View source for NOC-AE-13003004, Revised Phase 1 Staffing Assessment Submitted in Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights

{{Adams
| number = ML13182A021
| issue date = 06/03/2013
| title = Revised Phase 1 Staffing Assessment Submitted in Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights
| author name = Powell G
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000498, 05000499
| license number = 
| contact person = 
| case reference number = NOC-AE-13003004, STI 3369446
| document type = Letter type:NOC, Report, Miscellaneous
| page count = 45
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Nuclear Operating Company South Texas Proect Electric Generall$ Station PO. Box 289 Wadsworth. Texas 77483                                  ***  -
June 3, 2013 NOC-AE-13003004 10 CFR 50.54(f)
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Revised Phase 1 Staffing Assessment Submitted in Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights

==Reference:==
Letter from D. W. Rencurrel to NRC, Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident - Phase 1 Staffing Assessment, dated April 25, 2013, NOC-AE-13002989 (ML13123A028)
On April 25, 2013, STP Nuclear Operating Company (STPNOC) submitted STPNOC's Phase 1 Staffing Assessment Report as Enclosure 1 to the referenced letter. After the report was submitted it was determined the staffing numbers reported in Section 5.1.2, Table 5-1, and Table 5-2 of the report were incorrect. A Condition Report 13-5438 was written to address the discrepancies. The purpose of this letter is to correct STPNOC's Phase 1 Staffing Assessment Report and provide clarification. Changes to the report in the Enclosure are shown by a change bar in the right margin. The changes identified do not affect any of the conclusions of the assessment. No additional staff is needed at this time.
There are no commitments in this letter.
If there are any questions regarding this letter, please contact Robyn Savage at (361) 972-7438.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:                ZJACe        . Moi5 G. T. Powell Site Vice President

==Enclosure:==
STP Phase 1 Extended Loss of All AC Power (ELAP) ERO Staffing rds Analysis Report, Revision 1 A c STI 33694464

NOC-AE-13003004 Page 2 of 2 cc:
(paper copy)                                   (electronic copy)
Regional Administrator, Region IV              A. H. Gutterman, Esquire U. S. Nuclear Regulatory Commission            Morgan, Lewis & Bockius LLP 1600 East Lamar Boulevard Arlington, TX 76011-4511                       Balwant K. Singal U. S. Nuclear Regulatory Commission Balwant K. Singal                              John Ragan Senior Project Manager                         Chris O'Hara U.S. Nuclear Regulatory Commission             Jim von Suskil One White Flint North (MS 8 B1)                NRG South Texas LP 11555 Rockville Pike Rockville, MD 20852 Kevin Polio NRC Resident Inspector                         Richard Pena U. S. Nuclear Regulatory Commission            City Public Service P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady                                   Peter Nemeth City of Austin                                 Crain Caton & James, P.C.
Electric Utility Department 721 Barton Springs Road                        C. Mele Austin, TX 78704                               City of Austin Eric Leeds                                     Richard A. Ratliff Director, Office of Nuclear Reactor Regulation Texas Department of State Health U.S. Nuclear Regulatory Commission             Services One White Flint North (MS 13 H 16) 11555 Rockville Pike                           Robert Free Rockville, MD 20852                            Texas Department of State Health Services RMS

Enclosure NOC-AE-1 3003004 Enclosure South Texas Project (STP)
Phase 1 Extended Loss of All AC Power (ELAP)
ERO Staffing Analysis Report, Revision 1

Enclosure NOC-AE-1 3003004 Clean. Safe. Reliable.
South Texas Project Phase 1 Extended Loss of All AC Power (ELAP) ERO Staffing Analysis Report Revision 1

Enclosure NOC-AE-13003004 Page 2 of 42 TABLE OF CONTENTS 1      INTRODUCTION                                                                                          5 2      PHASE I STAFFING ANALYSIS 

==SUMMARY==
6 2.1      Task Analysis Results                                                                         6 2.1.1   Non-Validated Task Assessment                                                               6 2.1.2   Potential Task Overlap Assessment                                                           6 2.2     Time Motion Study (TMS) Results                                                               6 2.3     Augmented and Expanded ERO Assessment Results                                                 7 3      ON-SHIFT STAFFING COMPLEMENT                                                                          8 3.1     Shift Staffing Basis                                                                          8 3.2     Initial Shift Staffing Locations                                                              9 4      EXTENDED LOSS OF ALL AC POWER (ELAP)                                                                 10 4.1     Scope                                                                                        10 4.2     Assumptions                                                                                  10 4.3      Event Description and Initial Conditions                                                     11 4.4     Procedures Used in the Event                                                                 12 4.4.1   List of Procedures Applicable to a Loss of All AC Power and Emergency Plan Implementation                                                                             12 4.4.2   Procedure Changes Due to IER Responses Applicable to Phase 1                               12 5      AUGMENTED AND EXPANDED ERO RESPONSE ANALYSIS                                                         14 5.1     ERO Notification and Response during an ELAP                                                 14 5.1.1   General ERO Response                                                                       16 5.1.2   Position Specific ERO Response                                                             19 5.2     Expanded Response Functions for Phase 1 Staffing Assessment                                  21 6      LIST OF IMPROVEMENT ACTIONS IDENTIFIED DURING THE PHASE I ASSESSMENT                                                                                           24 7      LIST OF REFERENCES                                                                                   25 : NEI 10-05 Table 5 Controlling Method Correlation ......................................... 27 : NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables ................. 29 : NEI 10-05 Appendix D & E On-Shift Staffing Analysis Results Tables ............ 35 Page 2

Enclosure NOC-AE-1 3003004 Page 3 of 42 GLOSSARY Alternate Response Alternate TSC/OSC, located in the EOF in Bay City, Texas. Used in the event of a Facility           declared emergency when access to the site is restricted.
ANI                American Nuclear Insurers Personnel mobilized to assist the on-shift staff in responding to more serious events and accidents. Augmented ERO personnel are capable of performing a Augmented ERO      wide range of functions necessary for responding to a radiological emergency, up to and including a severe accident involving fuel damage. This group of people is normally offsite and split into teams.
BYP                Bypass CAP                Corrective Action Program CR                 Control Room CVCS               Chemical Volume Control System DC                 Direct current DP                 Differential pressure EAB                Electrical Auxiliary Building EAL                Emergency Action Level ECL                Emergency Classification Level EDG                Emergency Diesel Generator EDMG               Extensive Damage Mitigation Guidelines ELAP               Extended Loss of all AC Power Emergency          Document developed by Matagorda County that supports the STP Emergency Management Plan    Plan and the State of Texas Emergency Management Plan Emergency Notification System - used to provide operational and health physics ENS                information to the Nuclear Regulatory Commission Operations Center during the early phase of an emergency.
EOC                Emergency Operations Center EOF                Emergency Operations Facility ERDS               Emergency Response Data System ERF                Emergency Response Facility (e.g. TSC, OSC, EOF)
ERO                Emergency Response Organization - consists of those site personnel trained and ERO                qualified to respond to any accident within the scope of the plant design basis ESF                Engineered Safety Feature Additional personnel who expand the capability of the augmented ERO to facilitate timely and effective performance of critical emergency response Expanded ERO       functions - a typical augmented ERO for a multi-unit site would be challenged to effectively respond to a beyond design basis external event that resulted in an extended loss of AC power affecting more than one unit.
FBT                Fire Brigade Team FLEX               Diverse and Flexible Coping Strategies I&C                Instrumentation and Control IER                INPO Event Report Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami (including Supplement 1)
IER L1 11-2     Fukushima Daiichi Nuclear Station Spent Fuel Pool Loss of Cooling and Makeup Page 3

