NL-14-132, Response to 03/12/2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendations of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dia-ichi.

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Response to 03/12/2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendations of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dia-ichi.
ML14328A631
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 11/03/2014
From:
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-132
Download: ML14328A631 (35)
v • d • e


Text

Enterav Nuclear Northeast Indian Point Energy Center Entergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President NL-14-132 November 3, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Response to March 12, 2012, Request for Information (RFI) Pursuant to Title 10 of the Code of Federal Regulation 50.54(f) Regarding Recommendations of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dia-ichi Accident, Enclosure 5 Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment Indian Point Energy Center - Units 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

1. NRC letter to Entergy, RFI Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the NTTF Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012 (ML12053A340)
2. Entergy letter to NRC, Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Plan for Completing Emergency Communication and Staffing Assessments, dated May 11, 2012 (NL-12-054)
3. Nuclear Energy Institute (NEI) 12-01, Revision 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities
4. NRC Letter to NEI, dated May 15, 2012, USNRC Review of NEI 12-01, Guideline for Assessing Beyond-Design-Basis Accident Response Staffing and Communications Capabilities, Revision 0, dated May 2012

Dear Sir or Madam:

On March 12, 2012, the NRC issued Reference 1 which included Recommendation 9.3 in regarding the specific Requested Actions, Requested Information, and Required Response associated with Emergency Preparedness - Staffing. In accordance with 10 CFR 50.54,

NL-14-122 Docket Nos. 50-247 and 50-286 Page 2 of 2 "Conditions of licenses," paragraph (f), addressees were requested to submit a written response to the information requests within 90 days.

In accordance with Reference 1, Enclosure 5, Entergy Operations Inc. submitted an alternative course of action for performing the requested actions and providing the requested information (Reference 2). Enclosure 1 of Reference 2 described the alternative course of action and schedule for responding to the Emergency Preparedness - Staffing, Requested Information Items 1, 2, and

6. In accordance with Reference 2, Enclosure 1, Attachment 1 to this letter provides the required responses to Items 1, 2, and 6. to this letter provides the Indian Point Energy Center (IPEC) Phase 2 Staffing Assessment Report. The IPEC Phase 2 Staffing Assessment Report follows the assessment process methodology described in NEI 12-01, Reference 3, which was endorsed by the NRC, Reference 4.

There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, IPEC Licensing Manager at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on November 3, 2014.

Sincerely, JAV/sp Attachments: Response to the Requested Information NTTF Recommendation 9.3 Staffing, Requests, 1, 2, and 6

Enclosure:

Entergy IPEC Units 2 and 3 NEI 12-01 Phase 2 Staffing Assessment cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. David Lew, Acting Regional Administrator, NRC Region 1 NRC Resident Inspector Mr. John B. Rhodes, President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT TO NL-14-132 RESPONSE TO THE REQUESTED INFORMATION NTTF RECOMMENDATION 9.3 STAFFING, REQUESTS, 1, 2, AND 6 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNITS NOS 2 AND 3 DOCKET NOS. 50-247 and 50-286

NL-14-132 Docket Nos. 50-247 and 50-286 Attachment Page 1 of 3 Response to the Requested Information NTTF Recommendation 9.3 Staffing, Requests, 1, 2, and 6 Perform and provide an assessment of the staffing necessary to implement actions that address NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis-External-Events (EA-12-049). Refer to Section 3 of the document (Nuclear Energy Institute (NEI) 12-01) for guidance. Develop an implementation schedule for staffing changes and identify changes to the emergency plan.

(1) Requested Item 1 Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the Discussion section of Reference 1, Enclosure 5.

The Enclosure to this letter provides the IPEC Phase 2 Staffing Assessment Report conducted pursuant to Reference 2. A detailed timeline was developed based on a tabletop discussion and review of the on-shift response to the postulated beyond-design-basis external event (BDBEE) extended loss of alternating current (AC) power (ELAP). On-shift and augmented staff response was determined based upon the tabletop team members' review of applicable plant procedures and draft diverse and flexible support guidelines (FSGs) for the strategies identified at the time of the assessment. The focus of the timeline was to identify all onsite resources that would be required to execute each task to implement the initial and transition phase FLEX mitigating strategies and the Emergency Plan.

The tables describing the required minimum staffing, task implementation timeline, and NEI 10-05 modified staffing analysis tables for IPEC are included in the IPEC Phase 2 Staffing Assessment Report.

The Phase 2 Staffing Assessment concluded that the current minimum shift staffing is sufficient to execute all required initial and transition phase tasks actions, as well as the Emergency Plan functions, without the assignment of collateral duties that would adversely affect the ability to execute the Emergency Plan functions. Should a change to this conclusion resulting from revisions to strategies or implementation guidance occur it would be documented in the Final Overall Integrated Plan.

This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:

(la) How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NRC NTTF Recommendation 4.2.

NL-14-132 Docket Nos. 50-247 and 50-286 Attachment Page 2 of 3 Portable FLEX equipment stored in the FLEX storage building is planned to be trailer-mounted or on wheels for ease of deployment. Some equipment such as hoses and cables may be stored in cabinets or boxes inside plant buildings that have been analyzed for the BOBEE conditions. Available dedicated vehicles are planned to be utilized for deploying FLEX equipment from the storage location to the staging areas on site. These vehicles would also be used for debris removal.

A FLEX support guideline would be implemented to clear debris to allow for moving and setup of FLEX portable equipment.

In the specific case of a flooding event, it is expected that notice is given well before a flood level approaches either plant grade and/or the magnitude of the probable maximum flood since it is due t o a hurricane. Therefore, it is assumed that at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is available for the deployment of FLEX equipment for the flooding scenario. It is also assumed that electrical power and additional station personnel are available during this time.

(1b) It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-i, such as plant operations and assessment of operational aspects, emergency direction and control, notification /

communication, radiological accident assessment, and support of operational accident assessment, as appropriate.

The Emergency Plan Minimum Staffing Table shown in Section 4.0 of the IPEC Phase 2 Staffing Assessment Report provides a table showing who is responsible for each of the major functional areas of NUREG-0654 Table B-1 following the BDBEE.

(lc) New staff or functions identified as a result of the assessment.

The assessment did not identify the need for additional on-shift staff or changes to the Emergency Response Organization (ERO) structure. The assessment did not identify any new functions.

(ld) Collateral duties (personnel not being prevented from timely performance of their assigned functions).

The Phase 2 staffing assessment concluded that the current minimum on-shift staff is sufficient to support implementation of the FLEX mitigating strategies on both IPEC Units 2 and 3, as well as the required Emergency Plan actions with no unacceptable collateral duties.

(2) Response to Requested Information Item 2 Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate please include in the schedule the time to implement the changes associated with the Phase 2 staffing assessment.

NL-14-132 Docket Nos. 50-247 and 50-286 Attachment Page 3 of 3 The Enclosure provides the Phase 2 IPEC staffing assessment for the BDBEE and ELAP, multi-unit event. The Phase 2 staffing assessment was completed October 3, 2014. No modifications were identified in the Phase 2 assessment.

(6) Identify changes associated with the Phase 2 staffing assessment that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all AC power, multi-unit event, including any new or revised agreements with offsite resource providers (e.g.,

staffing, equipment, transportation, etc.).

Staff: The existing on-shift staff is sufficient to implement the Emergency Plan and ELAP strategies at both units during the first 6-hour "no site access" period.

No changes to the Emergency Plan on-shift staffing have been identified.

ERO: The existing augmented ERO provides sufficient staffing to fill the 24-hour ERO positions and satisfy the expanded response capability functions defined in NEI 12-01, Table 3.1 and Table 3.2. No changes to the Emergency Plan augmented ERO staffing have been identified.

Agreements: Agreements with offsite resource providers were addressed in the Phase 1 Staffing Assessment submitted April 30, 2013 (NL-13-070). Further review in the Phase 2 assessment determined no new or revised agreements are necessary.

