NLS2021035, Attachment/Enclosureport of Change and Summary of 50.54(q) Analysis - On-Shift Staffing Analysis, Rev. 3

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Attachment/Enclosureport of Change and Summary of 50.54(q) Analysis - On-Shift Staffing Analysis, Rev. 3
ML21132A056
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Site: Cooper Entergy icon.png
Issue date: 05/10/2021
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Nebraska Public Power District (NPPD)
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Office of Nuclear Reactor Regulation
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NLS2021035
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NLS2021035 Attachment Page 1 of 1 ATTACHMENT Cooper Nuclear Station Report of Change and Summary of 50.54(q) Analysis On-Shift Staffing Analysis, Revision 3 Change

Description:

The radio paging system and pagers are being eliminated at Cooper Nuclear Station (CNS). The CNS On-Shift Staffing Analysis,Section VIII Appendix C, Time Motion Studies Supporting the Staffing Analysis, was revised to replace references to pager activation with a description of Automated Notification System (ANS) activation. The ANS system contains the available contact information for the emergency response organization and is in place and functional for replacement of the radio paging system and pagers.

Additional changes to the On-Shift Staffing Analysis were made to replace the outdated term Dialogic/Dialogics Program with ANS, remove outdated instruction to activate the Dialogics pushbutton, remove the color description of the Scenario pushbutton, and update various task timelines.

Change Summary of Analysis (10 CFR 50.54(q) Screen):

The emergency planning impact screen determined the change did not impact a planning standard or program element and as such, did not require completion of a full 10 CFR 50.54(q) evaluation.

NLS2021035 Enclosure ENCLOSURE Cooper Nuclear Station On-Shift Staffing Analysis, Revision 3

CNS ON-SHIFT STAFFING ANALYIS REPORT Nebraska Public Power District COOPER NUCLEAR STATION 10CFR50 APPENDIX E ON-SHIFT STAFFING ANALYSIS Revision 3 April 28, 2021 Prepared by: % rx:J:dcw.nQ\ft/28/2021 Kim Tanne~ / Date COOPER Page 1

COOPER ON-SHIFT STAFFING ANALYIS REPORT TABLE OF CONTENTS I. INTRODUCTION ..................................................................................................................................3 II. ANALYSIS

SUMMARY

.......................................................................................................................3 A. Emergency Plan Minimum Staffing ......................................................................................4 B. Other Commitments to Shift Staffing ....................................................................................s C. Staffing Exceptions and Time Motion Studies (TMS) ........................................................ s D. Emergency Plan Tasks Not Analyzed ................................................................................... 6 lfL ANALYSIS PROCESS ........................................................................................................................6 IV. ACCIDENT SCENARIOS ...................................................................................................................8 A. Accident Selection ...................................................................................................................8 B. Accident Scenarios included in the Analysis ...................................................................... 8 C. Accident Scenarios not included in the Analysis ................................................................ 9 V. GENERAL ASSUMPTIONS AND LIMITATIONS .......................................................................... 10 A. Notes and Assumptions applicable to Cooper OSA: ....................................................... 10 B. NEI 10-05 Rev O Assumptions ............................................................................................10 VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS ........................................................... 13 VIL APPENDIX B - ON-SHIFT STAFFING ANALYSIS ...................................................................... 15 A. Accident Analysis #1 - Design Basis Threat (DBT) ......................................................... 15 B. Design Basis Accident Analysis #2 - Control Rod Drop Accident ................................ 22 C. Design Basis Accident Analysis #3 - Loss of Coolant Accident... ................................. 28 D. Design Basis Accident Analysis #5 - Fuel Handling Accident. ...................................... 35 E. Design Basis Accident Analysis #6 - Main Steam Line Break...................................... 41 F. Design Basis Accident Analysis #7 -Aircraft Probable Threat ..................................... 47 G. Design Basis Accident Analysis #8 - Control Room Evacuation and Shutdown ........ 53 H. Accident Analysis #9 - Station Blackout ...........................................................................59 I. Accident Analysis #10 - LOCA/General Emergency with Release and PAR. ............. 65 VIII. APPENDIX C-TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ....... 71 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ........................... 75 A. Overlap Requiring Compensatory Measures .................................................................... 75 X. REFERENCES ...................................................................................................................................75 XI. ORIGINAL STAFFING ANAL YIS TEAM ........................................................................................75 COOPER Page 2

COOPER ON-SHIFT STAFFING ANALYIS REPORT I. INTRODUCTION This document is a revision to the Cooper Nuclear Station On-shift Staffing Analysis (OSA) report dated July 20, 2015. This revision adds a clarifying not into the report identifying the process used for revising this document and Identifying it as part of the CNS Emergency Plan.

This revision continues to satisfy the requirements of 10 CFR 50 Appendix E Section IV.A.9, which states that nuclear power licensees shall perform "a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan." A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities. This analysis examined the capability of the minimum staff listed in Figure 5.2-1 of the Cooper Emergency Plan (E-Plan) to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-Plan.

NOTE: This report is considered part of the CNS Emergency Plan. Any changes made to this report must follow the guidance in CNS Administrative Procedure 0.29.1 "License Basis Document Changes".

IL ANALYSIS

SUMMARY

The OSA team determined that an on-shift staff offourteen (14) is required to respond to the most limiting accident scenario reviewed, main control room fire and shutdown at the remote shutdown panel. The on-shift staff consists of individuals necessary to support each of the E-Plan functional areas or tasks:

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

COOPER Page 3

COOPER ON-SHIFT STAFFING ANALYIS REPORT A. Emergency Plan Minimum Staffing Per 10 CFR 50.54 (q)(1 )(iii), Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV of Appendix E and, for nuclear power reactor licensees, the planning standards of§ 50.47(b).

The following table indicates the result of the NEI 10-05 staffing analysis of on-shift personnel to perform the required emergency planning functions and the licensing basis requirement for each on-shift position.

On-Shift Licensing Basis Staffing Position E-Plan Functional Area Requirement Analysis Results 50.54m Emergency Direction and Shift Manager (SM) E-plan 5.1.1, 5.1.2, 1 Control Figure 5.2-1 50.54m Control Room Supervisor (CRS) E-plan 5.1.1, 5.1.2, SSD 1 Figure 5.2-1 E-plan 5.1.1, 5.1.2, Shift Technical Engineer (STE) Technical Support 1 Figure 5.2-1 50.54m Reactor Operator #1 E-plan 5.1.1, 5.1.2, SSD 1 Figure 5.2-1 50.54m Reactor Operator #2 E-plan 5.1.1, 5.1 .2, SSD 1 Figure 5.2-1 E-plan 5.1.1, 5.1.2, Reactor Operator #3 FBL 1 Figure 5.2-1 Station Operator #1 E-plan 5.1.1, 5.1.2, Figure SSD 1 5.2-1 E-plan 5.1.1 , 5.1.2, Figure Station Operator #2 FB 1 5.2-1 E-plan 5.1.1, 5.1.2, Figure Station Operator #3 FB 1 5.2-1 E-plan 5.1.1, 5.1.2, Figure Notifications and Communicator1 1 5.2-1 Communications E-plan 5.1.1, 5.1.2, Figure Dose Assessor1 Dose Assessment 1 5.2-1 E-plan 5.1.1, 5.1.2, Figure Chemistry/Radiation Chemistry/RP Technician 1 5.2-1 Protection E-plan 5.1.1, 5.1.2, Figure Utility Worker Fire Brigade #1 FB 1 5.2-1 E-plan 5.1.1, 5.1.2, Figure Utility Worker Fire Brigade #2 FB 1 5.2-1 Per Security Access Control and Security Security Contingency Plan Contingency Accountability Plan TOTAL 14 1

Filled by staff qualified per TPP-101, Training Program Procedure and the Emergency Plan COOPER Page 4

COOPER ON-SHIFT STAFFING ANALYIS REPORT B. Other Commitments to Shift Staffing None.

C. Staffing Exceptions and Time Motion Studies (TMS)

1. The primary responsibility for the Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being time critical or required during the first 60 minutes of any of the analyzed events. It is therefore acceptable to assign the Chemistry Technician the E-Plan function of dose assessment. No further analysis or TMS is required.
2. The Shift Manager is assigned the responsibility to make some event notifications such as the Duty Plant Manager, and Operations Manager. These notifications by phone are considered communications that are approximately one minute in length and are tasks for the Shift Manager, No further analysis or TMS is required.
3. The analysis included a review of the implementation of the requirement to maintain continuous communications with the notification source during an aircraft threat in accordance with 10CFR50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The review of the Aircraft Threat Accident identified that there are sufficient personnel on-shift to perform this action during the event. Specifically, a licensed or non-licensed nuclear plant operator and a chemistry technician were all available to fill this function. No further analysis or TMS is required.
4. A Time Motion Study was completed to determine if the Shift Manager performance of ERO notification would impact the capability to maintain emergency direction and control as Emergency Director. The TMS demonstrated that the Shift Manager was able to maintain oversight for emergency direction and control during the approximate 90 seconds that it took to activate the ERO using Dialogics. ERO notification was evaluated as being an acceptable task for the Shift Manager. Details of the TMS are found in section VIII Appendix C COOPER Page 5

COOPER ON-SHIFT STAFFING ANALYIS REPORT D. Emergency Plan Tasks Not Analyzed

1. Repair and Corrective Action -. Repair and corrective action is defined as:
  • An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g.,

open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete.

In accordance with NEI 10-05 section 2.5, the analysis included a review of the repair and corrective action tasks. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

  • Unplanned/unexpected actions that address equipment failures. These actions are contingent in nature and cannot be specified in advance.

At CNS, Station Operators on shift will primarily be available to the Shift Manager to perform actions to assist in controlling/mitigating the event. Initial corrective actions are contained in and controlled by plant operating procedures. The Station Operators have been trained to perform specific actions within the Abnormal and Emergency Operating Procedures and maintenance support is not required. Maintenance is not included in the on-shift staff. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed

2. Rescue Operations and FirstAi.d: In accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response. Rescue operations and first aid may be performed by shift personnel assigned other functions. At CNS the Search and Rescue function is handled by trained emergency response personnel. If station personnel are unaccounted for in the initial or subsequent personnel accountability, an emergency team will be assigned to locate and if necessary, rescue them. Rescue operations and first aid response are acceptable collateral duties per the guidance of NEI 10-05 and was not analyzed.

