RA-17-071, Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition

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Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition
ML17317A328
Person / Time
Site: Oyster Creek
Issue date: 11/10/2017
From: Gallagher M
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
CAC MF9352, RA-17-071
Download: ML17317A328 (15)
v • d • e


Text

{{#Wiki_filter:Michael P. Gallagher Exelon Nuclear Exelon Generation Vice President License Renewal and Decommissioning 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.90 10 CFR 50.54(q) RA-17-071 November 10, 2017 U.S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15

Subject:

Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition

Reference:

1) Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "License Amendment Request -

Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defue/ed Condition," dated February 28, 2017, RA-17-012 (ML17060A289)

2) Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Response to Request for Additional Information (RAJ) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defue/ed Condition, " dated September 20, 2017 (ML 170263A066)
3) U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker, Exelon Generation Company, LLC - Draft Request for Additional Information - Oyster Creek ERO Staffing Amendment, dated October 11, 2017
4) U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker (Exelon Generation Company, LLC) - "Oyster Creek Nuclear Generating Station - Request for Additional Information Regarding License Amendment Request for Emergency Plan Changes to Revise the On-Shift Staffing and the Emergency Response Organization Staffing for a Permanently Defue/ed Condition (CAC NO. MF9352)," dated October 16, 2017 (ML17289A790)

U.S. Nuclear Regulatory Commission Response to Request for Additional Information and Supplemental Information to OCNGS License Amendment Request Docket Nos. 50-219 and 72-15 November 10, 2017 Page 2 By letter dated February 28, 2017 (Reference 1), as supplemented by letter dated September 20, 2017 (Reference 2), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAR) for Oyster Creek Nuclear Generating Station (OCNGS). The proposed amendment would revise the site emergency plan (SEP) for the permanently shutdown and defueled condition. Subsequently, in an electronic mail request dated October 11, 2017 (Reference 3), the NRC issued a draft Request for Additional Information (RAI) indicating that it had reviewed the information submitted in the Reference 2 letter, and that additional clarifying information was needed to support its continued review. The draft RAI in Reference 3 was further discussed during a teleconference on October 16, 2017, between Exelon and NRC representatives. As a result of the discussions, it was determined that no modification to the draft RAI was needed and the NRC issued a formal RAI on October 16, 2017 (Reference 4), and requested a response by November 15, 2017. Accordingly, Attachment 1 of this letter provides Exelon's response to the NRC's RAI and includes supplemental information in support of this amendment request. Attachment 2 includes the revised marked-up and clean-typed pages to the proposed OCNGS Emergency Plan "Table OCNGS B-1: Minimum Staffing Requirements," (replace pages B-38 through B-40). Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4). There are no regulatory commitments contained in this submittal. If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1oth day of November 2017. Respectfully, Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC

U.S. Nuclear Regulatory Commission Response to Request for Additional Information and Supplemental Information to OCNGS License Amendment Request Docket Nos. 50-219 and 72-15 November 10, 2017 Page 3 Attachments: 1. Response to NRCs Request for Additional Information

2. Revised Marked-Up and Clean-typed Pages for OCNGS Emergency Plan "Table OCNGS B-1: Minimum Staffing Requirements" cc: w/Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

Attachment 1 Response to NRCs Request for Additional Information Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-1

