NRC-15-0040, Emergency Preparedness Phase 2 Staffing Assessment
| ML15107A399 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 04/17/2015 |
| From: | Kaminskas V DTE Energy |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NRC-15-0040 | |
| Download: ML15107A399 (32) | |
Text
Vito A. Kaminskas Site Vice President DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.6515 Fax: 734.586.4172 Email: kaminskasv@dteenergy.com DTE Energy April 17, 2015 NRC-15-0040 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
References:
- 1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
- 2) U.S. Nuclear Regulatory Commission, "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)
- 3) Nuclear Energy Institute, "Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,"
Revision 0, May 2012 (ML12125A412)
- 4) U.S. Nuclear Regulatory Commission Letter to Ms. Susan Perkins-Grew, Emergency Preparedness Director, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Review of NEI 12-01,
'Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, Dated May 2012,"' May 15, 2012 (ML12131A043)
Subject:
Emergency Preparedness Phase 2 Staffing Assessment On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued "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" (Reference 2). Enclosure 5 of Reference 2 contained specific requested actions and information associated with Recommendation 9.3 for Emergency Preparedness Programs, including a Staffing Assessment.
US NRC NRC-15-0040 Page 2 The enclosure to this letter provides the Phase 2 Staffing Assessment Report for DTE Electric Company's Fermi 2 Nuclear Power Plant. The report follows the assessment process provided in the Nuclear Energy Institute report 12-01, "Guidelines for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,"
Revision 0, dated May 2012 (Reference 3), which was endorsed by NRC staff on May 15, 2012 (Reference 4). This letter contains no new regulatory commitments.
Should you have any questions or require additional information, please contact Mr.
Christopher Robinson, Licensing Manager at (734) 586-5076.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 17, 20 5 Vito A. Kaminskas Site Vice President Nuclear Generation
Enclosure:
Staffing Assessment Report cc:
Director, Office of Nuclear Reactor Regulation NRC Project Manager NRC Resident Office Reactor Projects Chief, Branch 5, Region III Regional Administrator, Region III Michigan Public Service Commission, Regulated Energy Division (kindschl(almichigan. ov)
Enclosure to NRC-15-0040 Staffing Assessment Report
Enrico Fermi Unit 2 Nuclear Power Plant z-Lm FUKUSHIMA RESPONSE NEI 12-01 PHASE 2 STAFFING ASSESSMENT REPORT FEBRUARY 12, 2015
Table of Contents Introduction and Definitions.........................................................................................................................
1 NEI (Phase 2) Staffing Assessment Process Overview................................................................................ 2 NEI (Phase 2) Staffing Assessment Results.............................................................................................
3 Follow-up Actions........................................................................................................................................
4 NEI (Phase 2) Staffing Assessment Details for Fermi 2...............................................................................5 NEI (Phase 2) Staffing Assessment Assumptions....................................................................................
6 Site Specific
References:
8 M ethodology.................................................................................................................................................9 Security Considerations................................................................................................................................
9 Appendix 1 - Tables....................................................................................................................................10 Table 1 - On-shift Positions Roles.............................................................................................................
11 Table 2 - Plant Operations & Safe Shutdown Minimum Operations Crew Necessary to Implement AOPs and EOPs, or FSGs if applicable.................................................................................................................12 Table 2A - Procedure Task Timing to Implement ELAP (First 6 Hours)..................................................13 Table 2B - Procedure Task Timing to Implement ELAP (Hours 7-24).....................................................16 Table 3 - Firefighting.................................................................................................................................
17 Table 4 - Radiation Protection & Chemistry..............................................................................................18 Table 5 - Emergency Plan Implementation................................................................................................19 Table 6 - Emergency Plan Implementation Timeline............................................................................
20 Table 7 - On-shift Staff Usage...................................................................................................................
21 Table 7A - On-shift Usage Table for First 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />...............................................................................
22 Table 8 - Strategy Resource Loading....................................................................................................
23 Table 9 - Communication Table.................................................................................................................25 Table 10 - Augmenting Emergency Response Organization................................................................
26 i
Introduction and Definitions This report documents the analysis performed by DTE Electric Company (DTE) to meet the commitments for conducting a staffing assessment for a Beyond Design Basis External Event (BDBEE) affecting the Fermi 2 Nuclear Power Plant to determine the response of on-shift and augmented resources to an Extended Loss of AC Power (ELAP) incident impacting a site. This report uses the terms, definitions, and acronyms commonly used in the U.S.
Nuclear Regulatory Commission (NRC) report, "The Near-term Task Force Review of Insights from Fukushima Dai-ichi Accident," and NRC and Nuclear Energy Institute (NEI) guidance documents. The following is provided as a reference to the terms, definitions, and acronyms used throughout this report.
Beyond Design Basis External Event (BDBEE) - Events initiated by natural phenomena that either exceeds the protections provided by the design basis features or involves natural phenomena within the design basis in combination with beyond design basis failures leading to an extended loss of alternating current (AC) power and/or loss of the ultimate heat sink.
Extended Loss of AC Power (ELAP) - The occurrence of a prolonged loss of all offsite power and a prolonged loss of all onsite AC power occurs with no foreseeable restoration time for either source.
FLEX capability equipment - Coping capability to prevent damage to the fuel in the reactor and spent fuel pools and to maintain the containment function by using installed equipment (referred to as the Initial Phase or Phase 1), using on-site portable equipment (referred to as the Transition Phase or Phase 2), and pre-staged off-site equipment that will be available after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (referred to as the Final Phase or Phase 3).
FLEX Support Guideline (FSG) - Procedures that provide to the extent possible, pre-planned strategies for accomplishing specific tasks in support of Emergency Operating Procedures (EOP) functions to improve the capability to cope with a BDBEE.
Staffing Assessment - A two (2) phased approach to assess the tasks and responsibilities assigned to the Emergency Response Organization (ERO) to evaluate any potential to overburden them with assigned duties. For a single unit like Fermi 2, Phase 1 applied only to the on-shift organization and was completed as directed by recent emergency preparedness rules, Interim Staff Guidance (ISG-0 1), "Emergency Planning for Nuclear Power Plants," and NEI 10-05, "Assessment of On-shift Emergency Response Organization Staffing and Capabilities." The Fermi Phase 1 Staffing Assessment was completed December 19, 2012. The Phase 2 Staffing Assessment (this report) is related to Near-Term Task Force (NTTF)
Recommendation 4.2 and includes the on-shift organization and augmenting ERO for the period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following an ELAP using diverse and flexible coping strategies (FLEX) capability equipment for the Initial and Transition Phases. The Phase 2 assessment is directed by NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communication Capabilities," and NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide." For purpose of clarification this study will be referred to in this document as the "NEI (Phase 2) Staffing Assessment."
Strategic Alliance for FLEX Emergency Response (SAFER) - The Pooled Equipment Inventory Company (PEICo) and AREVA NP, Inc. created the SAFER Team to develop and manage a FLEX regional response center program as part of the PEICo's existing Pooled Inventory Management (PIM)
Program for the U.S. nuclear industry.
1
NEI (Phase 2) Staffing Assessment Process Overview The assessment was conducted by a multi-disciplined team using draft FLEX Support Guidelines (FSGs) and Emergency Operating Procedure (EOP) revisions. Use of these procedures is acceptable in accordance with NEI 12-01, section 1.3.1.2. The staffing assessment also addressed the ability of the on-shift staff to perform required emergency response functions prior to the delayed arrival of up to six hours from the augmented Emergency Response Organization (ERO).
