Text

Response to December 16, 2013 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times
	ML14044A059
Person / Time
Site:	Palisades
Issue date:	02/13/2014
From:	Vitale A; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PNP 2014-003
	Download: ML14044A059 (224)
	v • d • e

Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 Tel 269 764 2000 Anthony J. Vitale Site Vice President PNP 2014-003 February 13, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to December 16, 2013 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times Palisades Nuclear Plant Docket 50-255 License No. DPR-20

REFERENCES:

1. Entergy Nuclear Operations, Inc. (ENO) letter to NRC, PNP 2013-044, License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated June 25, 2013 (ADAMS Accession No. ML13176A405).

2. NRC email to ENO, MF2321 PNP Request for Additional Information (RAI) for License Amendment Request to Revise ERO Staff Augmentation Response Times, dated July 23, 2013.

3. ENO letter to NRC, PNP 2013-060, Response to Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times, dated August 7, 2013 (ADAMS Accession No. ML13220A008).

4. NRC email to ENO, Request for Additional Information -

Palisades - Proposed Revision to Palisades Site Emergency Plan (SEP) to increase the staff Augmentation response time for certain Emergency Response Organization (ERO) positions from 30 to 60 minutes - MF2321, dated December 16, 2013.

PNP 2014-003 PNP 2014-003 Page 22 Page Dear Sir

Dear Sir or Madam:

or Madam:

In Reference In Reference 1, 1, Entergy Nuclear Operations, Entergy Nuclear Operations, Inc.

Inc. (ENO)

(ENO) submitted submitted aa license license amendment request amendment request to revise the to revise Site Emergency the Site Emergency Plan Plan (SEP)

(SEP) atat the Palisades Nuclear the Palisades Nuclear Plant (PNP).

Plant (PNP). The proposed amendment The proposed amendment would would revise revise the the PNP PNP SEP SEP to to increase increase the the staff augmentation response staff augmentation response times times for for certain certain emergency emergency response response organization organization positions. In positions. Reference 2, In Reference 2, ENO ENO received received aa request request for for additional additional information information (RAI)

(RAI) concerning the concerning the license license amendment amendment requestrequest (LAR),

(LAR), and and ENO ENO responded responded to to the the RAI RAI in in Reference 3. ENO received Reference 3. ENO received aa second second RAIRAI in in Reference Reference 4. 4.

The ENO The ENO response response to to the RAI in the RAI Reference 44 is in Reference is provided provided in in Attachment Attachment 1. 1.

Attachment 22 contains Attachment contains offsite offsite dose dose assessment assessment training training documentation, documentation, as as discussed discussed in in Attachment 1. 1. Attachment 33 contains contains the On-shift On-shift Staffing Staffing Analysis Report, Revision Revision 1, 1, as discussed in Attachment 1. Attachment 4 contains a marked up version of the On-shift Staffing Analysis Report, Revision 1.

shift 1. Attachment 5 containscontains the proposed revision to PNP SEP Figure 5-2, which is unchanged from the license amendment request except for an updated reference to the revised On-shift Staffing Analysis Report.

Attachment 6 contains changes to SEP Section 5.4, which align the section with the SEP Figure 5-2 changes proposed in the license amendment request. Attachment 7 contains a marked up version of the changes to SEP Section 5.4.

A copy of this response has been provided to the designated representative representative of the State of Michigan.

This letter contains no new or revised commitment commitments. s.

II declare under penalty of perjury that the foregoing is true and correct. Executed on February 13, 13, 2014.

Sincerely, ajv/jse ajv/jse Attachments Attachments: : 1.1. Response Response to to December December 16, 16, 2013 2013 Request Request forfor Additional Additional Information Information for for License License Amendment Amendment Request Request to to Revise Revise Emergency Emergency

Response

Response Organization Organization Staff Staff Augmentatio Augmentation Response n Response Times Times 2.

2. Offsite Offsite Dose Dose Assessment Assessment Training Training Documentati Documentation on 3.

3. On-shift On-shift Staffing Staffing Analysis Analysis Report, Report, Revision Revision 11 4.

4. On-shift On-shift Staffing Staffing Analysis Analysis Report, Report, Revision Revision 11 (marked (marked up up version) version)

PNP 2014-003 Page 3

5. Proposed Revision to Palisades Nuclear Plant Site Emergency Plan Figure 5-2

6. Proposed Revision to Palisades Nuclear Plant Site Emergency Plan Section 5.4

7. Proposed Revision to Palisades Nuclear Plant Site Emergency Plan Section 5.4 (marked up version) cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC State of Michigan

ATTACHMENT 1 RESPONSE TO DECEMBER 16, 2013 REQUEST FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST TO REVISE EMERGENCY RESPONSE ORGANIZATION STAFF AUGMENTATION RESPONSE TIMES A follow-up request for additional information (RAI) was received from the Nuclear Regulatory Commission (NRC), by electronic mail on December 16, 2013. The Entergy Nuclear Operations, Inc. (ENO) Palisades Nuclear Plant (PNP) response to the RAI is provided below.

The RAI questions reference the following documents:

Reference 1: ENO letter dated June 25, 2013 (ADAMS Accession No. ML1317A405)

Reference 2: ENO letter dated August 7, 2013 (ADAMS Accession No. ML13220A008)

Reference 3: NEI 10-05, Revision 0 (ADAMS Accession No. ML111751698)

Reference 4: NSIR/DPR ISG-01 (ADAMS Accession No. ML113010523)

NRC Request (December 16, 2013)

1. Section 4.2.4.2 of Reference 1 states that the on-shift Chemistry Technician is not required to perform any chemistry/radiochemistry sampling within the first 90-minutes of an analyzed event. Please explain how the reactor coolant sampling related emergency action levels (EALs) are determined for events that result in a loss of all three fission product barriers with no advance warning as required by section 2.10 of Reference 3. In addition, section 4.2.4.2 also states that the on-shift Chemistry Technician can perform offsite dose assessment calculations, including backup methodologies. Please provide evidence to support the qualifications of the on-shift Chemistry Technician to perform the normal and backup methods of offsite dose assessment calculations.

ENO Response

1. An event that results in a loss of all three fission product barriers would represent a condition that is already at a higher emergency classification than any emergency classification that could be achieved from EAL thresholds associated with sampling. For this condition, other fission product barrier EALs would be applied in order to facilitate timely assessment and classification of an emergency.

Containment isolation would occur for accidents of this type. In order to collect and analyze a primary coolant sample following such an event, containment must be un-isolated manually. The On-shift Staffing Analysis (OSA) Report 1 of 20

appropriately assessed that these actions would not take place in the first 90 minutes following such an accident sequence.

The qualification card used for offsite dose assessment training of the Chemistry Technician is provided in Attachment 2. The qualification card requires completion of an offsite dose assessment course as a prerequisite and also requires demonstration of dose assessment tasks.

Section 4.2.4.2 of Reference 1 states that backup methodologies for inputs are provided should these indications fail or otherwise not be available. This statement refers to the inputs provided for dose assessment, specifically meteorological data, rather than additional dose assessment methodologies that the Chemistry Technician is trained to implement.

NRC Request (December 16, 2013)

2. Section 4.2.4.4 of Reference 1 states that in-plant radiological monitoring instrumentation is sufficient for monitoring radiological conditions in the plant thus reducing the need for radiation protection (RP) personnel to enter the plant to obtain radiological data. Please explain how on-shift staff are made knowledgeable of area radiation levels in unknown and potentially escalating radioactive environments for events that result in an immediate loss of all three fission product barriers, which may potentially cause in-plant radiological instrumentation to be off-scale.

ENO Response

2. Thirty-four continuous monitoring points within the plant are selected to provide indication and warning where radioactivity may be present using area radiation monitors. All of these monitors have an upper range of at least 107 mrem/hr, providing sufficient range for severe accident conditions to provide indication of escalating radioactive environments. The Shift Manager prioritizes response actions based on all such inputs as well as knowledge of areas that may or may not need to be accessed. Areas will not be accessed to determine conditions if there is not an operational need.

In addition, PNP provides a specific radiation work permit with emergency dose and dose rate limits for entry into areas under accident conditions. The established dose and dose rate limits for this radiation work permit are set for levels significantly higher than those expected for work performed under normal operating conditions. These values represent turn back limits where, if encountered, work is stopped, the area is exited, and additional instructions and follow-up with the Shift Manager and Radiation Protection is required, protecting worker safety. This radiation work permit is continuously available on the 2 of 20

automated radiological access control system and does not require action by the on-shift RP Technician to set up or initiate for use.

Dedicated electronic alarming dosimeters set to the emergency radiation work permit limits are provided in the immediate Control Room area and at the radiological access control point. The alarming instrumentation provides a continuous indication of the dose and dose rate for personnel entering areas where there is a need to perform an operational response action. Under the conditions presented in this RAI question and given an operational need to enter an area, personnel may enter the area under the emergency radiation work permit and its established limits without RP escort. Should personnel receive an alarm on dose or dose rate, they are required to exit the area immediately for additional instructions and follow-up. The on-shift RP Technician is assigned to support on-shift Operator actions as prioritized by the Shift Manager.

NRC Request (December 16, 2013)

3. Section 4.2.5.1 of Reference 1 justifies the increase in response time for the Shift Engineer/Shift Technical Advisor (STA) by the addition of an on-shift Communicator. Please explain how the addition of an on-shift Communicator justifies the increase in response time for the core/thermal hydraulic technical support function, which is not related to the need for communications.

ENO Response

3. ENO understands this RAI to refer to the requested increase in response time for the Technical Support Center core/thermal hydraulics augmented responder from 30 to 60 minutes. The addition of an on-shift Communicator is not in itself intended to justify the increase in response time for the core/thermal hydraulic technical support function. The addition of the communicator to the on-shift staff complement was referenced because it ensures the STA remains available to monitor core/thermal hydraulics and provide technical support for the additional 30 minutes of technical support response time requested. The STA monitors core/thermal hydraulics and provides technical support throughout the event until relieved by the augmented Emergency Response Organization (ERO).

Previous to the changes resulting from the On-shift Staffing Analysis Report, the STA may have performed communications duties for some events.

Further justification for the requested additional 30 minutes of technical support response time is related to enhanced STA training as discussed in item number 11 of section 4.2.10 of Reference 1. This item reads as follows: The Shift Technical Advisor (STA) was originally trained as an advisor to the Control Room operating shift per NUREG-0737 Clarification of TMI Action Plan Requirements. In 1990, additional guidelines were developed by the Institute of Nuclear Plant Operations (INPO) for the training of STAs. This is 3 of 20

detailed in the guidance document INPO 90-003, Guidelines for the Training and Qualification of Shift Technical Advisors. The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations.

They also contribute to operations during normal plant conditions. By routine monitoring of equipment and plant operations, the STA can focus on preventative actions in order to mitigate the consequences of an accident.

In addition, since the PNP SEP was originally issued in the early 1980s, several changes have occurred that have lessened the burden on the STA during postulated events. In the 1990s, the PNP plant process computer (PPC) was installed. This computer provides plant personnel, including the STA, the capability to monitor and trend plant parameters in real time, including primary coolant system parameters, reactor core thermal performance parameters, emergency core cooling system parameters, meteorological data, containment isolation status, and radiation monitor readings. The Emergency Operating Procedures and Severe Accident Management Guidelines were implemented to improve the quality of operational information and guidance during emergency events. These improvements in the monitoring of plant parameters via the PPC, and in emergency procedures, have lessened the burden on the STA during postulated events.

NRC Request (December 16, 2013)

4. Section 4.2.5.2 of Reference 1 states that during the initial stages of an event, the major response activities are concentrated on determining the cause of the event and placing the plant in a safe condition through plant manipulations and system alignments. While the staff agrees with this statement, the repair and/or corrective action(s) needed during the most significant events are related to issues with the emergency core cooling system (ECCS) not operating correctly.

Please elaborate as to how the Nuclear Plant Operators can perform action(s) typically assigned to qualified maintenance personnel for all reasonable failure modes of ECCS equipment, including logic manipulation. Please provide documentation that supports this analysis and supports the task(s) that the Nuclear Plant Operators may need to do, and the qualifications needed to perform them.

ENO Response

4. As noted in Section 2.5 of NEI 10-05, Analysis of Repair and Corrective Action Responses, a repair or corrective action is defined as an action that can be performed promptly to restore a non-functional component to functional status 4 of 20

(e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout or tagout controls to complete. The Nuclear Plant Operators are trained to perform repair and corrective action type tasks as defined in NEI 10-05.

The PNP ECCS includes four safety injection tanks, and two redundant, 100%

capacity trains, each containing low and high pressure safety injection pumps.

Backup power for each train is provided by a dedicated emergency diesel generator. All system components, including the emergency diesel generators, meet quality standards, and are designed to withstand phenomena such as seismic events, tornados, floods, and fires, without a loss of function. The site technical specifications contain operability and surveillance test requirements that assure that the ECCS is available to perform its required safety functions.

