RS-18-097, Response to Request for Additional Information and Supplemental Information-License Amendment.

Response to Request for Additional Information and Supplemental Information-License Amendment.

ML18208A405
Person / Time
Site:	Dresden, Byron, Braidwood, Clinton, Quad Cities, LaSalle
Issue date:	07/27/2018
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RS-18-097
Download: ML18208A405 (16)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50.54(q)

RS-18-097 July 27, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, STN 50-457. and 72-73 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454, 50-455, and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 and 72-1046 Dresden Nuclear Power Station, Units 1, 2 and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237. 50-249. and 72-37 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374, and 72-70 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254. 50-265, and 72-53

Subject:

Response to Request for Additional Information and Supplemental Information -

License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements

References:

1) Letter from James Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements, dated January 31, 2018(ML18053A159)

U.S. Nuclear Regulatory Commission License Amendment Request Response to Request for Additional Information Changes to Emergency Plan Staffing July 27, 2018 Page2

2) Electronic Mail Request from Blake Purnell (U.S. Nuclear Regulatory Commission) to Richard Gropp, et al. (Exelon Generation Company, LLC) -

Exelon Generation Company, LLC - Request for Additional Information Regarding License Amendment Request to Revise Emergency Plan for Midwest Stations, dated June 28, 2018 (ML18180A077)

By letter dated January 31, 2018 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAA) to support changes to the Emergency Plans for the facilities listed in order to revise certain Emergency Response Organization (ERO) positions consistent with the minimum staff ERO guidance specified in draft Revision 2 of NUAEG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. "

In a U.S. Nuclear Regulatory Commission (NAG) electronic mail message dated June 28, 2018 (Reference 2), the NAC indicated that it had reviewed the information submitted in the Reference 1 letter pertaining to the proposed LAR and requested additional clarifying information to support its continued review. The NRG requested that Exelon respond within 30 days of the date of the electronic mail message.

Accordingly, Attachment 1 provides Exelon's response to the Request for Additional Information (RAI) contained in Reference 2 as well as provides supplemental information in support of the proposed ERO staffing changes. Attachment 2 includes revised pages for the proposed Exelon Standardized Emergency Plan (EP-AA-1000), Table 5-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan," that supports the changes as further discussed in the supplemental information provided.

Exelon has reviewed the information supporting a finding of No Significant Hazards Consideration and the Environmental Consideration provided to the NRG in the Reference 1 submittal. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional 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.

In accordance with 1O CFA 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the State of Illinois of this AAI response by transmitting a copy of this letter and the supporting attachments to the designated State Official.

There are no regulatory commitments contained in this submittal.

U.S. Nuclear Regulatory Commission License Amendment Request Response to Request for Additional Information Changes to Emergency Plan Staffing July 27, 2018 Page 3 If you have any questions concerning this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of July 2018.