The NEI (Phase 2) Staffing Assessment requires that the response to the ELAP scenario be evaluated based on the minimum staffing in the Emergency Plan (NEI 12-01, section 2.3.1) and the supplemental staff allowed by administrative staffing procedures (NEI 12-06, section 11.7). Fermi 2 Radiological Emergency Response Preparedness Plan, Rev 44, Table B-1, documents the approved minimum staff. Operations procedure, MOP03, revision 37, documents the administrative staff supporting the on-shift operating crew. The table below summarizes the available personnel used for performance of the NEI 12-01 (Phase 2) staffing assessment.
Enrico Fermi Atomic Power Plant Unit 2 Supplemental Radiological Emergency Response Preparedness Staff Plan, Revision 44
Reactor Operator (SRO)
Nuclear Supervising Operator (NSO) - RO 3
or SRO Nuclear Operator (NO) 5 Shift Technical Advisor (STA) 1 Chemistry Technician RP Technician 2
Maintenance Technician 2
RERP Communicator (NO) dl Fire Brigade b
Security a
Total:
16 1
Overall Total 17 (a) As required by the Fermi Security Plan. Not included in the 16 total.
(b) UFSAR 9A.l.3.3 requires a minimum of 5 plant personnel. MOP10, Fire Brigade, specifies a total of five dedicated members of the fire brigade, plus a communicator. Fire brigade is normally filled by personnel filling another position having functional qualifications, and is not included in the 16 total.
(c) Per MOP03, revision 37, the position Communicator (normally an NO) is a mandatory position and is administratively required to be on-shift.
(d) May be provided by personnel assigned other functions and is not in the total.
2
NET (Phase 2) Staffing Assessment Results No conflicts or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during this analysis. Transition Phase actions were required within the first six hours of the event.
Using NEI 12-01 guidance, the minimum on-shift staff as defined in Emergency Plan and the supplemental staff allowed by MOP03, performed all actions required by operating and emergency plan procedures in the first hour period relying only on installed structures, systems and components remaining in the initial phase of the response.
Once the General Emergency and the ELAP condition were declared, functional draft FLEX Support Guidelines (FSG) were successfully implemented, using on-shift resources during the first six (6) hours and augmented responders from six (6) to twenty-four (24) hours.
An evaluation (tabletop analysis) of each FSG was conducted, whether or not the strategy was required to be implemented. The evaluation was completed in order to determine the resources needed and estimated duration of each task associated with the strategy. The total number of resources identified and task duration, including travel times, were then used to identify the two most resource limiting FLEX strategies (Refer to Table 8 in Appendix 1).
This analysis identified that the two most resource limiting FSG coping strategies are:
29.FSG.01, FLEX DC 29.FSG.02, FLEX WATER The assessment also validated:
Equipment will be deployed to clear obstructions from the pathway between FLEX equipment's storage location and its deployment locations(s) [NEI 12-06, 11.3 (9)].
Deployment of FLEX equipment or debris removal equipment from storage locations does not depend on off-site or on-site power capability. [NEI 12-06, 11.3(10)].
Alternate transportation resources and access enhancing measures are available for site access (NEI 12-01, 3.9).
Ability to maintain critical communication and includes the number of units needed to implement any two strategies. (NEI 12-01, 4.1.6.2).
Follow-up actions were identified during the tabletop analysis. The follow-up actions were entered into the Fermi 2 Corrective Action Program.
3
Follow-up Actions During the tabletop procedural analysis, follow-up actions related to existing procedures and processes were identified:
- 1.
Clarify Operations Conduct Manual MOP03, revision 37, section 3.4.1 so that it is clear that the Fire Brigade Leader is the same position as NSO 3/Patrol. Currently, a count of the "Numbers" in column four (4) is 18 positions. Discussion during the assessment revealed that there are only 17-positions (16 required by the emergency plan and one administratively controlled). The difference is based on interpretation of the table included in the manual.
- 2.
Include guidance that any change to the minimum on-shift staff as defined in Emergency Plan or the supplemental administrative staff required by MOP03 will require an evaluation for impact to the NEI (Phase 2)
Staffing Assessment.
- 3.
There is currently limited guidance to assemble "off duty" Licensed Operators, Non-licensed Operators, Radiation Protection (RP), Chemistry, Maintenance, or Security personnel following an ELAP. Include guidance in appropriate procedure(s) that directs these personnel to report to the station or assemble at the AEOF, if the station is not accessible and provide training based on the procedure changes.
- 4.
LP-ER-828-0001 requires a revision. Page 19 directs that, "the ERO members should immediately report to their Emergency Response Facilities and if the site or roads leading to the site are not accessible, then they should immediately assemble at the Dixie Warehouse." Dixie Warehouse should be changed to the Alternate Emergency Operations Facility (AEOF).
- 5.
There are four documents that have conflicting information pertaining to Satellite Phones (phones numbers, number of units available, Gateway vs docking station etc.). Review and align the documents. The four documents are:
The Communication Bases, Revision 2, January 2015 EP-585, EMERGENCY SATELLITE PHONES, Revision 1, 10/24/14 29.FSG.06, Communications, Draft Revision 0 Emergency Telephone Directory, Revision 95, 12/4/14
- 6.
Determine the tool and storage location required to breach the exterior Protected Area Fence. If other than hand tool(s), determine if training is required.
- 7.
Add the uninterruptible power supply (UPS) "throw over" for the Satellite phones and Turbine Building (TB)
Radio Repeaters to 20.300.SBO Loss of Offsite and Onsite Power so that the satellite phones Gateways and TB Radio Repeaters are operable immediately. Currently not completed until entry into ELAP procedures.
- 8.
Determine task sequencing, the number of steam suits required and the training and qualification requirements needed to support 29.FSG.14, HPCI/RCIC Oil Cooling. Also determine if RP job coverage is required.
- 9.
The capability to perform dose assessment is impacted by ELAP. Evaluate if training or process changes are required to address the limited availability of data to support dose assessment.
- 10. Chemistry was not assigned any FSG tasks, evaluate if the Chemistry group should receive FSG training so that they could support a FSG task, if needed.
- 11. Determine the number and positions of the additional supplemental staff that should be procedurally brought on site in advance of a flooding event and the means to bring them in, house and feed them, and safely assemble them.
- 12. The diesel at the AEOF does not provide power to the four installed satellite phone gateways. Install a UPS(s) to meet the communication capability requirements for a facility within the 25 mile affected area surrounding the station.
- 13. Place in location the two satellite phones to the Control Room Conference Room as alternate hand held units.
- 14. After receipt of the final DTE Modular Accident Analysis Program (MAAP) Analysis, verify that there is no impact from that used from the preliminary analysis.
- 15. Validate the NEI (Phase 2) Staffing Assessment results against the final approved procedures/guidelines.
Include any identified discrepancies in the Fermi corrective action program.
4
NEI (Phase 2) Staffing Assessment Details for Fermi 2 The NEI (Phase 2) Staffing Assessment for Fermi 2 was conducted on February 10-11, 2015, using the guidance of NEI 12-01, NEI 12-06 and NEI 10-05.
