Text

Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 1 Staffing Assessment
	ML13123A028
Person / Time
Site:	South Texas
Issue date:	04/25/2013
From:	Rencurrel D; South Texas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NOC-AE-13002989
	Download: ML13123A028 (52)
	v • d • e

Nuclear Operating Company South Texas Pro/ed Electric GeneratingStation PO. Box 289 Wadsworth, Texas 77483 -vv - - --

April 25, 2013 NOC-AE-13002989 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Request for Information Pursuant to 10 CFR 50.54(f)

Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 1 Staffing Assessment

References:

1. Letter, Eric Leeds to E. D. Halpin, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," dated March 12, 2012 (ML12053A340)

2. Letter, D.W. Rencurrel to NRC, "60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated May 9, 2012 (ML12136A472)

3. Letter, D.W. Rencurrel to NRC, "Revised 60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated June 4, 2012 (ML12163A344)

4. Letter from D. W. Rencurrel to NRC, "90-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident, dated June 4, 2012 (ML12163A331)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1. of Reference 1 contained specific Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness programs. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f),

addressees were requested to submit a written response to the information requests.

In accordance with Reference 1, STP Nuclear Operating Company (STPNOC) submitted an alternative course of action for providing the requested information in Reference 2 STI 33680282

NOC-AE-1 3002989 Page 2 of 3 which was revised by Reference 3. As described in our alternative course of action (Reference 2 and 3), Enclosure 1 to this letter transmits STPNOC's Phase 1 Staffing Assessment Report. A summary of the Requested Information Items in References 2 and 3 and the conclusions from the staffing assessment, including an implementation schedule are provided in Enclosure 2.

The only commitments in this letter are summarized in Enclosure 3.

Note: The enclosed list of commitments also includes a revision to the estimated due date associated with the completion of the Phase 2 Staffing Assessment. See for details.

If there are any questions regarding this letter, please contact Robyn Savage at (361) 972-7438.

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

Executed on:

Enclosures:

1. STP Phase 1 Extended Loss of All AC Power (ELAP) ERO Staffing Analysis Report

2. Summary of Requested Items and Actions Planned for the Phase 1 Staffing Assessment

3. List of Commitments rds

NOC-AE-13002989 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Arlington, TX 76011-4511 Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal John Ragan Senior Project Manager Chris O'Hara U.S. Nuclear Regulatory Commission Jim von Suskil One White Flint North (MS 8 B13) NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio NRC Resident Inspector Richard Pena U. S. Nuclear Regulatory Commission City Public Service P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady Peter Nemeth City of Austin Crain Caton & James, P.C.

Electric Utility Department 721 Barton Springs Road C. Mele Austin, TX 78704 City of Austin Eric Leeds Richard A. Ratliff Director, Office of Nuclear Reactor Regulation Texas Department of State Health U.S. Nuclear Regulatory Commission Services One White Flint North (MS 13 H 16) 11555 Rockville Pike Alice Rogers Rockville, MD 20852 Texas Department of State Health Services RMS

Enclosure 1 NOC-AE-13002989 Enclosure 1 South Texas Project (STP)

Phase 1 Extended Loss of All AC Power (ELAP)

ERO Staffing Analysis Report

Enclosure 1 NOC-AE-I 3002989 Nucleal Op~etfrVf Con~any Clean. Safe. Reliable.

i1 South Texas Project Phase 1 Extended Loss of All AC Power (ELAP) ERO Staffing Analysis Report Revision 0

Enclosure 1 NOC-AE-1 3002989 Page 2 of 42 TABLE OF CONTENTS I INTRODUCTION 5 2 PHASE 1 STAFFING ANALYSIS

SUMMARY

6 2.1 Task Analysis Results 6 2.1.1 Non-Validated Task Assessment 6 2.1.2 Potential Task Overlap Assessment 6 2.2 Time Motion Study (TMS) Results 6 2.3 Augmented and Expanded ERO Assessment Results 7 3 ON-SHIFT STAFFING COMPLEMENT 8 3.1 Shift Staffing Basis 8 3.2 Initial Shift Staffing Locations 9 4 EXTENDED LOSS OF ALL AC POWER (ELAP) 10 4.1 Scope 10 4.2 Assumptions 10 4.3 Event Description and Initial Conditions 11 4.4 Procedures Used in the Event 12 4.4.1 List of Procedures Applicable to a Loss of All AC Power and Emergency Plan Implementation 12 4.4.2 Procedure Changes Due to IER Responses Applicable to Phase 1 12 5 AUGMENTED AND EXPANDED ERO RESPONSE ANALYSIS 14 5.1 ERO Notification and Response during an ELAP 14 5.1.1 General ERO Response 16 5.1.2 Position Specific ERO Response 19 5.2 Expanded Response Functions for Phase 1 Staffing Assessment 21 6 LIST OF IMPROVEMENT ACTIONS IDENTIFIED DURING THE PHASE 1 ASSESSMENT 24 7 LIST OF REFERENCES 25 : NEI 10-05 Table 5 Controlling Method Correlation ......................................... 27 : NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables ................. 29 : NEI 10-05 Appendix D & E On-Shift Staffing Analysis Results Tables ............ 35 Page 2

Enclosure I NOC-AE-13002989 Page 3 of 42 GLOSSARY Alternate Response Alternate TSC/OSC, located in the EOF in Bay City, Texas. Used in the event of a Facility declared emergency when access to the site is restricted.

ANI American Nuclear Insurers Personnel mobilized to assist the on-shift staff in responding to more serious events and accidents. Augmented ERO personnel are capable of performing a Augmented ERO wide range of functions necessary for responding to a radiological emergency, up to and including a severe accident involving fuel damage. This group of people is normally offsite and split into teams.

BYP Bypass CAP Corrective Action Program CR Control Room CVCS Chemical Volume Control System DC Direct current DP Differential pressure EAB Electrical Auxiliary Building EAL Emergency Action Level ECL Emergency Classification Level EDG Emergency Diesel Generator EDMG Extensive Damage Mitigation Guidelines ELAP Extended Loss of all AC Power Emergency Document developed by Matagorda County that supports the STP Emergency Management Plan Plan and the State of Texas Emergency Management Plan Emergency Notification System - used to provide operational and health physics ENS information to the Nuclear Regulatory Commission Operations Center during the early phase of an emergency.

EOC Emergency Operations Center EOF Emergency Operations Facility ERDS Emergency Response Data System ERF Emergency Response Facility (e.g. TSC, OSC, EOF)

ERO Emergency Response Organization - consists of those site personnel trained and qualified to respond to any accident within the scope of the plant design basis ESF Engineered Safety Feature Additional personnel who expand the capability of the augmented ERO to facilitate timely and effective performance of critical emergency response Expanded ERO functions - a typical augmented ERO for a multi-unit site would be challenged to effectively respond to a beyond design basis external event that resulted in an extended loss of AC power affecting more than one unit.

FBT Fire Brigade Team FLEX Diverse and Flexible Coping Strategies I&C Instrumentation and Control IER INPO Event Report Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami (including Supplement 1)

IER Li 11-2 Fukushima Daiichi Nuclear Station Spent Fuel Pool Loss of Cooling and Makeup Page 3

Enclosure I NOC-AE-1 3002989 Page 4 of 42 Near-Term Actions to Address the Effects of an Extended Loss of All AC Power in Response to the Fukushima Daiichi Event Initial Phase Coping Implementation of strategies that generally rely upon installed plant equipment Actions INPO Institute of Nuclear Power Operations JPM Job Performance Measure (a training activity)

MAB Mechanical Auxiliary Building Minimum On-Shift Those personnel required to be on site 24/7 per the site Emergency Plan.

Staffing MOV Motor Operated Valve NEI Nuclear Energy Institute "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities", June 2011 NEI 12-01 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", May 2012 NRC Nuclear Regulatory Commission NTTF The NRC "Near-Term Task Force" Activated upon declaration of an Unusual Event. Should the event escalate to an On-shift ERO Alert, the On-shift Organization will be augmented by the duty Emergency Response Organization.

ONP Off-Normal Procedure ORO Offsite Response Organization OSC Operations Support Center PAR Protective Action Recommendation PORV Power-Operated Relief Valve PWR Power RCP Reactor Coolant Pump RCS Reactor Coolant System RP or RPT Radiation Protection or Radiation Protection Technician SAM or SAMG Severe Accident Mitigation or Severe Accident Mitigation Guidelines SFP Spent Fuel Pool SG Steam Generator STP South Texas Project STPNOC STP Nuclear Operating Company TGB Turbine Generator Building TMS Time Motion Study Implementation of strategies that involve the use of on-site portable equipment Transition Phase and consumables to extend the coping period, and prevent a loss of functions Coping Actions needed for core cooling, containment, and spent fuel pool cooling. Setup for these strategies should be performed prior to the end of the Initial Phase.

TSC Technical Support Center Note: Acronyms with adjacent definitions may not be included in this glossary.

Page 4

Enclosure I NOC-AE-1 3002989 Page 5 of 42 INTRODUCTION Information requests related to Emergency Preparedness are contained in Enclosure 5 of the §50.54(f) Letter (Reference 7.11).

Within this enclosure are two Requested Actions; one involves performance of a staffing assessment and the other a communications assessment. The actions for the staffing assessment are summarized as follows:

Assess current staffing levels and determine the appropriatestaff to fill all necessary positions for responding to a multi-unit event during a beyond design basis external event, and determine if any enhancements are appropriategiven the considerations of Fukushima Near-Term Task Force (NTTF) Recommendation 9.3 (Reference 7.2).

Reference 7.3 endorsed the 2-phase approach in NEI 12-01 (Reference 7.4) to the schedule presented in the §50.54(f) Letter (Reference 7.1).

Reference 7.5 presented an alternate schedule to Reference 7.1 and stated that an onsite and augmented staffing assessment considering all requested functions except those related to Near Term Task Force (NTTF) Recommendation 4.2 (Phase 1 staffing analysis) would be provided. This report provides the Phase 1 staffing analysis for South Texas Project (STP) Units 1 and 2.

The criteria presented in the NEI 12-01 guidance are intended to assist with the identification of additional organizational capabilities that will facilitate simultaneous performance of accident mitigation and repair actions at all on-site units following a beyond design basis external event. In lieu of a standard template, the guidance provides recommended criteria for use in performing an assessment to identify the staff that should be available to respond to a beyond design basis external event affecting multiple units at a site.

Phase 1 Staffing Assessment For multi-unit plants, the Phase 1 staffing assessment will be performed by March 29, 2013, and provided to the NRC by April 30, 2013.

The staffing assessment, as requested by the 50.54(f) letter, will be performed using NEI 12-01 and material from NEI 10-05.

