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Independent Spent Fuel Storage Installation (ISFSI) - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe
	ML25098A330
Person / Time
Site:	Palo Verde
Issue date:	04/08/2025
From:	Spina J; Arizona Public Service Co
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	102-08914-JLS/MDD
	Download: ML25098A330 (1)
	v • d • e

10 CFR 50.90 10 CFR 50.54(q)

A member of the STARS Alliance LLC Callaway

Diablo Canyon

Palo Verde

Wolf Creek 102-08914-JLS/MDD April 8, 2025 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Docket Nos. STN 50-528, 50-529, 50-530 and 72-44 Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe Arizona Public Service Company (APS) is submitting a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), for PVNGS Units 1, 2, and 3 and related ISFSI, seeking approval of changes to the PVNGS Emergency Plan staffing requirements.

10 CFR 50.47(b) and 10 CFR 50, Appendix E, establish emergency planning standards that require: 1) adequate staffing, 2) satisfactory performance of key functional areas and critical tasks, and 3) timely augmentation of the response capability. APS is requesting Nuclear Regulatory Commission (NRC) approval of proposed changes to the Emergency Plan for PVNGS. The proposed changes would revise the staffing requirement for the Shift Manager/Emergency Coordinator position in the PVNGS Emergency Plan along with staff augmentation times (120 minutes for both normal and off normal timeframes).

Specifically, the proposed changes would revise the requirement for APS to maintain three Shift Manager/Emergency Coordinators on shift to one Shift Manager/Emergency Coordinator for the site with another Emergency Coordinator qualified individual on shift that has a senior reactor operator level of knowledge. Additionally, the current augmentation time for normal hours would be changed from 60 minutes to as soon as possible but no later than 120 minutes after declaration of an Alert or higher emergency classification level.

An evaluation of the proposed changes pursuant to 10 CFR 50.54, "Conditions of licenses,"

paragraph (q), "Emergency plans," determined that the proposed changes result in a reduction in effectiveness of the Emergency Plans for the affected facilities and, therefore, require prior NRC approval.

A pre-submittal call was held with the NRC staff on January 23, 2025 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML25034A149].

APS has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, Issuance of amendment.

JENNIFER L. SPINA Vice President Nuclear Regulatory and Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 Tel 623.393.4621

102-08914-JLS/MDD ATTN: Document Control Desk U. S. Nuclear Regulatory Commission License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe Page 2 The Enclosure to this letter provides the APS evaluation of the proposed changes. of the Enclosure contains marked-up pages of the current PVNGS Emergency Plan. Attachment 2 of the Enclosure contains clean copy pages of the PVNGS Emergency Plan. Attachment 3 of the Enclosure contains documentation of the State of Arizona review of the proposed changes.

The proposed changes have been reviewed by the Plant Review Board in accordance with the requirements of the PVNGS Quality Assurance Program Description.

No commitments are being made to the NRC by this letter.

APS requests that the changes be reviewed within eight months from the date of NRC acceptance review with implementation within six months following NRC approval.

If you have any questions about this request, please contact Michael D. DiLorenzo, Licensing Department Leader, at (623) 393-3495.

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

Executed on: April 8,20257 Sincerely, JLS/MDD/cr

Enclosure:

License Amendment Request, Palo Verde Nuclear Generating Station, Units 1, 2 and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Renewed Facility Operating License Nos. NPF-41, NPF-51 & NPF-74 (STN 50-528, STN 50-529, and STN 50-530), Evaluation of Proposed Changes cc:

J. D. Monninger NRC Region IV Regional Administrator W. T. Orders NRC NRR Project Manager for PVNGS N. Cuevas Resident Inspector for PVNGS B. D. Goretzki Arizona Department of Health Services - Bureau of Radiation Control Spina, Jennifer (Z08962)

Digitally signed by Spina, Jennifer (Z08962)

Date: 2025.04.08 13:54:35 -07'00'

Enclosure License Amendment Request Palo Verde Nuclear Generating Station, Units 1, 2 and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Renewed Facility Operating License Nos. NPF-41, NPF-51 & NPF-74 (STN 50-528, STN 50-529, and STN 50-530), Evaluation of Proposed Changes

Enclosure License Amendment Request Palo Verde Nuclear Generating Station, Units 1, 2 and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Renewed Facility Operating License Nos. NPF-41, NPF-51 & NPF-74 (STN 50-528, STN 50-529, and STN 50-530), Evaluation of Proposed Changes

Subject:

License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

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

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Supporting Attachments

- Emergency Plan marked-up pages. - Emergency Plan clean copy pages. - State and Local Government Review of License Amendment Changes

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 1

1.0

SUMMARY

DESCRIPTION 10 CFR 50.47(b) and 10 CFR 50 Appendix E establish emergency planning standards that require 1) adequate staffing; 2) satisfactory performance of key functional areas and critical tasks; and 3) timely augmentation of the response capability.

Arizona Public Service (APS) is requesting NRC approval of a proposed revision to the Palo Verde Nuclear Generating Station (PVNGS) Emergency Plan. The proposed changes would revise the staffing requirement for the Shift Manager/Emergency Coordinator position in the PVNGS Emergency Plan along with staff augmentation times (120 minutes for both normal and off normal timeframes).

