PNP 2014-051, Response to May 1, 2014 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times

Response to May 1, 2014 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times

ML14199A101
Person / Time
Site:	Palisades
Issue date:	07/16/2014
From:	Vitale A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PNP 2014-051
Download: ML14199A101 (208)

Text

a "Entergy-- 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 2014-051 July 16, 2014 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Response to May 1, 2014 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 OrganizationStaff 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 (ADAMS Accession No. ML13205A163).

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

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

Palisades- ProposedRevision to PalisadesSite 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 (ADAMS Accession No. ML13353A042).

PNP 2014-051 Page 2

5. ENO letter to NRC, PNP 2014-003, Response to December 16, 2013 Request for Additional Information for License Amendment Request to Revise Emergency Response OrganizationStaff Augmentation Response Times, dated February 13, 2014 (ADAMS Accession No. ML14044A059).

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

Palisades- LAR to Revise Emergency Response Response OrganizationStaff Augmentation Response Times - MF2321, dated May 1,2014 (ADAMS Accession No. ML14121A282).

Dear Sir or Madam:

In Reference 1, Entergy Nuclear Operations, Inc. (ENO) submitted a license amendment request to revise the Site Emergency Plan (SEP) at the Palisades Nuclear Plant (PNP). The proposed amendment would revise the PNP SEP to increase the staff augmentation response times for certain emergency response organization positions.

In Reference 2, ENO received a request for additional information (RAI) concerning the license amendment request (LAR), and ENO responded to the RAI in Reference 3.

ENO received a second RAI in Reference 4, and ENO responded to the second RAI in Reference 5.

ENO received a third RAI in Reference 6. The ENO response to the third RAI is provided in Attachment 1. contains the proposed revised SEP pages, and has been updated from information provided in Reference 1 to reflect the addition of a radiation protection technician 30-minute responder, as discussed in Attachment 1. Attachment 3 contains the On-shift Staffing Analysis Report, Revision 2, as discussed in Attachment 1. contains a marked up version of the On-shift Staffing Analysis Report, Revision 2.

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

This letter contains no new or revised commitments.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 16, 2014.

PNP 2014-051 Page 3 Sincerely, ajv/jse Attachments: 1. Response to May 1, 2014 Request for Additional Information for License Amendment Request to Revise Emergency Response Organization Staff Augmentation Response Times

2. Proposed Revision to Palisades Nuclear Plant Site Emergency Plan Pages

3. On-shift Staffing Analysis Report, Revision 2

4. On-shift Staffing Analysis Report, Revision 2 (marked up version) cc: Administrator, Region III, USNRC Project Manager, Palisades, USNRC Resident Inspector, Palisades, USNRC State of Michigan

ATTACHMENT 1 RESPONSE TO MAY 1, 2014 REQUEST FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST TO REVISE EMERGENCY RESPONSE ORGANIZATION STAFF AUGMENTATION RESPONSE TIMES Introduction In the Palisades Nuclear Plant (PNP) license amendment request (LAR) dated June 25, 2013, concerning emergency response organization staff augmentation response times, one of the changes that Entergy Nuclear Operations, Inc. (ENO) proposed was to extend the 30-minute response time for radiation protection (RP) technicians that perform in-plant protective action RP functions to 60 minutes. These functions include the following tasks: access control, RP coverage, personnel monitoring, and dosimetry.

With this proposed change in the LAR dated June 25, 2013, the emergency response organization for in-plant protective action RP functions would consist of four RP technicians responding within 60 minutes, with no RP technicians responding within 30 minutes.

This proposed change in the LAR would result in a total of one on-shift RP technician and twelve 60-minute RP technician responders for the following two RP major functional areas: (1) radiological accident assessment and support of operational accident assessment and (2) in-plant protective actions. The amendment request concluded that the on-shift RP technician would be capable of performing required RP functions in these areas during an emergency event until additional RP technicians arrive within 60 minutes.

ENO development of the response to the third NRC request for additional information (RAI) dated May 1, 2014 resulted in an ENO proposal to modify the LAR by retaining one RP technician as a 30-minute responder for in-plant protective action RP functions. With this change, the emergency response organization for in-plant protective action RP functions would consist of one RP technician responding within 30 minutes and three RP technicians responding within 60 minutes.

This change would result in a total of one on-shift RP technician, one 30-minute RP technician responder, and 11 60-minute RP technician responders for the following two major functional areas: (1) radiological accident assessment and support of operational accident assessment and (2) in-plant protective actions.

The 30-minute RP technician responder would as a minimum be qualified to perform all RP tasks except RP coverage for workers. These tasks would include offsite surveys, onsite (out-of-plant) surveys, in-plant surveys, access control duties, personnel monitoring, dosimetry, and general RP support duties. Having a 30-minute responder dedicated to assume these tasks as required ensures that the on-shift RP technician is available to provide RP coverage for any limited work activities before additional RP support arrives within 60 minutes of the event.

1 of 15 of the LAR, dated June 25, 2013, contained a proposed revision of Site Emergency Plan (SEP) Figure 5-2, titled "Plant Staffing and Augmentation Requirements," that reflected the staffing changes requested in the amendment request.

A revision to this figure is provided in Attachment 2 of this RAI response which incorporates the proposed change concerning one RP technician responding within 30 minutes and three RP technicians responding within 60 minutes for in-plant protective action RP functions. The revision of Figure 5-2 also includes a note describing the minimum qualifications for this 30-minute RP technician responder. The figure in supersedes the figure provided in Attachment 3 of the LAR. Other than changes associated with the 30-minute RP technician responder, the figure is unchanged from the version provided in the license amendment request.

ENO has reviewed the proposed changes against the standards in 10 CFR 50.47(b) and requirements in 10 CFR 50, Appendix E. The proposed changes would provide reasonable assurance that adequate protective measures will be taken in the event of a radiological emergency to protect the health and safety of the public. The changes do not impact the no significant hazards consideration documented in the LAR.

The responses to the RAI questions that follow reflect the change to one RP technician 30-minute responder and three 60-minute RP technician responders for in-plant protective action RP functions during an emergency event.

RAI Response A follow-up RAI was received from the Nuclear Regulatory Commission (NRC), by electronic mail on May 1, 2014. The ENO 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. ML13176A405)

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

Reference 3: ENO letter dated February 13, 2014 (ADAMS Accession No. ML14044A059)

Reference 4: NEI 10-05, Revision 0 (ADAMS Accession No. ML111751698)

Reference 5: NSIR/DPR ISG-01 (ADAMS Accession No. ML113010523)

NRC Request (May 1, 2014)

1. It is not clear to the staff how NEI 10-05 (Reference 4) can be used to justify staff augmentation changes. NEI 10-05 was createdby the industry to help licensees fulfill the requirementsof 10 CFR Appendix E, IV.A.9, which states, in part, that

"... on-shift personnel assigned emergency plan implementation functions are not assigned responsibilitiesthat would prevent the timely performance of their assigned functions as specified in the emergency plan." NEI 10-05 does not provide guidance that can be used to justify extensions to emergency response organization (ERO) timing nor does it assist the staff in making a reasonable 2 of 15

assurancefinding in accordance with 10 CFR 50.47(a) when evaluating the impact the possible delays in augmentation that may/or may not have with the ability of the on-shift crew to mitigate and/or manage the event.

a. Section 3.0, Background of Reference 3 states: "The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnelarrive in accordance with the site's emergency plan commitments. The augmenting ERO respondersassume many managerial,engineering,and administrative duties from the on-shift personnel, allowing on-shift personnel to focus more fully on plant operations. NUREG-0654 guidance recommends that there be, in additionto on-shift personnel, 30 and 60-minute responders."

i. Pleaseprovide additionaljustification that increasingthe augmentation time from 30 minutes to 60 minutes for the applicable ERO responderswill not negatively impact the ability of the on-shift crew to mitigate the event, i.e., the impact maintaininga 'dual-focus' (plantand emergency preparedness(EP)) will have on public health and safety. For some positions, maintainingsituationalawareness of the changing plant conditions may become difficult when managing EP requirementsfor an extended period of time, particularlyin the radiationprotection area, oversight, and communications areas. For all positions where an extension of the augmentation time is proposed, providejustification to support the change(s). Please note that NEI 10-05 does not provide guidance relative to this area.

1. The specific tasks/positions to be evaluatedare notifications/communications,offsite surveys, offsite dose assessment, onsite surveys, in-plant surveys, core/thermalhydraulics, health physics (HP) technician, electrician, and IC technician.

ENO Response

1. The response provided below includes additional information as requested, along with information previously provided in submittals supporting this LAR, that increasing the response time from 30 minutes to 60 minutes for certain emergency response augmentation staff will not negatively impact the ability of the on-shift staff to mitigate an emergency event.

Notifications/communications - The current SEP requires one augmented communications responder within 30 minutes and two augmented communications responders within 60 minutes for offsite notifications and communications. The proposed SEP change would require the 30-minute responder to respond within 60 minutes, so that all three of the augmented communications responders would be required within 60 minutes.

With the issuance of Revision 23 of the SEP in January 2013, an additional staff member was added to the minimum on-shift staffing complement to relieve the 3 of 15

shift manager and/or shift technical advisor (STA) of the concurrent task to perform these offsite communications. Prior to January 2013, the shift manager and STA were responsible for performing offsite notifications for some analyzed events, resulting in tasks that were concurrent with their primary emergency response tasks.

The addition of an emergency communicator to the on-shift staff obviated the need for augmented personnel to respond within 30 minutes for notifications and communications. The additional on-shift communicator is a dedicated emergency response function. This means that for all declared emergency events, the on-shift emergency communicator does not have any duties other than providing timely and accurate communications to offsite response agencies. The ability of the on-shift staff to perform notification and communications functions is ensured by the addition of the communicator to the on-shift staff.

As discussed in the previous submittals related to the LAR, the shift manager is normally assigned the responsibility for making selected event notifications, such as calls to the duty plant manager, the operations manager, and the NRC resident inspector. These notifications are communications that are approximately one minute in length and are considered to be acceptable tasks for the shift manager, and may be delegated to the communicator. In addition, the shift manager is assigned the task of notifying the off-shift emergency response organization (ERO) of the emergency. The shift manager can perform the concurrent tasks of maintaining emergency direction and control while notifying the ERO of the event using the computerized ERO notification system.

The on-shift communicator is capable of performing required notification and communication functions. Van Buren County and the State of Michigan are required to be notified within 15 minutes of the declaration of any emergency classification or change in protective action recommendation. The NRC is notified immediately following the state and local notifications and within 60 minutes of the emergency declaration. NRC notifications are treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRC communications are established, it is assumed that the NRC will request an open line to be continuously maintained with the NRC operations center. The availability of dedicated phone circuits and wireless headsets enables these NRC notifications to be performed by the same on-shift communicator who performs the state and county notifications. Using a headset as needed, a communicator can maintain an open line with the NRC while making state and county notifications on another line. This capability has been demonstrated in emergency drills and exercises conducted at PNP.

The change in response time for one of the communicators from 30 minutes to 60 minutes will not impact the ability of the on-shift staff to mitigate an emergency event.

Offsite surveys - The current SEP requires two augmented responders within 30 minutes and two augmented responders within 60 minutes to perform offsite radiological surveys. The proposed SEP revision requires all four of these responders within 60 minutes.

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The change in response time for offsite radiological survey responders is acceptable because there is no expected need to perform these surveys within at least the first 60 minutes of the event because of the use of installed post-accident effluent radiation monitors and the capability of on-shift staff to perform onsite surveys. In the unlikely event that an offsite survey is needed, the on-shift RP technician and the 30-minute RP technician responder would be available to perform the offsite survey. Offsite surveys are not expected to be needed during the initial stages of an event because expected release pathways are monitored release points. During at least the first 60 minutes of an accident, in-plant radiation monitoring instrumentation would be used because radiological release instrument data is easily obtained. Onsite surveys or installed post-accident effluent radiation monitors can provide rapid indication of a release of radioactive materials and can be used for offsite dose assessment calculation purposes.