Respectfully,

~~~

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1) Response to Request for Additional Information and Supplemental Information -

License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements

2) Revised Pages for Proposed Exelon Standardized Emergency Plan (EP-AA-1000),

Table 5-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan" cc: w/ Attachments Regional Administrator* NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRA - Byron Station NRC Project Manager, NRA - Clinton Power Station NRC Project Manager, NRA - Dresden Nuclear Power Station NRC Project Manager, NRA - LaSalle County Station NRC Project Manager, NRA - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Response to Request for Additional Information and Supplemental Information License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements Braidwood Station, Units 1 and 2 NRC Docket Nos. STN 50-456, STN 50-457, and 72-73 Byron Station, Units 1 and 2 NRC Docket Nos. 50-454, 50-455, and 72-68 Clinton Power Station, Unit 1 NRC Docket No. 50-461 and 72-1046 Dresden Nuclear Power Station, Units 1, 2 and 3 NRC Docket Nos.50-010, 50-237, 50-249, and 72-37 LaSalle County Station, Units 1 and 2 NRC Docket Nos. 50-373, 50-374, and 72-70 Quad Cities Nuclear Power Station, Units 1 and 2 NRC Docket Nos. 50-254, 50-265, and 72-53 Response to Request for Additional Information and Supplemental Information License Amendment Request ERO Staffing Changes Page 1of4 Attachment 1 Response to Request for Additional Information and Supplemental Information License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements By letter dated January 31, 2018 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAR) to support changes to the Emergency Plans for the facilities listed in order to revise certain Emergency Response Organization (ERO) positions consistent with the minimum staff ERO guidance specified in draft Revision 2 of NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

In a U.S. Nuclear Regulatory Commission (NRC) electronic mail message dated June 21, 2018, the NRC indicated that it had reviewed the information submitted in the Reference 1 letter and is seeking additional clarifying information to support its continued review. This electronic mail message contained a draft question regarding information provided in Reference 1 and Exelon was offered an opportunity to ask any clarifying questions related to the draft Request for Additional Information (RAI).

Exelon determined that it was unnecessary to request any further clarification regarding the proposed question.

Subsequently, in an NRC electronic mail message dated June 28, 2018 (Reference 2), the NRC formally issued the RAI and requested that Exelon respond within 30 days of the date of the electronic mail message.

Accordingly, this attachment contains Exelon's response to the Reference 2 RAI as well as provides supplemental information in support of the proposed ERO staffing changes. The specific question included in the Reference 2 electronic mail message is restated below followed by Exelon's response. The supplemental information being provided follows the response to the RAI question.

Response to NRC Question Enclosures 1 - 6 of the application provided separate evaluations of the proposed changes for each site. Section 2.4 of each enclosure states, in part:

Those ERO positions designated as Minimum Staffing in the [site] Emergency Plan are those required to activate their respective ERF [emergency response facility]. Specifically, these are the ERO positions that are the absolute minimum needed to implement the Emergency Plan (i.e., if any position or function is not staffed then the Emergency Plan may not be effectively implemented).

The planning standard in paragraph 50.47(b)(14) of Title 10 of the Code of Federal Regulations states:

"Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected." Section N, "Drill and Exercise Program," of EP-AA-1000, "Exelon Nuclear Standardized Radiological Emergency Plan," Revision 29 (ADAMS Package Accession No. ML18065A168), states that the Drill and Exercise Program will be Response to Request for Additional Information and Supplemental Information License Amendment Request ERO Staffing Changes Page 2 of 4 used to develop, maintain, and evaluate the capabilities of the ERO to respond to emergency conditions and safeguard the health and safety of station personnel and the general public. However, this plan does not address whether these periodic drill or exercises will be used on a continuing basis to specifically evaluate the adequacy of the minimum staffing levels to ensure that they continue to retain the necessary key skills to perform required major functions prior to full augmentation.

Describe how Exelon plans to specifically evaluate the adequacy of the minimum staffing levels to perform required functions until full augmentation, with the proposed ERO staffing changes, to ensure continued effective implementation of the respective emergency plans for each site.