Specifically, the proposed changes would revise the requirement for APS to maintain three Shift Manager/Emergency Coordinators on shift to only one Shift Manager/Emergency Coordinator for the site with another Emergency Coordinator qualified individual on shift that has a senior reactor operator level of knowledge.

Additionally, the current augmentation time for normal hours would be changed from 60 minutes to as soon as possible but no later than 120 minutes after declaration of an Alert or higher emergency classification level.

The proposed changes have been reviewed considering the requirements of 10 CFR 50.47, "Emergency plans," paragraph (b), 10 CFR 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and other applicable emergency preparedness NRC guidance documents. An evaluation of the proposed changes pursuant to 10 CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," determined that the proposed changes result in a reduction in effectiveness of the Emergency Plans for the affected facilities and, therefore, require prior NRC approval.

2.0 DETAILED DESCRIPTION 2.1 Proposed Changes 2.1.1 The content of the PVNGS Emergency Plan Table 1, "Minimum Staff Requirements,"

will be revised to change the number of Shift Manager/Emergency Coordinators on shift from one per unit to one for the site. This change is consistent with the Technical Specifications and more typically models that of other multiple unit sites. The proposed change will also denote a second qualified Emergency Coordinator who will be on shift and not assigned any technical specification required operating duties. It should be noted that the station intends to continue with three Shift Managers on shift as the normal business practice but desires the flexibility to go down to one Shift Manager for the site with an additional qualified Emergency Coordinator should circumstances warrant.

The specific wording changes are provided in Attachments 1 and 2 of this enclosure as marked-up and clean copies of the affected Emergency Plan pages, respectively. of the License Amendment Request contains information related to the review of the proposed changes by the State of Arizona.

2.1.2 The justification for the additional qualified Emergency Coordinator on shift is based on the same rationale used to qualify an augmentation time of 120 minutes off normal hours as it relates to the Command-and-Control function and is detailed in the Safety Evaluation Report dated July 31, 2020 (reference Section 2.3.5). APS will continue to maintain Shift Managers, Control Room Supervisors and Shift Technical

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 2

Advisors trained to the Emergency Coordinator level. Additionally, the request to extend normal working hours augmentation does not alter the rationale for having a second Emergency Coordinator on shift.

An on-shift analysis utilizing the guidance and methodology in NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities,"

concluded that the proposed changes did not result in conflicting duties for on-shift Shift Manager/Emergency Coordinator.

2.1.3 The content of PVNGS Emergency Plan Table 1, "Minimum Staff Requirements," will be revised to denote a staff augmentation time of as soon as possible but no later than 120 minutes from the declaration of an Alert or greater for both normal and off normal working hours.

The specific wording changes are provided in Attachments 1 and 2 of this enclosure as marked-up and clean copy of the affected Emergency Plan pages, respectively. of the License Amendment Request contains information related to the review of the proposed changes by the State of Arizona.

2.1.4 The justification for the rationale for an augmentation time of as soon as possible but no later than 120 minutes from the declaration of an Alert or higher emergency classification level is based on the current approved staffing off hours. There will not be any change to on shift minimum staffing beyond the reduction of the number of Shift Managers/Emergency Coordinators on shift. APS will continue to staff the full Emergency Response Facilities as soon as practical. The timeframe of 120 minutes for normal work hours allows additional time to report to the site Emergency Response Facilities after declaration of an Alert or higher emergency classification level to compensate for the increase in traffic and community development. It will also provide additional flexibility for plant staff who work from alternative work locations.

2.2 Reason for the Proposed Changes The PVNGS Emergency Plan is being revised to reduce the staffing requirement to maintain three qualified Shift Manager/Emergency Coordinators (one per unit) on a day-to-day basis. It should be noted that the station intends to continue with three shift managers on shift but desires the flexibility to operate with only one shift manager for the site with an additional qualified Emergency Coordinator should circumstances warrant. At all times there will be a minimum of a single Shift Manager on shift to oversee the three units at PVNGS. In addition to a single Shift Manager an additional qualified Emergency Coordinator will be on shift who does not have any Technical Specification required duties. This allows for Command-and-Control relief to the Emergency Coordinator during the first 120 minutes of a declared emergency until facility augmentation is complete. The current PVNGS Technical Specifications do not require a Shift Manager on shift for each unit, only one for the site to meet the 10CFR50.54(m) requirements. The Updated Final Safety Analysis Report (UFSAR) will be revised to only require a single Shift Manager for the site in conjunction with the implementation of this change, per 10 CFR 50.59.

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 3

2.3 Palo Verde Nuclear Generating Station Emergency Plan Background The PVNGS Nuclear Generating Station (Units 1, 2 and 3) is located west of Phoenix, AZ. The plant consists of a single site with three Pressurized-Water Reactors (PWRs).

The Facility Operating License (FOL) for Unit 1 was issued on June 1, 1985, and renewed on April 21, 2011, the FOL for Unit 2 was issued April 24, 1986, and renewed on April 21, 2011, and the FOL for Unit 3 was issued November 25, 1987, and also renewed on April 21, 2011.

The PVNGS Emergency Plan provides direction and guidance through emergency plan implementing procedures (EPIP), and associated program administrative documents.

The PVNGS Emergency Plan outlines the basis for response actions that would be implemented in an emergency. The Emergency Plan establishes the concepts, evaluation and assessment criteria, and protective actions that are necessary to limit and mitigate the consequences of potential or actual radiological emergencies.