The following personnel were present to complete the assessment:
Personnel (Position/Title)
Number Organization/Department Shift Manager 1
Operations Control Room Supervisor/STA/Fire 1
Operations Patrol Nuclear Supervising Operator 1
Operations Nuclear Operator 5
Operations Radiation Protection Technician 2
Radiation Protection RP Supervisor 1
Radiation Protection Chemistry Technician 1
Chemistry Chemistry Supervisor 1
Chemistry Maintenance Superintendent 1
Maintenance Radiological Emergency Response 1
RERP Preparedness (RERP) Manager Emergency Preparedness (EP) Staff 3
RERP Instrumentation and Controls (I&C) 1 Maintenance Maintenance Electrical Maintenance 1
Maintenance Mechanical Maintenance 1
Maintenance Operations Training 3
Training Manager Industry Interface 1
Engineering Probabilistic Safety Analysis (PSA) 1 Performance Engineering Engineer Security Alarm Station Operator (ASO) 1 Security Security Superintendent 1
Security Security Response Force Leader 1
Security Supervisor (procedures) 1 Operations Support Fukushima Project 1
I&C Engineering Associates (contractor)
Fukushima Project 1
Delta Engineering Service (contractor)
Director Organization Effectiveness 1
Organization Effectiveness Director Nuclear Production 1
Production EP Specialist 2
EC2 (contractor)
EP Specialist 1
Bartech (contractor) 5
NEI (Phase 2) Staffing Assessment Assumptions The ELAP event was evaluated using assumptions consistent with NEI 12-0 land NEI 12-06 and applicable assumptions from NEI 10-05. The following assumptions were applied.
- 1. No specific initiating event is used. The initial condition is assumed to be a loss of off-site power (LOOP) at the plant site resulting from an external event that affects the off-site power system either throughout the grid or at the plant with no prospect for recovery of off-site power for an extended period. Plant initial response is the same as station blackout (SBO) (20.300.SBO procedure). Entry to Extended Loss of AC Power (ELAP) will be within 45 minutes.
- 2.
The analyzed event occurs during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).
- 3.
No additional events or failures are assumed to occur immediately prior to or during the event. A hostile action directed at the affected site does not occur during the period that the site is responding to the event.
- 4.
Prior to the event the reactor has been operating at 100 percent rated thermal power for at least 100 days and is successfully shutdown or has just been successfully shut down from such a power history as required by plant procedures in advance of the impending event. Decay heat is based on ANSI/ANS 5.1 "Decay Heat Power in Light Water Reactors," (1979) evaluation methods.
- 5.
Modular Accident Analysis Program, Version 4, analysis for decay heat is used to establish maximum operator response timelines and actions.
- 6.
At the time of the postulated event, the reactor and supporting systems are within normal operating ranges for pressure, temperature, and water level for the appropriate plant condition. All plant equipment is either normally operating or available from the standby state as described in the plant design and licensing basis.
- 7.
Flood and seismic walk downs and associated analysis reports are completed and have confirmed there is no impact to the Systems, Structures or Components (SSCs) relied upon for implementing the proposed FLEX strategies.
- 8.
Normal access to the ultimate heat sink (UHS) is lost, but the water inventory in the UHS remains available and robust piping connecting the UHS to plant systems remains intact. The motive force for UHS flow, i.e., pumps, is assumed to be lost with no prospect for recovery.
- 9.
Instrumentation for key parameters is powered from Engineered Safety Feature (ESF) Direct Current (DC).
This ESF DC is available in Phase 1 and restored in Phase 2 electrical actions.
- 10. All equipment credited in current coping strategies remains available for use.
- 11. Other equipment, such as portable AC power sources, portable back up DC power supplies, spare batteries, and equipment for Title 10 Code of Federal Regulations (10 CFR) 50.54(hh)(2), may be used provided it is reasonably protected from the applicable external hazard and has predetermined hookup strategies with appropriate procedures/guidance and the equipment is stored in a relative close vicinity to the site.
- 12. The fire protection system ring header is not expected to survive, however, the fire protection piping in the reactor building and auxiliary building is isolable and is expected to survive to support FLEX coping strategies.
- 13. The event impedes site access as follows:
A. Post-event time: 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.
B. 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).
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.
- 14. On-site staff is at site administrative minimum shift staffing levels as allowed by NEI 12-06, section 11.7.
- 15. All personnel on-site are available to support site response.
- 16. On-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions. Following are the typical locations of personnel:
6
S Shift M anager.............................................................................................................................
C ontrol R oom C ontrol R oom Supervisor...........................................................................................................
Control R oom T
STA..........................................................................................................................................
Tagging Center N SO (1st and 2n..........
Control R oom 3 rd N SO (Also Fire Brigade Leader).........................................................................................
Tagging Center Nuclear Operator (14t, 2nd, 3 rd and 4"' NO)................................................................................
Tagging Center Radwaste Operator (5*b NO).......................................................................................Radwaste Control Room RP Technician (1st and 2 nd).......
RP O ffice Chem istry Technician................................................................................................................ Chem istry Lab Maintenance Technicians (1St and 2nd)................................................................................
Maintenance Shop S
Com m unicator (6 N O)...........................................................................................................Tagging Center
- 17. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain required dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.
- 18. Personnel assigned to the major response area of Plant Operations & Safe Shutdown meet the requirements and guidance established by NRC regulations and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown. Staff performance within this area is not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.
- 19. On-site security organization performance 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.
- 20. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.
- 21. 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. This assumption does not apply to the job specific duties for emergency notification to an Offsite Response Organization (ORO) or the NRC.
- 22. The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions.
- 23. Fuel for FLEX equipment stored in structures with designs which are robust with respect to seismic events, floods and high winds and associated missiles, remains available.
- 24. The FLEX connections will either be hardened or in diverse locations to ensure connections are available following the event.
- 25. Implementation strategies were assessed for hazards impact.
- 26. All Transition Phase components are stored on site and available for FLEX.
- 27. The FLEX equipment in the Transition Phase will be capable of coping for an indefinite period.
- 28. The emergency telephone communication network Direct-Inward-Dialing (DID) and Private Branch Exchange (PBX) for the site is unavailable.
- 29. Plant public address system (HiComs) is unavailable.
- 30. The Turbine Building radio repeaters are powered from a 10 kilovolt-amps (KVA) UPS located in the Rad-Waste Switchgear Room. It requires a manual action to position a transfer switch located in the Turbine Building. The Residual Heat Removal (RHR) building radio repeater is backed by 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> UPS that requires no manual action.
- 31. There are 16 dedicated hand-held radios, with 4 batteries for each radio.
- 32. There are additional plant handheld radios throughout the station. These radios may survive but are not credited during the BDBEE.
- 33. If the BDBEE would impact the radio repeater, portable radios will function with line of sight.
- 34. Installed Satellite phones with Uninterrupted Power Supply (UPS) or a diesel generator and external antenna are available for use by emergency response personnel for onsite and offsite communications. This system is expected to support the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a Station Blackout. The location of the installed satellite phones, including spare batteries, are as follows:
7
Control Room - 3 (Gateway) - UPS (H4000S002), with manual transfer switch (H4000M004).
This is the same UPS and switch for the TB radio repeaters and Operations Support Center (OSC).
OSC - 1 (Gateway) - UPS (H4000S002), with manual transfer switch (H4000M004). This is the same UPS and switch for the TB radio repeaters and Control Room.
Technical Support Center (TSC) - 4 (Gateway) -UPS (H4000S003)
Emergency Operations Facility (EOF) - 4 (Gateway) - Installed Diesel AEOF - 4 (Gateway) - Refer to Follow-up Actions Central Alarm Station (CAS) - 1 (Docking Station) - UPS (H4000S004)
Secondary Alarm Station (SAS) - 1 (Docking Station) - UPS (H4000S005)
Alternate Operations Support Center (AOSC) - 1 (Docking Station) - UPS (H4000S006)
- 35. If the BDBEE would impact a satellite phone antenna or power supply, the satellite phone can be altered and function as a handheld model. This requires removal of the SIM card from the installed system and placed into the handheld satellite phone.