Ill. ANALYSIS PROCESS The initial staffing analysis (Revision 0) was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, Security, Chemistry and Emergency Preparedness (EP} departments. The team members are identified in Section XII of this report.

The emergency response to each event scenario was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures.

Each scenario was reviewed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for Emergency Plan implementation as described in the Emergency Plan Section 5.1 and Figure 5.2.1, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, the team evaluated timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements.

COOPER Page 6

COOPER ON-SHIFT STAFFING ANALYIS REPORT The results of the analysis for each of the scenarios are included in Section VIII, APPENDIX B- ON-SHIFT STAFFING ANALYSIS. Note that NSIR DPR-ISG-01 states that only OBA accidents "which would result in an emergency declaration" should be evaluated in the staffing assessment. Each of CNS DBA's were evaluated and classified according to its FSAR Chapter XIV description. If the accident description alone did not result in a classification, the projected accident exclusion area boundary (EAB) dose found in the FSAR was utilized to determine if an EAL threshold would be exceeded within the first 60 minutes using the Abnormal Rad Level EAL thresholds. In cases where several projected dose rates were provided or release data was not detailed significantly to determine an EAL, the assessment used the radiological consequences associated with the realistic case in accordance with NEI 10-05.

COOPER Page 7

COOPER ON-SHIFT STAFFING ANALYIS REPORT IV. ACCIDENT SCENARIOS A. Accident Selection

1. The OSA scenarios were chosen using the guidance of NEI 10-05 and NSIR/DPR-ISG-01, "Interim Staff Guidance - Emergency Planning for Nuclear Power Plants." The evaluation considered the station Design Basis Accidents (DBA) described in the FSAR along with additional scenarios specified by the guidance documents. The scenarios considered were:
  • Design Basis Threat (DBT) ground assault
  • DBA Loss of Coolant Accident
  • OBA Fuel Handling Accident
  • Aircraft Probable Threat
  • Fire Requiring Evacuation of the Control Room and Plant Shutdown From Alternate Location
  • Station Blackout, (SBO)
  • LOCA/General Emergency with release and PAR
  • LOCA with entry into Severe Accident Management

B. Accident Scenarios included in the Analysis

1. Design Basis Threat (DBT) as described in NEI 10-05
  • Land and/or waterborne Hostile Action directed against the Protected Area by a Hostile Force. This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed. EAL is based on the event.
2. Control Rod Drop Accident as described in FSAR XIV-6 Section 6.2
  • One control rod drops and reactor trips on APRM 120% flux scram. Credit is not taken for MSIV closure. Release pathway is through condenser, turbine building, then to environment. EAL is based on condenser release EAB dose information in FSAR.
3. Loss of Coolant Accident as described in FSAR XIV-6 Section 6.3
  • Double ended guillotine break of a recirculation line. All ECCS operate as designed. EAL is based on fission product barrier EALs.
4. Fuel Handling Accident as described in FSAR XIV-6 Section 6.4
  • The accident involves a dropped fuel bundle on top of the core. Initial EAL is based on event.

COOPER Page 8

COOPER ON-SHIFT STAFFING ANALYIS REPORT

5. Main Steam Line Break Accident as described in FSAR XIV-6 Section 6.5
  • Break of one main steam line and followed by MSIV closure. Release is to the atmosphere through the top of the turbine building (puff release). Reactor coolant activity at TS limit.

No EAL on the accident but on the USAR EAB 2-hr dose.

6. Aircraft Probable Threat (50.54hh)
  • Notification is received from the NRC that a probable aircraft threat exists (>5 minutes,

<30 minutes). EAL is based on the event.

7, Control Room Fire and Remote Shutdown.

  • A fire occurs in the main control room requiring the evacuation and the procedure implemented to perform shutdown from the alternate shutdown panels. EAL is based on the event.
8. Station Blackout.

EAL is based on the event.

9. General Emergency with release and PAR
  • Assume GE condition with dose projection indication of a release greater than the protective action guideline (PAG).

C. Accident Scenarios not included in the Analysis

1. Accidents That Result in Direct Release to Secondary Containment
2. Implement SAMG
  • NEI 10~05 Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators. A review of the SAMGs associated with the initial site-specific Candidate High Level Actions concluded that no actions would require on-shift personnel other than licensed and non-licensed operators.

No analysis required.

3. NFPA 805 Fire
  • Fire leading to reactor trip with complications. The control room fire and alternate shutdown requires more resources and actions outside the control room than this fire. The team concluded the control room fire bounds the fire analysis. No additional analysis required.

COOPER Page 9

COOPER ON-SHIFT STAFFING ANALYIS REPORT V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions applicable to Cooper OSA:

1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Abnormal Operating Procedures (AOP), Emergency Operating Procedures (EOP), and Emergency Plan Implementing Procedures (EPIP). Any additional tasks directed by the Technical Support Center (TSC), Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures were not reviewed.
2. The OSA team determined RP/Chem Tech tasks performance is directed and prioritized by the Shift Manager. The time the RP/Chem Tech is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are required by Tech Specs within the 60 minute period after the declaration. Since the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.
3. All crews have one individual filling the SM and one individual filling the STE roles therefore the analysis did not consider using a dual-role individual
4. While the augmentation time used for this analysis was based on the time identified in the station's emergency plan (60 minutes), no additional tasks requiring the augmented ERO were noted as being required of the on-shift ERO for the first 90 minutes following the emergency declaration.

B. NEI 10-05 Rev O Assumptions

1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task. (60 min.).
2. On-shift personnel complement was limited to the minimum required number and composition as described in the site emergency plan. If the plan commitments allow for different minimum staffing levels (e.g., a variance between a normal dayshift and a backshift), use the staffing with the smallest number of personnel.
3. Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.
4. Event occurred during off-normal work hours where ERO was offsite and all required minimum on-shift positions were filled.
5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.
6. On-shift staff had necessary Radiation Worker qualification to obtain normal dosimetry and enter the radiological control area (RCA) (but not locked high or very high radiation areas) without the aid of a RP technician.

COOPER Page 10

COOPER ON-SHIFT STAFFING ANALYIS REPORT

7. Personnel assigned plant operations arid safe shutdown meet the requirements and guidance (analyzed through other programs such as operator training) and was evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.
8. In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain safe shutdown was done by a member of the on-shift staff as defined in the unit's Tech Specs.
9. Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.
10. Individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.
11. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.
12. Communications, briefings, and peer checks are acceptable collateral duties.
13. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIR/DPR-ISG-01) 14, The Staffing Analysis specified the resources available to perform "Repair and Corrective Actions" and "Rescue Operations and First Aid" but these may be assigned as collateral duty to a designated on-shift responder.
15. For assessment purposes, NRC notifications were treated as a continuous action per 10CFR50.72(c)(3) and 73.71(b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.
16. DBA (postulated accident, Condition IV event, or limiting fault) is considered as "Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation. As a result, a greater number and variety of actions would need to be implemented by plant personnel."
17. Unless otherwise specified in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, or by the FSAR initial conditions of a DBA analysis, it was assumed that the unit was in Mode 1, Power.
18. DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to prevent safe shutdown or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.
19. The Staffing Analysis used DBA analysis assumptions, inputs, timing of events, plant protective response, and specified manual operator actions and their timing, as documented in the FSAR.

COOPER Page 11

COOPER ON-SHIFT STAFFING ANALYIS REPORT

20. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began 15-minutes after the initiating event.
21. Severe Accident Management Guideline (SAMG) - It is sufficient to simply assume that the accident progressed to conditions requiring a severe accident response; it is not necessary to determine specific failures and the accident sequence.
22. SAMG - The actions analyzed included those that implement the initial site-specific actions assuming the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent challenge to containment integrity.

COOPER Page 12

COOPER ON-SHIFT STAFFING ANALYIS REPORT VI. APPENDIX A* ANALYZED EVENTS AND ACCIDENTS Summary Event Plant Analysis Event Type Description of Reference Document(s) Event ECL

  1. Mode1 Required?

Event 1 DBT Land and/or 1 NEI 10-05 Site Area Yes waterborne Emergency HOSTILE ISGIV.C ACTION directed against the Protected Area by a HOSTILE FORCE.

2 OBA Control Rod Drop 1 FSAR XIV-6 Section 6.2 Site Area Yes Accident Emergency 3 OBA Loss of Coolant 1 FSAR XIV-6 Section 6.3 Site Area Yes Accident Emergency 4 OBA Accidents that 1 Not described in FSAR N/A Na2 result in radioactive material release directly to the Secondary Containment 5 OBA Fuel Handling 5 FSAR XIV-6 Section 6.4 Alert Yes Accident 6 OBA Main Steam Line 1 FSAR XIV-6 Section 6.5 Unusual Event Yes Break 7 Assumed for Aircraft Probable 1 10CFR50.54hh (1) Alert Yes analysis purpose Threat RG 1.214 8 Assumed for Control Room 1 FSAR 14.6.1 Alert Yes Analysis Purpose Evacuation and Alternate Shutdown (fire in main control 10CFR50 NFPA 805 Fire room) Hazard Analysis 9 Assumed for Station Blackout 1 ISGIV.C Site Area Yes analysis purpose Emergency 10 Assumed for LOCA- General 1 ISGIV.C General Emergency Yes Analysis Purpose Emergency with radiological release and PAR 11 Assumed for LOCA with entry 1 ISGIVC General Emergency 3 No Analysis Purpose into severe accident procedures.

12 Assumed for NFPA 805 Fire 1 ISGIV.C Site Area 4 No Analysis Purpose with Reactor Trip Emergency 1 Plant mode per FSAR or assumed for analysis purpose COOPER Page 13

COOPER ON-SHIFT STAFFING ANALYIS REPORT 2

Includes 2 varieties of accidents: (1) Failures of the reactor coolant pressure boundary inside Secondary Containment and (2) failure involving fuel that is located outside the Primary Containment but inside the Secondary Containment. These accidents are not described in the FSAR since they are less severe than similar accidents in other categories. Analysis is not required.