Enclosure NOC-AE-1 3003004 Page 4 of 42 Near-Term Response toActions   to Address the Fukushima           Event of an Extended Loss of All AC Power in the Effects Daiichi Initial Phase Coping Implementation of strategies that generally rely upon installed plant equipment Actions INPO                 Institute of Nuclear Power Operations JPM                  Job Performance Measure (a training activity)
MAB                  Mechanical Auxiliary Building Minimum On-Shift     Those personnel required to be on site 24/7 per the site Emergency Plan.
Staffing MOV                  Motor Operated Valve NEI                  Nuclear Energy Institute "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities", June 2011 NEI 12-01        "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", May 2012 NRC                  Nuclear Regulatory Commission NTTF                 The NRC "Near-Term Task Force" Activated upon declaration of an Unusual Event. Should the event escalate to an On-shift ERO         Alert, the On-shift Organization will be augmented by the duty Emergency Response Organization.
ONP                  Off-Normal Procedure ORO                  Offsite Response Organization OSC                  Operations Support Center PAR                  Protective Action Recommendation PORV                 Power-Operated Relief Valve PWR                  Power RCP                 Reactor Coolant Pump RCS                 Reactor Coolant System RP or RPT           Radiation Protection or Radiation Protection Technician SAM or SAMG          Severe Accident Mitigation or Severe Accident Mitigation Guidelines SFP                  Spent Fuel Pool SG                   Steam Generator STP                 South Texas Project STPNOC              STP Nuclear Operating Company TGB                  Turbine Generator Building TMS                  Time Motion Study Implementation of strategies that involve the use of on-site portable equipment Transition Phase     and consumables to extend the coping period, and prevent a loss of functions Coping Actions      needed for core cooling, containment, and spent fuel pool cooling. Setup for these strategies should be performed prior to the end of the Initial Phase.
TSC                  Technical Support Center Note: Acronyms with adjacent definitions may not be included in this glossary.
Page 4

Enclosure NOC-AE-1 3003004 Page 5 of 42 INTRODUCTION Information requests related to Emergency Preparedness are contained in Enclosure 5 of the &sect;50.54(f) Letter (Reference 7.1).
Within this enclosure are two Requested Actions; one involves performance of a staffing assessment and the other a communications assessment. The actions for the staffing assessment are summarized as follows:
Assess current staffing levels and determine the appropriatestaff to fill all necessary positions for responding to a multi-unit event during a beyond design basis external event, and determine if any enhancements are appropriategiven the considerations of Fukushima Near-Term Task Force (NTTF) Recommendation 9.3 (Reference 7.2).
Reference 7.3 endorsed the 2-phase approach in NEI 12-01 (Reference 7.4) to the schedule presented in the &sect;50.54(f) Letter (Reference 7.1).
Reference 7.5 presented an alternate schedule to Reference 7.1 and stated that an onsite and augmented staffing assessment considering all requested functions except those related to Near Term Task Force (NTTF) Recommendation 4.2 (Phase 1 staffing analysis) would be provided. This report provides the Phase 1 staffing analysis for South Texas Project (STP) Units 1 and 2.
The criteria presented in the NEI 12-01 guidance are intended to assist with the identification of additional organizational capabilities that will facilitate simultaneous performance of accident mitigation and repair actions at all on-site units following a beyond design basis external event. In lieu of a standard template, the guidance provides recommended criteria for use in performing an assessment to identify the staff that should be available to respond to a beyond design basis external event affecting multiple units at a site.
Phase 1 Staffing Assessment For multi-unit plants, the Phase 1 staffing assessment will be performed by March 29, 2013, and provided to the NRC by April 30, 2013.
The staffing assessment, as requested by the 50.54(f) letter, will be performed using NEI 12-01 and material from NEI 10-05.
The objective of the staffing assessment is to evaluate the on-site and augmented staff needed to respond to a large-scale external event meeting the conditions described in the NEI 12-01 assumptions, NOT including staffing needed to implement actions that address NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049). That is; the staffing assessment will consider all requested functions except those related to Fukushima NTTF Recommendation 4.2 (FLEX) - an assessment considering these functions will be performed in Phase 2.
The results of the assessment have been verified and validated to ensure adequacy and accuracy. Each corrective action and enhancement identified during this assessment will be tracked in the site Corrective Action Program (CAP) with an estimated completion date. In accordance with the requirements of 10 CFR 50, Appendix B, any Condition Adverse to Quality identified during an assessment must be entered into a corrective action program.
Page 5

Enclosure NOC-AE-1 3003004 Page 6 of 42 2     PHASE 1 STAFFING ANALYSIS 

==SUMMARY==

The on-shift staffing analysis determined that a sufficient number of staff are present on site to perform all initial phase coping actions.
At the time of this Phase 1 assessment, two Fukushima-related IER response actions have been implemented that involve tasks to be performed by the on-shift staff. One of these tasks was applicable to the ELAP scenario and was assessed in the Phase 1 task analysis. None of the implemented responses to the Fukushima-related INPO IERs have an impact on the augmented or expanded ERO staffing. Refer to Section 4.4 for a description of the IER related procedure tasks.
Sufficient augmented ERO personnel resources exist to fill most expanded ERO functions. Utilizing Table 3.1 from NEI 12-01 to evaluate expanded staffing requirements, STP has identified staffing gaps for performing engineering assessments and for evaluating and implementing SAMGs. STP will ensure that the required numbers of qualified individuals are added to the expanded ERO to fill these roles.
Provisions and procedures for the establishment of an expanded ERO have not been developed at STP.
Using existing procedures and strategies, the event response did not result in entry conditions into STP Severe Accident Management Guidelines (SAMGs) procedure prior to the ERO augmentation (6 hours) and for a period greater than 24 hours.
The ability of the on-site staff to implement FLEX strategies will be evaluated as part of the Phase 2 staffing assessment since the FLEX equipment was not in place at the time of this assessment.
A list of improvement actions identified during the Phase 1 staffing assessment is provided in Section 6.
2.1   Task Analysis Results 2.1.1 Non-Validated Task Assessment The analysis did not identify any non-validated tasks - no time motion studies were required. Refer to Attachment 2, NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables, for additional documentation of the on-shift staffing task analysis results.
2.1.2 Potential Task Overlap Assessment No task overlaps were identified in the assessment. Refer to Attachment 2, NEI 10-05 Appendix D & E On-Shift Staffing Analysis Results Tables for additional information 2.2   Time Motion Study (TMS) Results No time motion studies were required as documented in Attachment 2, NEI 10-05 Appendix B On-Shift Staffing Analysis Results Tables.
Page 6

Enclosure NOC-AE-1 3003004 Page 7 of 42 2.3 Augmented and Expanded ERO Assessment Results Utilizing Table 3.1 from NEI 12-01 to evaluate expanded ERO staffing requirements, STP has identified staffing gaps in the current augmented ERO for performing engineering assessments and for evaluating and implementing SAMGs. Specifically, one additional ERO member must be qualified for the following positions:
         -   TSC Technical Manager
         -    Engineering Supervisor
         -    Engineer - Nuclear
         -    Engineer - Mechanical
         -    Engineer - Electrical
         -    Engineer - I&C
         -    TSC Operations Communicator STP will ensure that the required number of qualified individuals are added to the expanded ERO to fill these roles.
Currently, there are two Mechanical Engineers, three Nuclear Engineers, and one TSC Operations Communicator listed as members of STP's "Gold Team" - a fourth ERO team that maintains the required ERO qualifications but are not part of the regular duty rotation. The additional expanded ERO members will be added to this team.
Refer to Table 5-2 for additional documentation of the expanded ERO functional staffing resources and the identified gaps.
Action #1: Ensure that the required number of qualified individuals are added to fill all necessary roles of the expanded ERO.
Page 7