Offsite radiological monitoring tasks, such as soil, water and vegetation sampling, or retrieval of environmental dosimetry, such as thermoluminescent dosimeters, can be performed as additional personnel arrive up to their required 60-minute response time. These radiological survey tasks are considered in the recovery phase, following a release of radioactive material, and are not needed for the immediate protection of the public health and safety.

The 30-minute delay in the offsite survey responders' response time will not impact the ability of the on-shift staff to mitigate an emergency event.

Offsite dose assessment - The current SEP requires one augmented responder within 30 minutes to perform offsite dose assessment. The proposed SEP revision requires one augmented responder within 60 minutes to perform the offsite dose assessment.

As discussed in the previous submittals related to the LAR, the chemistry technician assigned on-shift is trained to perform offsite dose assessment calculations. One trained individual can rapidly perform these calculations with a computerized control room dose assessment program using effluent radiation monitor readings and meteorological indications, both of which are available in the control room. Backup methodologies for meteorological inputs are provided should these indications fail or otherwise not be available.

The reassignment of offsite dose assessment activities from the shift manager to other on-shift personnel supports the change in response time for the augmented offsite dose assessor from 30 to 60 minutes. No competing sampling activities for the on-shift chemistry technician have been identified within 60 minutes, which also supports the change in augmented responder time. In addition, monitoring of installed radiological plant instrumentation is sufficient to support offsite dose assessment activities until augmented personnel arrive. The on-shift chemistry technician would be fully capable of performing offsite dose assessments in bounding events, such as an event that progresses rapidly to a General Emergency.

The delay in response time for the augmented responder from 30 minutes to 60 minutes will not impact the ability of the on-shift staff to mitigate an emergency event.

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Onsite and in-plant surveys - The current SEP requires two augmented responders within 30 minutes and two augmented responders within 60 minutes to perform onsite and in-plant radiological surveys. The proposed SEP revision requires four augmented responders within 60 minutes to perform onsite and in-plant radiological surveys.

The need for onsite or in-plant surveys before the 60-minutes responders arrive is unlikely. 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. In-plant radiological monitoring instrumentation provides a means by which radiological conditions can be determined during an emergency, thereby reducing the need to send RP personnel into the plant to obtain radiological data, particularly when assessing initial radiological conditions in the early stages of an event. The radiological monitoring system ensures that both RP and ERO members are kept informed of current and changing radiological conditions. In-plant radiological instrumentation provides a continuous radiological status of the rooms monitored and provides local and remote alarming capability. In the unlikely event that an onsite or in-plant survey is needed, the on-shift RP technician and the 30-minute RP technician responder are available to perform onsite and in-plant surveys before the 60-minute responders arrive.

Core/thermal hydraulics - The current SEP requires one augmented responder within 30 minutes for the core/thermal hydraulics technical support area. The proposed SEP revision requires one augmented responder within 60 minutes for this technical support area.

Improvements in the monitoring of plant parameters via the PNP plant process computer and improvements in emergency procedures have lessened the burden on the STA during postulated events, as discussed in the previous LAR-related submittals.

Also as discussed in the previous submittals related to the LAR, the STA functions in an oversight role for accident assessment and evaluation of operating conditions, which includes providing the core/thermal hydraulic technical support function on-shift. Concurrent offsite communications tasks for the STA were eliminated with the addition of a dedicated on-shift communicator to the on-shift staffing complement and the reassignment of communications duties from the STA to the dedicated communicator. The elimination of this communications collateral duty allows the STA to focus entirely on performing assigned technical support activities required by operating procedures, Technical Specifications, and emergency implementing procedures without responding augmented staff. The addition of the on-shift staff to support communicator eliminates any STA communications responsibilities and obviates the need for a 30-minute responder for the core/thermal hydraulic technical support function.

The STA would be capable of performing the core/thermal hydraulic technical support function in bounding events, such as an event that progresses rapidly to a General Emergency.

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With the elimination of concurrent communications tasks and improvements that have lessened the burden on the STA, the on-shift STA is fully capable of performing the core/thermal hydraulic technical support function for 60 minutes or more. The change in response time for the augmented responder would not impact the ability of the on-shift staff to mitigate an emergency event.

Health physics (HP) technician - The current SEP requires two augmented responders within 30 minutes and two augmented responders within 60 minutes to perform in-plant RP protective action tasks, such as access control, RP coverage, personnel monitoring, and dosimetry. The proposed SEP revision requires one augmented responder within 30 minutes and three augmented responders within 60 minutes to perform in-plant RP protective action tasks.

The 30-minute RP technician responder would be qualified as a minimum to perform all RP tasks except RP coverage for workers. These tasks include offsite surveys, onsite (out-of-plant) surveys, in-plant surveys, access control duties, personnel monitoring, dosimetry, and general RP support duties. Having a 30-minute responder assume these tasks helps ensure that the on-shift RP technician maintains situational awareness and is available to cover any vital response activities, such as providing RP coverage for any limited work activities that may be required before additional RP support arrived within 60 minutes of the event. The RP technicians are dedicated to performing radiation protection tasks, and have no collateral duties.

As discussed in previous submittals related to the LAR, RP technician workload has decreased due to improvements in RP processes and equipment. Worker access control is now automated because radiation protection work processes have been computerized. Worker self-issuance of electronic dosimeters facilitates more efficient use of RP technicians to provide RP coverage while preserving the ALARA concept. Dedicated electronic alarming dosimeters set to the emergency radiation work permit limits are pre-staged in the immediate control room area and at the radiological access control point. RP coverage will only be provided if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a task. If RP coverage is deemed necessary, multiple emergency teams can be covered by the on-shift RP technician in areas not in excess of 1 Rem per hour.

The need for RP coverage for workers in the plant before the 60-minute RP technician responders arrive would be limited. In the early stages of a postulated emergency event, the major site response activities are concentrated on determining the cause of the event, identifying the status of plant equipment, and following emergency operating procedures to place the plant in a safe condition.

Only after plant status is understood and the plant is in a stable condition would operator attention be focused on corrective maintenance that may be needed to restore plant capabilities.

A response time for one RP technician of within 30 minutes and the response time for three RP technicians of within 60 minutes for in-plant RP protective action tasks are supported by reductions in RP technician workload due to improvements in RP processes and equipment, including the use of electronic alarming 7 of 15

dosimetry. This change will not adversely impact the ability of the on-shift staff to mitigate an emergency event.

Electrician and instrumentation & control (I&C) technician - The current SEP requires one electrician and one instrument and control (I&C) technician to respond within 30 minutes, and one electrician to respond within 60 minutes, to perform repair and corrective action tasks. The proposed SEP revision requires two electricians and one I&C technician to respond within 60 minutes.

NEI 10-05 (Reference 4) defines repair and corrective action as: "An action that can be performed promptly to restore a nonfunctional 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." NEI 10-05 provides a standard methodology for performing analyses of the ability of the on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency, as required by 10 CFR 50, Appendix E, Section IV.A.9.

As discussed in the previous submittals related to the LAR, 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. Any maintenance needs during the initial phase of the event would likely be limited in scope and only involve minor troubleshooting or repair activities. The on-shift nuclear plant operators have the necessary expertise and training to perform troubleshooting and minor repairs during plant operations, and would be available to perform any minor troubleshooting and repair activities that might be needed.

NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Table B-1, indicates that repair and corrective action tasks may be performed by qualified shift personnel assigned other emergency response functions/tasks. The nuclear plant operators are trained to perform the actions associated with the repair and corrective action functional area.

Actions, such as resetting breakers and valve manipulations, that are directed by the control room supervisor to mitigate the event in accordance with procedures, can be performed by the nuclear plant operators without augmented response personnel within the first 60 minutes of the event. The addition of two nuclear plant operators to the on-shift staffing complement in Revision 23 of the SEP, which was issued in January 2013, supports the response time change for two 30-minute repair and corrective action responders to 60 minutes.

This change will not impact the ability of the on-shift staff to mitigate an emergency event.

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Postulated Emerqencv Event Scenarios The proposed changes to augmented staff response times do not affect the ability of the site to perform required emergency planning functions while maintaining situational awareness, during bounding emergency planning events such as an event that rapidly progresses to a General Emergency (GE) event or a fire scenario.

Immediate Declaration of a GE - In a rapidly progressing GE event scenario, in which a GE is declared at the beginning of the event, the on-shift staff would remain capable of performing required functions until augmented staff arrives.

As discussed in the ENO response to RAI question #4 below, the required emergency actions and notifications specified in emergency response procedures for the shift manager are essentially the same between an Alert, a Site Area Emergency (SAE), and a GE. The only significant difference in actions prescribed in emergency response procedures between an Alert and a SAE is that a SAE requires notification of Public Affairs, and the only significant difference between a SAE and a GE is that the shift manager is required to make a Protective Action Recommendation.

With regard to other on-shift staff, the dedicated communicator is essentially required to perform the same notifications for either of the emergency classifications. Offsite surveys would not likely be needed during the initial stages of the event because expected release pathways are monitored release points, although the on-shift RP technician and the 30-minute RP technician responder would be available to perform offsite surveys if needed. The chemistry technician would be assigned to perform an offsite dose assessment, with no competing chemistry/radiochemistry sampling identified within the first 60 minutes of an event. The STA no longer has any communication duties and therefore is dedicated solely to perform STA duties, such as providing core/thermal hydraulics technical support during a an event in which a GE is immediately entered.

With regard to onsite and in-plant surveys, in-plant radiological monitoring instrumentation provides a ready means to assess radiological conditions during an emergency before augmented staff arrives, although the on-shift RP technician and the 30-minute RP technician responder would be available to perform any needed surveys during this period. In-plant radiation protection tasks can be performed by the on-shift RP technician and the 30-minute RP technician responder, particularly with the reductions in their workload due to the improvements in RP processes and equipment. The need for RP coverage for workers in the plant before the 60-minute RP technician responders arrive would be limited. In the early stages of a postulated emergency event, the major site response activities are concentrated on determining the cause of the event, identifying the status of plant equipment, and following emergency operating procedures to place the plant in a safe condition.

Other changes associated with the LAR, as described in the previous LAR-related submittals, support the capability of the plant staff to respond to a GE. Augmented responders are required to arrive as quickly as possible to an emergency event.

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This requirement, which currently exists as a management expectation, is added in the proposed SEP Figure 5-2, titled "Plant Staffing and Augmentation Requirements," along with the change in the response time for certain 30-minute augmented positions (see Attachment 2). The 60-minute response time represents a maximum allowable time for response. It is therefore expected that response to augment the shift staff would result in personnel arriving at earlier times up to the maximum 60 minutes.

In addition, the augmentation response times of 30 and 60 minutes are treated in the current revision of the SEP as "approximate" times. The term "approximate" is undefined and may be subject to individual interpretation by emergency responders. The proposed consolidated 60-minute response time for all augmented positions is a required time in the proposed SEP revision and is no longer treated as approximate.

ERO personnel are trained with the expectation that, even when they are not on duty, they are to respond to an emergency call out when they are fit for duty and otherwise available for timely response. This requirement can and does (as demonstrated during periodic testing) lead to multiple personnel filling an augmented response position with the potential for some responders to be able to respond more quickly than the individual that is on duty at the time. This "all call" response expectation ensures not only a timely response for augmentation, but provides for more than a minimum quantity of responders that can remove burden from the on-shift staff. This expectation is now discussed in the proposed SEP Figure 5-2 (see Attachment 2).

With the proposed changes to the augmented responder response times, site personnel will remain capable of performing required emergency planning duties while maintaining situational awareness in an event in which a GE is immediately entered.

Fire Scenarios - PNP has a 5-person onsite fire brigade crew that is available on site at all times, and is composed of trained and qualified nuclear plant operators.