3 CNS does not meet the NEI 10-05 intent for the analysis of implementing SAMG. NEI 10-05 Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators. The actions assessed by NEI 10-05 are those which implement the initial site-specific Candidate High Level Action assuming the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent challenge to containment integrity. CNS does not include maintenance qualified to perform maintenance job tasks in minimum staffing and any response actions would be performed by operators.

4 NFPA 805 Fire is bound by the Control Room Fire and Alternate Shutdown. Analysis is not required.

COOPER Page 14

COOPER ON-SHIFT STAFFING ANALYIS REPORT VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS A. Accident Analysis #1 - Design Basis Threat (DBT)

1. Accident Summary
  • Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat. Security Code Red condition.
2. Accident Specific Assumptions Made
  • This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.
  • Assume at power in Mode 1
  • Security notifies the Shift Manager of condition Security Code RED.
  • Assume all non-security staff is located inside the protected area at their normal work station when the event occurs.
  • Assume all systems function and the core remains covered. No fuel damage and no release.
3. Procedures for Accident Response
  • 5.5SECURITY
  • 5. 7.1, Emergency Classification
  • 5.7.2, Emergency Director EPIP
  • 5. 7 .6, Notification COOPER Page 15

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains the staffing identified in Section II.A, OSA Minimum Staffing.

CNS TABLE 1 - ON-SHIFT POSITIONS Analysis # 1 DBT Securit!l Threat Augmentation Role in Line On-shift Basis Unanalyzed TMS Elapsed Time (min)* Table#/

  1. Position Document Task? Required?

Line#

T2/L1 T5/L1 T5/L3 T5/L5 1 Emergency Shift Manager Plan 60 T5/L6 No Yes T5/L7 Figure 5.2-1 T5/L 11 TS/L 14 Emergency Control Room 2

Supervisor Plan N/A T2/L2 No No Figure 5.2-1 Emergency Shift Technical T2/L3 3

Engineer (STE)

Plan 60 No No T5/L 10 Figure 5.2-1 Emergency Reactor 4

Operator #1 Plan N/A T2/L4 No No Figure 5.2-1 Emergency Reactor 5

Operator#2 Plan N/A T2/L5 No No Figure 5.2-1 Emergency Reactor 6

Operator #3 Plan N/A N/A No No Fiqure 5.2-1 Emergency Station Operator

  1. 1 Plan N/A T2/L6 No No Fiqure 5.2-1 Emergency Station Operator 8 Plan N/A N/A No No
  1. 2 Figure 5.2-1 Emergency 9

Station Operator Plan 60 NIA No No

  1. 3 Figure 5.2-1 Emergency T5/L8 10 Communicator Plan 60 T5/L9 No No Fioure 5.2-1 T5/L 13 Emergency RP/Chem Tech 11
  1. 1 Plan 60 N/A No No Figure 5.2-1 Emergency 12 Dose Assessor Plan 60 N/A No No Figure 5.2-1 Utility Fire Emergency 13 Brigade Plan N/A N/A No No Member#1 Figure 5.2-1 Utility Fire Emergency 14 Brigade Plan N/A NIA No No Member#2 Figure 5.2-1 COOPER Page 16

COOPER ON-SHIFT STAFFING ANALYIS REPORT Security 15 Security Contingency 60 T5/L 15 No No Plan COOPER Page 17

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 1 DBT Security Threat Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 1 Licensed Operator Training Shift Manager Shift Manager Program 2 Licensed Operator Training Unit Supervisor Control Room Supervisor Program 3 Shift Technical Engineer Licensed Operator Training Shift Technical Advisor (STE) Program 4 Licensed Operator Training Reactor Operator #1 Reactor Operator #1 Program Licensed Operator Training 5 Reactor Operator #2 Reactor Operator #2 Program Non-Licensed Operator 6 ~uxiliary Operator #1 Station Operator #1 Training Program 7 ~uxiliary Operator #2 NIA NIA 8 Other needed for Safe Shutdown NIA N/A 9 Other needed for Safe Shutdown NIA NIA 10 Other needed for Safe Shutdown NIA NIA Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Task Analysis Line# Generic Title/Role On-Shift Position Controlling Method 11 Mechanic NIA N/A 12 Electrician NIA NIA 13 l&C Technician NIA NIA 14 Other N/A NIA 15 Other NIA NIA COOPER Page 18

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 3 - FIREFIGHTING ANALYSIS # 1 DBT Securit~ Threat Line Performed by Task Analysis Controlling Method 1 N/A Fire Protection Program 2 N/A Fire Protection Program 3 N/A Fire Protection Program 4 N/A Fire Protection Program 5 N/A Fire Protection Program Note: This accident does not include the need for firefighting, first aid or search & rescue.

COOPER Page 19

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4- RADIATION PROTECTION AND CHEMISTRY Analysis # 1 DBT Securitl Threat L Position Performing Performance Time Period After Emergency Declaration (minutes)

I Function/ Task N 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 ~0-45 f45-50 50-55 55-60 60-65 65- 70 80- 85-90 E 70 75 80 85 1 In-Plant Survey: N/A 2 !On-site Survey: NIA 3 Personnel Monitoring: ~

4 IJob Coverage: N/A 5 IOffsite Rad Assessment:

N/A 6 Other site specific RP (describe): N/A 7 Chemistry Function task 1#1 (describe)

N/A 8 Chemistry Function task

  1. 2 (describe)

N/A Note: No chemistry or RP job function tasks for the conditions described in the DBT assumptions. The RP/Chem Tech takes cover as directed.

COOPER Page 20

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 1 DBT Securit~ Threat Function I Task On-Shift Task Analysis Controlling Method Line#

Position Declare the emergency classification level Emergency Planning Training 1 Shift Manager (ECL) Program I EP Drills Approve Offsite Protective Action 2 NIA N/A Recommendations

~pprove content of State/local notifications Shift Manager Emergency Planning Training 3

Program 4 Approve extension to allowable dose NIA NIA Notification and direction to on-shift staff Licensed Operator Training 5 Shift Manager Program I Emergency Planning (e.g., to assemble, evacuate, etc.)

Training Program ERO notification Emergency Planning Training 6 Shift Manager Program Abbreviated NRC notification for DBT event Shift Manager Licensed Operator Training 7

Program Complete State/local notification form Emergency Planning Training 8 Communicator Program Perform State/local notifications Emergency Planning Training 9 Communicator Program Licensed Operator 10 Complete NRC event notification form STE Training Program Activate ERDS Emergency Planning Training 11 Shift Manager Program 12 Offsite radiological assessment N/A N/A Emergency Planning Training 13 Perform NRC notifications Communicator Program Perform other site-specific event Licensed Operator 14 notifications (e.g., Duty Plant Manager, Shift Manager INPO, ANI, etc.) Training Program Personnel Accountability Security Training Program I EP 15 Security Officer Drills COOPER Page 21

COOPER ON-SHIFT STAFFING ANALYIS REPORT B. Design Basis Accident Analysis #2 - Control Rod Drop Accident

1. Accident Summary
  • The control rod drop accident (CRDA) results from an assumed failure of the control rod-to-drive mechanism coupling after the control rod (very reactive rod) becomes stuck in its fully inserted position. It is assumed that the control rod drive is then fully withdrawn before the stuck rod falls out of the core. The control rod velocity limiter, an engineered safeguard, limits the control rod drop velocity. The resultant radioactive material release is maintained far below the guideline values of 10CFR50.67.
  • Loss of offsite power coincidental with CRDA.
  • Radionuclides are released from damaged fuel rods to the main condenser. Single release path is modeled from the leakage of main condenser at 1% volume per day to the turbine building. Activity is distributed throughout the turbine building and passes directly to the environment (with no mixing or holdup in the TB volume) as a diffuse ground level release
2. Accident Specific Assumptions Made
  • EAL is based on FSAR EAB dose information.
3. Procedures for Accident Response
  • 5.1 RAD, Building Radiation Trouble
  • 2.40G, Offgas Abnormal
  • 5.2Fuel, Fuel Failure
  • 5.3EMPWR, Emergency Power During Modes 1, 2, and 3
  • 5.7.16, Release Rate Determination
  • 5. 7 .17, Dose Assessment
  • 5. 7 .19, On-site Radiological Monitoring
  • 5. 7.1, Emergency Classification
  • 5.7.2, Emergency Director EPIP
  • 5.7.6, Notification
  • 5.7.10, Personnel Assembly and Accountability
  • 9.EN-RP-142, Failed Fuel Response COOPER Page 22

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains the staffing identified in Section II.A, OSA Minimum Staffing.

CNS TABLE 1 - ON-SHIFT POSITIONS Analysis # 2 Control Rod Droe Accident Augmentation Role in Line# !On-shift Position Unanalyzed TMS Basis Document Elapsed Time Table#/

Task? Required?