SUMMARY

By letter dated February 28, 2017 (ML17060A289) (Reference 1), as supplemented by letter dated September 20, 2017 (ML17263A066) (Reference 2), Exelon Generation Company, LLC (Exelon), requested prior U.S. Nuclear Regulatory Commission (NRC) approval of an amendment to the Oyster Creek Nuclear Generating Station (OCNGS) Site Emergency Plan (SEP) in support of Exelons intent to permanently cease power operations at OCNGS no later than December 31, 2019. The proposed amendment to the OCNGS SEP would revise the OCNGS Emergency Response Organization (ERO) on-shift and augmented staffing, based on the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel to the NRC in accordance with 10 CFR 50.82(a)(1)(i) and (ii). Subsequently, in an electronic mail request dated October 11, 2017 (Reference 3), the NRC issued a draft Request for Additional Information (RAI) indicating that it had reviewed the information submitted in the Reference 2 letter, and that additional clarifying information was needed to support its continued review. The draft RAI in Reference 3 was further discussed during a teleconference on October 16, 2017, between Exelon and NRC representatives. As a result of the discussions, it was determined that no modification to the draft RAI was needed and the NRC issued a formal RAI on October 16, 2017 (Reference 4), and requested a response by November 15, 2017. Accordingly, this attachment provides Exelons response to the NRC's RAI contained in the Reference 2 electronic mail request. The specific question is followed by Exelon's response. Exelon is providing information to supplement the amendment request as contained in the Attachments 2 of this submittal. Attachment 2 includes the revised marked-up and clean-typed pages to the proposed OCNGS SEP "Table OCNGS B-1: Minimum Staffing Requirements," (replaces pages B-38 through B-40). The revisions reflected with clouds represent changes from the original submittal (Reference 1). The redline and strikeout reflects the changes between the current operating SEP and the proposed Table OCNGS B-1. The SEP pages being submitted in this letter supersede in entirety those submitted in Reference 1 and Reference 2. RESPONSE TO RAI QUESTION RAI In a letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon), dated September 20, 2017, containing Exelons Response to NRC's Request for Additional Information and Supplemental Information, Exelon states in the response to RAI-OCNGS-3: Exelon has revised the proposed LAR (Reference 1) Table B-1, as provided in Attachment 2 to this submittal. This change restores the two RP Technicians (Item 4, In-Plant Surveys) (increased from one in the proposed LAR (Reference 1)) and the two Maintenance Personnel (Item 5, Repair and Corrective Actions) that are in the current OCNGS SEP. Additionally, "Note (c)" is being removed from the two designated shift Maintenance Personnel to indicate that they will not have any additional responsibilities and therefore will constitute part of the "Minimum Shift Size" compliment. Note (l) which states, "One position is filled by a Senior Maintenance Technician, the other position may be filled by an equipment operator" was deleted in the original submittal. It was reinstated as part of the RAI response. Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-2 It is unclear if the two Maintenance Personnel identified in the RAI response are specifically qualified to perform the duties of the required augmenting Electrical Maintenance and Mechanical Maintenance functions. The functions of the Electrical Maintenance and Mechanical Maintenance augmented responders need to be addressed per the guidance in NUREG-0654, Table B-1, "Repair and Corrective Actions," not by using the guidance in NEI 10-05, which is for onshift staffing. Additionally, there is no evaluation in the RAI response that two RP Technicians provide sufficient staffing and resources to mitigate an event with emergency classification levels up to and including a General Emergency. Previous NRC observations of other licensees drills have indicated that the reduced RP staffing did impact the performance of the emergency response organizations ability to implement mitigation actions. Exelon's Response to RAI Exelon understands the NRC's concerns with the proposed staffing levels with respect to the Maintenance and Radiation Protection (RP) personnel that will be available to respond to an event after the facility has permanently shutdown. As described below, Exelon is proposing the following changes to the staffing levels with regards to these positions. Exelon is proposing to revise the staffing levels for the Maintenance and the RP personnel consistent with the levels described in the current OCNGS operating SEP. This provides assurance that the RP positions will be appropriately staffed by qualified technicians and the Maintenance positions will be filled by qualified Maintenance personnel. This effectively returns the staffing regarding the RP and Maintenance personnel to what is in the current operating SEP. The revisions to the current SEP Table OCGS 2-1 are reflected below as shown by the relocation of notes and strikeouts. (a) Emergency Minimum 60 Minute Full Functional Area Major Tasks Position Shift Size Augmentation Augmentation

4. Radiological Offsite Dose PlantRP 1(c)

Accident Assessment Personnel Assessment and Support of Onsite Operational Surveys RP Personnel (d) Accident In-plant / RP Assessment Onsite Technicians(d) 2 (d) Surveys

6. In-Plant Protective Radiation RP 3(c) (d)

Actions Protection Personnel(d)