Drills: NEI 12-01 states that a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. No changes to the IPEC Emergency Plan Drill and Exercise Program are being made; however, Entergy is planning to incorporate requirements for drills and exercises involving a BDBEE scenario in accordance with the guidance and implementation schedule of NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events, when issued

ENCLOSURE TO NL-14-132 ENTERGY IPEC UNITS 2 AND 3 NEI 12-01 PHASE 2 STAFFING ASSESSMENT ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNITS NOS 2 AND 3 DOCKET NOS. 50-247 and 50-286

  • Entergy, THE POWER Of PEOPLE' ENTERGY INDIAN POINT ENERGY CENTER UNITS 2 AND 3 NEI 12-01 PHASE 2 STAFFING ASSESSMENT

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Table of Contents 1.0 EXECUTIVE SUM M ARY ................................................................................. 2 2.0 IN TRO D U CTIO N ............................................................................................... 3 3.0 SCOPE OF THE ELAP ERO STAFFING ASSESSMENT ................................ 3 4.0 EMERGENCY PLAN MINIMUM ON-SHIFT STAFFING ............................... 4 5.0 PHASE 2 STAFFING ASSESSMENT FOR BDBEE/ELAP .............................. 6 5.1 O n-shift Staff Responsibilities ............................................................................ 6 5.2 M ethodology ...................................................................................................... 6 5.3 NEI 12-01 General Assumptions and Limitations ............................................... 7 5.4 Other Assumptions for Staffing Assessment ...................................................... 7 5.5 NEI 12-06 Staffing Assumptions ....................................................................... 8 5.6 NEI 10-05 Applicable Assumptions to support Methodology ............................. 8 5.7 Severe Accident Management Guideline (SAMG) ............................................. 9 5.8 Assessment of the INITIAL PHASE Coping Strategies and Capability .............. 9 5.9 Assessment of TRANSITION PHASE Coping Strategies and Capability ........... 9 6.0 A UG M EN TED ERO .......................................................................................... 9 6.1 E R O R esponse ................................................................................................... 9 6.2 Expanded Emergency Response ........................................................................ 10 7.0 PHASE 2 STAFFING ASSESSMENT CONCLUSION .................................... 10 7.1 Staffi ng Level ................................................................................................... 10 7.2 Task A nalysis Results ..................................................................................... 10 7.3 Time Motion Study (TMS) Results ................................................................... 10 7.4 Augmented and Expanded ERO Assessment Results ........................................... 11 8.0 R EFER EN C ES ................................................................................................. 12 9.0. A TTA CH M EN TS ............................................................................................ 12 Attachment I Phase 2 Staffing Assessment NEI 10-05 Tabletop Data ..................... 13 Attachment 2 IPEC FLEX Implementation Timelines ............................................. 20 Attachment 3 Expanded Emergency Response Table ............................................ 27 Page 1 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment 1.0 EXECUTIVE

SUMMARY

Beyond Design Basis External Events (BDBEE) are events initiated by natural phenomena that either exceed the protections provided by design basis features or involve natural phenomena within the design basis in combination with beyond design-basis failures leading to an extended loss of ac power (ELAP) and/or loss of access to the ultimate heat sink (LUHS).

Using the methodology of (Nuclear Energy Institute) NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, this report presents the results of an assessment of the capability of the Indian Point Energy Center (IPEC) on-shift staff and augmented Emergency Response Organization (ERO) to respond to a BDBEE. The assumptions for the NEI 12-01 Phase 2 scenario postulate that the BDBEE involves a large-scale external event that results in:

" an extended loss of AC power

" an extended loss of access to ultimate heat sink

" impact on all units (all units are operating at full power at the time of the event)

" impeded access to the units by off-site responders as follows:

(1) 0 to 6 Hours Post Event - No site access.

(2) 6 to 24 Hours Post Event - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).

(3) 24 Hours Post Event - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

To conduct the on-shift portion of the assessment, a team of subject matter experts from Operations, Operations Training, Radiation Protection, Chemistry, Security, Emergency Planning and FLEX Project Team personnel performed a tabletop in July 2014. The participants reviewed the assumptions and applied procedural guidance, including applicable draft and approved FLEX Support Guidelines (FSGs) for coping with a BDBEE using minimum on-shift staffing. Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step to account for both the task and the estimated time to prepare for and perform the task.

The Phase 2 Staffing Assessment concluded that the current minimum on-shift staffing as defined in the IPEC Emergency Plan is sufficient to support the implementation of the mitigating strategies (FLEX strategies) on Units 2 and 3, as well as the required Emergency Plan action, with no unacceptable collateral tasks assigned to the on-shift personnel during the first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The assessment also concluded that the on-shift staffing, with assistance from augmented staff, is capable of implementing the FLEX strategies necessary after the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period within the constraints. It was concluded that the Emergency response function would not be degraded or lost.

This assessment also concluded that sufficient personnel resources exist in the current IPEC augmented ERO to fill positions for the expanded emergency response functions. Thus, the Page 2 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment ERO resources and capabilities necessary to implement Transition Phase coping strategies performed after the end of the "no site access" 6-hour time exist in the current program.

2.0 INTRODUCTION

The Nuclear Regulatory Commission (NRC) issued a Letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Requestfor Information Pursuantto Title 10 of the Code of FederalRegulations 50.54(W Regarding Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task ForceReview of Insightsfrom the Fukushima Dai-ichiAccident. Information requests related to Emergency Planning were contained in Enclosure 5 of the §50.54(f) letter. Enclosure 5 contained two requested actions; one involving performance of a staffing assessment and the other a communications assessment. The communications assessment is independent of the staffing assessment and not included as part of this report. The Phase 2 staffing assessment addresses Requested Information Items L12, and 6 of NTTF Recommendation 9.3. The actions for the staffing assessment are summarized as follows:

It is requested that addressees assess their currentstaffing levels and determine the appropriatestaff to fill all necessarypositionsfor respondingto a multi-unit event duringa beyond design basis naturalevent and determine if any enhancements are appropriategiven the considerations ofNear-Term Task Force (NTTF)

Recommendation 9.3.

A two-phased approach was established by the industry to respond to the information requests contained in the §50.54(f) letter associated with staffing. Additionally, NEI developed a technical report (NEI 12-01. Guideline for Assessing Beyond Design Basis Accident Response Staffing and CommunicationsCapabilities)that includes the recommended criteria for use in performing the staffing assessment for a BDBEE. The criteria provides for documenting the organizational capabilities that will facilitate simultaneous performance of extended coping capabilities following a BDBEE.

Note - Use of the term ELAP throughout this report also assumes a loss of access to the ultimate heat sink as part of the event. The use of the terms Phases 1, 2, and 3 refers to Initial Phase, Transition Phase and Final Phase respectively as referenced in the Mitigating Strategies Order and NRC JLD-ISG-2012-1.

3.0 SCOPE OF THE ELAP ERO STAFFING ASSESSMENT All sites with one or more operating units are required to perform a Phase 2 staffing assessment no later than 4 months prior to beginning of the second refueling outage (as used within the context of NRC Order EA-12-049). The Phase 2 assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2. Licensees of multi-unit sites have two options for providing the Phase 2 staffing assessment:

Provide one Phase 2 staffing assessment applicable to all on-site units. This assessment should be provided 4 months prior to the first occurrence of a second refueling outage at the site (i.e., the first "second refueling outage"). This option may be used by sites that will employ essentially identical mitigation strategies for all on-site units.

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Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Provide two or more Phase 2 staffing assessments as applicable to the different on-site units. Each assessment should be provided 4 months prior to the occurrence of the second refueling outage of the unit to which the assessment is applicable. This option may be used by all sites that will employ different mitigation strategies for on-site units.

IPEC Unit 2 and Unit 3 staffing assessments were performed per the guidance of the first option to conduct one assessment applicable to both units with a submittal date no later than November 3, 2014 based on the Unit 3 FLEX implementation. The intent of this assessment was to perform the following:

Evaluate the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, evaluate Transition Phase actions that must be performed prior to the end of the "no site access" time period.

  • Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

" Transition Phase - Implementation of strategies that involve the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling. Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.