Enclosure NOC-AE-1 3003004 Page 8 of 42 3   ON-SHIFT STAFFING COMPLEMENT 3.1   Shift Staffing Basis Only personnel required to be on-shift are credited in the staffing analysis. The on-shift personnel complement includes the minimum required number and composition as described in the STP Emergency Plan.
Functional Area                    Major Tasks                                            Emergency Positions 1.PatOertosadUnit Plant Operations      and                                                                      Manager Shift Supervisor                                                                        22 1
Control Room Staff                                     Reat          Operator                                                                   4 Assessment of Operational Aspects                                                                  Plant Operator                                                                           4
: 2. Emergency Direction             Command and Control                                    Shift Manager                                                                         1(a) and Control
: 3. Notification &                   Local! State                                          Pl_ant Operator1 Communication                  Federal (ENS)                                         Reactor Operator                                                                         1 Dose Assessment                                       Senior HP                                                                                1
: 4. Radiological                    .In-plantSurve.ys ............................ . RP T
                                                                                        ..-..                ~ c~i.n.can Techni              .....................................................        1 ses..
As                 .. ... ..
t...
                                                        ...u..
                                                               .S... .............           ......
                                                                                                ....T e... c!.n.c
                                                                                                              ....        a......
Chemistry                                             Chemistry Technician                                                                     1 n5Pl Sy t m............. Technical
                                               .......... Suport
                                                                 . .P.........            .. . Shift
                                                                           ....       . .....               Technical
                                                                                                             ....                Advisor
                                                                                                                                    ........ r..............................
                                                                                                                                                                               ........ 1(a)-
: 5. Plant System                                                                           Rad Waste Operator                                                                    1 Engineering, Repair,           Repair and Corrective                                 Mechanical Maintenance                                                                1 (a) and Corrective Actions         Actions                                                Electrical Maintenance                                                                   1 I&C Maintenance                                                                         1
: 6. In-Plant PAs                   Radiation Protection                                   RP Tech / Chem Tech                                                                  2(a)
: 7. Fire Fighting(D)               --                                                     Fire Brigade                                                                            5
: 8. 1-TAid and Rescue 0ps            --                                                    Plant Protection Personnel                                                            2{a
: 9. Site Access Control              Security & Accountability                             Plant Protection Personnel                                                             (C) and Accountability            _____________________________
              *"           .A**                                                                                                                          0T
::L:                            25 (a) These positions may be covered by on-shift personnel assigned other functions.
(b) Fire Brigade per Technical Specifications; composed of five plant operators not assigned other duties.
(c) Per the STP Security Plan.
Page 8

Enclosure NOC-AE-13003004 Page 9 of 42 3.2       Initial Shift Staffing Locations On-shift personnel can report to their assigned response locations within timeframes sufficient to allow for performance of assigned actions. The following are the typical locations of the on shift personnel:
* U1 S hift Manager ...................................................................................        C ontrol Room
* Ul Unit S upervisor ................................................................................         C ontrol Room
* Ul Reactor Operator, Primary RO (Ul Pri RO) .....................................                            Control Room
* U1 Reactor Operator, Balance of Plant (Ul BOP RO) ...........................                                Control Room
* U1 Plant Operator, TGB Watch (PO #1) ................. Unit 1 Turbine Generator Building
* Ul Plant Operator, MAB Watch (PO #2) .....................                             Unit 1 Mechanical Aux Building
* U2 S hift Manager ...................................................................................        C ontrol Room
* U2 Unit S upervisor ................................................................................         Control R oom
* U2 Reactor Operator, Primary RO (U2 Pri RO) .....................................                            Control Room
* U2 Reactor Operator, Balance of Plant (U2 BOP RO) ...........................                                Control Room
* U2 Plant Operator, TGB Watch (PO #3) ................. Unit 2 Turbine Generator Building
* U2 Plant Operator, MAB Watch (PO #4).....................                              Unit 2 Mechanical Aux Building
* ENS Com m unicator (RO #5) .................................................................                 Control Room
* State/County Communicator (PO #5) .................................                              Ul Electrical Aux Building
* Senior HP ........................................................        41' Elevation Mechanical Aux Building
* RP Technician #1 ............................................             41' Elevation Mechanical Aux Building
* RP Technician #2 ............................................             41' Elevation Mechanical Aux Building
* Chem istry Technician ....................................................................            29' Cold Chem Lab
* Electrical Maintenance ..................................................................             MO ST Team Trailer
* I&C Technician .............................................................................          MO ST Team Trailer Fire Brigade Leader, (P0                        .................................. U1 Turbine Generator Building
* Fire Brigade Member #1, (PO #7) (d)...................... U2 Turbine Generator Building SFire Brigade Member #2, (P0 #8) (U2                   ()          ............................. Electrical Aux Building
* Fire Brigade Member #3, (PO #9) ................................... Electrical Aux Building
* Fire Brigade Member #4, (PO #10)                         ....................................... Electrical Aux Building (d) State and County Communicator position and Fire Brigade positions are filled by the 6 on-shift Plant Operators not assigned safe shutdown duties - EAB Watch, Condensate Polishing (CP) Watch, and Yard Watch. Assignments are documented per site procedure OPOP01-ZQ-0022, "Plant Operations Shift Routines".
(e)EAB Watch Plant Operators Page 9

Enclosure NOC-AE-1 3003004 Page 10 of 42 4   EXTENDED LOSS OF ALL AC POWER (ELAP) 4.1 Scope
: 1. The staffing assessment determined the ability of the on-shift staff to implement Initial Phase coping actions. No Transition Phase actions were evaluated because none were established at the time of this assessment - the use of portable equipment and consumables will be developed as part of the FLEX strategies and will not be evaluated until the Phase 2 Staffing Assessment.
: 2. The applicable actions from the Station Blackout coping strategies in place at the time of the assessment were evaluated.
: 3. Those IER improvement actions already implemented at the time of the assessment (e.g., incorporated into plant procedures) were evaluated and discussed in Section 4.4.
: 4. The staffing assessment evaluated the ability of the on-shift staff to perform required emergency plan response functions prior to the arrival of the augmented ERO.
4.2 Assumptions
: 1. The ELAP event occurs during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).
: 2. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.
: 3. All equipment credited in current coping strategies remains available for use (e.g., a non-seismic water tank, diesel fire water pump).
: 4. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of an RP Technician.
: 5. The on-site security organization is able to satisfactorily perform all tasks related to Site and Protected Area Access Controls, under all event or accident conditions.
Performance of this function is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.
: 6. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.
: 7. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.
: 8. The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all Page 10

Enclosure NOC-AE-13003004 Page 11 of 42 positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.
: 9. For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase coping actions.
: 10. NEI 10-05 assumes that augmented ERO members will arrive on-site within their normal response times (60-minute or 75-minute response). NEI 12-01 assumes that augmented ERO members will not begin to arrive for 6 hours due to a LSEE.
The event impedes site access as follows:
A. Post event time: 6 hours - No site access. Consistent with NEI 12-01, which is based on a nominal 4 hours + 50%, this duration reflects the time necessary to clear roadway obstructions, use different travel routes and mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.
B. Post event time: 6 to 24 hours - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g.,
private resource providers or public sector support).
C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.
For purposes of this analysis, 6 hours will be used as the time period for the conduct of the on-shift ERO response actions. See assumption 1 0.A above.
: 11. Offsite facilities and staging areas are available.
4.3 Event Description and Initial Conditions A large-scale external event occurs that results in:
* all on-site units affected
* extended loss of all AC power
* impeded access to the units Initially, both reactors are operating at full power. Upon the loss of AC power, both reactors are successfully shut down.
This event results in a Site Area Emergency (SAE) Emergency Classification Level (ECL) based on Emergency Action Level (EAL) SS1.1 which escalates to a General Emergency ECL based on EAL SG1.1 once it has been determined that power cannot be restored before the coping time has been exceeded.
Page 11