5. Plant Systems Repair and Maintenance 2(c) (d)

Engineering and Corrective Personnel(l)(d) Corrective Actions Actions (OSC) Notes: (a) Response time is based on optimum travel conditions. (c) May be provided by personnel assigned other functions. Personnel can fulfill multiple functions. (d) Personnel numbers depend on the type and extent of the Emergency, (l) One position is filled by a Senior Maintenance Technician, the other position maybe filled by an equipment operator. Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-3 The above table reflects that Note (d) in the Full Augmentation column (proposed for deletion in the LAR submittal (Reference 1)), has been relocated to the Emergency Position column. Note (d) provides for calling in additional personnel to perform these functions dependent on the type and extent of the emergency. Maintenance Functions Exelon is proposing to remove the cited Notes (c) and (l) from the "Plant Systems Engineering and Corrective Actions" Functional Area to reflect that both the individuals assigned the Maintenance "Repair and Corrective Actions" functions, will be dedicated qualified Maintenance personnel (removing the allowance that one may be an Operator). These changes are reflected as shown above and in the revised OCNGS Table B-1 in Attachment 2 to this RAI response. The Maintenance personnel who will be designated to perform the "Repair and Corrective Actions" functions will be dedicated Maintenance personnel who will be qualified to perform both the Electrical Maintenance and Mechanical Maintenance functions of the augmented Maintenance responders addressed in the guidance in NUREG-0654, Table B-1, "Repair and Corrective Actions." RP Functions As proposed in Reference 1, Attachment 1, Section 5.2.3, "Offsite Dose Assessment" (Item 4, Table B-1) will be performed by plant personnel. This permits an Operations person to perform this function if the third RP technician is performing other RP-related functions. The RP technicians and Operations Supervisors/Certified Fuel Handlers who will perform the Dose Assessment function, will be trained and qualified to perform Dose Assessment, commensurate with the current level of training received by the RP individual(s). This function is augmented by Emergency Operations Facility (EOF) personnel within 60 minutes of notification who will assume the Offsite Dose Assessment function once the EOF is activated. As proposed in Reference 2, "Offsite Surveys" will be performed by the four dedicated Field Monitoring Team personnel who will report to the EOF RP Manager through the EOF Dose Assessment Coordinator and Field Team Communicator. OCNGS is proposing to return the RP personnel levels for "In-Plant and Onsite Surveys" (Item 4, Table B-1) and "In-Plant Protective Actions" (Item 6, Table B-1) to the level in the current operating SEP. Their activities will be coordinated through the Operational Support Center (OSC) Director. Additional RP technicians may be called in as reflected by Note (d). For a permanently shutdown and defueled condition, the evaluated Design Basis Accidents are limited to the Spent Fuel Pool (SFP) area where a single Radiation Protection technician(s) can provide adequate response and access control. OCNGS will normally staff three RP technicians on site to support the "Radiological Accident Assessment" and "In-Plant Protective Actions" functions. Additionally, worker access control is automated because RP work processes are computerized. Radiation Work Permit (RWP) access control and electronic dosimeter computer systems work together to provide a fully integrated system, allowing workers to sign-in on their RWP and to self-issue electronic dosimeters. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and will alarm at preset dose and dose rate alarms. An annual RWP dedicated for SEP response will be written and available on Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-4 the first day of each year, which will preauthorize access for Emergency Response Organization (ERO) personnel in accordance with SEP implementing procedures. These functions have been successfully demonstrated during ERO drills that go beyond DBAs for the operating plant with the same level of RP technicians. As proposed in Reference 1, Attachment 3a, Section B.5, RP Supervision will be performed initially by Operations Shift Management who will transfer responsibilities to the RP Manager (Technical Support Center (TSC)) in coordination with the OSC Director.

