NOC-AE-14003189, 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 2 Staffing Assessment

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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 2 Staffing Assessment
ML14351A156
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 11/25/2014
From: Capristo A
South Texas
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-14003189, STI: 33965919
Download: ML14351A156 (39)
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Text

Nuclear Operating Company South Texas Pro/ectElectric GencratingStation PO Boa.289 Wadsworth, Texas 77483 XA A -

November 25, 2014 NOC-AE-1 4003189 10 CFR 50.54(f)

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 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 Insigqhts-from the Fukushima Dai-ichi Accident - Phase 2 Staffing Assessment

References:

1. Letter from E.J. Leeds, NRC, to All Power Reactor Licensees, "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", March 12, 2012 (ML12053A340)

2. Letter from D. W. Rencurrel, STPNOC, to NRC Document Control Desk, "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", May 9, 2012 (ML12136A472)

3. Nuclear Energy Institute (NEI) 12-01, Revision 0, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", May 4, 2012 (ML12125A412) 4- Letter from D.L. Skeen, NRC, to S. 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", May 15, 2012 (ML12131A043)

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 regarding Near-Term Task Force (NTTF) Recommendation 9.3. Enclosure 5 of Reference 1 contains the specific requested actions and 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.

STI: 33965919

NOC-AE-14003189 Page 2 of 3 In accordance with Reference 1, Enclosure 5, South Texas Nuclear Operating Company (STPNOC) submitted an alternative course of action for performing the requested actions and providing the requested information (Reference 2). Attachment 1 of Reference 2 describes the alternate course of action and schedule for responding to Requested Information Items 1, 2, and

6. Enclosure 1 to this letter provides a status of Requested Information Items 1, 2, and 6.

The Phase 2 Staffing Assessment report for the South Texas Project (STP) is provided in to this letter. The STP Phase 2 Staffing Assessment report follows the assessment methodology described in NEI 12-01 (Reference 3) which was endorsed by the NRC in Reference 4.

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

If there are any questions regarding this letter, please contact Wendy Brost at (361).972-8516.

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

Executed on __-_z_-1 Date Aldo C p~risto Executive Vice President Chief Administrative Officer web

Enclosures:

1. Response to Requested Information: NTTF Recommendation 9.3 - Staffing, Requested Information Items 1, 2, and 6
2. South Texas Project Units 1 & 2, November 2014: Phase 2 Staffing Assessment
3. List of Commitments

NOC-AE-1 4003189 Page 3 of 3 cc:

(paper copy) (electronic copy)

Regional Administrator, Region IV Steve Frantz 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 NRC Resident Inspector Kevin Polio U. S. Nuclear Regulatory Commission Cris Eugster P. 0. Box 289, Mail Code: MN1 16 L. D. Blaylock Wadsworth, TX 77483 CPS Energy William M. Dean Peter Nemeth Director, Office of Nuclear Reactor Regulation Crain Caton & James, P.C.

U.S. Nuclear Regulatory Commission One White Flint North (MS 13 H16) C. Mele 11555 Rockville Pike John Wester Rockville, MD 20852 City of Austin Mark A. Satorius Richard A. Ratliff Executive Director for Operations Texas Department of State Health U.S. Nuclear Regulatory Commission Services One White Flint North (MS 16 E15) 11555 Rockville Pike Robert Free Rockville, MD 20852 Texas Department of State Health Services

Enclosure 1 NOC-AE-14003189 Enclosure 1 Response to Requested Information:

NTTF Recommendation 9.3 - Staffing, Requested Information Items 1, 2, and 6

Enclosure 1 NOC-AE-14003189 Page 1 of 3 Response to Requested Information:

NTTF Recommendation 9.3 - Staffing, Requested Information Items 1, 2, and 6

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

The Phase 2 Staffing Assessment concluded that the current minimum on-shift staff and augmented ERO are sufficient for executing all required initial and any necessary transition phase actions for the diverse and flexible coping (FLEX) strategies without the assignment of collateral duties that would adversely affect the ability to execute required Emergency Plan functions. No change to the on-shift staffing level or augmented ERO is required.

As part of the South Texas Project (STP) Phase 2 Staffing Assessment report (Enclosure 2),

a detailed timeline was developed based on a tabletop discussion and review of the on-shift response to the postulated beyond-design-basis external event (BDBEE) extended loss of alternating current (AC) power (ELAP). On-shift and augmented staff response was determined based upon the tabletop team members' review of applicable plant procedures and the current drafts of the diverse and FLEX support guidelines (FSGs). All onsite resources required for implementing the initial and transition phase FLEX mitigating strategies and the Emergency Plan are identified in the timeline.

The draft FSGs used in the tabletop exercise are still under development. Prior to the STP implementation date associated with Order EA-1 2-049 (April 2015 per the current 2RE1 7 refueling outage schedule), a review of this report will be performed based on the final validated FSGs and any applicable new procedures not available when the staffing tabletop was performed. This action item has been entered into the site condition reporting database and a supplement to this Phase 2 Staffing Assessment will be submitted if the new or revised procedures affect the results of the original assessment.1 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:

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

No equipment outside the power block will need to be deployed before offsite resources arrive at the plant. With the exception of the trailer-mounted diesel-driven pumps which are located on site in protected storage buildings, the majority of FLEX equipment is pre-staged inside Class 1 structures in the power block and would not be affected by the external events. Some equipment, such as hoses and cables, is stored in cabinets or lock-boxes inside plant buildings that have been analyzed for the BDBEE conditions.

I See Condition Report (CR) action #12-11657-35

Enclosure 1 NOC-AE-14003189 Page 2 of 3

b. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-I, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.

The Minimum On-Shift Staffing table shown in Section 4.0 of the Phase 2 Staffing Assessment report describes the responsible personnel for each of the major functional areas of NUREG-0654 Table B-1 following the BDBEE.

Overall, direction of emergency response will be assumed by the Emergency Director at the Emergency Operations Facility when all centers are fully manned. Direction of minute-to-minute facility operation will remain with the senior managers in the Technical Support Centers or Control Rooms.

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

The assessment did not identify the need for additional on-shift staff, changes to the Emergency Response Organization (ERO) structure, nor any new functions.

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

The Phase 2 Staffing Assessment concludes that the current minimum on-shift staff is sufficient to support implementation of the FLEX mitigating strategies for STP Units 1 and 2 without the assignment of collateral duties that would adversely affect the ability to execute required Emergency Plan functions.

In order to avoid a potential collateral duty for the Radiation Protection Technician (RPT) during a BDBEE and ELAP for a multi-unit event, the Chemistry Technician must retain the ability to perform on-site surveys for use during extreme emergency events. This requirement has been entered into the site condition reporting database and is listed as a commitment in Enclosure 3.2

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

The Phase 2 Staffing Assessment for the BDBEE and ELAP multi-unit event is provided in Enclosure 2. No modifications were identified.

9See Condition Report (CR) action #12-11657-36

Enclosure 1 NOC-AE-14003189 Page 3 of 3

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

staffing, equipment, transportation, etc.).

The existing on-shift staff is adequate to implement the Emergency Plan and ELAP strategies at STP Units 1 and 2 during the first six-hour "no site access" period. No changes to the Emergency Plan on-shift staffing have been identified.