The crew is not impacted by the proposed emergency planning changes. The availability of an on-shift fire brigade allows the other on-shift plant personnel to perform their emergency response functions without the added tasks of fire brigade or first-aid team duties. With the proposed changes to the augmented responder response times, site personnel will remain capable of performing required emergency planning duties while maintaining situational awareness in a fire scenario.

NRC Request (May 1, 2014)

2. Please explain how the OperationsSupport Center (OSC), Emergency Operations Facility (EOF), and Joint Information Center (JIC)are staffed and provide discussion at to why the minimum staffing positions are not discussed as part of the application'sminimum ERO staff.

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ENO Response

2. The OSC provides a control point for onsite and initial offsite support involving chemistry, RP, maintenance, and operations personnel during declared emergency events. The OSC is activated within approximately 60 minutes of an Alert or higher emergency classification, and OSC priorities are directed by the control room or the TSC. The OSC staff currently includes the following: OSC manager, operations support, OSC log keeper, work control coordinator, mechanical coordinator, electrical/l&C coordinator, RP/chemistry coordinator, nuclear plant operators, mechanics, I&C technicians, electricians, technicians, RP technicians, radio communicator, RP support, and chemistry technicians.

The EOF is responsible for overall management of an emergency and for communicating with external agencies upon transfer of responsibility from the control room, and is activated within approximately 60 minutes of an Alert or higher emergency classification. The EOF staff currently includes the following:

emergency director, communicators, EOF manager, radiological assessment coordinator, dose assessor, offsite team coordinator, technical advisor, EOF log keeper, offsite monitoring teams, lead offsite liaison, administration and logistics coordinator, administrative personnel, information technology specialist, security coordinator, security staff, and incident command post (security).

The JIC has the responsibility for notifying the public through the media of actions taken by the JIC's individual emergency response organizations and keeping them informed during an emergency at the PNP. When the Governor of the State of Michigan activates the Michigan Emergency Management Plan, due to a SAE at the PNP, the JIC is activated. Activation of the JIC is optional for the State at the Alert level. The JIC staff includes individuals designated as official spokespersons by the State of Michigan, ENO, and local counties. The JIC staff currently includes the following ENO responders: site communications manager/coordinator, company spokesperson, JIC manager, press release writer, information coordinator, media liaison, technical advisor, technical assistant, inquiry response coordinator, inquiry response, media monitor, logistics coordinator, administrative support, JIC log keeper, and security.

The Technical Support Center (TSC) provides management and technical support to Plant Operations personnel during emergency conditions from a location adjacent to the Control Room, and is operational within approximately 60 minutes of an Alert or higher emergency classification. The TSC staff currently includes the following: emergency plant manager, TSC log keeper, shift manager (control room), TSC manager, OSC manager, security coordinator, reactor engineer, ENS communicator, TSC communicator, engineering coordinator, maintenance coordinator, radiological coordinator, operations coordinator, administrative support, mechanical engineer, electrical/l&C engineer, and information technology specialist.

The staffing positions associated with the OSC, the EOF, the JIC, and the TSC were not discussed as part of the license amendment request because the LAR impacts only 30-minute responders and these facilities are not required to be 11 of 15

activated until approximately 60 minutes after declaration of an Alert. The license amendment request addressed the capability of the on-shift staff to perform required emergency response functions until they are augmented within 60 minutes, and therefore is not directly impacted by activation of the OSC, the EOF, the JIC, or the TSC. In addition, the response time changes would not impact the activation times of the facilities.

NRC Request (May 1, 2014)

3. The response to RAI #6, from Reference 3 did not provide sufficient information for the staff's review with respect to the original question. Please explain how the preset dose/dose rate area radiationmonitor (ARM) alarms change from 'normal' to 'accident'range(s).

ENO Response

3. The ARMs do not change from "normal" to "accident" ranges. They instead contain a fixed range, and have the ability to detect both normal and accident conditions.

RAI question #6 from Reference 3 asks how the 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. The response to this RAI discussed the ARMs containing a fixed range that is sufficient to provide indication of escalating radioactive environments during severe accident conditions, and discussed automated specific radiation work permits with pre-established emergency dose and dose rate limits for entry into areas under accident conditions.

In addition, PNP uses dedicated dosimeters preset to an accident range for the emergency radiation work, and are pre-staged in the immediate control room area and at the radiological access control point for use during an event, as previously discussed RAI question #6. When conditions indicate that RP coverage is not deemed necessary in a particular area of the plant, the use of the pre-staged personal electric dosimeters (which will alarm at preset accident dose and dose rate setpoints) and installed ARMs (which alarm locally and remotely at fixed dose rates) are credited in lieu of RP coverage.

NRC Request (May 1, 2014)

4. The response to RAI #8, from Reference 3 did not provide sufficient information for the staff's review with respect to the originalquestion. As stated in #1 above, NEI 10-05 does not provide sufficient guidance that can be used as justification for ERO augmentation timing extensions. Please provide additionalinformation that would document how operatortraining (LOR) and/or EP drills/exercisesis sufficient to demonstrate that the Shift Managercan maintainsituational 12 of 15

awareness of the event, while performing all the EP functions assigned,for 60-minutes without assistanceor relief. In particular,the general emergency (GE) scenario typically requiresa significant amount of time communicating with State and local agencies, as well as the NRC. Pleaseprovide documentation that the stated trainingprogramsuse this scenario,with significant multiple communication demands, for 60-minutes.

ENO Response

4. The shift manager is responsible for the overall assessment of emergency conditions. The shift manager has the overall responsibility for operational decisions involving the safety of the plant and its personnel, and for making protective action recommendations for the public during an emergency situation.

The shift manager implements the SEP through the use of specific Emergency Plan Implementing Procedures. Shift managers are trained in these activities as part of their initial qualification training and annual requalification training, and are required to demonstrate competence in these areas during simulator training sessions and emergency drills. The shift technical advisor (STA) is also trained in these activities and provides peer checking for the shift manager.

While the shift manager has overall responsibility for operational decisions involving the safety of the plant, the control room supervisor (CRS) and the two reactor operators (ROs) within the control room have the direct responsibility of operating the plant during an emergency situation. The CRS and ROs would implement the appropriate emergency operating procedures for the particular event and operate the plant. The shift manager would oversee the CRS and RO activities while implementing the SEP and maintaining situational awareness of the event as it unfolds.

The shift manager has overall responsibility for emergency response to an event until this responsibility is transitioned to the emergency director in the EOF within approximately 60 minutes of event initiation. The shift manager continues to maintain control of plant operations after overall emergency response responsibilities have been turned over to the EOF emergency director.

Initial shift manager training requires that the shift manager demonstrate knowledge and understanding of emergency planning procedures and processes.

This includes making required notifications and maintaining communications, recommending protective action recommendations to public officials, and determining protective measures for onsite personnel. This also includes managing the plant response to the event while implementing the emergency plan, understanding the typical decisions concerning priorities that a shift manager must make in transitioning from normal operations to coping with an emergency event and implementation of the emergency plan, and assigning priorities to activities to ensure resources are appropriately directed to manage the plant condition.

The proficiency of the on-shift operations staff to perform critical emergency planning functions, without support from off-shift/off-site resources, is evaluated during operations continuing training and annual license exams. Emergency 13 of 15

response drill objectives are integrated into evaluated simulator sessions for plant operators. During these sessions, there is no augmentation of the on-shift operations staff with additional personnel, and there is no turnover of emergency response duties or responsibilities to the TSC or EOF. The shift control room staff is expected to perform all emergency response tasks that are required by the simulator scenario, in conjunction with other required actions that are directed by normal, abnormal, and emergency operating procedures. Evaluated emergency response tasks include emergency classification, notification, off-site dose assessment, formulation, and simulated implementation of protective action recommendations for off-site authorities.

The ability of the shift manager to implement the site emergency plan while maintaining command and control of the plant is also verified during emergency planning drills and exercises. Emergency planning drills and exercises require the shift manager to perform required emergency planning duties through the Alert or SAE stages of scenarios while also maintaining command control of the plant response in accordance with plant operating procedures.

The required emergency planning actions and notifications for the shift manager specified in site emergency planning procedures for the Alert, SAE, and GE classifications are very similar. For each classification, the shift manager, or a designee such as the communicator, is required to announce the emergency on the site public address system, sound the emergency siren, notify county, state, and NRC officials, perform accountability, ensure the emergency response data system is activated, and initiate onsite monitoring and habitability. The only significant difference in shift manager procedurally-described duties between an Alert and a SAE is that the SAE requires notification of Public Affairs. The only significant difference between the SAE and GE is that the GE requires a Protective Action Recommendation. Otherwise, the required emergency actions and notifications specified in emergency planning procedures are virtually the same between an Alert, the SAE, and the GE.

In summary, operator training and emergency planning drills/exercises are sufficient to demonstrate that the shift manager can maintain situational awareness of the event, while performing all required emergency planning functions, without assistance from augmented staff.

NRC Request (December 16, 2013)

5. From Reference 3, Attachment 3, B.9: The GE event is intended to be a loss of all three fission product barrierswith a release in progress> 1 Rem total effective dose equivalent (TEDE) offsite. Please revise accordinglyor providedadditional justification.

ENO Response

5. The On-shift Staffing Analysis (OSA) was revised to reflect loss of all three fission product barriers with a release of greater than one rem TEDE offsite. The 14 of 15

revised OSA is provided in Attachment 3 and a markup of the revised OSA is provided in Attachment 4.

NRC Request (December 16, 2013)

6. From Reference 3, Attachment 3, V.A.20: For the release start time, it is the staff's expectations that it begins with the start of the event, not after 15-minutes as stated. Pleaserevise accordinglyor provided additionaljustification.

ENO Response

6. In the OSA, Revision 2,Section IV.B.9 (page 10), the Loss of Coolant Accident (LOCA)/GE scenario assumes that the site immediately enters a condition requiring the declaration of a GE with indication of a radiological release that results in a dose that exceeds the Environmental Protection Agency's Protective Action Guides beyond the site boundary, necessitating Protective Action Recommendations.

For other scenarios, the OSA assumes in Section V.B.20 (page 13) that, in cases where a design basis accident analysis included a radiological release, and the starting point of the release was not clearly defined, the release was assumed to begin 15 minutes after the initiating event. This assumption is in accordance with guidance provided in NEI 10-05, Section 2.8, which states "In cases where a Design Basis Accident analysis includes a radiological release, and the starting point of the release is not clearly defined, the staffing analysis may assume that the release begins 15-minutes after the initiating event."

15 of 15

ATTACHMENT 2 Proposed Revision to Palisades Nuclear Plant Site Emergency Plan Pages FIGURE 5-2 PLANT STAFFING AND AUGMENTATION REQUIREMENTS MAJOR TASKS POSITION TITLE ON STAFF AUGMENTATION MAJOR FUNCTIONAL AREA CAPABILITY AND OR EXPERTISE SHIFT RESPONSE TIME 30 Min 60 Min Plant Operations and Shift Engineer/Shift 1--

Assessment of Operational Technical Advisor (SRO)

Aspects Shift Manager (SRO) 1 ....

Control Room Supervisor 1 ....

(SRO)

Control Room Operators 2 Nuclear Plant Operators 6 Emergency Director Shift Manager 1 -

Notification/ Notify licensee, state, 1 -- 3 Communication local, and federal personnel and maintain communication Radiological Accident Emergency Operations Senior Manager .... 1 Assessment and Support Facility (EOF) Director of Operational Accident Offsite Dose Senior Radiation Protection Assessment Assessment (RP) Expertise 1*

Offsite Surveys -- 1** 4 Onsite (Out-of-Plant) -- 1* 2 In-Plant Surveys Rad Protection Technicians 1 1 2 Chemistry/Radiochemistry Chem Technicians 1 -- 1

• May be provided by shift personnel assigned other functions.

• • May be provided by qualified RP Technician assigned other RP functions.