Enclosure NOC-AE-13003004 Page 12 of 42 Initial Conditions: Both STP Unit 1 and Unit 2 are initially at 100% power at equilibrium, middle of core life.
Abnormal Conditions: None Scenario Events: An offsite electrical transient occurs resulting in a loss of all offsite power.
None of the Emergency Diesel Generators (EDGs) can be synchronized to any Unit 1 or Unit 2 AC bus, resulting in a dual-unit loss of all AC power.
One EDG on each unit is assumed to start, but cannot be paralleled with any electrical bus.
Adequate core cooling and heat sink is maintained throughout the 6 hour duration. No core damage occurs and no entry into SAMG is required Notes: This scenario constitutes a dual unit event.
The scenario is designed such that restoration of any AC power source is not possible before the arrival of ERO personnel (360 minutes).
4.4   Procedures Used in the Event 4.4.1 List of Procedures Applicable to a Loss of All AC Power and Emergency Plan Implementation
* OPOP05-EO-EOOO, Reactor Trip or Safety Injection
* OPOP05-EO-ECOO, Loss of All AC Power
* 0ERP01 -ZV-IN01, Emergency Classification
* OERP01-ZV-IN02, Notifications to Offsite Agencies
    " QERP01-ZV-IN03, Emergency Response Organization Notification
* QERP01-ZV-IN04, Assembly and Accountability
    " OERP01-ZV-IN05, Site Evacuation
* OERP01-ZV-SH01, Shift Manager
* QERP01-ZV-SH02, Acting Radiological Manager 4.4.2 Procedure Changes Due to IER Responses Applicable to Phase I Following the accident at Fukushima Daiichi, the Institute of Nuclear Power Operations (INPO) issued three IERs requiring the assessment of actions intended to improve the capabilities for responding to a beyond design basis event and an extended loss of all AC power, including events that impact the cooling of spent fuel.
: 1. Response to IER-L1-11-1 did not implement any new procedure actions to be performed by the on-shift or augmenting ERO.
: 2. Response to IER-Ll-11-2 included two items that affect actions to be performed by the on-shift ERO or augmenting ERO.
Page 12

Enclosure NOC-AE-13003004 Page 13 of 42
* STPNOC revised the Off-Normal Procedure (ONP) for a seismic event to add specific steps to check SFP temperatures and initiate a recovery log to ensure SFP level and temperature are maintained within specified limits. This procedure is not applicable to the ELAP and was therefore not assessed in the Phase 1 analysis.
* The ONPs for control room evacuation, natural or destructive phenomena (severe weather & flood) and loss of power to one or more 13.8 KV standby busses did not contain specific steps to check SFP level and temperature.
STPNOC revised each of the ONPs to include actions and contingencies to monitor SFP level and temperature. These actions were assessed in the Phase 1 analysis.
: 3. Response to lER-L1-1 1-4 included two items that affect actions to be performed by the on-shift ERO or augmenting ERO.
* Additional load shedding off DC busses
   "   Establish ventilation in the EAB Neither of these two strategies were implemented at the time of this analysis and were not assessed.
Page 13

Enclosure NOC-AE-1 3003004 Page 14 of 42 5       AUGMENTED AND EXPANDED ERO RESPONSE ANALYSIS                                           Page 14 of 42 Enclosure NOC-AE-13003004 5.1      ERO Notification and Response during an ELAP Staffing resources for assessment of the expanded ERO are provided by the depth of personnel filling the existing augmenting ERO positions. Table 5-1 below documents the augmenting ERO staffing requirements from Emergency Plan Table C-1, Figure C-2, C-3, C-4 and C-5. The numbers reported in Table 5-1 assume the site ERO is fully staffed.
Table 5-1 Augmented ERO Response Resources
                                                                                      #per            #
        .Assigned%     Major Function/Task :::ERO Title.Team                                  .. Qualified TSC Manager                              1             3 Assistant TSC Manager                    1             33 Emergency Direction and Control EOF         i rt or Ess Director                           1 1             3 Deputy EOF Director                      1              3 TSC Communicator                          1             3 TSC Ops Communicator                      1             3 OSC Communicator                          1             3 EOF Liaison                               1             3 Notification / Communication          Texas Liaison                             1             3 EOF Offsite Agency Communicator           1             3 EOF Licensing Director                    1             3 EOF Assistant Licensing Director          1             3 EOF Comm System Supervisor                1             3 EOF Fed Response Agency Liaison          1             3 Rad Assessment (Offsite Dose           EOF EEAs Dose Assessment oeAssmn    Specialist       1             3 Assessment)EOF                   Asst Dose Assessment13 Assessment)                           Specialist Rad Assessment (Offsite               Offsite Field Team                       2              6 Surveys)                              Offsite Field Team Driver                2              6 EOF Offsite Field Team Supervisor        1             3 Rad Assessment (In-Plant &             RP Technician                           3           39(&#xfd; O n s ite Su rv e y s )                 R P T ch i ia_                                  __   3__
In-Plant   Protective Actions In-PlantProtectiveActions              RPTcnia4                                             9)
_OSC      Radiological Coordinator           1             3 Rad Assessment (Sample                OSC Chemistry Analysis Supv               1             3 Analyses)                             Chemistry Technician                      1           13 TSC Radiological Manager                  1             3 Rad Assessment (RP                    TSC Assist Radiological Manager           1             3 Supervisory)                          TSC Chem/Radchem Manager                  1             3 EOF Radiological Director                1             3 Rad Assessment (ERF Surveys)           EOF Radiological Staff                   1             3 Plant Operations and Assmt of         OSC Plant Ops Discipline Lead             1             3 (0There are seven qualified RP Technicians currently credited as members of the Augmented ERO filling the positions of TSC Assistant Radiological Manager, EOF Radiological Staff, and Offsite Field Teams that are included in the total number of qualified RP Technicians. These seven individuals would not be available to augment the RP Technician staffing if filling their current augmented ERO position.
Page 14

Enclosure NOC-AE-1 3003004 Page 15 of 42
                                                                                       #per As~sioned"Maior FunctionhTask :I ERO Title                                   Team,    Qualified Operational Aspects TSC Assistant Operations Manager          1           3 TSC Nuclear Engineer                      1           3 TSC Mechanical Engineer                   1           3 TSC Electrical Engineer                   1           3 TSC Technical Manager                     1           3 Plant System Engineering            TSC Engineering Supervisor                1           3 TSC I&C Engineer                          1           3 EOF Technical Director                   1           3 EOF Technical Staff                      1           3 EOF System Status Evaluator              1           3 EOF Engineering Assistant                1           3 OSC Mechanical Maintenance Lead          1           3 Mechanic                                 1         46(g)
OSC Electrical Maintenance Lead          1           3 Electrician                              2         44 (n)
I&C Technician                           1         43FI OSC Coordinator                          1           3 Repair and Corrective Actions        Assistant OSC Coordinator                1           3 OSC Mechanical Maint Planner             1           3 OSC Electrical Maintenance Planner       1           3 OSC I&C Maintenance Planner              1           3 OSC I&C Maintenance Lead                 1           3 TSC Maintenance Manager                  1           3 TSC Maintenance Communicator             1           3 TSC Security Manager aae                       1           3 Access  Control and Personnel        TCScrt Accountability                       TSC Security Supervisor                  1           3 OSC Security Coordinator                 1           3 Resource Allocation and              TSC Rad Status Board Keeper              1           3 Administration                       TSC Administrative Manager               1           3 TSC Administrative Staff                 1           3 OSC Resource Coordinator                 1           3 OSC Status Board Keeper                  1           3 EOF Director Admin Assistant             1           3 EOF Status Board Keeper                  2           6 EOF Rad Status Board Keeper              1           3 EOF Support Organization Director         1          3 EOF Asst Support Org Director             1          3 EOF Procurement/Resources Supv            1          3 (g) Includes Mechanics from both Mechanical Maintenance and the Integrated Maintenance Team -
Apprentices and Supervisors are not included in this number (h) Includes Electricians from both Electrical Maintenance and the Integrated Maintenance Team -
Apprentices and Supervisors are not included in this number
(')Includes I&C Technicians from both the I&C Maintenance organization and the Integrated Maintenance Team - Apprentices and Supervisors are not included in this number Page 15

