design Basis Threat (DBT)

DBA Fuel Handling Accident (FHA) (Chapter 14 as revised to address the permanently defueled condition)

DBA Aircraft Probable Threat Control Room (CR) fire requiring CR evacuation (Appendix R Fire)

Station Blackout, (SBO)

General Emergency with radioactive release and Protective Action Recommendation (PAR)

Appendix R Fire (Fire resulting in a reactor trip)

B. Accident Scenarios included in the Analysis Design Basis Threat (DBT) as described in NEI 10-05 Land and/or waterborne Hostile Action directed against the Protected Area by a Hostile Force. 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. EAL is based on the event.

Fuel Handling Accident The accident involves a dropped fuel bundle on top of the core.

Initial EAL is based on the event.

Aircraft Probable Threat as described in 10 CFR 50.54(hh)(1)

Notification is received from the NRC, that a probable aircraft threat exists

(> 5 minutes, < 30 minutes). EAL is based on the event.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT CR Fire Requiring CR evacuation and Alternate Shutdown A fire occurs in the main control room requiring the evacuation and the procedures implemented to ensure SFP cooling is maintained.

General Emergency with release and PAR This event is based on the same initial conditions as the FHA, but assumes a dose that exceeds the Environmental Protection Agencys Protective Action Guides beyond the site boundary, and thus necessitates promulgation of a PAR.

C. Accident Scenarios Not Included in the Analysis Station Blackout ISG-01 provides guidance associated with the staffing analysis for an SBO.

ISG-01 states, in part:

Station blackouts are beyond the plants design basis and may not need to be addressed in the staffing analysis. The blackout coping analyses performed by licensees pursuant to 10 CFR 50.63 establish blackout coping times that exceed the required on-shift staff augmentation time. Also, since the control room fire scenario leading to evacuation and remote shutdown may adequately address the considerations involved with an Appendix R safe shutdown fire, licensees may not need to consider this scenario in the staffing analysis.

10 CFR 50.63(a)(1) states, in part:

Each light-water-cooled nuclear power plant licensed to operate under this part, each light-water-cooled nuclear power plant licensed under subpart C of 10 CFR part 52 after the Commission makes the finding under § 52.103(g) of this chapter, and each design for a light-water - cooled nuclear power plant approved under a standard design approval, standard design certification, and manufacturing license under part 52 of this chapter must be able to withstand for a specified duration and recover from a station blackout as defined in § 50.2.

Upon docketing of the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the Part 50 license will no longer authorize operation of the reactors or emplacement of fuel in the reactor vessels.

IPEC will no longer be a nuclear power plant licensed to operate under 10 CFR Part 50 and 10 CFR 50.63 will no longer be applicable. The SBO scenario is no longer considered an appropriate gauge by which to measure whether an event presents on-shift staff with responsibilities that would prevent the timely performance of assigned functions in the Emergency Plan. Therefore, this scenario is not considered in this analysis.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT Appendix R Fire (Fire that results in a Reactor Trip) 10 CFR 50 Appendix R is applicable to licensed nuclear power generating plants.

Once the certifications required by 10 CFR 50.82(a)(1) are docketed, IPEC will no longer be licensed to generate power. The Appendix R fire scenario is no longer considered an appropriate gauge by which to measure whether an event presents on-shift staff with responsibilities that would prevent the timely performance of assigned functions in the Emergency Plan. Therefore, this scenario is not considered in this analysis.

V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions Applicable to All IPEC OSA

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

2. IPEC 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. No specific emergency response tasks requiring the augmented ERO were identified prior to the 90 minutes following the emergency declaration.

3. There are no time critical RP and Chemistry tasks and task performance is directed and prioritized by the Shift Manager. The time RP 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. Because the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.

4. The Shift Manager of the unaffected unit is responsible for ERO notification and site-specific event notifications.

B. NEI 10-05 Rev 0 Assumptions 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 (60 min.).

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IPEC ON-SHIFT STAFFING ANALYIS REPORT On-shift personnel complement was limited to the minimum required number and composition as described in the site emergency plan, based on the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessels.

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

In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain SFP cooling was done by a member of the on-shift staff as defined in the units 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 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/DPR-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.

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IPEC 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.

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 interrupt SFP cooling 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 analysis used DBA analysis assumptions, inputs, timing of events, plant protective response, and specified manual operator actions and their timing, as documented in the USAR.

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.

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IPEC ON-SHIFT STAFFING ANALYIS REPORT VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS Summary Event Plant Reference Analysis Event # Description of Event ECL Type Mode 1 Document(s) Required?

Event Land and/or waterborne HOSTILE ACTION Permanently NEI 10-05 Site Area 1 DBT YES directed against the Defueled ISG IV.C Emergency Protected Area by a HOSTILE FORCE FSAR Chapter 14 As revised Fuel Handling Permanently to address 2 DBA Alert YES Accident Defueled permanently defueled conditions Assumed 10 CFR for Aircraft Permanently 3 50.48(hh)(1) Alert YES Analysis Probable Threat Defueled RG 1.214 Purpose Assumed Control Room for Evacuation Permanently 4 10 CFR 50.48 Alert YES Analysis and maintain Defueled Purpose SFP Cooling Assumed General Emergency for Permanently General 5 with radiological ISG IV.C YES Analysis Defueled Emergency release and PAR Purpose Assumed for Permanently Site Area 6 Station Blackout ISG IV.C NO 2 Analysis Defueled Emergency Purpose Assumed for Appendix R Fire with Permanently 7 ISG IV.C Alert NO 3 Analysis Reactor Trip Defueled Purpose 1

Once IPEC submits the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii),

per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactors or emplacement of fuel in the reactor vessels. IPEC will no longer be a nuclear power plant licensed to operate under Part 50.

2 Once IPEC submits the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii),

per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactors or emplacement of fuel in the reactor vessels and 10 CFR 50.63 will no longer be applicable.

3 Upon Termination of License as prescribed under 10 CFR 50.82 Unit 2s Fire Protection program will fall under 10 CFR 50.48 (f) which requires the maintenance of a fire protection program to address the potential for fires that could result in the release or spread of radioactive materials.

IPEC Page 15

IPEC ON-SHIFT STAFFING ANALYIS REPORT VII. APPENDIX B - UNIT 2 OR UNIT 3 ON-SHIFT STAFFING ANALYSIS A. Design Basis Accident Analysis #2 - Fuel Handling Accident

1. Accident Summary The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

2. Accident Specific Assumptions Made Additional plant personnel, including Operations, Chemistry, and RP Technician, would be on-site during fuel assembly movement. The presence of additional plant personnel would free the on-shift RP Technician to perform dose assessment.