The ECCS is designed such that it can perform its safety functions assuming a single failure and a loss of offsite power, as required by 10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants. That is, the ECCS is designed to be capable of performing its required safety functions with no required repairs or corrective actions.

Repair and corrective actions as defined in NEI 10-05 are intended to enhance plant response in various accident scenarios and are limited in scope. Although highly unlikely, these actions may be desired to ensure that the ECCS performs its required functions. If any malfunction occurred that would require prompt manual action, the manual action would most likely involve a repair or corrective action as defined in NEI 10-05, which the Nuclear Plant Operators are fully capable of performing. These repair and corrective actions are to be promptly performed by Nuclear Plant Operators and are not dependent on the arrival of maintenance personnel on site. These actions involve activities such as resetting breakers and repositioning valves, prior to 90 minutes after event initiation. More complex and involved actions requiring maintenance personnel are not expected to be performed in a prompt manner (i.e., not within 90 minutes of event initiation), since work planning and implementation of tagout controls would typically preclude such prompt completion.

NRC Request (December 16, 2013)

5. Section 4.2.6.1 of Reference 1 provides an analysis of the PNP automated radiation work permit system but does not discuss how this automated system would work during accident conditions, particularly those with extensive radioactive environments and changing plant conditions. Is the system automation capable of adjusting dose margins when entry is required during the most egregious accident scenarios, i.e., an immediate loss of all three fission product barriers? If RP involvement is necessary, please provide an evaluation of the impact on the on-shift RP Technician.

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ENO Response

5. As stated in the response to RAI #2, an emergency radiation work permit is pre-established allowing immediate access to areas with elevated radiological conditions when access is required to support operational needs. RP action is not required to adjust dose margins, set up, or initiate this radiation work permit for emergency use.

NRC Request (December 16, 2013)

6. Section 4.2.6.2 of Reference 1 provides justification for changing the RP Technician response time that includes the use of installed area radiation monitoring (ARMs) alarming at preset dose and dose rates. Please explain how these ARMs will suffice for events that are based upon an immediate loss of all three fission product barriers and thus may introduce dose or dose rates significantly greater than the alarm setpoints and/or the scale of the ARMs.

ENO Response

6. See response to RAI #2.

NRC Request (December 16, 2013)

7.Section II of Reference 2 states that the accident scenario of a main control room fire and shutdown at the remote shutdown panel is the most limiting. The staff believes that the accident scenario related to 10 CFR 50.54(hh)(1), involving potential or actual aircraft attacks could potentially be the accident scenario which would require the most use of available on-shift staff, particular those who would be assigned fire brigade duties or tasked with manipulating plant equipment in preparation for the potential attack. Please provide more justification that supports this decision.

ENO Response

7. ENO has revised the On-shift Staffing Analysis Report provided in Reference 2 to provide clarification and to update the analysis. A different treatment of the potential or actual aircraft attack-initiated accident scenario is provided in the revised analysis. In addition, the On-shift Staffing Analysis Report no longer specifies a most limiting accident scenario, providing better alignment with NEI 10-05. The revised report is provided in Attachments 3 and 4.

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NRC Request (December 16, 2013)

8.Section II.C of Reference 2 justifies adding the responsibility of some site specific event notifications to the Shift Manager by stating that they are of a limited duration and does not require a time motion study (TMS) or analysis to justify it.

While individual ERO functions of limited duration may be added without needing a TMS to justify it, the number of ERO functions assigned to the Shift Manager may be extra burdens that could affect the timeliness of emergency response actions. Please justify how these extra functions would not affect the timeliness of the Shift Managers responsibilities.

ENO Response

8. ENO has revised the On-shift Staffing Analysis Report provided in Reference 2 to provide clarification and to update the analysis. The revised analysis is provided in Attachments 3 and 4. The site specific notifications referenced above represent notifications to senior plant management (e.g., Duty Plant Manager, Operations Manager, and NRC Resident Inspector). These notifications are of short duration and were deemed acceptable in accordance with the guidance of NEI 10-05, Sections 3.1.13 and 3.2.2.6(a)(14). Additionally, the Shift Manager is routinely evaluated in the ability to maintain effective oversight and control of the plant and situational awareness of the event while performing various emergency response tasks, including the notifications noted above. These evaluations are normally in the form of simulator sessions during Operations training or emergency preparedness drills, and routinely test the ability of the Shift Manager to manage these various tasks while continuing to maintain oversight and control of the plant and situational awareness of the event. Finally, the notifications to ENO management are discretionary in the sense that a Shift Manager is empowered as the senior management representative with all final decision making authority. These notifications are not required in order for the Shift Manager to make decisions.

NRC Request (December 16, 2013)

9.Section II.C of Reference 2 states that an analysis, or TMS, is not needed to support the addition of communicator duties to a Nuclear Plant Operator, RP Technician, or Chemistry Technician, for a 10 CFR 50.54(hh) event. Please provide further technical discussions for this statement as the staff cannot determine what duties are assigned to these positions for this accident scenario.

ENO Response

9. No specific time-critical tasks/duties are assigned to the RP Technician or Chemistry Technician for a 10 CFR 50.54(hh) event. The RP Technician and Chemistry Technician are not assigned to the Fire Brigade at PNP. Additionally, 7 of 20

the RP Technician and multiple Nuclear Plant Operators have no time-critical tasks/duties, other than relocating to non-target areas of the plant, and are available (if needed) to maintain an open phone line with the NRC.

NRC Request (December 16, 2013)

10.Section IV.C.2, and Appendix A (Event # 14), of Reference 2 states that no emergency declaration would be expected for a dropped spent fuel cask. Please explain when EAL E-HU1 would be declared and provide further explanations as appropriate.

ENO Response

10. PNP Emergency Action Level (EAL) EU1.1 would be expected to be declared anytime the EAL entry conditions are met (i.e., damage to a loaded cask confinement boundary). A NRC-approved single failure proof crane is used to transport spent fuel casks, so a dropped spent fuel cask while transferring a loaded cask from the spent fuel pool to track alley is not expected.

In addition, spent fuel casks are designed such that the structural integrity of the cask would not be compromised under postulated cask drop scenarios while the loaded cask is transported from the plant out to the concrete cask storage pad.

Personnel, in addition to the minimum on-shift complement, would be assigned to the spent fuel movement and cask loading operations, including Radiation Protection personnel, and would be immediately available to respond to the event.

NRC Request (December 16, 2013)

11. Reference 2, Appendix B, Event #1, Design Basis Threat (DBT):

a. Please explain why a water-based threat was not analyzed, do not use sensitive or safeguard information to respond.

b. In accordance with the direction given in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the emergency classification level (ECL) ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

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iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

c. Please explain the basis for why the STA was not analyzed to justify the responsibility of performing notification to the NRC of the DBT event.

d. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

e. Reference 4, section IV.C (page 14) states that licensees should ensure that sufficient staff is available to simultaneously implement both the emergency plan and the security plan in a DBT environment to include, as a minimum, the potential for restricted movement of site personnel. The staff can find no evidence of this being reviewed, please review and provide further information to support the justification.

ENO Response

11. ENO has revised the On-shift Staffing Analysis Report provided in Reference 2 to provide clarification and to update the analysis. The revised report is provided in Attachments 3 and 4.

a. NEI 10-05, Appendix A, provides guidance to analyze the response to a land and/or waterborne hostile action and the assumptions to use associated with this DBT event. Using the assumptions provided in NEI 10-05, no additional actions were identified for the on-shift ERO when responding to a waterborne attack as compared to a ground attack.

b. The Shift Manager is routinely evaluated in the ability to maintain effective oversight and control of the plant and situational awareness of the event while performing the various emergency response tasks noted above.

These evaluations are normally in the form of simulator sessions during Operations training or emergency preparedness drills, and routinely test the ability of the Shift Manager to manage these various tasks while continuing to maintain oversight and control of the plant and situational awareness of the event.

Additionally, as noted in Section 3.2.3 of NEI 10-05, all of the tasks noted above (except ERO notification and other site specific notifications) are 9 of 20

acceptable tasks to be performed by the Shift Manager without requiring the performance of a TMS. The acceptability of the Shift Manager to perform ERO notification was documented in a TMS included in Section VIII of the On-shift Staffing Analysis Report. The acceptability of the Shift Manager to perform the brief communications identified as other site-specific event notifications is discussed in Section II. C. 2 of the On-shift Staffing Analysis Report, Section 3.1.13 of NEI 10-05, and the response to RAI #8. These other site-specific event notifications are normally limited to brief notifications to the Duty Plant Manager, Operations Manager, and Resident NRC Inspector. These short duration tasks were evaluated as being able to be performed by the Shift Manager without impacting the ability to perform other emergency functions/tasks.

Completion of State/Local notification form - As described in Table 5 - Line 8 of Attachment 3 for each analyzed event, the Shift Manager completes the State/local notification form. A computer is used to generate this form. Long-term observation of performance during drill and simulator session indicates this form can be completed in 1-2 minutes using the computer-driven menus and drop-down lists.

Completion of NRC event notification form - The completed State/Local message form as well as observation of actual plant conditions and decisions already made and communicated by the Shift Manager to the crew are used by the communicator to provide information to the NRC. The NRC event notification form (NRC Form 361) is not completed prior to calling the NRC for declared emergency events in the Control Room in the interest of providing timely notification.

ERDS activation - Subsequent to the completion of the original On-shift Staffing Analysis Report, PNP has established a 24/7 ERDS connection with the NRC, obviating the need for any member of the on-shift staff to establish the connection and start the transmission of data.

INPO/American Nuclear Insurers (ANI) - INPO/American Nuclear Insurers (ANI) - Other notifications, such as notifications to INPO and ANI, are not made by the on-shift staff, but instead are deferred to other supporting staff.

c. The STA position was analyzed to perform the abbreviated NRC notification for the DBT security threat event as noted in Appendix B, Accident Analysis

1, Table 5, Line #7, in the On-shift Staffing Analysis Report.

d. Thirty-minute responders are listed in the applicable table of the On-shift Staffing Analysis Report in accordance with the formatting requirements of NEI 10-05, Section 3.2.2.2.c, to depict existing SEP information.Section V.A.2 of the report indicates that the analysis was performed using a 90-minute augmentation response time. Upon approval of the changes 10 of 20

requested in Reference 1, members of the augmented ERO would arrive within 60 minutes to relieve the on-shift Communicator and RP #1.

e. The On-shift Staffing Analysis Report verified the staff needed to simultaneously implement both the SEP and Security Plan in a DBT environment. The specific actions required to implement the SEP are detailed in Attachment 3. The analysis verified the on-shift Security staff was not needed to implement any immediate primary SEP response actions, leaving them available to implement required Security Plan actions for a DBT event. Security personnel are not assigned to the fire brigade at PNP.

NRC Request (December 16, 2013)

12. Reference 2, Appendix B, Event #2, Control Rod Ejection Accident:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 12.a. See RAI #11 response b.

12.b. See RAI #11 response d.

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NRC Request (December 16, 2013)

13. Reference 2, Appendix B, Event #3, Small Line Break Outside Containment:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 13.a. See RAI #11 response b.

13.b. See RAI #11 response d.

NRC Request (December 16, 2013)

14. Reference 2, Appendix B, Event #4, Main Steam Line Break Inside Containment:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL 12 of 20

ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 14.a. See RAI #11 response b.

14.b. See RAI #11 response d.

NRC Request (December 16, 2013)

15. Reference 2, Appendix B, Event #5, Loss of Coolant Accident:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS 13 of 20

viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 15.a. See RAI #11 response b.

15.b. See RAI #11 response d.

NRC Request (December 16, 2013)

16. Reference 2, Appendix B, Event #6, Fuel Handling Accident;

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 16.a. See RAI #11 response b.

16.b. See RAI #11 response d.

14 of 20

NRC Request (December 16, 2013)

17. Reference 2, Appendix B, Event #7, Waste Tank Rupture:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 17.a. See RAI #11 response b.

17.b. See RAI #11 response d.

NRC Request (December 16, 2013)

18. Reference 2, Appendix B, Event #8, Aircraft Probable Threat:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL ii. Approve content of State/Local notifications 15 of 20

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

c. The guidance in Reference 3, specifically Section 2.13, requires a site-specific list of response tasks for this event, and a collateral duty analysis (with possible TMS) to verify personnel are not assigned ERO functions that would preclude timely performance of their other assigned functions. As stated in the assumptions for this event in Reference 2, consideration of the dispersal of the site fire brigade away from target areas must be given, note that Table 3 appears to be inconsistent with this assumption. Please follow the guidance provided in Section 2.13 of Reference 3 and revise accordingly.

ENO Response 18.a. See RAI #11 response b.

18.b. See RAI #11 response d.

18.c. ENO has revised the On-shift Staffing Analysis Report provided in Reference 2 to provide clarification and to update the analysis. The revised report is provided in Attachments 3 and 4.

NRC Request (December 16, 2013)

19. Reference 2, Appendix B, Event #9, Control Room Fire Requiring Evacuation and Remote Shutdown:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

16 of 20

i. Declare the ECL ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

c. In accordance with Section 2.9 of Reference 3, please provide the validation results for the assessment and determination that this event scenario is the most limiting fire related scenario.