Enclosure NOC-AE-1 3003004 Page 16 of 42
-       I _____________________________________________________________________
                                                                                    #, per Assigned Maio r Funiction/Task ERO Title                                            Qualified EOF Records Supervisor                     1           3 EOF Support Orientation Coordinator        1           3 EOF Materials Engineer                     1           3 EOF Information Systems Analyst            1           3 EOF Employee Support                       1           3 EOF Purchaser                              1           3 EOF Administrative Staff                   2           6 JIC Administrative Manager                 1           3 JIC Administrative Staff                   6          18 Company Spokesperson                       1           3 EOF Site Public Affairs Coordinator        1           3 EOF Site Public affairs Specialist         1           3 JIC Director                               1           3 JIC Senior Staff Writer                    1           3 JIC Public Inquiry Manager                 1           3 JIC Media Relations Manager                1           3 Public Information                JIC Media Relations ANI Liaison            1           3 JIC Internet/Graphics Technician           1           3 JIC Audio-Visual Specialist                1           3 JIC Communications Technician              1           3 JIC Technical Support Liaison              1           3 JIC Media Rel Tech Spokesperson            1           3 JIC Media Relations Staff                  3           9 JIC Public Inquiry Staff                   7          21 5.1.1   General ERO Response
: 1. ImDlementina Strateav for the Expanded ERO When the ERO notification system is operable, all qualified ERO members on a team are contacted and expected to report if fit for duty. In the absence of the call out system, all ERO members are trained to report to the EOF following a large scale external event.
Action #2: Develop specific guidance for how and when to establish the expanded ERO from the pool of augmented ERO.
: 2. Response Timeliness for the Expanded ERO On 07/12/12 a Training Bulletin was issued to "communicate the expectation of the augmenting ERO to automatically respond to a designated staging area." The bulletin was sent to the minimum and full staffing ERO members (ERO roster personnel), but was not communicated to off-shift Operations, Maintenance, Radiation Protection, or Security personnel. Procedure OPGP05-ZV-0003, dated 12/27/12, Addendum 1, was revised to provide the following:
If local telephone landlines and cellularsystems are not available to call-out the ERO during a large scale external event (e.g., hurricane,major flood), ERO members must go to the EOF when made aware (e.g., by direct observation, media reports, word of mouth), of the event. Once there, decisions will be made on how and when they will be transportedto the plant site.
Page 16

Enclosure NOC-AE-1 3003004 Page 17 of 42 Action #3: Develop and communicate the process to expand the automatic response of ERO personnel who report to the EOF in the event of a loss of communications due to a large scale event to include appropriate activation of off-shift Operations, Maintenance, Security, RP personnel, and expanded ERO.
Action #4 The changes in Action #3 will be included in annual site training.
: 3. Work Location for the Expanded ERO As described above, during a wide spread loss of power off hours event TSC and OSC ERO personnel will automatically respond to the EOF, which has been designated as the alternate TSC/OSC. The facility is located approximately 12.5 air miles north-northeast of the station at 4000 Avenue F, in Bay City, Texas.
The alternate TSC/OSC has equipment for communicating with the control room, and plant security. TSC and OSC personnel at the alternate TSC/OSC have the capability to perform engineering assessment activities, including damage control team planning and preparation prior to returning to the site.
Site procedure OERP01-ZV-OF03, Alternate TSC/OSC, describes the layout and assigned work areas for the alternate TSC/OSC. This alternate facility was designed to support current augmented ERO staffing.
Action #5: Identify and revise applicable site procedures to address logistics for the expanded ERO response teams for a dual unit event.
: 4. Transportation to the Site for the Expanded ERO STP's 90-day response to Recommendation 9.3 of the NTTF letter (Reference 7.10) states that the following methods of access to the site are available:
: 1. STP has multiple roadways to access the site:
        " From the West - Highway 521
        " From the North - Farm to Market (FM) 1468
        " From the East - Highway 521
: 2. STP's owner controlled area is located on the west bank of the Colorado River.
The river can be used to transportpersonnel and small equipment by boat from surrounding areasto the site.
: 3. Helicopters can be used to transportpersonnel to the site.
: 4. STP has road clearing equipment and a boat onsite which may be available after a large scale event.
: 5. STPNOC has an agreement with Matagorda County to provide local resources upon request or state and federal resourcesif there is a disasterdeclaration.
These resourcesinclude road clearing equipment, off-road and high water vehicles, boats and helicopters.
Page 17

Enclosure NOC-AE-13003004 Page 18 of 42 The process used by the ERO for obtaining emergency assistance is as follows:
       -   Upon activation of the EOF, the Emergency Operations Center (EOC) for Matagorda County is contacted for assistance
           " The EOC is located in the Matagorda County Sheriffs Office, approximately 1.2 miles north of the EOF
           " STP has a Letter of Agreement in place with Matagorda County to provide assistance in the event of an emergency
       -   If Matagorda County requires additional resources to assist in their Emergency Management efforts, they will contact the Texas Department of Public Safety in Pierce, Texas
       -   Should further resources be required, the State Operations Center in Austin, Texas would be contacted.
Contact numbers for Matagorda County EOC, Department of Public Safety in Pierce, the State Operations Center in Austin, and the US Coast Guard in both Houston and Corpus Christi are listed the site Emergency Communications Directory (including back-up satellite phone numbers, where applicable).
: 5. ERO Drill & Exercise Program NEI 12-01 states that a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. In particular, standard objectives and extent-of-play may need to be revised to clarify the expected demonstration of functions that are dependent upon the type of scenario event or accident (i.e., within or beyond design basis, and number of affected units). For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit.
Current STP drill and exercise procedures do not include evaluation objectives or demonstration criteria for dual unit events or expanded ERO activities. Future guidance is expected from the NRC in this area.
Page 18

Enclosure NOC-AE-13003004 Page 19 of 42 5.1.2 Position Specific ERO Response
: 1. Radiation Protection Technicians (RPTs)
The equation below was used to determine the required number of on-site RP Technicians (on-shift plus augmented ERO RP Technicians that perform on-site response functions) for the STP expanded ERO:
RPTT = RPTcop + RPTRcA      + RPTNc Where:
RPTT = Total required number of on-site RP Technicians.
RPTcop = Number needed to support implementation of any 2 extended loss of AC power coping strategies per unit. Determine this number by reviewing strategies for each unit.
RPTRCA = Number needed for repair and corrective action (2 x the number of units).
RPTNC = Number of on-site RP Technicians performing other emergency plan functions that would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams.
The STP RPTcop number is based upon the coping strategies of OPOP05-EO-ECOO which requires two RPTs to provide job coverage into radiation areas for personnel to perform the required actions.
The STP RPTRCA number is four RPTs.
The STP RPTNc number is based upon emergency plan Table C-1 which requires two RPTs to perform onsite surveys and one RPT to perform dose assessments which would preclude them from performing job coverage for extended loss of all AC power coping, repair or corrective action teams (note, Table C-1 provides for four individuals for performing offsite surveys).
9 (RPTT) = 2 (RPTcop) + 4 (RPTRCA) + 3 (RPTNc)
Thus, the total required number of on-site RP Technicians to be provided as part of the expanded ERO is 18, based on staffing needed to operate on 12-hour shifts.
Following a beyond design basis external event 32 RP Technicians are available to support performance of assigned emergency plan functions and the expanded response capability (Refer to Table 5-1 and Note (0).
Provisions exist for obtaining additional RP Technicians through industry agreement with INPO as part of the INPO Emergency Resources Manual documented by a current letter of agreement.
Page 19