Listed below are relevant documents associated with PVNGS Emergency Response Organization staffing and augmentation.

2.3.1 PVNGS Emergency Plan, Revision 3 - PVNGS's original Emergency Plan Safety Evaluation (SER) was issued in NUREG-0857 and the Supplements culminating in 1984. The SER contained multiple supplements associated with the Emergency Planning function. This corresponded to Revision 5 of the shared Station Emergency Plan that closed out all of the outstanding licensing conditions identified in NUREG-0857. The final Safety Evaluation Report removing the initial licensing conditions was not issued until later as October of 2000 (TAC NOS. MA7746, MA7747, AND MA7748).

Revision 3 of the PVNGS Emergency Plan lists all positions in the Emergency Response Organization (ERO) and does not clearly differentiate minimum staff positions. In subsequent revisions, a clear list of the positions that correspond with NUREG-0654 Table B1 was put in the Emergency Plan.

2.3.2 Regional Acceptance Letter dated October 1994 of Revision 14 of the PVNGS Emergency Plan. Note also discussed in SER (TACs. MB7822 / MB7823 / MB7824) dated March 26, 2004. This revision approved changes to the emergency response organization. NRC Correspondence dated February 25, 1994, Proposed Revision 13 to the (PVNGS) Emergency Plan (Legacy ADAMS Accession No. 9403090086).

2.3.3 Regional Acceptance Letter dated April 1995 of Revision 15 of the PVNGS Emergency Plan. This revision approved changes to the emergency response organization.

Additional information regarding approval can be found in NRC Inspection Report dated August 9, 2021 (ML21217A331).

2.3.4 PVNGS, Units 1, 2, and 3 - Emergency Plan Change to Reduce Number of Shift Technical Advisors in Emergency Response Organization Staffing (TACs. MB7822 /

MB7823 / MB7824) dated March 26, 2004. This revision removed one of three STAs but listed the emergency response positions as it referenced the changes to Revision 27 of the Emergency Plan.

2.3.5 PVNGS Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Docket Nos. STN 50-528, 50-529, 50-530 and 72-44, Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 License Amendment Request for Changes to Emergency Plan Staffing Requirements - Issuance of Amendment Nos 213, 213, and 213 to

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 4

Revise Emergency Plan Staff Augmentation Times, dated July 31, 2020 (EPID L-2019-LLA-0222) (ML20163A037) 2.4 On-Shift Staffing Analysis (OSA)

Regulatory Issue Summary (RIS) 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation, states that an on-shift staffing analysis under 10 CFR 50, Appendix E, Section IV.A.9 should not be used to provide the primary basis to support the Technical Evaluation of a License Amendment Request (LAR). The OSA however may be utilized as part of the overall evaluation of staffing changes. The RIS states:

an evaluation performed using only the guidance of NEI 10-05 does not satisfy the requirement to identify and evaluate changes to ERO augmentation timing or ERO augmentation staffing that reduces the capability to perform an emergency planning function.

In conjunction with this License Amendment Request, APS validated the results of the OSA performed under 10 CFR 50, Appendix E, Section IV.A.9. The results are used to support the conclusions made in this License Amendment Request for on-shift Shift Manager staffing; however, APS understands the OSA comprises a select set of identified scenarios and should not be used as the sole basis for the conclusions in the Technical Evaluation.

The PVNGS OSA is considered part of the station Emergency Plan and is maintained as a standalone document referenced in the Emergency Plan.

The changes submitted have been evaluated under the requirements of 10 CFR 50, Appendix E, Section IV.A.9 and have been found consistent with the OSA evaluation currently in place.

3.0 TECHNICAL EVALUATION

3.1 Functional Analysis 3.1.1 EP Function: Command-and-Control (formerly Emergency Direction and Control)

The Command-and-Control function includes the following tasks as defined in the NUREG-0654, Revision 2 guidance:

Provide overall ERO command-and-control, until relieved.

Approve Emergency Action Level (EAL) and/or Protective Action Recommendation (PAR) classifications/determinations, until relieved.

Authorize personnel dose extensions, until relieved.

This function is important for effective emergency response because adequate Command-and-Control enables the PVNGSs ERO to effectively develop priorities for response planning and corrective action(s) and to provide a unified approach to the event response by providing a single individual with overall command-and-control authority. The function is staffed and always maintained and is assigned to the Operations Shift Manager (SM) with another qualified Emergency Coordinator on shift. The augmentation (relief) of this position is intended to relieve the SM of EP functions so that the SM can focus on the event response from an operations

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 5

perspective. As plant conditions support, this occurs with TSC and EOF facility activation currently at 60/120 minutes (proposed change to as soon as possible but no later than 120 minutes at all times following an Alert declaration, or greater),

and is a position staffed by the TSC Emergency Coordinator and EOF Emergency Operations Director. The EOF Emergency Operations Director takes responsibility for those EP functions associated with PARs and notification to the State and County following activation of the EOF, also at the Alert or greater Emergency Classification Level (ECL). The TSC Emergency Coordinator assumes the remaining functions from the Shift Manager/Emergency Coordinator.

a. On-Shift Staff - The table below identifies the current, proposed, and NUREG-0654, Revision 2, guidance for this EP Function.