We have determined the number and composition of staff required to satisfy the expanded response capability functions defined in Table 3.2 of NEI 12-01 (see Attachment 3 of Enclosure 2) and verified that we have sufficient qualified ERO personnel to provide 24-hour coverage for these functions.

The results of the Phase 2 Staffing Assessment do not indicate that new or revised agreements are necessary.

Enclosure 2 NOC-AE-14003189 Enclosure 2 South Texas Project Units 1 & 2, November 2014 Phase 2 Staffing Assessment

Enclosure 2 NOC-AE-14003189 Page 1 of 29 9t,'10 ýAl PHASE 2 South Texas Project Units I & 2 STAFFING November 2014 ASSESSMENT

Enclosure 2 NOC-AE-14003189 Page 2 of 29 Table of Contents G lossary ..................................................................................................................................... 3 1.0 Executive Sum m ary .................................................................................................... 4 2.0 Introduction ...................................................................................................................... 5 3.0 Scope of the Phase 2 Staffing Assessm ent ................................................................. 5 4.0 Em ergency Plan Minim um O n-shift Staffing ................................................................. 6 5.0 Phase 2 Staffing Assessm ent for BDBEE / ELAP ......................................................... 8 5.1 O n-shift Staff Responsibilities .................................................................................. 8 5.2 Methodology ................................................................................................................. 8 5.3 Staffing Assessm ent Assum ptions ............................................................................ 9 5.4 Severe Accident Managem ent G uideline (SAM G ) Usage ......................................... 9 5.5 Assessm ent of Initial Phase Coping Strategies and Capability ................................ 10 5.6 Assessm ent of Transition Procedures and Actions ............................................... 10 6.0 Augm ented Em ergency Response O rganization (ERO ) ............................................. 10 6.1 ERO Response ........................................................................................................... 10 6.2 Expanded Em ergency Response ............................................................................ 11 7.0 Phase 2 Staffing Assessm ent Conclusions .............................................................. 12 7.1 Staffing Level .............................................................................................................. 12 7.2 Task Analysis Results ............................................................................................ 12 7.3 Tim e Motion Study Results ..................................................................................... 12 7.4 Augmented and Expanded ERO Assessment Results ........................................... 12 7.5 Identified Issues .......................................................................................................... 12 8.0 References ..................................................................................................................... 13 9.0 Attachm ents ................................................................................................................... 13 Attachment 1 - Phase 2 Staffing Assessment Tabletop Data ......................................... 14 Attachm ent 2 - Task Im plem entation Tim eline ............................................................... 22 Attachment 3 - Expanded Emergency Response Functions .......................................... 28

Enclosure 2 NOC-AE-14003189 Page 3 of 29 GLOSSARY Alternate Alternate TSC/OSC, located in the EOF in Bay City, Texas. Used in the event of a declared Response Facility emergency when access to the site is restricted.

Personnel mobilized to assist the on-shift staff in responding to more serious events and accidents. Augmented ERO personnel are capable of performing a 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.

DC Direct current EDG Emergency Diesel Generator ELAP Extended Loss of all AC Power ENS Emergency Notification System - used to provide operational and health physics information to the Nuclear Regulatory Commission Operations Center during the early phase of an emergency.

EOF Emergency Operations Facility ERDS Emergency Response Data System 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 Additional personnel who expand the capability of the augmented ERO to facilitate timely and dERO effective performance of critical emergency response 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.

FLEX Diverse and Flexible Coping Strategies I&C Instrumentation and Control Initial CopingPhase Actions Implementation of strategies that generally rely upon installed plant equipment INPO Institute of Nuclear Power Operations MAB Mechanical Auxiliary Building Minimum On-Shift Those personnel required to be on site 24/7 per the site Emergency Plan.

Staffing NEI Nuclear Energy Institute NEI 10-05 "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities", June 2011 12-01 "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", May 2012 Activated upon declaration of an Unusual Event. Should the event escalate to an Alert, the On-shift Organization will be augmented by the duty Emergency Response Organization.

OSC Operations Support Center PORV Power-Operated Relief Valve 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 Implementation of strategies that involve the use of on-site portable equipment and consumables Transition Phase to extend the coping period, and prevent a loss of functions needed for core cooling, containment, Coping Actions 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.

Enclosure 2 NOC-AE-14003189 Page 4 of 29 1.0 EXECUTIVE

SUMMARY

This report presents the results of an assessment of the capability of the South Texas Project (STP) on-shift staff and augmented Emergency Response Organization (ERO) to respond to a Beyond Design Basis External Event (BDBEE). The assessment was conducted by the South Texas Project Nuclear Operating Company (STPNOC) using the methodology and guidelines presented in Nuclear Energy Institute (NEI) 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities[Reference 1].

The assumptions for the NEI 12-01 Phase 2 Staffing Assessment scenario include:

  • All units on site are impacted
  • All units are operating at full power at the time of the event
  • Access to the units by off-site responders is affected as follows:

o 0-6 hours post-event - No site access o 6-24 hours post-event - Limited site access. Individuals may access the site by walking, personal vehicle, or via alternate transportation capabilities (e.g., private resource providers or public sector support).

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

As part of the assessment, a team of subject matter experts from Operations, Operations Support, Maintenance, Radiation Protection, Chemistry, Plant Protection, Emergency Response, Licensing, and the FLEX project team conducted a tabletop assessment in August 2014. The participants reviewed the assumptions and applied procedural guidance, including draft FLEX Support Guidelines (FSGs), for coping with a BDBEE using minimum on-shift staffing. Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step.

The Phase 2 Staffing Assessment concluded that the current minimum on-shift staff, as defined in the STPEGS Emergency Plan [Reference 2], is sufficient to support the implementation of both the FLEX mitigating strategies for Units 1 and 2 for the first six hours of the event without the assignment of collateral duties that would adversely affect the ability to execute required Emergency Plan functions. The assessment also concluded that the on-shift staff is capable of implementing the necessary Transition Phase coping strategies after the initial six-hour "no site access" period with assistance from the augmented ERO.

The assessment further concluded that the existing Emergency Response program provides sufficient personnel resources and capabilities from the augmented ERO to fill all positions required for expanded emergency response functions with no emergency response functions being degraded or lost.

The FSGs will not be finalized until just prior to FLEX implementation, so the results of the assessment require validation before full implementation can be achieved. An action has been created in the site condition reporting database to track this verification. If necessary, STP will submit a supplement to this report describing any changes to the procedures that resulted in a change to the Phase 2 Staffing Assessment conclusions.

Enclosure 2 NOC-AE-14003189 Page 5 of 29

2.0 INTRODUCTION

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a 50.54(f) letter to all power reactor licensees regarding Recommendation 2.1, 2.3, and 9.3 of the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident [Reference 3].

Enclosure 5 of the 50.54(f) letter contains two information requests related to Emergency Planning: one involving performance of a staffing assessment and the other a communications assessment. The communications assessment is independent of the staffing assessment and not included as part of this report.

In NTTF Recommendation 9.3, the NRC requested that licensees assess their current staffing levels and determine the appropriate staff to fill all necessary positions for responding to a multi-unit event during a BDBEE and determine if any enhancements are needed.

NEI 12-01 establishes a two-phased approach to respond to these information requests and includes recommended criteria for use in performing the staffing assessment.

All sites with one or more operating units are required to perform a Phase 2 staffing assessment no later than four months prior to the beginning of the second refueling outage following the submittal of the site's FLEX Overall Integrated Plan (as used within the context of NRC Order EA-12-049).