Enclosure NOC-AE-13003004 Page 20 of 42
: 2. Administrative Support Personnel STP evaluated the administrative support positions on the ERO and determined that the number of administrative staff personnel is sufficient.
: 3. SAMG Implementation The assessment considered the number and qualifications of ERO personnel necessary for simultaneous implementation of the two most task intensive SAMG strategies in both units. The two most labor intensive strategies were as follows:
           "    SAG-i, Inject into Steam Generators
           "    SAG-2, Depressurize the RCS Implementation of the SAG-1 strategy requires the following personnel resources:
ERO Positi6o           'per unit F nction Plant Operator             3     Operate Equipment Mechanic                   2     Connect Hoses RP Technician              2     Job Coverage Implementation of the SAG-2 strategy requires the following personnel resources:
ERO Position&        # perunitll Function Plant Operator             2     Operate Equipment RP Technician              2     Job Coverage These two strategies implemented simultaneously and in both units, would require the following personnel resources:
* 10 Plant Operators
* 4 Mechanics
* 8 RP Technicians As stated in NEI 12-01, while personnel previously assigned to other functions such as emergency repair and corrective actions should not be included, members of the on-shift staff may be included.
Page 20

Enclosure NOC-AE-1 3003004 Page 21 of 42 5.2     Expanded Response Functions for Phase 1 Staffinq Assessment Table 5-2 addresses NEI 12-01 Table 3.1 expanded staffing requirements and documents the staffing necessary to support the simultaneous deployment of emergency repair and corrective action teams to each affected unit. The number required column is equal to two times the specified staffing consideration per unit in order to support 24-hour expanded ERO staffing based on 12-hour shifts.
Per current site procedures, one of the existing three ERO teams is on call each week - there will be no changes to this procedure at this time. There is reasonable assurance that the additional personnel for the expanded ERO can be brought to the site by the time they are needed.
Table 5-2 Expanded vs. Augmented ERO Response Comparison 2..STP                                                          Augmenited:ERO         4Rqie Function         'Key Roles andStaffing Considerations                                 LocAtion Positions                              I.Available
* Overall cognizance of the activities related to implementation of repair and corrective actions, and implementation of Transition Unit Response        Phase coping and Severe Accident Management (SAM)                          TSC Manager / Asst TSC           4           6 Coordination         strategies for an assigned unit                                   TSC      Manager
* One individual per unit; individuals should not be assigned other functions a  Provides coordination of Operations staff and support for an Operations           assigned unit                                                     CR / TSC Ops Manager / Asst Ops           4           6 Coordination      0  One individual per unit; individuals should not be assigned other          Manager functions
* Provides coordination of Maintenance staff and support for an Maintenance          assigned unit                                                     OSC      OSC Coordinator / Asst OSC       4           6 Coordination      0  One individual per unit; individuals should not be assigned other          Coordinator functions
* Provides coordination of Engineering staff and support for an Engineering          assigned unit                                                     TSC      TSC Technical Manager            4           6 Coordination
* One individual per unit; individuals should not be assigned other          Engineering Supervisor functions Page 21

Enclosure NOC-AE-1 3003004 Page 22 of 42
.Function         .Kaey.Roles and Staffing Considerations           .....                              Postions " t....Location            R      e   Available
* One team for each unit to perform engineering assessments in support repair and corrective actions                                          Engineer   - Nuclear~j)                4             3 Engineering
* Team composition (i.e., number and represented disciplines) as         TSC     Engineer - Mechanicalu)                4             3 Assessments             described in the emergency plan                                                Engineer - Electricalj)                4             3
* Team may include personnel responsible for performing other functions for the same assigned unit TSC Technical Manager Engineering Supervisor                 4             3 Evaluation of     e    One team for each unit to evaluate selection of SAM strategies;                Engineer- Nuclear                      4             3 Severe                 team performs evaluations not done by Control Room personnel                   Engineer - Mechanical                  4             3 Accident
* Team composition (i.e., number and represented disciplines) as         TSC     Engineer - Electrical                  4             3 Management             described in governing site programs, procedures and guidelines                Engineer - I&C(k)                      4             3 (SAM)
* Team may include personnel responsible for performing other                    Rad Manager / Asst Rad                 4             3 Strategies             functions for the same assigned unit                                           Manager                                4             6 Ops Manager / Asst Ops                 4             6 Manager Unit In-Plant
* Overall cognizance of on-site and in-plant teams performing or                 Maintenance Discipline Team                   supporting repair and corrective actions for an assigned unit                  Leaders (Electrical, MSi                                    4             9 Coordination
* One individual per unit; individuals should not be assigned other              Mechanical, I&C) functions
* Two individuals per unit to assist with implementation of repair Non-Licensed          and corrective actions                                                 OSC     Plant Operators                        8         77(1)(m)
Operators
* Should not include members of the on-shift staff Mechanical       0    Two individuals per unit to implement repair and corrective Maintenance            actions Repair and                                                                                   OSC     Mechanic                               8           46 Corrective a             Staffing may include an on-shift individual (i.e., 2 individuals for a Action                 unit composed of 1 on-shift and 1 augmented)
: 0) Engineers also credited as SAMG Evaluators (k) The I&C Engineer position is not listed as a required minimum staffing position for the TSC or EOF, but they are listed as trained SAMG Evaluators (1)10 of these available POs are counted as part of the minimum on-shift staff (m)As of 2/27/2013, 61 of the available plant operators were fully qualified and the remaining 16 were not fully qualified Page 22

Enclosure NOC-AE-13003004 Page 23 of 42
                                           *>STP                                                              Augmecnted ERO             # Required Key  Roles and :staffing Considerations KFunction                                                                  Location ,Positions                                  :Available.
Electrical         0 Two individuals per unit to implement repair and corrective Maintenance            actions                                                                                                                              (n)
Repair  and a              Staffing may include an on-shift individual (i.e., 2 individuals for a OSC       Electrician                           844)
Corrective Action                 unit composed of 1 on-shift and 1 augmented)
I&C Repair and R       Two   individuals per unit to implement repair and corrective actions                                                                               Tehiin43(0)
Corrective                                                                                    OSC       I&C Technician8 Action             0   Staffing may include an on-shift individual (i.e., 2 individuals for a unit composed of 1 on-shift and 1 augmented)
Plant Operators                      10           77
* Number and composition of personnel capable of simultaneous            OSC       Mechanics                             4           46 RP Technicians                        8_32(P)
Implementation         implementation of any 2 SAM strategies at each unit Shift Manager                         4          10 (q) of SAM             ,   Should not include personnel assigned to other functions (e.g.,
Strategies             emergency repair and corrective actions); however, may include         CR        Shift Technical Advisor               4            9 members of the on-shift staff and personnel responsible for                      Reactor Operators                     4         31(r)(s) implementation of Transition Phase coping strategies TSC       Operations Communicator               4            3 (n) One of these Electricians is counted as part of the minimum on-shift staffing.
(o) One of these I&C Technicians is counted as part of the minimum on-shift staffing.
(p) Three of these RP Technicians are counted as part of the minimum on-shift staffing.
(q) Two of these Shift Managers are counted as part of the minimum on-shift staffing.
(r) Five of these Reactor Operators are counted as part of the minimum on-shift staffing.
(s) This total includes only personnel specifically designated as Reactor Operators - it does not include those individuals with active RO or SRO licenses holding other positions.
Page 23