EP Function: Command-and-Control - On-shift Minimum Staff Current Emergency Plan, Table 1 Proposed Emergency Plan, Table 1 NUREG-0654, Revision 2 Guidance (1)* Shift Manager /

Emergency Coordinator per unit (1)* Shift Manager

/ Emergency Coordinator for site (1) *Qualified Emergency Coordinator (1)* Shift Manager /

Emergency Coordinator

May be performed by persons assigned other functions Emergency Plan Change Assessment PVNGSs existing on-shift staffing table currently exceeds the requirement of NUREG-0654, Revision 2 in that APS has two additionally qualified Shift Manager/Emergency Coordinators on shift allowing for Command-and-Control relief as needed during the 120-minute augmentation timeframe. The total number of staffed ECs will be reduced to two, one being the Shift Manager/EC and the other being a qualified Emergency Coordinator who has a senior reactor operator level of knowledge.

NUREG-0654, Revision 2 Alignment APS will maintain the existing title for this EP Function. The NUREG-0654, Revision 2 Operations Shift Manager will be titled Shift Manager/EC, however, the number of qualified Emergency Coordinators on shift will continue to exceed the NUREG-0654 guidance.

Emergency Plan Change Assessment PVNGSs current Emergency Plan allows a single Emergency Coordinator in the Command-and-Control function with two additional Shift Managers able to stand in the position. The elimination of the two Shift Managers from the available on shift relief and replacing them with a qualified Emergency Coordinator with a senior reactor operator level of knowledge ensures adequate relief for the Shift Manager/Emergency

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 6

Coordinator during the augmentation period (120 minutes). The other qualified Emergency Coordinator may have other collateral duties as long as they are not part of the Technical Specification required positions. No change in the Shift Manager/Emergency Coordinator role in this function will take place.

The UFSAR (Section 13.1.2.6.2 page 13-1-6 and 18.U.A.1.3 page 18.I.A-8) and plant procedures (40DP-90OP02 Conduct of Operations Step 2.3) allow for the Control Room Supervisor to stand in for the Shift Manager in the event the Shift Manager may be out of the affected unit Control Room. That includes promptly assessing the plant during the initial stages of an emergency. That functional capability is periodically assessed during Licensed Operations Continuing Training (LOCT) to ensure a timely assessment and declaration of an emergency capability is maintained.

NUREG-0654, Revision 2 Alignment APS will continue to maintain an Emergency Coordinator on shift consistent with the guidance. There are no differences or deviations from the NUREG-0654, Revision 2 guidance.

3.1.2 EP Function: Emergency Response Organization Staff Augmentation APS is proposing a change to the PVNGS emergency response organization staff augmentation time from the current 60/120 minutes (normal/off normal hours) to as soon as possible but not to exceed 120 minutes at all times following the declaration of an Alert or higher emergency classification.

Emergency Plan Change Assessment The justification for the staff augmentation times included in this request is based on the current Emergency Plan. In 1993, the NRC was requested to approve Revision 13 of the Emergency Plan (Reference 6.12) which provided the rationale for an augmentation time of 60 minutes during normal working hours and 120 minutes during off normal hours. In 1994, the NRC granted approval for that change (Reference 6.13). The NRC used that same timeframe in the Safety Evaluation dated March 19, 2004 (Reference 6.14), that approved the change in the number of Shift Technical Advisors on-shift. The rationale for the timeframe remains valid. APS believes the following rationale for implementing an as soon as possible but not to exceed 120 minutes augmentation would be valid for normal working hours:

o There is no more risk of an accident or emergency during Off-Normal Hours than Normal Working Hours, nor would the level of severity be different, if an event were to occur.

o The PVNGS remote location and property size makes 60-minute augmentation a challenge.

o Required augmented ERO members maintain unescorted access and fall under the fitness for duty program which also requires a 120-minute response time during normal working hours.

o Existing traffic and community development are increasing and travel during peak times both from the site to the EOF and offsite to onsite are challenged.

o The entire ERO, including the JIC, is activated for an Alert or higher ECL.

o PVNGS continues to use an all call/all come augmentation response where the entire ERO is called out at the Alert level, in addition to the designated duty team.

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 7

o Additional resources to support the following functions remain in place at all times:

Command-and-Control:

Augmented Command-and-Control assistance to the affected Unit Shift Manager in the form of a second qualified Emergency Coordinator.

Shift Managers, Control Room Supervisors and Shift Technical Advisors are all trained to the Emergency Coordinator position.

Radiation Protection:

Additional Radiation Protection support for onsite and offsite field monitoring is available if needed.

Dose Assessment and Radiation Protection leadership available on shift.

Repair Teams:

The number of plant equipment operators on site (12, 4 per unit) allows for support of operations and maintenance critical activities at all times.

One mechanic, one electrician and one Instrumentation and Controls (I&C) technician to support critical maintenance activities at all times.

Communications:

Offsite communications to State and Local government and the NRC is in place.

Engineering Support:

Unaffected unit Shift Technical Advisor.

Security Leadership to support the callout process.

3.2 Other Changes to the Emergency Plan 3.2.1 None 3.3 Impact of Proposed Changes on State Emergency Plan 3.3.1 Potential Impact of ERO Changes on Off-Site Emergency Response Organizational Interfaces APS provided a draft copy of the License Amendment Request to representatives from the Arizona Department of Emergency and Military Affairs (ADEMA) to ensure no adverse impact on the ability of State and local response organizations to effectively implement their FEMA-approved Radiological Emergency Response Plan (RERP) plans would exist.