2 Evaluate the ability of the on-shift staff to implement the Station Blackout (SBO) coping strategies in place before ELAP is declared.

3 Evaluate the EOPs and FSGs for responding to an ELAP affecting both units. (Note:

Draft FSGs and draft emergency operating procedures revised for FLEX implementation were used.)

4 Evaluate whether the ability of the on-shift staff to perform any required emergency response functions would be degraded or lost prior to the arrival of the augmented ERO.

5 Consistent with the site access assumption, evaluate the ability of the on-shift staff and augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" time period.

The staffing level determined as a result of the Phase 2 assessment will be verified and validated in the process used to reasonably assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed within the constraints identified in the Overall Integrated Plan (OIP) or order EA 12-049. Validation will be performed at a date after the submittal of the staffing assessment report per NEI guidance "FLEX Beyond Design Basis Validation Process" dated 07/18/2014.

4.0 EMERGENCY PLAN MINIMUM ON-SHIFT STAFFING The IPEC Emergency Plan establishes the licensing basis for the on-shift staffing complement as determined by the staffing assessment performed as part of the overall Emergency Planning rulemaking published in November of 2011. Only personnel required to be on-shift are credited in the Phase 2 Staffing Assessment for the initial 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of the event.

The following table indicates the on-shift personnel necessary to perform Initial Phase plant operations and the required emergency planning functions.

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Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment NUREG-0654 NUREG-0654 Functional Functional On-Shift Staffing On-Shift Area/Tasks Area/Tasks U2 Staffing U3 U2 staff U3 staff Emergency Emergency Direction and Direction and Shift Manager (SM) Control/ Safe Control/Safe 1 Shutdown / Shutdown /

Assessment of Assessment of Operational Aspects Operational Aspects Plant Plant Control Room Operations/Safe Operations/Safe Shutdown / Shutdown / 1 Supervisor (CRS) Assessment of Assessment of Operational Aspects Operational Aspects Shift Technical Plant System Plant System Advisor (STA) Engineering / Engineering /1 Technical Support Technical Support Plant Plant Operations/Safe Operations/Safe Reactor Operators Shutdown / Shutdown / 2 2 (RO) Assessment of Assessment of Operational Aspects Operational Aspects Plant Plant Nuclear Plant Operator Operations/Safe Operations/Fire4 (NPO) Shutdown/Fire O rat e Brigade Brigade Nuclear Plant Operator Communicator / Notifications I (NPO)

Chemistry Chemistry/Offsite Chemistry/Offsite 1 Dose Assessment Dose Assessment Radiological Radiological Radiation Protection Assessment / In- Assessment / In-(RP) plant Protective plant Protective Actions Actions Nuclear Plant Operator (available for operations/safe shutdown U1 where qualified / other as directed by Emergency Director)

Fire Brigade Leader for both units (available SRO for plant operations/safe shutdown in non-fire events on unit licensed on and other as directed by the Emergency Director)

Security Access Control and Accountability Per Security Contingency Plan Emergency plan tasks of repair and corrective action, first aid and rescue operations are provided by personnel assigned other functions as allowed by NUREG-0654 Table B-1 and NEI 10-05. The SM provides emergency direction and control of plant operations and assessment of operational aspects.

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Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment 5.0 PHASE 2 STAFFING ASSESSMENT FOR BDBEE/ELAP 5.1 On-shift Staff Responsibilities On-shift staff responsibilities and actions assumed in the tabletop are as follows:

  • U2 SM assumed the Emergency Director (ED) function 0 On-shift Communicator was available to perform off-site notifications
  • The (2) CRSs, (2) ROs, (1) FBL SRO, and (10) NPOs were available to perform plant operations to establish and maintain core cooling, spent fuel pool level, and containment integrity as directed by each unit CRS using ECAs, and FSGs.
  • Two RP Technicians and two Chemistry Technicians were available to perform their emergency plan functions and other tasks as directed by the Shift Manager in either unit.

(1) One of the two Chemistry Technicians was responsible for the task of dose assessment should a release occur. Both are qualified and either may be called to the control room to perform the function should a release occur. Otherwise, they were available to perform tasks to implement FLEX as directed by SM/ED.

(2) One of the two RP techs was available to perform job support, in-plant surveys, and onsite surveys as directed by the SM/RD. Either RP tech could be called upon for the task when needed; otherwise they were available to perform tasks to implement FLEX as directed by the Shift Manager.

The U3 SM was available to assist the ED with other communications such as contacting the Corporate Duty Manager, or Corporate Emergency Center (CEC) and coordinating request for resources.

Existing coping strategies do not anticipate the use of Security Officers other than to perform duties related to their assigned security roles. Tasks assigned for FLEX response are consistent with their normal duties such as monitoring and controlling sites access, providing site access for FLEX equipment staging, and providing compensating measures for vital area doors that may need to remain open to facilitate room environmental conditions or staging and operation of FLEX equipment.

It was assumed that the Emergency Director and Communicator functions and responsibilities remained in the Control Room throughout the duration of this assessment. It is recognized, however, that the augmented ERO would be expected to arrive on-site or at their designated off-site facilities and assume these functions from the Control Room as soon as possible.

5.2 Methodology The Phase 2 staffing assessment for response functions related to NTTF Recommendation 4.2 must be based on the actions delineated in the procedures and guidelines developed in response to the Order to ensure accurate results. Once the site specific actions associated with the FLEX implementation response strategies are defined (i.e., down to the procedure or guideline step level), the staffing needed to perform these actions can be assessed with the necessary level of accuracy.

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Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment

  • IPEC Unit 2 procedures were not available at the time of the assessment however; the strategies are similar on both units so all transition strategies identified in the Implementation Plan for both units were considered.
  • A tabletop was used to determine what plant actions and emergency plan implementation actions were required based on procedures during an ELAP. In cases where multiple tasks were assigned to an individual, the team evaluated the timing of the tasks to ensure that they could be performed by the individual in series within any specified time constraints. A team of Emergency Planning, Operations, Operations Training, Security, Chemistry, and FLEX Project Team personnel completed the assessment of the on-shift staff's response to a BDBEE and ELAP.

" The guidance of NEI 10-05 was used to determine if the number and composition of the on-shift staff is sufficient to implement the Emergency Plan, Initial Phase actions and, with assistance from augmented staff, implement Phase 2 mitigation strategies and repair or corrective actions intended to maintain or restore the functions of core cooling, containment integrity, and spent fuel pool makeup for both units.

  • The guidance of NEI 10-05 was used but the tables were modified to include tasks to implement the FLEX strategies.
  • Due to the lead time before Phase 3, it was assumed that offsite equipment would arrive on site and appropriate staff would be available to receive, stage, and operate the equipment. Therefore, the staffing assessment did not consider Phase 3 FLEX strategies.

5.3 NEI 12-01 General Assumptions and Limitations

" A large-scale external event occurs that results in:

- all onsite units affected

- extended loss of AC power with simultaneous LUHS

- impeded access to all units

  • Initially, all on-site reactors are operating at full power and are successfully shut down.
  • A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.
  • The event impedes site access as follows:

- Post event time: 0 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - No site access. This duration reflects the time necessary to clear road way obstructions, use different travel routes, mobilize alternate transportation capabilities, etc.

- Post event time: 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities.

- Post event time: 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment., supplies, and large numbers of personnel.

5.4 Other Assumptions for Staffing Assessment The result of the beyond-design-basis event may place the plant in a condition where it cannot comply with certain Technical Specifications and/or with its Security Plan, and as such, may warrant invoking 10 CFR 50.54(x) and/or 10 CFR 73.55(p).

For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase and any necessary Transition Phase coping Page 7 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment actions during the 0-6 hour period. It is assumed an adequate number of augmented ERO members arrive on site between 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to assist the on-shift staff to successfully implement the appropriate FLEX strategies and FSGs.

InitialPhase - Implementation ofstrategies that generally rely upon installedplant equipment.

Transition Phase - Implementation of strategies that involve the use ofportable equipment and consumables to extend the coping period, and maintain or restore the functions of core cooling, containment integrity,and spentfuel pool cooling.