This analysis assumes an ALERT declaration based on area radiation monitors reaching levels to prompt an emergency declaration.

3. Procedures for Accident Response (To be modified to address permanent cessation of power operations)

IP-EP-120, Classification IP-EP-115, Forms IP-EP-210, Central Control Room 2-AOP-FH-1, Fuel Damage or Loss of SFP/Refuel Cavity Level IPEC Page 16

IPEC ON-SHIFT STAFFING ANALYIS REPORT

4. Tables IPEC TABLE 1 - ON-SHIFT POSITIONS Analysis # 2 - Fuel Handling Accident (Unit 2 or Unit 3)

Augmentation On-shift Role in Table Unanalyzed TMS Line # Basis Document Elapsed Time Position # / Line # Task? Required?

(min)*

T2/L1 T5/L1 Affected T5/L3 1 E-Plan Table B-1 60 T5/L5 No No Unit SM T5/L8 T5/L10 T2/L2 Affected 2 E-Plan Table B-1 N/A T5/L9 No No Unit NCO T5/L13 Affected 3 E-Plan Table B-1 60 T4/L6 No No Unit RP Unaffected T5/L6 4 E-Plan Table B-1 N/A No No Unit SM T5/L14 Unaffected 5 E-Plan Table B-1 N/A N/A No No Unit NCO Unaffected N/A T4/L7 6 E-Plan Table B-1 No No Unit RP T5/L12 Security Contingency Plan 60 7 Security T5/L15 No No

/ E-Plan Table B-1 IPEC Page 17

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 2 - UNIT 2 PLANT OPERATIONS One Unit - One Control Room Analysis # 2 - Fuel-Handling Accident (FHA)

Minimum Operations Crew Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method Licensed Operator 1 Affected Unit Shift Manager Shift Manager Training Program (or equivalent)

Non-Licensed Operator 2 Affected Unit Non-Certified Nuclear Plant Operator Training Program (or equivalent)

Other (non-Operations) Personnel Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A IPEC Page 18

IPEC ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade IPEC TABLE 3 - FIREFIGHTING Analysis # 2 - Fuel-Handling Accident (Unit 2 or Unit 3)

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 No firefighting activities included in this accident.

IPEC Page 19

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 2 - FHA (Unit 2 or Unit 3)

L Performance Time Period After Emergency Declaration (minutes)*

Position I

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

In-Plant Survey:

1 ____N/A___

On-site Survey:

2 ____N/A___

Personnel 3 Monitoring:

____N/A____

Job Coverage:

4 ____N/A____

Offsite Rad Assessment:

5 _(Included in Table 5___

Other site specific Affected 6 Unit RP X X X X X X contamination monitoring Other site specific:

Unaffected 7 Unit RP: Monitor X X X X X X X X Plant vents for rising levels

• Times are estimated.

IPEC Page 20

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 2 - FHA (Unit 2 or Unit 3)

Line# Function / Task On-Shift Position Task Analysis Controlling Method Declare the Affected Unit Emergency Planning 1 Emergency Classification Level (ECL) Shift Manager Training Program / EP Drills Approve Offsite Protective Action 2 N/A N/A Recommendations Approve content of State/local Affected Unit Emergency Planning 3 notifications Training Program Shift Manager 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift Licensed Operator Training staff (e.g., to assemble, evacuate, Affected Unit 5 Program / Emergency etc.) Shift Manager Planning Training Program ERO notification Unaffected Unit Emergency Planning 6

Shift Manager Training Program Abbreviated NRC notification for 7 N/A N/A DBT event Complete State/local notification form Affected Unit Emergency Planning 8

Shift Manager Training Program Perform State/local notifications Affected Unit Emergency Planning 9

NCO Training Program Affected Unit Licensed Operator 10 Complete NRC event notification form Shift Manager Training Program 11 Activate ERDS N/A N/A Offsite radiological assessment Unaffected Unit Emergency Planning 12 RP Technician Training Program 13 Perform NRC notifications Affected Unit NCO Emergency Planning Training Program Perform other site-specific event Unaffected Unit Licensed Operator 14 notifications (e.g., Duty Plant Shift Manager Training Program Manager, INPO, ANI, etc.)

Personnel Accountability Security Training 15 Security Program / EP Drills IPEC Page 21

IPEC ON-SHIFT STAFFING ANALYIS REPORT B. Design Basis Accident Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling

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 to lose SFP cooling capabilities.

2. Accident Specific Assumptions Made Assumed Control Room staff does not have time to perform any procedural actions other than declare the Alert and make the plant announcement before leaving the control room.

Affected Unit Shift Manager maintains field oversight of the response and Unaffected Unit Shift Manager assumes the Emergency Director function.

Evacuating control room personnel respond to the unaffected unit control room.

3. Procedures for Accident Response (To be modified to address permanent cessation of power operations) 2-AOP-SSD-1, Control Room Inaccessibility Safe Shutdown Control IP-EP-120, Classifications IP-EP-115, Forms IP-EP-210, Central Control Room IPEC Page 22

IPEC ON-SHIFT STAFFING ANALYIS REPORT

4. Tables IPEC TABLE 1 - ON-SHIFT POSITIONS Analysis # 4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling (U2 or U3)

Augmentation Role in On-shift Unanalyzed TMS Line # Basis Document Elapsed Time Table # /

Position Task? Required?

(min) Line #

Affected 1 E-Plan Table B-1 60 T2/L1 No No Unit SM T2/L2 Affected 2 E-Plan Table B-1 N/A T5/L9 No No Unit NCO T5/L13 Affected 3 E-Plan Table B-1 60 T4/L4 No No Unit RP T5/L1 T5/L3 T5/L5 Unaffected 4 E-Plan Table B-1 N/A T5/L6 No No Unit SM T5/L8 T5/L10 T5/L14 Unaffected 5 E-Plan Table B-1 N/A T3/L1 No No Unit NCO Unaffected N/A 6 E-Plan Table B-1 N/A No No Unit RP Security Contingency Plan 60 7 Security T5/L15 No No

/ E-Plan Table B-1 IPEC Page 23

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 2 - UNIT 2 PLANT OPERATIONS One Unit - One Control Room Analysis # 4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling (U2)

Minimum Operations Crew Necessary to Implement AOPs if Applicable Task Analysis Controlling Line # Generic Title/Role On-Shift Position Method Licensed Operator Training 1 Affected Unit Shift Manager Shift Manager Program (or equivalent)

Non-Licensed Operator Training 2 Affected Unit Non-Certified Nuclear Plant Operator Program (or equivalent)

Other (non-Operations) Personnel Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A Fire Brigade IPEC TABLE 3 - FIREFIGHTING Analysis # 2 - Fuel-Handling Accident (Unit 2 or Unit 3)

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 No firefighting activities included in this accident.