ADEMA provided a letter dated February 21, 2025, stating ADEMA completed their review of a draft copy of the License Amendment Request. The objective of the review was to identify any potential impacts on the State of Arizona/Maricopa County Offsite Emergency Response Plan. ADEMA concluded that based upon the review of the document the proposed changes will not adversely impact the offsite programs nor the health and welfare of the public. ADEMA concurs and recommends approval of the LAR. See Attachment 3 State and Local Government Review of License Amendment Changes for a copy of the referenced correspondence.

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 8

4.0 REGULATORY EVALUATION

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

Section 50.47, "Emergency Plans," of Title 10 of the Code of Federal Regulations (10 CFR) sets forth the U.S. Nuclear Regulatory Commissions (NRC) emergency plan requirements for nuclear power plant facilities. The regulation in 10 CFR 50.47(a)(1)(i) states, in part:

no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Section 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Planning Standard (2) of this section requires that:

On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities and offsite support and response activities are specified.

Section IV.A of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, states:

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

1.

A description of the normal plant operating organization.

2.

A description of the onsite emergency response organization (ERO) with a detailed discussion of:

a.

Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency.

b.

Plant staff emergency assignments.

c.

Authorities, responsibilities, and duties of an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures.

3.

A description, by position and function to be performed, of the licensee's

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 9

headquarters personnel who will be sent to the plant site to augment the onsite emergency organization.

4.

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

5.

Identification, by position and function to be performed, of other employees of the licensee with special qualifications for coping with emergency conditions that may arise. Other persons with special qualifications, such as consultants, who are n o t employees of the licensee and who may be called upon for assistance for emergencies shall also be identified. The special qualifications of these persons shall be described.

6.

A description of the local offsite services to be provided in support of the licensee's emergency organization.

7.

By June 23, 2014, identification of, and a description of the assistance expected from, appropriate State, local, and Federal agencies with responsibilities for coping with emergencies, including hostile action at the site. For purposes of this appendix, "hostile action" is defined as an act directed toward a nuclear power plant or its personnel that include the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.

8.

Identification of the State and/or local officials responsible for planning for, ordering, and controlling appropriate protective actions, including evacuations when necessary.

9.

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

Revision 1 to NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980, was intended to aid licensees, applicants for licenses, or State and local emergency response organizations in the development of their Radiological Emergency Response Plans. The NRC endorsed this document for use in this effort via Revision 2 to Regulatory Guide (RG) 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, dated October 1981. RG 1.101 allowed for licensees to submit alternatives to the guidance provided in NUREG-0654/FEMA-REP-1 for staff review and approval if necessary.

Section II.B of NUREG-0654/FEMA-REP-1, Revision 1, states, in part:

On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available, and the interfaces among various onsite response activities

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 10 and offsite support and response activities are specified.

Evaluation Criteria 5 of Section II.B of NUREG-0654/FEMA-REP-1, Revision 1, states, in part:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

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

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

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

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

NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants, provides guidance for addressing emergency planning requirements for nuclear power plants. This guidance is based on changes to Emergency preparedness regulations 10 CFR 50.47 and 10 CFR 50 Appendix E, that were published in the Federal Register (FR) on November 23, 2011 (i.e.,

reference 76FR72560). The guidance should be used by licensees and applicants for implementing changes to onsite EP programs based on the revised emergency preparedness requirements and by NRC for reviewing the adequacy of the revised onsite emergency preparedness programs.

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 11 In addition, APS also reviewed NUREG-0654, Revision 2 (NUREG-0654/FEMA-REP-1, Revision 2), Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated May 2015 and RIS 2016-10, License Amendment Requests for Changes to Emergency Response Organization Staffing and Augmentation (ML15338A291) in support of this submittal.

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

4.2 Precedent Numerous multi-unit sites have a single Shift Manager as Emergency Coordinator.

APS currently has a 120-minute off hours augmentation for the full Emergency Response Organization following declaration of an Alert or higher emergency classification level based on additional resources placed on shift.

Callaway Nuclear Station submitted a license amendment for standardizing their augmentation time to a single number on February 8, 2022 (ML22039A317). The license amendment was supplemented during a request for additional information on July 13, 2022 (ML22194A80), and a final Safety Evaluation was obtained on February 23, 2023 (ML22361A070).

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit," Arizona Public Service Company (APS) requests amendments to the following licenses:

NPF-41, NPF-51 & NPF Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2 and 3, respectively.

The requested amendments to the licenses support changes to the PVNGS Emergency Plan based upon completion of a supporting evaluation of onsite Emergency Response Organization (ERO) staffing.

The proposed changes have been reviewed considering the applicable requirements of 10 CFR 50.47, 10 CFR 50 Appendix E, and other applicable NRC guidance criteria.

APS has evaluated the proposed changes to the PVNGS Emergency Plan and determined that the changes do not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92, "Issuance of amendment," is provided below.

1.

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

Response: No.