(min)* Line#

T2/L 1 T5/L 1 Emergency Plan T5/L3 1 Shift Manager 60 No Yes Figure 5.2-1 T5/L5 T5/L6 T5/L 14 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5.2-1 T2/L3 Shift Technical Emergency Plan 3 60 T5/L 10 No No Engineer (STE) Figure 5.2-1 T5/L 11 Emergency Plan 4 Reactor Operator #1 N/A T2/L4 No No Fioure 5.2-1 Emergency Plan 5 Reactor Operator #2 N/A T2/L5 No No Figure 5.2-1 Emergency Plan 6 Reactor Operator #3 N/A N/A No No Figure 5.2-1 Emergency Plan 7 Station Operator #1 N/A T2/L6 No No Figure 5.2-1 Emergency Plan N/A N/A 8 Station Operator #2 No No Figure 5.2-1 Emergency Plan 60 N/A 9 Station Operator #3 No No Figure 5.2-1 T5/L8 Emergency Plan 10 Communicator 60 T5/L9 No No Figure 5.2-1 T5/13 T4/L 1 Emergency Plan 60 11 RP/Chem Tech #1 T4/L7 No No Figure 5.2-1 Emergency Plan T5/L 12 12 Dose Assessor 60 No No Figure 5.2-1 Utility Fire Brigade Emergency Plan 13 N/A N/A No No Member #1 Figure 5.2-1 Utility Fire Brigade Emergency Plan 14 N/A NIA No No Member #2 Figure 5.2-1 Security 15 Security 60 TS/L 15 No No Contingency Plan COOPER Page 23

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2-PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 2 Control Rod Drop Accident Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable line# Generic Title/Role On-Shift Position Task Analysis Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program Licensed Operator 2 Unit Supervisor Control Room Supervisor Training Program Shift Technical Engineer Licensed Operator 3 Shift Technical Advisor (STE) Training Program Licensed Operator 4 Reactor Operator #1 Reactor Operator #1 Training Program Licensed Operator 5 Reactor Operator #2 Reactor Operator #2 Training Program Non-Licensed Operator 6 Auxiliary Operator #1 Station Operator # 1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A COOPER Page 24

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING ANALYSIS # 2 Control Rod Droo Accident Line Performed by Task Analysis Controlling Method 1 N/A NIA 2 N/A N/A 3 N/A NIA 4 N/A N/A 5 NIA NIA The CRDA does not include the need for firefighting.

COOPER Page 25

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 2 Control Rod Droo Accident L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function/ Task N

E 0-5 5-10 10-15 '15-20 20-25 25-30 30-35 35-40 140-45 !45-50 50-55 55-60 60-65 65- 70 80-85-90 70 75 80 85 1 I In-Plant Survey:

lApplicable steps of EN-RP-142, Failed Fuel X X X X X X X X X

Response

2 On-site Survey: N/A 3 Personnel Monitoring:

N/A 4 Job Coverage: N/A 5 rOffsite Rad Assessment:

I/Included in Table S>

6 rOther site specific RP (describe): N/A 7 Chemistry Function task W1 (describe) - N/A 8 Chemistry Function task

  1. 2 (describe) - N/A
  • Performance Times are estimated Rx coolant sample as directed by the SM is not required until 2-6 hours after shutdown.

Procedure directs Offgas sample (not time critical) but it isolates. Sample not required during the 60 minutes.

COOPER Page 26

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5- EMERGENCY PLAN IMPLEMENTATION Analysis # 2 Control Rod Droe Accident Line Function/ Task On-Shift Position Task Analysis

  1. Controlling Method Emergency Planning Declare the emergency classification level 1 Shift Manager rrraining Program / EP
ECL)

Drills Approve Offsite Protective Action 2

Recommendations NIA N/A Approve content of State/local notifications Emergency Planning 3 Shift Manager Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Notification and direction to on-shift staff Training Program /

5 ~e.g., to assemble, evacuate, etc.)

Shift Manager Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Complete State/local notification form Emergency Planning 8 Communicator Training Program Perform State/local notifications Emergency Planning 9 Communicator Training Program Non-Licensed Operator 10 Complete NRC event notification form STE Training Program Emergency Planning 11 ~ctivate ERDS STE Training Program Emergency Planning 12 Offsite radiological assessment Dose Assessor Training Program Emergency Planning 13 Perform NRC notifications Communicator

!Training Program Perform other site-specific event notifications (e.g., Duty Plant Manager, Licensed Operator 14 Shift Manager INPO, ANI, etc.) !Training Program Personnel Accountability Security Training Program 15 Security V EP Drills COOPER Page 27

COOPER ON-SHIFT STAFFING ANALYIS REPORT C. Design Basis Accident Analysis #3 - Loss of Coolant Accident

1. Accident Summary
  • This event involves the postulation of a spectrum of piping breaks inside containment varying in size, type, and location. Break of a large recirculation pipe represents the limiting pipe break inside the containment. Reactor scram, MSIVs isolate, ECCS initiates and injects.
  • Worst case 2-hour period for exclusion area boundary dose occurs from 1.3 to 3.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of 1.002 rem TEDE.
2. Accident Specific Assumptions Made
  • Loss of offsite power at the initiating event and is not restored during event.
  • No operator action for the first 1O minutes. Post-LOCA manual valve manipulations are after the initiating alarm is received.
  • Classification is made on fission product barrier EAL.
3. Procedures for Accident Response
  • 5.2FUEL, Fuel Failure
  • 5.1 RAD, Building Radiation Trouble
  • 5. 7.1, Emergency Classification
  • 5.7 .2, Emergency Director EPIP
  • 5.7.6, Notification
  • 5.7.10, Personnel Assembly and Accountability
  • 5.7.14, Stable Iodine Thyroid Blocking (Kl)
  • 5. 7 .16, Release Rate Determination
  • 5.7.17, Dose Assessment
  • 5. 7 .19, On-site Radiological Monitoring COOPER Page 28

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains staffing identified in Section II.A, OSA Minimum Staffing CNS TABLE 1 -ON-SHIFT POSITIONS Analysis # 3 Loss of Coolant Accident Augmentation Role in Line On-shift Basis Unanalyzed TMS Elapsed Time (min)* Table#/
  1. Position Document Task? Required?

Line#

T2/L 1 T3/L 1 T5/L 1 Emergency 1 Shift Manager T5/L3 Plan 60 No Yes T5/L5 Figure 5.2-1 T5/L6 T5/L 14 T5/L 11 Emergency Control Room 2 Plan N/A T2/L2 No No

$upervisor Figure 5.2-1 Emergency Shift Technical T2/L3 3 Plan 60 No No Engineer (STE) T5/L 10 Figure 5.2-1 Emergency Reactor 4 Plan N/A T2/L4 No No Operator #1 Fioure 5.2-1 Emergency Reactor 5 Plan N/A T2/L5 No No Operator#2 Figure 5.2-1 Emergency Reactor 6 Plan N/A N/A No No Operator#3 Figure 5.2-1 Emergency Station Operator 7 Plan N/A T2/L6 No No

  1. 1 Figure 5.2-1 Emergency Station Operator N/A N/A 8 Plan No No W2 Figure 5.2-1 Emergency

!Station Operator 60 N/A 9 Plan No No W3 Figure 5.2-1 Emergency T5/L8 10 Communicator Plan 60 T5/L9 No No Figure 5.2-1 TS/13 T4/L 1 Emergency RP/Chem Tech 60 T4/L4 11 Plan No No

  1. 1 T4/L6 Figure 5.2-1 Emergency 12 Dose Assessor Plan 60 T5/L 12 No No Figure 5.2-1 Utility Fire Emergency 13 Brigade Plan N/A N/A No No Member #1 Figure 5.2-1 Utility Fire Emergency N/A 14 N/A No No Brigade Plan COOPER Page 29

COOPER ON-SHIFT STAFFING ANALYIS REPORT Member#2 FiQure 5.2-1 Security 15 Security Contingency 60 T5/L 15 No No Plan COOPER Page 30

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 3 Loss of Coolant Accident Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method Licensed Operator 1 Shift Manager Shift Manager

!Training Program Licensed Operator 2 Unit Supervisor Control Room Supervisor rrraining Program Shift Technical Engineer Licensed Operator 3 Shift Technical Advisor (STE) rrraining Program Licensed Operator 4 Reactor Operator #1 Reactor Operator #1 rrraining Program Licensed Operator 5 Reactor Operator #2 Reactor Operator #2 rrraining Program Non-Licensed Operator 6 Auxiliary Operator #1 Station Operator #1 rrraining Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician NIA N/A 14 Other N/A N/A 15 Other N/A N/A COOPER Page 31

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING ANALYSIS # 3 Loss of Coolant Accident Line Performed by Task Analysis Controlling Method 1 NIA NIA 2 NIA NIA 3 NIA NIA 4 N/A NIA 5 NIA N/A The LOCA does not include a fire.

COOPER Page 32

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 3 Loss Of Coolant Accident L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function/ Task N 70-E 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65- 75- 80-85-90 70 75 80 85 1 In-Plant Survey: Set up portable sampler for CR X X X monitoring 2 K:>n-site Survey: N/A 3 Personnel Monitoring:

NIA 4 Uob Coverage: Proc. 5.2 Att 1 (Operator valve manipulations X X X X X X iw/in 100 min of SD) 5 Offsite Rad Assessment:

l(lncluded in Table 5) 6 Other site specific RP (describe): RP Briefing/ X X X X X Issue Kl 7 Chemistry Function task t#1 (describe) - N/A 8 Chemistry Function task

  1. 2 (describe)- N/A
  • Performance Times are estimated Note: Tasks are as directed by the SM. The only time critical task is job coverage for operators to manipulate valves within 100 minutes of shutdown. TSC and OSC are operational within 60 minutes to provide RP support.

COOPER Page 33

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5- EMERGENCY PLAN IMPLEMENTATION Analysis # 3 Loss of Coolant Accident Line Function / Task On-Shift Position Task Analysis

  1. Controlling Method Emergency Planning Declare the emergency classification level 1 (ECL)

Shift Manager Training Program I EP Drills A.pprove Offsite Protective Action 2

Recommendations N/A NIA Approve content of State/local notifications Shift Manager Emergency Planning 3

!Training Program 4 Approve extension to allowable dose NIA NIA Licensed Operator Notification and direction to on-shift staff  ;[raining Program I 5 (e.g to assemble, evacuate, etc.)

Shift Manager Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program Abbreviated NRC notification for DBT 7

event N/A N/A Complete State/local notification form Emergency Planning 8 Communicator Training Program Perform State/local notifications Emergency Planning 9 Communicator Training Program Non-Licensed Operator 10 !Complete NRC event notification form STE Training Program Emergency Planning 11 !Activate EROS Shift Manager iTraining Program Emergency Planning 12 bffsite radiological assessment Dose Assessor Training Program Emergency Planning 13 Perform N RC notifications Communicator Training Program Perform other site-specific event Licensed Operator 14 notifications (e.g., Duty Plant Manager, Shift Manager

!Training Program INPO, ANI, etc.)