The Phase 2 Staffing Assessment addresses Requested Information Items 1, 2, and 6 of NTTF Recommendation 9.3.

The NRC requested that licensees assess their current staffing levels and determine the appropriate staff to fill all necessary positions for responding to a multi-unit event during a BDBEE and determine if any enhancements are appropriate given the considerations of Near-Term Task Force (NTTF) Recommendation 9.3.

3.0 SCOPE OF THE PHASE 2 STAFFING ASSESSMENT The Phase 2 assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2, the FLEX mitigation strategies.

The intent of this assessment is to perform the following:

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

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

o Transition Phase - Implementation of strategies involving the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling.

Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.

Enclosure 2 NOC-AE-14003189 Page 6 of 29

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

  • Evaluate the EOPs and FSGs for responding to an ELAP affecting both units.
  • Evaluate whether the ability of the on-shift staff to perform any required emergency response functions would be degraded or lost prior to the arrival of the augmented ERO.
  • Consistent with the site access assumption, evaluate the ability of the on-shift staff and augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" time period.

The staffing level determined as a result of the Phase 2 assessment will be verified and validated following the finalization of the FSGs.

This Phase 2 staffing assessment is applicable to both STP Unit 1 and Unit 2.

4.0 EMERGENCY PLAN MINIMUM ON-SHIFT STAFFING Table C-1 of the STPEGS Emergency Plan lists the minimum required on-shift staffing complement for STP. Only these minimum required on-shift personnel are credited in the Phase 2 Staffing Assessment for performing Initial Phase plant operations and required emergency response functions.

Not including Plant Protection personnel, the minimum on-shift staffing consists of:

Number Personof On-shift Position Personnel Shift Managers (1 per unit) 2 Unit Supervisors (1 per unit) 2 Reactor Operators (2 per unit) 4 Plant Operators (2 per unit) 4 Communicators (1 Reactor Operator / 1 Plant Operator) 2 Senior Radiation Protection Technician 1 Radiation Protection Technicians 2 Chemistry Technician 1 Electrician 1 I&C Technician 1 Fire Brigade (Plant Operators) 5 Total 25 An excerpt of Table C-1 is shown below.

Enclosure 2 NOC-AE-14003189 Page 7 of 29 Minimum On-Shift Staffing (Source: Table C-1, STPEGS Emergency Plan [Reference 2])

MAJOR UNIT 1 UNIT 2 ONSITE FUNCTIONAL AREA ONSHIFT* ONSHIFT* ONSHIFT Shift Manager - - 2 Unit Supervisor 1 1 -

Plant Operations and Assessment of Reactor Operators 2 2 Operational Aspects Plant Operators 2 2 Shift Technical Advisor - -

Emergency Direction and Control*** Shift Manager 1** 1"*

(Emergency Director)

Notification /

Communications Radiological Accident Senior Health Physics Expertise (Dose 1 Assessment and Assessment)

Support of RP Technicians (onsite / offsite surveys) - 2 Operational Accident Assessment Chemistry Technician - 1 Plant System Shift Technical Advisor -*

Engineering Radwaste Operator 1"* 1"*

Repair and Corrective Mechanical Maintenance - 1 Action Electrical Maintenance - 1** AND 1 I&C Technician - 1 RP Technicians (Access Control / RP Protective Actions Coverage for corrective actions, search 2**

and rescue, first aid, and firefighting /

Personnel Monitoring / Dosimetry)

Fire Brigade Fire Suppression Plant Operations Personnel - per Technical I Specifications Rescue Operations Plant Protection Personnel All per and First Aid Security Plan For each unaffected unit in operation, maintain at least one Unit Supervisor, two Reactor Operators, and two Plant Operators. In accordance with Section 6.0 of the Technical Specifications for each unit, the shift crew composition may be less than the minimum number of operators (licensed or non-licensed) shown above for a period of time not to exceed two (2) hours in order to accommodate unexpected absences of on-duty shift crew members, provided immediate actions are taken to restore the crew composition. The minimum staff for a unit in cold shutdown will be one Senior Reactor Operator, one Reactor Operator, and one Plant Operator for that unit.

    • These positions may be covered by on-shift personnel assigned other functions.

Overall, direction of emergency response to be assumed by the Emergency Director at the Emergency Operations Facility when all centers are fully manned. Direction of minute-to-minute facility operation remains with senior manager in the Technical Support Center or Control Room.

Enclosure 2 NOC-AE-14003189 Page 8 of 29 5.0 PHASE 2 STAFFING ASSESSMENT FOR BDBEE / ELAP 5.1 On-shift Staff Responsibilities The on-shift staff responsibilities and actions assumed in the tabletop include:

  • The Unit 1 Shift Manager assumes the Emergency Director (ED) function.
  • The Unit 2 Shift Manager is available to assist the ED with miscellaneous communications other than ERO callout and required notifications to federal, state, and county agencies.
  • The Unit Supervisor, Reactor Operators, Plant Operators, and Maintenance staff are available to establish and maintain core cooling, spent fuel pool makeup, and electrical power restoration using Emergency Operating Procedures (EOPs) and FSGs.

" The Senior Radiation Protection Technician (SRPT) assumes the Acting Radiological Manager function in the Unit 1 Control Room. The SRPT would normally perform off-site dose assessments, however,, the ELAP does not involve fuel damage, radioactive leaks, airborne releases, or any other unusual radiological hazards so an off-site release is not expected. In addition the ELAP causes a loss of power to normal radiation monitoring instrumentation - radiological monitoring data will be provided by site surveys.

" The Radiation Protection Technicians (RPTs) are generally engaged in providing access control and job coverage inside each unit's Mechanical Auxiliary Building (MAB). It is not feasible for a single RPT to control MAB access and provide job coverage simultaneously, so the tabletop analysis assumes that access to a MAB is secured whenever the attending RPT is needed to provide job coverage. The interruption in MAB access is not considered significant given the small number of personnel assumed to be onsite.

  • The RPTs conduct in-plant and site radiation surveys when not providing access control or job coverage. The Chemistry Technician (CT) is available to assist with site surveys.
  • All Fire Brigade members (Plant Operators) are available to perform Initial and Transition Phase tasks because the assumed event does not involve a fire. Tasks include local PORV control, FLEX pump alignment, load stripping, and FLEX equipment staging.

" Plant Protection (i.e., Security) personnel were not credited with involvement in Initial or Transition Phase tasks.

5.2 Methodology STP performed a tabletop assessment to determine the required operational and emergency response actions for the minimum on-shift staff and augmenting ERO following a BDBEE and ELAP. The tabletop assessment team included representatives from Emergency Response, Operations, Operations Support, Licensing, Maintenance, Chemistry, Radiation Protection, Plant Protection, and the FLEX project team.

Enclosure 2 NOC-AE-14003189 Page 9 of 29 The assessment team reviewed the tasks of each member of the minimum on-shift staff in responding to the ELAP and constructed a timeline (Attachment 2) recording the tasks and the approximate time they would be performed following the event. Task duration was recorded in half-hour intervals. The assessment team noted all potential instances where the on-shift staff was assigned conflicting tasks or collateral duties that would distract from their ability to fulfill Emergency Plan responsibilities.