The objective of the staffing assessment is to evaluate the on-site and augmented staff needed to respond to a large-scale external event meeting the conditions described in the NEI 12-01 assumptions, NOT including staffing needed to implement actions that address NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049). That is; the staffing assessment will consider all requested functions except those related to Fukushima NTTF Recommendation 4.2 (FLEX) - an assessment considering these functions will be performed in Phase 2.

The results of the assessment have been verified and validated to ensure adequacy and accuracy. Each corrective action and enhancement identified during this assessment will be tracked in the site Corrective Action Program (CAP) with an estimated completion date. In accordance with the requirements of 10 CFR 50, Appendix B, any Condition Adverse to Quality identified during an assessment must be entered into a corrective action program.

Page 5

Enclosure I NOC-AE-13002989 Page 6 of 42 2 PHASE 1 STAFFING ANALYSIS

SUMMARY

The on-shift staffing analysis determined that a sufficient number of staff are present on site to perform all initial phase coping actions.

At the time of this Phase 1 assessment, two Fukushima-related IER response actions have been implemented that involve tasks to be performed by the on-shift staff. One of these tasks was applicable to the ELAP scenario and was assessed in the Phase 1 task analysis. None of the implemented responses to the Fukushima-related INPO IERs have an impact on the augmented or expanded ERO staffing. Refer to Section 4.4 for a description of the IER related procedure tasks.

Sufficient augmented ERO personnel resources exist to fill most expanded ERO functions. Utilizing Table 3.1 from NEI 12-01 to evaluate expanded staffing requirements, STP has identified staffing gaps for performing engineering assessments and for evaluating and implementing SAMGs. STP will ensure that the required numbers of qualified individuals are added to the expanded ERO to fill these roles.

Provisions and procedures for the establishment of an expanded ERO have not been developed at STP.

Using existing procedures and strategies, the event response did not result in entry conditions into STP Severe Accident Management Guidelines (SAMGs) procedure prior to the ERO augmentation (6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ) and for a period greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The ability of the on-site staff to implement FLEX strategies will be evaluated as part of the Phase 2 staffing assessment since the FLEX equipment was not in place at the time of this assessment.

A list of improvement actions identified during the Phase 1 staffing assessment is provided in Section 6.

2.1 Task Analysis Results 2.1.1 Non-Validated Task Assessment The analysis did not identify any non-validated tasks - no time motion studies were required. Refer to Attachment 2, NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables, for additional documentation of the on-shift staffing task analysis results.

2.1.2 Potential Task Overlap Assessment No task overlaps were identified in the assessment. Refer to Attachment 2, NEI 10-05 Appendix D & E On-Shift Staffing Analysis Results Tables for additional information 2.2 Time Motion Study (TMS) Results No time motion studies were required as documented in Attachment 2, NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables.

Page 6

Enclosure 1 NOC-AE-1 3002989 Page 7 of 42 2.3 Augmented and Expanded ERO Assessment Results Utilizing Table 3.1 from NEI 12-01 to evaluate expanded ERO staffing requirements, STP has identified staffing gaps in the current augmented ERO for performing engineering assessments and for evaluating and implementing SAMGs. Specifically, one additional ERO member must be qualified for the following positions:

- TSC Technical Manager

- Engineering Supervisor

- Engineer- Nuclear

- Engineer - Mechanical

- Engineer - Electrical

- Engineer - I&C

- TSC Operations Communicator STP will ensure that the required number of qualified individuals are added to the expanded ERO to fill these roles.

Currently, there are two Mechanical Engineers, three Nuclear Engineers, and one TSC Operations Communicator listed as members of STP's "Gold Team" - a fourth ERO team that maintains the required ERO qualifications but are not part of the regular duty rotation. The additional expanded ERO members will be added to this team.

Refer to Table 5-2 for additional documentation of the expanded ERO functional staffing resources and the identified gaps.

Action #1: Ensure that the required number of qualified individuals are added to fill all necessary roles of the expanded ERO.

Page 7

Enclosure I NOC-AE-13002989 Page 8 of 42 3 ON-SHIFT STAFFING COMPLEMENT 3.1 Shift Staffing Basis Only personnel required to be on-shift are credited in the staffing analysis. The on-shift personnel complement includes the minimum required number and composition as described in the STP Emergency Plan.

Functional Area Major Tasks Emergency Positions "

-a.=

Shift Manager 2

1. Plant Operations and Assessment of Control Room Staff Reat Operator 4 Operational Aspects Plant Operator 4

2. Emergency Direction Command and Control Shift Manager 1(a) and Control

3. Notification &to Noiic 3.~~~ Local!_State .... !.

oc ! _ta e ................................... Plant

.. r Operator1 a....... a o.............

._...p_.e

......... 1..............

Communication Federal (ENS) Reactor Operator 1 Dose Assessment Senior HP 1

4. Radiological n-plant Surv.eys . . RP Technician ... 1_ .1 Assessment Onsite Surveys R'PTechnkcian"........ 1..

Chemistry Chem istry Technician 1 l a)

Technical ..Support 5PlnS y t m................................................. ...... .......... Shift Technical

...... W s e .ai

........O eAdvisor

... (

a o..............................................

5. Plant System Rad Waste Operator.... 1(5)

Engineering, Repair, Repair and Corrective Mechanical Maintenance 1(a) and Corrective Actions Actions Electrical Maintenance 1 I&C Maintenance 1

6. In-Plant PAs Radiation Protection RP Tech / Chem Tech 2(a)

7. Fire Fighting(D' -- Fire Brigade 5

8. 1't Aid and Rescue Ops -- Plant Protection Personnel 2

9. Site Access Control and Accountability Security & Accountability Plant Protection Personnel (c)

TOTAL: 25 (a) These positions may be covered by on-shift personnel assigned other functions.

(b) Fire Brigade per Technical Specifications; composed of five plant operators not assigned other duties.

(c) Per the STP Security Plan.

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Enclosure 1 NOC-AE-1 3002989 Page 9 of 42 3.2 Initial Shift Staffing Locations On-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions. The following are the typical locations of the on shift personnel:

U 1 S hift Manager ................................................................................... Control R oom

Ul Unit S upervisor ................................................................................ Control R oom

U1 Reactor Operator, Primary RO (Ul Pri RO) ..................................... Control Room

Ul Reactor Operator, Balance of Plant (Ul BOP RO) ........................... Control Room

U1 Plant Operator, TGB Watch (PO #1) ................. Unit 1 Turbine Generator Building

Ul Plant Operator, MAB Watch (PO #2) ..................... Unit 1 Mechanical Aux Building

U2 Shift Manager ................................................................................... C ontrol Room

U2 Unit S upervisor ................................................................................ C ontrol Room

U2 Reactor Operator, Primary RO (U2 Pri RO) ..................................... Control Room

U2 Reactor Operator, Balance of Plant (U2 BOP RO) ........................... Control Room

U2 Plant Operator, TGB Watch (PO #3) ................. Unit 2 Turbine Generator Building

U2 Plant Operator, MAB Watch (PO #4) ..................... Unit 2 Mechanical Aux Building

ENS Com m unicator (RO #5) ................................................................. Control Room

State/County Communicator (PO #5) ................................. U1 Electrical Aux Building

Senior HP ........................................................ 41' Elevation Mechanical Aux Building

RP Technician #1 ............................................ 41' Elevation Mechanical Aux Building

RP Technician #2 ............................................ 41' Elevation Mechanical Aux Building

Chem istry Technician .................................................................... 29' Cold Chem Lab

Electrical Maintenance .................................................................. MO ST Team Trailer

I&C Technician ............................................................................. MO ST Team Trailer

Fire Brigade Leader, (PO #6)(d) .................................... U1 Turbine Generator Building

Fire Brigade Member #1, (PO #7) ............................ U2 Turbine Generator Building

Fire Brigade Member #2, (PO #8)(d) ................................... U2 Electrical Aux Building

Fire Brigade Member #3, (PO #9) (e)......................................... Electrical Aux Building

Fire Brigade Member #4, (PO #10)(e) ....................................... Electrical Aux Building (d) State and County Communicator position and Fire Brigade positions are filled by the 6 on-shift Plant Operators not assigned safe shutdown duties - EAB Watch, Condensate Polishing (CP) Watch, and Yard Watch. Assignments are documented per site procedure OPOP01-ZQ-0022, "Plant Operations Shift Routines".

(e)EAB Watch Plant Operators Page 9

Enclosure 1 NOC-AE-1 3002989 Page 10 of 42 4 EXTENDED LOSS OF ALL AC POWER (ELAP) 4.1 Scope

1. The staffing assessment determined the ability of the on-shift staff to implement Initial Phase coping actions. No Transition Phase actions were evaluated because none were established at the time of this assessment - the use of portable equipment and consumables will be developed as part of the FLEX strategies and will not be evaluated until the Phase 2 Staffing Assessment.

2. The applicable actions from the Station Blackout coping strategies in place at the time of the assessment were evaluated.

3. Those IER improvement actions already implemented at the time of the assessment (e.g., incorporated into plant procedures) were evaluated and discussed in Section 4.4.

4. The staffing assessment evaluated the ability of the on-shift staff to perform required emergency plan response functions prior to the arrival of the augmented ERO.

4.2 Assumptions

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

2. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.

3. All equipment credited in current coping strategies remains available for use (e.g., a non-seismic water tank, diesel fire water pump).

4. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of an RP Technician.

5. The on-site security organization is able to satisfactorily perform all tasks related to Site and Protected Area Access Controls, under all event or accident conditions.

Performance of this function is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.

6. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.

7. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.

8. The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all Page 10

Enclosure 1 NOC-AE-1 3002989 Page 11 of 42 positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.

9. For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase coping actions.

10. NEI 10-05 assumes that augmented ERO members will arrive on-site within their normal response times (60-minute or 75-minute response). NEI 12-01 assumes that augmented ERO members will not begin to arrive for 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months due to a LSEE.

The event impedes site access as follows:

A. Post event time: 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - No site access. Consistent with NEI 12-01, which is based on a nominal 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months + 50%, this duration reflects the time necessary to clear roadway obstructions, use different travel routes and mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

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

private resource providers or public sector support).

C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

For purposes of this analysis, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months will be used as the time period for the conduct of the on-shift ERO response actions. See assumption 10.A above.

11. Offsite facilities and staging areas are available.

4.3 Event Description and Initial Conditions A large-scale external event occurs that results in:

all on-site units affected

extended loss of all AC power

impeded access to the units Initially, both reactors are operating at full power. Upon the loss of AC power, both reactors are successfully shut down.

This event results in a Site Area Emergency (SAE) Emergency Classification Level (ECL) based on Emergency Action Level (EAL) SS1.1 which escalates to a General Emergency ECL based on EAL SG1.1 once it has been determined that power cannot be restored before the coping time has been exceeded.