- 36. Handheld satellite phones are available at:
o OSC-2 o
TSC-1 o
EOF-3 o
AEOF - 3 o
Joint Information Center (JIC) - 1 o
Control Room conference room Refer to Follow-up Actions o
FLEX Support Facility (FSF) 1 (FLEX Building) - 1 (currently a spare until building is completed) o FSF 2 (FLEX Building) - 1 (currently a spare until building is completed)
- 37. The Alternate Emergency Operation Facility is located approximately 22 miles from the site and is available as a staging location.
- 38. Site access methods are arranged via land, air, or water as discussed in letter NRC-12-0039.
- 39. There will be early warning for a flooding event (NEI 12-06 Section 6.2.2). Flood warning would initiate a reactor shutdown and plant cool down (Abnormal Operating Procedure (AOP) 20.000.01, Acts of Nature).
Flood duration will be 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> (UFSAR Section 2.4.5.4.2.3). Select personnel would be activated in advance of the flood.
Site Specific
References:
- 1.
AOP 20.300.SBO, Rev 18, "Loss of Offsite and Onsite Power"
- 2.
AOP 20.000.01, Acts of Nature, Revision 48
- 3.
DC-6585 VOL I, Loss of HVAC - Room Environment Analysis in Support of FLEX: RB/AB/TB Temperature Profile Analysis, Revision 0, 10/21/2014
- 4.
DC-6586 VOL I, Loss of HVAC - Room Environment Analysis in Support of FLEX: Battery Room Temperature and Hydrogen Concentration, Revision 0, 10/21/2014
- 5.
DC-6587 VOL I, Loss of HVAC - Room Environment Analysis in Support of FLEX: HPCI, RCIC Room Temperature and Water Level Analysis
- 6.
Preliminary DTE MAAP Analysis Runs, "Fermi 2 FLEX Coping Time Evaluation", and "Series 600 Cases for Fermi 2 FLEX MAAP Scoping Time Analysis," Reference letter NJPR-13-0028, dated March 27, 2013, as supplemented by "MAAP Drafts"
- 7.
NRC-12-0039, Request Regarding Emergency Preparedness Communications and Staffing, June 8, 2012
- 8.
NRC-12-0064, Request for Assessment of Emergency Preparedness Communications, October 29, 2012
- 9.
NRC-12-0032, 60 Day Response to March 12, 2012 Information Request, May 8, 2012
- 10. NRC-13-0010, Near-Term Task Force Recommendation 9.3, February 22, 2013
- 11. Emergency Communication Bases, Revision 2, January, 2015
- 12. Draft FSGs listed in Table 8 8
Methodology An assessment of on-shift staffing was performed using NEI 12-01, NEI 12-06, and NEI 10-05 guidance. Subject matter experts and consultants were assembled to provide analysis support. The assessment was conducted via a tabletop procedural analysis using DTE procedures to determine if tasks have been sufficiently analyzed for performance by the minimum on-shift staff as designated in the Emergency Plan and supplemental administrative staff as allowed by NEI 12-06. A pre-job brief was conducted outlining the assessment process and to familiarize personnel with the type of event. Copies of draft FSGs were provided. The Shift Manager and CRS participants reviewed FSG actions and identified them to the team.
The following provides the summary of the assessment process that was used to document the analysis. An evaluation (tabletop analysis) of each FSG was conducted, whether or not the strategy was required to be implemented. A team representing the minimum on-shift staff augmented with other staff personnel participated as the assessment team. The tabletop analysis was completed in order to determine the resources needed and estimated duration of each task associated with the strategy. The total number of resources identified and task duration, including travel times, were then used to identify the two most resource limiting FLEX strategies. Forms from NEI 10-05 were modified to meet the timelines described by the assessment team during the tabletop analysis. For the first 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period, each on-shift position from the Emergency Plan and the one additional on-shift position were entered in Table 1. For position titles with more than one position holder, a unique sequential number was assigned to each position. Security was entered as group (the Security Plan defines minimum staffing). Additional tables were completed by entering the shift position and a described role, specific function, or tasks and the communication equipment used during the described task. The on-shift resources and their actions were then summarized (Table 1).
For the period after 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, Table 10 was completed to validate that there are sufficient resources available to implement the Emergency Plan and support FLEX Transition Phase strategies.
The following is a list of tables used during the assessment.
Table 1 - On-shift Positions Roles Table 2 - Personnel Necessary to Implement AOPs and EOPs, or FSGs Table 2A - Procedure Task Timing to Implement ELAP (First 6 Hours)
Table 2B - Procedure Task Timing to Implement ELAP (Hours 7-24)
Table 3 - Firefighting (not applicable for this event analysis)
Table 4 - Radiation Protection & Chemistry Timeline of Activities Table 5 - Emergency Plan Implementation Table 6 - Emergency Plan Implementation Timeline Table 7 - On-shift Staff Usage Table 7A - On-shift Usage Table for First 6 Hours Table 8 - Strategy Resource Loading Table 9 - Communication Table 10 - Augmenting Emergency Response Organization Security Considerations Existing coping and planned mitigation strategies do not require the use of Security Officers to perform duties unrelated to their assigned roles. Tasks assigned for FLEX response are consistent with their normal duties and assigned as non-routine collateral duties. Security Officers will perform functions within their current roles such as monitoring and controlling site access, providing for ease of access to emergency equipment and pathways, and providing compensating measures for any vital area doors that may need to remain open to facilitate room environmental conditions.
9
Appendix 1 - Tables 10
Table 1 - On-shift Positions Roles Line On-shift Position Reference Tabo/lne#
Action Required?
- 1.
Shift Manager (OPSI)
Fermi Emergency Plan, Rev 44 T2L1 Yes - Note 2 T5L1 T5L2 T5L3 T5L6 T5L9
- 2.
Control Room Supervisor (OPS2)
Fermi Emergency Plan, Rev 44 T2L2 Yes - Note 2
- 3.
Control Room NSOI -RO (OPS3)
Fermi Emergency Plan, Rev 44 T2L3 Yes - Note 2
- 4.
HI 1P603 NSO2 - (OPS4)
Fermi Emergency Plan, Rev 44 T2L4 Yes - Note 2
- 5.
Shift Technical Advisor (OPS1 1)
Fermi Emergency Plan, Rev 44 T2L5 Yes - Note 2
- 6.
Patrol NSO/Fire Brigade Leader - NS03 (OPS5)
Fermi Emergency Plan, Rev 44 T2L6 Yes - Note 2
- 7.
Reactor Building/Fire Brigade 1 - NO (OPS6)
Fermi Emergency Plan, Rev 44 T2L7 Yes - Note 2
- 8.
Turbine Building/Fire Brigade 2 - NO (OPS7)
Fermi Emergency Plan, Rev 44 T2L8 Yes - Note 2
- 9.
Additional Operator 1/Fire Brigade 3 - NO (OPS8)
Fermi Emergency Plan, Rev 44 T2L9 Yes - Note 2
- 10.
Additional Operator 2/Fire Brigade 4 - NO (OPS9)
Fermi Emergency Plan, Rev 44 T2L10 Yes - Note 2
- 11.
Radwaste/Safe Shutdown Operator - NO (OPS10)
Fermi Emergency Plan, Rev 44 T2Ll1 Yes - Note 2
- 12.
Radiation Protection Technician (RP1)
Fermi Emergency Plan, Rev 44 T2L13 Yes - Note 2
- 13.
Radiation Protection Technician (RP2)
Fermi Emergency Plan, Rev 44 T2L14 Yes - Note 2
- 14.
Chemistry Technician (ChemI)
Fermi Emergency Plan, Rev 44 T2L15 No - Note 3 T5L11
- 15.