IPEC Page 24

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling (U2)

L Performance Time Period After Emergency Declaration (minutes)*

Position I

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

In-Plant Survey:

1 ____N/A____

On-site Survey:

2 ____N/A____

Personnel 3 Monitoring:

____N/A_____

Job Coverage:

4 Affected Unit X X X X X X X X X X RP FB support Offsite Rad Assessment:

5 _(Included in Table 5____

Other site-specific RP 6 (describe):

___N/A___

Chemistry Function Task #1 7

(describe)

____N/A___

Chemistry Function Task #2 8

(describe)

____N/A___

• Times are estimated.

IPEC Page 25

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling (U2)

Line# Function / Task On-Shift Position Task Analysis Controlling Method Declare the Unaffected Unit Emergency Planning 1 Emergency Classification Level (ECL) Shift Manager Training Program / EP Drills Approve Offsite Protective Action 2 N/A N/A Recommendations Approve content of Unaffected Unit Emergency Planning 3 State/local notifications Training Program Shift Manager 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., to assemble, evacuate, Unaffected Unit Licensed Operator Training Program /

5 etc.) Shift Manager Emergency Planning Training Program ERO notification Unaffected Unit Emergency Planning 6

Shift Manager Training Program Abbreviated NRC notification for 7 N/A N/A DBT event Complete State/local notification form Unaffected Unit Emergency Planning 8

Shift Manager Training Program Perform State/local notifications Affected Unit Emergency Planning 9

NCO Training Program Complete NRC event notification form Unaffected Unit Licensed Operator 10 Shift Manager Training Program 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A 13 Perform NRC notifications Affected Unit NCO Emergency Planning Training Program Perform other site-specific event Unaffected Unit Licensed Operator 14 notifications (e.g., Duty Plant Shift Manager Training Program Manager, INPO, ANI, etc.)

Personnel Accountability Security Training 15 Security Program / EP Drills IPEC Page 26

IPEC ON-SHIFT STAFFING ANALYIS REPORT C. Design Basis Accident Analysis #5 - General Emergency with Radioactive Release and PAR

1. Accident Summary The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.

A General Emergency is declared when the Shift Manager is given a dose assessment update that projects > 1 Rem TEDE at the Site boundary

2. Accident Specific Assumptions Made Additional plant personnel, including Operations, Chemistry, and RP Technician, would be on-site during fuel assembly movement. The presence of additional plant personnel would free the on-shift RP Technician to perform dose assessment.

This analysis assumed a General Emergency declaration based on area radiation monitors reaching levels to prompt an emergency declaration.

3. Procedures for Accident Response (To be modified to address permanent cessation of power operations)

IP-EP-120, Classifications IP-EP-115, Forms IP-EP-210, Central Control Room 2-AOP-FH-1, Fuel Damage or Loss of SFP/Refuel Cavity Level IPEC Page 27

IPEC ON-SHIFT STAFFING ANALYIS REPORT

4. Tables IPEC TABLE 1 - ON-SHIFT POSITIONS Analysis # 5 - General Emergency with Radioactive Release and PAR (U2 or U3)

Augmentation Role in On-shift Unanalyzed TMS Line # Basis Document Elapsed Time Table # /

Position Task? Required?

(min) Line #

T2/L1 T5/L1 T5/L2 Affected T5/L3 1 E-Plan Table B-1 60 No No Unit SM T5/L4 T5/L5 T5/L8 T5/L10 T2/L2 Affected 2 E-Plan Table B-1 N/A T5/L9 No No Unit NCO T5/L13 Affected 3 E-Plan Table B-1 60 T4/L6 No No Unit RP Unaffected T5/L6 4 E-Plan Table B-1 N/A T5/L14 No No Unit SM Unaffected 5 E-Plan Table B-1 N/A N/A No No Unit NCO Unaffected N/A T4/L7 6 E-Plan Table B-1 No No Unit RP T5/L12 Security Contingency Plan 60 7 Security T5/L15 No No

/ E-Plan Table B-1 IPEC Page 28

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 2 - UNIT 2 PLANT OPERATIONS One Unit - One Control Room Analysis # 5 - General Emergency with Radioactive Release and PAR Minimum Operations Crew Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method Licensed Operator 1 Affected Unit Shift Manager Shift Manager Training Program (or equivalent)

Non-Licensed Operator 2 Affected Unit Non-Certified Nuclear Plant Operator Training Program (or equivalent)

Other (non-Operations) Personnel Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A IPEC Page 29

IPEC ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade IPEC TABLE 3 - FIREFIGHTING Analysis # 5 - General Emergency with Radioactive Release and 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 Firefighting activities included are not included in this accident.

IPEC Page 30

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 5 - General Emergency with Radioactive Release and PAR L Performance Time Period After Emergency Declaration (minutes)*

Position I

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

In-Plant Survey:

1 ____N/A____

On-site Survey:

2 ____N/A____

Personnel 3 Monitoring:

____N/A_____

Job Coverage:

4 ____N/A_____

Offsite Rad Assessment:

5 _(Included in Table 5____

Other site specific Affected 6 Unit RP X X X X X X contamination monitoring Other site-specific:

Unaffected 7 Unit RP: Monitor X X X X X X X X Plant vents for rising levels Chemistry Function task #2 8 (described)

____N/A___

• Times are estimated.

IPEC Page 31

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 5 - General Emergency with Radioactive Release and PAR (U2 or U3)

Task Analysis Controlling Line# Function / Task On-Shift Position Method Declare the Affected Unit Emergency Planning 1 Emergency Classification Level (ECL) Shift Manager Training Program / EP Drills Approve Offsite Protective Action Affected Unit 2 N/A Recommendations Shift Manager Approve content of State/local Affected Unit Emergency Planning 3 notifications Training Program Shift Manager Approve extension to allowable dose Affected Unit N/A 4

Shift Manager Notification and direction to on-shift Licensed Operator Training staff (e.g., to assemble, evacuate, Affected Unit 5 Program / Emergency etc.) Shift Manager Planning Training Program ERO notification Unaffected Unit Emergency Planning 6

Shift Manager Training Program Abbreviated NRC notification for 7 N/A N/A DBT event Complete State/local notification form Affected Unit Emergency Planning 8

Shift Manager Training Program Perform State/local notifications Affected Unit Emergency Planning 9

NCO Training Program Affected Unit Licensed Operator 10 Complete NRC event notification form Shift Manager Training Program 11 Activate ERDS N/A N/A Offsite radiological assessment Unaffected Unit Emergency Planning 12 RP Technician Training Program 13 Perform NRC notifications Affected Unit NCO Emergency Planning Training Program Perform other site-specific event Unaffected Unit Licensed Operator 14 notifications (e.g., Duty Plant Shift Manager Training Program Manager, INPO, ANI, etc.)