1 of 3

FIGURE 5-2 PLANT STAFFING AND AUGMENTATION REQUIREMENTS POSITION TITLE ON STAFF AUGMENTATION MAJOR FUNCTIONAL AREA MAJOR TASKS OR EXPERTISE SHIFT CAPABILITY AND RESPONSE TIME I 1 30 Min 60 Min Plant System Technical Support Core/Thermal Hydraulics 1" -- 1 Engineering, Repair, Electrical .... 1 and Corrective Actions Mechanical .... 1 Repair and Corrective Mechanical Maintenance 1" -- 1 Actions Radwaste Operator .... 1 Electrical Maintenance 1* -- 2 Instrument and Control (I&C) Technician .... 1 Protective Actions Radiation Protection: RP Technicians 2* 1 3 (In-Plant) (See Note)

a. Access Control

b. RP Coverage

c. Personnel monitoring

d. Dosimetry Fire Fighting -- Fire Brigade Local Support per Technical Specifications

• May be provided by shift personnel assigned other functions.

Note: Qualified as a minimum for all RP tasks except RP coverage.

2 of 3

FIGURE 5-2 PLANT STAFFING AND AUGMENTATION REQUIREMENTS STAFF AUGMENTATION MAJOR TASKS POSITION TITLE ON CAPABILITY AND MAJOR FUNCTIONAL AREA RESPONSE TIME OR EXPERTISE SHIFT 30 Min 1 60 Min Rescue Operations 2* Local Support and First-Aid Site Access Control Security, fire fighting Security Personnel All per and Personnel communications, personnel Security accountability Plan TOTAL 14 1 25 NOTES: 1. Staff augmentation personnel are required to respond as quickly as possible, within the required response time.

2. The Shift Manager may call out designated ERO members or the full ERO complement at any time in an emergency event regardless of classification.

3. Even when they are not on duty, staff augmentation personnel are to respond to an emergency call out when they are fit for duty and otherwise available for timely response.

4. The on-shift staffing requirements listed in this figure are a result of the Palisades Nuclear Plant On-shift Staffing Analysis Report, Revision 0, dated December 18, 2012, conducted in accordance with NEI 10-05 and required by 10CFR50 Appendix E, Section IV.A.9.

• May be provided by shift personnel assigned other functions.

3 of 3

ATTACHMENT 3 ON-SHIFT STAFFING ANALYSIS REPORT, REVISION 2 92 Pages Follow

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES NUCLEAR STATION ON-SHIFT STAFFING ANALYSIS Rev 2 May 22, 2014 Prepared by:~/W /vt, Date Peer Review yYA-A j1*. -5 L  ; ."

Myra(J~nes 6, / Date Approved by: ,...z,;/-, I1 Dan Malone / Datd - / "

PALISADES ON-SHIFT STAFFING ANALYIS REPORT TABLE OF CONTENTS

1. INT R O D UC T IO N ................................................................................................................................. 4 1I. AN ALY S IS S U M M A R Y .............................................................................................................. 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 Ill. A NA LY S IS P R O C E S S ........................................................................................................................ 8 IV . AC C ID E N T S C E N AR IO S ............................................................................................................. 9 A. A ccide nt S election ........................................................................................................... . . 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 ...................................... 22 C. Design Basis Accident Analysis #3 - Small Line Break Outside Containment as described in FS AR 14.23 ............................................................................................... 28 D. Design Basis Accident Analysis #4 - Main Steam Line Break Inside Containment.. 34 E. Design Basis Accident Analysis #5 - Loss of Coolant Accident .............................. 40 F. Design Basis Accident Analysis #6 - Fuel Handling Accident ................................ 46 G. Design Basis Accident Analysis #7 - Waste Tank Rupture ...................................... 52 H. Accident Analysis #8 - Aircraft Probable Threat ........................................................ 58 I. Accident Analysis #9 - Control Room Fire Requiring Evacuation and Remote S h u td ow n ............................................................................................................................... 64 J. Accident Analysis #10 - Station Blackout ................................................................... 70 K. Accident Analysis #11 - LOCA/General Emergency with Release and PAR ...... 76 PALISADES Page 2

PALISADES ON-SHIFT STAFFING ANALYIS REPORT L. Accident Analysis #15 - Steam Generator Tube Rupture with Concurrent Loss of Off-s ite P ow e r ........................................................................................................................ 82 VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ...... 88 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ..................... 91 A. Overlap Requiring Compensatory Measures ............................................................. 91 X. C O R R E C T IV E A C T IO N S ........................................................................................................... 91 A. Corrective Actions and Compensatory Measures ...................................................... 91 X I. R EF E R E N CE S ................................................................................................................................... 92 X II. STA FFIN G A NA LY IS T EA M ...................................................................................................... 92 Page 3 PALISADES Page 3

PALISADES ON-SHIFT STAFFING ANALYIS REPORT INTRODUCTION This document is a revision to the Palisades Nuclear Station On-shift Staffing Analysis (OSA) report dated February 10, 2014. This revision aligns the assumed conditions for the "Loss of Coolant Accident (LOCA) I General Emergency (GE) with a radiological release and Protective Accident Recommendations (PAR) Accident" as described in Section IV.B.9 with the conditions used for the analysis as described in Section VII.K.1.

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 analysisdemonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilitiesthat would prevent the timely performance of their assignedfunctions 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.

I1. 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) o Fire Fighting (FB)

• Accident Assessment o Radiation Protection and Chemistry o Notification/Communication

• Technical Support o 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 4

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 Requirement E-Plan Functional Area Analysis Results 50.54m Emergency Direction and Shift Manager (SM) E-Plan Figure 5-2 Control 1 50.54m Control Room Supervisor (CRS) E-Plan Figure 5-2 SSD 1 Shift Technical Advisor (STA) E-Plan Figure 5-2 Technical Support 1 50.54m Control Room Operator (RO #1) E-Plan Figure 5-2 1 50.54m Control Room Operator (RO #2) E-Plan Figure 5-2 1 Nuclear Plant Operator (NPO #11) E-Plan Figure 5-2 SSD 1 Nuclear Plant Operator (NPO #2) E-Plan Figure 5-2 FB 1 Nuclear Plant Operator (NPO #3) E-Plan Figure 5-2 FB 1 Nuclear Plant Operator (NPO #4) E-Plan Figure 5-2 FB 1 Nuclear Plant Operator (NPO #5) E-Plan Figure 5-2 FB 1 Nuclear Plant Operator (NPO #6) E-Plan Figure 5-2 FB 1 Communicator E-Plan Figure 5-2 Communications Notifications 1 E-Plan Figure 5-2 Accident Chemistry Technician Assessment/Chemistry 1 Radiation Protection (RP) #1 E-Plan Figure 5-2 Radiation Protection 1 Security Contingency Access Control and Per Security Security Plan/E-Plan Figure Accountability Contingency 5-2 Plan TOTAL 14 PALISADES Page 5

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.

Page 6 PALISADES Page 6

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-i, 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 7

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-i, 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.

Ill. ANALYSIS PROCESS The initial staffing analysis (Revision 0) was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, 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. The review process for the administrative change included in Revision 2 was limited to an independent peer review and final review and concurrence by the station EP Manager as documented on the report cover page.

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 DBA's 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.

Page 8 PALISADES Page 8

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 ifa 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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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.

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 Agency's Protective Action Guides beyond the site boundary, necessitating Protective Actions Recommendations.

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 PALISADES Page 10

PALISADES ON-SHIFT STAFFING ANALYIS REPORT 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.

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 (El). 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.

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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 unit's Tech Specs.

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

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

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

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

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

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

PALISADES Page 12

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.

Page 13 PALISADES Page 13

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

1. 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 E Analysis

1. Type of Event Mode' Document(s) Event ECL Required?

13 Assumed Appendix R Fire 1 ISG IV.C Alert No3 for Analysis Purpose 14 DBA Dropped Cask 1 FSAR 14.11 None No4 15 DBA Steam Generator Tube 1 FSAR 14.15 Alert Yes Rupture with concurrent LOOP Plant mode per FSAR or assumed for analysis purpose 2SAMG 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.

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

4 No emergency declaration is expected for this event.

Page 15 PALISADES 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. As noted in the analysis assumptions detailed in Section V.B.1 1 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

• El-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 Line On-shift Augmentation Role in Unanalyzed TMS

1. Position Basis Document Elapsed Time Table # I Task? Required?

1. ______osition____________ (min)* Line # Task? Required?

T2/L1 T5/L1 Emergency Plan T5/L3 1 Shift Manager Figure 5-2 60 T5/L5 No Yes T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/L3 3,dvisor Figure 5-2 T5/L7 No No 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No 6 Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 30 T5/L9 12 Communicator 5-2 T5/L13 No No 13 Chem Tech Emergency Plan 60 N/A No No Figure 5-2 14 RP#1 Emergency Plan 30 N/A No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A N/A No No I _ _ _ lPlan Figure 5-2 1 1 1 Page 17 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 1 Shift Manager Shift Manager Licensed Operator Training Program 2 Unit Supervisor CRS Licensed Operator Training Program 3 Shift Technical Advisor STA Licensed Operator Training 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 raining 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 Page 18 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 1N/A N/A 2 N/A N/A 3N/A N/A N/A N/A N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

Page 19 PALISADES Page 19

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. 1 (describe)

N/A 8 Chemistry Function task

1. 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.

Page 20 PALISADES Page 20

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5- EMERGENCY PLAN IMPLEMENTATION Analysis # 1 DBT Security Threat Line Function / Task On-Shift Task Analysis Controlling Method Position Declare the emergency classification level Emergency Planning Training ECL)Shift ManagerProgram!/ EP Drills pprove Offsite Protective Action 2 2Recommendations N/A N/A 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Training Program Notification and direction to on-shift staff Shfeaa er Ee en annn Training 5 (e.g., to assemble, evacuate, etc.) Shift Manager Emergency Planning Training I Program Emergency Planning Training Shift Manager Program 6 ERO notification 7 Abbreviated NRC notification for DBT event STA Licensed Operator Training Program 8 Complete State/local notification form Shift Manager Emergency Planning Training EmProgram Perform State/local notifications Communicator Emergency Planning Training 9 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 Communicator Emergency Planning Training 13 Perform NRC notifications Program 14 Perform other site-specific event notifications N/A N/A 14 (e.g., Duty Plant Manager, INPO, ANI, etc.) N/AN/A 15 Personnel Accountability Security Security Training Program / EP 5 PDrills Page 21 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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

• El-1 Rev. 56, Emergency Classification and Actions

• EI-3 Rev. 31, Communications and Notifications

• EI-2.2 Rev. 15, Emergency Staff Augmentation

• E1-12.1 Rev. 18, Personnel Accountability and Assembly

• ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 22 PALISADES Page 22

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

1. Position (min)* Line # Task? Required?

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

Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 24 PALISADES Page 24

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 2 Control Rod Election 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.

Page 25 iPage 25 PALISADES

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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 0-45 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: RP goes x x x x x x x x x x x to CR for job support 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

1. 2(describe) - N/A I"1 K1, will pertorm tne above taSK as directed Dy the Snirt Mianager. I aSK are not time critical. i ne time to perrorm tne taSKs and tne time to compiete tne tasks are estimated.

Page 26 PALISADES Page 26

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

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

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

(e.g., to assemble, evacuate, etc.) Emergency Planning Training Program ERO notification Shift Manager Emergency Planning Licensed Operator 7 Abbreviated NRC notification for DBT event N/A" ann rga Training Program 8 Complete State/local notification form Shift Manager Emergency Planning Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning Chem Technician Training Program 12 Offsite radiological assessment Emrgencyg Plogannn Communicator Emergency Planning 13 Perform NRC notifications I 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 1Security 5 EP Drills Page 27 PALISADES 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 1pCi/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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

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

• El-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 Page 28 PALISADES Page 28

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 3 Small Line Break Outside Containment Line On-shift Lin O-shftUnanalyzed Augmentation Role in TMS

1. Position Basis Document Elapsed Time Table # I Task? Required?

1. __osition(min)* Line #

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

______ _____Figure 5-2 _ _ _ _ _ _ _ _ _ _ _ _ _

14 RP#1 Emergency Plan 30 T4/L4 No No

_Figure 5-2 1 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No

_Plan Figure 5-2 1-Page 29 PALISADES PALISADES Page 2 9

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 1 Shift Manager Shift Manager Licensed Operator Training Program Unit Supervisor CRS Licensed Operator 2

Training Program 3 STA Licensed Operator 3Shift Technical Advisor raining 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 uxiliary 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 Page 30 PALISADES Page 3 0

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.