The assessment team used the guidance of NEI 10-05, Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities[Reference 4], to determine ifthe number and composition of the on-shift staff was sufficient to implement the Emergency Plan, Initial Phase actions, and, with the assistance from augmented staff, Transition Phase actions intended to maintain or restore core cooling, containment integrity, and spent fuel pool makeup for both units. The NEI 10-05 data tables have been modified to include tasks associated with FLEX strategies and are included as Attachment 1.

5.3 Staffing Assessment Assumptions The following assumptions apply from NEI 12-01:

  • A large-scale external event occurs that results in: both on-site units affected, an ELAP, and impeded access to the units

" Initially, both on-site reactors are operating at full power and are successfully shut down.

  • A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.
  • The event impedes site access as follows:

o Post event time: 0 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - no site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

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

o 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.

  • On-shift personnel are limited to the minimum complement allowed by the site emergency plan (i.e., the minimum required number for each position).

Additionally, we assumed that offsite emergency response facilities and staging areas are available including those located within the 25-mile telecommunications blackout range.

5.4 Severe Accident Management Guideline (SAMG) Usage The assessment team concluded the on-shift staff and augmented ERO would not need to perform SAMG activities as a result of the BDBEE and ELAP.

Enclosure 2 NOC-AE-14003189 Page 10 of 29 5.5 Assessment of Initial Phase Coping Strategies and Capability No significant task overlaps were identified for the Initial Phase of the event and there is no adverse impact to the ability of the on-shift staff to execute any required emergency response functions. Although it is not feasible for a single RPT to control MAB access and provide job coverage simultaneously MAB access can be secured whenever the attending RPT is needed to provide job coverage. This interruption in MAB access is not significant due the small number of personnel assumed to be onsite.

5.6 Assessment of Transition Procedures and Actions For the first six hours of the event, the Transition Phase requires the on-shift staff to provide onsite FLEX equipment and consumables to maintain or restore functions until additional resources become available from offsite. Actions include:

" Valve alignment of FLEX RCS makeup pump (FSG-3)

" DC load shedding (FSG-4)

  • Damage assessment, cabling installation, and equipment staging (FSG-5)
  • Operation of the FLEX diesel generators (FSG-19)

Following the initial six hour "no site access" period, the augmented ERO and on-shift staff perform Transition Phase tasks including:

  • Connection of trailer-mounted pumps to use the Essential Cooling Water (ECW) pond as a suction source (FSG-3)
  • Continued operation of the FLEX diesel generators (FSG-19)
  • National SAFER Response Center (NSRC) generator hookup (FSG-21)

Transition Phase functions to be performed by the expanded ERO are described in Attachment 3.

6.0 AUGMENTED EMERGENCY RESPONSE ORGANIZATION (ERO) 6.1 ERO Response As described in the STPNOC Phase 1 Staffing Assessment [Reference 5], the augmented ERO has been trained to automatically report to the Emergency Operations Facility when made aware of a large-scale external event even if no call-out notifications are received.

Methods of access to the site expected to be available after a widespread large scale natural event are listed in the STP response to Requested Information Item 4

[Reference 6]:

  • STP has multiple roadways to access the site:

o From the West - Highway 521 o From the North - Farm to Market (FM) 1468 o From the East - Highway 521

Enclosure 2 NOC-AE-14003189 Page 11 of 29

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

The river can be used to transport personnel and small equipment by boat from surrounding areas to the site.

" Helicopters can be used to transport personnel to the site.

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

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

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

The process used by the ERO for obtaining emergency assistance from Matagorda County, the Texas Department of Public Safety, and the US Coast Guard is explained in the Phase 1 Staffing Assessment [Reference 5].

6.2 Expanded Emergency Response The methods to augment the ERO are described in the STPNOC Phase 1 Staffing Assessment including work locations and transportation to the site [Reference 5]. The Phase 2 Staffing Assessment revised the expanded emergency response table, Table 5-2, of the Phase 1 Assessment by including the expanded response functions from Table 3.2 of NEI 12-01. These additional response functions are detailed in Attachment 3.

Enclosure 2 NOC-AE-14003189 Page 12 of 29 7.0 PHASE 2 STAFFING ASSESSMENT CONCLUSIONS 7.1 Staffing Level The Phase 2 Staffing Assessment concluded that the current minimum on-shift staff and augmented ERO are sufficient for executing all required initial and any necessary transition phase actions for the diverse and flexible coping (FLEX) strategies without the assignment of collateral duties that would adversely affect the ability to execute required Emergency Plan functions. No change to the on-shift staffing level or augmented ERO is required.

7.2 Task Analysis Results Refer to Attachment 1, Phase 2 Staffing Assessment Tabletop Data, and Attachment 2, Task Implementation Timeline, for details of on-shift staffing tasks. No unassigned tasks were identified and no task overlaps that would adversely affect the ability to execute necessary response actions or required Emergency Plan functions were performed by the on-shift staff.

Task performance times were the best estimate of the assessment team based on operating experience.

7.3 Time Motion Study Results No collateral tasks that would adversely affect the ability to execute necessary response actions or required Emergency Plan functions were identified therefore a time motion study was not required.

7.4 Augmented and Expanded ERO Assessment Results The existing ERO is sufficient to fill augmented ERO positions and those positions needed to support expanded response positions for responding to a BDBEE affecting both units.

7.5 Identified Issues The assessment team noted one issue that has the potential to influence the validity of the assessment results. Draft versions of the FSGs were used for this assessment and the FSGs will not be finalized until just prior to FLEX implementation, so the results of the assessment require validation before full implementation can be achieved. This issue is being tracked through the site condition reporting process'.

Upon finalization of the FSGs, a gap analysis will be performed between the final FSGs and the draft versions used in this assessment and the assessment results will be validated against any differences. If necessary, STP will submit a supplement to this report describing any changes to the procedures that resulted in a change to the Phase 2 Staffing Assessment conclusions.

1 See Condition Report (CR) action #12-11657-35

Enclosure 2 NOC-AE-14003189 Page 13 of 29

8.0 REFERENCES

1. Nuclear Energy Institute (NEI) 12-01, Revision 0, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", May 4, 2012 (ML12125A412)
2. South Texas Project Electric Generating Station Emergency Plan, Revision 20
3. Letter from E.J. Leeds, NRC, to All Power Reactor Licensees, "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", March 12, 2012 (ML12053A340)
4. NEI 10-05, Revision 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities", June 23, 2011 (ML111751698)
5. Letter from G.T. Powell, STPNOC, to NRC Document Control Desk, "Revised Phase 1 Staffing Assessment Submitted in 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-lchi Accident", June 3, 2013 (ML13182A021)
6. Letter from D.W. Rencurrel, STPNOC, to NRC Document Control Desk, "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 Dai-ichi Accident", June 4, 2012 (ML12163A331) 9.0 ATTACHMENTS Attachment 1 - Phase 2 Staffing Assessment Tabletop Data Attachment 2 - Task Implementation Timeline Attachment 3 - Expanded Emergency Response Functions

Enclosure 2 NOC-AE-14003189 Page 14 of 29 Attachment 1 Phase 2 Staffing Assessment Tabletop Data

Enclosure 2 NOC-AE-14003189 Page 15 of 29 Phase 2 Staffing Assessment Tabletop Data Accident Summary:

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

o Extended loss of AC power (ELAP) to both units o Impeded access to both units.