References:

1. Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition," dated February 28, 2017 (ML17060A289) (CAC NO. MF9352)
2. Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition," dated September 20, 2017 (ML170263A066)
3. U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker, Exelon Generation Company, LLC - Draft Request for Additional Information - Oyster Creek ERO Staffing Amendment, dated October 11, 2017
4. U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker (Exelon Generation Company, LLC) - "Oyster Creek Nuclear Generating Station - Request for Additional Information Regarding License Amendment Request for Emergency Plan Changes to Revise the On-Shift Staffing and the Emergency Response Organization Staffing for a Permanently Defueled Condition (CAC NO. MF9352)," dated October 16, 2017 (ML17289A790)

Attachment 2 Revised Marked-Up and Clean-typed Pages for OCNGS Emergency Plan "Table OCNGS B-1: Minimum Staffing Requirements" (Replaces pages B-38 through B-40 in Proposed LAR, Attachment 3)

PART II: Planning Standards And Criteria Exelon Generation Table OC NGS 28 -1: Minimum Staffing Requirements Functional Area Major Tasks Emergency Positions I Minimum <a>so Minute NIU Shift Size Auamentation ,_ A, __ 

                                                                                                                                                        ~. - -

Shift Manager (CR) 1

1. Plant Operations/Safe ShiftControl Room Supervisor (CR) 1 Shutdown and Assessment Control Room Staff Non-Certified Reactor Operator (CR) 2 of Operational Aspects EEJtii13ment G13erator +

Shift Emergency Director (CR) 1<c>

2. Emergency Direction and Command and Control Station Emergency Director (TSC) 1 Control Emergency Operations Corporate Emergency Director (EOF) 1 Emergency Shift Communicator (CR) 1 Communications +SC Qirecter (+SC) +

EGP rnrecter (EGP) + State/Local Communicator ffi 1 (EOF) 1 (+SC) Gt-

3. Notification & ENS Communicator 1 (TSC) 1 (EGF)

Communication HPN Communicator 1 (EOF) 1 (+SC) Plant Status G13erations Gommtinieater (CRl'+SC) i (c) In-Plant Team Control Qamage Gentrel Cemm . (CRl'+SCtGSC) i (c) 1(+SC) Technical Activities +echnical Cemmtinicator (+SC) (c) + Governmental '"'-- -* -*-- I ._, ___ / C:l""\C: \ 

                                                                                                  ,-               ,,.........      +(c)           tE>>

Offsite Dose PlantRP Personnel 1( 7 Assessment RP GrotiJ:) bead (GSC) ft>> Dose Assessment Coordinator (EOF) 1 Qose Assessor (EGP) +

4. Radiological Accident Radiation Controls Coordinator (TSC) +

Assessment and Support of Offsite Surveys Operational Accident Field Team Communicator (EOF) 1 + Dff-SitP. Eield T.eam Personnel (h) 

                                                                                                                                    ~

tGj Assessment I *-.::i -ci ~ x -, *~ ( ~\.... .l '( '< __ ,~ ) ln-pla~nsife Chemistry '" * - rveys 

                                                             ' i. i "A ...>;.

RPT ec hnicians-Chemistry Personne~ 1. Q tGj tGj 

                                                                                                                                                    +

RP Supervisory Radiation Protection Manager(TSC/EOF) TBD 2019 B-38 EP- OC-1000 (Revision X)

PART II: Planning Standards And Criteria Exelon Generation Table OCNGS 28-1: Minimum Staffing Requirements (Cont'd) Functional Area Major Tasks Emergency Positions Minimum <a>60 Minute Fu<< Shift Size Auamentation A. ,_ Technical Support a+A t IRsideRt Assessor fil (CR) Technical Manager (TSC) 1 GeFe,l+lieFmal l=l~* eFattlies 15AgiAeeF E+8G) MeGRaRisal eR§iReer <:>> (+aG) elestrisal eR§iReer <:>> (+aq a.A.MG QesisieR Maker (+aG) (G) a.A.MG e¥al1:Jator (+aG) 2fGl

5. Plant System Engineering, 1 Operations Manager (TSC)

Repair and Corrective ...... . - ,..._ Q 

                                                           ~
                                                                                                      /TC"r"\

Actions Repair and Corrective Actions Maintenance P-~rso; ~;l~l)(d) Maintenance Manag::: ~ l. j \ (OSC) (TSC) 2El tat OSC Directorfkl (OSC) (G) 1 OaG AssistaRt Qirnstor (OaC) Accident Analysis Technical Support Manager (EOF) 1 G13eratieAs AEl>liser (eGF) 6. In-Plant Protective Actions Radiation Protection RP Person ~el<~> 