ENO Response 19.a. See RAI #11 response b.

19.b. See RAI #11 response d.

19.c. ENO has revised the On-shift Staffing Analysis Report provided in Reference 2 to provide clarification and to update the analysis. Specifically, in Section IV.C.3 of the report, a discussion was added concerning the basis for the most limiting fire scenarios. The revised report is provided in Attachments 3 and 4.

NRC Request (December 16, 2013)

20. Reference 2, Appendix B, Event #10, Station Blackout:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL 17 of 20

ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 20.a. See RAI #11 response b.

20.b. See RAI #11 response d.

NRC Request (December 16, 2013)

21. Reference 2, Appendix B, Event #11, LOCA/General Emergency with Release and PAR:

a. Please explain why the accident assumption is made that this event would be prefaced by the declaration of a Site Area Emergency (SAE), and thus all actions for the SAE are completed. Reference 3, Section 2.10, and Reference 4,Section IV.C, do not make this assumption. This event is based upon an immediate loss of all three fission product barriers with an offsite release, regardless of cause, and expects the on-shift organization to be able to effectively implement the emergency plan until relieved by the ERO staff, as paraphrased from Reference 3, 2.10, and Reference 4,Section IV.C.

Please explain.

b. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL 18 of 20

ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

c. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 21.a. ENO has revised the On-shift Staffing Analysis Report provided in Reference 2 to provide clarification and to update the analysis. The revised report is provided in Attachments 3 and 4. The updated report analyzes an event that goes directly to a General Emergency.

21.b. See RAI #11 response b.

NRC Request (December 16, 2013)

22. Reference 2, Appendix B, Event #15, Steam Tube Rupture with Concurrent Loss of Off-Site Power:

a. In accordance with the guidance provided in Reference 4, IV.C, please explain how the Shift Manager can perform the following and still maintain effective oversight and control of the plant, and maintain situational awareness of the event:

i. Declare the ECL ii. Approve content of State/Local notifications

1. Who completes this content? This is not listed in the ON-SHIFT STAFFING ANALYSIS and was not analyzed.

iii. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.)

iv. ERO notification

v. Complete State/Local notification form 19 of 20

1. Inconsistent with ii above, please explain.

vi. Complete NRC event notification form vii. Activate ERDS viii. Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

b. Please explain who will be relieving the Communicator and RP #1 within 30-minutes as depicted on Table #1 for this event.

ENO Response 22.a. See RAI #11 response b.

22.b. See RAI #11 response d.

20 of 20

ATTACHMENT 2 OFFSITE DOSE ASSESSMENT TRAINING DOCUMENTATION 5 Pages Follow

NOTE This form is used to approve training materials that do not have a review/approval block.

TRAINING MATERIAL NUMBER:

PL-RPR- 582-206O Rev 1

TRAINING MATERIAL TITLE:

Perform Quick Method Dose Assessment per EI-6.0 Offsite Dose Calculation and Recommendation for Protective Actions Lesson Plan Qualification Card / Lab Guide Simulator Guide Familiarization Guide CBT Course Electronic Document/Form Graded Approach to Training Other New Material Minor Revision Major Revision Cancellation Lesson Plan/Material Superseded REASON FOR REVISION (include reason for site specific exception date as necessary):

Chemistry went from PL-N00150 rev 8 Quick Dose Assessment to PLLP-CM-QUICK DOSE. Quick Dose Assessment as the prerequisite because EP needed to continue to use PL-N00150 for OPS. Thus chemistry made minor editoral changes to PL-N00150 rev 8 and renamed the class PLLP-CM-QUICK DOSE.

REVIEW / APPROVAL: Electronic Approval (TEAR )

Prepared By: Jarrod J Miller 01-21-13

- Preparer Date

Reviewed By: Michael G Mlynarek 01-07-13

- Technical Reviewer (e.g., SME, line management) Date

Instructional Adequacy Determined By: Walter E Nelson 01-07-13

- Instructional Technologist or Qualified Instructor Date Approved By: Walter E Nelson 01-21-13

- Discipline Training Superintendent or Fleet Training Manager Date

Technical review, instructional adequacy, and fleet review N/A for electronic document or form. Instructional adequacy review is not required for graded approach to training topics.

- Indicates that the training material has been reviewed for inclusion of items referenced on TQF-201-DD06, Training Material Checklist as appropriate.

FLEET PROGRAM REVIEW POINT OF CONTACT: Not Applicable Name or N/A Exception Date Name or N/A Exception Date ANO NP BRP PLP CNS PNPS GGNS RBS HQN VY IPEC W3 JAF Indexing Information Signed Copy on File Class Code:

END OF DOCUMENT ENTERGY NUCLEAR Page 1 E-DOC TITLE: E-DOC NO. REVISION NO.

TRAINING MATERIAL APPROVAL TQF-201-DD01 17

OJT and TPE Qualification Guide Trainee Name: Login ID:

Training Program: Chemistry Training ID #: PL-582 206 01 11 Perform Quick Method Dose Assessment per EI-6.0 Offsite Dose Calculation and Task

Title:

Recommendation for Protective Actions List the OE to be used for OJT:

OE25818, Dose Assessment Computer Program, Raddose V, failed during an Emergency Response Drill Prerequisites:

a. PLLP-CM-QUICKDOSE Quick Dose Assessment Prerequisites verified complete: /

Qualified Trainer Date OJT completed: /

Qualified Trainer (print & sign name) or N/A & Trainee Initial Date N/A if OJT challenged Task Performance Evaluation (TPE)

OJT has been completed / challenged per EN-TQ-204 for the listed task and I /

am ready to take the TPE. Trainee Signature (print and sign name) Date TPE unsuccessful (Document TPE failures per EN-TQ-204)

SAT - Task evaluation was successfully completed in accordance with EN-TQ-204.

/

Qualified Evaluator (print and sign name) Date Qualification Trainee is competent (qualified) to perform this task independently.

/

Training Program Owner or designee or N/A Date (N/A for Duty Area or Job Qualification) (print and sign name)

Verification Record has been verified to be complete.

/

Training Supervision (print and sign name) Date Training Records Updated Entered /

Print and Sign Name Date Send completed OJT/TPE Documentation and Comment Sheets to Training Records Check here indicates the LMS was updated.

ENTERGY NUCLEAR Page 2 of 5 E-DOC TITLE: E-DOC NO. REVISION NO.

OJT/TPE TQF-201-OJT 5

I. Task:

Perform Quick Method Dose Assessment per EI-6.0 Offsite Dose Calculation and Recommendation for Protective Actions II. Terminal Objective:

Given emergency conditions, perform Quick Dose Assessment Method in accordance with EI-6.0, Offsite Dose Calculation and Recommendations for Protective Actions and provide results to Control Room SRO.

III.

References:

1. EI-6.0 Offsite Dose Calculation and Recommendation for Protective Actions

2. EP Job Aid GEN-012, Palisades Event Technical Data Sheet Completion IV. General Tools and Equipment:

1. PPC (not required)

2. Dose Assessment computer V. Initial Conditions Perform Quick Method Dose Assessment per EI-6.0 Offsite Dose Calculation and Recommendation for Protective Actions per Shift Manager Direction.

VI. Personnel Safety Considerations No special PPE is required for this task VII. Commitments None VII. Instructor Notes/Set-up Simulator, TSC, and the Control Room all have a Dose Assessment computer ENTERGY NUCLEAR Page 3 of 5 E-DOC TITLE: E-DOC NO. REVISION NO.

OJT/TPE TQF-201-OJT 5

PERFORMANCE OBJECTIVES (Section I)

Task

Title:

Perform Quick Method Dose Assessment per EI-6.0 Offsite Dose Calculation and Recommendation for Protective Actions Task #: PL-582 206 01 11 Trainee Name Date Check if management observation required or stamp here Initial Continuing Overall Grade: PASS FAIL (Circle One)

Shaded objective numbers indicate a must perform step.

An

next to the objective number indicates an alternate path. All alternate paths must be trained during OJT; at least one alternate path per performance objective must be evaluated during TPE.

OBJECTIVES OJT TPE Code Complete Complete Management expectations/core work practices applied appropriately for the task. (See

1. P attachment 9.2 of EN-TQ-204 for pass/fail criteria)

Retrieve Meteorological data from the PPC and

2. P Dose Assessment computer Retrieve Meteorological data from the Control

3. S Room Perform Quick Method Dose Assessment per

4. EI-6.0 Offsite Dose Calculation and P Recommendation for Protective Actions

5. Determine if PAGs are exceeded. P ENTERGY NUCLEAR Page 4 of 5 E-DOC TITLE: E-DOC NO. REVISION NO.

OJT/TPE TQF-201-OJT 5

COMMENTS (Section II)

COMMENTS:

Any clarifying asked and the trainee response must be documented.

Note any opportunities for improvement provided to the trainee.

Note reason for TPE failure, if applicable.

ENTERGY NUCLEAR Page 5 of 5 E-DOC TITLE: E-DOC NO. REVISION NO.

OJT/TPE TQF-201-OJT 5

ATTACHMENT 3 ON-SHIFT STAFFING ANALYSIS REPORT, REVISION 1 92 Pages Follow

PALISADES ONSHIFT PALISADES ON-SHIFT STAFFING STAFFING ANALYIS ANALYIS REPORT PALISADES NUCLEAR STATION ON-SHIFT STAFFING ANALYSIS ONSHIFT Rev I1 February 10, 2014 Prepare d by: Pn 4 ~

//L-<r.J'91~

// Z Z- 7- /u Prepared by: ..

I M. F. Guynn I/ Date Review by ..

My(J .e ate I...,

Approved by: ~~~~~~~P!4t.::..L.~-

Dan Malone I/ Date

PALISADES ON-SHIFT STAFFING ANALYIS REPORT TABLE OF CONTENTS I. INTRODUCTION ............................................................................................................................ 4 II. ANALYSIS

SUMMARY

.................................................................................................................. 4 A. Emergency Plan Minimum Staffing .................................................................................. 5 B. Other Commitments to Shift Staffing ................................................................................ 6 C. Staffing Exceptions and Time Motion Studies (TMS) ..................................................... 6 D. Emergency Plan Tasks Not Analyzed .............................................................................. 7 III. ANALYSIS PROCESS ................................................................................................................... 8 IV. ACCIDENT SCENARIOS .............................................................................................................. 9 A. Accident Selection ............................................................................................................. 9 B. Accident Scenarios included in the Analysis ................................................................... 9 C. Accident Scenarios not included in the Analysis ........................................................... 10 V. GENERAL ASSUMPTIONS AND LIMITATIONS ...................................................................... 11 A. Notes and Assumptions applicable to all accidents in Palisades Staffing Analysis: .. 11 B. NEI 10-05 Rev 0 Assumptions........................................................................................ 12 VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS ........................................................ 14 VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS .................................................................. 16 A. Accident Analysis #1 - Design Basis Threat (DBT)...................................................... 16 B. Design Basis Accident Analysis #2 - Control Rod Ejection ......................................... 23 C. Design Basis Accident Analysis #3 - Small Line Break Outside Containment as described in FSAR 14.23 ................................................................................................ 29 D. Design Basis Accident Analysis #4 - Main Steam Line Break Inside Containment. . 35 E. Design Basis Accident Analysis #5 - Loss of Coolant Accident.................................. 41 F. Design Basis Accident Analysis #6 - Fuel Handling Accident ..................................... 47 G. Design Basis Accident Analysis #7 - Waste Tank Rupture ......................................... 53 H. Accident Analysis #8 - Aircraft Probable Threat ........................................................... 59 I. Accident Analysis #9 - Control Room Fire Requiring Evacuation and Remote Shutdown .......................................................................................................................... 65 J. Accident Analysis #10 - Station Blackout...................................................................... 71 K. Accident Analysis #11 - LOCA/General Emergency with Release and PAR............. 76 PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT L. Accident Analysis #15 - Steam Generator Tube Rupture with Concurrent Loss of Off-site Power................................................................................................................... 83 VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ...... 89 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ......................... 92 A. Overlap Requiring Compensatory Measures ................................................................ 92 X. CORRECTIVE ACTIONS ............................................................................................................ 92 A. Corrective Actions and Compensatory Measures......................................................... 92 XI. REFERENCES ............................................................................................................................. 93 XII. STAFFING ANALYIS TEAM........................................................................................................ 93 PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT I. INTRODUCTION This document is a revision to the Palisades Nuclear Station On-shift Staffing Analysis (OSA) report dated December 18, 2012.. This revision provides additional clarification to actions performed by on-shift staff, incorporates technological advancements implemented to reduce on-shift staff burden, and provides additional discussion of the basis for some evaluated events.

This revision continues to satisfy the requirements of 10 CFR 50 Appendix E Section IV.A.9, which states that nuclear power licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities. This analysis examined the capability of the minimum staff listed in Figure 5-2 of the Palisades Emergency Plan (E-Plan) to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-Plan.