Security Training 15 Personnel Accountability Security Program I EP Drills COOPER Page 34

COOPER ON-SHIFT STAFFING ANALYIS REPORT D. Design Basis Accident Analysis #5 - Fuel Handling Accident.

1. Accident Summary
  • The fuel handling accident is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism, resulting in the dropping of a raised fuel assembly onto the core. The drop causes mechanical damage to the bundle being dropped.
  • The drywell and reactor building are open with ventilation running. All releases to the environment are through the reactor building ventilation.
  • The drop of a fuel bundle in containment over the reactor pressure vessel bounds a drop of a fuel bundle in the reactor building due to the greater drop height.
  • Since Secondary Containment is not assumed to be functioning, the discharge is a ground level, unfiltered release from the ventilation exhaust plenum to the discharge point on the Reactor Building roof. This release point was determined to provide the most limiting dose consequences over other Reactor Building hatches, doors, and airlocks
2. Accident Specific Assumptions Made
  • Onsite personnel will be in accordance with the refuel outage staffing plan that includes additional SROs, ROs, NPOs, RP Techs, and Maintenance.
3. Procedures for Accident Response
  • EOP-5A, EOP Flowchart, Radioactive Release Control
  • 5.1 RAD, Building Radiation Trouble
  • 5. 7 .1 , Emergency Classification
  • 5.7.2, Emergency Director EPIP
  • 5. 7.6, Notification
  • 5.7.16, Release Rate Determination
  • 5.7.17, Dose Assessment
  • 5.7.19, On-site Radiological Monitoring COOPER Page 35

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains the staffing identified in Section II.A, OSA Minimum Staffing CNS TABLE 1 - ON-SHIFT POSITIONS Analysis # 5 Fuel Handling Accident Augmentation Role in Table #

On-shift Unanalyzed TMS Line# E-Plan Reference Elapsed Time /Line#

Position Task? Required?

(min)

T2/L 1 T5/L 1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5.2-1 T5/L6 T5/L 11 TS/L 14 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5.2-1 Shift Technical Emergency Plan 3

Engineer (STE)

N/A T5/L 10 No No Figure 5.2-1 Reactor Operator Emergency Plan 4

1#1 N/A T2/L4 No No Figure 5.2-1 Reactor Operator Emergency Plan 5 N/A T2/L5 No No W2 Figure 5.2-1 Reactor Operator Emergency Plan 6 NIA N/A No No W-3 Figure 5.2-1 Station Operator Emergency Plan 7 N/A T2/L6 No No

  1. 1 Figure 5.2-1 Station Operator Emergency Plan NIA N/A 8 #2 No No Figure 5.2-1 Station Operator Emergency Plan 60 9
  1. 3 Figure 5.2-1 N/A No No T5/L8 Emergency Plan 10 Communicator Figure 5.2-1 60 T5/L9 No No T5/L 13 RP/Chem Tech Emergency Plan 60 11 T4/L3 No No 1#1 Figure 5.2-1 Emergency Plan 60 T5/L 12 12 Dose Assessor Figure 5.2-1 No No Utility Fire Brigade Emergency Plan N/A N/A 13 No No Member #1 Figure 5.2-1 Utility Fire Brigade Emergency Plan N/A N/A 14 No No Figure 5.2-1 Member#2 Security 15 Security Contingency Plan 60 TS/L 15 No No COOPER Page 36

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 5 Fuel Handlina Accident Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role Kln-Shift Position Task Analysis Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program Licensed Operator 2 Unit Supervisor Control Room Supervisor Training Program Shift Technical Engineer Licensed Operator 3 Shift Technical Advisor (STE) Training Program Licensed Operator 4 Reactor Operator #1 Reactor Operator #1 Training_ Program Licensed Operator 5 Reactor Operator #2 Reactor Operator #2 Training Program Non-Licensed Operator 6 ~uxiliary Operator #1 Station Operator #1 Training Program 7 V-\uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A COOPER Page 37

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING ANALYSIS # 5 Fuel Handlina Accident Line Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A FHA does not include a fire.

COOPER Page 38

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 5 Fuel Handlina Accident L Position Performing I Function/ Task Performance Time Period After Emergency Declaration (minutes)*

N E 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 140-45 45-50 50-55 55-60 60-65 65- 70 80-85-90 70 75 80 85 1 In-Plant Survey: N/A 2 !On-site Survey: N/A 3 Personnel Monitoring:

RP/CHEM#1 X X X X X 4 I.Job Coverage: NIA 5 !Offsite Rad Assessment:

11 Table 5) 6 Other site specific RP (describe): N/A 7 Chemistry Function task W1 (describe)

NIA 8 Chemistry Function task

  1. 2 (describe)

NIA

  • Times are estimated.

Note: RP/Chem#1 assists in monitoring and decon of building evacuees. Additional RP on shift for refueling/outage COOPER Page 39

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5-EMERGENCY PLAN IMPLEMENTATION Analysis # 5 Fuel Handlina Accident Function/ Task On-Shift Position Task Analysis Line#

Controlling Method Emergency Planning Declare the emergency classification level 1

(ECL)

Shift Manager If raining Program / EP Drills

~pprove Offsite Protective Action 2

Recommendations NIA NIA Emergency Planning 3 ~pprove content of State/local notifications Shift Manager Ifraining Program 4 Approve extension to allowable dose NIA N/A Licensed Operator 5

Notification and direction to on-shift staff Shift Manager Ifraining Program I (e.g., to assemble, evacuate, etc.} Emergency Planning Ifraining Program Emergency Planning 6 ERO notification Shift Manager Training ProQram 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Emergency Planning Communicator Training Program g Perform State/local notifications Emergency Planning Communicator Training Program Non-Licensed Operator 10 Complete NRC event notification form ~TE Training Program Emergency Planning 11 Activate EROS Shift Manager Training Program Emergency Planning 12 Offsite radiological assessment Dose Assessor Training Prooram Emergency Planning 13 Perform NRC notifications Communicator If raining Program Perform other site-specific event Licensed Operator Train in~

14 notifications (e.g., Duty Plant Manager, Shift Manager Program INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program COOPER Page 40

COOPER ON-SHIFT STAFFING ANALYIS REPORT E. Design Basis Accident Analysis #6 - Main Steam Line Break.

1 Accident Summary

  • This event involves the postulation of a large steam line pipe break outside containment downstream of the outermost isolation valve with a simultaneous loss of offsite power. No fuel damage is calculated to result but the EAB dose assumes coolant 1-131 TS limit of
s; 4 µCi/gm. MS IVs isolate resulting in a steam cloud (puff) to environment within seconds.
2. Accident Specific Assumptions Made
  • Emergency Classification is not required based on the break of the main steam line. This analysis is based on the FSAR MSLB accident dose. Assume the turbine building vent reaches the Alert level for ~ 15 minutes (EAL AA 1.1)
3. Procedures for Accident Response
  • 5.1 RAD, Building Radiation Trouble
  • 5. 7.1, Emergency Classification
  • 5.7.2, Emergency Director EPIP
  • 5. 7 .6, Notifications
  • 5. 7.16, Release Rate Determination
  • 5.7.17, Dose Assessment
  • 5.7.19, On-site Radiological Monitoring COOPER Page 41

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains the staffing identified in Section II.A, OSA Minimum Staffing.

CNS TABLE 1 - ON-SHIFT POSITIONS Analysis # 6 Main Steam Line Break (MSLB}

Augmentation Role in Table Line On-shift Unanalyzed TMS E-Plan Reference Elapsed Time # I Line#

  1. Position Task? Required?

(min)

T2/L1 T5/L 1 Emergency Plan T5/L3 1 Shift Manager 60 T5/L5 No Yes Figure 5.2-1 T5/L6 T5/L 14 T5/L 11 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5.2-1 Shift Technical Emergency Plan T2/L3 3 60 No No Engineer (STE) Figure 5.2-1 T5/L 10 Reactor Operator Emergency Plan 4

  1. 1 Figure 5.2-1 NIA T2/L4 No No Reactor Operator Emergency Plan 5
  1. 2 Figure 5.2-1 N/A T2/L5 No No Reactor Operator Emergency Plan 6
  1. 3 Figure 5.2-1 N/A N/A No No Station Operator Emergency Plan 7
  1. 1 Figure 5.2-1 N/A T2/L6 No No 8

Station Operator Emergency Plan N/A N/A ft.2 No No Figure 5.2-1 9

Station Operator Emergency Plan 60 N/A

  1. 3 No No FiQure 5.2-1 T5/L8 Emergency Plan 10 Communicator Figure 5.2-1 60 T5/L9 No No T5/L 13 11 RP/Chem Tech Emergency Plan 60 T4/L 1
  1. 1 No No Figure 5.2-1 12 Dose Assessor Emergency Plan 60 T5/L 12 No No Fioure 5.2-1 Utility Fire Emergency Plan 13 Brigade Member Figure 5.2-1 N/A N/A No No
  1. 1 Utility Fire 14 Brigade Member Emergency Plan N/A N/A No No Figure 5.2-1
  1. 2 Security Contingency 15 Security 60 T5/L 15 No No Plan COOPER Page 42

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2- PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 6 Main Steam Line Break (MSLB)

Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program Licensed Operator 2 Unit Supervisor Control Room Supervisor Training Program Shift Technical Engineer Licensed Operator 3 Shift Technical Advisor (STE) Training Program Licensed Operator 4 Reactor Operator #1 Reactor Operator #1 Training Program Licensed Operator 5 Reactor Operator #2 Reactor Operator #2 Training Program Non-Licensed Operator 6 Auxiliary Operator #1 Station Operator #1 Training Program 7 Auxiliary Operator #2 NIA N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations} Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other NIA N/A 15 Other N/A N/A COOPER Page 43

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING ANALYSIS # 6 Main Steam Line Break lSLBl Line Performed by Task Analysis Controlling Method 1 NIA N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The MSLB analysis does not include a fire.