                                                                           *- 1 T--'--'--' /\-'-'- -
                                                                                 *~-                 .--
                                                                                                     /Cl"'IC'\   f"'y--..
                                                                                                                 ~ 3<c> -{

tat

7. Fire Fighting -- Fire BrigadeW ~
8. First Aid and Rescue -- Plant Personnel 2<c) tat Ooerations Security & Accountability Security Team Personnel (g) (g)
9. Site Access Control and Security Coordinator (TSC) 1 Personnel Accountability
                                ~ *- - *-*
                                 ""' ,... __ *-=**

Logistics I Administration f"'--* -~1 Logistics Manager I llr"\ (EOF) 1 be§istiGs GoerdiRator (+aG) 10. Resource Allocation and Administration Glerisal ata# (+aGtOaCteOF) tat e¥eRtS ReGereer (eOFtJIG) 2 AemiAistrati¥e CoereiRator (eGF) Com131:Jter a13esialist (+aC) TBD 2019 B-39 EP- OC-1000 (Revision X)

PART II: Planning Standards And Criteria Exelon Generation Table OC NGS ~B-1: Minimum Staffing Requirements (Cont'd) Functional Area Major Tasks Emergency Positions Minimum <a>so Minute MHl ,__ Corporate Spokesperson (JIC) Shift Size Augmentation 1 A 

                                                                                                                                                            *~

4-

11. Public Information Media Interface Technical Advisor I Spokesperson (JIC) 1 4-Information P1;Jblic Information Director (JIG) 4-Development News VIJriter tJlG1 4-Media Monitoring and Rumor Control NJ OEM Conducts Rumor Control (JIC)

Facility Operation and JIC Director (JIC) 1 Control JIG Coorainator (JIG) 4-Aaministrative Coorainator (JIG) 4-Clerical S1;Jpport (JIG) AA Minimum Total +otal Shift Size Minimum A MHl r ~-, Staff TOTAL: ~10 -{ 3423 20+ 

                                                                                                                        \..JJ (a ~~~~T1l('ltS'iT.~ti<ml'<OPtiTTT1~t1'3¥~m\ditic1F~Y--'("""""~:-<'-Y-Y-"'<Y-Y"""'<'-r'<~-Y-Y-"'<Y-'<"""<'-r'<~-Y-Y--Y-Y--'("""""~~

(b (c~~~~~~~~~~~~~~~~~~Qgi;~~~~~::=::;:::::::=::::;::::::=::::::=::::::::::;::~.._.,,.__,,..._.,.._,._,.,--""-~-, (d (e) '-Staffi~~tAe~~w...e~S-bitsiabR-~~m-ik~~.ifi~~fiEJ...oft..~WIM~-witR..eftsf~~flci~-Ao-.hell&,..9.\~~frJrt will be made to dispatch an Exelon Nuclear representative upon request from County EOC Director. (f) Fire Brigade per UFSAR I FHAR.:m.M, as applicable. The OC Post Shutdown OSSA assumes a Fire Brigade consisting of five (5) persons. Per the assessment, two (2) additional plant personnel are needed to form the fire brigade in conjunction with three (3) Operations staff on shift (who are assigned to the Fire Brigade as a collateral duty). Upon a successful evaluation and approval of an incipient Fire Brigade in accordance with 10 CFR 50.48(f) , the Fire Brigade compliment will be reduced to three (3). Th is is anticipated to occur sometime following shutdown . Until the 50.48(f) Fire Brigade evaluation is completed , the Fire Brigade will consist of five (5) persons. (g) Function performed by on-shift security personnel. (h) Each Field Survey Team consists of a Lead and Driver. (i) Refer to Section 2.1.1 ana 2.1.2 for aescription of on shift STA ana lneiaent Assessor staffing req1;Jirements. G) State I Loeal eomm1;Jnieator f1;Jnction in TSG assignea as collateral a1;Jty to either mechanical or eleetrical engineer (60 min1;Jte staff personnel) TBD 2019 B-40 EP- OC-1000 (Revision X)

PART II: Planning Standards And Criteria Exelon Generation Table OCNGS B-1: Minimum Staffing Requirements Functional Area Major Tasks Emergency Positions Minimum <a>so Minute Shift Size Auamentation Shift Manager (CR) 1