Personnel Accountability Security Training 15 Security Program / EP Drills IPEC Page 32

IPEC ON-SHIFT STAFFING ANALYIS REPORT VIII. APPENDIX B - COMMON CONTROL ROOM SHIFT STAFFING ANALYSIS A. Accident Analysis #1 - Design Basis Threat (DBT)

NOTE Threat based event is single procedure and both Units affected. Unit 3 Takes lead on EP actions

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.

Security Code Red condition.

2. Accident Specific Assumptions Made 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 Security notifies the Shift Manager of condition Security Code RED.

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

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

3. Procedures for Accident Response (To be modified to address permanent cessation of power operations) 0-AOP-SEC-1, Response to Security Compromise IP-EP-120, Classification 2/3-E-0, Reactor Trip or Safety Injection IP-EP-115, Forms IP-EP-210, Central Control Room IPEC Page 33

IPEC ON-SHIFT STAFFING ANALYIS REPORT

4. Tables IPEC TABLE 1 - ON-SHIFT POSITIONS Analysis # 1 - DBT Security Threat Augmentation Role in On-shift Unanalyzed TMS Line # Basis Document Elapsed Time Table # /

Position Task? Required?

(min)* Line #

U2 T2/L1 T5/L1 T5/L3 1 U2 SM E-Plan Table B-1 N/A T5/L5 No No T5/L8 T5/L10 U2 T2/L2 T5/L7 2 U2 NCO E-Plan Table B-1 N/A T5/L9 No No T5/L13 3 U2 RP E-Plan Table B-1 N/A N/A No No U3 Shift E-Plan Table B-1 U3 T2/L1 4 60 T5/L6 No No Manager T5/L14 U3 E-Plan Table B-1 5 N/A U3 T2/L2 No No NCO 6 U3 RP E-Plan Table B-1 N/A N/A No No Security 7 Security Contingency Plan / 60 T5/L15 No No E-Plan Table B-1 IPEC Page 34

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 2 - UNIT 2 PLANT OPERATIONS One Unit - One Control Room Analysis # 1 - DBT Security Threat Minimum Operations Crew Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program (or equivalent)

Non-Licensed Operator Training 2 Non-Certified Operator Nuclear Plant Operator Program (or equivalent)

IPEC TABLE 2 - UNIT 3 PLANT OPERATIONS One Unit - One Control Room Analysis # 1 - DBT Security Threat Minimum Operations Crew Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method Licensed Operator Shift Manager Training Program 1 Shift Manager (or equivalent)

Non-Licensed Operator 2 Non-Certified Operator Nuclear Plant Operator Training Program (or equivalent)

Other (non-Operations) Personnel Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method 4 Mechanic N/A N/A 5 Electrician N/A N/A 6 I&C Technician N/A N/A 7 Other N/A N/A 8 Other N/A N/A IPEC Page 35

IPEC ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade IPEC 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 Note: This accident does not include the need for firefighting, first aid or search and rescue.

IPEC TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 1 - DBT Security Threat L

Performance Time Period After Emergency Declaration (minutes)*

I Position Performing N Function / Task 10 20 30 40 50 60 70 80 E 0-5 5-10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 In-Plant Survey:

1

____N/A___

On-site Survey:

2 ____N/A___

Personnel 3 Monitoring:

____N/A_____

Job Coverage:

4 ____N/A_____

Offsite Rad 5 Assessment:

___N/A____

Other site-specific 6 RP (describe):

____N/A_____

Chemistry Function 7 task #1 (describe)

____N/A___

Chemistry Function 8 task #2 (describe)

____N/A_____

Note: No Chemistry or RP job function tasks for the conditions described in the DBT assumptions.

RP takes cover as directed IPEC Page 36

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 1 - DBT Security Threat On-Shift Line# Function / Task Task Analysis Controlling Method Position Declare the emergency U2 Shift Emergency Planning 1

classification level (ECL) Manager Training Program / EP Drills Approve Offsite Protective 2 N/A N/A Action Recommendations Approve content of U2 Shift 3 Emergency Planning Training Program State/local notifications Manager Approve extension to 4 N/A N/A allowable dose Notification and direction U2 Shift Licensed Operator Training Program /

5 to on-shift staff (e.g., to Manager Emergency Planning Training Program assemble, evacuate, etc.)

U3 Shift 6 ERO notification Emergency Planning Training Program Manager Abbreviated NRC Licensed Operator Training Program /

7 U2 NCO notification for DBT event Emergency Planning Training Program Complete State/local U2 Shift 8 Emergency Planning Training Program notification form Manager Perform State/local 9 U2 NCO Emergency Planning Training Program notifications Complete NRC event U2 Shift 10 Licensed Operator Training Program notification form Manager 11 Activate ERDS N/A N/A Offsite radiological 12 N/A N/A assessment 13 Perform NRC notifications U2 NCO Emergency Planning Training Program Perform other site-specific event notifications U3 Shift 14 Licensed Operator Training Program (e.g., Duty Plant Manager, Manager INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program / EP Drills IPEC Page 37

IPEC ON-SHIFT STAFFING ANALYIS REPORT B. Accident Analysis #3 - Aircraft Probable Threat NOTE Threat based event is single procedure and both Units affected. Unit 3 Takes lead on EP actions

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 incipient fire brigade member 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.

3. Procedures for Accident Response (To be modified to address permanent cessation of power operations) 0-AOP-SEC-2, Aircraft Threat IP-EP-120, Classification IP-EP-115, Forms IP-EP-210, Central Control Room (for both units)

IPEC Page 38

IPEC ON-SHIFT STAFFING ANALYIS REPORT

4. Tables IPEC TABLE 1 - ON-SHIFT POSITIONS Analysis # 3 - Aircraft Probability Threat Augmentation Role in On-shift Unanalyzed TMS Line # Basis Document Elapsed Time Table # /

Position Task? Required?