  • On-shift personnel are limited to the minimum complement allowed by the site emergency plan (i.e., the minimum required number for each required position). This would typically be the on-shift complement present during a backshift, weekend, or holiday.

" Off-site emergency response facilities and staging areas are available, including those located within the 25 mile telecommunications blackout range.

5.5 NEI 12-06 Staffing Assumptions The FLEX strategies documented in the event sequence analysis assume:

- No independent, concurrent events

- All personnel onsite are available to support site response

- All reactors on-site initially operating at power, unless site has procedural direction to shut down due to the impending event.

5.6 NEI 10-05 Applicable Assumptions to support Methodology

  • On-Shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.
  • The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas unless allowed by procedure or Emergency Plan) without the aid of a Radiation Protection Technician.
  • Performance of site and protected area access control function is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.

The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement.

This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.

The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions.

Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.

The analyzed event occurs during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).

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Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment 5.7 Severe Accident Management Guideline (SAMG)

It was concluded in the Phase 2 Staffing Assessment that the on-shift staff and augmented ERO would not be called upon to perform SAMG activities for the event analyzed for this report. The IPEC FLEX strategy is assumed to be successful to the extent that SAMG entry will not be necessary.

5.8 Assessment of the INITIAL PHASE Coping Strategies and Capability The Phase 2 staffing assessment for the Initial Phase actions during the first 6-hours concluded that there were no task overlaps for the activities assigned to the on-shift staff and the ability of the on-shift staff to perform any required emergency response functions were not degraded or lost. Refer to Attachment 1, Phase 2 Staffing Assessment NEI 10-05 Tabletop Data and Attachment 2, IPEC FLEX Implementation Timelines.

5.9 Assessment of TRANSITION PHASE Coping Strategies and Capability

  • On-shift Staff Transition Phase Coping Actions (Hours 0 - 6 )

The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore functions until they can be accomplished with resources brought from off site. Actions may include:

1) Initial Assessment and FLEX Equipment Staging (FSG-005)
2) DC Load Shed (FSG-004)
3) Debris removal (FSG-005)
4) Deploy FLEX Phase 2 Generator, Connect cables and start DG (FSG-005)
5) Deploy and stage additional FLEX equipment
6) Alternate AFW/EFW Suction Source (FSG-002)
  • Augmented ERO and On-shift Staff Transition Phase Coping Actions The following tasks are assumed to be performed by the on-shift and augmented staff after the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> no access period using limited augmented ERO members as shown in Attachment 2.
1) Long Term RCS Inventory Control (FSG-001)
2) Makeup to the Spent Fuel Pool (FSG-01 1)
3) Alternate Low Pressure Feedwater (FSG-003)
4) Alternate CST Makeup (FSG-006)
5) Refuel FLEX equipment (FSG-005) 6.0 AUGMENTED ERO 6.1 ERO Response The methods to notify and augment the ERO was identified in Entergy's 90-Day Response to the March12, 2012 Information Request, Action Planfor Completing Emergency Communication and Stqffing Assessments ((NL- 12-075) and in Entergy Letter dated April 30, 2013, Entergy 's Response to the March 12, 2012, Information Request, Enclosure 5, Recommendation 9.3, Emergency Preparedness- Staffing, Page 9 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Requested Information items 1, 2, and 6 (Phase 1 Staffing Assessment). (NL- 13-70)

The Phase I Staffing Assessment addressed site access for the augmented ERO.

6.2 Expanded Emergency Response

  • The expanded emergency response was identified in the Phase 1 Staffing Assessment submitted in Entergy Letter dated April 30, 2013, Entergy's Response to the March 12, 2012, Information Request, Enclosure 5, Recommendation 9.3. Emergency Preparedness- Staffing, Requested Information items 1, 2, and 6.
  • The Phase 2 Staffing Assessment revised the expanded emergency response table by including the recommended expanded response described in NEI 12-01 Table 3.2. The revised portion of the expanded response is shown in Attachment 3. The expanded response table and implementation guidance is provided in a FLEX Support Guideline.

7.0 PHASE 2 STAFFING ASSESSMENT CONCLUSION 7.1 Staffing Level This assessment concluded that the current minimum on-shift staffing as defined in the IPEC Emergency Plan, is sufficient to support the implementation of the ELAP strategies on Units 2 and 3, as well as the required Emergency Plan actions, with no unacceptable collateral duties. The staffing assessment did not identify the need for additional on-shift staff.

The NPOs performed tasks in series when necessary and were able to timely perform all assigned functions. The NPOs performed actions to ensure core cooling, containment integrity, and spent fuel pool makeup. The performance of coping strategies does not impact the ability of the on-shift staff to perform any required emergency response function.

Emergency response functions would not be degraded or lost prior to the arrival of the augmented ERO.

The existing on-shift staff and augmented ERO is sufficient to implement existing BDBEE and ELAP strategies on both units simultaneously while continuing to perform required Emergency Planning tasks without unacceptable collateral duties. No change to the on-shift staffing level or augmented ERO is required. The emergency plan will not be changed as a result of the shift staffing assessment. No interim actions have been taken or are planned as a result of the assessment.

7.2 Task Analysis Results Refer to Attachment 1, Phase 2 Staffing Assessment NEI 10-05 Tabletop Data, and Attachment 2, IPEC FLEX Implementation Timelines, for the analysis of on-shift staffing tasks.

  • The task analysis did not identify any unassigned tasks.
  • The task analysis did not identify any task overlaps that were performed by the on-shift staff.
  • The time to perform the task was best estimate of the assessment team based on operating experience.

7.3 Time Motion Study (TMS) Results Page 10 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Collateral tasks were not identified, therefore a time motion study was not required.

Refer to Attachment 2, IPEC FLEX Implementation Timelines, for the on-shift staffing task timing and sequence analysis results.

7.4 Augmented and Expanded ERO Assessment Results The existing ERO is sufficient to fill augmented ERO positions and those positions needed to support expanded response positions assigned as necessary if responding to a BDBEE on both units. IPEC has four ERO teams that have been trained to respond to the site.

Page 11 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment

8.0 REFERENCES

8.1 NEI 12-01, Rev 0, Guidelinefor Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities 8.2 NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities 8.3 NSIR DPR-ISG-0 1, Interim Staff Guidance - Emergency Planningfor Nuclear Power Plants 8.4 NRC Letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Requestfor Information Pursuantto Title 10 ofthe Code ofFederalRegulations 50.54(t) Regarding Recommendation 2.1, 2.3, and 9.3, Qf the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident.

8.5 NRC Order Number EA-12-049, dated March 12, 2012, Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 8.6 Entergy letter (NL- 12-054) to the NRC dated May 11, 2012, Entergy's 60-Day Response to the March 12, 2012, Information Request, Action Planfor CompletingEmergency Communication and Staffing Assessments (ML12144A157) 8.7 Entergy Letter (NL- 12-075) dated June 8, 2012, Entergy 's 90-Day Response to the March 12, 2012, Information Request, Action Planfor Completing Emergency Communication and Staffing Assessments (ML12164A566) 8.8 Entergy Letter (NL-13-070) dated April 30, 2013, Entergy's Response to the March 12, 2012, Information Request, Enclosure 5, Recommendation 9.3, Emergency Preparedness-Staffing, Requested Information items 1, 2. and 6 (Phase 1 Staffing Assessment) 8.9 NRC Interim Staff Guidance JLD-ISG-2012-01, Rev. 0, dated August 29, 2012, Compliance with Order EA-12-049, Order Modifying Strategies for Beyond-Design-Basis External Events 8.10 NEI 12-06 Rev. 0, August 2012, Diverse and Flexible CopingStrategies (FLEA)

Implementation Guide 8.11 IP-RPT-13-00059 Rev 02, IP3 FLEX Strategy Development 8.12 Indian Point Energy Center Emergency Plan 9.0. ATTACHMENTS ATTACHMENT I PHASE 2 STAFFING ASSESSMENT NEI 10-05 TABLETOP DATA ATTACHMENT 2 IPEC FLEX IMPLEMENTATION TIMELINES ATTACHMENT 3 EXPANDED EMERGENCY RESPONSE TABLE Page 12 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 1 Attachment I Phase 2 Staffing Assessment NEI 10-05 Tabletop Data Note NEI-10-05 Tables are modified to include Emergency Plan and FLEX implementation tasks.