Scheduled Maintenance Technician (M1)
Fermi Emergency Plan, Rev 44 T2L16 Yes - Note 2
- 16.
Scheduled Maintenance Technician (M2)
Fermi Emergency Plan, Rev 44 T2L17 Yes - Note 2
- 17.
Communicator Outside Rounds - NO (OPS 12)
Operations Conduct Manual MOP03, Rev 37 T2L12 No - Note 1 T5L7 T5L8 T5L12
- 18.
Security Fermi Emergency Plan, Rev 44 and T5L14 No - Note 3 Security Plan Notes:
- 1)
Line 17 NO Is an administratively controlled position and not part of RERP minimum staff
- 2)
Training required for FSG support actions (see Table 2A).
- 3)
Not assigned any FSG duties 11
Table 2 - Plant Operations & Safe Shutdown Minimum Operations Crew Necessary to Implement AOPs and EOPs, or FSGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation
- 1.
Shift Manager Shift Manager (SM)(OPS 1)
Licensed Operator Training
- 2.
Unit Supervisor Control Room Supervisor (CRS)(OPS2)
Licensed Operator Training
- 3.
Reactor Operator 1 Control Room NSO - (NSO1) (OPS3)
Licensed Operator Training
- 4.
Reactor Operator 2 H 11 P603 NSO-RO - (NSO2) (OPS4)
Licensed Operator Training
- 5.
Shift Technical Advisor Shift Technical Advisor (STA) (OPS11)
Licensed Operator Training
- 6.
Reactor Operator 3 Patrol NSO/Fire Brigade Leader - (NSO3) (OPS5)
Licensed Operator Training
- 7.
Auxiliary Operator 1 Reactor Building/Fire Brigade 1 - NO (OPS6)
Non-licensed Operator Training
- 8.
Auxiliary Operator 2 Turbine Building/Fire Brigade 2 -NO (OPS7)
Non-licensed Operator Training
- 9.
Auxiliary Operator 3 Additional Operator 1/Fire Brigade 3 - NO Non-licensed (OPS8)
Operator Training
- 10.
Auxiliary Operator 4 Additional Operator 2/Fire Brigade 4 - NO Non-licensed (OPS9)
Operator Training
- 11.
Auxiliary Operator 5 Radwaste/Safe Shutdown Operator - NO (OPS 10)
Non-licensed Operator Training
- 12.
Auxiliary Operator 6 Communicator - NO (OPS 12)
Non-licensed Operator Training Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or FSGs if applicable Line Generic Title/Role On-Shift Position Task Performance Validation
- 13.
Radiation Protection Radiation Protection Technician (RP 1)
RP Training Technician
- 14.
Radiation Protection Radiation Protection Technician (RP2)
RP Training Technician
- 15.
Chemistry Technician Chemistry Technician (Cheml)
Chemistry Training
- 16.
Maintenance Technician Scheduled Maintenance Technician (Ml)
Maintenance Training
- 17.
Maintenance Technician Scheduled Maintenance Technician (M2)
Maintenance Training 12
Table 2A - Procedure Task Timing to Implement ELAP (First 6 Hours)
Action & Resources Performance Time Color Coding:
360 Minutes (6 Hours) Period Post-event time: No site access SAE Site Area Emergency Declaration and Notification - SS1 General Emergency Declaration and Notification - SGL
____Task-performance time Line Task 20-30-so 90 10 140-160-10-200-220-240-260-280-300-320-Tas Set.
esorce10 140 30 40 03 60 607 08 40 100 120 1210 160 180 200 220 240 260 280 300 320 340 306 1
20.300.SBO Loss of Offsite and Onsite Power-17 Minimum shift assemble at Control Room and Ops dispatched to attempt CTG and diesel manual starts 2
Emergency Classification and Notification Process -
SM (OPS1)
Dedicated Emergency Plan Functions and OPS12 SAE - SS1 Communication 3
Dedicated Plant Operations CRS (OPS2)
NSO (OPS3)
STA OPS11 4
29.FSG.01:FLEXDC Att. 1and OPS4 DC Load Shedding - Strip Control Room (CR) DC 2
OPS7 loads per 29.400.01 Att. 1 Strip Switchgear Room DC loads per 29.FSG.01 Att. 1/2 (path is through Div. 2 Switchgear room down to Relay Room (RR) 5 29.FSG.08: HPCI Defeats 3.1 -3.5 OPS7 HPCI/RCIC Protection - Preserve HPCI minimum 4.1.1,&
OPS8 aow logic, Barometric Condenser logic and defeat 4O22 all other HPCI trips and isolations per 29.FSG.08 6
29.FSG.01:FLEXDC 6.1 -6.3 OPS7 DC Restoration-In Div. 1 Switchgear room, remove OPS8 MCC 72B-2A positions for electrical protection for BID.
7 29.FSG.01:FLEXDC 6.4-6.6 OPS7 DC Restoration - In Div. 2 Switchgear room, remove OPS8 MCC 72F-2A positions for electrical protection for BID.
8 29.FSG.01:FLEXDC 4
OPS6 DC Restoration -
OPS5 Hook up FLEX Generator N cables to FSF #1 M2 switchgear (K1 101 S002A). Report hookup to P603 via Satellite Phone.
9 29.FSG.02:FLEX Water 3.5 M1 Debris Removal -
When debris cleared, drive FLEX Truck to south end of VBS section.
10 29.FSG.01:FLEXDC 5
OPS9 DC Restoration -Hook up FLEX Generator N OPS10 cables to FSF #1 switchgear (K1101 S002A). Report hookup to P603 via Satellite Phone.
11 29.FSG.01:FLEXDC 7
OPS4 DC Restoration-Hook up FLEX Generator N cables OPS8 to FSF #1 switchgear (K1 101 S002A). Report hookup to P603 via Satellite Phone.
12 29.FSG.04:FLEX AC 3.1 OPS4 AC Load Restoration Div. 1 -
OPS7 Work with H11 P603 to establish protection for OPS8 inserting BID in 72B position 2C. H11P603 controls power at FSF#1. Protection established per 29.FSG.04.
13
Table 2A - Procedure Task Timing to Implement ELAP (First 6 Hours)
Action & Resources Performance Time Color Coding:
360 Minutes (6 Hours) Period Post-event time: No site access SAE Site Area Emergency Declaration and Notification - SS1 General Emergency Declaration and Notification - SG1 Task performance time Line Task Sect.
Resource 1"
10-20 20-0 40-s0
- 0.
60-70 70-0 0-s0 90 100~
2-4 140-160-180-200-220-240-260-280-300-320 33 1s 30 40 60 100 120 160 180 200 220 240 260 280 300 320 340 13 29.FSG.02:FLEX Water 3.6.1 &
M1 FLEX Water Deployment inside PA - pull FLEX 3.6.2 Flow Trailer to West wall of RB and disconnect/deploy trailer. Security Opens gates and cuts access hole.
14 29.FSG.02:FLEX Water 3.6.3 RP2 FLEX Water Deployment inside PA Connect FLEX M1 Flow Trailer to RHR connection point using hose on trailer.
15 29.FSG.02:FLEXWater 3.6.4&5 RP2 FLEX Water Deployment inside PA Connect Hose M1 section #1 to outlet of FLEX Flow Trailer (533' section).
16 29.FSG.02:FLEX Water 3.7.1 -
OPS9 Open Building FSF#2.
3.7.5 OPS10 17 29.FSG.02:FLEX Water 3.7.6-OPS9 FLEX Water Deployment Outside PA Connect 3.7.10 OPS10 Tugger to Source/Lift Pump and move to East Op RP1 area.