II. ANALYSIS

SUMMARY

The OSA team determined that an on-shift staff of fourteen (14) is able to cope with the spectrum of analyzed events, as described in Section IV of this report, until augmenting Emergency Response Organization (ERO) staff arrives. The on-shift staff consists of individuals necessary to support each of the emergency plan functional areas or tasks:

Emergency Direction and Control Plant Operations and Safe Shutdown (SSD)

Fire Fighting (FB)

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

The minimum on-shift staffing identified by this analysis is reflected in Table 1, On-Shift Positions, for each analyzed event. This is intended to identify the analyzed tasks performed by each on-shift ERO staff member based on the findings of the OSA.

PALISADES Page

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

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

On-Shift Licensing Basis Staffing Position E-Plan Functional Area Requirement Analysis Results 50.54m Emergency Direction and 1 Shift Manager (SM) E-Plan Figure 5-2 Control 50.54m Control Room Supervisor (CRS) E-Plan Figure 5-2 SSD 1 E-Plan Figure 5-2 Shift Technical Advisor (STA) Technical Support 1 50.54m SSD Control Room Operator (RO #1) E-Plan Figure 5-2 1 50.54m SSD Control Room Operator (RO #2) E-Plan Figure 5-2 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #1) SSD 1 E-Plan Figure 5-2 FB Nuclear Plant Operator (NPO #2) 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #3) FB 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #4) FB 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #5) FB 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #6) FB 1 E-Plan Figure 5-2 Communicator Communications Notifications 1 E-Plan Figure 5-2 Accident Chemistry Technician 1 Assessment/Chemistry E-Plan Figure 5-2 Radiation Protection (RP) #1 Radiation Protection 1 Security Contingency Per Security Access Control and Security Plan/E-Plan Figure Contingency Accountability 5-2 Plan TOTAL 14 PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT B. Other Commitments to Shift Staffing No additional station commitments were identified conflicting with this staffing analysis.

C. Staffing Exceptions and Time Motion Studies (TMS)

1. The primary responsibility for the on-shift Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. As noted in the Site Emergency Plan, the on-shift Chemistry Technician may also be required to support the on-shift Radiation Protection Technician implement tasks to support the Major Functional Area of Protective Actions (In-plant).

While the capability to perform these tasks are specified in the Emergency Plan, this analysis did not identify the need to utilize the on-shift Chemistry Technician to perform any of these Radiation Protection related tasks. It is recognized, however, that the Shift Manager will prioritize and utilize the on-shift staff as needed. It is therefore acceptable to assign the Chemistry Technician the E-Plan function of dose assessment. No further analysis or TMS is required.

2. The Shift Manager is assigned the responsibility to make site specific event notifications to the Duty Plant Manager, Operations Manager, and Resident Inspector. These notifications by phone are considered communications that are approximately one minute in length and are deemed acceptable in accordance with NEI 10-05 Section 3.2.2 (6)(a)(14) due to the short duration of the notifications. Additionally, these notifications are collectively evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills and are not deemed as impacting the Shift Managers ability to maintain oversight of the event or perform other required emergency plan tasks. In accordance with the guidance of NEI 10-05, Line 14 of NEI Table 5 contained in Section VII of this report does not reflect the performance of these short duration notifications. No further analysis or TMS is required.

3. Station staff are required to maintain continuous communications with the notification source during an aircraft threat in accordance with 10CFR50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The analysis of this event identified that the on-shift chemistry technician has no other assigned tasks in response to this event and would be available if needed to perform this task during the event. No further analysis or TMS is required.

PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. The Shift Manager is assigned the task of notifying the off-shift ERO of the emergency. A Time Motion Study (TMS) was conducted to ensure the Shift Manager could perform the concurrent tasks of maintaining emergency direction and control while notifying the ERO of the event using Everbridge. The TMS demonstrated the Shift Manager was able to maintain Emergency Direction and Control during the approximate two minutes it took to notify the ERO using Everbridge.

Additionally, the task of ERO notification is routinely evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills.

5. The Palisades Emergency Response Data System (ERDS) link to the NRC is operated continuously and does not require activation following a declared emergency. The task of ERDS activation is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

6. NRC event notifications required due to the declaration of an Emergency Classification in accordance with 10 CFR 50.72 is made verbally using the Emergency Notification System. A written event notification form is not generated by on-shift staff for this notification. Formal written notifications to the NRC as may be required by 10 CFR 50.72 resulting from any of the analyzed events may be generated by the augmented staff. The task of completing the NRC event notification form is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

D. Emergency Plan Tasks Not Analyzed

1. Repair and Corrective Action - Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by shift personnel assigned other functions. Repair and corrective action is defined as:

An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g.,

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

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

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

Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

At Palisades, Nuclear Plant Operators are trained to perform the actions associated with this functional area. Actions (e.g., reset breakers, valve manipulation) directed by the Control Room Supervisor to mitigate the event per procedures were performed by the Nuclear Plant Operators in this analysis. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

2. Rescue Operations and First Aid: In accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response although neither task was required during the evaluated scenarios. Per the guidance of NUREG-0654, Table B-1, rescue operations and first aid may be performed by shift personnel assigned other functions. The on-shift Radiation Protection staff member is trained and available to perform first aid and the station Fire Brigade staff are trained and available to perform search and rescue if needed. Rescue operations and first aid response are acceptable collateral duties per the guidance of NEI 10-05.

III. ANALYSIS PROCESS The initial staffing analysis (Revision 0) was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments. Additionally, members of the Security staff provided input to the analysis.

The team members performing reviews to Revision 1 of the staffing analysis are identified in Section XII of this report. Revision 1 of this report was based on input, reviews and concurrence from station personnel from the same departments as those participating in the original analysis.

Each scenario was reviewed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for Emergency Plan implementation as described in the Emergency Plan Figure 5-2, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, the team evaluated timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements.

The results of the analysis for each of the scenarios are included in Section VIII, APPENDIX B - ON-SHIFT STAFFING ANALYSIS. Note that NSIR DPR-ISG-01 states that only DBA accidents which would result in an emergency declaration should be evaluated in the staffing assessment. Each of Palisades DBAs were evaluated and classified according to its FSAR Chapter 14 description. If the accident description alone did not result in a classification, the projected accident Exclusion Area Boundary (EAB) dose was utilized to determine if an EAL threshold would be exceeded within the first 60 minutes using the Abnormal Radiation Level EAL thresholds. In cases where several projected doses were provided or release data was not detailed significantly to determine an EAL, the assessment used the radiological consequences associated with the realistic case in accordance with NEI 10-05.

PALISADES Page

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

1. The OSA scenarios were chosen using the guidance of NEI 10-05 and NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants. The evaluation considered the station Design Basis Accidents (DBA) described in the USAR along with additional scenarios specified by the guidance documents. The scenarios considered were:

Design Basis Threat (DBT) ground assault Control Rod Ejection Accident Main Steam Line Break Accident Loss of Coolant Accident, (LOCA)

Fuel Handling Accident Aircraft Probable Threat Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire)

Station Blackout, (SBO)

LOCA/General Emergency with release and PAR LOCA with entry into Severe Accident Management Small Line Break Outside Containment Waste Gas Accident Steam Generator Tube Rupture (SGTR)

Dropped Cask Appendix R Fire B. Accident Scenarios included in the Analysis

1. Design Basis Threat (DBT) as described in NEI 10-05 The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

2. Control Rod Ejection Accident as described in FSAR 14.16 This event assumes the reactivity insertion from the control rod ejection results in an overpower trip. The thermal-hydraulic analysis for this event is performed for only a few seconds. The remaining consequences of this event are covered by the small break LOCA analysis as noted in Chapter 14.17.2 of the FSAR.

3. Main Steam Line Break (MSLB) Inside Containment as described in FSAR 14.14 This event assumes a double-ended guillotine break of a Main Steam Line inside containment with a loss of offsite power. Release information was not available in the FSAR, however, to determine if a radiation based EAL condition would be met in the first 60 minutes of the event. Emergency declaration was based on the loss of offsite power.

PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Loss of Coolant Accident as described in FSAR 14.17.

This event is defined by a large rupture of the PCS cold leg piping between the PCP and the reactor vessel for the PCS loop containing the pressurizer. This event also includes a loss of offsite power and failure of 1 diesel generator.

5. Fuel Handling Accident (FHA) as described in 14.19.

The FHA is assumed to occur in containment two days after shutdown. An Alert emergency declaration was assumed to be declared due to the event.

6. Aircraft Probable Threat (50.54hh)

Notification is received from the NRC that a probable aircraft threat exists (>5 minutes,

<30 minutes).

7. Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire) as described in NEI 10-05.

A fire occurs in the main control room requiring the evacuation and the procedure implemented to shutdown from the remote shutdown panels.

8. Station Blackout as described in NEI 10-05.

A loss of all offsite AC power occurs and the failure of the emergency diesel generators to start. The SM determines power cannot be restored and declares a SAE on EAL SS1.1.

9. LOCA/General Emergency (GE) with release and PAR as described in NEI 10-05.

This event is based on the same initial conditions of the LOCA but assumes system failures meet the GE conditions of a loss of 2 fission product boundaries with the potential loss of the third.

10. Small Line Break Outside Containment as described in FSAR 14.23.

This analysis assumes a charging line break resulting in a 160 gpm primary coolant leak outside containment.

11. Waste Gas Accident as described in FSAR 14.21.

This event assumes the rupture of a waste gas decay tank. EAL AA1.1 conditions are assumed to be met based on expected stack high range monitor readings.

12. Steam Generator Tube Rupture as described in FSAR 14.15 This event analyzes the response of a failure of a steam generator U-tube combined with a loss of offsite power.

C. Accident Scenarios not included in the Analysis

1. LOCA with entry into Severe Accident Management Guidelines (SAMG) as described in NEI 10-05.

NEI 10-05 Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators. Palisades SAMGs are guided by the TSC. All on-shift actions prior to off-site augmentation are performed by Licensed and Non-licensed operators. No additional analysis is required.

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT

2. Dropped Cask as described in FSAR 14.11.

Analyzed dropped cask events were identified as events that would only occur with the availability of additional station staff above and beyond those represented by station minimum staff and are outside the bounds of this analysis. Additionally, it was determined that no emergency declaration would be expected for this event.

3. Appendix R Fire The team concluded the Control Room and Cable Spreading Room fires to be the most limiting fire events for resources and therefore a staffing analysis for the additional Appendix R fire scenario is not required. A review of operating procedures indicated that a fire in either of these rooms involves essentially the same operator actions, so the analysis considers only the Control Room fire in identifying required operator actions.

The emergency plan and fire brigade responsibilities are the same for all fire events although the Control Room fire and the Cable Spreading Room fire also require the additional actions to support a remote plant shutdown. Station Fire Protection, Appendix R, and Operations staff were used to validate these fire events as being the most man-power intensive.

V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions applicable to all accidents in Palisades Staffing Analysis:

1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Off Normal Procedures (ONP), Emergency Operating Procedures (EOP), and Emergency Implementing Procedures (EI). Any additional tasks directed by the Technical Support Center (TSC), Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures were not reviewed.

2. Palisades has 30 minute and 60 minute emergency responders when augmented while the ERO is offsite. This analysis was conducted assuming a 90 minute response of the augmented ERO to allow the use of this analysis for a possible future extension in ERO augmentation times. No specific emergency response tasks requiring the augmented ERO were identified prior to the 90 minutes following the emergency declaration.

3. The OSA team determined there are no time critical RP and Chemistry tasks and that task performance is directed and prioritized by the Shift Manager. The time RP or Chemistry is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration.

Since the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.

4. All crews have one individual filling the SM and one individual filling the STA roles therefore the analysis did not consider using a dual-role individual.

PALISADES Page 11

PALISADES ON-SHIFT STAFFING ANALYIS REPORT B. NEI 10-05 Rev 0 Assumptions

1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task. As noted above, this analysis assumed a 90 minute augmentation time.

2. On-shift personnel complement was limited to the minimum required number and composition as described in the site emergency plan. If the plan commitments allow for different minimum staffing levels (e.g., a variance between a normal dayshift and a backshift), the staffing with the smallest total number of personnel was used for the analysis.

3. Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.

4. Event occurred during off-normal work hours where ERO was offsite and all required minimum on-shift positions were filled.

5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.

6. On-shift staff had necessary Radiation Worker qualification to obtain normal dosimetry and enter the radiological control area (RCA) (but not locked high or very high radiation areas) without the aid of a RP technician.

7. Personnel assigned plant operations and SSD met the requirements and guidance (analyzed through other programs such as operator training) and were not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

8. In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain safe shutdown were done by a member of the on-shift staff as defined in the units Tech Specs.

9. Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.

10. Individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.

11. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.

12. Communications, briefings, and peer checks are acceptable collateral duties.

13. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIR/DPR-ISG-01]

14. The Staffing Analysis specified the resources available to perform Repair and Corrective Actions and Rescue Operations and First Aid but these may be assigned as collateral duty to a designated on-shift responder.