I. Accident Summary:

  • A large-scale external event occurs that results in:

- All on-site units affected

- ELAP/LUHS

- Impeded access to the units

" Initially, both units are operating at full power and are successfully shut down.

  • The event results in a Site Area Emergency based on EAL SSl .1. The event is upgraded to a General Emergency SG 1.1 once it has been determined that power cannot be restored before the station blackout coping time will be exceeded.

" The most limiting hazard for on-shift staffing was used for the assessment. On-shift personnel respond as shown in Attachment 2.

2. Accident Assumptions:
  • The start and load manual actions for Diesel Generators are unsuccessful.

" Attachment 2 assumptions include:

- SM/CRS are expected to use available staff to provide periodic relief (if needed) for individuals working in extreme environmental conditions (e.g., high heat areas).

- Estimated task times include expected pre-job and safety briefings

- Augmented Chemistry support is available to relieve Chemistry of Dose Assessment at T > 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />

  • Assumptions are identified in Section 5.0 of this document.
3. Procedures Reviewed for Accident Response Include:

" Common Control Room IP-EP- 115, Emergency Plan Forms IP-EP- 120,. Emergency Classification IP-EP-210,. Central Control Room IP-EP-410, Protective Action Recommendation

  • U2 Procedures 2-ECA-0.0, Loss of All AC Power 2-AOP-SFP.1, Loss of Spent Fuel Pit Cooling

" U3 Procedures 3-ECA-0.0 Loss of All AC Power 3-AOP-SFP.1, Loss of Spent Fuel Pool Cooling

" FLEX Support Guidelines FSG-001, Long Term RCS Inventory Control FSG-002, Alternate AFW/EFW Suction Source FSG-003,. Alternate Low Pressure Feedwater FSG-004, ELAP DC Bus Load Shed /Management FSG-005, Initial Assessment and FLEX Equipment Staging FSG-006, Alternate CST Makeup Page 13 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment I FSG-01 1, Alternate SFP Makeup and Cooling FSG-100, BDBEE / ELAP Emergency Response FSG-101, EP Communications NOTE: NEI 10-05 Tables 1-5 shown here are modified to include Emergency Plan and FLEX implementation tasks LflC TABLE 1 - ON-SHIFT POSITIONS Multi-Unit ELAP/LUBS Role in Table # / Line # Collateral Tasks?

Line -shift Positio Unanalyzed Task? (See Attachment 2 for Task S_ i sequence & timeline)

T2/L1 T5/L1 T5/L2 I U2 SM T5/L3 No T5/L5 T5/L8 T5/L10 2 U2 CRS T2/L2 No No 3 U2STA T2/L3 No No 4 U2 RO #1 T2/L4 No No 5 U2 RO #2 T2/L5 No No 6 U2 NPO #1 T2/L6 No No 7 U2 NPO #2 T2/L7 No No 8 U2 NPO #3 T2/L8 No No U2 NPO #4 T2/L9 No No 9

10 U2 NPO #5 T2/L10 No No 11 U2 Chemistry T2a/L24 No No T4/L1 12 U2 RP T4/L2 No No (Refer to ATT 2)

T2a/L22 T2/,11 13 U3 SM T5/L14 No No 14 U3 CRS T2/L12 No No 15 U3 STA T2/L13 No No Page 14 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment I 16 U3 RO #1 T2/L14 No No 17 U3 RO #2 T2/L15 No No 18 U3 NPO #1 T2/L16 No No 19 U3 NPO #2 T2/L17 No No 20 U3 NPO #3 T2/L18 No No 21 U3 NPO#4 T2/L19 No No 22 U3 Chemistry T2a/L25 No No 23 U3 RP T4/L4 No No (Refer to ATT 2)

T2a/L23 24 Ul NPO T2/L20 No No T5/L6 25 Communicator T5/L9 No No T5/L13 26 SRO FBL T2/L21 No No 27 Security T5/L15 No No Page 15 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 1 IFEC TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN Two Unit - Two Control Room Multi-Unit ELAP/LUJIS Operations Crew Avilabl to Implemnut AOPs, EOPs, SAMGs, or FSGs s Applic.ble Line# Gnric TitRol On-Shift Position Task Analysis Controlling Method (Note

________________(Notel1) 2) 1 Shift Manager U2 SM Licensed Operator Training Program 2 Unit Supervisor U2 CRS Licensed Operator Training Program 3 Shift Technical Advisor U2STA Licensed Operator Training Program 4 Reactor Operator #1 U2 RO #1 Licensed Operator Training Program 5 Reactor Operator #2 U2 RO #2 Licensed Operator Training Program 6 Auxiliary Operator #1 U2 NPO #1 Non-Licensed Operator Training Program 7 Auxiliary Operator #2 U2 NPO #2 Non-Licensed Operator Training Program 8 Auxiliary Operator #3 U2 NPO #3 Non-Licensed Operator Training Program 9 Auxiliary Operator #4 U2 NPO #4 Non-Licensed Operator Training Program 10 Auxiliary Operator #5 U2 NPO #5 Non-Licensed Operator Training Program 11 Shift Manager U3 SM Licensed Operator Training Program 12 Unit Supervisor U3 CRS Licensed Operator Training Program 13 Shift Technical Advisor U3 STA Licensed Operator Training Program 14 Reactor Operator #1 U3 RO #1 Licensed Operator Training Program 15 Reactor Operator #2 U3 RO #2 Licensed Operator Training Program 16 Auxiliary Operator #1 U3 NPO #1 Non-Licensed Operator Training Program 17 Auxiliary Operator #2 U3 NPO #2 Non-Licensed Operator Training Program 18 Auxiliary Operator #3 U3 NPO #3 Non-Licensed Operator Training Program 19 Auxiliary Operator #4 U3 NPO#4 Non-Licensed Operator Training Program 20 Auxiliary Operator U1 NPO Non-Licensed Operator Training Program 21 SRO Fire Brigade Leader SRO FBL Licensed Operator Training Program

  • The Communicator NPO does not perform AOP, EOP, or FSG tasks.

Note 1: During a BDBEE that results in an ELAP/LUHS, all positions, except the SM, STA, and Communicator, are expected to be utilized if available to implement or assist in the implementation of FLEX strategies using Flex Support Guidelines (FSG) under the direction of the Control Room Supervisor and oversight by the Shift Manager.

Note 2: The controlling method put in place when FLEX is implemented will follow the guidance recommended by the industry. Each position will receive the INPO initiated NANTEL Generic Basic FLEX Initial Course. Shift Managers and Control Room Supervisors will also receive the NANTEL Generic Advanced FLEX Training Course. A training plan developed using the systematic approach to training (SAT) process is in place for additional FLEX training.

Page 16 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment I 22 U2 RP U2 RP N/A 23 U3 RP U3 RP N/A 24 U2 Chemistry U2 Chemistry N/A 25 U3 Chemistry U3 Chemistry N/A Note 1: During a BDBEE that results in an ELAP/LUHS, these positions may to be utilized, if available, to assist in the implementation of FLEX strategies using FSGs under the instructions of Operations.

Note 2: The controlling method put in place when FLEX is implemented will follow the guidance recommended by the industry. Each position will receive the INPO initiated NANTEL Generic Basic FLEX Initial Course.

Fire Brigade (No firefighting activities included in this accident.).

Staff filling fire brigade positions is shown in the minimum staffing table in Section 4.0.