  • Initially, both units are operating at full power and are successfully shut down.
  • The event involves a loss of offsite power and a failure of all emergency AC power sources resulting in an ELAP. All emergency diesel generators experience a catastrophic failure resulting in a complete loss of all AC power.
  • The event prompts the declaration of a Site Area Emergency which is upgraded to a General Emergency when it is determined that power cannot be restored within four hours.
  • The complement of on-shift personnel is limited to minimum staffing described in Table C-1 of the STPEGS Emergency Plan. On-shift personnel respond as shown in Attachment 2.

Emergency Operating Procedures Reviewed:

" OPOP05-EO-ECOO, Rev. 23 - Loss of All AC Power

  • ECA-0.0 (Draft) - Loss of All AC Power Draft Fukushima Support Guidelines Reviewed:
  • OPOPi 2-ZO-FSGO3 - Alternate Low Pressure Feedwater
  • OPOP12-ZO-FSG04 - ELAP DC Bus Load Shed / Management
  • OPOP12-ZO-FSGO5 - Initial Assessment and FLEX Equipment Staging

" OPOP12-ZO-FSGO9 - Low Decay Heat Temperature Control

  • OPOP1 2-ZO-FSGO19 - 480V FLEX Diesel Generator Operation

Enclosure 2 NOC-AE-14003189 Page 16 of 29 Note: Tables 1-5 are modified from NEI 10-05 to reflect FLEX implementation tasks [Reference 4].

TABLE 1 - ON-SHIFT POSITIONS On-shift Position Role Unanalyzed Collateral (Ref.: Table C-1, STPEGS Emergency Plan) (Table # / Line#) Task? Tasks?2 1 Unit 1 Shift Manager (Ul SM) T2/L1 No No T5/L1 T5/L2 T5/L3 T5/L5 2 Unit 1 Unit Supervisor (Ul US) T2/L2 No No 3 Unit 1 Reactor Operator 1 (Ul RO1) T2/L3 No No 4 Unit 1 Reactor Operator 2 (Ul RO2) T2/L4 No No 5 Unit 1 Plant Operator 1 (Ul P01) T2/L5 No No 6 Unit 1 Plant Operator 2 (Ul P02) T2/L6 No No 7 Unit 2 Shift Manager (U2 SM) T2/L7 No No 8 Unit 2 Unit Supervisor (U2 US) T2/L8 No No

.9 Unit 2 Reactor Operator 1 (U2 RO1) T2/L9 No No 10 Unit 2 Reactor Operator 2 (U2 R02) T2/L10 No No 11 Unit 2 Plant Operator 1 (U2 P01) T2/L1 1 No No 12 Unit 2 Plant Operator 2 (U2 P02) T2/L12 No No 13 State & County Communicator (XO1) T5/L8 No No T5/L9 14 NRC Communicator (X02) T5/L6 No No T5/110 T5/L 13 15 Electrician (El) T2/L18 No No 16 I&C Technician (IC1) T2/L19 No No 17 Senior Radiation Protection Technician (SRPT) T2/L20 No No 18 Radiation Protection Technician 1 (RPT1) T2/L21 No No T4/L1 T4/1L5 T4/L8 19 Radiation Protection Technician 2 (RPT2) T2/L22 No No T4/1L2 T4/1L6 T4/1L9 20 Chemistry Technician (CT1) T2/L23 No No T4/1L3 T4/L 10 21 Fire Brigade 1 (FB1) T2/L13 No No 22 Fire Brigade 2 (FB2) T2/L14 No No 23 Fire Brigade 3 (FB3) T2/L15 No No 24 Fire Brigade 4 (FB4) T2/L16 No No 25 Fire Brigade 5 (FB5) T2/L17 No No 26 Plant Protection T5/15 No No 2 Refer to Attachment 2 for the task timeline

Enclosure 2 NOC-AE-1 4003189 Page 17 of 29 TABLE 2 - PLANT OPERATIONS AND SAFE SHUTDOWN Minimum Operations Crew Necessary to Implement AOPs, EOPs, SAMGs, or FSGs Line # Generic Title/Role On-shift Position Task Analysis Controlling Method 1 Shift Manager Unit 1 Shift Manager (Ul SM) Licensed Operator Training Program 2 Unit Supervisor Unit 1 Unit Supervisor (Ul US) Licensed Operator Training Program 3 Reactor Operator 1 Unit 1 Reactor Operator 1 (Ul RO1) Licensed Operator Training Program 4 Reactor Operator 2 Unit 1 Reactor Operator 2 (Ul R02) Licensed Operator Training Program 5 Plant Operator 1 Unit 1 Plant Operator 1 (Ul P01) Non-licensed Operator Training Program 6 Plant Operator 2 Unit 1 Plant Operator 2 (U1 P02) Non-licensed Operator Training Program 7 Shift Manager Unit 2 Shift Manager (U2 SM) Licensed Operator Training Program 8 Unit Supervisor Unit 2 Unit Supervisor (U2 US) Licensed Operator Training Program 9 Reactor Operator 1 Unit 2 Reactor Operator 1 (U2 RO1) Licensed Operator Training Program 10 Reactor Operator 2 Unit 2 Reactor Operator 2 (U2 R02) Licensed Operator Training Program 11 Plant Operator 1 Unit 2 Plant Operator 1 (U2 P01) Non-licensed Operator Training Program 12 Plant Operator 2 Unit 2 Plant Operator 2 (U2 P02) Non-licensed Operator Training Program 13 Fire Brigade 1 (Plant Operator) Fire Brigade 1 (FB1) Non-licensed Operator Training Program 14 Fire Brigade 2 (Plant Operator) Fire Brigade 2 (FB2) Non-licensed Operator Training Program 15 Fire Brigade 3 (Plant Operator) Fire Brigade 3 (FB3) Non-licensed Operator Training Program 16 Fire Brigade 4 (Plant Operator) Fire Brigade 4 (FB4) Non-licensed Operator Training Program 17 Fire Brigade 5 (Plant Operator) Fire Brigade 5 (FB5) Non-licensed Operator Training Program Other Personnel Necessary to Implement AOPs, EOPs, SAMGs, or FSGs Line # Generic Title/Role On-shift Position Task Analysis Controlling Method 18 Eledtrtician Electrician (El) N/A 19 I&C Technician I&C Technician (IC1) N/A 20 Senior Radiation Protection Senior Radiation Protection N/A Technician Technician (SRPT) 21 Radiation Protection Technician 1 Radiation Protection Technician 1 N/A (RPT1) 22 Radiation Protection Technician 2 Radiation Protection Technician 2 N/A (RPT2) 23 Chemistry Technician Chemistry Technician (CT1) N/A

Enclosure 2 NOC-AE-14003189 Page 18 of 29 TABLE 3- FIREFIGHTING Line # Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A

Enclosure 2 NOC-AE-14003189 Page 19 of 29 TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Line Position Performance Time Period after Event (Hours)

  1. Performing 0.0- 0.5- 1.0- 1.5- 2.0- 2.5- 3.0- 3.5- 4.0- 4.5- 5.0- 5.5-Function / Task 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0 5.5 6.0 1 In-plant survey Radiation Protection X X Technician 1 (RPT1) 2 On-site survey Radiation Protection X X Technician 2 (RPT2) 3 On-site survey Chemistry Technician X X X X X X X X X (CT1) 4 RP personnel do not perform personnel monitoring. The ELAP does not involve fuel Personnel monitoring damage, radioactive leaks, airborne releases, or any other unusual radiological hazards. All on-shift personnel entering an RCA carry electronic dosimeters with pocket dosimeters available as backup if needed.