Page 11

Enclosure 1 NOC-AE-1 3002989 Page 12 of 42 Initial Conditions: Both STP Unit 1 and Unit 2 are initially at 100% power at equilibrium, middle of core life.

Abnormal Conditions: None Scenario Events: An offsite electrical transient occurs resulting in a loss of all offsite power.

None of the Emergency Diesel Generators (EDGs) can be synchronized to any Unit 1 or Unit 2 AC bus, resulting in a dual-unit loss of all AC power.

One EDG on each unit is assumed to start, but cannot be paralleled with any electrical bus.

Adequate core cooling and heat sink is maintained throughout the 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months duration. No core damage occurs and no entry into SAMG is required Notes: This scenario constitutes a dual unit event.

The scenario is designed such that restoration of any AC power source is not possible before the arrival of ERO personnel (360 minutes).

4.4 Procedures Used in the Event 4.4.1 List of Procedures Applicable to a Loss of All AC Power and Emerqency Plan Implementation

OPOP05-EO-EOOO, Reactor Trip or Safety Injection

OPOP05-EO-ECOO, Loss of All AC Power

OERP01-ZV-IN01, Emergency Classification

OERP01-ZV-IN02, Notifications to Offsite Agencies

" OERP01-ZV-IN03, Emergency Response Organization Notification

0ERP01 -ZV-IN04, Assembly and Accountability

OERP01-ZV-IN05, Site Evacuation

OERP01-ZV-SH01, Shift Manager

" 0ERP01-ZV-SH02, Acting Radiological Manager 4.4.2 Procedure Changes Due to IER Responses Applicable to Phase 1 Following the accident at Fukushima Daiichi, the Institute of Nuclear Power Operations (INPO) issued three IERs requiring the assessment of actions intended to improve the capabilities for responding to a beyond design basis event and an extended loss of all AC power, including events that impact the cooling of spent fuel.

1. Response to IER-L1-1 1-1 did not implement any new procedure actions to be performed by the on-shift or augmenting ERO.

2. Response to IER-Ll-11-2 included two items that affect actions to be performed by the on-shift ERO or augmenting ERO.

Page 12

Enclosure 1 NOC-AE-13002989 Page 13 of 42

STPNOC revised the Off-Normal Procedure (ONP) for a seismic event to add specific steps to check SFP temperatures and initiate a recovery log to ensure SFP level and temperature are maintained within specified limits. This procedure is not applicable to the ELAP and was therefore not assessed in the Phase 1 analysis.

The ONPs for control room evacuation, natural or destructive phenomena (severe weather & flood) and loss of power to one or more 13.8 KV standby busses did not contain specific steps to check SFP level and temperature.

STPNOC revised each of the ONPs to include actions and contingencies to monitor SFP level and temperature. These actions were assessed in the Phase 1 analysis.

3. Response to IER-L1-1 1-4 included two items that affect actions to be performed by the on-shift ERO or augmenting ERO.

Additional load shedding off DC busses

Establish ventilation in the EAB Neither of these two strategies were implemented at the time of this analysis and were not assessed.

Page 13

Enclosure 1 NOC-AE-1 3002989 Page 14 of 42 5 AUGMENTED AND EXPANDED ERO RESPONSE ANALYSIS 5.1 ERO Notification and Response during an ELAP Staffing resources for assessment of the expanded ERO are provided by the depth of personnel filling the existing augmenting ERO positions. Table 5-1 below documents the augmenting ERO staffing requirements from Emergency Plan Table C-1, Figure C-2, C-3, C-4 and C-5. The numbers reported in Table 5-1 assume the site ERO is fully staffed.

Table 5-1 Augmented ERO Response Resources

'*/ .... ** *# per #

Assigned Major FunctioniTask ERO Title *v Team :Qualified TSC Manager 1 3 Assistant TSC Manager 1 33 rt or 1 Emergency Direction and Control Ass EOF iDirector 1 3 Deputy EOF Director 1 3 TSC Communicator 1 3 TSC Ops Communicator 1 3 OSC Communicator 1 3 EOF Liaison 1 3 Notification / Communication Texas Liaison 1 3 EOF Offsite Agency Communicator 1 3 EOF Licensing Director 1 3 EOF Assistant Licensing Director 1 3 EOF Comm System Supervisor 1 3 EOF Fed Response Agency Liaison 1 3 EOF Dose Assessment Specialist 1 3 RadAssessment) (OEOF Asst Dose Assessment 1 3 Assessment) Specialist 1_3 Offsite Field Team 2 6 Rad Assessment (Offsite Offsite Field Team Driver 2 6 Surveys) EOF Offsite Field Team Supervisor 1 3 Rad Assessment (In-Plant & RP Technician 3 36(ý Onsite Surveys)

RP Technician 4 In-Plant Protective Actions OSC Radiological Coordinator 1 3 Rad Assessment (Sample OSC Chemistry Analysis Supv 1 3 Analyses) Chemistry Technician 1 14 TSC Radiological Manager 1 3 Rad Assessment (RP TSC Assist Radiological Manager 1 3 Supervisory) TSC Chem/Radchem Manager 1 3 EOF Radiological Director 1 3 Rad Assessment (ERF Surveys) EOF Radiological Staff 1 3 Plant Operations and Assmt of OSC Plant Ops Discipline Lead 1 3 Operational Aspects TSC Assistant Operations Manager 1 3 (f There are two additional qualified RP Technicians currently credited as members of the Offsite Field Team and are therefore not included in the total number of qualified RP Technicians Page 14

Enclosure I NOC-AE-1 3002989 Page 15 of 42 I ______________________________________________________________________________

per Assianed Maior.Functiciiask ERO Title Team* Qualified TSC Nuclear Engineer 1 3 TSC Mechanical Engineer 1 3 TSC Electrical Engineer 1 3 TSC Technical Manager 1 3 Plant System Engineering TSC Engineering Supervisor 1 3 TSC I&C Engineer 1 3 EOF Technical Director 1 3 EOF Technical Staff 1 3 EOF System Status Evaluator 1 3 EOF Engineering Assistant 1 3 OSC Mechanical Maintenance Lead 1 3 Mechanic 1 54(g)

OSC Electrical Maintenance Lead 1 3 Electrician 2 52_H)

I&C Technician 1 51(l')

OSC Coordinator 1 3 Repair and Corrective Actions Assistant OSC Coordinator 1 3 OSC Mechanical Maint Planner 1 3 OSC Electrical Maintenance Planner 1 3 OSC I&C Maintenance Planner 1 3 OSC I&C Maintenance Lead 1 3 TSC Maintenance Manager 1 3

_TSC Maintenance Communicator 1 3 TSC TCScrt Security Manager aae 1 3 Access Control and Personnel Accountability TSC Security Supervisor 1 3 OSC Security Coordinator 1 3 TSC Rad Status Board Keeper 1 3 TSC Administrative Manager 1 3 TSC Administrative Staff 1 3 OSC Resource Coordinator 1 3 OSC Status Board Keeper 1 3 EOF Director Admin Assistant 1 3 EOF Status Board Keeper 2 6 EOF Rad Status Board Keeper 1 3 EOF Support Organization Director 1 3 Resource Allocation and EOF Asst Support Org Director 1 3 Administration EOF Procurement/Resources Supv 1 3 EOF Records Supervisor 1 3 EOF Support Orientation Coordinator 1 3 EOF Materials Engineer 1 3 EOF Information Systems Analyst 1 3 EOF Employee Support 1 3 EOF Purchaser 1 3 EOF Administrative Staff 2 6 JIC Administrative Manager 1 3 JIC Administrative Staff 6 18 (g) Includes Mechanics from both Mechanical Maintenance and the Integrated Maintenance Team -

Apprentices and Supervisors are not included in this number (h) Includes Electricians from both Electrical Maintenance and the Integrated Maintenance Team -

Apprentices and Supervisors are not included in this number

(')Includes I&C Technicians from both the I&C Maintenance organization and the Integrated Maintenance Team - Apprentices and Supervisors are not included in this number Page 15

Enclosure 1 NOC-AE-1 3002989 Page 16 of 42 I __________________________________________________

per Assigned Major Function/Task ERO Title ....... Qualifipd; Company Spokesperson 1 3 EOF Site Public Affairs Coordinator 1 3 EOF Site Public affairs Specialist 1 3 JIC Director 1 3 JIC Senior Staff Writer 1 3 JIC Public Inquiry Manager 1 3 JIC Media Relations Manager 1 3 Public Information JIC Media Relations ANI Liaison 1 3 JIC Internet/Graphics Technician 1 3 JIC Audio-Visual Specialist 1 3 JIC Communications Technician 1 3 JIC Technical Support Liaison 1 3 JIC Media Rel Tech Spokesperson 1 3 JIG Media Relations Staff 3 9 JIC Public Inquiry Staff 7 21 5.1.1 General ERO Response

1. Implementing Strategy for the Expanded ERO When the ERO notification system is operable, all qualified ERO members on a team are contacted and expected to report if fit for duty. In the absence of the call out system, all ERO members are trained to report to the EOF following a large scale external event.

Action #2: Develop specific guidance for how and when to establish the expanded ERO from the pool of augmented ERO.

2. Response Timeliness for the Expanded ERO On 07/12/12 a Training Bulletin was issued to "communicate the expectation of the augmenting ERO to automatically respond to a designated staging area." The bulletin was sent to the minimum and full staffing ERO members (ERO roster personnel), but was not communicated to off-shift Operations, Maintenance, Radiation Protection, or Security personnel. Procedure OPGP05-ZV-0003, dated 12/27/12, Addendum 1, was revised to provide the following:

If local telephone landlines and cellularsystems are not available to call-out the ERO during a large scale external event (e.g., hurricane,major flood), ERO members must go to the EOF when made aware (e.g., by direct observation, media reports,word of mouth), of the event. Once there, decisions will be made on how and when they will be transportedto the plant site.

Action #3: Develop and communicate the process to expand the automatic response of ERO personnel who report to the EOF in the event of a loss of communications due to a large scale event to include appropriate activation of off-shift Operations, Maintenance, Security, RP personnel, and expanded ERO.

I Action #4 The changes in Action #3 will be included in annual site training.

Page 16

Enclosure 1 NOC-AE-1 3002989 Page 17 of 42

3. Work Location for the Expanded ERO As described above, during a wide spread loss of power off hours event TSC and OSC ERO personnel will automatically respond to the EOF, which has been designated as the alternate TSC/OSC. The facility is located approximately 12.5 air miles north-northeast of the station at 4000 Avenue F, in Bay City, Texas.