Enclosure NOC-AE-1 3003004 Page 24 of 42 6     LIST OF IMPROVEMENT ACTIONS IDENTIFIED DURING THE PHASE I ASSESSMENT The following enhancements have been entered into the CAP system to track their resolution:
Description                                   Estimated Completion Date Action #1: Ensure that the required number of qualified               March 31, 2014 individuals are added to fill all necessary roles of the expanded ERO.
Action #2: Develop specific guidance for how and when to              December 4, 2014 establish the expanded ERO from the pool of augmented ERO.
Action #3: Develop and communicate the process to expand the          December 4, 2014 automatic response of ERO personnel who report to the EOF in the event of a loss of communications due to a large scale event to include appropriate activation of off-shift Operations, Maintenance, Security, RP personnel, and the expanded ERO.
Action #4: The changes in Action #3 will be included in annual        December 4, 2014 site training.
Action #5: Identify and revise applicable site procedures to          December 4, 2014 address logistics for the expanded ERO response teams for a dual unit event.
Note: None of the above listed actions are classified as Conditions Adverse to Quality (CAQ).
These actions apply to a Beyond Design Basis event and therefore do not meet the requirements of a CAQ.
The December 4, 2014 date was chosen to align with the completion and submittal of the STP Phase 2 Staffing Assessment.
The March 31, 2014 date was chosen to align with the Engineering Department's process for assigning ERO responsibilities and to give sufficient time to incorporate ERO changes into the appropriate site directories.
Page 24

Enclosure NOC-AE-13003004 Page 25 of 42 7    LIST OF REFERENCES 7.1     Letter from E. J. Leeds (NRC) to E. D. Halpin, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated March 12, 2012 (ML12053A340) 7.2     SECY-1 1-0093, "The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", n, refer to NRC staff report entitled, Recommendations for Enhancing Reactor Safety in the 21st Century, dated July 12, 2011 (ML111861807) 7.3     Letter from D. L. Skeen (NRC) to Susan Perkins-Grew (NEI), U.S. Nuclear Regulatory Commission Review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012, letter dated May 15, 2012 (ML12131A043) 7.4     NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Rev. 0 (ML12126A344) 7.5     Letter, D.W. Rencurrel to NRC, "Revised 60-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident", dated June 4, 2012 (ML12163A331) 7.6     NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, Rev. 0 (ML111751698) 7.7     STP Response to IER 11-1, Fukushima Daiichi Nuclear Station Fuel Damage Caused by Earthquake and Tsunami, dated 04/15/11 7.8     STPNOC Response to IER 11-2, Fukushima Daiichi Nuclear Station Spent Fuel Pool Loss of Cooling and Makeup, dated 09/22/11 7.9     STPNOC Response to IER 11-4, Near-Term Actions to Address the Effects of an Extended Loss of all AC Power in Response to the Fukushima Daiichi Event, dated 01/19/12 7.10    Letter from D. W. Rencurrel to NRC, "90-Day Response to Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident", dated June 4, 2012 (ML12163A331) 7.11    STP Emergency Plan Section C, Organizational Control of Emergencies, Rev ICN 20-9 7.12    OPOP05-EO-EOOO, Reactor Trip or Safety Injection Rev. 22 7.13    OPOP05-EO-ECOO, Loss of All AC Power, Rev. 23 7.14    OERP01-ZV-IN01, Emergency Classification, Rev. 9 7.15    OERPO1-ZV-IN02, Notifications To Offsite Agencies, Rev. 29 7.16    OERP01-ZV-IN03, Emergency Response Organization Notification, Rev. 17 Page 25

Enclosure NOC-AE-1 3003004 Page 26 of 42 7.17 OERP01-ZV-IN04, Assembly and Accountability, Rev. 13 7.18 OERP01-ZV-IN05, Site Evacuation, Rev. 12 7.19 OERP01-ZV-IN07, Offsite Protective Action Recommendations, Rev 13 7.20 OERP01-ZV-SH01, Shift Manager, Rev. 27 7.21 OERP01-ZV-SH02, Acting Radiological Manager, Rev. 10 7.22 OERP01-ZV-TP01, Offsite Dose Calculations, Rev. 20 7.23 OERP01-ZV-OF03, Alternate TSC/OSC, Rev. 1 7.24 SAG-i, Inject into the Steam Generators, Rev. 1 7.25 SAG-2, Depressurize the RCS, Rev. 1 7.26 SAG-3, Inject into the RCS, Rev. 1 7.27 SAG-4, Inject into Containment, Rev. 1 7.28 SAG-5, Reduce Fission Product Releases, Rev. 1 7.29 SAG-6, Control Containment Conditions, Rev. 1 7.30 SAG-7, Reduce Containment Hydrogen, Rev. 1 7.31 SAG-8, Flood Containment, Rev. 1 7.32 SACRG-1, Severe Accident Control Room Guideline Initial Response, Rev. 1 7.33 SACRG-2, Severe Accident Control Room Guideline After the TSC is Functional, Rev. 1 Page 26

Enclosure NOC-AE-1 3003004 Page 27 of 42 kaf   nn" t:.h      NEF0IEO-Ot  T   arb&Ie5 Co-n1tinollng Meto         Correlation"K
* Operations Training Program and EP Drill ProgramriTask Line FunctionlTask                        Analysis Controlling Methods.
1   Declare the Emergency                Emergency Response Training Program Learning Objectives for Classification Level (ECL)           Emergency Direction, Part 1 TERMINAL OBJECTIVE:
: 01. Given the necessary reference materials and a hypothetical emergency situation, classify the emergency.
Enablinq OBJECTIVE:
: 06. Using applicable references, CLASSIFY an incident for a specified plant condition or set of plant parameters.
: 2. Approve Offsite Protective           Emergency Response Training Program Learning Objectives for Action Recommendations               Emergency Direction, Part 2 TERMINAL OBJECTIVE:
: 01. Given necessary reference materials and a hypothetical emergency situation, determine the correct Protective Action Recommendation (PAR).
Drill Objective OBJ-B-2, On-Shift Emergency Director Demonstrate the Shift Manager's ability to immediately and unilaterally initiate any emergency response action, including providing protective action recommendations to authorities responsible for implementing off-site emergency measures.
: 3. Approve content of State/local        Drill Objective OBJ-A-2, Operational Agreement notifications                         Demonstrate the coordination of the implementation of emergency measures and the exchange of information between the utility and Federal, State and local agencies and other support organizations having an emergency response role within the EPZ.
: 4. Approve extension to                  Drill Objective OBJ-K-1, Emergency Worker Exposure Controls allowable dose limits                 Demonstrate the ability to establish on-site exposure guidelines consistent with EPA Manual of Protective Action Guides and Protective Actions For Nuclear Incidents (EPA 400-R-92-001) for:
removal of injured persons, undertaking corrective actions, performing assessment actions, providing first aid, performing personnel decontamination, providing ambulance services, and providing medical treatment services.
: 5. Notification and direction to        Drill Objective OBJ-J-1, Assembly & Accountability on-shift staff (e.g., to              Demonstrate the capability to account for all individuals on-site assemble, evacuate, etc.)            and ascertain the names of missing individuals within 30 minutes of the start of Assembly & Accountability and account for all on-site individuals continuously thereafter.
Drill Objective OBJ-J-2, Alerting On-site Personnel Demonstrate the means, within the required time, to alert individuals who do not have emergency assignments (such as visitors, contractor and construction personnel, and persons who may be in the public access areas within the owner controlled area).
Page 27