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT

15. For assessment purposes, NRC notifications were treated as a continuous action per 10CFR50.72(c)(3) and 73.71(b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.

16. DBA (postulated accident, Condition IV event, or limiting fault) is considered as Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation. As a result, a greater number and variety of actions would need to be implemented by plant personnel.

17. Unless otherwise specified in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, or by the USAR initial conditions of a DBA analysis, it was assumed that the unit was in Mode 1, Power.

18. DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to prevent safe shutdown or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.

19. The Staffing Analysis used DBA analysis assumptions, inputs, timing of events, plant protective response, and specified manual operator actions and their timing, as documented in the FSAR.

20. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began 15-minutes after the initiating event.

21. Severe Accident Management Guideline (SAMG) - this analysis assumed the accident progressed to conditions requiring a severe accident response; it did not include determining specific failures and the accident sequence.

22. SAMG - The actions analyzed included those that implement the initial site-specific actions assuming the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent challenge to containment integrity.

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS Event Event Summary Description Plant Reference Analysis 1 Event ECL

Type of Event Mode Document(s) Required?

1 DBT Land and/or 1 NEI 10-05 Site Area Yes waterborne HOSTILE Emergency ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

2 DBA Control Rod Ejection 1 FSAR 14.16 Site Area Yes Emergency 3 DBA Small Line Break 1 FSAR 14.23 Site Area Yes Outside Containment Emergency 4 DBA Main Steam Line Break 1 FSAR 14.14 Unusual Yes Inside Containment Event (due with LOOP (bounding to LOOP) for steam piping failures) 5 DBA LOCA 1 FSAR 14.17 Site Area Yes Emergency 6 DBA Fuel Handling Accident 5 FSAR 14.19 Alert Yes 7 DBA Waste Tank Rupture 1 FSAR 14.21 Alert Yes 8 Assumed Aircraft Probable 1 10CFR50.54hh(1) Alert Yes for Threat analysis RG 1.214 purpose 9 Assumed Control Room 1 10CFR50 Alert Yes for Evacuation and Appendix R Analysis Remote Shutdown (fire Purpose in main control room) Procedure ONP-25.2 10 Assumed Station Blackout 1 10CFR50.63 Site Area Yes for Emergency analysis purpose 11 Assumed LOCA - General 1 ISG IV.C General Yes for Emergency with Emergency Analysis radiological release Purpose and PAR 12 Assumed LOCA with entry into 1 ISG IV.C General No2 for severe accident Emergency Analysis procedures.

Purpose PALISADES Page 14

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Event Event Summary Description Plant Reference Analysis Event ECL

Type of Event Mode1 Document(s) Required?

13 Assumed Appendix R Fire 1 ISG IV.C Alert No3 for Analysis Purpose 4

14 DBA Dropped Cask 1 FSAR 14.11 None No 15 DBA Steam Generator Tube 1 FSAR 14.15 Alert Yes Rupture with concurrent LOOP 1

Plant mode per FSAR or assumed for analysis purpose 2

SAMG is written to be implemented by the TSC. NEI 10-05 Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators. Palisades does not include maintenance qualified to perform maintenance job tasks in minimum staffing and any response actions would be performed by operators.

3 Appendix R Fire is bound by the Control Room Fire and Remote Shutdown.

4 No emergency declaration is expected for this event.

PALISADES Page 15

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

1. Accident Summary Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat.

This analysis concluded that sufficient staff was available to simultaneously implement both the emergency plan and the security plan. The conclusion that sufficient staff was available to implement the security plan was based on security staff personnel not being assigned collateral duties that would prevent the timely performance of their assigned functions.[m1] As noted in the analysis assumptions detailed in Section V.B.11 of this report and NEI 10-05 Section 3.1 items 12, the security organization is assumed to be able to satisfactorily perform all tasks related to Site and Protected Area Access Controls, under all event or accident conditions.

2. Accident Specific Assumptions Made The Palisades DBT for this analysis assumes a land based threat although a waterborne threat was also considered to determine if it was a more man-power limiting event. This analysis identified that a change to the mode of the attack did not impact the staffing analysis or identify the assignment of any additional collateral duties for on-shift personnel that would prevent the timely performance of their assigned functions as specified in the emergency plan.

This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

Assume at power in Mode 1 Security notifies the Shift Manager of condition of hostile action occurring within the protected area (Security code RED)

Assume all non-security staff is located inside the protected area at their normal work station when the event occurs.

Assume all systems function and the core remains covered. No fuel damage and no release.

3. Procedures for Accident Response AOP-44 Rev. 0, Response to Attack on Palisades EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4, Rev. 52, Operations Organization, Responsibilities and Conduct PALISADES Page 16

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 1 DBT Security Threat Augmentation Role in Line On-shift Unanalyzed TMS Basis Document Elapsed Time Table # /

Position Task? Required?

(min)* Line #

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 T2/L3 Shift Technical Emergency Plan 3 60 T5/L7 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 N/A No No Figure 5-2 Emergency Plan N/A 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A N/A No No Plan Figure 5-2 PALISADES Page 17

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 1 DBT Security Threat Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator Training 1 Shift Manager Program CRS Licensed Operator Training 2 Unit Supervisor Program STA Licensed Operator Training 3 Shift Technical Advisor Program Nuclear Control Operator Licensed Operator Training 4 Reactor Operator #1

1 Program Nuclear Control Operator Licensed Operator Training 5 Reactor Operator #2

2 Program Nuclear Plant Operator #1 Non-Licensed Operator 6 Auxiliary Operator #1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Task Analysis Line # Generic Title/Role On-Shift Position Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 18

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 1 DBT Security Threat 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 This accident does not include the need for firefighting, first aid or search & rescue.

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

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

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

1 (describe)

N/A 8 Chemistry Function task

2 (describe)

N/A No chemistry or RP job function tasks for the conditions described in the DBT assumptions. RP and Chemistry take cover as directed.

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 1 DBT Security Threat Function / Task On-Shift Task Analysis Controlling Method Line#

Position Declare the emergency classification level Emergency Planning Training 1 Shift Manager (ECL) Program / EP Drills Approve Offsite Protective Action 2 N/A N/A Recommendations Emergency Planning Training 3 Approve content of State/local notifications Shift Manager Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Program Notification and direction to on-shift staff 5 Shift Manager / Emergency Planning Training (e.g., to assemble, evacuate, etc.)

Program Emergency Planning Training 6 ERO notification Shift Manager Program 7 Abbreviated NRC notification for DBT event STA Licensed Operator Training Program Emergency Planning Training 8 Complete State/local notification form Shift Manager Program Emergency Planning Training 9 Perform State/local notifications Communicator Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Emergency Planning Training 13 Perform NRC notifications Communicator Program Perform other site-specific event notifications 14 N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program / EP Drills PALISADES Page 21

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

1. Accident Summary This event assumes the reactivity insertion from the control rod ejection results in an overpower trip. The thermal-hydraulic analysis for this event is performed for only a few seconds. The remaining consequences of this event are covered by the small break LOCA analysis as noted in Chapter 14.17.2 of the FSAR.

2. Accident Specific Assumptions Made Reactivity insertion - overpower trip.

The thermal-hydraulic analysis for this event is performed for only a few seconds. The remaining consequences of this event are covered by the small break LOCA analysis in Chapter 14.17.2 The analysis assumes 14.7% of the fuel fails due to DNB considerations.

100% of the activity released from the damaged fuel is instantaneously released to the containment atmosphere, from which leakage to the environment occurs.

Radioactivity is transported to the secondary system through a 0.3 gpm primary to secondary leak in each steam generator.

EAB worst 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months dose containment release is within acceptable limits.

3. Procedures for Accident Response EOP-4.0 Rev. 22, Loss of Coolant Accident Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct PALISADES Page 22

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 2 Control Rod Ejection Accident Augmentation Role in Line On-shift Unanalyzed TMS Basis Document Elapsed Time Table # /

Position Task? Required?

(min)* Line #

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 T5/L9 Emergency Plan 12 Communicator 30 T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan T4/L4 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A N/A No No Plan Figure 5-2 PALISADES Page 23

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 2 Control Rod Ejection Accident Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 24

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 2 Control Rod Ejection Accident Line Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

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

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

N/A 4 Job Coverage: RP goes to CR for job support X X X X X X X X X X X X X X X X X 5 Offsite Rad Assessment:

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

1 (describe) - N/A 8 Chemistry Function task

2 (describe) - N/A RP will perform the above task as directed by the Shift Manager. Task are not time critical. The time

to perform the tasks and the time to complete the tasks are estimated.

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

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

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

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program Licensed Operator 7 Abbreviated NRC notification for DBT event N/A`

Training Program Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chem Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

Security Training Program 15 Personnel Accountability Security

/ EP Drills PALISADES Page 27

PALISADES ON-SHIFT STAFFING ANALYIS REPORT C. Design Basis Accident Analysis #3 - Small Line Break Outside Containment as described in FSAR 14.23

1. Accident Summary This analysis assumes a charging line break resulting in a 160 gpm primary coolant leak outside containment.

2. Accident Specific Assumptions Made PCS activity of 1µCi/gm DEI released to the Auxiliary Building atmosphere.

No reactor depressurization or trip was assumed to occur. An iodine spike was not assumed.

Leak isolation time assumed to be 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

3. Procedures for Accident Response AOP-23 Rev. 0, Primary Coolant Leak EOP-4 Rev. 22, LOCA Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct PALISADES Page 28

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 3 Small Line Break Outside Containment Augmentation Role in Line On-shift Unanalyzed TMS Basis Document Elapsed Time Table # /

Position Task? Required?

(min)* Line #

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan T4/L4 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 PALISADES Page 29

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 3 Small Line Break Outside Containment Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 30

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 3 Small Line Break Outside Containment 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 This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 31

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 3 Small Line Break Outside Containment L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

N/A 4 Job Coverage: RP goes to CR for job support X X X X X X X X X X X X X X X X X 5 Offsite Rad Assessment:

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

1 (describe) - N/A 8 Chemistry Function task

2 (describe) - N/A RP will perform the above task as directed by the Shift Manager. Task are not time critical. The time

to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 32

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 3 Small Line Break Outside Containment Line Function / Task On-Shift Position Task Analysis

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

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

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program Licensed Operator 7 Abbreviated NRC notification for DBT event N/A Training Program Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chem Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

Security Training Program 15 Personnel Accountability Security

/ EP Drills PALISADES Page 33

PALISADES ON-SHIFT STAFFING ANALYIS REPORT D. Design Basis Accident Analysis #4 - Main Steam Line Break Inside Containment.

1. Accident Summary This event assumes a double-ended guillotine break of a Main Steam Line inside containment with a loss of offsite power. Release information was not available in the FSAR to determine if a radiation based EAL condition would be met in the first 60 minutes of the event. Emergency declaration was based on the loss of offsite power.

2. Accident Specific Assumptions Made MSL break assumes 0.3 gpm primary to secondary leak for the affected SG that flashes to steam and is released through the break area.

FSAR analysis assumes radionuclide releases from the primary coolant associated with 0.5% fuel failures.

The EAB worst 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months dose was noted in the FSAR as being within acceptable criteria but specific release information was not available to determine if a radiation based EAL condition was met in the first 60 minutes of the event. The event declaration was therefore made based on the loss of off-site power.

3. Procedures for Accident Response EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications AOP-2 Rev. 0, Excessive Load ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct EOP-6.0 Rev.19, Excess Steam Demand Event PALISADES Page 34

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 4 Main Steam Line Break Augmentation Role in Table #

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

Position Task? Required?

(min)

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan T4/L4 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 PALISADES Page 35

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 4 Main Steam Line Break Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A PALISADES Page 36

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 4 Main Steam Line Break 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 This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 37

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 4 Main Steam Line Break L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function / Task N 65- 70- 75- 80-E 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 85-90 70 75 80 85 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: RP is available to support job X X X X X X X X X X X X X X X X X coverage or surveys as required 5 Offsite Rad Assessment:

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

1 (describe)

N/A 8 Chemistry Function task

2 (describe)

N/A Although no specific radiological tasks were identified, the RP is available to provide support as directed by the Shift Manager. Tasks are not time critical.

The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 38

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 4 Main Steam Line Break Function / Task On-Shift Position Task Analysis Line #

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

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

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chemistry Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event N/A 14 notifications (e.g., Duty Plant Manager, N/A INPO, ANI, etc.)

Security Training Program 15 Personnel Accountability Security Officer

/ EP Drills PALISADES Page 39

PALISADES ON-SHIFT STAFFING ANALYIS REPORT E. Design Basis Accident Analysis #5 - Loss of Coolant Accident.

1. Accident Summary This event is defined by a large rupture of the PCS cold leg piping between the PCP and the reactor vessel for the PCS loop containing the pressurizer. This event also includes a loss of offsite power and failure of 1 diesel generator.

2. Accident Specific Assumptions Made Large rupture of the PCS cold leg piping between the PCP and the reactor vessel for the PCS loop containing the pressurizer.