5 Job coverage (Unit 1)Y Radiation Protection X X X X X X X X X X Technician 1 (RPT1) 6 Job coverage (Unit 2 )3 Radiation Protection X X X X X X X X X X Technician 2 (RPT2) 7 Off-site radiological The ELAP does not involve fuel damage, radioactive leaks, airborne releases, or any assessment other unusual radiological hazards.

N/A 8 RCA access control (UnitX X X X X X X X X X Radiation Protection Technician 1 (RPT1) 9 RCA access control (UnitX X X X X X X X X X Radiation Protection Technician 2 (RPT2) 10 Secure secondary sample lineups Chemistry Technician X X (CT1) 3 RPT1 and RPT2 provide both job coverage and RCA access control for the Unit 1 and Unit 2 Mechanical Auxiliary Buildings (MABs), respectively. Both tasks cannot be performed simultaneously by a single RPT, so access to a MAB is curtailed while the RPT is performing job coverage.

Enclosure 2 NOC-AE-14003189 Page 20 of 29 TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Line # Function / Task On-shift Position Task Analysis Controlling Method 1 Declare the Emergency U1 SM Operations Training Program Classification Level (ECL) Emergency Preparedness Drill Program 2 Approve off-site Protective Action U1 SM Operations Training Program Recommendations Emergency Preparedness Drill Program 3 Approve content of state and U1 SM Operations Training Program local notifications Emergency Preparedness Drill Program 4 Approve extension of allowable N/A N/A dose limits Notification and direction to on-5 shift staff (e.g., assembly, U1 SM Operations Training Program evacuation, etc.) Emergency Preparedness Drill Program 6 ERO notification XO2 Operations Training Program Emergency Preparedness Drill Program Abbreviated NRC notification for N/A N/A DBT event 8 Complete state / local notification XO1 Operations Training Program form Emergency Preparedness Drill Program 9 Perform state and local XO1 Operations Training Program notifications Emergency Preparedness Drill Program 10 Complete NRC event notification X02 Operations Training Program form Emergency Preparedness Drill Program 11 Activate ERDS 4 N/A N/A 5

12 Offsite radiological assessment N/A N/A 13 Perform NRC notifications X02 Operations Training Program Emergency Preparedness Drill Program Perform other site-specific event 14 notifications (e.g., INPO, ANI, N/A N/A etc.)

15 Personnel accountability Plant Protection Security Training Program I Emergency Preparedness Drill Program 4 ERDS is continuously activated.

5 The ELAP does not involve fuel damage, radioactive leaks, airbome releases, or any other unusual radiological hazards. Since this event will not result in a radioactive release, NEI 10-05 states that this column should be entered as "N/A" [Reference 4].

Enclosure 2 NOC-AE-14003189 Page 21 of 29 Attachment 2 Task Implementation Timeline

Enclosure 2 NOC-AE-14003189 Page 22 of 29 Task Implementation Timeline Unit Position Time (Hrs) Task Collateral Duty?

I Shift Manager (Ul SM) 1. 0.0-0.5 1. Assume duties of Emergency Director. Classify event as Site Area No Emergency.

2. 0.5-1.0 2. Upgrade event to General Emergency. Make Protective Action Recommendations.
3. 1.0-6.0 3. Continue executing the duties of Emergency Director until relieved by augmented ERO.

1 Unit Supervisor (Ul US) 1. 0.0-6.0 1. Direct and supervise performance of Emergency Operating No Procedures (EOPs) and Fukushima Support Guidelines (FSGs).

1 Reactor Operator 1 (UI R01) 1. 0.0-0.5 1. Perform post-trip immediate actions. Dispatch Ul P01 to strip No sequencers and align Positive Displacement Pump (PDP).

2. 0.5-1.0 2. Establish steam generator PORV control. Monitor primary system parameters. Establish hand switch lineup.
3. 1.0-3.0 3. Support plant cooldown. Maintain steam generator PORV control.

Monitor primary system parameters.

4. 3.0-6.0 4. Stabilize plant at 410 psig secondary pressure.
5. 6.0-6.5 5. Isolate accumulators.

1 Reactor Operator 2 (U1 R02) 1. 0.0-0.5 1. Perform post-trip immediate actions. Align AFW to 1D steam No generator. Dispatch Ul P02 to cross-connect steam generators.

2. 0.5-1.0 2. Commence plant cooldown to 410 psig secondary pressure.
3. 1.0-3.0 3. Continue plant cooldown.
4. 3.0-6.5 4. Stabilize plant at 410 psig secondary pressure.
5. 6.5-8.0 5. Continue cooldown to 300OF primary temperature.

1 Plant Operator 1 (Ul P01) 1. 0.0-0.5 1. Transfer station blackout switches. Strip sequencers. No

2. 0.5-1.0 2. Perform load stripping per ECO.0.
3. 1.0-2.0 3. Perform deep load stripping per FSG-4.
4. 2.0-2.5 4. Perform electrical lineup and start FLEX diesel generator.
5. 2.5-3.0 5. Load initial FLEX communications equipment and lighting onto FLEX diesel generator.
6. 3.0-3.5 6. Energize A battery charger and exhaust fan.
7. 3.5-4.0 7. Energize C battery charger and exhaust fan.
8. 4.0-4.5 8. Energize 14M and 14N lighting panels.
9. 4.5-5.0 9. Energize 14L and 14U lighting panels.

110. 6.0-6.5 10. Align breakers for accumulator isolation.

Enclosure 2 NOC-AE-14003189 Page 23 of 29 Position Time (Hrs) Task Collateral Unit 1 Plant Operator 2 (Ul P02) 1. 0.0-1.0 1. Align RWSTNCT charging and letdown valves. No

2. 1.0-1.5 2. Perform valve lineup for powering PDP from FLEX diesel generator. Verify spent fuel pool level.
3. 2.5-4.5 3. Start and control PDP.
4. 4.5-5.5 4. Inspect power block for damage and flooding.

2 Shift Manager (U2 SM) 1. 0.0-6.0 1. Assess unit status. Assist Unit Supervisor as needed. No Communicate with Unit 1 as required.

2 Unit Supervisor (U2 US) 1. 0.0-6.0 1. Direct and supervise performance of Emergency Operating No Procedures (EOPs) and Fukushima Support Guidelines (FSGs).

2 Reactor Operator 1 (U2 RO1) 1. 0.0-0.5 1. Perform post-trip immediate actions. Dispatch U2 P01 to strip No sequencers and align Positive Displacement Pump (PDP).

2. 0.5-1.0 2. Establish steam generator PORV control. Monitor primary system parameters. Establish hand switch lineup.
3. 1.0-3.0 3. Support plant cooldown. Maintain steam generator PORV control.

Monitor primary system parameters.

4. 3.0-6.0 4. Stabilize plant at 410 psig secondary pressure.
5. 6.0-6.5 5. Isolate accumulators.

2 Reactor Operator 2 (U2 R02) 1. 0.0-0.5 1. Perform post-trip immediate actions. Align AFW to 2D steam No generator. Dispatch U2 P02 to cross-connect steam generators.