(min)* Line #

U2 T2/L1 T5/L1 T5/L3 1 U2 SM E-Plan Table B-1 N/A No No T5/L5 T5/L8 T5/L10 U2 T2/L2 2 U2 NCO E-Plan Table B-1 N/A T5/L9 No No T5/L13 3 U2 RP E-Plan Table B-1 N/A N/A No No U3 Shift E-Plan Table B-1 4 N/A N/A No No Manager E-Plan Table B-1 U3 T2/L1 5 U3 NCO N/A T5/L6 No No T5/L14 6 U3 RP E-Plan Table B-1 N/A N/A No No Security 7 Security Contingency Plan / 60 T5/L15 No No E-Plan Table B-1 IPEC Page 39

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 2 - UNIT 2 PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis # 3 - Aircraft Probability Threat Minimum Operations Crew Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program (or equivalent)

Non-Licensed Operator 2 Non-Certified Operator Nuclear Plant Operator Training Program (or equivalent)

IPEC TABLE 2 - UNIT 3 PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis # 3/9 - Aircraft Probability Threat Minimum Operations Crew Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program (or equivalent)

Non-Licensed Operator 2 Non-Certified Operator Nuclear Plant Operator Training Program (or equivalent)

Other (non-Operations) Personnel Necessary to Implement AOPs, if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method 3 Mechanic N/A N/A 4 Electrician N/A N/A 5 I&C Technician N/A N/A 6 Other N/A N/A 7 Other N/A N/A IPEC Page 40

IPEC ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade IPEC TABLE 3 - FIREFIGHTING Analysis # 3/9 - Aircraft Probability 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 FB stages in the In-Processing Building, no firefighting activities during the 30 minutes included in the analysis IPEC Page 41

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 3/9 - Aircraft Probability Threat L Performance Time Period After Emergency Declaration (minutes)*

I Position Performing N Function / Task 5 15 25 35 45 55 65 75 85-0-5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 E

In-Plant Survey:

1 ____N/A___

On-site Survey:

2 ____N/A_____

Personnel Monitoring:

3 ____N/A_____

Job Coverage:

4 ____N/A_____

Offsite Rad 5 Assessment:

(Included in Table 5 Other site-specific RP 6 (describe):

____N/A_____

Chemistry Function 7 task #1 (described)

____N/A___

Chemistry Function 8 task #2 (describe)

____N/A_____

Note: No RP job function tasks for the conditions described in the Aircraft Threat assumptions.

IPEC Page 42

IPEC ON-SHIFT STAFFING ANALYIS REPORT IPEC TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 3/9 - Aircraft Probability Threat On-Shift Task Analysis Controlling Line# Function / Task Position Method Declare the emergency classification level U2 Shift Emergency Planning Training 1

(ECL) Manager Program / EP Drills Approve Offsite Protective Action 2 N/A N/A Recommendations Approve content of State/local U2 Shift Emergency Planning Training 3

notifications Manager Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Notification and direction to on-shift staff U2 Shift 5 Program / Emergency Planning (e.g., to assemble, evacuate, etc.) Manager Training Program U3 Shift Emergency Planning Training 6 ERO notification Manager Program Abbreviated NRC notification for DBT 7 N/A N/A event U2 Shift Emergency Planning Training 8 Complete State/local notification form Manager Program Emergency Planning Training 9 Perform State/local notifications U2 NCO Program U2 Shift Licensed Operator Training 10 Complete NRC event notification form Manager Program N/A 11 Activate ERDS N/A (runs 24/7) 12 Offsite radiological assessment N/A N/A Emergency Planning Training 13 Perform NRC notifications U2 NCO Program Perform other site-specific event U3 Shift Licensed Operator Training 14 notifications (e.g., Duty Plant Manager, Manager Program INPO, ANI, etc.)

Security 15 Personnel Accountability Security Training Program / EP Drills IPEC Page 43

IPEC ON-SHIFT STAFFING ANALYIS REPORT IX. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS A. ERO Notification (Everbridge activation)

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 IPEC Page 44

IPEC 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 can be justified as an acceptable overlap to the Shift Managers primary emergency plan function of direction and control.

The Time Motion Study may be completed during simulator training/evaluation or during EP drills LOCATION:

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)].

IPEC Page 45

IPEC ON-SHIFT STAFFING ANALYIS REPORT Function / Responsibility (Task) Analysis Template Event: __All_______ Site: ___IPEC____ Position: __Shift Manager________ Line #: __1____

Function Responsibility (Task) Action Step Duration 1.Notification 1.1 Initiate notification to the ERO via the 1.1.1 ERON Program Retrieve the Everbridge instruction that contains the 22 sec.

[TRAINING] Access code and Pass code.

1 (On the PC)

Open ERO Notification System by clicking: 17 sec.

Start Nuclear Corporate Apps (ESM) Nuclear Emergency Response (ESM) ERON 2

Enter Access code (XXXXX) and Pass code (XXXXX) 11 sec.

and click the SUBMIT button 3

Select the appropriate classification by clicking on it. 8 sec.

(Select ALERT) 4 Answer Yes or No to Security EAL question, Was the 8 sec.

event declared on a Security EAL? [ Click on YES]

5 Select proper response action by clicking on it. 10 sec.

[Select Security Event}

6 Review the message that was generated in the User Message box at the bottom of the screen. Ensure the 12 sec.

message contains the information to communicate to the ERO. Additional information can be added to the IPEC Page 46

IPEC ON-SHIFT STAFFING ANALYIS REPORT message by clicking in the User Message box and typing.

7 Once satisfied with the message content, click send 7 sec.

notification button. [Click Send Notification]

8 Answer YES to send verification question, Are you 5 sec.

CERTAIN you want to send this message? [Click YES]

9 If message was successfully sent, you will see a dialog 5 sec.

box

[Click Return]

END OF INITIATE NOTIFICATION TO ERO TASK 2.Emergency Direction and 2.1 Maintain emergency direction and control 1 Control of the event response. Oversight of the emergency response. NA 2

Initiate any emergency actions. NA Comments:

The task of ERO notification/activation via ERON for the Non-ED Unit Shift Manager does not negate or interfere with the SMs ability to continue oversight of control room activities or to initiate additional emergency actions.

END OF EMERGENCY DIRECTION AND CONTROL TASK IPEC Page 47

IPEC ON-SHIFT STAFFING ANALYIS REPORT Task Performer: __ Donald Dewey__________ Position: ____ Shift Manager/AOM__________ Date:______4/9/13________

Name Job Title Evaluator: _____ Anthony Ambrose__________ Position: ____ Sr. Emergency Planner_________ Date:______4/9/13________

Name Job Title Evaluator:_____Brian McCarthy____________ Position:_____ Shift Manager/AOM__________ Date:_____4/9/13__________

IPEC Page 48

IPEC ON-SHIFT STAFFING ANALYIS REPORT X. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures.