Rapid depressurization of the PCS, reactor trip signal but credit is taken for shut down by coolant voiding in the core. Experience DNB.

SIAS signal initiated Loss of offsite power and failure of 1 D/G Assumes loss of one ECCS train, one HPSI, one LPSI, all containment spray pumps and all containment fan coolers are operational.

3. Procedures for Accident Response EOP-4.0 Rev. 22, Loss of Coolant Accident Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct AOP-23, Rev. 0, Primary Coolant Leak PALISADES Page 40

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 5 Loss of Coolant Accident Augmentation Role in Table Line On-shift Unanalyzed TMS E-Plan Reference Elapsed Time # / Line #

Position Task? Required?

(min)

T2/L1 T5/L1 T5/L2 Emergency Plan T5/L3 1 Shift Manager 60 No Yes Figure 5-2 T5/L5 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan T4/L4 14 RP 30 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 PALISADES Page 41

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 5 Loss of Coolant Accident Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A PALISADES Page 42

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 5 Loss of Coolant Accident Line Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 43

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 5 Loss of Coolant Accident L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function / Task N 65- 70- 75- 80-E 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 85-90 70 75 80 85 1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: RP reports to the CR to provide RP support (including in plant X X X X X X X X X X X X X X X X X and out of plant surveys) as directed by the SM.

5 Offsite Rad Assessment:

_(Included in Table 5 6 Other site specific RP (describe): N/A 7 Chemistry Function task

1 (describe) N/A 8 Chemistry Function task

2 (describe) N/A RP will perform the above task as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 44

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

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

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

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

Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chemistry Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications N/A 14 N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program PALISADES Page 45

PALISADES ON-SHIFT STAFFING ANALYIS REPORT F. Design Basis Accident Analysis #6 - Fuel Handling Accident

1. Accident Summary The fuel handling accident is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism, resulting in the dropping of a raised fuel assembly onto stored fuel bundles. The FHA is assumed to occur in containment two days after shutdown. An Alert emergency declaration was assumed to be declared due to the event.

2. Accident Specific Assumptions Made An Alert is declared on the fuel handling event. Radiological release rates are not available to classify on the release.

Additional station personnel, including Operations and Health Physics Technicians, would normally be on-site during fuel movement activities. Additional station personnel were not required, however, to support initial response actions.

3. Procedures for Accident Response AOP-34 Rev. 0, Fuel Handling Accident EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct PALISADES Page 46

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #6 - Fuel Handling Accident Augmentation Role in Table #

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

Task? Required?

(min)

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan T4/L4 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 PALISADES Page 47

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 6 - Fuel Handling Accident Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 48

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 6 - Fuel Handling Accident Line Performed by Task Analysis Controlling Method 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 49

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #6 - Fuel Handling Accident L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

RP#2 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: RP reports to the CR to provide RP support (including in plant X X X X X X X X X X X X X X X X X and out of plant surveys) as directed by the SM.

5 Offsite Rad Assessment:

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

1 (describe) N/A 8 Chemistry Function task

2 (describe) N/A RP will perform the above task as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 50

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #6 - Fuel Handling Accident Line Function / Task On-Shift Position Task Analysis Controlling

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

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

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

Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chemistry Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications N/A 14 N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program PALISADES Page 51

PALISADES ON-SHIFT STAFFING ANALYIS REPORT G. Design Basis Accident Analysis #7 - Waste Tank Rupture

1. Accident Summary This event assumes the rupture of a waste gas decay tank. EAL AA1.1 conditions are assumed to be met based on expected stack high range monitor readings.

2. Accident Specific Assumptions Made A rupture in the Waste Gas System or a rupture of the volume control tank would result in offsite doses well below the 10 CFR 100 limits, and would not present any undue risk to the health and safety of the public.

The release for this accident is similar to the small break LOCA outside containment.

Details are not provided to determine an EAL, therefore an assumption is made that EAL AA1.1 conditions are met based on the stack high range monitor.

3. Procedures for Accident Response HP-2.8 Rev. 25, Response to Unusual Radiological Occurrences[m2]

EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct PALISADES Page 52

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #7 - Waste Tank Rupture Augmentation Role in Table #

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

Task? Required?

(min)

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan T4/L4 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 PALISADES Page 53

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room ANALYSIS # 7 - Waste Tank Rupture Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 54

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 7 - Waste Tank Rupture 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 This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 55

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #7 -Waste Tank Rupture L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

RP#2 2 On-site Survey: N/A 3 Personnel Monitoring: N/A 4 Job Coverage: RP reports to the CR to provide RP support (including in plant X X X X X X X X X X X X X X X X X and out of plant surveys) as directed by the SM.

5 Offsite Rad Assessment:

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

1 (describe) N/A 8 Chemistry Function task

2 (describe) N/A RP will perform the above task as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

PALISADES Page 56

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #7 - Waste Tank Rupture Line Function / Task On-Shift Position Task Analysis Controlling

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

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

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

Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chemistry Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications N/A 14 N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program PALISADES Page 57

PALISADES ON-SHIFT STAFFING ANALYIS REPORT H. Accident Analysis #8 - Aircraft Probable Threat

1. Accident Summary The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 minutes, but less than 30 minutes from the site, and considers the dispersal of the site fire brigade away from target areas for firefighting.

The analysis does not include a scenario or response actions taken during or after a crash.

2. Accident Specific Assumptions Made The Shift Manager receives the call from the NRC of probable aircraft threat.

All non-security on-shift personnel are inside the protected area fence at their normal workstation.

Fire brigade personnel are included in Table 3, Firefighting to signify they are performing actions (relocation outside of the target area) specific to their assignment to the fire brigade and are not available to perform other tasks. While the inclusion of the fire brigade in Table 3 varies from the guidance of NEI 10-05, Section 3.2.2 (4)(a), the addition more clearly identifies on-shift staff actions.

3. Procedures for Accident Response AOP-44 Rev. 0, Response to Security Threats EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct PALISADES Page 58

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #8 - Aircraft Probable Threat Augmentation Role in Table Unanalyzed TMS Line On-shift Position Basis Document Elapsed Time 5 / Line # Task? Required?

(min)

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A T3/L1 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A T3/L2 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A T3/L3 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A T3/L4 No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A T3/L5 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T4/L7 No No Figure 5-2 Emergency Plan T4/L6 14 RP#1 30 No No Figure 5-2 Security Contingency Plan 15 Security N/A T5/L15 No No

/ Emergency Plan Figure 5-2 PALISADES Page 59

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #8 - Aircraft Probable Threat Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 60

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #8 - Aircraft Probable Threat Line Performed by Task Analysis Controlling Method 1 Nuclear Plant Operator #2 Fire Brigade Training 2 Nuclear Plant Operator #3 Fire Brigade Training 3 Nuclear Plant Operator #4 Fire Brigade Training 4 Nuclear Plant Operator #5 Fire Brigade Training 5 Nuclear Plant Operator #6 Fire Brigade Training This accident does not include the need for firefighting, first aid or search & rescue. The fire brigade is required, however, to relocate to the Training Center and is therefore not available to perform other tasks.

PALISADES Page 61

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #8 - Aircraft Probable Threat L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

(Included in Table 5 - N/A 6 Other site specific RP :

Relocate to survey vehicle X X X X X X X X X X outside PA 7 Chemistry Function task

1: Support NRC open-X X X X X X X X X X line communications if needed 8 Chemistry Function task

2 (describe) - N/A

Times are estimated No specific RP or Chemistry tasks are performed for this event. At the on-set of this event, RP relocates to the survey vehicle outside the protected area and the Chemistry Technician is available to support NRC communications from the Control Room.

PALISADES Page 62

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #8 - Aircraft Probable Threat Line Function / Task* On-Shift Position Task Analysis Controlling

Method Declare the emergency classification level Emergency Planning 1 Shift Manager (ECL) Training Program / EP Drills Approve Offsite Protective Action N/A 2 N/A Recommendations Emergency Planning 3 Approve content of State/local notifications Shift Manager Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Notification and direction to on-shift staff (e.g.,

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

Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications N/A 14 N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program PALISADES Page 63

PALISADES ON-SHIFT STAFFING ANALYIS REPORT I. Accident Analysis #9 - Control Room Fire Requiring Evacuation and Remote Shutdown

1. Accident Summary This event involves a large transient fire requiring evacuation of the Control Room. The event has the potential to include shorts and/or spurious signals producing potential LOCA pathways and/or incorrect system lineup for shutdown.

2. Accident Specific Assumptions Made The Nuclear Control Operator will initiate a manual reactor trip prior to evacuating the control room.

The Shift Manager will make the plant announcement prior to evacuating the control room.

3. Procedures for Accident Response AOP-40 Rev. 0, Fire Which Threatens Safety Related Equipment AOP-41 Rev. 0, Alternate Safe Shutdown Procedure EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4.0 Rev. 52, Operations Organization, Responsibilities and Conduct PALISADES Page 64

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #9 - CR Evacuation & Remote SD Augmentation Role in Table Unanalyzed TMS Line On-shift Position Basis Document Elapsed Time 5 / Line # Task? Required?

(min)

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A T3/L1 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A T3/L2 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A T3/L3 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A T3/L4 No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A T3/L5 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 N/A No No Figure 5-2 Emergency Plan T4/L4 14 RP#1 30 No No Figure 5-2 Security Contingency Plan 15 Security N/A N/A No No

/ Emergency Plan Figure 5-2 PALISADES Page 65

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #9 - CR Evacuation & Remote SD Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 66

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #9 - CR Evacuation & Remote SD Line Performed by Task Analysis Controlling Method 1 Nuclear Plant Operator #2 Fire Brigade Training Nuclear Plant Operator #3 2 Fire Brigade Training Nuclear Plant Operator #4 3 Fire Brigade Training Nuclear Plant Operator #5 4 Fire Brigade Training Nuclear Plant Operator #6 5 Fire Brigade Training PALISADES Page 67

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #9 - CR Evacuation & Remote SD L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

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

1 (describe) - N/A 8 Chemistry Function task

2 (describe) - N/A

Times are estimated PALISADES Page 68

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #9 - CR Evacuation & Remote SD Line Function / Task* On-Shift Position Task Analysis

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

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

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications N/A 14 N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability N/A N/A PALISADES Page 69

PALISADES ON-SHIFT STAFFING ANALYIS REPORT J. Accident Analysis #10 - Station Blackout

1. Accident Summary A loss of all offsite AC power occurs and the failure of the emergency diesel generators to start. The SM determines power cannot be restored and declares a SAE on EAL SS1.1.

2. Accident Specific Assumptions Made At time T-0 a loss of all AC power occurs No release occurs

3. Procedures for Accident Response EOP-3 Rev. 15, Station Blackout Recovery AOP-26 Rev. o, Loss of Spent Fuel Pool cooling SOP-34 Rev. 29, Palisades Plant Computer (PPC) System EMG Emergency Management guideline PALISADES Page 70

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #10 - Station Blackout Augmentation Role in Table Unanalyzed TMS Line Basis On-shift Position Elapsed Time 5 / Line # Task? Required?

Document (min)

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 N/A No No Figure 5-2 Emergency Plan N/A 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / N/A T5/L15 No No Emergency Plan Figure 5-2 PALISADES Page 71

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #10 - Station Blackout Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 72

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #10 - Station Blackout 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 This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 73

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #10 - Station Blackout L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

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

1 (describe) - N/A 8 Chemistry Function task

2 (describe) - N/A

Times are estimated Chemistry does not have an assigned chemistry task for SBO. Chemistry is available for dose assessment if a release occurs.

PALISADES Page 74

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #10 - Station Blackout Line Function / Task* On-Shift Position Task Analysis

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

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

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment N/A N/A Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event notifications N/A 14 N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program K. Accident Analysis #11 - LOCA/General Emergency with Release and PAR

1. Accident Summary (Assumed for Staffing Analysis Purpose)

The unit immediately enters a condition requiring the declaration of a General Emergency with indication of a radiological release that results in a dose that exceeds the Environmental Protection Agencys Protective Action Guides beyond the site boundary, necessitating Protective Actions Recommendations..

2. Accident Specific Assumptions Made No transients other than LOCA are considered.

3. Procedures for Accident Response EOP-4.0 Rev. 22, Loss of Coolant Accident Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications PALISADES Page 75

PALISADES ON-SHIFT STAFFING ANALYIS REPORT EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct EI-6.13, Rev. 23, Protective Action Recommendations for Offsite Populations PALISADES Page 76

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #11 - LOCA/GE with PAR Augmentation Role in Table Unanalyzed TMS Required?

Line Basis On-shift Position Elapsed Time 5 / Line # Task?

Document (min)

T2/L1 T5/L1 T5/L2 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L4 No Yes Figure 5-2 T5/L5 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan N/A 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / N/A T5/L15 No No Emergency Plan Figure 5-2 PALISADES Page 77

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #11 - LOCA/GE with PAR Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 78

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #11 - LOCA/GE with PAR 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 This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 79

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #11 - LOCA/GE with PAR L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

4 Job Coverage: RP reports to the CR to provide RP support (including in plant X X X X X X X X X X X X X X X X X and out of plant surveys) as directed by the SM.