The alternate TSC/OSC has equipment for communicating with the control room, and plant security. TSC and OSC personnel at the alternate TSC/OSC have the capability to perform engineering assessment activities, including damage control team planning and preparation prior to returning to the site.

Site procedure OERP01-ZV-OF03, Alternate TSC/OSC, describes the layout and assigned work areas for the alternate TSC/OSC. This alternate facility was designed to support current augmented ERO staffing.

SAction #5: Identify and revise applicable site procedures to address logistics for the expanded ERO response teams for a dual unit event.

4. Transportation to the Site for the Expanded ERO STP's 90-day response to Recommendation 9.3 of the NTTF letter (Reference 7.10) states that the following methods of access to the site are available:

1. STP has multiple roadways to access the site:

From the West - Highway 521

" From the North - Farm to Market (FM) 1468

" From the East- Highway 521

2. STP's owner controlled area is located on the west bank of the Colorado River.

The river can be used to transportpersonneland small equipment by boat from surroundingareasto the site.

3. Helicopters can be used to transportpersonnel to the site.

4. STP has road clearing equipment and a boat onsite which may be available after a large scale event.

5. STPNOC has an agreement with Matagorda County to provide local resources upon request or state and federal resources if there is a disasterdeclaration.

These resources include road clearing equipment, off-road and high water vehicles, boats and helicopters.

Page 17

Enclosure I NOC-AE-1 3002989 Page 18 of 42 The process used by the ERO for obtaining emergency assistance is as follows:

- Upon activation of the EOF, the Emergency Operations Center (EOC) for Matagorda County is contacted for assistance

" The EOC is located in the Matagorda County Sheriffs Office, approximately 1.2 miles north of the EOF

STP has a Letter of Agreement in place with Matagorda County to provide assistance in the event of an emergency

- If Matagorda County requires additional resources to assist in their Emergency Management efforts, they will contact the Texas Department of Public Safety in Pierce, Texas

- Should further resources be required, the State Operations Center in Austin, Texas would be contacted.

Contact numbers for Matagorda County EOC, Department of Public Safety in Pierce, the State Operations Center in Austin, and the US Coast Guard in both Houston and Corpus Christi are listed the site Emergency Communications Directory (including back-up satellite phone numbers, where applicable).

5. ERO Drill & Exercise Program NEI 12-01 states that a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. In particular, standard objectives and extent-of-play may need to be revised to clarify the expected demonstration of functions that are dependent upon the type of scenario event or accident (i.e., within or beyond design basis, and number of affected units). For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit.

Current STP drill and exercise procedures do not include evaluation objectives or demonstration criteria for dual unit events or expanded ERO activities. Future guidance is expected from the NRC in this area.

Page 18

Enclosure 1 NOC-AE-1 3002989 Page 19 of 42 5.1.2 Position Specific ERO Response

1. Radiation Protection Technicians (RPTs)

The equation below was used to determine the required number of on-site RP Technicians (on-shift plus augmented ERO RP Technicians that perform on-site response functions) for the STP expanded ERO:

RPTT = RPTcop + RPTRCA + RPTNC Where:

RPTT = Total required number of on-site RP Technicians.

RPTcop = Number needed to support implementation of any 2 extended loss of AC power coping strategies per unit. Determine this number by reviewing strategies for each unit.

RPTRCA = Number needed for repair and corrective action (2 x the number of units).

RPTNC = Number of on-site RP Technicians performing other emergency plan functions that would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams.

The STP RPTcop number is based upon the coping strategies of OPOP05-EO-ECOO which requires two RPTs to provide job coverage into radiation areas for personnel to perform the required actions.

The STP RPTRCA number is four RPTs.

The STP RPTNc number is based upon emergency plan Table C-1 which requires two RPTs to perform onsite surveys and one RPT to perform dose assessments which would preclude them from performing job coverage for extended loss of all AC power coping, repair or corrective action teams (note, Table C-1 provides for four individuals for performing offsite surveys).

9 (RPTT) = 2 (RPTcop) + 4 (RPTRCA) + 3 (RPTNc)

Thus, the total required number of on-site RP Technicians to be provided as part of the expanded ERO is 18, based on staffing needed to operate on 12-hour shifts.

Following a beyond design basis external event 36 RP Technicians are available to support performance of assigned emergency plan functions and the expanded response capability (Refer to Table 5-1).

Provisions exist for obtaining additional RP Technicians through industry agreement with INPO as part of the INPO Emergency Resources Manual documented by a current letter of agreement.

Page 19

Enclosure 1 NOC-AE-1 3002989 Page 20 of 42

2. Administrative Support Personnel STP evaluated the administrative support positions on the ERO and determined that the number of administrative staff personnel is sufficient.

3. SAMG Implementation The assessment considered the number and qualifications of ERO personnel necessary for simultaneous implementation of the two most task intensive SAMG strategies in both units. The two most labor intensive strategies were as follows:

SAG-l, Inject into Steam Generators

SAG-2, Depressurize the RCS Implementation of the SAG-1 strategy requires the following personnel resources:

ERO Position # per unit Function Plant Operator 3 Operate Equipment Mechanic 2 Connect Hoses RP Technician 2 Job Coverage Implementation of the SAG-2 strategy requires the following personnel resources:

ERO Position: # per unit Function Plant Operator 2 Operate Equipment RP Technician 2 Job Coverage These two strategies implemented simultaneously and in both units, would require the following personnel resources:

0 10 Plant Operators

4 Mechanics

8 RP Technicians As stated in NEI 12-01, while personnel previously assigned to other functions such as emergency repair and corrective actions should not be included, members of the on-shift staff may be included.

Page 20

Enclosure 1 NOC-AE-1 3002989 Page 21 of 42 5.2 Expanded Response Functions for Phase 1 Staffing Assessment Table 5-2 addresses NEI 12-01 Table 3.1 expanded staffing requirements and documents the staffing necessary to support the simultaneous deployment of emergency repair and corrective action teams to each affected unit. The number required column is equal to two times the specified staffing consideration per unit in order to support 24-hour expanded ERO staffing based on 12-hour shifts.

Per current site procedures, one of the existing three ERO teams is on call each week - there will be no changes to this procedure at this time. There is reasonable assurance that the additional personnel for the expanded ERO can be brought to the site by the time they are needed.

Table 5-2 Expanded vs. Augmented ERO Response Comparison Function . KeyRoles and Staffing Considerations Location STP Augmented ERO Positions Required Available 0 Overall cognizance of the activities related to implementation of repair and corrective actions, and implementation of Transition Unit Response Phase coping and Severe Accident Management (SAM) strategies TSC TSC Manager / Asst TSC Manager 4 6 Coordination for an assigned unit

One individual per unit; individuals should not be assigned other functions

Provides coordination of Operations staff and support for an Operations assigned unit CR / TSC Ops Manager/ Asst Ops Manager 4 6 Coordination 0 One individual per unit; individuals should not be assigned other functions

Provides coordination of Maintenance staff and support for an Maintenance assigned unit OSC OSC Coordinator / Asst OSC 4 Coordination

One individual per unit; individuals should not be assigned other Coordinator functions

Provides coordination of Engineering staff and support for an Engineering assigned unit TSC TSC Technical Manager 4 6 Coordination 0 One individual per unit; individuals should not be assigned other Engineering Supervisor functions Page 21

Enclosure I NOC-AE-13002989 Page 22 of 42

Function Key Role and Staffing Considerations Location STP Augmented ERO Positions Required A;vilable

One team for each unit to perform engineering assessments in support repair and corrective actions Engineer - Nuclear0 j) 4 3 Engineering e Team composition (i.e., number and represented disciplines) as TSC Engineer - MechanicalO) 4 3 Assessments described in the emergency plan Engineer - ElectricalO) 4 3 a Team may include personnel responsible for performing other functions for the same assigned unit TSC Technical Manager 4 3

One team for each unit to evaluate selection of SAM strategies; Engineering Supervisor 4 3 Evaluation of team performs evaluations not done by Control Room personnel Engineer - Nuclear 4 3 Severe Accident o Team composition (i.e., number and represented disciplines) as TSC Engineer - Mechanical 4 3 Management described in governing site programs, procedures and guidelines Engineer - Electrical 4 3 (SAM) Strategies e Team may include personnel responsible for performing other Engineer - I&C(k) 4 3 functions for the same assigned unit Rad Manager / Asst Rad Manager 4 6 Ops Manager / Asst Ops Manager 4 6 U Overall cognizance of on-site and in-plant teams performing or Team supporting repair and corrective actions for an assigned unit Maintenance Discipline Leaders 4 9 Coordination

One individual per unit; individuals should not be assigned other (Electrical, Mechanical, I&C) functions

Two individuals per unit to assist with implementation of repair and Non-Licensed corrective actions OSC Plant Operators 8 77(l)(m)

Operators 0 Should not include members of the on-shift staff Mechanical

Two individuals per unit to implement repair and corrective actions Maintenance Repair and 5 0 Staffing may include an on-shift individual (i.e., 2 individuals for a OSC Mechanic 854 Corrective Action unit composed of 1 on-shift and 1 augmented)

0) Engineers also credited as SAMG Evaluators (k) The I&C Engineer position is not listed as a required minimum staffing position for the TSC or EOF, but they are listed as trained SAMG Evaluators (1)10 of these available POs are counted as part of the minimum on-shift staff (m) As of 2/27/2013, 61 of the available plant operators were fully qualified and the remaining 16 were not fully qualified Page 22

Enclosure 1 NOC-AE-1 3002989 Page 23 of 42 Function,~ Key Roles and Staffing Considerations Location STIR Augmented ERO Positions. Requ ired Available Electrical 0 Two individuals per unit to implement repair and corrective actions Maintenance Repair and 0 Staffing may include an on-shift individual (i.e., 2 individuals for a OSC Electrician 8 52 Corrective Action unit composed of 1 on-shift and 1 augmented)

I&C Repair and R Two individuals per unit to implement repair and corrective actions Staffing may include an on-shift individual (i.e., 2 individuals for a OSC I&C Technician 8 51 Corrective Action

unit composed of 1 on-shift and 1 augmented)

Plant Operators 10 77 0 Number and composition of personnel capable of simultaneous OSC Mechanics 4 54 implementation of any 2 SAM strategies at each unit RIP Technicians 8 36 Implementation of . Should not include personnel assigned to other functions (e.g., Shift Manager 4 10 SAM Strategies emergency repair and corrective actions); however, may include CR Shift Technical Advisor 4 9 members of the on-shift staff and personnel responsible for Reactor Operators 4 44 implementation of Transition Phase coping strategies TSC Operations Communicator 4 3 Page 23

Enclosure I NOC-AE-1 3002989 Page 24 of 42 6 LIST OF IMPROVEMENT ACTIONS IDENTIFIED DURING THE PHASE I ASSESSMENT The following enhancements have been entered into the CAP system to track their resolution:

Description Estimated Completion Date Action #1: Ensure that the required number of qualified March 31, 2014 individuals are added to fill all necessary roles of the expanded ERO.