COOPER Page 44

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4-RADIATION PROTECTION AND CHEMISTRY Analysis # 6 Main Steam Line Break (MSLB)

Line# 0 osition Performing Performance Time Period After Emergency Declaration (minutes}*

Function/ Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 ~0-65 65- 70 80-85-90 70 75 80 85 1 In-Plant Survey:

RP/Chem#1 Turb. X X X X X X X X X Bldg 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Uob Coverage: N/A 5 IOffsite Rad Assessment:

(Included in Table 5 6 !Other site specific RP

  • ~describe): N/A 7 Chemistry Function task t#1 (describe) N/A 8 Chemistry Function task
  1. 2 (describe) N/A
  • Performance times are estimated.

COOPER Page 45

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5-EMERGENCY PLAN IMPLEMENTATION Analysis # 6 Main Steam Line Break ,MSLB)

Line Function I Task On-Shift Position Task Analysis Controlling

  1. Method Emergency Planning Declare the emergency classification level 1 Shift Manager !Training Program I EP (ECL)

Drills Approve Offsite Protective Action 2 N/A N/A Recommendations Emergency Planning 3 Approve content of State/local notifications Shift Manager

!Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Notification and direction to on-shift staff Training Program I 5 Shift Manager

e.g., to assemble, evacuate, etc.) Emergency Planning Training Program 6 Emergency Planning ERO notification Shift Manager Ifraining Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Communicator Training Program 9 Emergency Planning Perform State/local notifications Communicator

!Training Program Licensed Operator Trainin~

10 Complete NRC event notification form STE Program Emergency Planning 11 Activate EROS Shift Manager Ifraining Program 12 Offsite radiological assessment Emergency Planning Dose Assessor Training Program 13 Perform NRC notifications Emergency Planning Communicator Training Program Perform other site-specific event notifications Licensed Operator Trainin~

14 Shift Manager (e.g., Duty Plant Manager, INPO, ANI, etc.) Program 15 Personnel Accountability NIA N/A COOPER Page 46

COOPER ON-SHIFT STAFFING ANALYIS REPORT F. Design Basis Accident Analysis #7 -Aircraft Probable Threat

1. Accident Summary
  • The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 minutes, but less than 30 minutes from the site, and considers the dispersal of the site fire brigade away from target areas for firefighting.
  • The analysis does not include a scenario or response actions taken during or after a crash.
2. Accident Specific Assumptions Made
  • The Shift Manager receives the call from the NRC of probable aircraft threat.
  • All non-security on-shift personnel are inside the protected area fence at their normal workstation.
3. Procedures for Accident Response
  • 5.5AIRCRAFT, Aircraft Threat COOPER Page 47

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains the staffing identified in Section II.A, OSA Minimum Staffing.

CNS TABLE 1 - ON-SHIFT POSITIONS Analysis #7 - Aircraft Probable Threat Line Augmentation Role in Table #

On-shift Position E-Plan Reference Unanalyzed TMS Elapsed Time /Line#

(min) Task? Required?

T2/L 1 T5/L 1 Emergency Plan T5/L3 1 Shift Manager 60 No Yes Figure 5.2-1 TS/LS TS/L6 T5/L 14 Control Room Emergency Plan T2/L2 2

Supervisor Figure 5.2-1 N/A No No T5/L 11 Shift Technical Emergency Plan T2/L3 3 60 No No Engineer (STE) Figure 5.2-1 T5/L 10 Reactor Operator Emergency Plan 4

1#1 Figure 5.2-1 N/A T2/L4 No No Reactor Operator Emergency Plan 5

1#2 Figure 5.2-1 N/A T2/L5 No No Reactor Operator Emergency Plan 6

  1. 3 Figure 5.2-1 N/A T3/L1 No No Station Operator Emergency Plan 7

Figure 5.2-1 N/A T2L6 No No

  1. 1 Station Operator Emergency Plan N/A 8 T3/L2 No No
  1. 2 Figure 5.2-1 Station Operator Emergency Plan 60 T3/L3 9 No No
  1. 3 Figure 5.2-1 Emergency Plan T5/L8 10 Communicator 60 T5/L9 No No Figure 5.2-1 T5/L 13 Emergency Plan 60 11 RP/Chem Tech #1 NIA No No Figure 5.2-1 Emergency Plan 60 12 Dose Assessor N/A No No Figure 5.2-1 Utility Fire Brigade Emergency Plan 13 NIA T3/L4 No No Member #1 FiQure 5.2-1 Util 1ty Fire Brigade Emergency Plan 14 Member#2 N/A T3/L5 No No Figure 5.2-1 Security 15 Security 60 N/A No No Continqency Plan COOPER Page 48

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 7 - Aircraft Probable Threat Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program Licensed Operator 2 Unit Supervisor Control Room Supervisor

!Training Program Shift Technical Engineer Licensed Operator training 3 Shift Technical Advisor (STE) Program Licensed Operator 4 Reactor Operator #1 Reactor Operator #1

!Training Program Licensed Operator 5 Reactor Operator #2 Reactor Operator #2

!Training Program Non-Licensed Operator 6 Auxiliary Operator #1 Station Operator #1

!Training Program 7 Auxiliary Operator #2 NIA N/A a Other needed for Safe Shutdown N/A NIA 9 other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A COOPER Page 49

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING ANALYSIS #7 Aircraft Probable Threat Line Performed by Task Analysis Controlling Method 1 Reactor Operator #3 Fire Brigade Training 2 Station Operator #2 Fire Brigade Training 3 Station Operator #3 Fire Brigade Training 4 Utility Worker #1 Fire Brigade Training 5 Utility Worker #2 Fire Brigade Training FB relocates to outside the footprint.

COOPER Page 50

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4- RADIATION PROTECTION AND CHEMISTRY Analysis #7 - Aircraft Probable Threat L Position Performing I Function/ Task Performance Time Period After Emergency Declaration (minutes)*

N E 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65- 70 80-85-90 70 75 80 85 1 In-Plant Survey:

N/A 2 On-site Survey: N/A 3 Personnel Monitoring: NIA 4 Job Coverage: N/A 5 IOffsite Rad Assessment:

lflncluded in Table 5 6 Other site specific RP

describe): N/A 7 K:;hemistry Function task 1#1 (describe) N/A 8 Chemistry Function task
  1. 2 (describe) NIA RP/ Chemistry Tech goes with FB to location outside the footprint as directed by the SM.

COOPER Page 51

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5-EMERGENCY PLAN IMPLEMENTATION Analysis #7 - Aircraft Probable Threat Line Function / Task On-Shift Position Task Analysis Controlling

  1. Method Declare the emergency classification level Emergency Planning 1 Shift Manager (ECL) Training Program I EP Drills Approve Offsite Protective Action 2

Recommendations N/A N/A Emergency Planning 3 Approve content of State/local notifications Shift Manager Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Notification and direction to on-shift staff (e.g.,

5 Shift Manager Program I Emergency to assemble, evacuate, etc.)

Planning Training Program Emergency Planning 6 ERO notification !Shift Manager il"raining Program 7 Abbreviated NRC notification for DBT event N/A NIA Emergency Planning 8 Complete State/local notification form Communicator il"raining Program Emergency Planning 9 Perform State/local notifications Communicator

[Training Program Non-Licensed Operator 10 Complete NRC event notification form STE

[Training Program Emergency Planning 11 Activate EROS CRS il"raining Program 12 Offsite radiological assessment N/A N/A Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications Licensed Operator Training 14 $hift Manager (e.g., Duty Plant Manager, INPO, ANI, etc.) Program 15 Personnel Accountability N/A N/A COOPER Page 52

COOPER ON-SHIFT STAFFING ANALYIS REPORT G. Design Basis Accident Analysis #8 - Control Room Evacuation and Shutdown

1. Accident Summary
  • Fire in the Main Control that requires control room evacuation.
  • If the nuclear system becomes isolated from the main condenser, decay heat is transferred from the reactor to the suppression pool via the relief valves. The incident detection circuitry initiates operation of the RCIC and HPCI systems on low water level which maintains reactor vessel water level, and the RHR suppression pool cooling mode is used to remove the decay heat from the suppression pool if required. When reactor pressure falls below 100 psig level, the RHR shutdown cooling mode is started.
2. Accident Specific Assumptions Made
  • The ATC operator will perform the immediate actions of the procedure to initiate a manual scram and verify all rods in before evacuating the control room.
  • Subsequent actions are performed form outside the control room.
3. Procedures for Accident Response
  • 5.1 INCIDENT, Site Emergency Incident
  • 5.4FIRE-S/D, Fire Induced Shutdown from Outside Control Room
  • 5.7.1, Emergency Classification
  • 5.7.2, Emergency Director EPIP
  • 5. 7 .6, Notification
  • 5.4POST-F IRE-CONTROL COOPER Page 53

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables N0 te T a bl e 1 contains th e staffmg 'd I en t'fi 11e d .In Sect1on IIA ' OSAM'.

inImum staffi ng CNS TABLE 1 - ON-SHIFT POSITIONS Analysis #8 - CR Evacuation & Alternate SD Augmentation Role in Table#

Line Unanalyzed TMS On-shift Position E-Plan Reference Elapsed Time /Line#

  1. Task? Required?

(min)

T2/L 1 T5/L 1 T5/L3 1 Shift Manager Emergency Plan 60 T5/L5 No Yes Figure 5.2-1 T5/L6 T5/L11 TS/L 14 Control Room Emergency Plan 2

Supervisor N/A T2/L2 No No Figure 5.2-1 Shift Technical Emergency Plan T2/L3 3

Engineer (STE) Figure 5.2-1 60 No Yes T5/L 10 Reactor Operator Emergency Plan 4

  1. 1 Figure 5.2-1 N/A T2/L4 No No Reactor Operator Emergency Plan 5 N/A T2/L5 No No
  1. 2 Figure 5.2-1 Reactor Operator Emergency Plan 6 Figure 5.2-1 N/A T3/L1 No No
  1. 3 Station Operator Emergency Plan 7 N/A T2/L6 No No
  1. 1 Figure 5.2-1 Station Operator Emergency Plan N/A 8 T3/L2 No No W-2 Figure 5.2-1 Station Operator Emergency Plan 60 T3/L3 9 No No W3 Figure 5.2-1 T5/L8 Emergency Plan 10 Communicator 60 T5/L9 No No Figure 5.2-1 T5/L 13 Emergency Plan T4/L4 11 RP/Chem Tech #1 60 No Figure 5.2-1 No Emergency Plan N/A 12 Dose Assessor 60 No No Figure 5.2-1 Utility Fire Brigade Emergency Plan 13 T3/L4 Member #1 FiQure 5.2-1 N/A No No Utility Fire Brigade Emergency Plan 14 N/A T3/L5 No No Member#2 Figure 5.2-1 Security 15 Security 60 T5/L 15 No No Contingency Plan COOPER Page 54