2. 0.5-1.0 2. Commence plant cooldown to 410 psig secondary pressure.
3. 1.0-3.0 3. Continue plant cooldown.
4. 3.0-6.5 4. Stabilize plant at 410 psig secondary pressure.
5. 6.5-8.0 5. Continue cooldown to 300°F primary temperature.

2 Plant Operator 1 (U2 P01) 1. 0.0-0.5 1. Transfer station blackout switches. Strip sequencers. No

2. 0.5-1.0 2. Perform load stripping per ECO.0.
3. 1.0-2.0 3. Perform deep load stripping per FSG-4.
4. 2.0-2.5 4. Perform electrical lineup and start FLEX diesel generator.
5. 2.5-3.0 5. Load initial FLEX communications equipment and lighting onto FLEX diesel generator.
6. 3.0-3.5 6. Energize A battery charger and exhaust fan.
7. 3.5-4.0 7. Energize C battery charger and exhaust fan.
8. 4.0-4.5 8. Energize 14M and 14N lighting panels.
9. 4.5-5.0 9. Energize 14L and 14U lighting panels.
10. 6.0-6.5 10. Align breakers for accumulator isolation.

Enclosure 2 NOC-AE-14003189 Page 24 of 29 Unit Position Time (Hrs) Task Collateral Duty?

2 Plant Operator 2 (U2 P02) 1. 0.0-1.0 1. Align RWST/VCT charging and letdown valves. No

2. 1.0-1.5 2. Perform valve lineup for powering PDP from FLEX diesel generator. Verify spent fuel pool level.
3. 2.5-4.5 3. Start and control PDP.
4. 4.5-5.5 4. Inspect power block for damage and flooding.

State & County Communicator (XO1) 1. 0.0-0.5 1. Perform state and county notifications. No

2. 0.5-1.0 2. Perform state and county notifications.
3. 1.0-1.5 3. Perform deep load stripping for Unit 1 per FSG-4.
4. 1.5-2.0 4. Perform state and county follow-up notifications.
5. 2.5-3.0 5. Perform state and county follow-up notifications.
6. 3.0-3.5 6. Transfer satellite telephone to Unit 1 Control Room per FSG-5.
7. 3.5-4.0 7. Perform state and county follow-up notifications.
8. 4.5-5.0 8. Perform state and county follow-up notifications.
9. 5.5-6.0 9. Perform state and county follow-up notifications.
10. 6.0-7.0 10. Turn over Communicator duties to augmented ERO.
11. 8.0-9.5 11. Connect hoses for Unit 2 FLEX RCS makeup pump.
12. 9.5-10.5 12. Connect hoses for Unit 2 FLEX SFP makeup pump.

- NRC Communicator (X02) 1. 0.0-0.5 1. Perform ERO callout and ENS communications.

2. 0.5-6.0 2. Perform ENS communications.

- Electrician (El) 1. 0.0-0.5 1. Perform setup of OSC.

2. 0.5-1.5 2. Connect cables to Unit 1 MCC EIA2 per FSG-5.
3. T1.5-2.5 3. Connect cables to Unit 1 MCC EIC2 per FSG-5.
4. 2.5-3.5 4 Connect cables to Unit 1 MCC E1A4 per FSG-5.
5. 3.5-4.5 5. Connect cables to Unit 1 MCC El B4 per FSG-5.
6. 4.5-5.5 6. Connect cables to Unit 1 MCC E1C4 per FSG-5.

- I&C Technician (ICI) 1. 0.0-0.5 1. Perform setup of OSC.

2. 0.5-1.5 2. Connect cables to Unit 2 MCC E2A2 per FSG-5.
3. 1.5-2.5 3. Connect cables to Unit 2 MCC E2C2 per FSG-5.
4. 2.5-3.5 4 Connect cables to Unit 2 MCC E2A4 per FSG-5.
5. 3.5-4.5 5. Connect cables to Unit 2 MCC E2B4 per FSG-5.
16. 4.5-5.5 6. Connect cables to Unit 2 MCC E2C4 per FSG-5.

- Senior Radiation Protection Technician (SRPT) 1. 0.0-6.0 1. Assumes duties of Acting Radiological Manager in Unit 1 Control Room.

Enclosure 2 NOC-AE-14003189 Page 25 of 29 Unit Position Time (Hrs) Task Collateral Duty?

Radiation Protection Technician 1 (RPT1) 1. 0.0-1.5 1. Provide access control for Unit 1 MAB and job coverage for No operators as needed. (Note: Access to MAB suspended while RPT1 provides job coverage.)

2. 1.5-2.5 2. Perform in-plant surveys.
3. 2.5-6.0 3. Provide access control for Unit 1 MAB and job coverage for operators as needed. (Note: Access to MAB suspended while RPT1 provides job coverage.)

Radiation Protection Technician 2 (RPT2) 1. 0.0-1.5 1. Provide access control for Unit 2 MAB and job coverage for No operators as needed. (Note: Access to MAB suspended while RPT2 provides job coverage.)

2. 1.5-2.5 2. Perform site surveys.
3. 2.5-6.0 3. Provide access control for Unit 2 MAB and job coverage for operators as needed. (Note: Access to MAB suspended while RPT2 provides job coverage.)

Chemistry Technician (CT1) 1. 0.0-1.0 1. Secure secondary sample panel valve lineups. No

2. 1.0-6.0 2. Perform site surveys.

Fire Brigade 1 (FB1) 1. 0.0-0.5 1. Perform Unit 1 TSC diesel generator checks. No

2. 0.5-1.0 2. Attempt local start of Unit 1 EDGs.
3. 1.0-6.0 3. Perform local control of SG PORV. Observe areas for potential internal flooding.
4. 6.0-6.5 4. Align Unit 1 FLEX SG makeup pump per FSG-3.
5. 6.5-7.0 5. Start Unit 1 FLEX SG makeup pump per FSG-3.
6. 7.0-7.5 6. Secure Unit 1 turbine-driven AFW pump per FSG-9.

Fire Brigade 2 (FB2) 1. 0.0-0.5 1. Perform Unit 2 TSC diesel generator checks. No

2. 0.5-1.0 2. Attempt local start of Unit 2 EDGs.
3. 1.0-6.0 3. Perform local control of SG PORV. Observe areas for potential internal flooding.
4. 6.0-6.5 4. Align Unit 2 FLEX SG makeup pump per FSG-3.
5. 6.5-7.0 5. Start Unit 2 FLEX SG makeup pump per FSG-3.
6. 7.0-7.5 6. Secure Unit 2 turbine-driven AFW pump per FSG-9.

Enclosure 2 NOC-AE-1 4003189 Page 26 of 29 Position Time (Hrs) Task Collateral Unit

__ Duty?

Fire Brigade 3 (FB3) 1. 0.0-0.5 1. Perform AFW cross-connect lineup for Unit 1. No

2. 0.5-1.0 2. Perform Unit 1 breaker alignments in preparation for FSG-5.
3. 1.0-2.0 3. Connect hoses for Unit 1 SG makeup pump per FSG-5.
4. 2.0-2.5 4. Perform Unit 1 MCC load stripping per FSG-5.
5. 2.5-3.0 5. Perform initial Unit 1 battery charger breaker alignments per FSG-4.
6. 3.0-4.0 6. Perform lineup for filling FLEX diesel generator fuel Oil storage tank per FSG-19.
7. 4.0-4.5 7. Move portable radios and chargers from OSC break room to Unit 1 Control Room per FSG-5.
8. 4.5-6.0 8. Transport trailer-mounted FLEX pump and hose trailer to Protected Area 6.
9. 6.0-7.0 9. Fill Unit 1 FLEX diesel generator fuel oil storage tank per FSG-1 9.
10. 12.0-13,0 10. Fill Unit 1 FLEX diesel generator fuel oil storage tank per FSG-1 9.
11. 18.0-19.0 11. Fill Unit 1 FLEX diesel generator fuel oil storage tank per FSG-19.
12. 23.5-24.5 12. Fill Unit 1 FLEX diesel generator fuel oil storage tank per FSG-19.