Page 31 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 0-5 5-10 10-15 15-2020-25 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: RP goes o 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. 1 (describe) - N/A 8 Chemistry Function task

1. 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.

Page 32 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

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

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

15 Personnel Accountability 15Security IEP DrillsTraining Program Security Page 33 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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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

• El-1 Rev. 56, Emergency Classification and Actions

• El-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 Page 34 PALISADES Page 34

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 4 Main Steam Line Break Line # On-shift E-Plan Reference augen Role in Table # Unanalyzed TMS Position ElapsediLine#Time Task? Required?

T2/L1 T5/L1 Emergency Plan 6T5/L3 Shift Manager Figure 5-2 Figur 60 5-2T5/1_6 T5/L5 No Yes T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 30 T5/L9 12 Communicator Emere 5-2 T5/L13 No No Figure 5-2 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 14 RP1Emergency Plan 30 T4/L4 No No RP#1 ~~Figure 5-2 _____________

Security Contingency 15 Security Plan / Emergency N/A T5/L1 5 No No Plan Figure 5-2 Page 35 PALISADES 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 Shift Manager Licensed Operator 1 Training Program Unit Supervisor CRS Licensed Operator 2

Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary Operator #1 #1 Training Program Other (non-Operations) Personnel Necessary to Implement ONPs and EOPs or SAMGs ifApplicable 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 Page 36 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.

Page 37 PALISADES Page 3 7

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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 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: RP is available to support job X X X X X X X X X X X X X X X X X

-overage or surveys as required 5 Offsite Rad Assessment:

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

1. 1 (describe)

N/A 8 Chemistry Function task

1. 2 (describe)

N/A 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.

Page 38 PALISADES Page 38

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 4 Main Steam Line Break Line # Function I Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1 cECL) Shift Manager Training Program / EP Drills pprove Offsite Protective Action N/A N/A 2

_ Recommendations 3 Approve content of State/local notifications Shift Manager Emergency Planning T'raining Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Notification and direction to on-shift staff Shft M raining Program /

(e.g., to assemble, evacuate, etc.) i anager Emergency Planning I T-raining Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A Emergency Planning 8 Complete State/local notification form Shift Manager Emraining Program 9Emergencyg Plogannn 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning Training Program 13 Perform NRC notifications Communicator Emergency Planning I 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 Officer Security Training Program EP Drills Page 39 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 DIG

• 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

• El-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 Page 40 PALISADES Page 40

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

1. Position E-Plan Reference Elapsed Time # / Line # Task? Required?

1. __Position_ (min) Task? Required?

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

Training Program Unit Supervisor CRS Licensed Operator 2

Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 42 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.

Page 43 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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 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: 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A I II 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.

Page 44 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

1. Method Declare the emergency classification level Emergency Planning 1 Decla Shift Manager Training Program / EP (ECL) Drills 2 Approve Offsite Protective Action N/A Emergency Planning Recommendations Training Program 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A Emergency Planning Training Program Notification and direction to on-shift staff (e.g., Licensed Operator Training 5 a directio to Shift Manager Program / Emergency to assemble, evacuate, etc.) Planning Training Program Emergency Planning Shift Manager rainin Pram 6 ERO notification Training Program 7 Abbreviated NRC notification for DBT event N/A N/A EmergencyPram Planning 8 Complete State/local notification form Shift Manager rainin Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Techncian Chemistry Technicianrnn EmergencyPaPlanning 12 Offsite radiological assessment Training Program Perform NRC notifications Communicator Emergency Planning 13 Training Program Perform other site-specific event notifications N/A N/A 14 (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program Page 45 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

• El-1 Rev. 56, Emergency Classification and Actions

• EI-3 Rev. 31, Communications and Notifications

• EI-2.2 Rev. 15, Emergency Staff Augmentation

• El-1 2.1 Rev. 18, Personnel Accountability and Assembly

• ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 46 PALISADES Page 46

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

1. On-shift Position

1. ________ E-Plan Reference m)Task?

Elapsed (min)

Time I Line # UanalyzeduTMSRequired?

T2/L1 T5/L1 Emergency Plan T5/L3 1 Shift Manager Figure 5-2 60 T5/L5 No Yes T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 12 Communicator Emergency Plan 30 T5/L19 Figure 5-2 T5/13 No No 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No I _ _ __ _ lPlan Figure 5-2 1 1 1 1 Page 47 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 Shift Manager Licensed Operator 1

1_ ShiftManagerTraining Program Unit Supervisor CRS Licensed Operator 2

Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 48 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.

Page 49 PALISADES 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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 50-55 55-60 60-65 65- 70- 75- 80- 85-90 E 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. 1 (describe) N/A 8 Chemistry Function task

1. 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 comple te the tasks are estimated.

Page 50 PALISADES Page SO

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION AnRIv_*iq *iR - F~iplI Hz~ndlinn Ac~cidpint

- #..F..u I H.n- Accident Line Function I Task On-Shift Position Task Analysis Controlling

1. Method Declare the emergency classification level Emergency Planning 1 Decla Shift Manager Training Program / EP (ECL) Drills N/A N/A 2 Approve Offsite Protective Action Recommendations Emergency Planning Program 3 Approve content of State/local notifications Shift Manager Training 4 Approve extension to allowable dose N/A N/A Operator Training 5 Notification and direction to on-shift staff (e.g., Sicensed toasmleautec)Shift Manager Program / Emergency Loassemble, evacuate, etc.) Planning Training Program EmergencyPram Planning Shift Manager rainin 6 ERO notification Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager Emergency Planning Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Chemitry echncian Emergency Planning hemistry Technicianrg a 12 Offsite radiological assessment Training Program 13 Perform NRC notifications Communicator Emergency Planning Training Program N/A N/A 14 Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program Page 51 PALISADES Page 5 1

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

• El-1 Rev. 56, Emergency Classification and Actions

• EI-3 Rev. 31, Communications and Notifications

• EI-2.2 Rev. 15, Emergency Staff Augmentation

• E1-12.1 Rev. 18, Personnel Accountability and Assembly

• ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 52 PALISADES Page 52

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

1. On-shift Position E-Plan Reference Elapsed (min)Time I Line # Task? Required?

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

1_ _ Shi __ManagerTraining Program Unit Supervisor CRS Licensed Operator 2

Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 54 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.

Page 55 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 5-50 50-55 55-60 60-65 70 75 80 85 85-90 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A J LI RP' will perform the above task as directed by the Shift Manager. Tasks are not time critical. I he time* to pertorm the tasks and me time to complete te tasks are estimated.

Page 56 PALISADES Page 56

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis @7 - Wa'ste Thnk Riinttire Line Function I Task On-Shift Position Task Analysis Controlling

1. Method Emergency Planning 1 Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills N/A N/A 2 Approve Offsite Protective Action Recommendations Emergency Planning Approve content of State/local notifications Shift Manager Training Program 3

4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., Licensed Operator Training 5 an directio to Shift Manager Program / Emergency

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

15 Personnel Accountability Security Officer Security Training Program Page 57 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

• El-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 Page 58 PALISADES 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 Emergency Plan T5/L3 1 Shift Manager Emere 5-2 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A T3/L1 No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A T3/L2 No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A T3/L3 No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A T3/L4 No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A T3/L5 No No Operator #6 Figure 5-2 30 T5/L9 Emergency Plan T5/1No 12 Communicator Figure 5-2 T5/13 No No 13 Chem Tech Emergency Plan 60 T4/L7 No No Figure 5-2 14 RP#1 Emergency Plan 30 T4/L6 No No Figure 5-2 Security 15 Security Contingency Plan N/A T5/L15 No No Emergency Plan Figure 5-2 Page 59 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 TitleIRole On-Shift Position Task Analysis Controlling Method Shift Manager Licensed Operator 1 Shift Manager Training Program CRS Licensed Operator 2 Unit Supervisor I _nitSupervisor Training Program 3 STA Licensed Operator 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 uxiliary 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 Page 60 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.

Page 61 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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 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:

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. 1: Support NRC open- X X X X X X X X x X line communications if needed 8 Chemistry Function task r2 (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.

Page 62 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

1. Method Declare the emergency classification level Emergency Planning 1ECL) Training Program / EP Drills N/A N/A 2 Approve Offsite Protective Action Recommendations EmergencyPramPlanning 3 Approve content of State/local notifications Shift Manager rainin Training Program 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., Licensed Operator Training 5 an directio to Shift Manager Program / Emergency o assemble, evacuate, etc.) Planning Training Program EmergencyPramPlanning 6 ERO notification Shift Manager rainin Training Program 7 Abbreviated NRC notification for DBT event N/A N/A EmergencyPramPlanning 8 Complete State/local notification form Shift Manager rainin Training Program 9 Perform State/local notifications Communicator Emergency Planning T'raining 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 13 Perform NRC notifications Communicator Emergency Planning 1raining Program N/A N/A 14 Perform other site-specific event notifications (e.g., Duty Plant Manager, INPO, ANI, etc.) l' 15 Personnel Accountability Security Security Training Program Page 63 PALISADES Page 63

PALISADES ON-SHIFT STAFFING ANALYIS REPORT 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

• El-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 Page 64 PALISADES Page 64

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #9 - CR Evacuation & Remote SID Augmentation Role in Table Unanalyzed TMS

1. On-shift Position Basis Document Elapsed Time 5 / Line # Task? Required?

(min)

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

______________ Fig]ure 5-2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security 15 Security Contingency Plan N/A N/A No No Emergency Plan

_Figure 5-2 Page 65 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 Vlinimum 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 2 __UnitSupervisor_ Training Program 3 Shift Technical Advisor STA Licensed Operator Sraining 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 uxiliary 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 Page 66 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 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 Page 67 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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 50-55 55-60 60-65 65- 70 80- 85-90 E 70 75 80 85 1 In-Plant Survey: N/A 2 On-site Survey: 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:

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

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

1. 2 (describe) - N/A

• Times are estimated Page 68 PALISADES Page 68

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

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

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

(e.g., to assemble, evacuate, etc.) Shift Manager Emergency Planning I_ Training Program Emergency Planning 6ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8Complete State/local notification form Shift Manager Emergenin yPlanninm 9 Emergency Planning 9 Perform State/local notifications Communicator Emergency Planning T-rainingl 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 13 Perform NRC notifications Communicator Emergency Planning I-raining Program 14 Perform other site-specific event notifications N/A

_e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability N/A N/A Page 69 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 Page 70 PALISADES Page 70

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE I - ON-SHIFT POSITIONS Positione Basis Augmentation Role in Table Unanalyzed TMS LiOn-shift Line i Elapsed Time 5 / Line # Task? Required?

(m n)

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

______________Fig]ure 5-2 _ ______ _ _ _ _ _

14 RP#1 Emergency Plan 30 N/A No No Figure 5-2 Security Contingency 15 Security Plan / N/A T5/L15 No No Emergency Plan

_Figure 5-2 1 Page 71 PALISADES 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 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 72 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.

Page 73 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 5-50 50-55 55-60 60-65 70 75 80 850 85-90 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:

(Includedin 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.