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 8 - CR Evacuation & Alternate SD Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 1 Licensed Operator Shlft Manager Shift Manager Training Program 2 Licensed Operator Unit Supervisor Control Room Supervisor rrraining Program 3 Shift Technical Engineer Licensed Operator Shift Technical Advisor (STE) Training Program 4 Licensed Operator Reactor Operator #1 Reactor Operator #1 rrraining Program 5 Licensed Operator Reactor Operator #2 Reactor Operator #2 rrraining Program 6 Non-Licensed Operator Auxiliary Operator #1 Station Operator # 1 rrraining Program 7 Auxiliary Operator #2 NIA N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A NIA 12 Electrician NIA N/A 13 l&C Technician NIA NIA 14 Other N/A N/A 15 Other NIA N/A COOPER Page 55

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING ANALYSIS # 8 - CR Evacuation & Alternate SD Line Performed by Task Analysis Controlling Method 1 Reactor Operator #3 Fire Brigade Training 2 Station Operator #2 Fire Brigade Training 3 Station Operator #3 Fire Brigade Training 4 Utility Worker #1 Fire Brigade Training 5 Utility Worker #2 Fire Brigade Training COOPER Page 56

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4- RADIATION PROTECTION AND CHEMISTRY Analysis #8-CR Evacuation & Alternate SD L Position Performing I Performance Time Period After Emergency Declaration (minutes)*

Function/ Task N

E 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 140-45 45-50 50-55 55-60 60-65 65 75 85-90 70 75 80 85 1 In-Plant Survey:

RP#2 2 !On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Uob Coverage:

RP/Chem#1 Support FB X X X X X X X X X X X X X X X X X 5 IOffsite Rad Assessment:

IOncluded in Table 5 6 !Other site specific RP (describe): N/A 7 Chemistry Function task 1#1 (describe) N/A 8 Chemistry Function task t;/-2 (describe) N/A COOPER Page 57

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5- EMERGENCY PLAN IMPLEMENTATION Analysis #8 - CR Evacuation & Alternate SD Line Function / Task On-Shift Position Task Analysis Controlling

  1. Method Emergency Planning Declare the emergency classification level 1 Shift Manager rrraining Program/ EP (ECL)

Drills Approve Offsite Protective Action 2

Recommendations N/A N/A Emergency Planning 3 Approve content of State/local notifications Shift Manager Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Notification and direction to on-shift staff (e.g.,

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

Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Communicator Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Licensed Operator Training Complete NRC event notification form Communicator Program Emergency Planning 11 Activate EROS Shift Manager Training Program 12 Offsite radiological assessment NIA N/A Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications Licensed Operator Training 14 Shift Manager

,e.g., Duty Plant Manager, INPO, ANI, etc.) Program 15 Personnel Accountability N/A N/A COOPER Page 58

COOPER ON-SHIFT STAFFING ANALYIS REPORT H. Accident Analysis #9 - Station Blackout

1. Accident Summary
  • At power, normal lineups and no additional events
2. Accident Specific Assumptions Made
  • Assume the Shift Manager recognizes power cannot be restored within 15 minutes after the loss before the 15 minute SBO EAL period has expired.
3. Procedures for Accident Response
  • 5.3SBO, Station Blackout
  • 2.4FPC, Fuel Pool Cooling Trouble
  • 5.3ALT-STRATEGY, Alternate Core Cooling Mitigating Strategies
  • 2.2.99, Supplemental Diesel Generator System
  • 2.2.100, SAMG Diesel Generator System
  • 5.7.1, Emergency Classification
  • 5.7.2, Emergency Director EPIP
  • 5. 7.6, Notification
  • 5.7.10, Personnel Assembly and Accountability COOPER Page 59

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains the staffing identified in Section II.A, OSA Minimum Staffing.

CNS TABLE 1 - ON-SHIFT POSITIONS Analysis #9 - Station Blackout Augmentation Role in Table Unanalyzed TMS Line On-shift Position Basis Document Elapsed Time 5 /Line# Task? Required?

(min)

T2/L 1 T5/L 1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5.2-1 T5/L6 TS/L 11 T5/L 14 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5.2-1 Shift Technical Emergency Plan T2/L3 3

Engineer (STE) Figure 5.2-1 60 No No T5/L10 Reactor Operator Emergency Plan 4

  1. 1 Figure 5.2-1 N/A T2/L4 No No Reactor Operator Emergency Plan 5 N/A T2/L5 No No r#2 Figure 5.2-1 Reactor Operator Emergency Plan 6
  1. 3 Figure 5.2-1 N/A N/A No No Emergency Plan 7 Station Operator #1 N/A T2/L6 No No Figure 5.2-1 Emergency Plan 8 Station Operator #2 N/A N/A No No Figure 5.2-1 Emergency Plan N/A 9 Station Operator #3 60 No No Figure 5.2-1 T5/L8 Emergency Plan 10 Communicator Figure 5.2-1 60 T5/L9 No No TS/L 13 Emergency Plan 11 RP/Chem Tech #1 60 N/A No No Figure 5.2-1 Emergency Plan 12 Dose Assessor 60 N/A No No Figure 5.2-1 Utility Fire Brigade Emergency Plan 13 N/A N/A No No Member #1 Figure 5.2-1 Utility Fire Brigade Emergency Plan 14 N/A NIA No No Member#2 Figure 5.2-1 Security 15 Security !Contingency 60 T5/L 15 No No Plan COOPER Page 60

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #9 - Station Blackout Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method Licensed Operator 1 Shift Manager Shift Manager rrraining Program Licensed Operator 2 Unit Supervisor Control Room Supervisor rrraining Program Shift Technical Licensed Operator 3 Shift Technical Advisor Engineer (STE) rrraining Program Licensed Operator 4 Reactor Operator #1 Reactor Operator #1 Training Program Licensed Operator 5 Reactor Operator #2 Reactor Operator #2 rrraining Program Non-Licensed Operator 6 ~uxiliary Operator #1 Station Operator #1 [f raining Program 7 ~uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A NIA 9 Other needed for Safe Shutdown NIA NIA 10 Other needed for Safe Shutdown NIA N/A Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# ~eneric Title/Role On-Shift Position !Task Analysis Controlling Method 11 Mechanic NIA NIA 12 Electrician NIA N/A 13 l&C Technician N/A N/A 14 Other NIA N/A 15 Other N/A NIA COOPER Page 61

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING Analysis #9 - Station Blackout Line Performed by Task Analysis Controlling Method 1 NIA NIA 2 NIA N/A 3 NIA NIA 4 N/A N/A 5 NIA NIA The Station Blackout Analysis does not include the need for firefighting COOPER Page 62

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #9 - Station Blackout L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function/ Task N 70 E 0-5 5-10 10-15 15-20 20-25 .25-30 30-35 35-40 ~0-45 ~5-50 50-55 55-60 60-65 65- 80-85-90 70 75 80 85 1 In-Plant Survey: NIA 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 !Job Coverage: N/A 5 Offsite Rad Assessment:

IOncluded in Table 5 - NIA 6 Other site specific RP :

N/A 7 Chemistry Function task t#1: N/A 8 !Chemistry Function task f#-2 (describe) - N/A RP/Chemistry Tech does not have an assigned task for SBO.

COOPER Page 63

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5- EMERGENCY PLAN IMPLEMENTATION Analysis #9 -Station Blackout Line Function / Task* On-Shift Position Task Analysis Controlling

  1. Method Emergency Planning Declare the emergency classification level 1 Shift Manager Training Program / EP (ECL)

Drills lApprove Offsite Protective Action 2 NIA NIA Recommendations 3 Approve content of State/local notifications Emergency Planning Shift Manager iTraining Program 4 Approve extension to allowable dose NIA N/A licensed Operator Notification and direction to on-shift staff rrraining Program I 5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program 6 ERO notification Emergency Planning Shift Manager iTraining Program 7 Abbreviated NRC notification for DBT event NIA N/A 8 Complete State/local notification form Emergency Planning Communicator rrraining Program 9 Perform State/local notifications Emergency Planning Communicator iTraining Program Licensed Operator 10 Complete NRC event notification form STE rrraining Program Activate EROS Emergency Planning 11 Shift Manager iTraining Program 12 Offsite radiological assessment NIA N/A Perform NRG notifications Emergency Planning 13 Communicator iTraining Program Perform other site-specific event notifications Licensed Operator 14 Shift Manager (e.g., Duty Plant Manager, INPO, ANI, etc.) ifraining Program 15 Personnel Accountability Security Security Training Program COOPER Page 64

COOPER ON-SHIFT STAFFING ANALYIS REPORT I. Accident Analysis #1 O - LOCA/General Emergency with Release and PAR

1. Accident Summary (Assumed for Staffing Analysis Purpose)
  • The unit is in a Site Area Emergency AS1 when the Shift Manager is given a dose assessment update that projects >1 Rem TEDE dose at the site boundary.
2. Accident Specific Assumptions Made
  • All actions for SAE are complete.
  • The ERO would be activated at an Alert or SAE. For Staffing Analysis purpose, the T=O clock is used for the emergency plan actions to evaluate the capability to implement the GE classification, PAR and notification functions before the ERO arrives.
3. Procedures for Accident Response
  • 5.7.1, Emergency Classification
  • 5.7.2, Emergency Director EPIP
  • 5.7.6, Notification
  • 5.7.16, Release Rate Determination
  • 5. 7 .17, Dose Assessment
  • 5.7.20, Protective Action Recommendation COOPER Page 65

COOPER ON-SHIFT STAFFING ANALYIS REPORT

4. Tables Note: Table 1 contains the staffing identified in Section II.A, OSA Minimum Staffing.

CNS TABLE 1 - ON-SHIFT POSITIONS Analysis #10-LOCA/GE with PAR Line Augmentation Role in Table Unanalyzed TMS On-shift Position Basis Document Elapsed Time 5 I Line# Task? Required?