Fire Brigade 4 (FB4) 1. 0.0-0.5 1. Perform AFW cross-connect lineup for Unit 2. No

2. 0.5-1.0 2. Perform Unit 2 breaker alignments in preparation for FSG-5.
3. 1.0-2.0 3. Connect hoses for Unit 2 SG makeup pump per FSG-5.
4. 2.0-2.5 4. Perform Unit 2 MCC load stripping per FSG-5.
5. 2.5-3.0 5. Perform initial Unit 2 battery charger breaker alignments per FSG-4.
6. 3.0-4.0 6. Perform lineup for filling FLEX diesel generator fuel oil storage tank per FSG-19.
7. 4.0-4.5 7. Move portable radios and chargers from OSC break room to Unit 2 Control Room per FSG-5.
8. 4.5-6.0 8. Transport trailer-mounted FLEX pump and hose trailer to 6

Protected Area6.

9. 6.0-6.5 9. Fill Unit 2 FLEX diesel generator fuel oil storage tank per FSG-1 9.
10. 12.0-13.0 10. Fill Unit 2 FLEX diesel generator fuel oil storage tank per FSG-19.
11. 18.0-19.0 11. Fill Unit 2 FLEX diesel generator fuel oil storage tank per FSG-19.
12. 23.5-24.5 12. Fill Unit 2 FLEX diesel generator fuel oil storage tank per FSG-19.

6 This action can be performed as early as 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event but could wait until the expanded ERO arrives.

Enclosure 2 NOC-AE-14003189 Page 27 of 29 Position Time (Hrs) Task Collateral Unit Duty?

- Fire Brigade 5 (FB5) 1. 0.0-1.0 1. Conduct plant damage assessment per FSG-5. No

2. 1.0-1.5 2. Perform deep load stripping for Unit 2 per FSG-4.
3. 1.5-2.5 3. Conduct plant damage assessment per FSG-5.
4. 2.5-3.5 4. Open QPDS cabinet doors in Unit 1 and Unit 2 per FSG-5.
5. 3.5-4.0 5. Transfer TSC satellite phone to Unit 2 Control Room per FSG-5.
6. 4.5-6.0 6. Transport trailer-mounted FLEX pump and hose trailer to Protected Area.
7. 8.0-9.5 7. Connect hoses for Unit 1 FLEX RCS makeup pump per FSG-5.
8. 9.5-10.5 8. Connect hoses for Unit 1 FLEX SFP makeup pump per FSG-5.

- Mechanic 1 (MI) 1. 8.0-10.5 1. Connect hoses for Unit 2 FLEX makeup pumps per FSG-5. N/A

- Electrician 2 (E2) 1. 8.0-10.5 1. Connect hoses for Unit 1 FLEX makeup pumps per FSG-5. N/A

- Radiation Protection Technician 3 (RPT3) 1. 8.0-10.5 1. Provide job coverage for Unit 1 FLEX makeup pump hose team. N/A Radiation Protection Technician 4 (RPT4) 1. 8.0-10.5 1. Provide job coverage for Unit 2 FLEX makeup pump hose team. N/A Radiation Protection Technician 5 (RPT5) 1. 6.0-24.0 1. Conduct offsite surveys. N/A Radiation Protection Technician 5 (RPT5) 1. 6.0-24.0 1. Conduct offsite surveys. N/A

Enclosure 2 NOC-AE-14003189 Page 28 of 29 Attachment 3 Expanded Emergency Response Functions

Enclosure 2 NOC-AE-14003189 Page 29 of 29 Expanded Emergency Response Functions Note: The expanded emergency response functions occur at least 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following event initiation. This Table has been adapted from Table 3.2 of NEI 12-01 [Reference 1].

Expanded Total Number Required for Response Location Key Roles and Considerations Units 1&2 Function Evaluation of TSC /

  • One team for each unit to Unit 1 Transition EOF evaluate selection of Transition 1 TSC Manager/ Asst.

Phase Coping coping strategies; team performs TSC Manager Strategies evaluations not done by Control 1 Operations Manager / Assistant Room personnel Operations Manager

  • Team composition (i.e., number 1 TSC Technical Manager/

and represented disciplines) as Engineering Supervisor described in governing site 1 Nuclear Engineer programs, procedures, and 1 Mechanical Engineer guidelines 1 Electrical Engineer

" Team may include personnel 1 Radiological Manager / Asst.

responsible for performing other Radiological Manager functions for the same assigned Unit2 unit 1 TSC Manager / Asst. TSC Manager 1 Operations Manager / Assistant Operations Manager 1 TSC Technical Manager/

Engineering Supervisor 1 Nuclear Engineer 1 Mechanical Engineer 1 Electrical Engineer 1 Radiological Manager / Asst.

Radiological Manager Implementation OSC I Number and composition of Unit 1 of Transition TSC personnel capable of 5 Plant Operators 8 Phase Coping simultaneous implementation of 2 Electricians Strategies any two Transition Phase coping 1 Electrical Engineer 9 strategies at each unit 7 3 Others1 ° (Electricians, I&C

" Should not include personnel Technicians, Mechanics, or assigned to other functions (e.g., Plant Operators) emergency repair and corrective actions); however, may include Unit 2 members of the on-shift staff and 4 Plant Operators personnel responsible for 2 Electricians implementation of SAM strategies 3 Others 9 (Electricians, i&C Technicians, Mechanics, or Plant Operators) 7 The two most personnel-intensive Transition Phase tasks performed following the end of the "no site access" period are connecting the trailer-mounted pumps to use the ECW pond as a suction source

ýfrom FSG-3, Addendum 7) and NSRC generator hookup (from FSG-21)

Additional Plant Operator needed from one Unit to operate the pump for FSG-3, Addendum 7 9 Electrical Engineer provides technical assistance to both units when energizing a 4160V Engineered Safety Feature bus with the NSRC generator.

10 Any combination of three individuals from this group can assist in connecting and running hoses for FSG-3, Addendum 7

Enclosure 3 NOC-AE-14003189 Enclosure 3 List of Commitments

Enclosure 3 NOC-AE-14003189 Page 1 of 1 List of Commitments The following table identifies the action to which the STP Nuclear Operating Company (STPNOC) has committed. Statements in this submittal with the exception of those in the table below are provided for information purposes and are not considered commitments.

Scheduled Due Condition Commitments Date Report End of refueling outage 2RE17 Procedures and/or training programs will be revised to ensure that Chemistry Technicians retain the 12-11657-36 ability to perform on-site surveys. (Estimated date 4/30/2015)

Note: The scheduled due date was chosen to align with the compliance date for NRC Order EA-12-049 for STP Unit 2.

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