18 29.FSG.02:FLEX Water 3.7.11 -
OPS9 FLEX Water Deployment Outside PA 3.7.14 OPS10 Using winch and backdoor deploy source pump to RP1 CWP using rope and buoy. This also deploys the 8" RP2 hose.
19 29.FSG.02:FLEX Water 3.7.15-OPS9 FLEX Water Deployment Outside PA 3.7.22 OPS10 Deploy minimum flow hose from discharge of Lift pump to CWP. This included deploying 2.5" hose and staking Monitor nozzle toward CWP.
Deploy Hose section #3 by driving FLEX Truck #2 to north end of VBS.
20 29.FSG.05:Containment Cooling 3.1 OPS4 FLEX Water/Bleed Path Alignment -Align EITHER 4.1 OPS7 D1 RHR OR D2 RHR based on instructions from OPS8 CRNSO to receive FLEX Water.
21 29.FSG.02:FLEX Water 4
OPS10 FLEX Water Filling hose and initial pump ops -
Verify that inside PA and outside PA Hose deployments are completed (check with CR and FSF#1).
22 29.FSG.05:Containment Cooling 3.3 OPS5 Containment Cooling: FLEX Water Feed/HPCI Bleed - Start FLEX Water supply feed to Torus by opening selected RHR Div. 1 OR Div. 2 Torus Valves.
14
Table 2A - Procedure Task Timing to Implement ELAP (First 6 Hours)
Action & Resources Performance Time Color Coding:
360 Minutes (6 Hours) Period Post-event time: No site access SAE Site Area Emergency Declaration and Notification - SS1 General Emergency Declaration and Notification - SG1 Task performance time Line Task Sect.
Resource 0-10-20 20-30-4~
60-70 9080 80-90 90-120-140 140-160 180-200-220-240-260-20-300-320-340-360 10 30 40 60 100 120 160 180 200 220 240 260 280 300 320 340 23 29.FSG.05:Containment Cooling 4.1.5 -
OPS5 Containment Cooling: FLEX Water 4.1. 8 Shift HPCI from minimum Flow mode to Bleed mode by opening E4150F008.
24 29.FSG.04:FLEXAC 3.2 OPS4 Restore 72E Positions 5B (Battery Fans/RPS) and OPS7 5A (Div. 1 RHR valves).
25 29.FSG.02:FLEX Water N/A RP1 Reliees OPS 10 monitoring rS and Pumps 26 29.FSG.10:Oiesel Air Compressor 3
M1 CONNECTsON AND STARTUP OF FLEX AIR M2 COMPRESSOR & SUPPLING FLEX AIR TO NIAS 27 2g.FSG.10:DieselAir Compressor 4
OPS15 CONNECTION AND STARTUP OF FLEX AIR
_____COMPRESSOR & SUPPLING FLEX AIR TO NIAS 15
Table 2B - Procedure Task Timing to Implement ELAP (Hours 7-24)
Action & Resources Performance Time Color Coding:
7-24 Period Post-Event Time: Limited Site Access SAE Site Area Emergency Declaration and Notification - SS1 General Emergency Declaration and Notification - SG1 Task performance time Line Task Sect.
Resource 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 28 AEOF is functional and coordination of movement of select personnel to the site begins. Note 1 29 Emergency Classification and Notification Process-SM (OPS1)
Dedicated Emergency Plan Functions and Communication OPS12 30 Dedicated Plant Operations CRS (OPS2)
NSO (OPS3)
STA OPS11 31 Replacement On-Shift Staff (17) and Security personnel transported to site and turnover and assume duties.
32 Extra Maintenance and Operations and Security personnel transported to Site 33 29.FSG.02:FLEX Water RP1 Monitoring DG and Pumps 34 Monitoring DG and Pumps - alternating personnel ERO-1 ERO-2 35 29.FSG.17:FLEX FUEL MANAGEMENT ERO-3 Refueling operations ERO-4 ERO-6 36 ERO EP/BDB Procedures TSC Emergency Director ERO assist with Emergency Plan Duties & ORO and NRC TSC Communicator Communications from AEOFITSC and EOF 37 ERO EP/BDB Procedures EOF Communicator SAFER Site Point Of Contact (SPOC) Coordination at AEOF/TSC and EOF 38 ERO EP/BDB Procedures Technical Engineer Engineering staff reviewing plant data and strategies at Operations Liaison AEOF/TSC and EOF Support Engineers 39 ERO EP/BDB Procedures Emergency Officer and Coordination of the Corporate Response Plan AEOF/TSC staff and EOF 40 Additional ERO transported to site 41 29.FSG.15 ERO-7 Preparation for connection of SAFER 4160 VAC generators ERO-at Fermi 2 ERO-1 42 29.FSG.15 TSC & EOF Security Coordination and set up of the Onsite and Offsite Staging for Advisor Phase 3 equipment at AEOF, Airport, and Fermi 2 ERO Support Personnel Note 1 - The AEOF will assemble the offsite responders and activate. ERO members will be transported to the Fermi site based on the priority of support needed. The TSC and EOF will activate as soon as possible and activities will transfer from the AEOF to the site.
16
Table 3 - Firefighting Task Analysis Line Performed By Controlling Method
- 1.
Not required by scenario N/A
- 2.
Not required by scenario N/A
- 3.
Not required by scenario N/A
- 4.
Not required by scenario N/A
- 5.
Not required by scenario N/A Notes:
Fire Brigade response not required for this event.
17
Table 4 - Radiation Protection & Chemistry Performance Time Period After Event Initiation Line Position Performing Function/Task Minutes - Hour 1 Hour 0-10-20-30-40-50-2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 10 20 30 40 50 60
- 1.
In-Plant Survey None Identified
- 2.
Out of Plant Survey None Identified
- 3.
Personnel Monitoring None Identified:
- 4.
Job Coverage None Identified
- 5.
Offsite Radiological Assessment
- 6.
Other Site-Specific RP -
None Identified:
- 7.
Chemistry function/task #1 - Describe:
None Identified
- 8.
Chemistry function/task #2 - Describe:
None Identified Task performance time No RP or Chemistry functions were performed during the initial or transition phase response of the first 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
No surveys were required.
Based on the location entered to perform actions during the initial and transition phase, no special RP briefs or coverage was required.
There is no release. Field Teams were not dispatched until after the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period. Restricted site access prohibited team dispatch. Field Teams were dispatched from the AEOF after the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period.
18
Table 5 - Emergency Plan Implementation Line Function/Task On-Shift Position
- 1.
Declare the Emergency Classification Level (ECL)
Shift Manager
- 2.
Approve Offsite Protective Action Recommendations Shift Manager
- 3.
Approve content of State/local notifications Shift Manager
- 4.
Approve extension to allowable dose limits N/A
- 5.
Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)
N/A (Note 5)
- 6.
- 7.
Complete State/local notification form Communicator-NO (OPS12)
- 8.
Perform State/local notifications Communicator-NO (OPS12) (Note 3)
- 9.
Complete NRC event notification form Shift Manager
- 10.
Activate Emergency Response Data System (ERDS)
N/A (Note 4)
- 11.
Offsite radiological assessment Chem1 (Note 2)
- 12.
Perform NRC notifications Communicator-NO (OPS12) (Note 3)
- 13.
Perform other site-specific event notifications (e.g., Institute of Nuclear N/A (Note 6)
Power Operations (INPO), American Nuclear Insurers (ANI), etc.)
- 14.