The proposed changes to the PVNGS Emergency Plan do not increase the probability or consequences of an accident. The proposed changes do not

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 12 impact the function of plant Structures, Systems, or Components (SSCs). The proposed changes do not affect accident initiators or accident precursors, nor do the changes alter design assumptions. The proposed changes do not alter or prevent the ability of the onsite ERO to perform their intended functions to mitigate the consequences of an accident or event. The proposed changes remove ERO positions no longer credited or considered necessary in support of Emergency Plan implementation.

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

2.

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

Response: No.

The proposed changes have no impact on the design, function, or operation of any plant SSCs. The proposed changes do not affect plant equipment or accident analyses. The proposed changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed changes do not introduce failure modes that could result in a new accident, and the proposed changes do not alter assumptions made in the safety analysis. The proposed changes remove ERO positions no longer credited or considered necessary in support of Emergency Plan implementation.

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

3.

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

Response: No.

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

The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses.

There are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes. Margins of safety are unaffected by the proposed changes to the ERO staffing.

The proposed changes are associated with the PVNGS Emergency Plan staffing and do not impact operation of the plant or its response to transients or accidents. The proposed changes do not affect the Technical Specifications. The proposed changes do not involve a change in the method of plant operation, and no accident analyses

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 13 will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by these proposed changes. The proposed changes to the Emergency Plan will continue to provide the necessary onsite ERO response staff.

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

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

5.0 ENVIRONMENTAL CONSIDERATION

The proposed changes are applicable to emergency planning standards for PVNGS involving proposed ERO staffing changes. The proposed changes do not reduce the capability to meet the emergency planning standards established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure.

Accordingly, the proposed changes meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the proposed changes.

6.0 REFERENCES

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

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

6.3 NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, Washington, DC, November 1980.

6.4 10 CFR 50.47, Emergency plans.

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

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

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

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe 14 6.8 NUREG-0857, Safety Evaluation Report related to the operation of Palo Verde Nuclear Generating Station Units 1, 2, and 3 (Dockets Nos. STN 50-528, STN 50-529, and STN 50-530), dated November 1981.

6.9 NUREG-0857, Safety Evaluation Report related to the operation of Palo Verde Nuclear Generating Station Units 1, 2, and 3 (Dockets Nos. STN 50-528, STN 50-529, and STN 50-530), Supplement 1, Appendix C, dated November 1981.

6.10 NUREG-0857, Safety Evaluation Report related to the operation of Palo Verde Nuclear Generating Station Units 1, 2, and 3 (Dockets Nos. STN 50-528, STN 50-529, and STN 50-530), Supplements 4, 5, 7, and 8 Section 13, Emergency Planning. (various dates) 6.11 Palo Verde 1, 2, & 3 Amendment, To Remove or Correct Outdated Administrative Information, and Remove Completed Licensing Conditions From the Licenses, (MA7746, MA7747, MA7748) dated October 10, 2000.

6.12 PVNGS Correspondence 102-02733, dated November 16, 1993, Submittal of Revision 13 of Emergency Plan.

6.13 NRC Correspondence dated February 25, 1994, PROPOSED REVISION 13 TO THE (PVNGS) EMERGENCY PLAN.

6.14 PVNGS Units 1, 2, and 3 - Emergency Plan Change to Reduce Number of Shift Technical Advisors in Emergency Response Organization Staffing (TACs. MB7822 /

MB7823 / MB7824), dated March 26, 2004.

6.15 Palo Verde Nuclear Generating Station, Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 213, 213, and 213 to Revise Emergency Plan Staff Augmentation Times (EPID L-2019-LLA-0222) (ML20163A037).

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe Emergency Plan Marked-up Pages

PVNGS EMERGENCY PLAN REVISION 76 PAGE 20 OF 379 In the event a member of the ERO minimum staff becomes incapacitated or is otherwise unavailable, they shall be replaced as soon as reasonably possible. Operating unit staff who are ERO members are governed by PVNGS Technical Specification 5.2 and its exceptions.

During normal station work hours, notification of on-site ERO may occur via PA announcement, emergency evacuation alarm system and/or mobile devices.

During off-hours, notification of ERO is accomplished by activating the automated callout system. A manual system is also available if the automated system is not available.

For an Unusual Event classification, on-shift personnel respond to the emergency and the event is directed from the affected unit Control Room/ STSC. Command of the situation remains there with the on-shift Emergency Coordinator (EC) until termination/recovery or reclassification to a higher-level emergency occurs. For events affecting all three units, command and control is in Unit 1. APS/Palo Verde Communications provides media interface during an Unusual Event.

In the event of an Alert or higher classification level, the on-shift EC orders the activation of the TSC, OSC, EOF, and JIC. The on-site ERO is directed by the EC-TSC. The EOD in the EOF provides overall coordination of the event and direction of the Palo Verde ERO.

4.2.1 ON-SHIFT EMERGENCY ORGANIZATION Palo Verde Nuclear Generating Station on-shift emergency organization is sufficient to permit the required mitigation response and effectively implement the Emergency Plan as required in 10CFR50 Appendix E.

Table 1 of the Emergency Plan reflects the results of the Palo Verde On-Shift Emergency Response Organization Staffing and Capabilities analysis as required by 10 CFR 50, Appendix E. The initial Palo Verde On-Shift Emergency Response Organization Staffing and Capabilities analysis is retained as Correspondence #090-05063 (RCTSAI 4164598) and updated as appropriate.