Response to RAl-1 Exelon understands the need to evaluate the adequacy of the ERO to respond to and perform the functions of the Emergency Plan. The Exelon Emergency Plan continues to require that both Minimum Staff and Full-Augmentation staff participate in Off-Hours Report-In Drills. In those drills, both the Minimum Staff and Full-Augmentation ERO are notified to respond to their respective Emergency Response Facilities (ERFs) at the same time using the same notification process. Exelon's management expectations for both Minimum Staff and Full-Augmentation ERO is that response to the notification is to occur directly without delay.

Exelon will institute a "Minimum Staff" drill to be conducted once per drill cycle. The drill will include participation from the Minimum Staff of the Emergency Operations Facility (EOF), the Joint Information Center (JIC), the Technical Support Center (TSC), and the Operations Support Center (OSC) from one of the affected Exelon stations which have implemented the approved ERO staffing change license amendment. This will allow Exelon to periodically demonstrate that the Standardized Emergency Plan is effectively implemented to perform the required Emergency Preparedness functions utilizing only the Minimum Staff defined in the Emergency Plan. Since the ERO Minimum Staff is the same for each station under the Exelon Standardized Emergency Plan, it is not necessary to perform the drill for each station in a drill cycle. The stations would select one station to demonstrate the effectiveness of the minimum staff ERO. Credit for the "Minimum Staff" drill will be given to all of the affected stations. The drill will be evaluated in accordance with Exelon's Drill and Exercise Program; however, the drill may or may not be evaluated for DEP performance in accordance with NEI 99-02, "Regulatory Assessment Performance Indicator Guideline."

Supplemental Information in Support of License Amendment Request On-Shift Chemistry Function Exelon proposes to clarify a statement made in the Reference 1 License Amendment Request (LAR) dated January 31, 2018, regarding the Chemistry Function. Specifically, Section 2.1.2, "On-Shift ERO Revision Summary," within Enclosures 1 through 6 of the Reference 1 LAR, included the following statement:

• The on-shift Chemistry EP Function is revised to be a collateral function.

As a result of discussions during an April 26, 2018, public meeting held via teleconference between Exelon and NRC representatives (Reference 3), it was clarified that as long as the Chemistry Function was not needed for emergency response, it would not be necessary to include the Chemistry Function as part of the ERO staff. As evaluated in the Reference 1 LAR (i.e., Section 3.2.3 within each station's enclosure), it was concluded that the Chemistry Function was not needed to support the emergency Response to Request for Additional Information and Supplemental Information License Amendment Request ERO Staffing Changes Page 3 of 4 response for the affected stations. In light of the discussions from the public meeting on April 26, 2018, Exelon is deleting the referenced statement noted above regarding retaining the Chemistry Function as a collateral function from Enclosures 1 through 6.

On-Shift Repair Team Function On June 12, 2018, the NRC provided a letter (Reference 4) to the industry regarding Alternative Guidance for Licensee Emergency Response Organizations. The letter informs the industry that they have revised Section 11.B, Table B-1 of NUREG-0654, based in part on comments received from the public on the draft Revision 2 of NUREG-0654. The NRC has stated that the revised ERO staffing guidance has been finalized.

In response to the final guidance, Exelon is revising the LAR to align Exelon with the recent changes incorporated in the Alternative Guidance. Specifically, the committed ERO response for the Repair Team and the Repair Team Supervision functions are no longer applicable as an On-Shift function provided the licensee maintains the ability to get Emergency Core Cooling System (ECCS) equipment operational utilizing the on-shift operations staffing. Exelon is aligning the Emergency Plan ERO Staffing tables with the finalized guidance for the on-shift Repair Team and Repair Team Supervision Functions by annotating these functions "Not Applicable." See Attachment 2 for the revised EP-AA-1000, Table 5-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan," pages for the Exelon fleet. Note that for the Clinton Station, one (1) Repair Team Activity position will continue to be filled by a station Instrument Maintenance Department (IMO) person. The IMO person is annotated in this table to support performance of specific EOP activities such as lifting leads and installing jumpers. The IMO person is required on shift until such time that operators are trained and qualified to perform these tasks.

References

1. Letter from James Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements, dated January 31, 2018 (ML18053A159)

2. Electronic Mail Request from Blake Purnell (U.S. Nuclear Regulatory Commission) to Richard Gropp, et al. (Exelon Generation Company, LLC)- Exelon Generation Company, LLC - Request for Additional Information Regarding License Amendment Request to Revise Emergency Plan for Midwest Stations, dated June 28, 2018 (ML18180A077)