5 Offsite Rad Assessment:

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

1 (describe) N/A 8 Chemistry Function task

2 (describe) N/A RP will perform the above task as directed by the Shift Manager. Tasks are not time critical. The time* to perform the tasks and the time to complete the tasks are estimated.

Chemistry does not have an assigned chemistry task for LOCA. Chemistry is available for dose assessment.

PALISADES Page 80

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #11 - LOCA/GE with PAR Line Function / Task* On-Shift Position Task Analysis

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

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

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program Licensed Operator 7 Abbreviated NRC notification for DBT event N/A Training Program Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chemistry Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event N/A 14 notifications (e.g., Duty Plant Manager, N/A INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program PALISADES Page 81

PALISADES ON-SHIFT STAFFING ANALYIS REPORT L. Accident Analysis #15 - Steam Generator Tube Rupture with Concurrent Loss of Off-site Power

1. Accident Summary This event analyzes the response of a failure of a steam generator U-tube combined with a loss of offsite power.

2. Accident Specific Assumptions Made Radiation monitor alarms on the MSLs, condenser air ejector discharge, SG blowdown line, fan room and plant stack before the reactor trip/turbine trip.

Following a reactor trip and turbine trip, the radioactive fluid is released through the steam generator safety or atmospheric dump valves as a result of the loss of normal AC power.

Doses are calculated for an event generated iodine spike, initial activity of 1 µCI/gm and a spiking factor of 335 (GIS) and a pre-accident iodine spike 40 µCI/gm (PIS).

Primary to secondary leakage rate of 432 gallons per day is assumed in the unaffected steam generator for the duration of the transient.

3. Procedures for Accident Response EOP-5.0 Rev. 17, Steam Generator Tube Rupture Recovery EOP-1.0 Rev. 15, Standard Post Trip Actions EI-1 Rev. 56, Emergency Classification and Actions EI-3 Rev. 31, Communications and Notifications EI-2.2 Rev. 15, Emergency Staff Augmentation EI-12.1 Rev. 18, Personnel Accountability and Assembly ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct AOP-24 Rev. 0, SGT leak PALISADES Page 82

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #15 - Steam Generator Tube Rupture Augmentation Role in Table Unanalyzed TMS Required?

Line Basis On-shift Position Elapsed Time 5 / Line # Task?

Document (min)

T2/L1 T5/L1 T5/L3 Emergency Plan 1 Shift Manager 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 Control Room Emergency Plan 2 N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3 60 No No Advisor Figure 5-2 Nuclear Control Emergency Plan 4 N/A T2/L4 No No Operator #1 Figure 5-2 Nuclear Control Emergency Plan 5 N/A T2/L5 No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan 6 N/A T2/L6 No No Operator #1 Figure 5-2 Nuclear Plant Emergency Plan 7 N/A N/A No No Operator #2 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 8 No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 9 No No Operator #4 Figure 5-2 Nuclear Plant Emergency Plan 10 N/A N/A No No Operator #5 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A 11 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan 12 Communicator T5/L13 No No Figure 5-2 Emergency Plan 13 Chem Tech 60 T5/L12 No Yes Figure 5-2 Emergency Plan T4/L4 14 RP#1 30 No No Figure 5-2 Security Contingency 15 Security Plan / N/A T5/L15 No No Emergency Plan Figure 5-2 PALISADES Page 83

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #15 - Steam Generator Tube Rupture Minimum Operations Crew Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor Training Program STA Licensed Operator 3 Shift Technical Advisor Training Program Nuclear Control Operator Licensed Operator 4 Reactor Operator #1

1 Training Program Nuclear Control Operator Licensed Operator 5 Reactor Operator #2

2 Training Program Nuclear Plant Operator Non-Licensed Operator 6 Auxiliary Operator #1

1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis Controlling Method 7 Mechanic N/A N/A 8 Electrician N/A N/A 9 I&C Technician N/A N/A 10 Other N/A N/A 11 Other N/A N/A PALISADES Page 84

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #15 - Steam Generator Tube Rupture 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 This accident does not include the need for firefighting, first aid or search & rescue.

PALISADES Page 85

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis #15 - Steam Generator Tube Rupture L Position Performing Performance Time Period After Emergency Declaration (minutes)*

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

4 Job Coverage: RP performs surveys and job X X X X X X X X X X X X X X X X X coverage as needed and directed by the SM.

5 Offsite Rad Assessment:

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

1 (describe) N/A 8 Chemistry Function task

2 (describe) N/A

Times are estimated Chemistry does not have an assigned chemistry task and is available for dose assessment.

PALISADES Page 86

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis #15 - Steam Generator Tube Rupture Line Function / Task* On-Shift Position Task Analysis

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

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

5 Shift Manager (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program Licensed Operator 7 Abbreviated NRC notification for DBT event N/A Training Program Emergency Planning 8 Complete State/local notification form Shift Manager Training Program Emergency Planning 9 Perform State/local notifications Communicator Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning 12 Offsite radiological assessment Chemistry Technician Training Program Emergency Planning 13 Perform NRC notifications Communicator Training Program Perform other site-specific event N/A 14 notifications (e.g., Duty Plant Manager, N/A INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program PALISADES Page 87

PALISADES ON-SHIFT STAFFING ANALYIS REPORT VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS A. Dose Assessment

1. See Section II.C.1 for the exception taken for the Chemistry Technician to perform dose assessment. No time motion study or corrective actions is required.

B. ERO notification (Everbridge activation)

PALISADES TIME MOTION STUDY OF OVERLAPPING TASKS TASK 1: ACTIVATE THE ERO USING EVERBRIDGE JOB: SHIFT MANAGER TASK 2: EMERGENCY DIRECTION AND CONTROL JOB: SHIFT MANAGER PALISADES Page 88

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PURPOSE:

Perform a Time Motion Study to evaluate whether assigning the performance of ERO notification using Everbridge to the Shift Manager or STA can be justified as an acceptable overlap to the Shift Managers primary emergency plan function of direction and control.

NOTE The Time Motion Study may be completed during simulator training/evaluation or during EP drills LOCATION:

Simulator (to use the TRAINING event code to avoid inadvertent ERO activation for an EMERGENCY event.)

Codes are site specific.

REQUIRED TOOLS/EQUIPMENT:

A. Individual performing the procedure actions must be logged on to the computer being used.

B. PC with Internet 7.0 and internet access.

C. Instructions/codes for activating Everbridge in the TRAINING mode. [Staged Instruction sheet for activating Everbridge may be used in lieu of EN-EP-310, Emergency Response Organization Notification System)]

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Function / Responsibility (Task) Analysis Template Event: ALL Site: Palisades Position: Shift Manager Line #: 1 Function Responsibility (Task) Action Step Duration 1.Notification 1.1 Initiate notification to Retrieve the Everbridge instruction that contains the [TRAINING] Access code 10 seconds the ERO via the ERON and Pass code.

Program (On the PC) Open ERO Notification System by clicking: 20 seconds Start Nuclear Corporate Apps (ESM) Nuclear Emergency Response (ESM) ERON Enter Access code (XXXXX) and Pass code (XXXXX) and click the SUBMIT 15 seconds button Select the appropriate classification by clicking on it. 15 seconds (Select ALERT or scenario ECL)

Answer Yes or No to Security EAL question, Was the event declared on a 5 seconds Security EAL? [ Click on NO]

Select proper response action by clicking on it. 10 seconds

[Select Activate All ERFs}

Review the message that was generated in the User Message box at the bottom 20 seconds of the screen. Ensure the message contains the information to communicate to the ERO. Additional information can be added to the message by clicking in the User Message box and typing.

Once satisfied with the message content, click send notification button. [Click 10 seconds Send Notification]

Answer YES to send verification question, Are you CERTAIN you want to send 5 seconds this message? [Click YES]

If message was successfully sent, you will see a dialog box. [Click Return] 10 seconds END OF INITIATE NOTIFICATION TO ERO TASK 2 minutes (total time) 2.Emergency 2.1 Maintain emergency Oversight of the emergency response. Maintained Throughout Direction and direction and control of the Control event response.

Initiate any emergency actions. Initiated as required END OF EMERGENCY DIRECTION AND CONTROL TASK Task Performer: Bruce Bauer Position: Shift Manager Date: 11/05/2012 Name Job Title Evaluator: Dan Malone Position: EP Manager Date: 11/05/2012 Name Job Title PALISADES Page 90

PALISADES ON-SHIFT STAFFING ANALYIS REPORT IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures None X. CORRECTIVE ACTIONS A. Corrective Actions and Compensatory Measures None PALISADES Page 91

PALISADES ON-SHIFT STAFFING ANALYIS REPORT XI. REFERENCES NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.

Palisades Emergency Plan, Rev 25 XII. STAFFING ANALYIS TEAM The staffing analysis team consisted of plant and Entergy Corporate staff representing the following departments / organizations:

Fleet Emergency Preparedness Project Management Operations Training Security Chemistry Radiation Protection Regulatory Assurance Emergency Planning Engineering o Fire Protection o Appendix R PALISADES Page 92

ATTACHMENT 4 ON-SHIFT STAFFING ANALYSIS REPORT, REVISION 1 (marked up version)

(additions are underlined, deletions are stricken out)

(additions and deletions are not shown for Table of Contents) 93 Pages Follow

PALISADES ONSHIFT PALISADES ON-SHIFT STAFFING STAFFING ANALYIS ANALYIS REPORT PALISADES NUCLEAR STATION ON-SHIFT STAFFING ANALYSIS ONSHIFT Rev I1 February 10, 2014 Prepare d by: Pn 4 ~

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PALISADES ON-SHIFT STAFFING ANALYIS REPORT TABLE OF CONTENTS I. INTRODUCTION ............................................................................................................................ 4 II. ANALYSIS

SUMMARY

.................................................................................................................. 4 A. Emergency Plan Minimum Staffing .................................................................................. 6 B. Other Commitments to Shift Staffing ................................................................................ 7 C. Staffing Exceptions and Time Motion Studies (TMS) ..................................................... 7 D. Emergency Plan Tasks Not Analyzed .............................................................................. 8 III. ANALYSIS PROCESS ................................................................................................................... 9 IV. ACCIDENT SCENARIOS ............................................................................................................ 10 A. Accident Selection ........................................................................................................... 10 B. Accident Scenarios included in the Analysis ................................................................. 10 C. Accident Scenarios not included in the Analysis ........................................................... 11 V. GENERAL ASSUMPTIONS AND LIMITATIONS ...................................................................... 12 A. Notes and Assumptions applicable to all accidents in Palisades Staffing Analysis: .. 12 B. NEI 10-05 Rev 0 Assumptions........................................................................................ 13 VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS ........................................................ 15 VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS .................................................................. 17 A. Accident Analysis #1 - Design Basis Threat (DBT)...................................................... 17 B. Design Basis Accident Analysis #2 - Control Rod Ejection ......................................... 23 C. Design Basis Accident Analysis #3 - Small Line Break Outside Containment as described in FSAR 14.23 ................................................................................................ 29 D. Design Basis Accident Analysis #4 - Main Steam Line Break Inside Containment. . 35 E. Design Basis Accident Analysis #5 - Loss of Coolant Accident.................................. 41 F. Design Basis Accident Analysis #6 - Fuel Handling Accident ..................................... 47 G. Design Basis Accident Analysis #7 - Waste Tank Rupture ......................................... 53 H. Accident Analysis #8 - Aircraft Probable Threat ........................................................... 59 I. Accident Analysis #9 - Control Room Fire Requiring Evacuation and Remote Shutdown .......................................................................................................................... 65 J. Accident Analysis #10 - Station Blackout...................................................................... 71 K. Accident Analysis #11 - LOCA/General Emergency with Release and PAR............. 77 PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT L. Accident Analysis #15 - Steam Generator Tube Rupture with Concurrent Loss of Off-site Power................................................................................................................... 83 VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ...... 89 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ......................... 92 A. Overlap Requiring Compensatory Measures ................................................................ 92 X. CORRECTIVE ACTIONS ............................................................................................................ 92 A. Corrective Actions and Compensatory Measures......................................................... 92 XI. REFERENCES ............................................................................................................................. 93 XII. STAFFING ANALYIS TEAM........................................................................................................ 93 PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT I. INTRODUCTION This document is a revision to the Palisades Nuclear Station the final report for the On-shift Staffing Analysis (OSA) report dated December 18, 2012.that commenced at Palisades Nuclear Station during the week of June 11, 2012. This revision provides additional clarification to actions performed by on-shift staff, incorporates technological advancements implemented to reduce on-shift staff burden, and provides additional discussion of the basis for some evaluated events.

This revision continues to OSA satisfyies the requirements of 10 CFR 50 Appendix E Section IV.A.9, which states that nuclear power licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities. This analysis examined the capability of the minimum staff listed in Figure 5-2 of the Palisades Emergency Plan (E-Plan) to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-Plan.