Action #2: Develop specific guidance for how and when to December 4, 2014 establish the expanded ERO from the pool of augmented ERO.

Action #3: Develop and communicate the process to expand the December 4, 2014 automatic response of ERO personnel who report to the EOF in the event of a loss of communications due to a large scale event to include appropriate activation of off-shift Operations, Maintenance, Security, RP personnel, and the expanded ERO.

Action #4: The changes in Action #3 will be included in annual December 4, 2014 site training.

Action #5: Identify and revise applicable site procedures to December 4, 2014 address logistics for the expanded ERO response teams for a dual unit event.

Note: None of the above listed actions are classified as Conditions Adverse to Quality (CAQ).

These actions apply to a Beyond Design Basis event and therefore do not meet the requirements of a CAQ.

The December 4, 2014 date was chosen to align with the completion and submittal of the STP Phase 2 Staffing Assessment.

The March 31, 2014 date was chosen to align with the Engineering Department's process for assigning ERO responsibilities and to give sufficient time to incorporate ERO changes into the appropriate site directories.

Page 24

Enclosure I NOC-AE-1 3002989 Page 25 of 42 7 LIST OF REFERENCES 7.1 Letter from E. J. Leeds (NRC) to E. D. Halpin, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated March 12, 2012 (ML12053A340) 7.2 SECY-1 1-0093, "The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", n, refer to NRC staff report entitled, Recommendations for Enhancing Reactor Safety in the 21st Century, dated July 12, 2011 (ML.1 11861807) 7.3 Letter from D. L. Skeen (NRC) to Susan Perkins-Grew (NEI), U.S. Nuclear Regulatory Commission Review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012, letter dated May 15, 2012 (ML12131A043) 7.4 NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Rev. 0 (ML12126A344) 7.5 Letter, D.W. Rencurrel to NRC, "Revised 60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated June 4, 2012 (ML12163A331) 7.6 NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Rev. 0 (ML111751698) 7.7 STP Response to IER 11-1, Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami, dated 04/15/11 7.8 STPNOC Response to IER 11-2, Fukushima Daiichi Nuclear Station Spent Fuel Pool Loss of Cooling and Makeup, dated 09/22/11 7.9 STPNOC Response to IER 11-4, Near-Term Actions to Address the Effects of an Extended Loss of all AC Power in Response to the Fukushima Daiichi Event, dated 01/19/12 7.10 Letter from D. W. Rencurrel to NRC, "90-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident", dated June 4, 2012 (ML12163A331) 7.11 STP Emergency Plan Section C, Organizational Control of Emergencies, Rev ICN 20-9 7.12 OPOP05-EO-EOOO, Reactor Trip or Safety Injection Rev. 22 7.13 OPOP05-EO-ECOO, Loss of All AC Power, Rev. 23 7.14 OERP01-ZV-IN01, Emergency Classification, Rev. 9 7.15 OERP01-ZV-IN02, Notifications To Offsite Agencies, Rev. 29 7.16 OERP01-ZV-IN03, Emergency Response Organization Notification, Rev. 17 Page 25

Enclosure 1 NOC-AE-1 3002989 Page 26 of 42 7.17 OERP01-ZV-IN04, Assembly and Accountability, Rev. 13 7.18 OERP01-ZV-IN05, Site Evacuation, Rev. 12 7.19 OERP01-ZV-IN07, Offsite Protective Action Recommendations, Rev 13 7.20 OERP01-ZV-SH01, Shift Manager, Rev. 27 7.21 OERP01-ZV-SH02, Acting Radiological Manager, Rev. 10 7.22 OERP01-ZV-TP01, Offsite Dose Calculations, Rev. 20 7.23 OERP01-ZV-OF03, Alternate TSC/OSC, Rev. 1 7.24 SAG-i, Inject into the Steam Generators, Rev. 1 7.25 SAG-2, Depressurize the RCS, Rev. 1 7.26 SAG-3, Inject into the RCS, Rev. 1 7.27 SAG-4, Inject into Containment, Rev. 1 7.28 SAG-5, Reduce Fission Product Releases, Rev. 1 7.29 SAG-6, Control Containment Conditions, Rev. 1 7.30 SAG-7, Reduce Containment Hydrogen, Rev. 1 7.31 SAG-8, Flood Containment, Rev. 1 7.32 SACRG-1, Severe Accident Control Room Guideline Initial Response, Rev. 1 7.33 SACRG-2, Severe Accident Control Room Guideline After the TSC is Functional, Rev. 1 Page 26

Enclosure I NOC-AE-1 3002989 Page 27 of 42 : NE!0, Table 5 ontroq!g !Me** *relation..

Functionl .... Operations Training Program and EP Drill Program Task Line

nctin Analysis Controling Methods 1 Declare the Emergency Emergency Response Training Program Learning Objectives for Classification Level (ECL) Emergency Direction, Part 1 TERMINAL OBJECTIVE:

01. Given the necessary reference materials and a hypothetical emergency situation, classify the emergency.

Enabling OBJECTIVE:

06. Using applicable references, CLASSIFY an incident for a specified plant condition or set of plant parameters.

2. Approve Offsite Protective Emergency Response Training Program Learning Objectives for Action Recommendations Emergency Direction, Part 2 TERMINAL OBJECTIVE:

01. Given necessary reference materials and a hypothetical emergency situation, determine the correct Protective Action Recommendation (PAR).

Drill Objective OBJ-B-2, On-Shift Emergency Director Demonstrate the Shift Manager's ability to immediately and unilaterally initiate any emergency response action, including providing protective action recommendations to authorities responsible for implementing off-site emergency measures.

3. Approve content of State/local Drill Objective OBJ-A-2, Operational Agreement notifications Demonstrate the coordination of the implementation of emergency measures and the exchange of information between the utility and Federal, State and local agencies and other support organizations having an emergency response role within the EPZ.

4. Approve extension to Drill Objective OBJ-K-1, Emergency Worker Exposure Controls allowable dose limits Demonstrate the ability to establish on-site exposure guidelines consistent with EPA Manual of Protective Action Guides and Protective Actions For Nuclear Incidents (EPA 400-R-92-001) for:

removal of injured persons, undertaking corrective actions, performing assessment actions, providing first aid, performing personnel decontamination, providing ambulance services, and providing medical treatment services.

5. Notification and direction to Drill Objective OBJ-J-1, Assembly & Accountability on-shift staff (e.g., to Demonstrate the capability to account for all individuals on-site assemble, evacuate, etc.) and ascertain the names of missing individuals within 30 minutes of the start of Assembly & Accountability and account for all on-site individuals continuously thereafter.

Drill Objective OBJ-J-2, Alerting On-site Personnel Demonstrate the means, within the required time, to alert individuals who do not have emergency assignments (such as visitors, contractor and construction personnel, and persons who may be in the public access areas within the owner controlled area).

Page 27

Enclosure 1 NOC-AE-13002989 Page 28 of 42 tchiA et .. _.EI.1.E.0.05: Tabl.e a.,t...d5 cOntr..ig

.on CorrelatLi**.

Operations Training Program. and EP Drill Program Task Line Function/Task Analysis Controlling Methods

6. ERO notification Drill Objective OBJ-E-1, ERO Notifications Demonstrate the ability to alert, notify and mobilize ERO personnel.

7. Abbreviated NRC notification N/A Assumptions dictate no hostile action is occurring for DBT event

8. Complete State/local Drill Objective OBJ-E-2, Initial Notification notification form Demonstrate the ability to provide an accurate initial off-site notification message within 15 minutes from emergency declaration.

9. Perform State/local Drill Objective OBJ-E-2, Initial Notification notifications Demonstrate the ability to provide an accurate initial off-site notification message within 15 minutes from emergency declaration.

10. Complete NRC event Drill Objective OBJ-Q-1, NRC Notifications notification form Demonstrate the ability to notify the NRC.

11. Activate ERDS N/A ERDS is continuously active at STP.

12. Offsite radiological Drill Objective OBJ-I-2, Release and Dose Assessment assessment Demonstrate the capability to determine the magnitude of radioactive releases or perform dose assessments based on plant parameters, effluent monitors, field data and meteorological conditions. -

13. Perform NRC notifications Drill Objective OBJ-Q-1, NRC Notifications Demonstrate the ability to notify the NRC.

14. Perform other site-specific N/A Not performed by STP shift staff event notifications (e.g.,

INPO, ANI, etc.)

15. Personnel accountability Drill Objective OBJ-I-1, Assembly and Accountability Demonstrate the capability to account for all individuals on-site and ascertain the names of missing individuals within 30 minutes of the start of Assembly & Accountability and account for all on-site individuals continuously thereafter.

16. Implement Security N/A Assumptions dictate no hostile action is occurring Contingency Plan Page 28

Enclosure I NOC-AE-1 3002989 Page 29 of 42 Attachment .2: NEI 1-5Appenx B On-Shift Staffing Analysis Results Tables ;. .

TABLE 1 - On-Shift Positions Extended Loss of All AC Power (ELAP)

Emergency Plan . Augmentation Role.. in Table'# 1: Unanalyzed T.. S LE0ine On-shift Position Reference Elapsed.Time (min) Line# Tak? Required?

2/1 5/1

1. Ui Shift Manager Table C-1 5/2 No No 5/3 5/5

2. Ul Unit Supervisor Table C-1 2/2 No No

3. Ul Reactor Operator (Ul Pri RO), Table C-1 2/3 No No

4. Ul Reactor Operator (Ul BOP RO) Table C-1 2/4 No No

5. Ul TGB Watch Plant Operator (PO #1) Table C-1 2/5 No No 2/6.A 2/6.B

6. Ul MAB Watch Plant Operator (PO #2) Table C-1 2 /6.C No No 216.D 2/6.E 2/6.F

7. U2 Shift Manager Table C-1 2/7 No No

8. U2 Unit Supervisor Table C-1 2/8 No No

9. U2 Reactor Operator (U2 Pri RO) Table C-1 2/9 No No 10 U2 Reactor Operator (U2 BOP RO) Table C-1 2/10 No No

11. U2 TGB Watch Plant Operator (PO #3) Table C-1 2/11 No No 2/12.A 2/12.B

12. U2 MAB Watch Plant Operator (PO #4) Table C-1 2/ 12.C No No 2/12.D 2/12.E 2/12.F Page 29

Enclosure 1 NOC-AE-1 3002989 Page 30 of 42

Attachment:

NEIO005.Appendix B On-ShIft Stafftng Analysis ReSultsle"l:

Emergency Plan Augmentation Role in Table #. Unanalyzed TMS.