Personnel accountability Security Note 1 - Emergency Callout System (ECOS) will be activated, however, self-activation of ERO based on event (wide spread loss of grid)
Note 2 - Dose Assessment capability is impacted by ELAP - limited data available to perform dose assessment. In addition, no radiological release exists - dose assessment not required. Automatic protective action recommendations (PARs) implemented at General Emergency (GE).
Note 3 - State/local and NRC notifications are completed using satellite phones Note 4 - ERDS is unavailable as a result of loss of Communication Building Note 5 - Public address (PA) system is unavailable due to BDBEE Note 6-INPO notified via ECOS. Other organizations notified after ERO augmentation.
19
Table 6 - Emergency Plan Implementation Timeline Function/Task On-shift Time from Event Initiation (Minutes)
Position 3
6 9
12 15 18 21 24 27 30 35 40 45 50 55 60 65 70 75 80 85 90 Evaluate & Declare the Emergency SM Sit< Area Energency General Emr yre cy Approve Offsite PARs SM Approve extension to allowable dose limits N/A Notification and direction to on-shift staff (e.g., to assemble, evacuate, N/A etc.) (Note 5)
ERO notification SM Complete State/local notification form NO SAE G
(OPS 12)
E Approve State/local notifications SM S
G A
E E
Perform State/local notifications NO SAE A
(OPS 12)
Complete NRC event notification form SM Activate ERDS N/A Offsite radiological assessment (Note 2)
N/A Perform NRC notifications NO (OPS12)
Perform other site-specific event notifications (e.g., INPO, ANI, etc.)
N/A (Note 6)
Personnel accountability Security Task performance time Notes:
Note 1 - ECOS will be activated, however, self-activation of ERO based on event (wide spread loss of grid)
Note 2 - No radiological release. Dose Assessment capability is impacted by ELAP - limited data available to perform dose assessment. Initial PARS implemented at GE.
Note 3 - State/local and NRC notifications are completed using satellite phones Note 4 - ERDS is unavailable as a result of loss of Communication Building Note 5 - PA system is unavailable due to BDBEE Note 6 - INPO notified via ECOS. Other organizations notified after ERO augmentation.
20
Table 7 - On-shift Staff Usage Staff Usage (Emergency Plan Minimum Staffing is the 14S 16people)
Minutes Hour 2 Hour Line Position 0-10-20-30-40-50-60-70-80-90-100-120-140-160-180-200-220-240-260-280-300-320-340-4 5
6 1
8 9
10 12 14 16 18 20 22 24 10 20 30 40 50 60 70 80 90 100 120 140 160 180 200 220 240 260 280 300 320 340 360 1
OPS1 Emergency Director - Emergency Plan - Periodic Duty Relieved By Next Shift/TSC Director 2
OPS2.
Control Room Oversight Relieved By Next Shift CRS 3
OPS3 Plant Monitoring and Manipulation From Control Room Relieved By Next Shift NSO 4
OPS4 H11P60 SBO Response FSG.01 o
5 OPS5 SBO Response FSG.01 FSG.05 Patrol 6
OPS7 SBO Response FSG.01 FSG.08 FSG.01 FSG.04 FSG.05 FSG.04 NO 8
OPS8 SBO Response FSG.01 FSG.08 FSG.01 FSG.04 FSG.05 NO 9
OPS9 SBO Response FSG.01 FSG.02 NO 10 OPS10 SBO Response FSG.01 FSG.02 FSG.10 NO 11 OPS11 STA assigned Duties and Emergency Plan - Periodic Duty Relieved By Next Shift STA 12 RP1 Assemble at Control FSG.02 Equipment Monitoring Outside Relieved By Next Shift 13 RP2 Assemble at Control FSG.02 Room 14 Chem1 Assemble at Control Room 15 M1 Assemble at Control Debris Removal FSG.02 FSG.10 Room 16 M2 Assemble at Control FSG.01 FSG.10 Room 17 OPS12 Communications - Emergency Plan - Periodic Duty Relieved By Next Shift/TSC Communicator Comm.
Task performance time - includes travel time.
21
Table 7A - On-shift Usage Table for First 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Resource Total Utilization Comments Min of 360 OPS1 (Shift Mgr.)
360 100.00%
Emergency Plan - Periodic Duty OPS2 (Control Room Sup.
360 100.00%
Control Room Oversight CRS)
OPS3 (CR NSO/RO) 360 100.00%
Plant Monitoring and Manipulation From Control Room OPS4 (H11P603 NSO/RO) 195 54.17%
OPS5 (Patrol NSO/RO) 41 11.39%
OPS6 (NO) 135 37.50%
OPS7 (NO) 294 81.67%
OPS8 (NO) 249 69.17%
OPS9 (NO) 194 53.89%
OPS10 (NO) 277 76.94%
OPS1 1 (STA) 360 100.00%
STA assigned Duties and Emergency Plan - Periodic Duty OPS12 RERP 360 100.00%
Communications - Emergency Plan - Periodic Duty Communicator (NO)
M1 153 42.50%
M2 68 18.89%
Cheml 0
0.00%
RP1 170 47.22%
RP2 80 22.22%
22
Table 8 - Strategy Resource Loading Strategy Description Resources Duration Notes (Minutes) 29.400.01 FLEX -DC Load Shedding OPS4 10 29.FSG.01 FLEX DC & 2-DC Load Shedding OPS7 (NO) 15 OPS8 (NO)
Sec 6.1 -6.3 and Sec 6.4-6.6 - DC Restoration OPS7 (NO) 34 OPS8 (NO)
Sec 4 - DC Restoration OPS5 (NO) 110 OPS6 (NSO)
M2 Sec 5 -DC Restoration OPS9 (NO) 52 OPS10 (NO)
Sec 7 - DC Restoration OPS7 (NO) 20 OPS8 (NO)
Sec 7 - DC Restoration OPS4 (NSO) 15 Total 7 positions 29.FSG.02 FLEX Water & 2 - DC Load OPS7 (NO) 15 OPS8 (NO) 3.5 - Debris Removal M1 40 3.6.1 & 3.6.2 - FLEX Water Deployment M1 15 Security opens gates and (Inside PA) access hole 3.6.3-FLEX Water Deployment (Inside RP2 15 PA)
M1 3.6.4 & 3.6.4 - FLEX Water Deployment RP2 35 (Inside PA)
M1 3.7.1 - 3.7.5 - FLEX Water Deployment OPS9 (NO) 33 (Outside PA)
OPS10 (NO) 3.7.6 - 3.7.10 - FLEX Water Deployment OPS9 (NO) 20 (Outside PA)
OPS10 (NO)
RP-01 3.7.11 - 3.7.14 - FLEX Water Deployment OPS9 (NO) 35 (Outside PA)
OPS10 (NO)
RP1 3.7.11 - 3.7.14 - FLEX Water Deployment RP2 50 (Outside PA) 3.7.15 - 3.7.17 - FLEX Water Deployment OPS9 (NO) 10 (Outside PA)
OPS10 (NO) 3.7.18 - 3.7.22 - FLEX Water Deployment OPS9 (NO) 15 (Outside PA)
OPS10 (NO) 4 - FLEX Water Filling Hose and pump OPS10 (NO) 20 operation Monitoring pump and DG RP1 Ongoing until ERO Relieved OPS 10 Total 7 positions 29.FSG.03 RPV PRESSURE CONTROL OPS3 (NSO)
As needed Completed as part of AOP OPS2 (CRS)
As needed Completed as part of AOP 29.FSG.04 FLEX AC 3 - AC Load Restoration Div. 1 OPS4 (NSO) 78 3 - AC Load Restoration Div. 1 OPS7 (NO) 71 OPS8 (NO) 3.2-AC Load Restoration Div. 2 OPS4 (NSO) 62 OPS7 (NO) 23
Table 8 - Strategy Resource Loading Strategy Description Resources Duration Notes (Minutes) 29.FSG.12 FLEX FP INJECTION Completed at same time 29.FSG.05 CONTAINMENT COOLING 3.1-FLEX Water/Bleed Path Alignment OPS7 (NO) 15 4.1-FLEX Water/Bleed Path Alignment OPS8 (NO) 37 3.1 &4.1-FLEX Water/Bleed Path OPS4 (NSO) 28 Alignment 3.3, 4.1.5-4.1.8 - FLEX Water/Bleed Path OPS5 (NSO) 8 Alignment 29.FSG.07 ARI DEFEAT OPS7 (NO) 40 Completed at same time 29.FSG.08 HPCI DEFEATS OPS8 (NO) 29.FSG.09 RCIC TURBINE TRIP/ISOLATION DEFEATS TO SUPPORT FLEX 29.FSG.10 DIESEL AIR COMPRESSOR 4 - position diesel OPS10 (NO) 50 3 - route hoses M1 40 M2 29.FSG.14 HPCI/RCIC OIL COOLING Hook up hose Unknown - initially 85 This task was assigned after assigned to fire all other tasks were completed.