IPEC TABLE 3 - FIREFIGHTING Line Performed by Task Analysis C~ontrollig Method I N/A N/A 2 N/A N/A 3 N/A N/Aý 4 N/A N/Aý 5 N/A N/A Page 17 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment I IPEC TABLE 4-RADIATION PROTECTION AND CHEMISTRY L Position Pefrmn Performance Time Period After Event (hours)*

I Function / Task N 0-1.5-11.012.0-13.0- .0-15.0- .0-17.0-18.0-19.0-110.0 11.0 12.0 13.0 14.0115.0116.0-S5.0 6.0 .0 8.0 9.0 1 11.0 12.0113.0 14.0 15.0 16.0124.0 I In-Plant Survey: As directed by SM*

RP 2 On-site Survey: As directed by SM*

RP 3 Personnel Monitoring:

4 Job Coverage: As directed by SM*

RP 5 ffsite Rad ssessment: 6Include n Table 5) 6 her site specific RP describe):

7 hemistry Function ask #1 (describe) 8 hemistry Function ask #2 (describe)

  • The team determined there are no time sensitive RP or Chemistry tasks and that task performance is directed and prioritized by the Shift Manager. The time RP or Chemistry is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are taken due to the loss of power to the equipment necessary to analyze samples. No fuel damage or release is anticipated since core cooling, containment integrity, and spent fuel pool makeup are maintained. RP and Chemistry are available to assist with staging and setup of FLEX equipment when not performing dose assessment, surveys, or job support. Both Chemistry Technicians are qualified to perform dose assessment.

RP Technicians may perform RP tasks at either unit.

Page 18 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 1 IPEC TABLE 5-EMERGENCY PLAN IMPLEMENTATION Multi-Unit ELAP/LURS _ _ _ _ _ _ _ _ _

Line Function / Task On-Shift Task Analysis Controlling

_____________________ Position Method I Declare the emergency classification level U2 SM mergency Planning Training (ECL) Program / EP Drills 2 Approve Offsite Protective Action U2 SM Emergency Planning Training Recommendations Program / EP Drills 3 Approve content________________________________________Program of State/local notifications U2 SM mergency Planning Training 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Notification and direction to on-shift staff Un Sa ergenc Planning 5 (e.g., to assemble, evacuate, etc.) U2 SM Program / Emergency Planning Training Program 6 ERO notification Communicator Emergency Planning Training Program Abbreviated NRC notification for DBT N/A NA event 8 Complete State/local notification form U2 SM Emergency Planning Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form U2 SM icensed Operator Training Program 11 Activate ERDS (Note 1) N/A 12 Offsite radiological assessment (Note 2) N/A 13 Perform NRC notifications Communicator Emergency Planning Training Program Perform other site-specific event icensed Operator Training 14 notifications (e.g., Duty Plant Manager, (Note 3) rogram INPO, ANI, etc.) Program 15 Personnel Accountability Security Security Training Program / EP 5 erills Note 1: ERDS at both units normally operates 24/7 and therefore does not require specific actions to activate the system.

It is recognized, however, that the BDBEE is assumed to result in the loss of normal communication paths for ERDS. If ERDS capability is lost, critical information would be communicated directly to the NRC over other communication paths, such as satellite phones.

Note 2: U2 (U3) Chemistry will report to the U2 (U3) Control Room to assist the SM/ED as directed and be available for offsite radiological assessment if needed. A release is not anticipated since core cooling, spent fuel pool cooling and containment integrity are maintained during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. If no release is expected, the SM is expected to direct Chemistry to assist with FLEX strategy implementation.

Note 3: The SM will not make these communications. The Duty Plant Manager will report to the site or the staging area and is responsible for other site specific event notifications.

Page 19 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 2 ATTACHMENT 2 IPEC FLEX IMPLEMENTATION TIMELINES Timeline It is assumed on-shift staff will be relieved after +6 hours as personnel are able to access the site. The relief staff will continue the tasks for the job position as shown. The intent of this table is to identify the job position, tasks, and estimated timeline to complete the Emergency Plan, initial phase and transition phase tasks and to demonstrate that no collateral duties have an adverse impact on implementing the Emergency Plan or FLEX strategies.

Unit POSITION TIME TASK Collateral Duty?

U2 Shift Manager (1) T=0 - 15 min (1) Assess event, declare SAE and assume ED function No (2) 15- 30 min (2) Approve NMF & Direct communicator to make notifications / Direct SAE evacuation &

(3) T=I hr. accountability (4) 1 - 1.5 hr.

(5) 3 - 4 hr. (3) Declare ELAP (6) All other times and until (4) Call SAFER / Direct Security to enable FLEX equipment access/ED responsibilities EOF/AEOF is operational (5) Declare GE / Develop PAR / Direct notifications (6) Perform oversight and ED responsibilities / Continues SM oversight after relieved as ED U2 Control Room (1) T=0 -1.0 hr. (1) Direct immediate plant actions for SBO No Supervisor (2) 1 - duration (2) Direct EOP and ELAP actions / Direct debris removal and staging of FLEX equipment U2 Shift Technical (1) T=O - 1 hr. (1) Technical Support / Plant monitoring and assessment / contact Con-Ed for availability of No Advisor (2) 1 - 1.5 hr. power (3) 2 - until mode 5 entered (2) Assessment for FLEX per FSG-005 Att. 1

_ (3) Technical Support / Plant monitoring and assessment U2 Reactor Operator (1) T=0 -0.5 hr. (1) Immediate plant actions No

  1. 1 (2) 0.5 - 3 hr. (2) Coordinate plant cooldown with NPO#3 (3) 3 - duration (3) Plant monitoring Page 20 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 2 Unit POSITION TIME TASK Collateral Duty?

U2 Reactor Operator (I) T=0 - I hr. (1) Open CR panel doors per 2-ECAO.0 step 5.b (10 min) Coordinate attempt to restore power No

  1. 2 (2) I - 1.5 hr. (2) Monitor channel and train indications per FSG-004 step 4.1 (10 min) / Initiate deep load (3) 1.5- 3.5 hr. shed per FSG-004 Att. 1 (20 min)

(4) 3.5 -4 hr. (3) Plant monitoring (5) 4 - 5 hr. (4) Go to the U2 FLEX RCS and SFP makeup pumps staging area to assist running hoses and (6) 5 - 7.5 hr. lineup of RCS makeup and SFP makeup strategies.

(7) 8 - 10 hr. (5) Unload U2 non-collapsible and collapsible hoses from trailer at pump staging areas (8) 10-duration (6) Perform FSG-001 I Att. I and FSG-0 I I Att 2 to align hoses for RCS and SFP makeup. (2.5 hr.) RCS and SFP makeup available at T=8 (7) Layout and hookup hoses for Alternate Low Pressure Feedwater makeup per FSG-003 Att.

1 (2 hrs.)

(8) Available to start Alternate SG makeup when needed U2 Nuclear Plant (1) T=0 - I hr. (1) Investigate DG failure/Attempt to start Appendix R DG/ perform DC load shed per 2- No Operator #1 (2) 1 - 1.5 hr. AOP-DC-1 (3) 3.5-4 hr. (2) FSG 004 DC deep load shed (4) 4 - 5.5 hrs. (3) Go to the U2 FLEX DG staging area to run cables and setup DG when staged (5 min)

(5) 5.5- 7 hr. (4) Unload DG cables from trailer and hookup FLEX DG per FSG-005 Att. 3 (90 min)

(6) 7 - 7.5 hr. (5) Start DG per FSG-005 Att 4 and align breakers per Att 5 (90 min)

(7) 7.5 - until OSC is (6) Re-start battery room exhaust fans and battery chargers (15 mrin) operational (7) Periodic monitoring of FLEX DG U2 Nuclear Plant (1) T=O-0.5 hr. (1) Open AFW roll-up doors (10 min) No Operator #2 (2) 0.5- 1 hr. (2) Line up N2 to ADV to allow control from CR (15 min)

(3) 1 - 8 hr.. (3) Available for local manual control of aux feed reg vlvs as needed / Support Aux Feedwater (4) 8- 10 hr. Bldg tasks (5) 10 - until OSC is (4) Run hoses and hookup Alternate low pressure Feedwater makeup per FSG-003 Att 1 (2 hr.)

operational (5) Support Aux Feedwater Bldg tasks U2 Nuclear Plant (1) T=O - I hr. (1) Close RCP letdown isolation valves per 2-ECA-0.0 step 3 (25 min) No Operator #3 (2) 1 - 1.5 hr. (2) Monitor SFP level and temperature (10 min)

(3) 1.5-2.5 hr. (3) Perform BAST line flush (60 min)

(4) 3 - 3.5 hr. (4) Perform FSG-01 1 Att I to establish FSB natural circulation ventilation (30 min)

(5) 3.5 -4 (5) Go to U2 FLEX RCS and SFP staging area to run and connect hoses when equipment is (6) 4- 5 hr. staged (7) 5 -7.5 hr. (6) Unload U2 non-collapsible and collapsible hoses from trailer at pump staging area (1 hr.)