3. Meeting Summary from the U.S. Nuclear Regulatory Commission, May 1, 2018 - Summary of April 26, 2018, Meeting with Exelon Generation Company, LLC Regarding Draft Guidance for Emergency Response Organization Staffing (EPID L-2018-LRM-0028) (ML18120A177)

4. Letter from the U.S. Nuclear Regulatory Commission to the Nuclear Energy Institute (NEI) -

Alternative Guidance for Licensee Emergency Response Organizations, dated June 12, 2018.

(ML18022A352)

ATTACHMENT 2 Revised Pages for Proposed Exelon Standardized Emergency Plan (EP-AA-1000), Table 5-1, "Emergency Response Organization (ERO) Staffing and Augmentation Plan"

PART Ill: Appendices Exelon Nuclear Appendix5 Table 5-1: Emergency Response Organization (ERO) Staffing and Augmentation Plan EOF - Alert or TSC I OSC Greater I -~

I Emergency Alert or Greater Alert or Greater Augment w/in 60 min.

Augment Augment Preparedness (EP) On-Shift w/in 60 min. w/in 90 min.

Functions I

I I

Command and Control

• Provide overall ERO command and control , until relieved.

I (1) Shift (1) Station

!

• Approve emergency Not applicable (1) Corporate I action level (EAL) Emergency Emergency Emergency and/ or protective Director Director Director action recommendation I (PAR) classifications, I

until relieved.

• Authorize personnel dose extensions, until relieved.

I I

Communications 3 II

• Communicate EAL I

and PAR (1) ENS classifications to Shift Communicator ( 1) State I Local Not applicable offsite response Communicator 1 (TSC) Communicator organizations I l

(OROs),

including the NRC, until relieved.

I - - -

1 Radiation Protection

!

• Provide qualified I

! radiation protection I coverage for responders (3) Additional (3) Additional accessing potentially (2) Radiation Radiation Radiation unknown radiological Protection Protection Protection Not applicable environments during Personnel Personnel [In Personnel [In emergency addition to addition to

! personnel on-s/Jift] personnel on-shift conditions.

• Provide in-plant surveys. I (OSC) and those responding within

• Control dosimetry and 60 min.] (OSC) radiologically controlled area access.

December 2017 Appendix 5 Page 1 EP-AA-1000 (Revision 30)

PART Ill: Appendices Exelon Nuclear EOF - Alert or TSC I OSC Greater Alert or Greater Alert or Greater Augment Emergency w/in 60 min.

Preparedness On-Shift Augment Augment w/in (EP) Functions w/in 60 min. 90min.

Supervision of Radiation Protection 1

Staff and Site Radiation Protection I

• Evaluate and assess i plant and offsite radiological data in the development of onsite I protective actions and I offsite PARs, until I relieved. I

• Recommend onsite (1) TSC Radiation I (1) Shift Protection Manager 1 Not applicable (1) EOF Radiation protective actions Emergency Protection and offsite PARs to I Director (RPM) (TSC)

Manager (EOF) the applicable I!

decision- maker, I

until relieved.

• Direct all radiation I protection activities, including field monitoring team I

(FMT) direction, until relieved.

• Provide relevant information to applicable I communicators who are communicating offsite PARs to OROs, I I I

until relieved.

Dose Assessments/

Projections (1) Dose (1) Shift Dose I*I Perform dose assessments/projectio Assessor1 Not applicable Not applicable Assessment Coordinator I

ns and provide input to applicable PAR II (EOF)

I decision- maker, until I

relieved.

I

. l December 2017 Appendix 5 Page 2 EP-AA-1000 (Revision ~30)

PART Ill: Appendices Exelon Nuclear EOF - Alert or I TSC I OSC Greater Alert or Greater Alert or Greater Augment I Emergency w/in 60 min.

I Augment Augment w/in I Preparedness On-Shift I w/in 60 min. 90 min.

I (EP) Functions I;

i l Emergency Classifications Emergency Classification ( 1) Operations

• Evaluate plant Advisor1 Manager (TSC) Not applicable Not applicable conditions and I recommend emergency classifications, until I relieved.

I lrsc I IEngineering Staff I

• (1) Electrical/ I Instrumentation and Control (l&C):

Engineering I(11 Corel Provide engineering

• Provide engineering Thermal coverage for the coverage related to Hydraulics ERO related to As needed Not applicable the specific discipline Engineer -

electrical or l&C of the assigned STA1 equipment.

engineer, until i ' . Evaluate * (1) Mechanical:

relieved.

reactor Provide i; conditions. engineering coverage for i the ERO i related to mechanical equipment.

• (1) Core/Thermal Hydraulics:

I Evaluate reactor conditions.

(1) Security Coordinator (TSC)

Security staffing

• Coordinate Security per the site- security- related Not applicable Not applicable specific security activities and I plan. information with I

the Emergency I Coordinator.

' . J December 2017 Appendix 5 Page 3 EP-AA-1000 (Revision 30)

PART Ill: Appendices Exelon Nuclear EOF

• Alert or TSC I OSC Greater Alert or Greater Alert or Greater Augment Emergency w/in 60 min.

Preparedness On-Shift Augment Augment (EP) Functions w/in 60 min. w/in 90 min.

I l Maintenance i Personnel I

Maintenance (OSC) i Personnel I* (1) l&C i (OSC) Technician:

I * (1) Electrical Provide assistance with I Maintenance Technician:

Provide logic manipulation, Repair Team Activities \ Not applicable 4 electrical support for event mitigation and I Not applicable support for ECCS equipment repair.

equipment, and support event of digital l&C mitigation, and if applicable.

equipment Additional l&C repair. staff may be called out if

• (1) Mechanical needed.

Maintenance Technician: Provide mechanical support

• Electrical I for ECCS Maintenance equipment, event Technicians - As mitigation, and needed.

equipment repair.

• Mechanical Maintenance Technicians - As I needed.

I I

December 2017 Appendix 5 Page 4 EP-AA-1000 (Revision 30)

PART Ill: Appendices Exelon Nuclear I

I TSC I OSC EOF - Alert or Greater I - --- ..

I Alert or Greater Alert or Greater Augment Emergency w/in 60 min.

Preparedness On-Shift Augment Augment (EP) Functions w/in 60 min. w/in 90 min.

OSC Supervisors I! I * (1) Electrical I

I Maintenance Supervisor I /Lead:

i Supervise OSC activities related to (1) osc electrical equipment.

Director Supervision of Not applicable

• Supervise OSC Not applicable Repair Team activities as * (1) Mechanical Activities directed by Maintenance I Emergency Supervisor I I Coordinator. Lead:

I Supervise I

I OSC activities related to I mechanical equipment.

• (1) l&C Supervisor I Lead: Supervise OSC activities l related to l&C I

I equipment. May be combined I I with I Electrical Supervisor.

I

• (1) Radiation Protection I Supervisor I Lead

• I I Supervise OSC activities related to radiation protection.

December 2017 Appendix 5 Page 5 EP-AA-1000 (Revision 30)

PART Ill: Appendices Exelon Nuclear EOF - Alert or TSC I OSC Greater Alert or Greater Alert or Greater I Augment Emergency w/in 60 min.

Augment Augment Preparedness (EP) On-Shift w/in 60 min. w/in 90 min.

Functions Onsite FM Individual

• (1)Qualified I

individual to I assess the protected area for radiation and contamination and I

provide input to the TSC RPM.

Responsible for Offsite FMT B I radiation protection I coverage for the * (1) Qualified I' FMT as directed by TSC RPM or individual to assess the area(s)

EOF RPM. outside the protected area for radiation and contamination, Offsite FMT A and for radioactive I * (1) Qualified plume tracking, as Field Monitoring Not applicable I the individual to assess area(s) outside directed by, and under the control Not applicable Teams (FMTs) I the protected area of, the EOF DAG for radiation and or RPM .

contamination, and Responsible for for radioactive the radiation plume tracking, as protection directed by, and II coverage of the under the control of, I FMT as directed the EOF DAC or by EOF RPM.

RPM. Responsible (1) Driver to for the radiation I* provide protection coverage transportation.

of the FMT as directed by EOF RPM.

• (1) Driver to provide transportation.

December 2017 Appendix 5 Page 6 EP-AA-1000 (Revision 30)

PART Ill: Appendices Exelon Nuclear I

TSC I OSC EOF/JIC - Alert 01 Greater2 Augment Alert or Greater Alert or Greater w/in 90 min.

Emergency Preparedness On-Shift Augment Augment (EP) Functions w/in 60 min. w/in 90 min.

I I Media Information

• Manage and Not applicable Not applicable Not applicable Corporate coordinate media Spokesperson information related to the event.

• JIC Director I

• Public Information Director

• Other personnel may I be assigned I this function if I i no collateral I II duties are assigned to an i I I

I individual that are beyond the

! capability of I that individual to perform at any given time _

I I

I I I I I I I I I December 2017 Appendix 5 Page 7 EP-AA-1000 (Revision 30)

PART Ill: Appendices Exelon Nuclear I

-i------- TSC I osc EOF/JIC *Alert or Greater 2 I

Augment w/in 90 I

Emergency Alert or Greater Alert or Greater I Preparedness (EP)

On-Shift I Functions I Augment w/in 60 Augment w/in 90 I min. min.

I I

Ii --

I I

IJIC/EOF Information I I

Not applicable Not applicable Not applicable * (1) EOF/JIC I Technology (IT) Computer i Specialist (@

I 90 min from I Alert or higher)

I l I j

I I i i II I

I I I I

I I!

t 1

I I I Ij I

l II j

1. Other personnel may be assigned this function if no collateral duties are assigned to an individual that are beyond the capability of that individual to perform at any given time.

2. Exelon's Communication Department will perform necessary JIC functions at the Unusual Event declaration and initially upon a higher initial EAL declaration. The JIC facility will be activated within 90 minutes of an Alert declaration; however some functions may continue 1

to be performed by the Exelon Communications Department. Some JIC functions such as Public Information Director. New Writer, Media Monitor, Rumor Control may be performed remotely by Exelon's Communication Department.

3. Additional Communications will be staffed at the EOF or TSC if needed.

4. At Clinton, one (1) Repair Team Activity position is filled by a station IMO person. The IMO person is annotated in this table to support performance of specific EOP activities such as lifting leads and installing jumpers. The IMO person is required on shift until such time that operators are trained and qualified to perform these tasks.

December 2017 Appendix 5 Page 8 EP-AA-1000 (Revision 30)