Line On-shiftPo.sition Reference "'Elapsed Time (mm) Line#

,Task? R.e.qUred?.

13. ENS Communicator (RO #5) Table C-1 5/10 No No 5/13

14. State/County Communicator (PO #5) Table C-1 5/8 No No Table C-1i2/15 N/A N/A

15. Fire Brigade Leader (PO #6) 3/1 N/A N/A Table C-1i2/16 N/A N/A

16. FBT Member #1 (PO #7) 3/2 N/A N/A 2 / 17 N/A N/A N/A N/A

17. FBT Member #2 (PO #8) Table C-1i /17 13/3 N/A N/A Table C-1 2/18 No No

18. FBT Member #3 (PO #9) 3/4 N/A N/A

19. FBT Member #4 (PO #10) Table C-1 2/19 No No 3/5 N/A N/A

20. I&C Technician Table C-1 - 2/20 N/A N/A

21. Elect. Maintenance Table C-1 - 2/21 N/A N/A

22. Senior HP Table C-1 360 4/1 4/5 No No 4/1

23. RP Technician #1 Table C-1 360 4/4/ No No

24. RP Technician #2 Table C-1 360 4/1 No No 4/4

25. Chemistry Technician Table C-1 360 4/8 N/A N/A

26. Security All per STP Security Plan 5/6 No No 5/15 Note: In Table 1, those on-shift positions with tasks labeled as N/A were not assigned a specific action for the first six hours.

Page 30

Enclosure I NOC-AE-1 3002989 Page 31 of 42 Attachment.2: IiO*O5 Appen BOn-Shift tfjng A ysisResults Tablebs _-,

TABLE 2 - Plant Operations & Safe Shutdown Extended Loss of All AC Power (ELAP)

Minimum Crew (Two Units - One Control Room)

LOne Generic TitleiRole. On-Shift Position Task Description ' . : Controlling Method

1. Shift Manager Ul Shift Manager Plant Oversight Ops Training Program

2. Unit Supervisor #1 Ul Unit Supervisor Direct Ul CR operations (EO0 / ECOO) Ops Training Program

3. Reactor Operator #1 Ul Reactor Operator (Ul Pri RO) Perform Ul CR operations (EO00 / ECO0) Ops Training Program

4. Reactor Operator #2 Ul Reactor Operator (Ul BOP RO) Perform Ul CR operations (EO00 / ECO0) Ops Training Program

5. Auxiliary Operator #1 Ul TGB Watch Plant Operator (PO Attempt to start Ul TSC DG (in-plant ECO0 action) Ops Training Program Auxiiar Opeato #1 #1)

6. Auxiliary Operator #2 Ul MAB Watch Plant Operator A. Isolate Ul RCP Seal Return (in-plant ECO0 action) JPM 20.02 (PO #2) B. Isolate Ul Thermal Barriers (in-plant ECO0 action) JPM 28.02 C. Isolate Ul Seal Injection (in-plant ECQO action) JPM 28.02 D. Close Ul MOV-0025 (in-plant ECOO action) Ops Training Program E. Close Ul RA-MOV-0004 & RA-MOV-0006 (in-plant JPM 127.02 ECO0 action)

F. Verify Ul SFP Level (in-plant ECO0 action) Ops Training Program

7. Shift Technical Advisor U2 Shift Manager STA Tasks Ops Training Program

8. Unit Supervisor #2 U2 Unit Supervisor Direct U2 CR operations (EOOO / ECO0) Ops Training Program

9. Reactor Operator #3 U2 Reactor Operator (U2 Pri RO) Perform U2 CR operations (EOOO / ECO0) Ops Training Program

10. Reactor Operator #4 U2 Reactor Operator (U2 BOP RO) Perform U2 CR operations (EOOO / ECO0) Ops Training Program Auxiliary U2 TGB Watch Plant Operator Attempt to start U2 TSC DG (in-plant ECOO action) Ops Training Program yOperator #3 (PO #3)

12. Auxiliary Operator #4 U2 MAB Watch Plant Operator A. Isolate U2 RCP Seal Return (in-plant ECOO action) Ops Training Program (PO #4) B. Isolate U2 Thermal Barriers (in-plant ECOO action) Ops Training Program C. Isolate U2 Seal Injection (in-plant ECO0 action) Ops Training Program D. Close U2 MOV-0025 (in-plant ECO0 action) Ops Training Program E. Close U2 RA-MOV-0004 & RA-MOV-0006 (in-plant JPM 127.02 ECO0 action)

F. Verify U2 SFP Level (in-plant ECO0 action) Ops Training Program

13. Other ENS Communicator (RO #5) NRC communications/notifications per site procedure EP Training Program OERPOI-ZV-IN02 Page 31

Enclosure I NOC-AE-1 3002989 Page 32 of 42 aihet2,NE.10-05 Appq~ndix B OnSitStaffing Analysis~esultsT es~hls~~.

14. Other State/County Communicator State/County notifications per site procedure OERP01-ZV- EP Training Program (PO #5) IN02

15. Other Fire Brigade Leader (PO #6) N/A N/A

16. Other FBT Member #1 (PO #7) N/A N/A

17. Other FBT Member #2 (PO #8) N/A N/A

18. Other FBT Member #3 (PO #9) A. Place SG PORV Station Blackout PWR switches to JPM 34.02 bypass (Unit 1) Ops Training Program B. Ul Load Shed (in-plant ECOO action)

19. Other FBT Member #4 (PO #10) A. Place SG PORV Station Blackout PWR switches to JPM 34.02 bypass (Unit 2) Ops Training Program B. U2 Load Shed (in-plant ECO0 action)

Other (non-Operations) Personnel Line Generic Title/Role* K. On-Shift Position Ts Description Conitroiing Method

20. I&C Technician I&C Technician N/A N/A

21. Electrical Technician Electrical Maintenance N/A N/A TABLE 3 - Firefighting Extended Loss of All AC Power (ELAP)

Line Performd

.Contro!ingBy . . .

Task Description Method

1. Fire Brigade Leader (PO #6) N/A N/A

2. FBT Member #1 (PO #7) N/A N/A

3. FBT Member #2 (PO #8) N/A N/A

4. FBT Member #3 (PO #9) N/A N/A

5. FBT Member #4 (PO #10) N/A N/A Page 32

Enclosure I NOC-AE-1 3002989 Page 33 of 42 7Attachnment.2: NEI 10-05 Appendix B 0n-iSShStaffing Analysis-ResultsT-ae-s _ . "--..

TABLE 4 - Radiation Protection and Chemistry Extended Loss of All AC Power (ELAP)

"= Position Performing ... Performance Time. Period After E*ergen.cy. Declaration (minutes)

..FunctionlTask. .0-30 :30-60 60-90 90;1 120-150:

120. 0150-1801.80-210 2,10240 240-300 300-330 330-360 In-Plant Survey

1. On-Shift Position:

HP Supervisor X X X

2. On-Site Radiological Survey On-Shift Position:

3. Personnel Monitoring On-Shift Position:

4. Job Coverage X X X X X X X X X X X On-Shift Position: X X X X X X X X X X X RP Technician #1 RP Technician #2

5. Offsite Radiological X Assessment On-Shift Position:

HP Supervisor

6. Other RP -

On-Shift Position:

7. Sampling X X X X X X X X X X X On-Shift Position:

Chemistry

8. Other Chem - Describe:

On-Shift Position:

Note: The basis for the selected performance time period was established by the subject matter experts during the task analysis review.

Page 33

Enclosure I NOC-AE-1 3002989 Page 34 of 42 : NEI-E -05 "Appendix BýOn-S-hift-S-taffing Analysis Results-Tables ___

TABLE 5 - Emergency Plan Implementation Extended Loss of All AC Power (ELAP)

...'Line FunctionLTask

On-Shift-Positi6 : Cbntrolling Method :

1. Declare the Emergency Classification Level (ECL) Ul Shift Manager EP Training Program

2. Approve Offsite Protective Action Recommendations U1 Shift Manager EP Training Program EP Drill Program

3. Approve content of State/local notifications U1 Shift Manager EP Drill Program

4. Approve extension to allowable dose limits N/A N/A

5. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.) U1 Shift Manager EP Drill Program

6. ERO notification Security EP Drill Program

7. Abbreviated NRC notification for Design Basis Threat event N/A N/A

8. Complete State/local notification form State/County Communicator EP Drill Program

9. Perform State/local notifications State/County Communicator EP Drill Program

10. Complete NRC event notification form ENS Communicator EP Drill Program

11. Activate ERDS N/A N/A

12. Offsite radiological assessment N/A N/A

13. Perform NRC notifications ENS Communicator EP Drill Program

14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.) N/A N/A

15. Personnel accountability Security EP Drill Program

16. Implement Security Contingency Plan N/A Security Training Program Note: Line #3, #8 and #9 includes initial and follow-up State/local notifications.

Page 34

Enclosure 1 NOC-AE-1 3002989 Page 35 of 42

. . .5Appendix &E 0n-ShiftStaa in na!ysReuts b!es ..... T

.;;.. . .L* . ... . ... . . . . . . .. ....

Extended Loss of All Power (ELAP) Position: Ul MAB Watch Plant Operator (PO #2) Line #:1-6 Appendix D: Function / Responsibility (Task) Analysis

.uncti.n (Task) .. Action Step ~Duration Responsibilityv (Task). Acio St 1.1 Isolate U1 RCP Seal Return (2/6.A) 1.1.1 ECO0 Step 4.c 3 1.2 Isolate U1 Thermal Barriers (2/6.B) 1.2.1 ECOO Step 8.b 9

1. Plant Operations (status 1.3 Isolate U1 Seal Injection (2/6.C) 1.3.1 ECOO Step 8.c 9 monitoring and EOP actions) 1.4 Close U1 MOV-0025 (2/6.D) 1.4.1 ECOO Step 20.b 5 1.5 Close Ul RA-MOV-0004 & RA-MOV-0006 (2/6.E) 1.4.1 ECOO Step 21.a 10 1.6 Verify U1 Spent Fuel Pool Level (2/6.F) 1.5.1 ECOO Step 24.a 15 Timing for Isolate RCP Seal Return, Isolate Thermal Barriers, Isolate Seal Injection and Verify CVCS Charging line isolated (MOV-0025) were taken from Ops walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."

Timing for closure for RA-MOV-0004 & RA-MOV-0006 is taken from JPM 127.02.

Timing for Verify Spent Fuel Pool Level is taken from operator experience (a visual check of SFP level from the operating deck is a non-technical general operator rounds task).