II. ANALYSIS

SUMMARY

The OSA team determined that an on-shift staff of fourteen (14) is able to cope with the spectrum of analyzed events, as described in Section IV of this report, until augmenting Emergency Response Organization (ERO) staff arrives.required to respond to the most limiting accident scenario reviewed, main control room fire and shutdown at the remote shutdown panel. The on-shift staff consists of individuals necessary to support each of the emergency plan functional areas or tasks:

Emergency Direction and Control Plant Operations and Safe Shutdown (SSD)

Fire Fighting (FB)

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

The minimum on-shift staffing identified by this analysis is reflected in Table 1, On-Shift Positions, for each analyzed event. This is intended to identify the analyzed tasks performed by each on-shift ERO staff member PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT based on the findings of the OSA. Any overlap of tasks or other conflicts identified during this OSA are captured in Section IX of this report and are based on the actual staffing at the time the analysis was considered complete.

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

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

On-Shift Licensing Basis Staffing Position E-Plan Functional Area Requirement Analysis Results 50.54m Emergency Direction and 1 Shift Manager (SM) E-Plan Figure 5-2 Control 50.54m Control Room Supervisor (CRS) E-Plan Figure 5-2 SSD 1 E-Plan Figure 5-2 Shift Technical Advisor (STA) Technical Support 1 50.54m SSD Control Room Operator (RO #1) E-Plan Figure 5-2 1 50.54m SSD Control Room Operator (RO #2) E-Plan Figure 5-2 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #1) SSD 1 E-Plan Figure 5-2 FB Nuclear Plant Operator (NPO #2) 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #3) FB 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #4) FB 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #5) FB 1 E-Plan Figure 5-2 Nuclear Plant Operator (NPO #6) FB 1 E-Plan Figure 5-2 Communicator Communications Notifications 1 E-Plan Figure 5-2 Accident Chemistry Technician 1 Assessment/Chemistry E-Plan Figure 5-2 Radiation Protection (RP) #1 Radiation Protection 1 Security Contingency Per Security Access Control and Security Plan/E-Plan Figure Contingency Accountability 5-2 Plan TOTAL 14 PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT B. Other Commitments to Shift Staffing No additional stations commitments were identified conflicting with this staffing analysis.

C. Staffing Exceptions and Time Motion Studies (TMS)

1. The primary responsibility for the on-shift Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. As noted in the Site Emergency Plan, the on-shift Chemistry Technician may also be required to support the on-shift Radiation Protection Technician implement specific tasks to support the Major Functional Area of Protective Actions (In-plant). These specific tasks consist of access control, RP Coverage, Ppersonnel monitoring, and dosimetry. While the capability to perform these tasks are specified in the Emergency Plan, this analysis did not identify the need to utilize the on-shift Chemistry Technician to perform any of these Radiation Protection related tasks. It is recognized, however, that the Shift Manager will prioritize and utilize the on-shift staff as needed. It is therefore acceptable to assign the Chemistry Technician the E-Plan function of dose assessment. No further analysis or TMS is required.

2. The Shift Manager is assigned the responsibility to make some site specific event notifications such as to the Duty Plant Manager, Operations Manager, and Resident Inspector. These notifications by phone are considered communications that are approximately one minute in length and are acceptable tasks for the Shift Manager.deemed acceptable in accordance with NEI 10-05 Section 3.2.2 (6)(a)(14) due to the short duration of the notifications. Additionally, these notifications are collectively evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills and are not deemed as impacting the Shift Managers ability to maintain oversight of the event or perform other required emergency plan tasks. In accordance with the guidance of NEI 10-05, Line 14 of NEI Table 5 contained in Section VII of this report does not reflect the performance of these short duration notifications. No further analysis or TMS is required.

3. Station staff are required to maintain continuous communications with the notification source during an aircraft threat in accordance with 10CFR50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The analysis of this event identified that the on-shift chemistry technician has no other assigned tasks in response to this event and would be available if needed to there are sufficient personnel on-shift to perform this task during the event. Specifically, a Nuclear Plant Operator, the radiation protection technician and/or chemistry technician can be made available to fill this function. No further analysis or TMS is required.

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4. The Shift Manager is assigned the task of notifying the off-shift ERO of the emergency. A Time Motion Study (TMS) was conducted to ensure the Shift Manager could perform the concurrent tasks of maintaining emergency direction and control while notifying the ERO of the event using Everbridge. The TMS demonstrated the Shift Manager was able to maintain Emergency Direction and Control during the approximate two minutes it took to notify the ERO using Everbridge.

Additionally, the task of ERO notification is routinely evaluated in conjunction with other Shift Manager duties and responsibilities during Operations simulator training evaluations and Emergency Plan drills.

5. The Palisades Emergency Response Data System (ERDS) link to the NRC is operated continuously and does not require activation following a declared emergency. The task of ERDS activation is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

6. NRC event notifications required due to the declaration of an Emergency Classification in accordance with 10 CFR 50.72 is made verbally using the Emergency Notification System. A written event notification form is not generated by on-shift staff for this notification. Formal written notifications to the NRC as may be required by 10 CFR 50.72 resulting from any of the analyzed events may be generated by the augmented staff. The task of completing the NRC event notification form is therefore not included as an on-shift task requiring evaluation as part of this staffing analysis.

D. Emergency Plan Tasks Not Analyzed

1. Repair and Corrective Action - Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by shift personnel assigned other functions. Repair and corrective action is defined as:

An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g.,

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

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

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

Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

At Palisades, Nuclear Plant Operators are trained to perform the actions associated with this functional area. Actions (e.g., reset breakers, valve manipulation) directed by the Control Room Supervisor to mitigate the event per procedures were performed by the Nuclear Plant Operators in this analysis. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed PALISADES Page

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

2. Rescue Operations and First Aid: In accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response although neither task was required during the evaluated scenarios. Per the guidance of NUREG-0654, Table B-1, rescue operations and first aid may be performed by shift personnel assigned other functions. The on-shift Radiation Protection staff member is trained and available to perform first aid and the station Fire Brigade staff are trained and available to perform search and rescue if needed. Rescue operations and first aid response are acceptable collateral duties per the guidance of NEI 10-05.

III. ANALYSIS PROCESS The initial staffing analysis (Revision 0) was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments. Additionally, members of the Security staff provided input to the analysis.

The team members performing reviews to Revision 1 of the staffing analysis are identified in Section XII of this report. Revision 1 of this report was based on input, reviews and concurrence from station personnel from the same departments as those participating in the original analysis.

This analysis was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments. Additionally, personnel from Engineering and Security provided input to the analysis. The team members are identified in Section XII of this report.

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

Each scenario was reviewed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for Emergency Plan implementation as described in the Emergency Plan Figure 5-2, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, the team evaluated timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements.

The results of the analysis for each of the scenarios are included in Section VIII, APPENDIX B - ON-SHIFT STAFFING ANALYSIS. Note that NSIR DPR-ISG-01 states that only DBA accidents which would result in an emergency declaration should be evaluated in the staffing assessment. Each of Palisades DBAs were evaluated and classified according to its FSAR Chapter 14 description. If the accident description alone did not result in a classification, the projected accident Exclusion Area Boundary (EAB) dose was utilized to determine if an EAL threshold would be exceeded within the first 60 minutes using the Abnormal Radiation Level EAL thresholds. In cases where several projected doses were provided or release data was not detailed significantly to determine an EAL, the assessment used the radiological consequences associated with the realistic case in accordance with NEI 10-05.

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

1. The OSA scenarios were chosen using the guidance of NEI 10-05 and NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants. The evaluation considered the station Design Basis Accidents (DBA) described in the USAR along with additional scenarios specified by the guidance documents. The scenarios considered were:

Design Basis Threat (DBT) ground assault Control Rod Ejection Accident Main Steam Line Break Accident Loss of Coolant Accident, (LOCA)

Fuel Handling Accident Aircraft Probable Threat Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire)

Station Blackout, (SBO)

LOCA/General Emergency with release and PAR LOCA with entry into Severe Accident Management Small Line Break Outside Containment Waste Gas Accident Steam Generator Tube Rupture (SGTR)

Dropped Cask Appendix R Fire B. Accident Scenarios included in the Analysis

1. Design Basis Threat (DBT) as described in NEI 10-05 The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

2. Control Rod Ejection Accident as described in FSAR 14.16 This event assumes the reactivity insertion from the control rod ejection results in an overpower trip. The thermal-hydraulic analysis for this event is performed for only a few seconds. The remaining consequences of this event are covered by the small break LOCA analysis as noted in Chapter 14.17.2 of the FSAR.

3. Main Steam Line Break (MSLB) Inside Containment as described in FSAR 14.14 This event assumes a double-ended guillotine break of a Main Steam Line inside containment with a loss of offsite power. Release information was not available in the FSAR, however, to determine if a radiation based EAL condition would be met in the first 60 minutes of the event. Emergency declaration was based on the loss of offsite power.

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4. Loss of Coolant Accident as described in FSAR 14.17.

This event is defined by a large rupture of the PCS cold leg piping between the PCP and the reactor vessel for the PCS loop containing the pressurizer. This event also includes a loss of offsite power and failure of 1 diesel generator.

5. Fuel Handling Accident (FHA) as described in 14.19.

The FHA is assumed to occur in containment two days after shutdown. An Alert emergency declaration was assumed to be declared due to the event.

6. Aircraft Probable Threat (50.54hh)

Notification is received from the NRC that a probable aircraft threat exists (>5 minutes,

<30 minutes).

7. Fire requiring evacuation of the Control Room and plant shutdown from remote location, (Appendix R Fire) as described in NEI 10-05.

A fire occurs in the main control room requiring the evacuation and the procedure implemented to shutdown from the remote shutdown panels.

8. Station Blackout as described in NEI 10-05.

A loss of all offsite AC power occurs and the failure of the emergency diesel generators to start. The SM determines power cannot be restored and declares a SAE on EAL SS1.1.

9. LOCA/General Emergency (GE) with release and PAR as described in NEI 10-05.

This event is based on the same initial conditions of the LOCA but assumes system failures meet the GE conditions of a loss of 2 fission product boundaries with the potential loss of the third.

10. Small Line Break Outside Containment as described in FSAR 14.23.

This analysis assumes a charging line break resulting in a 160 gpm primary coolant leak outside containment.

11. Waste Gas Accident as described in FSAR 14.21.

This event assumes the rupture of a waste gas decay tank. EAL AA1.1 conditions are assumed to be met based on expected stack high range monitor readings.

12. Steam Generator Tube Rupture as described in FSAR 14.15 This event analyzes the response of a failure of a steam generator U-tube combined with a loss of offsite power.

C. Accident Scenarios not included in the Analysis

1. LOCA with entry into Severe Accident Management Guidelines (SAMG) as described in NEI 10-05.

NEI 10-05 Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift PALISADES Page 11

PALISADES ON-SHIFT STAFFING ANALYIS REPORT personnel other than licensed and non-licensed operators. Palisades SAMGs are guided by the TSC. All on-shift actions prior to off-site augmentation are performed by Licensed and Non-licensed operators. No additional analysis is required.

2. Dropped Cask as described in FSAR 14.11.

Analyzed dropped cask events were identified as events that would only occur with the availability of additional station staff above and beyond those represented by station minimum staff and are outside the bounds of this analysis. Additionally, it was determined that no emergency declaration would be expected for this event.

3. Appendix R Fire The team concluded the Control Room and Cable Spreading Room fires to be the most limiting fire events for resources and therefore a staffing analysis for the additional Appendix R fire scenario is not required. A review of operating procedures indicated that a fire in either of these rooms involves essentially the same operator actions, so the analysis considers only the Control Room fire in identifying required operator actions.

The emergency plan and fire brigade responsibilities are the same for all fire events although the Control Room fire and the Cable Spreading Room fire also require the additional actions to support a remote plant shutdown. Station Fire Protection, Appendix R, and Operations staff were used to validate these fire events as being the most man-power intensive.

The team concluded the Control Room fire to be the most limiting for resources and therefore a staffing analysis for an additional fire scenario is not required. The emergency plan and fire brigade responsibilities are the same for both events.

V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions applicable to all accidents in Palisades Staffing Analysis:

1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Off Normal Procedures (ONP), Emergency Operating Procedures (EOP), and Emergency Implementing Procedures (EI). Any additional tasks directed by the Technical Support Center (TSC), Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures were not reviewed.

2. Palisades has 30 minute and 60 minute emergency responders when augmented while the ERO is offsite. This analysis was conducted assuming a 90 minute response of the augmented ERO to allow the use of this analysis for a possible future extension in ERO augmentation times. No specific emergency response tasks requiring the augmented ERO were identified prior to the 90 minutes following the emergency declaration.

3. The OSA team determined there are no time critical RP and Chemistry tasks and that task performance is directed and prioritized by the Shift Manager. The time RP or Chemistry is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration.

Since the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.

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4. All crews have one individual filling the SM and one individual filling the STA roles therefore the analysis did not consider using a dual-role individual.

B. NEI 10-05 Rev 0 Assumptions