{min)

T2/L 1 T5/L 1 T5/L2 Emergency Plan 1 Shift Manager 60 T5/L3 No Yes Figure 5.2-1 T5/L4 T5/L5 T5/L 14 Control Room Emergency Plan 2

Supervisor Figure 5.2-1 N/A T2IL2 No No Shift Technical Emergency Plan T2/L3 3 60 No No Engineer (STE) Figure 5.2-1 T5IL 10 Emergency Plan 4 Reactor Operator #1 figure 5.2-1 N/A T2/L4 No No Emergency Plan 5 Reactor Operator #2 Figure 5.2-1 NIA T2IL5 No No Emergency Plan 6 Reactor Operator #3 Figure 5.2-1 N/A NIA No No Emergency Plan 7 Station Operator #1 Figure 5.2-1 N/A T2/L6 No No Emergency Plan N/A N/A 8 Station Operator #2 No No Figure 5.2-1 g Emergency Plan 60 Station Operator #3 N/A No No Figure 5.2-1 T5/L8 Emergency Plan 10 Communicator 60 T5/L9 No No Figure 5.2-1 T5/L 13 Emergency Plan 11 RP/Chem Tech #1 Figure 5.2-1 60 N/A No No Emergency Plan 60 T5/L 12 12 Dose Assessor No No Figure 5.2-1 Utility Fire Brigade Emergency Plan 13 Member #1 N/A N/A No No Figure 5.2-1 Utility Fire Brigade Emergency Plan 14 N/A NIA No No Member#2 Figure 5.2-1 Security 15 Security 60 T5IL 15 No No Contingency Plan COOPER Page 66

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #10-LOCA/GE with PAR Minimum Operations Crew Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position rrask Analysis Controlling Method Licensed Operator 1 Shift Manager Shift Manager il"raining Program Licensed Operator 2 Unit Supervisor Control Room Supervisor

!Training Program Shift Technical Engineer Licensed Operator 3 Shift Technical Advisor (STE) rrraining Program Licensed Operator 4 Reactor Operator #1 Reactor Operator #1

!Training Program Licensed Operator 5 Reactor Operator #2 Reactor Operator #2

!Training Program Non-Licensed Operator 6 Auxiliary Operator #1 Station Operator # 1 Ifraining Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A NIA 9 Other needed for Safe Shutdown N/A NIA 10 Other needed for Safe Shutdown NIA NIA Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line# Generic Title/Role On-Shift Position Task Analysis Controlling Method 11 Mechanic NIA NIA 12 Electrician N/A N/A 13 l&C Technician N/A NIA 14 Other N/A N/A 15 Other N/A N/A COOPER Page 67

COOPER ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade CNS TABLE 3 - FIREFIGHTING Analysis #10 - LOCA/GE with PAR Line Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A NIA N/A 3 N/A N/A 4 NIA N/A 5 N/A Note: The LOCA/GE with PAR Analysis does not include the need for firefighting.

COOPER Page 68

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 4- RADIATION PROTECTION AND CHEMISTRY Analysis #10 - LOCA/GE with PAR L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function/ Task N 70-E 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65- 75 85-90 70 75 80 85 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: N/A 5 Offsite Rad Assessment:

{Included in Table 5 NIA 6 Other site specific RP

describe): N/A 7 Chemistry Function task
  1. 1 {describe) - N/A 8 Chemistry Function task
  1. 2 (describe) - N/A
  • Times are estimated. Note: The Dose Assessor is available for dose assessment COOPER Page 69

COOPER ON-SHIFT STAFFING ANALYIS REPORT CNS TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #10-LOCA/GE with PAR Line Function/ Task* On-Shift Position Task Analysis

  1. Controlling Method Declare the emergency classification level Emergency Planning 1 Shift Manager Training Program / EP
EGL)

Drills Approve Offsite Protective Action Emergency Planning 2 Shift Manager Recommendations Training Program 3 Approve content of State/local notifications Emergency Planning Shift Manager Training Program 4 Approve extension to allowable dose Emergency Planning Shift Manager Training Program Licensed Operator Notification and direction to on-shift staff Training Program /

5 Shift Manager e.g., to assemble, evacuate, etc.) Emergency Planning Training Program 6 ERO notification N/A N/A 7 Abbreviated NRG notification for DBT event NIA N/A 8 Complete State/local notification form Emergency Planning Communicator Training Program Perform State/local notifications Emergency Planning 9 Communicator Training Program Complete NRG event notification form Licensed Operator 10 STE Training Program 11 Activate EROS N/A N/A Emergency Planning 12 Offsite radiological assessment Dose Assessor Training Program Perform NRC notifications Emergency Planning 13 Communicator Training Program Perform other site-specific event notifications Licensed Operator 14 e.g., Duty Plant Manager, INPO, ANI, etc.) Shift Manager Training Program 15 Personnel Accountability NIA NIA COOPER Page 70

COOPER ON-SHIFT STAFFING ANALYIS REPORT VIII, APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS A. TMS Shift Manager Activate Automated Notification System (ANS)

COOPER TIME MOTION STUDY OF OVERLAPPING TASKS TASK 1: ACTIVATE THE ERO USING ANS JOB: SHIFT MANAGER TASK 2: PERFORM EMERGENCY DIRECTION AND CONTROL JOB: SHIFT MANAGER COOPER Page 71

COOPER ON-SHIFT STAFFING ANALYIS REPORT PURPOSE:

Perform a Time Motion Study to evaluate whether assigning the performance of ERO notification using the ANS to the Shift Manager is an acceptable task overlap to the Shift Manager's primary emergency plan function of emergency direction and control.

NOTE The Time Motion Study may be completed during simulator training/evaluation or during an EP drill while the Shift Manager is performing the Emergency Director function.

LOCATION:

Simulator REQUIRED TOOLS/EQUIPMENT:

A. Telephone with ANS Activation Module B. Procedure 5.7.2 Attachment 1 Activation of ANS-Hardcard C. Simulator ANS Communication Cross-Tie is in OFF or not cross-tied .

COOPER Page 72

COOPER ON-SHIFT STAFFING ANALYIS REPORT APPENDIX D (NEI 10-05)

Function/ Responsibility (Task) Analysis Template Event: Site: CNS Position: Shift Manaaer Line#: 1 Function Responsibility (Task) Action Step Duration Clock/Step Time In 1.Notification 1.1 Initiate notification to the CAUTION:

ERO via the Alert and The Simulator Communication Cross- tie for Notification System (ANS) ANS must be OFF to prevent inadvertent activation of the ERO. +5/5 sec 1.1.1 Retrieve the Activation of ANS Hardcard instruction.

1.1.2 At the ANS ACTIVATION MODULE, pick up handset +10/5 sec and verify dial tone.

1.1.3

+26/16 sec Depress desired scenario pushbutton.

1.1.4

+38/12 sec Wait until system says "Goodbye" then hang up.

1.1.5 When ANS activates within 3 minutes, then STOP 1:19 / 41 sec END OF ERO NOTIFICATION TASK 1 min 19 sec TOTAL TASK DURATION:

Function Responsibility (Task) Duration Action Step 2.Emergency 2.1 Maintain emergency 1 . Oversight of the emergency response. 41 sec Direction and direction and control of the Control event response.

2. Initiate any emergency actions. 48 sec NOTE:

The TMS is for overlap period. The total time considered for this task should be concurrent with Task 1.

END OF EMERGENCY DIRECTION AND CONTROL TASK 1 min 29 sec TOTAL TASK DURATION RESULT:

COOPER Page 73

COOPER ON-SHIFT STAFFING ANALYIS REPORT Explain why it is acceptable or not acceptable for the Shift Manager to perform the task of notifying the ERO:

The process of activating the ERO takes 38 seconds to perform the actions required followed by 41 seconds of monitoring the Shift Manager telephone to verify that it activated. Activating the ERO is covered by 2.1-2 to initiate any emergency actions. Per the Shift Manager, more time would be expended directing someone to activate the ERO with code 222 than it would to just do it. This task is very short in duration and the shift manager is able to stay apprised of plant conditions while doing it.

The Shift Manager used proper place-keeping techniques while performing this task.

_,,,,~*=*,,.,~,<*m,N"""Y""" NW;c,.WCll ;,-, h',Y*NN~*>,;,,.-;,c<<< ,.,;,,-;,,w <WN>)'.',,,.-N,W,-,;m,>,;,Y/W*1/4""h" ~,-,,,,....,.y,...,._,.,,.,,,.;, _,,--,,.,,-

1 NAME POSITION I DATE Task Performer Assistant Operations Ron Shaw Nov. 3, 2012 Manager Evaluator Emergency Preparedness Tim Rients Nov. 3, 2012 Coordinator Validation of Updated Timeline for Section 1.1 Task Performer Simulator & Training Support Jim Florence Mar. 25, 2021 Superintendent

""'"m'""'-~'""""'w,-,,we*---*=*--m=N.,-,,N<s*~,, '"'<",,.YC-W,n, Evaluator Emergency Preparedness Tina Haynes Mar. 25, 2021 Coordinator COOPER Page 74

COOPER ON-SHIFT STAFFING ANALYIS REPORT IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures None X. REFERENCES

  • NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities
  • NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants
  • NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.
  • Fred Guynn, Entergy ECH Sr Project Manager, EP
  • Myra Jones, CMCG Contractor
  • Dave Werner, CNS Training
  • John Teten, CNS Chemistry
  • - Kip Reeves, CNS Emergency Planning
  • Ron Shaw, CNS Operations
  • Tim Rients, CNS Emergency Planning
  • Mark Uhri, CNS Chemistry
  • Greg Brewer, CNS Training COOPER Page 75
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