The On-shift Emergency Organization (Figure 1) consists of the following positions:

4.2.1.1 Emergency Coordinator (EC)

[Ref. INPO IER L1 13-10, Recommendation 5i]

The affected unitsite Shift Manager (SM) or designee initially assumes the responsibilities of the EC and is responsible for the command and control of the plant emergency response. Palo Verde maintains an additional qualified Emergency Coordinator on shift in addition to the Technical Specification required operating crew. Members of the normal

PVNGS EMERGENCY PLAN REVISION 76 PAGE 21 OF 379 shift organization assume emergency positions to carry out actions as described below.

The EC has the responsibility and authority to initiate emergency actions, including providing notification and Protective Action Recommendations (PAR) to governmental agencies responsible for off-site emergency measures. The EC is also responsible for communication of plant status and radiological conditions including dose projection results as appropriate.

Procedures provide for accelerated calls and verbal notification to the NRC using the Emergency Notification System (ENS) of Security-based events considered to be a credible imminent threat or Hostile Action.

The affected unitsite Shift Manager may be relieved as EC by another qualified EC. At an Alert or higher emergency classification level, the EC directs the Security Director to initiate callouts to the ERO in accordance with the associated implementing procedure. Upon arrival of the designated EC-TSC, the EC-STSC

At the onset of an incident, the EC has the following responsibilities:

Notification of offsite emergency management agencies. (non-delegable duty until relieved by EOD)

Making protective action recommendations as necessary to offsite emergency management agencies. (non-delegable duty until relieved by EOD)

Classification of emergency events (non-delegable duty)

Determination of the necessity for site evacuation and authorization for emergency workers to exceed 10CFR20 exposure limits Activation of the Palo Verde ERO for an alert or higher emergency classification level 4.2.1.2 Control Room Supervisor The Control Room Supervisor (CRS) located in the unit control rooms, reports to the EC. The CRS performs initial assessment and evaluation of any abnormal or emergency conditions. In the absence of the Shift Manager/EC, the Control Room Supervisor will perform the initial assessment of the emergency plan and perform any required actions.

After the EC declares an emergency, the CRS maintains the normal duties of directing the Nuclear Operators and assisting the EC.

PVNGS EMERGENCY PLAN REVISION 76 PAGE 34 OF 379 TABLE 1 MINIMUM SHIFT STAFFING FOR EMERGENCIES TABLE 1 MINIMUM SHIFT STAFFING FOR EMERGENCIES Emergency Preparedness Function On Shift Technical Support Center (TSC)/

Operations Support Center (OSC)

Emergency Operations Facility (EOF)/ Joint Information Center (JIC)

Alert or Greater Augment w/in 60/120-min Note 2 Alert or Greater Augment w/in 60 / 120-min Note 2 Command & Control Provide overall ERO command and control until relieved.

Approve emergency action level (EAL) and/or PAR classifications until relieved.

Authorize personnel dose extensions until relieved.

Shift Manager* / Emergency Coordinator * -Note 1 Emergency Coordinator Note 1 Technical Specification Required Operating Crew Control Room Supervisor (1 per unit)

Control Room Operators (2 per unit)

One per unit (1) Emergency Coordinator (TSC)

(1) Emergency Operations Director (EOF)

Communications Communicate EAL and PAR classifications to offsite agencies, including the NRC, until relieved.

(1) State and Local Communicator (STSC)

Note 1 (1) NRC Communicator (STSC)

Note 1 (1) NRC Communicator (TSC)

Additional Communicators as needed (1) State and Local NAN Communicator (EOF)

Additional Communicators as needed

PVNGS EMERGENCY PLAN REVISION 76 PAGE 35 OF 379 TABLE 1 MINIMUM SHIFT STAFFING FOR EMERGENCIES Emergency Preparedness Function On Shift Technical Support Center (TSC)/

Operations Support Center (OSC)

Emergency Operations Facility (EOF)/ Joint Information Center (JIC)

Alert or Greater Augment w/in 60/120-min Note 2 Alert or Greater Augment w/in 60 / 120-min Note 2 Repair Team Activities Auxiliary Operators (4 per unit=12 includes qualified STSC Communicator and STSC NRC Communicator on shift) -Note 1 (1) Mechanical Maintenance Technician-Note 1 (1) Electrical Maintenance Technician-Note 1 (1) I&C Maintenance Technician-Note 1 (1)

Mechanical Maintenance Technician (OSC)

(1) Electrical Maintenance Technician (OSC)

(1)

I&C Maintenance Technician (OSC)

Additional Maintenance technicians as needed Not applicable Supervision of Repair Team Activities Shift Manager/ Emergency Coordinator (1) -Note 1 (1) OSC Manager (2) OSC Repair Team Coordinators (1) OSC RP Group Lead Not applicable

PVNGS EMERGENCY PLAN REVISION 76 PAGE 36 OF 379 TABLE 1 MINIMUM SHIFT STAFFING FOR EMERGENCIES Emergency Preparedness Function On Shift Technical Support Center (TSC)/

Operations Support Center (OSC)

Emergency Operations Facility (EOF)/ Joint Information Center (JIC)

Alert or Greater Augment w/in 60/120-min Note 2 Alert or Greater Augment w/in 60 / 120-min Note 2 Radiation Protection /

Field Monitoring Provide qualified health physics (RP) coverage for responders accessing potentially unknown radiological environments during emergency conditions.