NONE 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.

IPEC Emergency Plan Indian Point No. 1 Safety Analysis Report Decommissioning Plan for Indian Point Unit 1, October 1980 XII. STAFFING ANALYIS TEAM Paul Bowe, Operations Craig Delamater, Emergency Planning Chris Bohren, Operations IPEC Page 49

Attachment 2 Page 1 of 4 10CFR50.54(Q)(3) Screenina Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Study Equipment/Facility/Other: Indian Point Energy Center {IPEC)

Title:

Indian Point On-Shift Staffing Analysis {PSEP)

Part I. Description of Activity Being Reviewed (This is generally changes to the emergency plan, EALs, EAL bases, etc. - refer to Section 3.0 Step 6):

The activity being reviewed is a revision to the IPEC Units 2 and 3 Phase 1, Staffing Assessment, (OSSA) to incorporate changes identified in the attached revision matrix. The Staffing Assessment has been updated to reflect the changes in the IPEC Fire Protection Plan.

YES ~ NO Part II. Activity Previously Reviewed? 50.54(q)(3) Continue to Evaluation is next part Is this activity fully bounded by an NRC approved 10CFR50.90 submittal or NOT required.

Alert and Notification System Design Report? Enter justification below and If YES, identify bounding source document number/approval reference and complete Part ensure the basis for concluding the source document fully bounds the VI.

proposed change is documented below:

Justification: N/A D Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes Check if any other regulatory change processes control the proposed activity. (Refer to EN-Ll-100 and 10 CFR 50.54(Q)).

APPLICABILITY CONCLUSION D If there are no other controlling change processes, continue the 10CFR50.54(q)(3) Screening.

~ One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 10CFR50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below.

D One or more controlling change processes are selected and fully bounds all aspects of the activity. 10CFR50.54(q)(3)

Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES 10 CFR 50.54(q)

YES ~NO Part IV. Editorial Change 50.54(q)(3) Continue to Evaluation is next part Is this activity an editorial or typographical change such as formatting, paragraph NOT required.

numbering, spelling, or punctuation that does not change intent? Enter justification Justification: This staffing study revision contains various editorial changes, but "NO" and continue is checked because the procedure revision contains non-editorial changes per the to next part or attached revision matrix. See the editorial change on the attached document on lines complete Part VI as 1-Cover page applicable.

Part V. Emergency Planning Element/Function Screen (Associated 10CFR50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NUREG-0654/FEMA REP-1 Section II?

EN-EP-3O5 ROOS

Attachm ent 2 Page 2 of 4 10CFR50.54(Q)(3) Screeni ng Procedu re/Docum ent Number: IPEC Phase 1 Revision: 22-01 Staffing Study Equipment/Facility/Other: Indian Point Energy Center (IPEC}

Title:

Indian Point On-Shift Staffing Analysis (PSEP}

1. Responsibility for emergency response is assigned. [1 J

2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 staffing) in accordance with the emergency plan. [1J

3. The process ensures that on shift emergency response responsibilities are staffed and assigned.

[2J ~

4. The process for timely augmentation of onshift staff is established and maintained. [2J

5. Arrangements for requesting and using off site assistance have been made. [3J

6. State and local staff can be accommodated at the EOF in accordance with the emergency plan.

[3J

7. A standard scheme of emergency classification and action levels is in use. [4J

8. Procedures for notification of State and local governmental agencies are capable of alerting them of the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5J

9. Administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway. [5J

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved Alert and ANS design report and supporting FEMA approval letter. [5J

11. Systems are established for prompt communication among principal emergency response organizations. [6J

12. Systems are established for prompt communication to emergency response personnel. [6J

13. Emergency preparedness information is made available to the public on a periodic basis within plume exposure pathway emergency planning zone (EPZ). [7J the

14. Coordinated dissemination of public information during emergencies is established. [7J

15. Adequate facilities are maintained to support emergency response. [8J

16. Adequate equipment is maintained to support emergency response. [8J

17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9J

18. A range of public PARs is available for implementation during emergencies. [1 OJ

19. Evacuation time estimates for the population located in the plume exposure pathway EPZ available to support the formulation of PARs and have been provided to State and local are governmental authorities. [1 OJ

20. A range of protective actions is available for plant emergency workers during emergencies, those for hostile action events.[1 OJ including

21. The resources for controlling radiological exposures for emergency workers are established

22. Arrangements are made for medical services for contaminated, injured individuals. [12J

. [11J

23. Plans for recovery and reentry are developed. [13J

24. A drill and exercise program (including radiological, medical, health physics and other program areas) is established. [14J EN-EP-3O5 ROOS

Attachm ent 2 Page 3 of 4 1 0CFR50 .54(Q)(3 ) Screeni ng Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Study Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point On-Shift Staffing Analysis (PSEP)

25. Drills, exercises, and training evolutions that provide performan ce opportuniti es to develop, maintain, and demonstra te key skills are assessed via a formal critique process in order to identify weaknesse s. [14]

26. Identified weaknesse s are corrected. [14]

27. Training is provided to emergency responders. [15]

28. Responsib ility for emergency plan developme nt and review is established . [16]

29. Planners responsibl e for emergency plan developme nt and maintenan ce are properly trained. [16]

APPLICABILITY CONCLUSION If no Part V criteria are checked, a 10CFR50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

If any Part V criteria are checked, complete Part VI and perform a 10CFR50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION The following changes are non-editorial, but they screen out because the change does not change the meaning or intent of a description in the emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan:

Change 2: This change documents that Unit 2 and Unit 3 are now permanently defueled. No change to staffing levels or responsibilities are made by this by this change. The meaning or intent of a description in the emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan are not affected by this change. No further evaluation is required for this change.

Change 3: This change documents that Unit 2 and Unit 3 are now permanently defueled. No change to staffing levels or responsibilities are made by this by this change. The meaning or intent of a description in the emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan are not affected by this change. No further evaluation is required for this change.

Change 4: This change documents that Unit 2 and Unit 3 are now permanently defueled. No change to staffing levels or responsibilities are made by this by this change. The meaning or intent of a description in the emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan are not affected by this change. No further evaluation is required for this change.

Change 5: This change documents that Unit 2 and Unit 3 are now permanently defueled. No change to staffing levels or responsibilities are made by this by this change. The meaning or intent of a description in the emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan are not affected by this change. No further evaluation is required for this change.