(8) 8- 9 hr. (7) Perform FSG-001 Att I and FSG-0I I Att 2 to align hoses for RCS and SFP makeup (2.5 (9) As necessary until OSC is hr.)

operational (8) Available for SFP and RCS makeup as needed Page 21 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 2 Unit POSITION TIME TASK Collateral Duty?

U2 Nuclear Plant (1) T=0 - 1 hr. (I) Isolate Hotwell per 2-ECA-0.0 Step 9 (10 min) No Operator #4 (2) 1 - 2 hr. (2) Go to U2 DG staging area to run cables when the equipment is staged (3) 3.5- 4 hr. (3) Unload FLEX DG cables from trailer (45 min) and hookup per FSG-005 Alt 3 (45 min)

(4) 4 - 5.5 hr. (4) Start DG per FSG-005 Att 4 (15 min) and align breakers per Att 5 (90 min) Restart U2 (5) 5.5 - 7. 5 hr. battery chargers (15 min) Complete at T=7.5 (6) 10- 12 hr. (5) Set-up hoses for CST makeup per FSG-006 Att 1 (2 hrs.)

(7) 11 - as necessary until (6) Available for CST makeup when needed OSC is operational U2 Nuclear Plant (1) 1 -4 hr. (I) Transit to FLEX Storage bldg. and commence initial debris removal No Operator #5 (2) 4 - 5 hr. (2) Transfer and unload U2 collapsible hose trailer at pump staging areas (3) 5- 5.5 hr. (3) Transfer U2 SFP MU pump (4) 5.5 - 6 hr. (4) Transfer U2 SG MU pump (5) 6- 9 hr. (5) Transfer and unload U2 diesel driven air compressor and hoses (6) 10- 12 hr. (6) Set up hoses and FLEX CST makeup pump for CST makeup per FSG-006 Att. 1 (2 hrs.)

(7) 11-16 hr. or until OSC is (7) Plant walk-dowvn - damage assessment operational UI UI Nuclear Plant (1) T=0- I hr. (1) Replace radio repeater antenna if damaged No Operator (2) I -3.5 hr. (2) Transit to FLEX storage bldg. and support debris removal (2.5 hr.)

(3) 3.5- 4 hr. (3) Transfer U2 DG cables to staging area ( 30 min)

(4) 4 -4.5 hr. (4) Transfer U2 FLEX DG to staging area (30 min)

(5) 4.5 - 5 hr. (5) Transfer U2 RCS inventory makeup pump to staging area (30 min)

(6) 5 - 5.5 hr. (6) Transfer U2 CST makeup pump to staging area (30 min)

(7) 5.5 - 8 hr. (7) Transfer lighting trailers #1, 2, 4, 6, and 8 to staging area (30 min each)

(8) 10- 12 hr. (8) Setup hoses for CST makeup per FSG-006 Att 1(2 hrs.)

(9) until OSC is operational (9) As directed U2 Radiation (I) T=0 - 1 hr. (I) Report to the U2 CR / Perform RP support actions as directed by the SM or ED since no No Protection (2) 3.5 - 4 hr. release or fuel damage.

(3) 4 -4.5 hr. (2) RP support to establish FSB natural circulation ventilation per FSG-011 (30 min)

(4) 4.5- 5.5 hr. (3) Establish radiological monitoring for U2 SFP fill activities and level monitoring (30 min (5) 5.5 - 8 hr. (4) RP support to unload U2 hose trailers (I hr.)

(6) 8 - until OSC is (5) RP support to align hoses for RCS and SFP makeup (2.5 hrs.)

operational (6) RP support as needed Page 22 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 2 Unit POSITION TIME TASK Collateral Duty?

U2 Chemistry (I) T=0 - I hr. (1) Report to the U2 CR and perform actions as directed by the SM or ED/ available for dose No (2) 1 - 3.5 hr. assessment should a release occur (3) 3.5- 8 hr. (2) Transit to FLEX bldg., support debris removal (4) 8 - 10 hr. (3) Transfer U3 FLEX DG cables to staging area (30 min)

(5) 10 - until OSC is Transfer U3 FLEX DG to staging area (30 mii1) operational Transfer U3 RCS inventory makeup pump to staging area (30 min)

Transfer U3 SFP makeup pump to staging area (30 min)

Transfer U3 Steam generator makeup pump to staging area (30 min)

Transfer U3 diesel driven air compressor to staging area (30 min)

Transfer U3 diesel driven air compressor hoses to staging area (30 min)

Transfer light trailer #7 to staging area (30 min)

(4) Stage FLEX portable fuel tank with truck per FSG-005 Att 2 step 4 (5) Commence refuel strategy 113 Shift Manager (1) T=0 - I hr. (1) Post event SM oversight responsibilities / Communicate with U2 SM on plant status. No (2) 1 - 1.5 classification, and ELAP (3) 1.5 - 2 hr. (2) U3 SM oversight responsibilities / declare ELAP / assist ED as requested / coordinate need (4) 2- duration for FLEX equipment and actions of U3 Chemistry and RP techs with ED/ implement FSG-100 (3) If directed by the ED, contact County EOC/911 to make requests for assistance (debris removal, transportation. local conditions, etc.) (FSG-100) (2 min) /continue SM oversight and assist ED as requested (4) SM responsibilities / assist ED U3 Control Room (1) T=0 - I hr. (I) Direct immediate plant actions per SBO and Loss of SFP cooling procedures, and EOP No Supervisor (2) 1 - duration (2) Direct and coordinate EOP/ELAP actions U3 Shift Technical (I) T=0 - I hr. (I) Technical Support / Plant monitoring and assessment No Advisor (2) 1 - 1.5 hr. (2) Assessment per FSG-005 Att 1 1 (3) 3 - until mode 5 (3) Technical Support Plant monitoring Page 23 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 2 Unit POSITION TIME TASK Collateral Duty?

U3 SRO Fire Brigade (1) T=0 - 1 hr. (1) Replace CAF radio repeater antenna (if damaged) No' Leader (2) 1 -4 hr. (2) Transit to FLEX bldg. / commence initial debris removal and movement of FLEX (3) 4-9 hr. equipment (4) 11 - 16 / duration (3) Transfer and unload U2/U3 non-collapsible hose trailer at pump staging areas Transfer / unload U3 collapsible hose trailer Transfer U2 CST MU pump Transfer light trailer #3 then #5 Transfer U3 diesel air compressor hoses Transfer U3 diesel air compressor (4) Plant walkdowns damage assessment / as directed U3 Reactor Operator (I) T=0-0.5 hr. (1) Immediate plant actions No

  1. 1 (2) 0.5- 1 hr. (2) Coordinate RCS cooldown with NPO#3 (3) 1 -3 (3) Perform plant cooldown / plant monitoring (4) 3- 10 hr. (4) Plant monitoring (5) 10- 18 hr. (5) Open head vent valve for letdown / plant monitoring (6) 18 - duration (6) Plant monitoring U3 Reactor Operator (1) T=O - 0.5 hr. (I) Immediate plant actions /open CR panel doors/ Assume loss of U3 CST and open SG No
  1. 2 (2) 0.5 - I hr. supply from CWST PCV-1 188 (3) 1.0- 1.5 hr. (2) Perform AOP/SBO load shed (4) 3.5 -4 hr. (3) FSG-004 DC load shed (5) 4 - 5 hr. (4) Go to U3 FLEX RCS and SFP staging area to run and connect hoses when equipment is (6) 5 -7.5 hr. staged (7) 10- 12 hr. (5) Unload RCS and SFP hoses at staging area, CST and SG hoses at staging area (8) duration (6) Perform RCS and SFP makeup hose connections and alignment for makeup (7) Align FLEX SG makeup pump and hoses for suction from hotwell and discharge to AFW tie-in per FSG-003 Att. 3 to be available if lose AFW (8) As directed.