Provide in-plant surveys, onsite surveys, and offsite surveys.

Support offsite field monitoring teams1.

Radiation Monitoring.

(3) RP Technicians (1 per unit)

Onsite / Offsite FMT (1) RP Technician (1) RFAT Driver Note: RP staffed from onshift RP technicians if warranted.

(6)

Additional RP Technicians Offsite FMT B (1) RP Technician (from augmented RPT s)

(1) RFAT Driver Not applicable Supervision of Radiation Protection Evaluate and assess plant and offsite radiological data in the development of onsite protective actions and offsite PARs, until relieved.

Radiation Protection Monitor/RP Group Lead - Note 1

(relocates to OSC as RP Group Lead once TSC/EOF manned)

(1) Radiation Protection Coordinator (TSC)

(1) Radiological Assessment Coordinator (EOF)

Dose Assessments/

Projections Perform dose assessments/projections and provide input to applicable PAR decision-maker, until relieved by the EOF.

Radiation Protection Monitor /

RP Group Lead - Note 1 (Relocates to OSC as RP Group Lead once TSC/EOF manned)

Not applicable in TSC (1) Dose Assessment Health Physicist (EOF)

PVNGS EMERGENCY PLAN REVISION 76 PAGE 37 OF 379 TABLE 1 MINIMUM SHIFT STAFFING FOR EMERGENCIES Emergency Preparedness Function On Shift Technical Support Center (TSC)/

Operations Support Center (OSC)

Emergency Operations Facility (EOF)/ Joint Information Center (JIC)

Alert or Greater Augment w/in 60/120-min Note 2 Alert or Greater Augment w/in 60 / 120-min Note 2 Emergency Classifications Evaluate plant conditions and recommend emergency classifications, until relieved.

Affected Unit Shift Technical Advisor (1 of 2 per site) -

Note 1 (1) Operations Manager (TSC)

Not applicable Engineering Provide engineering coverage related to the specific discipline of the assigned engineer, until relieved Unaffected Unit Shift Technical Advisor* (1 of 2 per site)

Core/Thermal Hydraulics Engineer TSC Engineering Staff:

(1) Electrical/ I&C Engineer (1) Mechanical Engineer (1) Reactor Analyst*

Not applicable JIC Manage and coordinate media information related to the event.

Not applicable Staff for handling media inquiries (may not be a TSC/ OSC function, but needs to be established at this point).

JIC Manager Security (1) Security Director (TSC)

Coordinate security related activities and information with the Emergency Coordinator.

Security staffing is per the site Security Plan.

Not applicable Not applicable Fire Team Fire Team staffing per site Fire Protection Program

PVNGS EMERGENCY PLAN REVISION 76 PAGE 38 OF 379 Note 1 - Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time. A shift staffing evaluation in accordance with 10 CFR Part 50, Appendix E has been performed to support assignment of multiple roles to individual on-shift. For augmented ERO positions, a similar approach is acceptable for evaluating whether personnel can adequately perform multiple functions without having competing priorities.

Note 22-Augmentation during normal working hours is normally from resources onsite along with some offsite personnel. but within 60 minutes, Ooff hours augmentation is normally within 120 minutes. The emergency response facilities are augmented as soon as possible but no later than 120 minutes after an alert or higher emergencyDMBTTJGJDBUJPOMFWFM

PVNGS EMERGENCY PLAN REVISION 76 PAGE 39 OF 379 FIGURE 1 ON SHIFT PALO VERDE EMERGENCY RESPONSE ORGANIZATION

PVNGS EMERGENCY PLAN REVISION 76 PAGE 67 OF 379 Radiological Assessment Coordinator Environmental Assessment Line Radiological Assessment Coordinator Control Room Line Engineering Director Technical Line Engineering Director OSC Line Radiological Assessment Communicator TSC Line Each of the phones on the dedicated lines also functions as a normal in-plant PVNGS phone.

These lines are discussed in more detail in the applicable subsections that follow.

The EC/EOD Line, Maintenance Line, and Radiological Line are administratively dedicated lines that are also available for use in an emergency and are discussed in the subsections that follow. The phones listed below consist of single line and multi-line phones. The multiline phones are equipped with a power fail line and a PBX line.

7.2.1 CONTROL ROOM LINE The Control Room Line has a dedicated primary line providing communications links with conference capability between the Control Room, the TSC, the Unit STSC, the EOF, the OSC, and the RSP.

7.2.2 ENVIRONMENTAL ASSESSMENT LINE The Environmental Assessment Line has a dedicated primary and backup line providing communications links with conference capability between the TSC, EOF, the Control Room and the RSP.

7.2.3 EC/EOD LINE The EC/EOD line has a separate dedicated primary line with conference capability among the EOF, TSC, the Unit, and the RSP.

This line provides a communications link between the ECs. It also permits three-way conversations between the EC-TSC, EOD and the Shift Manager/STSC Emergency Coordinator.

7.2.4 EOF LINE The EOF Line has a dedicated primary line providing communications links with conference capability between the EOF, the Control Room, the TSC, the Unit STSC, the OSC, and the RSP.

Enclosure - License Amendment Request for Approval of Changes to Emergency Plan Shift Manager/Emergency Coordinator Staffing Requirements and Staff Augmentation Timeframe Emergency Plan Clean Copy Pages