Page 35

Enclosure 1 NOC-AE-13002989 Page 36 of 42 Achment 3: NEIP10-05;AppendixD&E.On-Shi Staffing ArnaysisResults Tables.,

Extended Loss of All Power (ELAP) Position: U1 MAB Watch Plant Operator (P0 #2) Line #:1-6 Appendix E: Work Activities Analysis

.ime Plantlequiprie~ntienvironmental T im e events and conditions

. .. Task (Action 41:4 Step description

.. . :.1 ". ... ... L.::: .

, applicable to the functions and tasks (start.&' oj) 00:00 Actions completed at U1 MAB 29'. Refer to section 4.3 for Perform U1 in-plant ECO actions: Isolate U1 RCP Seal Return event and conditions description (00:00 - 00:03) 00:04 Actions completed at U1 MAB 41' penetration space. Refer to Perform U1 in-plant ECO0 actions: Isolate U1 Thermal Barriers section 4.3 for event and conditions description (00:04 - 00:13)

Actions event andcompleted at description U1 MAB 29'. Refer to section 4.3 for Perform Ul in-plant ECOO actions: Isolate U1 Seal Injection conditions (00:14 - 00:23)

Perform U1 in-plant ECO0 actions: Verify U1 CVCS Charging line isolated 00:24 eActions completed at U MAB 29'. Refer to section 4.3 for (MOV-0025) event and conditions description (00:24 - 00:29) 00:30 Actions completed at U1 MAB 41' penetration space. Refer to Perform Ul in-plant ECOO actions: Close U1 RA-MOV-0004 & RA-MOV-0006 section 4.3 for event and conditions description (00:30 - 00:40) 00:41 Actions completed at U1 FHB operating deck. Refer to section Perform U1 in-plant ECO0 actions: Verify U1 Spent Fuel Pool Level 4.3 for event and conditions description (00:41 - 00:56)

Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.

Page 36

Enclosure 1 NOC-AE-1 3002989 Page 37 of 42

,Attachrment3: .NEI 10-05Append.x D & E 0n-ShiftStaff.ngAAnalysis Results Tables_:

Extended Loss of All Power (ELAP) Position: U2 MAB Watch Plant Operator (P0 #4) Line #:1-12 Appendix D: Function I Responsibility (Task) Analysis Function Duration Responsibility (Task) .(.) Action Step 1.1 Isolate U2 RCP Seal Return (2/12.A) 1.1.1 ECOO Step 4.c 3 1.2 Isolate U2 Thermal Barriers (2/12.B) 1.2.1 ECOO Step 8.b 9

1. Plant Operations (status 1.3 Isolate U2 Seal Injection (2/12.C) 1.3.1 ECOO Step 8.c 9 monitoring and EOP actions) 1.4 Close U2 MOV-0025 (2/12.D) 1.4.1 ECOO Step 20.b 5 1.5 Close U2 RA-MOV-0004 & RA-MOV-0006 (2/12.E) 1.4.1 ECO0 Step 21.a 10 1.6 Verify U2 Spent Fuel Pool Level (2/12.F) 1.5.1 ECO0 Step 24.a 15 Timing for Isolate RCP Seal Return, Isolate Thermal Barriers, Isolate Seal Injection and Verify CVCS Charging line isolated (MOV-25) were taken from Operations walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."

Timing for closure for RA-MOV-0004 & RA-MOV-0006 is taken from JPM 127.02.

Timing for Verify Spent Fuel Pool Level is taken from operator experience (a visual check of SFP level from the operating deck is a non-technical general operator rounds task).

Page 37

Enclosure I NOC-AE-1 3002989 Page 38 of 42 rAttachment 3: *NEI 10'-05Appendix D & E On-Shift Staffing Analysis Results Tables' Extended Loss of All Power (ELAP) Position: U2 MAB Watch Plant Operator (PO #4) Line #:1-12 Appendix E: Work Activities Analysis ime: Plant/equipment/environmentaI events and conditions Task: Action Step description .7.

ai:ppliicable to the funrctions and tasks. (start& stop)

Actions completed at U2 MAB 29'. Refer to section 4.3 for Perform U2 in-plant ECO0 actions: Isolate U2 RCP Seal Return event and conditions description (00:00 - 00:03) 00:04 Actions completed at U2 MAB 41' penetration space. Refer to Perform U2 in-plant ECO0 actions: Isolate U2 Thermal Barriers section 4.3 for event and conditions description (00:04 - 00:13) 00:14 Actions completed at U2 MAB 29'. Refer to section 4.3 for Perform U2 in-plant ECO0 actions: Isolate U2 Seal Injection event and conditions description (00:14 - 00:23)

Perform U2 in-plant ECOO actions: Verify U2 CVCS Charging line isolated 00:24 Actions completed event and conditionsat description U2 MAB 29'. Refer to section 4.3 for (MOV-0025)

(00:24 - 00:29)

Actions completed at U2 MAB 41' penetration space. Refer to Perform U2 in-plant ECO0 actions: Close U2 RA-MOV-0004 & RA-MOV-0006 section 4.3 for event and conditions description (00:30 - 00:35) 00:41 Actions completed at U2 FHB operating deck. Refer to section Perform U2 in-plant ECOO actions: Verify U2 Spent Fuel Pool Level 4.3 for event and conditions description (00:41 - 00:56)

Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.

Page 38

Enclosure 1 NOC-AE-1 3002989 Page 39 of 42 actthamchent3-:N,

.... N b_10-05x Appendx. &.E On"Shft Sta Aabe-

____afin Aaysis R'esult-s Table6s- M6_

Extended Loss of All Power (ELAP) Position: Fire Brigade Member #3 (PO #9) Line #:1-18 Appendix D: Function / Responsibility (Task) Analysis Duration

,Function Responsibility (Task) Action Step'(mi) 1.1 Ensure the SG PORV Station Blackout power switches are in "BYP" (2/19.A) 2.5

Place U1 Train "A" SG PORV Station Blackout PWR switch to Bypass 2

Place U1 Train "D" SG PORV Station Blackout PWR 1.1.1 ECQO Conditional Information switch to Bypass Page (CIP) 2

Place U1 Train "B" SG PORV Station Blackout PWR switch to Bypass 2.5

1. Plant Operations (status 1 switch Place U1 Train "C" SG PORV Station Blackout PWR to Bypass _________________

monitoring and EOP actions) 1.2tU L oSepasB h

1.2 U1 Load Shed (2/18.13)

" De-energize ESF Load Sequencers (ECO0 Addendum 4, 3 Step 1.)

De-energize DP1201 Components (ECO0 Addendum 4, 3 Step 2.b) 1.2.1 ECO0 Step 7.a

De-energize DP1204 Components (ECO0 Addendum 4, 3 Step 2.c)

De-energize 120 VAC Non-!E Loads (ECOO Addendum 4, 4.5 Step 3.)

Note: Duration times are rounded up to the nearest half-minute Timing for Load Shed actions and for placing SG PORV Station Blackout switches in bypass were taken from Operations walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."

Page 39

Enclosure 1 NOC-AE-1 3002989 Page 40 of 42 O-05;ApendixD&

~A~ttachent 3: E~n-Sif............. . . ~ **~*

Extended Loss of All Power (ELAP) Position: Fire Brigade Member #3 (P0 #9) Line #:1-18 Appendix E: Work Activities Analysis Time Plant/equipment/environmental events and conditions Task / Action Step description "

applicable to the fucItions and tasks (start & stop)

Perform U1 in-plant ECOO actions: Place U1 Train "A"SG PORV Station 00:00 Actions completed at U EAB 10'. Refer to section 43 for Blackout PWR switch to Bypass event and conditions description (00:00 - 00:02:30)

Perform U1 in-plant ECOO actions: Place Ul Train "D"SG PORV Station 00:03:30 Actions completedio at EAB 10'. Refer to section 4.3 for Blackout PWR switch to Bypass event and conditions description (00:03:30- 00:05:30)

Perform U1 in-plant ECO0 actions: Place U1 Train "B"SG PORV Station 00:06:30 Actions completed at 1 EAB 3 Refer to section 4.3 for Blackout PWR switch to Bypass event and conditions description (00:06:30- 00:08:30)

Perform U1 in-plant ECOO actions: Place U1 Train "C" SG PORV Station 00:09:30 Actions completed at U EAB 60'. Refer to section 4.3 for Blackout PWR switch to Bypass event and conditions description (00:09:30- 00:12)

Perform U1 in-plant ECO0 actions: U1 Load Shed - De-energize ESF Load 00:13 Actions completed at U1 EAB 10'. Refer to section 4.3 for Sequencers event and conditions description (00:13 - 00:16)

Perform U1 in-plant ECOO actions: U1 Load Shed - De-energize DP1201 00:17 Actions completed at U1 EAB 10'. Refer to section 4.3 for Components event and conditions description (00:17 - 00:20)

U! EAB 60'. Refer to section 4.3 for Perform U1 in-plant ECOO actions: U1 Load Shed - De-energize DP1204 00:21 Actions completed dat descripeoon Components event and conditions description (00:21 - 00:24)

Perform Ul in-plant ECOO actions: U1 Load Shed - De-energize 120 VAC Non-00:25 Actions completed at U EAB 10'. Refer to section 4.3 for 1 E Loads event and conditions description (00:25 - 00:29:30)

Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.

Page 40

Enclosure 1 NOC-AE-1 3002989 Page 41 of 42 NEI 10-05 Appendi-xD &.E On-Shift Staffing Analysig ResulsTablaess eAttachrment3:- ........... , ....

Extended Loss of All Power (ELAP) Position: Fire Brigade Member #4 (PO #10) Line #:1-19 Appendix D: Function / Responsibility (Task) Analysis Duration Function Responsibility (Task): .** . .Action Step. (m) 1.1 Ensure the SG PORV Station Blackout power switches are in "BYP" (2/19.A) 2.5

Place U2 Train "A" SG PORV Station Blackout PWR switch to Bypass 2

Place U2 Train "D" SG PORV Station Blackout PWR 1.1.1 ECO0 Conditional Information switch to Bypass Page (CIP) 2

Place U2 Train "B" SG PORV Station Blackout PWR switch to Bypass 2.5

1. Plant Operations (status Place U2 1 switch Train "C" SG PORV Station Blackout PWR to Bypass monitoring and EOP actions) 1.2tU2 L o BypasB 1.2 U2 Load Shed (2/18.13)

" De-energize ESF Load Sequencers (ECO Addendum 4, 3 Step 1.)

" De-energize DP1 201 Components (ECOO Addendum 4, 3 Step 2.b) 1.2.1 ECOO Step 7.a

" De-energize DP1204 Components (ECOO Addendum 4, 3 Step 2.c)

" De-energize 120 VAC Non-lE Loads (ECOO Addendum 4, 4.5 Step 3.)