Page 74 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

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

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

15 Personnel Accountability Security Security Training Program Page 75 PALISADES PALISADES Page 75

PALISADES ON-SHIFT STAFFING ANALYIS REPORT K. Accident Analysis #11 - LOCAIGeneral 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 Agency's 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

• El-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

• EI-6.13, Rev. 23, Protective Action Recommendations for Offsite Populations Page 76 PALISADES Page 76

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

1. Elapsed Time 5 / Line # Task?

(min)

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

____ ____Figure 5-2 _ _ _ _ _ _ _____ _ _ _ _ _ _ _ _ _ _ _

Security Contingency 15 Security Plan / N/A T5/L1 5 No No Emergency Plan Figure 5-2 Page 77 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 Vlinimum 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 2_ UnitSupervisorTraining Program 3 Shift Technical Advisor STA Licensed Operator Sraining 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 uxiliary 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 Page 78 PALISADES Page 78

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analvsis #11 - LOCA/GE with PAR A__ali ........................

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.

Page 79 PALISADES 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

E 65- 70- 75- 80-0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 50-55 55-60 60-65 70 75 80 85 85-90 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A r

lr~r ,..II peirm m 4, aov tait s air.e eo-I oy. - f'e . t~n. /Ivi"nge asi--ar I not ime

.. cr:--1'itica i .e im to perror--m .1-C IS~t ,JuJInc tiri to c Iip LC

,I.A i.I.A RIP will perform the above taSK as directed by the Shift Manager. I aSKS are not time critcal. I he time to perform the tasks aria the Lime to complete the tasks are estimated.

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

Page 80 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

1. Controlling Method Declare the emergency classification level Emergency Planning 1 the Shift Manager Training Program / EP (ECL) Drills 2 Approve Offsite Protective Action Shift Manager Emergency Planning Recommendations Training Program Emergency Planning Shift Manager rainin Pr a m 3 Approve content of State/local notifications Training Program Emergency Planning Approve extension to allowable dose Shift Manager Training Program 4

Licensed Operator Notification 5 and direction to on-shift staff ~~~~~Shift Manager Training EegnyPann Program /

(e.g., to assemble, evacuate, etc.) Emergency Planning T-raining Program EmergencyPram Planning ERO notification Shift Manager rainin 6 -raining Program Licensed Operator Abbreviated NRC notification for DBT event N/A rining pror 7 ]raining Program EmergencyPram Planning 8 Complete State/local notification form Shift Manager rainin

]raining Program 9 Perform State/local notifications Communicator Emergency Planning

_raining Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning 1oraining Program Perform NRC notifications Communicator Emergency Planning 13 T-raining 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 Page 81 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 pCI/gm and a spiking factor of 335 (GIS) and a pre-accident iodine spike 40 pCI/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

• El-1 Rev. 56, Emergency Classification and Actions

• EI-3 Rev. 31, Communications and Notifications

• EI-2.2 Rev. 15, Emergency Staff Augmentation

• El-1 2.1 Rev. 18, Personnel Accountability and Assembly

• ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct

• AOP-24 Rev. 0, SGT leak Page 82 PALISADES Page 82

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

1. Elapsed Time 5 / Line # Task?

(min)

T2/L1 T5/L1 T5/L3 Shift Manager Emergency Figure 5-2 Plan 60 T5/L5 T5/L6 No Yes T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figlure 5-2 _______ ______ ______

4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Operator #3 Figure Emergency 5-2 Plan N/A

___________________ N/A No ______ No 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 30 T5/L9 12 Communicator Emergency Figure 5-2 Plan T5/13 T/1 NooN No 13 Chem Tech Emergency Plan 60 T5/L12 No Yes I_ Figure 5-2 14 RP#1 Emergency Plan 30 T4/L4 No No

=Figure 5-2 Security Contingency 15 Security Plan / N/A T5/L15 No No Emergency Plan

,Figure 5-2 Page 83 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 Unit Supervisor CRS Licensed Operator 2

2_ UnitSupervisorTraining Program 3 STA Licensed Operator 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 uxiliary 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 Page 84 PALISADES PALISADES Page 84

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Analysis #15 - Steam Generator Tube Ruoture 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 5N/A N/A N/A N/A This accident does not include the need for firefighting, first aid or search &rescue.

Page 85 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)*

N I Function /Task 0-5 65 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 60-65 65-0 5 0 70 80- 85-90 E 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A

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

Page 86 PALISADES PALISADES Page 86

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

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

(e.g., to assemble, evacuate, etc.) Emergency Planning Training Program EmergencyPrPlanning a m Shift Manager rainin 6 ERO notification Training Program Licensed Operator bbreviated NRC notification for DBT event N/A rining pror 7

Program eTraining Complete State/local notification form Shift Manager Emergency Planning 8

Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning Training Program 13 Perform NRC notifications Communicator Emergency Planning I 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 Page 87 PALISADES 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 Page 88 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 Manager's 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-31 0, Emergency Response OrganizationNotification 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 direction and control of the Throughout Direction and 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 Page 91 PALISADES Page 91

PALISADES ON-SHIFT STAFFING ANALYIS REPORT XI. REFERENCES

• NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response OrganizationStaffing and Capabilities

• NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planningfor Nuclear Power Plants

• NUREG-0654, Criteriafor Preparationand Evaluation of Radiological Emergency Response Plans and Preparednessin Support of Nuclear Power Plants.

• Palisades Emergency Plan, Rev 25 XlI. 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 Page 92 PALISADES Page 92

ATTACHNENT 4 ON-SHIFT STAFFING ANALYSIS REPORT, REVISION 2 (marked up version)

(additions are underlined, deletions are stricken out)

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

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES NUCLEAR STATION ON-SHIFT STAFFING ANALYSIS Rev 2 May 22, 2014 Prepared by:

M. F. Guvnn / Date Peer Review by: ,.k..

Myra J nes / Date Approved by: . A/6/

Dan Malone / Dat - "

PALISADES ON-SHIFT STAFFING ANALYIS REPORT TABLE OF CONTENTS

1. INT R O D UCT IO N ................................................................................................................................. 4 II. A NA LY S IS S U M M A R Y ....................................................................................................................... 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 Ill. A NA LY S IS P R O C E S S ........................................................................................................................ 8 IV . A CC ID E NT S C E NA R IO S ................................................................................................................... 9 A. A ccid e nt S e lectio n .................................................................................................................. 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 ....................................... 22 C. Design Basis Accident Analysis #3 - Small Line Break Outside Containment as described in FSA R 14.23 ................................................................................................ . 28 D. Design Basis Accident Analysis #4 - Main Steam Line Break Inside Containment.. 34 E. Design Basis Accident Analysis #5 - Loss of Coolant Accident .............................. 40 F. Design Basis Accident Analysis #6 - Fuel Handling Accident ................................. 46 G. Design Basis Accident Analysis #7 - Waste Tank Rupture ...................................... 52 H. Accident Analysis #8 - Aircraft Probable Threat ......................................................... 58 I. Accident Analysis #9 - Control Room Fire Requiring Evacuation and Remote S h u td o w n ............................................................................................................................... 64 J. Accident Analysis #10 - Station Blackout .................................................................... 70 K. Accident Analysis #11 - LOCA/General Emergency with Release and PAR ........ 76 PALISADES Page 2

PALISADES ON-SHIFT STAFFING ANALYIS REPORT L. Accident Analysis #15 - Steam Generator Tube Rupture with Concurrent Loss of O ff-s ite Po w e r ........................................................................................................................ 82 VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ...... 88 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ..................... 91 A. Overlap Requiring Compensatory Measures ............................................................. 91 X. C O R R E C T IVE AC T IO NS ........................................................................................................... 91 A. Corrective Actions and Compensatory Measures ...................................................... 91 XI. R EF ER ENC ES ................................................................................................................................... 92 XII. STA FFIN G A NA LY IS T EA M...................................................................................................... 92 Page 3 PALISADES Page 3

PALISADES ON-SHIFT STAFFING ANALYIS REPORT INTRODUCTION This document is a revision to the Palisades Nuclear Station On-shift Staffing Analysis (OSA) report dated December 18, 20!2February 10. 2014. This revision provides additional ,la;,fiati t.*oThis revision aligns the assumed conditions for the "Loss of Coolant Accident (LOCA) I General Emergency (GE) with a radiological release and Protective Accident Recommendations (PAR) Accident" as described in Section IV.B.9 with the conditions used for the analysis as described in Section VII.K.1.actions performed by on shift staff, incorporates technological advancem8nts implemontod to red-ucea on shift staff burden, and provyideG additionRal dsuion f the basis,fo-r solme cvaluatcd 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 analysisdemonstrating that on-shift personnel assigned emergency plan implementation functions are not assignedresponsibilitiesthat 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 OrganizationStaffing 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 Planningfor 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:

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

• Fire Fighting (FB)

• Accident Assessment

• Radiation Protection and Chemistry

• Notification/Communication

• Technical Support o 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.

PALISADES Page 4

PALISADES ON-SHIFT STAFFING ANALYIS REPORT 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.

Page 5 PALISADES PALISADES Page 5

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 reouired emeroencv Dlannine functions and the licensina basis reouirement for each on-shift Dosition.

On-Shift Licensing Basis E-Plan Functional Area Staffing Position Requirement Analysis Results M50.54m Emergency Direction and Shift Manager (SM) E-Plan Figure 5-2 Control 50.54m Control Room Supervisor (CRS) E-Plan Figure 5-2 SSD 1 Shift Technical Advisor (STA) E-Plan Figure 5-2 Technical Support 1 50.54m Control Room Operator (RO #1) E-Plan Figure 5-2 1 50.54m Control Room Operator (RO #2) E-Plan Figure 5-2 1 Nuclear Plant Operator (NPO #1) E-Plan Figure 5-2 SSD 1 E-Plan Figure 5-2 FB 1 Nuclear Plant Operator (NPO #2)

Nuclear Plant Operator (NPO #3) E-Plan Figure 5-2 FB Nuclear Plant Operator (NPO #4) E-Plan Figure 5-2 FB 1 Nuclear Plant Operator (NPO #5) E-Plan Figure 5-2 FB Nuclear Plant Operator (NPO #6) E-Plan Figure 5-2 FB 1 Communicator E-Plan Figure 5-2 Communications Notifications 1 Chemistry Technician E-Plan Figure 5-2 Accident Assessment/Chemistry 1 Radiation Protection (RP) #1 E-Plan Figure 5-2 Radiation Protection 1 Security Contingency Access Control and Per Security Security Plan/E-Plan Figure Accountability Contingency 5-2 Plan TOTAL 14 Page 6 PALISADES Page 6

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. Itis 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 ifneeded to perform this task during the event. No further analysis or TMS is required.

Page 7 PALISADES PALISADES Page 7

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-I, 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 8

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-i, 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.

Ill. ANALYSIS PROCESS The initial staffing analysis (Revision 0) was conducted by a joint team of corporate Emergency Preparedness (EP) personnel and station personnel from the Operations, Training, 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. The review process for the administrative change included in Revision 2 was limited to an independent peer review and final review and concurrence by the station EP Manager as documented on the report cover page.

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 DBA's 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.

Page 9 PALISADES Page 9

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 ifa 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 10

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.

Theis event is based en the same initial conditionS Of the-. LCA.hbu*.tassumes system failu-iroc meoet the GE coenditio~nl of a-locs6 of 2 ficcion pFd-rodut boun_1da_;rie6 With the potenta iess of the thrdunit 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 Agency's Protective Action Guides beyond the site boundary, necessitating Protective Actions Recommendations.

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.

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 (El). 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 12

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 unit's Tech Specs.

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

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

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

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

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

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

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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.

Page 14 PALISADES PALISADES Page 14

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

1. Type of Event Mode 1 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 15

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

1. Type of Event Mode' Document(s) Required?

13 Assumed Appendix R Fire 1 ISG IV.C Alert No3 for Analysis Purpose 14 DBA Dropped Cask 1 FSAR 14.11 None No4 15 DBA Steam Generator Tube 1 FSAR 14.15 Alert Yes Rupture with concurrent LOOP Plant mode per FSAR or assumed for analysis purpose 2SAMG 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.

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

4 No emergency declaration is expected for this event.

Page 16 PALISADES Page 16

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. 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

• El-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 17

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 1 DBT Security Threat Line On-shift Augmentation Role in L osit Basis Document Elapsed Time Table # Task? Required?