Change 15: This change is to update the staffing analysis with the current implementing procedure information that was changed during the implementation of the PSEP. Unit 2 Control no longer takes the lead during a dual unit event. Unit 3 Control Room will take the lead, and the appropriate procedure changes and reviews have been made to document those changes. The meaning or intent of a description in the emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan are not affected by this change.

No further evaluation is required for this change.

Change 17: This change is to update the staffing analysis with the current implementing procedure information that was changed during the implementation of the PSEP. Unit 2 Control no longer takes the lead during a dual unit event. Unit 3 Control Room will take the lead, and the appropriate procedure changes and reviews have been made to document those changes. The meaning or intent of a description in the emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan are not affected by this change.

No further evaluation is required for this change.

Change 21: This change updates the names of the personnel that were involved in updating this staffing analysis. No chanae to staffina levels or resoonsibilities are made bv this bv this chanae. The meaning or intent of a description in the EN-EP-305 R008

Attachment 2 Page 4 of 4 10CFR50.54(Q)(3) Screening Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Study Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point On-Shift Staffing Analysis (PSEP) emergency plan, facilities or equipment described in the emergency plan or a process described in the emergency plan are not affected by this change. No further evaluation is required for this change.

The above changes from the revision matrix made to the On-Shift Staffing Analysis have been reviewed to determine if they affect any of the planning standards or program elements in Part V of this form. It has been concluded that there is no effect on the planning elements and no further evaluation is required for these changes.

Part V. Emergency Planning Element 3, in Part V of this form, is affected by changes 6,7,8,9,10,11,12,13,14,16,18,19,20 identified on the revision matrix. A 10CFR 50.54(q) evaluation will be performed to determine if the effectiveness of the IPEC Emergency Plan is reduced and prior NRC approval is required.

Part VI. Signatures:

Preparer Name (Print) Date:7/7/2022 Craig Delamater (Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Date:

Walter Wittich Sr. Licensing Specialist Approver Name (Print) Approver Signature Matt Johnson Manager, Nuclear EN-EP-3O5 ROOS

Attach ment 3 Page 1 of 5 1 0CFR5 0.54(Q )(3) Evalua tion Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Analysis Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point On-Shift Staffing Analysis (PSEP)

Part I. Description of Proposed Change:

Assessment, (OSSA) to incorporate The activity being reviewed is a revision to the IPEC Units 2 and 3 Phase 1, Staffing Staffing Assessm ent has been updated to reflect the changes in changes identified in the attached revision matrix. The following items from the revision matrix did not screen out:

the IPEC Fire Protection Plan. The 18, 19,20 and will be evaluated in this documen t under Part V of this document.

6,7,8,9,10, 11,12, 13, 14,16, Change:

Part II. Description and Review of Licensing Basis Affected by the Proposed through the The Indian Point On-Shift Staffing Analysis Report {Phase 1) (OSSA) has been reviewed with the criteria described in NEI 96-07 and EN Process Applicability Determination (PAD) in accordance does not (1) change the facility or procedure s as described in the UFSAR/DSAR or (2)

Ll-100. This proposed change under the Emergen cy Plan 10 CFR create a test or equipment not described in the UFSAR/DSAR and is governed with EN-EP-30 5. These proposed changes do not involve structures, systems 50.54(q) screening process in accordance controlled by 10 CFR 50.59 or 72.48 and do not have the potential to impact any of the License Basis or components to the questions contained in Documents (LBDs) on the PAD form, except for the Emergency Plan. All responses were determine d to be "no impact". Since these proposed changes do not contain sections Ill and IV of the PAD form it is determine d to be fully governed under any requirements that could affect any LBDs other than the Emergency Plan, 10 CFR 50.54(q}.

ncy Part Ill. Describe How the Proposed Change Complies with Relevant Emerge Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

10 CFR 50.47(b}( 2)-Onsite Emergency Organization and assigned.

The process ensures that on-shift emergency response responsibilities are staffed references to the site fire brigade from Site Compliance: The changes associated with revision 22-01 of OSSA update all change is consisten t with changes to the Fire a five team to an incipient fire brigade made up of one individual. The aligns with the Fire Protection Program. These position reductions were Protection Program and will ensure the staffing have no adverse effect on maintain the effectiven ess of the Emergen cy Plan because the plan states that analyzed and the "Fire Brigade is staffer per the Fire Protection Plan".

review, the Licensing Research Previous NRC Commitments - During the Process Applicability Determination (PAD) for potential NRC Commitm ent changes because of this revision. There System and the NRC Orders were reviewed were no identified conflicts with the On-Shift Staffing Analysis revision.

ommitments, and the Indian Point A review of U2/U3 Post Defuel Technical Specifications, U2/U3 DSAR, NRC Orders/C Emergency Plan were all conducted.

Program Part IV. Description of Emergency Plan Planning Standards, Functions and Elements Affected by the Proposed Change:

10 CFR 50.47(b)( 2)-Onsite Emergency Organization and assigned.

The process ensures that on-shift emergency response responsibilities are staffed CFR Part 50 provide Program Elements: Sections IV.A.1, IV.A.2.a- c, and IV.A.6 of Appendix E to 10 in Section I1.B of NUREG-0 654 and in the IPEC supporting requirements. Informing criteria appear Emergency Plan.

EN-EP-305 R008

Attachment 3 Page 2 of 5 1 0CFR50.54(Q)(3) Evaluation Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Analysis Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point On-Shift Staffing Analysis (PSEP)

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

Change 6: This change adjusts the staffing based on the changes made to the fire protection plan, which goes from a fire brigade team to an incipient fire brigade (1 person) because of being beyond the post zirc-fire conditions. The current Emergency plan states that the Fire Brigade is staffed per the Fire Protection Program Plan, therefore table B-1 is not impacted. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A.1, IV.A.2.a-c, and IV.A.6 and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Change 7: This change adjusts the staffing based on the changes made to the fire protection plan, which goes from a fire brigade team to an incipient fire brigade (1 person) because of being beyond the post zirc-fire conditions. The current Emergency plan states that the Fire Brigade is staffed per the Fire Protection Program Plan, therefore table B-1 is not impacted. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A 1, IV.A.2.a-c, and IV.A.6, and IV.C and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Change 8: This change adjusts the duties of the NCO based on the changes made to the fire protection plan, which goes from a fire brigade team to an incipient fire brigade (1 person) because of being beyond the post zirc-fire conditions. The NCO is no longer responsible to participate in the Fire brigade. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A 1, IV.A.2.a-c, and IV.A.6 and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Change 9: This change adjusts the duties of the NCO based on the changes made to the fire protection plan, which goes from a fire brigade team to an incipient fire brigade (1 person) because of being beyond the post zirc-fire conditions. The NCO is no longer responsible to participate in the Fire brigade. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