Note: Duration times are rounded up to the nearest half-minute Timing for Load Shed actions and for placing SG PORV Station Blackout switches in bypass were taken from Operations walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."

Page 41

Enclosure I NOC-AE-13002989 Page 42 of 42 LAttachment 3: NEII10-05 Apendix D & E On-Shift Staffing Analysis Results Tables'. 7 .:...

Extended Loss of All Power (ELAP) Position: Fire Brigade Member #4 (P0 #10) Line #:1-19 Appendix E: Work Activities Analysis TimeTm.., . ,

Plant/equipment/environmental events,,. and conditions

Task I Action Step description; ., .

applicable to the functions and tasks (start & stop)

Perform U2 in-plant ECOO actions: Place U2 Train "A"SG PORV Station 00:00 Actions completed at U2 EAB 10'. Refer to section 4.3 for Blackout PWR switch to Bypass event and conditions description (00:00 - 00:02:30)

Perform U2 in-plant ECO0 actions: Place U2 Train "D"SG PORV Station 00:03:30 Actions completed at U2 EAB 10'. Refer to section 4.3 for Blackout PWR switch to Bypass event and conditions description (00:03:30- 00:05:30)

Perform U2 in-plant ECO0 actions: Place U2 Train "B"SG PORV Station 00:06:30 Actions completed at U2 EAB 35'. Refer to section 4.3 for Blackout PWR switch to Bypass event and conditions description (00:06:30- 00:08:30)

Actions completed at U2 EAB 60'. Refer to section 4.3 for Perform U2 in-plant EC0O actions: Place U2 Train "C" SG PORV Station 00:09:30 eeti ndconditi deAript.Ron Blackout PWR switch to Bypass event and conditions description (00:09:30- 00:12)

Perform U2 in-plant ECOO actions: U2 Load Shed - De-energize ESF Load 00:13 Actions completed at U2 EAB 10'. Refer to section 4.3 for Sequencers event and conditions description (00:13 - 00:16)

Actions completed at U2 EAB 10'. Refer to section 4.3 for Perform U2 in-plant ECOO actions: U2 Load Shed - De-energize DP1201 event and conditions description Components

____________________________________(00:17 - 00:20)

Perform U2 in-plant ECOO actions: U2 Load Shed - De-energize DP1204 00:21 Actions completed at U2 EAB 60'. Refer to section 4.3 for Components event and conditions description (00:21 - 00:24)

Actions completed at U2 EAB 10'. Refer to section 4.3 for Perform U2 in-plant EC0O actions: U2 Load Shed - De-energize 120 VAC Non-00:25 Actiond conditi U2 I E Loads event and conditions description (00:25 - 00:29:30)

Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.

Page 42

Enclosure 2 NOC-AE-13002989 Enclosure 2 South Texas Project (STP)

Summary of Requested Items and Actions Planned for the Phase 1 Staffing Assessment

Enclosure 2 NOC-AE-13002989 Page 1 of 3 Summary of Requested Items and Actions Planned for the Phase 1 Staffing Assessment Below is a summary of the Requested Information Items delineated in References 2 and 3 and conclusions based on the completion of the South Texas Project (STP) Phase 1 staffing assessment provided in Enclosure 1 to this submittal.

Phase 1 Staffing Assessment Request #1 Provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the NRC Request. This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures.

The following functions are requested to be assessed:

How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the order regarding the NTTF Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654. Table B-1 such as plant operations and assessment of operational aspects, emergency direction and control, notification/

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

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

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

Provide onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase I staffing assessment] by 4/30/2013.

Provide onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]. To be provided 4 months prior to the beginning of 2RE17 (Original Estimated date 6/4/14)*

As used within the context of NRC Order EA-12-049.

This date correspondedto 4 months prior to the beginning of the planned first occurrence of the second refueling outage (2RE17) as identified in Reference 3. The 2RE16 outage counts as the first refueling outage based on submitting the overall integratedplan on February28, 2013.

IRE 19 outage will be the second refueling outage in the second Unit.

STPNOC Actions Taken/Actions Planned - Request #1 The overall results of the STP Phase 1 Assessment are included in Enclosure 1 to this letter with a summary of potential staffing issues discussed below.

Enclosure 2 NOC-AE-1 3002989 Page 2 of 3 Summary of Requested Items and Actions Planned for the Phase I Staffing Assessment On-shift Emergency Response Organization (ERO) Staffing Assessment Conclusions The assessment concluded that the required minimum on-shift staffing as specified in the STP Emergency Plan for Units 1 & 2 is sufficient to support the initial phase coping actions and Emergency Plan actions in a dual unit event involving the extended loss of all emergency AC power sources.

Augmented ERO Staffing Assessment Conclusions The current augmented ERO resources are sufficient to meet the recommended staffing levels identified in NEI 12-01 to perform most of the expanded ERO functions. STP has identified staffing gaps for performing engineering assessments and for evaluating and implementing Severe Accident Management Guidelines (SAMGs). STP will ensure that the required numbers of qualified individuals are added to the expanded ERO to fill these roles.

The Phase 2 Staffing Assessment is expected to be completed by 12/4/2014 (Four months prior to the start of 2RE1 7). Note: This date is based on the 4/4/2015 start date for 2RE1 7. The outage dates for the start of 2RE1 7 were recently changed due to a forced outage in Unit 2.

This revises the commitment dates provided in References 2 and 3 (See Enclosure 3).

Request #2 Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate, please include in the schedule the time to implement the changes.

1. Conduct the onsite and augmented staffing assessment:

The onsite and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment].

Completion Date: 3/29/2013.

The onsite and augmented staffing assessment considering functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]

Estimated Completion: 5 months prior to the beginning of 2RE1 7* (OriginalEstimated date 5/4/14)

2. A schedule of the time needed to implement changes associated with the Phase 1 staffing assessment. Estimated Completion: 4/30/2013.

Those associated with the Phase 2 staffing assessment. Estimated Completion: 4 months prior to the beginning of 2RE1 7* (OriginalEstimated date 6/4/14)*

As used within the context of NRC Order EA-12-049.

This date corresponded to 4 months prior to the beginning of the currently planned first occurrence of the second refueling outage (2RE17). The 2RE16 outage counts as the first refueling outage based on submitting the overall integrated plan on February 28, 2013. 1RE19 outage will be the second refueling outage in the second Unit.

Enclosure 2 NOC-AE-13002989 Page 3 of 3 Summary of Requested Items and Actions Planned for the Phase 1 Staffing Assessment STPNOC Actions Taken/Actions Planned - Request #2 Phase 1 Assessment:

The following enhancements are being tracked in the Corrective Action Program.

1. Ensure that the required number of qualified individuals are added to fill all necessary roles of the expanded ERO (See Table 5-2). This will be completed by 3/31/14.

2. Develop specific guidance for how and when to establish the expanded ERO from the pool of augmented ERO. This will be completed by 12/4/14.

3. Develop and communicate the process to expand the automatic response of ERO personnel who report to the EOF in the event of a loss of communications due to a large scale event to include appropriate activation of off-shift Operations, Maintenance, Security, RP personnel, and expanded ERO. This will be completed by 12/4/14.

4. The changes in action #3 will be included in annual site training. This will be completed by 12/4/14.

5. Identify and revise applicable site procedures to address logistics for the expanded ERO response teams for a dual unit event. This will be completed by 12/4/14.

Phase 2 Assessment:

The Phase 2 Staffing Assessment is expected to be completed by 12/4/2014 (Four months prior to the start of 2RE1 7).

Note: This date is based on the 4/4/2015 start date for 2RE1 7. The outage dates for the start of 2RE17 were recently changed due to a forced outage in Unit 2. This revises the commitment dates provided in References 2 and 3 (See Enclosure 3).

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

staffing, equipment, transportation, etc.).

Changes will be identified as follows:

Those associated with the Phase 1 staffing assessment.

Completion: 4/30/2013.

Those associated with the Phase 2 staffing assessment.

Estimated Completion: 4 months prior to the beginning of 2RE1 7* (Original Estimated date 6/4/14)

STPNOC Actions Taken/Actions Planned - Request #6 STP will ensure that the required number of qualified individuals are maintained to man the expanded ERO. No changes to the Emergency Plan are considered necessary at this time.

When the Phase 2 Assessment is completed, changes to the emergency plan will be considered at that time.

Enclosure 3 NOC-AE-1 3002989 Enclosure 3 South Texas Project (STP)

List of Commitments

Enclosure 3 NOC-AE-1 3002989 Page 1 of 1 List of Commitments The following table identifies those actions committed to by the STP Nuclear Operating Company (STPNOC) in this document. Any statements in this submittal with the exception of those in the tables below are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments and revised commitments to Robyn Savage at (361) 972-7438.

Commitments Scheduled Due Condition Date Report

1. Ensure that the required number of qualified March 31, 2014 12-11657 individuals are added to fill all necessary 12-11657-28 roles of the expanded ERO (Table 5-2 positions)

TSC Technical Manager

Engineering Supervisor

Engineer - Nuclear

Engineer - Mechanical

Engineer - Electrical

Engineer - I&C

TSC Operations Communicator Revised Commitments dates related to the Phase 2 Staffing Assessment Commitments Original Revised Condition Scheduled Scheduled Report Due Date Date

1. STPNOC will perform a second staffing 4 months prior 4 months prior 12-11657-10 assessment as requested by the 50.54(f) to the to the letter using NEI 12-01 and provide the beginning of beginning of results of the assessment to the NRC. 2RE17 2RE17 *

(Phase 2 Assessment). STPNOC will (estimated (estimated provide the NRC with the results of the date 6/4/14) date 12/4/14)

Phase 2 assessment and an implementation schedule of the time needed to implement any changes.

2. STPNOC will identify changes associated 4 months prior 4 months prior 12-11657-12 with the Phase 2 staffing assessment that to the to the have been made or will be made to our beginning of beginning of emergency plan regarding the on-shift or 2RE17 2RE17

augmented staffing changes including any (estimated (estimated new or revised agreements with offsite date 6/4/14) date 12/4/14) resource providers (e.g., staffing, equipment, transportation, etc.) and provide this to the NRC

Note: The STP Phase 2 Staffing Assessment is expected to be completed by 12/4/2014 (Four months prior to the start of 2RE17). This date is based on the 4/4/2015 start date for 2RE17.

The outage dates for the start of 2RE1 7 were recently changed due to an ongoing forced outage in Unit 2. This revises the commitment dates provided in References 2 and 3 related to the Phase 2 Staffing Assessment.

NOC-AE-13002989, Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 1 Staffing Assessment

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NOC-AE-13002989, Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 1 Staffing Assessment

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