1. Position (min)* Line #

T2/L1 T5/L1 EmerencyPlanT5/1_3 1 Shift Manager Emergency Plan 60 T5/15 No Yes Figure 5-2 T5/LN6 T5/L8 2 Control Room Emergency Plan N/A T2/12 No No Supervisor Figure 5-2 Shift Technical Emergency Plan T2/LN3 Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 30 T5/L9 12 Communicator Emergency Plan T5/L13 No No Figure 5-2 13 Chem______

Tech

______Figlure 5-2 Plan Emergency _ _ _ _60_ _ _ _ N/A

____ No _ _No_ _

14 RP#1 Emergency Plan 30 N/A No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A N/A No No Plan Figure 5-2 Page 18 PALISADES PALISADES Page 18

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 2 Unit Supervisor CRS Licensed Operator Training Program STA Licensed Operator Training Shift Technical Advisor 3 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 6 uxiliary Operator #1 Nuclear Plant Operator #1 Non-Licensed Operator 1AAuxiliaryOperator_#1Training 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 Page 19 PALISADES Page 19

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 3N/A N/A N/A N/A N/A N/A This accident does not include the need for firefighting, first aid or search & rescue.

Page 20 PALISADES Page 20

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 5-50 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. 1 (describe)

N/A 8 Chemistry Function task

1. 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.

Page 21 PALISADES Page 21

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 1 DBT Security Threat Lin Function / Task On-Shift Task Analysis Controlling Method Position 1 Declare the emergency classification level Shift Manager Emergency Planning Training

_ _ _ __ _Program / EP Drills 2 pprove Offsite Protective Action N/A N/A Recommendations Emergency Planning Training 3 pprove content of State/local notifications Shift Manager Program 4 Approve extension to allowable dose N/A N/A NJotification and direction to on-shift staff Licensed Operator Training Program 5 N ne.g., evacuate, etc.)

to assemble, Shift Manager Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event STA Licensed Operator Training Program 8 Complete State/local notification form Shift Manager Emergency Planning Training 8 ComleteProgram 9 Perform State/local notifications Communicator Emergency Planning 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 13 Perform NRC notifications Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A 14 (e.g., Duty Plant Manager, INPO, ANI, etc.) N/AN/A 15 Personnel Accountability 1Security Security Training Program / EP IlDrills Page 22 PALISADES Page 22

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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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

• El-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 Page 23 PALISADES Page 23

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 2 Control Rod Ejection Accident Line On-shift Augmentation Role in

1. Position Basis Document Elapsed Time Table #I Unanalyzed TMS

1. ____osition_____ (min)* Line # Task? Required?

T2/L1 T5/L1 T5/L3 1 Shift Manager Emergency Plan 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No

_ Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan T5/L9 12 Communicator Figure 5-2 30 T5/L13 No No 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A N/A No No

_Plan Figure 5-2 1 1 1 Page 24 PALISADES Page 24

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 Shift Manager Licensed Operator 1

Training Program CRS Licensed Operator 2 Unit Supervisor I_ Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 25 PALISADES Page 25

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING ANALYSIS # 2 Control Rod Election 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.

Page 26 PALISADES Page 26

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 2 Control Rod Eiection Accident 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 5-50 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: RP goes X X X X X X X X X X X X X X to CR for job support 5 Offsite Rad Assessment:

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

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

1. 2 (describe) - N/A 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.

Page 27 PALISADES Page 27

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

1. Controlling Method Declare the emergency classification level Emergency Planning 1(ECL) Shift Manager Training Program / EP Drills 2 Approve Offsite Protective Action N/A N/A Recommendations Emergency Planning Approve content of State/local notifications Shift Manager Training Program 3

4 Approve extension to allowable dose N/A N7/A Licensed Operator Notification and direction to on-shift staff Shift Manager Training Program /

(e.g., to assemble, evacuate, etc.) Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning 6raining Program 7 Abbreviated NRC notification for DBT event N/A' Licensed Operar Training Program Emergency Planning 8 Complete State/local notification form Shift Manager Eraining Program Emrgencyg Plogannn 9 Perform State/local notifications Communicator Emergency Planning T'raining Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Emergency Planning Offsite radiological assessment Chem Technician Emraining Program 12 13 Perform NRC notifications Communicator Emergency Planning Training Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

15 Personnel Accountability Security EP DrillsTraining Program 1Security Page 28 PALISADES Page 28

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 1pCi/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 <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

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

• El-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 Page 29 PALISADES Page 29

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 3 Small Line Break Outside Containment Line On-shift Augmentation Role in Un Position Basis Document Elapsed Time Table # Task? Required?

1. _Position _(min)* Line #

T2/L1 T5/L1 Emergency Plan T5/L3 1 Shift Manager Figure 5-2 60 T5/L5 No Yes T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No

,Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 30 T5/L9 12 Communicator Emere 5-2 T5/L13 No No Figure 5-2 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 1RP1Emergency Plan 30 T4/L4 No No 14 RP#1 ~~Figlure 5-2 _______ ___ _____

Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No I______ _ Plan Figure 5-2 1 1 1 Page 30 PALISADES PALISADES Page 30

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 Shift Manager Licensed Operator 1

Training Program Unit Supervisor CRS Licensed Operator 2

Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 31 PALISADES Page 31

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 Fhis accident does not include the need for firefighting, first aid or search & rescue.

Page 32 PALISADES Page 32

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY AnmallciR1 2Qmnrll I iný Irn All,, aiei.eI Pnnf"inrnn L Position Performing Performance Time Period After Emergency Declaration (minutes)*

I Function / Task N65- 70- 75- 80-850 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 70 75 80 85 85-90 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 5 Offsite Rad Assessment:

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

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

1. 2 (describe) - N/A 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.

Page 33 PALISADES PALISADES Page 33

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

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

(e.g., to assemble, evacuate, etc.) Shift Manager Emergency Planning Training Program 6 IERO notification Shift Manager Emergency Planning Training Program Licensed Operator 7 Abbreviated NRC notification for DBT event N/A rining pror Training Program Emergency Planning 8 Complete State/local notification form Shift Manager Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological1 assessment Chem Technician Emergency Planning

1Training Program 13 Perform NRC notifications Communicator Emergency Planning 1raining Program Perform other site-specific event 14 notifications (e.g., Duty Plant Manager, N/A N/A INPO, ANI, etc.)

Program 15TPersonnel Accountability 1Security rEP DrillsTraining Security Page 34 PALISADES Page 34

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 <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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

• El-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 Page 35 PALISADES Page 3S

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis # 4 Main Steam Line Break On-shift Augmentation Role in Table # Unanalyzed TMS Line # Position E-Plan Reference Elapsed Time ILine# Task? Required?

ositin(mi) __ Task?___ Required T2/L1 T5/L1 Emergency Plan 60 T5/L3 Shift Manager Figure 5-2 T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No

_ Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 30 T5/L9 12 Communicator Figure 5-2 T5/L13 No No 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 Page 36 PALISADES Page 36

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 1 Shift Manager Shift Manager Licensed Operator Training Program 2 Unit Supervisor CRS Licensed Operator Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 37 PALISADES PALISADES Page 37

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.

Page 38 PALISADES PALISADES Page 38

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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 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: 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. 1 (describe)

N/A 8 Chemistry Function task

1. 2 (describe)

N/A

,akIthough 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.

Page 39 PALISADES Page 39

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 4 Main Steam Line Break Line # Function / Task On-Shift Position Task Analysis Controlling Method Declare the emergency classification level Emergency Planning 1 ECL) Shift Manager Training Program / EP Drills 2 Approve Offsite Protective Action N/A N/A Recommendations 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A N/A Licensed Operator Notification and direction to on-shift staff Training Program /

(e.g., to assemble, evacuate, etc.) Shift Manager Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning 6 __E__O__noti _____ation_____hi__ t MTraining Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager Emergency Planning Training Program 9 Perform State/local notifications Communicator Emergency Training ProgramPlanning 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning Training Program 13 Perform NRC notifications Communicator Emergency Planning 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 Officer Security Training Program

_EP Drills Page 40 PALISADES Page 40

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

• El-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 Page 41 PALISADES Page 41

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

1. Position E-Plan Reference Elapsed Time # / Line # Task? Required?

1. _Position (min) Task? Required?

T2/L1 T5/L1 T5/L2 1 Shift Manager Emergency Plan 60 T5/L3 No Yes Figure 5-2 T5/L5 T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figiure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Emergency Plan 30 T5/L9 12 Communicator Figure 5-2 T5/L13 No No 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 14 RP Emergency Plan 30 T4/L4 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No Plan Figure 5-2 1 1 Page 42 PALISADES Page 42

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 Shift Manager Licensed Operator 1 Training Program Unit Supervisor CRS Licensed Operator 2

Training Program Shift Technical Advisor STA Licensed Operator 3

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 uxiliary Operator #1 #1 raining 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 Page 43 PALISADES Page 43

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.

Page 44 PALISADES Page 44

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 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: 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A i-i' wili perrorm tne aoove taSK as airectea by the Shift Manager. i asks are not time critical. I ne time- to perform tne tasks ana tne time to compiete the tasks are estimated.

PALISDES PgeM4 PALISADES Page 45

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

1. Method Emergency Planning 1 eclare the emergency classification level Shift Manager Training Program / EP (ECL) )Drills 2 Approve Offsite Protective Action N/A Emergency Planning Recommendations Training Program 3 Approve content of State/local notifications Shift Manager Emergency Planning Emraining Program 4 Approve extension to allowable dose N/A Emergency Planning Training Program to on-shift staff (e.g., Shift Manager directionetc.) Licensed Operator Training 5 to assemble,and Notification evacuate, Program / Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager Emergency Planning Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning Training Program 13 Performn NRC notifications Communicator Emergency Planning Training Program Perform other site-specific event notifications N/A N/A 14 (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program Page 46 PALISADES PALISADES Page 46

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

• El-1 Rev. 56, Emergency Classification and Actions

• EI-3 Rev. 31, Communications and Notifications

• EI-2.2 Rev. 15, Emergency Staff Augmentation

• E1-12.1 Rev. 18, Personnel Accountability and Assembly

• ADMIN-4 Rev. 52, Operations Organization, Responsibilities and Conduct Page 47 PALISADES Page 47

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

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

1. (min) Task? Required?

T2/L1 T5/L1 Emergency Plan T5/L3 1 Shift Manager Figure 5-2 60 T5/L5 No Yes T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 No 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 30_______

12 Communicator Emergency Plan T5/113 No No Figure 5-2 13 Chem Tech Emergency Plan 60 T5/L12 No Yes I Figure 5-2 14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No

_Plan Figure 5-2 1 1 Page 48 PALISADES Page 48

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 1 Shift Manager Shift Manager Licensed Operator Training Program 2 Unit Supervisor CRS Licensed Operator Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 49 PALISADES Page 49

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.

Page 50 PALISADES Page 50

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 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:

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

1. 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.

Page 51 PALISADES Page 51

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

1. Method Declare the emergency classification level Emergency Planning 1 Decla Shift Manager Training Program / EP (ECL) Drills N/A N/A 2 Approve Offsite Protective Action Recommendations 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., Licensed Operator Training 5 to assemble, evacuate, etc.) Shift Manager Program / Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager Emergency Planning Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Techncian Emergency Planning 12 Offsite radiological assessment Chemistry Technician Trn Pa Training Program 13 Perform NRC notifications Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program Page 52 PALISADES Page 52

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 AAM.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

• El-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 Page 53 PALISADES Page 53

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #7 - Waste Tank Rupture Line Augmentation Role in Table # Unanalyzed TMS e On-shift Position E-Plan Reference Elapsed Time ElpsdTask? / Line # UanalyzeduTMS Required?