EN-EP-3O5 ROOS

Attachment 3 Page 3 of 5 10CFR50.54(Q)(3) Evaluation Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Analysis Equipment/Facility/Other: Indian Point Energy Center {IPEC)

Title:

Indian Point On-Shift Staffing Analysis {PSEP) plan, continues to meet The change does not represent a reduction in the effectiveness of the emergency 1, IV.A.2.a -c, and IV.A.6 planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A l are not assigned and can be incorporated without prior NRC approval because on-shift personne performa nce of assigned emergen cy plan functions.

responsibilities that would prevent timely there will be an incipient Change 10: This change removes the minimum number for the fire brigade, since study used the guidance fire brigade in accordance with the fire protection plan. This revision of the staffing personnel assigned in NEI 10-05. The analysis demonstrates that at this reduced staffing level, on-shift are not assigned responsi bilities that would prevent the timely emergency plan implementation functions performance of their assigned functions as specified in the Emergen cy Plan.

plan, continues to meet The change does not represent a reduction in the effectiveness of the emergency Appendi x E Sections IV.A 1, IV.A.2.a -c, and IV.A.6 planning standard 10 CFR 50.47(b)(2) and 10CFR50 on-shift personne l are not assigned and can be incorporated without prior NRC approval because emergen cy plan functions .

responsibilities that would prevent timely performance of assigned operation should the Change 11: This change states that IPEC Operators will continue to perform rescue guidance in NEI 10-05. The analysis demonstrates need arise. This revision of the staffing study used the l assigned emergen cy plan that at this reduced staffing level, without the STA, on-shift personne timely performance of their implementation functions are not assigned responsibilities that would prevent the assigned functions as specified in the Emergency Plan.

plan, continues to meet The change does not represent a reduction in the effectiveness of the emergency 1, IV.A.2.a -c, and IV.A.6 planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A l are not assigned and can be incorporated without prior NRC approval because on-shift personne timely performa nce of assigned emergen cy plan functions.

responsibilities that would prevent because that function Change 12: This change removes the Fire Brigade Leader from the accident scenario 10-05. The analysis is no longer applicable. This revision of the staffing study used the guidance in NEI cy plan implementation demonstrates that at this reduced staffing level, on-shift personnel assigned emergen nce of their assigned functions are not assigned responsibilities that would prevent the timely performa functions as specified in the Emergency Plan.

plan, continues to meet The change does not represent a reduction in the effectiveness of the emergency 0 Appendi x E Sections IV.A 1, IV.A.2.a -c, and IV.A.6 planning standard 10 CFR 50.47(b)(2) and 10CFR5 because on-shift personne l are not assigned and can be incorporated without prior NRC approval emergen cy plan functions .

responsibilities that would prevent timely performance of assigned because that function Change 13: This change removes the Fire Brigade Leader from the accident scenario study used the guidance in NEI 10-05. The analysis is no longer applicable. This revision of the staffing personne l assigned emergen cy plan implementation demonstrates that at this reduced staffing level, on-shift the timely performa nce of their assigned functions are not assigned responsibilities that would prevent functions as specified in the Emergency Plan.

plan, continues to meet The change does not represent a reduction in the effectiveness of the emergency E Sections IV.A.1, IV.A.2.a -c, and IV.A.6 planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix l are not assigned and can be incorporated without prior NRC approval because on-shift personne cy plan functions .

responsibilities that would prevent timely performance of assigned emergen EN-EP-3O5 ROOS

Attachment 3 Page 4 of 5 10CFR50.54(Q)(3) Evaluation Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Analysis Equipment/Facility/Other: Indian Point Energy Center {IPEC)

Title:

Indian Point On-Shift Staffing Analysis {PSEP)

Change 14: This change removes the Fire Brigade Leader from the accident scenario because that function is no longer applicable. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A.1, IV.A.2.a-c, and IV.A.6 and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Change 16: Change 14: This change removes the Fire Brigade Leader from the accident scenario because that function is no longer applicable. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A.1, IV.A.2.a-c, and IV.A.6 and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Change 18: This change removes the reference to the site fire brigade and replaces it with the incipient fire brigade to be aligned with the changes in the fire protection plan. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A 1, IV.A.2.a-c, and IV.A.6 and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Change 19: This change removes the Fire Brigade Leader from the accident scenario because that function is no longer applicable. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, 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.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A 1, IV.A.2.a-c, and IV.A.6 and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Change 20: This change removes the duties of the SRO/FBL to perform actions of the Fire Brigade. This position has been eliminated in the fore protection plan and is not applicable in this accident scenario. This revision of the staffing study used the guidance in NEI 10-05. The analysis demonstrates that at this reduced staffing level, on-shift personnel assigned emergency plan implementation functions are not EN-EP-3O5 ROOS

Attachment 3 Page 5 of 5 10CFR50.54(Q)( 3) Evaluation Procedure/Document Number: IPEC Phase 1 Revision: 22-01 Staffing Analysis Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Indian Point On-Shift Staffing Analysis (PSEP) assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the Emergency Plan.

The change does not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A.1, IV.A.2.a-c, and IV.A.6 and can be incorporated without prior NRC approval because on-shift personnel are not assigned responsibilities that would prevent timely performance of assigned emergency plan functions.

Conclusion Regarding Impact:

These changes do not represent a reduction in the effectiveness of the emergency plan, continues to meet planning standard 10 CFR 50.47(b)(2) and 10CFR50 Appendix E Sections IV.A.2.a-c, IV.A.2, and IV.C and can be incorporated without prior NRC approval because the effectiveness of the emergency plan is not reduced. These changes can be incorporated without prior NRC approval.

Part VI. Evaluation Conclusion Answer the following questions about the proposed change.

1. Does the proposed change comply with 10CFR50.47(b) and 10CFR50 Appendix E? ~YES ONO

2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no reduction in effectiveness)? ~YES0NO

3. Does the proposed change constitute an emergency action level scheme change? YES~NO If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10CFRS0.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process(es). Refer to Section 6.7 Step 8.

Part VII. Signatures Preparer Name (Print)

Date: / /

Craig Delamater '7 7/,).;J.

Sr. Emergency Planner (Optional) Reviewer Name (Print) Reviewer Signature Date:

Reviewer Name (Print) Date:

Walter Wittich Sr. Licensing Specialist Approver Name (Print) Approver Signature Matt Johnson Mgr., Nuclear EN-EP-305 R008