brigade qualified Numerous resources were persons.
available. Task was not further evaluated because of undetermined qualifications to wear fire suits and if RP job coverage was needed.
Time Sensitive Task Resource Limiting Task 29.FSG.01 & 29.FSG.02
- 29. FSG.06, COMMUNICATION: manages enhanced communication performed as part of other tasks
- 29. FSG.13, CONTAINMENT VENTING, Contingency, not evaluated 24
Table 9 - Communication Table TASK METHOD Assigned Person Number Source Satellite Phone Used (Simulated)
Notify ORO from Installed Satellite Phone RERP Communicator 1
CR Gateway SAT 28 Control Room (OPS12)
Notify NRC from Installed Satellite Phone RERP Communicator 1
CR Gateway SAT 28 Control Room (OPS 12)
Notify SAFER Installed Satellite Phone SM (OPSO1) 1 CR Gateway SAT 1 CR from Control Room and NRC Continuous, when requested Communicate from Installed Satellite Phone Hl lP603 (OPS04) 1 CR Gateway SAT 2 CR Control Room with Handheld Radio NOs for SBO and FLEX strategies Communicate with Handheld Satellite Phone Patrol NSO (OPS05) 1 OSC Cabinet SAT 35 NOs for strategies Handheld Radio Communicate with Handheld Satellite Phone OPS06 1 each OSC Cabinet SAT 16 CR and Patrol NSO Handheld Radio Communicate with Handheld Satellite Phone OPS09 1 each OSC Cabinet SAT 17 CR and Patrol NSO Handheld Radio FLEX Strategies Handheld Radio OPS 07 1
OSC Cabinet Note 1 FLEX Strategies Handheld Radio OPS 08 1
OSC Cabinet Note 1 FLEX Strategies Handheld Radio OPS 10 1
OSC Cabinet Note 1 FLEX Strategies Handheld Radio RPO1 1
OSC Cabinet Note 1 FLEX Strategies Handheld Radio M01 1
OSC Cabinet Note 1 FLEX Strategies Handheld Radio RPO2 1
OSC Cabinet Note 1 FLEX Strategies Handheld Radio M02 1
OSC Cabinet Note 1 Note 1 - SAT 34 is at the FLEX Support Facility 1 and SAT 33 is at FLEX Support Facility 2 to allow communication from each building.
25
Table 10 - Augmenting Emergency Response Organization ERO Position Number on Team Total TSC Emergency Director 1
4 TSC Technical Engineer 1
4 TSC Operation Liaison 1
4 TSC Tech. Comm.
1 5
TSC NRC Tech. Comm.
1 4
TSC Communicator 1
4 TSC Nuclear Safety Advisor 1
4 TSC Mechanical Engineer Note1 1
5 TSC Electrical Engineer Note 1 1
5 TSC I & C Engineer Note 1 1
5 TSC Thermal/Hydraulic Engineer Note 1 1
5 TSC System Engineer Note 1
1 5
TSC Emergency Status Engineers 1
4 TSC Rad. Protection Advisor 1
4 TSC Asst. Rad. Protection Advisor 1
4 TSC Dose Assessor 1
4 TSC Rad. Chem Advisor 1
4 TSC Administrator 2
8 TSC Administrative Support 1
4 TSC Security Advisor 1
4 OSC Coordinator 1
4 Asst. OSC Coordinator 2
8 OSC Maintenance Coordinator 1
4 OSC Asst. Maintenance Coordinator 2
8 EOF Emergency Officer 1
4 EOF Nuclear Ops Advisor 1
4 EOF Rad. Prot. Coordinator 1
4 EOF Asst. Rad. Prot. Coordinator 1
4 EOF Dose Assessor 1
4 EOF Administrator 2
8 EOF Communicator 2
8 EOF Status Board Clerk 2
8 EOF Public Info. Coordinator 1
4 EOF RET Coordinator 1
4 EOF Administrative Support 1
4 EOF Security Advisor 1
4 RET Drivers 4
16 RET Samplers 2
8 State Liaison 1
4 Monroe County Liaison 1
4 Wayne County Liaison 1
4 26
Table 10 - Augmenting Emergency Response Organization Notes
- 1.
Positions make up "Support Engineer" defined in Emergency Plan (1 individual out of pool of positions required to meet plan commitments, typical staffing includes 5).
- 2.
The ERO member total is typical for a 4 team rotation and may vary as a result of retirements, transfers, etc.
- 3.
The ERO reports to the Alternate Emergency Operations Facility in the event of a wide spread communications loss.
- 4.
Available methods of access to the Fermi 2 site from land, air and water include:
Land Routes
- a. The primary access to the Fermi 2 site is via a wide road that is surrounded by open farm fields. There are limited structures that may impact access.
- b. A separate (over mile distant) access route to an alternate site access point is available.
- c. The primary and alternate access routes are accessible from the local road network from many directions.
- d. Two major interstate highways provide near site access to Fermi 2.
- e. Fermi 2 has coordinated plans with both Monroe and Wayne County and the State of Michigan governments for assistance to maintain site access.
Air Access
- a. Three on-site helicopter pads are located at the Fermi 2 site (Two are required by the Emergency Plan)
" Water Access
- a. Access to the Fermi 2 site from Lake Erie is available within the General Service Water intake area and at a construction barge slip.
- 5.
Following a beyond design basis external event, on-site Radiation Protection (RP) Technicians are available in sufficient numbers to support performance of assigned emergency plan functions and the expanded response capability.
- 6.
For ERO augmentation, the emergency plan implementing procedure EP-220 requires a total of 14 Radiation Protection (RP)
Technicians. As of February 12, 2015, there are a total of 43 RP qualified personnel (qualification number SAP 42001722) and 36 Radiological Emergency Teams (RET) qualified personnel (qualification number SAP 42001591). The qualified staff varies from month to month and the number of personnel provided here represents only a benchmark that minimum qualified staffing for ERO augmentation is available to support the emergency plan, as well as an ELAP.
- 7.
For ERO augmentation, total number of OSC personnel required for Damage Control and Rescue is five (5) (EP-204-01).
On February 12, 2015, there are a total of 212 qualified personnel (qualification number SAP 42001593). The qualified staff varies from month to month and the number of personnel provided here represents only a benchmark that minimum qualified staffing for ERO augmentation is available to support the emergency plan, as well as an ELAP.
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