U3 Nuclear Plant (1) T=0 - 0.5 hr. (1) Investigate DG failure attempt to start and attempt to start (30 min) No Operator #1 (2) 0.5- 1 hr. (2) Attempt start Appendix R DG / DC load shed per 3 AOP-DC (10 min)

(3) 1 - 1.5 hr. (3) Deep DC load shed per FSG-004 Att 1 (15 nin)

(4) 1.5- 2 hr. (4) Verify DC bus voltage per FSG-004 step 4.3 (5) 3.5 -4 hr. (5) Go to U3 FLEX DG staging area to run cables when the equipment is staged (6) 4 - 5.5 hr. (6) Unload DG cables from trailer and hookup to DG per FSG-005 Att 3 (90 min)

(7) 5.5 - 7 hr. (7) Start FLEX DG and align breakers per FSG-005 - Att 5 (90 min)

(8) 7 -7.5 (8) Re-start battery room exhaust fans and battery chargers (15 min) Complete at 7.5 hrs.

(9) 7.5 until OSC operational (9) Periodic monitoring of FLEX DG operation Page 24 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 2 Unit POSITION TIME TASK Collateral Duty?

U3 Nuclear Plant (i) T=0 - 0.5 hr. (1) Immediate plant actions / isolate RCP letdown & seal water 3-ECA-0.0 No Operator #2 (2) 1 - 1.5 hr. (2) Monitor U3 SFP level and temperature (10 min)

(3) 1.5- 2.5 hr. (3) Perform BAST line flush per CVCS-8 with assistance from U2 NPO (60 min)

(4) 3 -3.5 hr. (4) Establish FSB Natural Circulation ventilation per FSSG-0l I Att 1(30 min)

(5) 3.5 - 4 hr. (5) Go to U3 FLEX RCS and SFP makeup staging area to run and connect hoses when the (6) 4 - 5.0 hr. equipment is staged (7) 5 - 7.5 hr. (6) Unload U3 hoses from trailer at pump staging areas (8) 8-9 hr. (7) Align hoses for RCS and SFP makeup per FSG-001 Att l and FSG-011 Att 2 Available at (9) 10- II hr. T=8 (10) 11-until OSC (8) Refill SFP operational (9) Start RCS makeup and continue as necessary (10) Available for SFP and RCS makeup as needed U3 Nuclear Plant (1) T=0 - 0.5 hr. (1) Verify,MSIV bypass valves closed / go to Aux Feed pump room area and monitor N2. No Operator #3 (2) 0.5 - I hr. Install N2 backupjumper to PCV-1 188 per FSG-002 Aut 2 (30 min)

(3) 8 - 10 hr. (2) Lineup N2 to atmospheric dump valves to allow control from CR (15 min)/ Remain in area (4) 10 - OSC operational to be available to perform tasks as necessary (3) Align FLEX SG makeup pump and hoses for suction from hotwell and discharge to AFW tie-in per FSG-003 A". 3 to be available if lose AFW (4) Support tasks in Aux Feed Bldg / monitor nitrogen / Start FLEX SG makeup if TDAFW pump lost U3 Nuclear Plant I) T=0-0.5 hr. (1) Break condenser vacuum (10 min) / Close CST to hotwell isolation valves (10 min) 3-ECA- No Operator #4 2) 0.5- 1 hr. 0.0

3) 3.5 -4 hr. (2) Vent generator hydrogen and secure seal oil pump (20 min) 3-ECA-0.0
4) 4 - 5.5 hr. (3) Go to U3 FLEX DG staging area to run cables when equipment is staged
5) 5.5 -7 hr. (4) Unload and hookup FLEX DG cables per FSG-005 ATT 3 (90 min)
6) 7 - 7.5 hr. (5) Start FLEX DG and align breakers per Att 5 (90 min)
7) 7.5 - OSC operational (6) Restart battery room exhaust fans and battery chargers ( 15 min) Chargers in service at T=7.5 (7) As directed U3 Communicator I) T=O - 0.5 hr. (I) Report to the control room / Establish initial offsite communication using satellite phone. No (Nuclear Plant (2) 0.5 - 1 hr. Make State and local notifications Operator #5) (3) 1 hr. - until EOF assumes (2) Make NRC notification and notify ERO via Everbridge using satellite phone (will be the function received outside the 25 mile zorle)

(3) Make offsite notifications as required Page 25 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 2 Unit POSITION TIME TASK Collateral Duty?

U3 Chemistry (1) T=0 - I hr. (1) Report to U3 CR to be available for dose assessment if needed No Technician (2) 1 - 8 hr. (2) Available for dose assessment as necessary (3) 8 - 10 hr. (3) Stage portable fuel tank with truck per FSG-005 Att 2 (2 hr.)

(4) 10-Until OSC (4) Commence refuel strategy operational U3 Radiation (1) T=0 - 3 hr. (I) Report to control room / RP support as needed No Protection (2) 3 - 3.5 hr. (2) RP support to establish FSB naturalization ventilation Technician (3) 3.5 - 4 hr. (3) RP support for filling SFP and monitoring SFP level and temperature (4) 4 - 5.5 hr. (4) If available support unloading U3 FLEX hose trailers at staging areas (5) 5.5- 7.5 hr. (5) Support alignment of hoses for RCS and SFP makeup.

(6) 7.5- until OSC (6) Onsite and in-plant Radiation monitoring and job coverage as needed operational Security (1) T=0 - duration (I) Security function to include opening gates and doors to provide access for FLEX equipment No or environmental conditions Page 26 of 27

Entergy IPEC UNITS 2 AND 3 Phase 2 Staffing Assessment Attachment 3 ATTACHMENT 3 Expanded Emergency Response Table NOTE ERO positions are filled in accordance with the applicable facility emergency implementing procedure. Selected ERO positions are shown in the Table to show comparable responsibilities for NEI 12-01 Table 3.2 recommended expanded emergency response individuals. Expertise from both units is desired, but not required, for those positions.

Expanded TOTAL Response Number required ERO Available to Function from Location Key Roles and Staffing Considerations U2 and U3 Implement Coping NEI 12-01, Strategies for 2 units Table 3.2 Evaluation of TSC o One team for each unit to evaluate selection Transition Phase of Transition Coping strategies; team No additional team Unit Operations Coordinator Coping Strategy performs evaluations not done by the members Unit Engineering Coordinator Control Room TSC Engineering Team 9 Team composition (i.e., number and represented disciplines) as described in governing site programs, procedures and guidelines.

- Team may include personnel responsible for performing other functions for the same assigned unit.

Implementation of OSC o Number and composition of personnel U2 - 5 NPO 4 ERO OSC Teams Transition Phase capable of simultaneous implementation of Coping Strategies any 2 Transition Phase coping strategies at U3 - 5 NPO each unit.

o Should not include personnel assigned to other function (e.g., emergency repair and corrective actions); however, may include members of the on-shift staff and personnel responsible for implementation of SAM strategies.

IPEC Simultaneous Im plementation of 2 Transition Phase Coping Strategies Strategy Required Staff to Implement Available Staff U2 FSG-003 Implement Alternate Low 2 Operators Pressure Feedwater 48 ROs*

U2 FSG-006 Implement CST Makeup 3 Operators 55 NPOs*

U3 FSG-003 Implement Alternate Low 2 Operators Pressure Feedwater U3 FSG-006 Implement CST Makeup 3 Operators

  • Unit specific qualification is not required for running and connecting hoses/cables and operating FLEX equipment.

Qualified on-shift staff is available to manipulate or operate installed plant valves or equipment.

Page 27 of 27

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