(min)

T2/L1 T5/L1 Emergency Plan T5/L3 1 Shift Manager Emere 5-2 60 T5/L5 No Yes Figure 2T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/12 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 Communicator Emergency Plan 30 T5/L9 12 Figure 5-2 T5/113 No No 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security Contingency 15 Security Plan / Emergency N/A T5/L15 No No I ____ _ Plan Figure 5-2 1 1 Page 54 PALISADES Page 54

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 Shift Manager Licensed Operator 1 Training Program 2 Unit Supervisor CRS Licensed Operator Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 55 PALISADES Page 55

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 q

accident does not include the need tor tiretighting, tirst aid or search & rescue.

I siS Page 56 PALISADES PALISADES Page 56

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

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 70 75 80 85 85-90 E ___________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 o 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A P

KIP' will perform me above taSK as airectea Dy tne Shift Manager. TaKs I are not time critical. I ne time- to perform tne tasks ana me time to complete tne tasks are estimated.

Page 57 PALISADES PALISADES Page 57

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

1. Method Declare the emergency classification level Emergency Planning 1 cECL) Shift Manager Training Program / EP Drills pprove Offsite Protective Action N/A N/A 2

Recommendations 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., Licensed Operator Training 5 to assemble, evacuate, etc.) Shift Manager Program / Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager Emergency Planning Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A 12 Offsite radiological assessment Chemistry Technician Emergency Planning Training Program 13 Perform NRC notifications Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Officer Security Training Program Page 58 PALISADES Page 58

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

• El-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 Page 59 PALISADES Page 59

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

(min)

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

______________Figure 5-2 _ _ _ _ _ _ _ _ _ _ _ ______

14 RP#1 Emergency Plan 30 T4/L6 No No Figure 5-2 Security 15 Security Contingency Plan N/A T5/L15 No No

/ Emergency Plan Figure 5-2 Page 60 PALISADES Page 60

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 1 Shift Manager Shift Manager Licensed Operator Training Program 2 Unit Supervisor CRS Licensed Operator Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 61 PALISADES PALISADES Page 61

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.

Page 62 PALISADES Page 62

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 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 5-50 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:

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. 1 Support NRC open- X X X x x x x x x x line communications if needed 8 Chemistry Function task 02 (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.

Page 63 PALISADES Page 63

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

1. Method Declare the emergency classification level Emergency Planning 1 (ECL) Shift Manager Training Program / EP Drills N/A N/A 2 Approve Offsite Protective Action Recommendations 3 Approve content of State/local notifications Shift Manager Emergency Planning Training Program 4 Approve extension to allowable dose N/A N/A Notification and direction to on-shift staff (e.g., Licensed Operator Training 5 to assemble, evacuate, etc.) Shift Manager Program / Emergency o aPlanning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager Emergency Planning mTraining Program 9 Perform State/local notifications Communicator Emergency Planning 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 13 Perform NRC notifications Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program Page 64 PALISADES Page 64

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

1. 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

• El-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 Page 65 PALISADES Page 65

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #9 - CR Evacuation & Remote SD Line Augmentation Role in Table Unanalyzed TMS

1. On-shift Position Basis Document Elapsed Time 5 / Line # Task? Required?

(min)

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

_____ ____ Figure 5-2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security 15 Security Contingency Plan N/A N/A No No Emergency Plan Figure 5-2 Page 66 PALISADES PALISADES Page 66

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 Shift Manager Licensed Operator 1 Training Program 2 Unit Supervisor CRS Licensed Operator Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 67 PALISADES Page 67

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 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 Page 68 PALISADES Page 68

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

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

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

1. 2 (describe) - N/A

• Times are estimated Page 69 PALISADES Page 69

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

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

(e.g., to assemble, evacuate, etc.) ShiftEmergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager EmrgeninyPlanninm 9 Emergency Planning 9 Perform State/local notifications Communicator Emergency Planning Training] Prog]ram 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 13 Perform NRC notifications Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A 4(e.g., Duty Plant Manager, INPO, ANI, etc./

15 Personnel Accountability IN/A N/A Page 70 PALISADES Page 70

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 Page 71 PALISADES Page 71

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analvsis #10 - Station Blackout Line Basis Augmentation Role in Table Unanalyzed TMS Line On-shift Position

1. Document Docu t (m Elapsed (min)

Time 5 I Line #

_____ Task?

_____ Required?

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

_Figure 5-2 1 Page 72 PALISADES Page 72

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #10 - Station Blackout Vlinimum 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 Shift Manager Licensed Operator 1 Training Program Unit Supervisor CRS Licensed Operator 2 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 uxiliary 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 Page 73 PALISADES Page 73

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.

Page 74 PALISADES Page 74

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analvsis #10 - Station Blackout 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 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: RP#1 CR forjob 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. 1 (describe) - N/A 8 Chemistry Function task

1. 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.

Page 75 PALISADES Page 75

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

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

(e.g., to assemble, evacuate, etc.) Shift Manager Emergency Planning T'raining Program 6 ERO notification Shift Manager Emergency Planning Training Program 7 Abbreviated NRC notification for DBT event N/A N/A 8 Complete State/local notification form Shift Manager Emergency Planning T-raining Program 9 Perform State/local notifications Communicator Emergency Planning

_-raining 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 13 Perform NRC notifications. Communicator Emergency Planning Training Program 14 Perform other site-specific event notifications N/A N/A 1 (e.g., Duty Plant Manager, INPO, ANI, etc.)

15 Personnel Accountability Security Security Training Program Page 76 PALISADES Page 76

PALISADES ON-SHIFT STAFFING ANALYIS REPORT 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 Agency's 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

• El-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

• EI-6.13, Rev. 23, Protective Action Recommendations for Offsite Populations Page 77 PALISADI~S PALISADES Page 77

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

4. Tables PALISADES TABLE 1 - ON-SHIFT POSITIONS Analysis #11 - LOCAIGE with PAR Line Basis Augmentation Role in Table Unanalyzed TMS Required?

1. On-shift Position Document Elapsed Time 5 / Line # Task?

(min)

T2/L1 T5/L1 T5/L2 T5/L3 1 Shift Manager Emergency Plan 60 T5/L4 No Yes Figure 5-2 T5/L5 T5/L6 T5/L8 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Figure 5-2 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 No No 10 Nuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 12 Communicator Emergency Plan T5/1No Figure 5-2 T5/113 No No 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 14 RP#1 Emergency Plan 30 N/A No No Figure 5-2 Security Contingency 15 Security Plan / N/A T5/L15 No No Emergency Plan I _ _ __ _ lFigure 5-2 1 1 1 1 Page 78 PALISADES Page 78

PALISADES ON-SHIFT STAFFING ANALYIS REPORT PALISADES TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN One Unit - One Control Room Analysis #11 - LOCAIGE with PAR Vlinimum 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 Shift Manager Licensed Operator 1

Training Program 2 Unit Supervisor CRS Licensed Operator Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 79 PALISADES Page 79

PALISADES ON-SHIFT STAFFING ANALYIS REPORT Fire Brigade PALISADES TABLE 3 - FIREFIGHTING Anni rnia R1 '1 - I frA~AIW= ifh*DA92 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.

Page 80 PALISADES Page 80

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

4 Job Coverage: RP reports o 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A I II 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.

Page 81 PALISADES PALISADES Page 81

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

1. Controlling Method Emergency Planning 1 Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills 2 Approve Offsite Protective Action Shift Manager Emergency Planning Recommendations Training Program 3 Approve content of State/local notifications Shift Manager Emergency Planning IJIJIU[Training Program EmergencyPram Planning Approve extension to allowable dose Shift Manager rainin 4 Training Program Licensed Operator Notification 5 and direction to on-shift staff ~~~~~Shift Manager Training Program /

EegnyPann (e.g., to assemble, evacuate, etc.) Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program Licensed Operator Abbreviated NRC notification for DBT event N/A rining pror 7 Training Program EmergencyPram Planning Shift Manager rainin 8 Complete State/local notification form Training Program 9 Perform State/local notifications Communicator Emergency Planning Training Program 10 Complete NRC event notification form N/A N/A 11 Activate ERDS N/A N/A Chemistry Technician Emergency Planning 12 Offsite radiological assessment Training Program 13 Perform NRC notifications Communicator Emergency Planning 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 Page 82 PALISADES Page 82

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 0 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 pCI/gm and a spiking factor of 335 (GIS) and a pre-accident iodine spike 40 pCI/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

• El-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 Page 83 PALISADES PALISADES Page 83

PALISADES ON-SHIFT STAFFING ANALYIS REPORT

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

Line 5 / Line # Task?

e On-shift Position Document (min)Time Elapsed T2/L1 T5/L1 T5/L3 1 Shift Manager Emergency Plan 60 T5/L5 No Yes Figure 5-2 T5/L6 T5/L8 T2/L2 No No Figure 5-2 Plan 2 Control Room Emergency N/A Supervisor 3 Shift Technical Emergency Plan 60 T2/L3 No No Advisor Figure 5-2 4 Nuclear Control Emergency Plan N/A T2/L4 No No Operator #1 Figure 5-2 5 Nuclear Control Emergency Plan N/A T2/L5 No No Operator #2 Figure 5-2 6 Nuclear Plant Emergency Plan N/A T2/L6 No No Operator #1 Figure 5-2 7 Nuclear Plant Emergency Plan N/A N/A No No Operator #2 Figure 5-2 8 Nuclear Plant Emergency Plan N/A N/A No No Operator #3 Figure 5-2 NoNo 9 Nuclear Plant Emergency Plan N/A N/A No No Operator #4 Figure 5-2 10 lNuclear Plant Emergency Plan N/A N/A No No Operator #5 Figure 5-2 11 Nuclear Plant Emergency Plan N/A N/A No No Operator #6 Figure 5-2 30 T5/L9 12 Communicator Emergency Plan T5/L13 No No Figure 5-2 13 Chem Tech Emergency Plan 60 T5/L12 No Yes Figure 5-2 ______ _____ __ ____

14 RP#1 Emergency Plan 30 T4/L4 No No Figure 5-2 Security Contingency 15 Security Plan / N/A T5/L15 No No Emergency Plan

_Figure 5-2 1 1 Page 84 PALISADES Page 84-

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 Unit Supervisor CRS Licensed Operator 2

Training Program 3 Shift Technical Advisor STA Licensed Operator 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 uxiliary 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 Page 85 PALISADES Page 85

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.

Page 86 PALISADES PALISADES Page 86

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 0-5 5-10 10-15 15-2020-25 25-30 30-35 35-40 40-45 5-50 50-55 55-60 60-65 65- 70 80- 85-90 E 70 75 80 85 1 In-Plant Survey: N/A 2 On-site Survey: 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. 1 (describe) N/A 8 Chemistry Function task

1. 2 (describe) N/A

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

Page 87 PALISADES Page 87

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

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

(e.g., to assemble, evacuate, etc.) Emergency Planning Training Program 6 ERO notification Shift Manager Emergency Planning Training Program Licensed Operator 7 Abbreviated NRC notification for DBT event N/A rining Pro r Eraining Program 8 Complete State/local notification form Shift Manager Emergency Planning T-raining Program 9 Perform State/local notifications Communicator Emergency Planning

_raining Program 10 Complete NRC event notification form N/A [N/A 11 Activate ERDS N/A N/A Techncian Emergency Planning Chemistry Technician rnn Pa 12 Offsite radiological assessment Eraining Program 13 Perform NRC notifications Communicator Emergency Planning 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 Page 88 PALISADES Page 88

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 Page 89 PALISADES PALISADES Page 89

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 Manager's 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 1iNotification 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 Manaqer Date: 11/05/2012 Name Job Title Evaluator: Dan Malone Position: EP Manager Date: 11/05/2012 Name Job Title PALISADES Page 91

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 Page 92 PALISADES Page 92

PALISADES ON-SHIFT STAFFING ANALYIS REPORT X1. REFERENCES

• NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities

• NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planningfor Nuclear Power Plants

• NUREG-0654, Criteriafor Preparationand Evaluation of Radiological Emergency Response Plans and Preparednessin 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

" Appendix R Page 93 PALISADES Page 93