1. Plant Operations/Safe Shift Supervisor (CR) 1 Shutdown and Assessment Control Room Staff Non-Certified Operator (CR) 2 of Operational Aspects Shift Emergency Director (CR) 1<c)
2. Emergency Direction and Command and Control Station Emergency Director (TSC) 1 Control Emergency Operations Corporate Emergency Director (EOF) 1 Emergency Shift Communicator (CR) 1 Communications State/Local Communicator 1 (EOF)

ENS Communicator 1 (TSC)

3. Notification & HPN Communicator 1 (EOF)

Communication Plant Status (c) In-Plant Team Control (c) Technical Activities (c) Governmental (c) Offsite Dose Plant Personnel 1 Assessment Dose Assessment Coordinator (EOF) 1

4. Radiological Accident Offsite Surveys Field Team Communicator (EOF) 1 Assessment and Support of Off-Site Field Team Personnel Ch) 4 Operational Accident Assessment ln-plant/Onsite Surveys RP Technicians 2 Chemistry Chemistry Personnel<d>

RP Supervisory Radiation Protection Manaaer(TSC/EOF) 2 TBD 2019 B-38 EP- OC-1000 (Revision X)

PART II: Planning Standards And Criteria Exelon Generation Table OCNGS 8-1: Minimum Staffing Requirements (Cont'd) Functional Area Major Tasks Emergency Positions Minimum <a>so Minute Shift Size Auamentation Technical Support Technical Manager (TSC) 1 Operations Manager (TSC) 1

5. Plant System Engineering, Repair and Corrective Repair and Corrective Maintenance Personnel<d> (OSC) 2 Actions Maintenance Manager (TSC) 1 Actions OSC Director (OSC) 1 Accident Analysis Technical Support Manager (EOF) 1
6. In-Plant Protective Actions Radiation Protection RP Personnel<d> 3Cc)
7. Fire Fighting -- Fire Brigade (f)
8. First Aid and Rescue -- Plant Personnel 2<c)

Ooerations Security & Accountability Security Team Personnel (g) (g)

9. Site Access Control and Security Coordinator (TSC) 1 Personnel Accountability Logistics I Administration Logistics Manager (EOF) 1
10. Resource Allocation and Administration TBD 2019 B-39 EP- OC-1000 (Revision X)

PART II: Planning Standards And Criteria Exelon Generation Table OCNGS B-1: Minimum Staffing Requirements (Cont'd) Functional Area Major Tasks Emergency Positions Minimum <al60 Minute Shift Size Augmentation Corporate Spokesperson (JIC) 1

11. Public Information Media Interface Technical Advisor I Spokesperson (JIC) 1 Information Development Media Monitoring and Rumor Control NJ OEM Conducts Rumor Control (JIC)

Facility Operation and JIC Director (JIC) 1 Control Minimum Total Shift Size Minimum Staff TOTAL: 10 23 (a) Response time is based on optimum travel conditions. (b) DELETED (c) May be provided by personnel assigned other functions. Personnel can fulfill multiple functions . (d) Additional personnel may be called in to augment staff depending on the type and extent of the emergency. (e) Staffing of the County EOC Liaison position is not required based on agreements with offsite agencies; however, every effort will be made to dispatch an Exelon Nuclear representative upon request from County EOC Director. (f) Fire Brigade per UFSAR I FHAR, as applicable. The OC Post Shutdown OSSA assumes a Fire Brigade consisting of five (5) persons. Per the assessment, two (2) additional plant personnel are needed to form the fire brigade in conjunction with three (3) Operations staff on shift (who are assigned to the Fire Brigade as a collateral duty) . Upon a successful evaluation and approval of an incipient Fire Brigade in accordance with 10 CFR 50.48(f), the Fire Brigade compliment will be reduced to three (3). This is anticipated to occur sometime following shutdown. Until the 50.48(f) Fire Brigade evaluation is completed, the Fire Brigade will consist of five (5) persons. (g) Function performed by on-shift security personnel. (h) Each Field Survey Team consists of a Lead and Driver. TBD 2019 B-40 EP- OC-1000 (Revision X)}}

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