Enclosure NOC-AE-13003004 Page 28 of 42 Attai  h     n6M *'.NEb 14-0-Table 5 ControgllinM~eho.d. Corre.ati                 ..
: 4.                             - Operations Training Program and EPDriII Program Task Line Function/Task                   Analysis ControllinngMethodsI-
: 6. ERO notification             Drill Objective OBJ-E-1, ERO Notifications Demonstrate the ability to alert, notify and mobilize ERO personnel.
: 7. Abbreviated NRC notification  N/A      Assumptions dictate no hostile action is occurring for DBT event
: 8. Complete State/local          Drill Objective OBJ-E-2, Initial Notification notification form            Demonstrate the ability to provide an accurate initial off-site notification message within 15 minutes from emergency declaration.
: 9. Perform State/local          Drill Objective OBJ-E-2, Initial Notification notifications                Demonstrate the ability to provide an accurate initial off-site notification message within 15 minutes from emergency declaration.
: 10. Complete NRC event           Drill Objective OBJ-Q-1, NRC Notifications notification form            Demonstrate the ability to notify the NRC.
: 11. Activate ERDS                 N/A       ERDS is continuously active at STP.
: 12. Offsite radiological         Drill Objective OBJ-I-2, Release and Dose Assessment assessment                   Demonstrate the capability to determine the magnitude of radioactive releases or perform dose assessments based on plant parameters, effluent monitors, field data and meteorological conditions.
: 13. Perform NRC notifications    Drill Objective OBJ-Q-1, NRC Notifications Demonstrate the ability to notify the NRC.
: 14. Perform other site-specific  N/A       Not performed by STP shift staff event notifications (e.g.,
INPO, ANI, etc.)
: 15. Personnel accountability     Drill Objective OBJ-I-1, Assembly and Accountability Demonstrate the capability to account for all individuals on-site and ascertain the names of missing individuals within 30 minutes of the start of Assembly & Accountability and account for all on-site individuals continuously thereafter.
: 16. Implement Security           N/A      Assumptions dictate no hostile action is occurring Contingency Plan Page 28

Enclosure NOC-AE-1 3003004 Page 29 of 42 Fta&#xfd;hmen-_t2:    NEl 410-05 AppendixB OnO-S         ffgn          Results Tables                                      ..
TABLE I - On-Shift Positions                                                              Extended Loss of All AC Power (ELAP)
Emergency:Pla'ni        Augmentation  Rolein Table#I/ Unanalyzed.        TM Required?
Line            On-shirt~position                  eference        ElapsedTme (mi)
* Line#        Task?..
2/1 5/1
: 1. Ul Shift Manager                    Table C-1                                         5/2          No              No 5/3 5/5
: 2. Ul Unit Supervisor                  Table C-1                                         2/2          No              No
: 3. Ul Reactor Operator (Ul Pri RO)     Table C-1                                         2/3          No              No
: 4. Ul Reactor Operator (U1 BOP RO)     Table C-1                                         2/4          No              No
: 5. Ul TGB Watch Plant Operator (PO #1) Table C-1                                         2/5          No              No 2/6.A 2  /6.B3 2/6.B
: 6. Ul MAB Watch Plant Operator (PO #2) Table C-1                                       2 /6.C 2/6.D          No              No 2/6.E 2 /6.F
: 7. U2 Shift Manager                    Table C-1                                         2/7          No              No
: 8. U2 Unit Supervisor                  Table C-1                                         2/8          No              No
: 9. U2 Reactor Operator (U2 Pri RO)     Table C-1                                         2/9          No              No 10  U2 Reactor Operator (U2 BOP RO)     Table C-1                                        2/10          No              No
: 11. U2 TGB Watch Plant Operator (PO #3) Table C-1                                        2/11          No              No 2/12.A 2 /12.B3 2/12.C
: 12. U2 MAB Watch Plant Operator (PO #4) Table C-1                                      2/   12.C 2/12.D          No              No 2 /12.E 2 /12.F Page 29

Enclosure NOC-AE-1 3003004 Page 30 of 42
,Atta6chmenti2"-.:       N.EIO-05_ Appen6d.ixBBOn-Shift Staffing Analysis R              u                                                             _ResultsTa
       *:b&#xf7;...:~~               .......   . .,*   ~ . ~~~~
                                                       .                ~~~ ~~~.           .. .. :..................F.::::.                               . * :. .?.*  ;:::..
Emergency Plan,           Augmentation:                      Role in Table # / iUnanalyzed                   TMS Line       "On-shift              Position    .:Reference                         :,Elapsed Time (min).                        Line#           Task? :              Required?
: 13.      ENS Communicator (RO #5)                     Table C-1                                                               5/10              No                         No 5/13
: 14. State/County Communicator (PO #5)             Table C-1                                                                5/8              No                         No Table C-1                                                               2/15              N/A                        N/A
: 15.      Fire Brigade Leader (PO #6) 3/1              N/A                        N/A Table C-1i2/16                                                                            N/A                        N/A
: 16.      FBT Member #1 (PO #7) 3/2             N/A                         N/A
: 17.      FBT Member #2 (PO #8)                        Table C-1                                        -2                       /17             N/A                        N/A 3/13             N/A                        N/A
: 18.      FBT Member #3 (PO #9)                        Table C-1i2/18                                                                            No                         No 3/4              N/A                        N/A
: 19.      FBT Member #4 (PO #10)                       Table C-1                                                               2/19              No                         No 3/5              N/A                        N/A
: 20.      I&C Technician                               Table C-1                                         -                     2/20              N/A                        N/A
: 21.      Elect. Maintenance                           Table C-1                                         -                     2/21              N/A                        N/A 4/1
: 22.      Senior HP                                    Table C-1                                    360                         4/5              No                         No 4/1
: 23.      RP Technician #1                             Table C-1                                    360                         4/
4/4              No                         No
: 24.         RP Technician #2                           Table C-1                                   360                         4/1              No                         No 4/4
: 25.         Chemistry Technician                       Table C-1                                   360                         4/8              N/A                        N/A
: 26.        Security                                    All per STP Security Plan                                               5/6              No                         No 5/15 Note: In Table 1, those on-shift positions with tasks labeled as N/A were not assigned a specific action for the first six hours.
Page 30

Enclosure NOC-AE-1 3003004 Page 31 of 42 Attachmeht 2-:    _:NE,10-05   Appoendix R On-Shift Staffing      alsisR       uts:Tables                .       ..             ' .
TABLE 2 - Plant Operations & Safe Shutdown                                                                 Extended Loss of All AC Power (ELAP)
Minimum Crew (Two Units - One Control Room)
Line. Generic TitleiRole .. nShiftPosition                -:: Task Description .                                         ControllingMethod
: 1. Shift Manager           Ul Shift Manager                    Plant Oversight                                            Ops   Training Program
: 2. Unit Supervisor #1      Ul Unit Supervisor                  Direct Ul CR operations (EOOO I ECOO)                      Ops   Training Program
: 3. Reactor Operator #1     Ul Reactor Operator (Ul Pri RO)     Perform U1 CR operations (EO00 / ECO0)                     Ops   Training Program
: 4. Reactor Operator #2     Ul Reactor Operator (U1 BOP RO)     Perform U1 CR operations (EOOO / ECO0)                     Ops   Training Program
: 5. Auxiliary Operator #1   Ul TGB Watch Plant Operator (PO     Attempt to start Ul TSC DG (in-plant ECOO action)          Ops   Training Program Auxiiar Opeato #1     #1)
: 6. Auxiliary Operator #2   Ul MAB Watch Plant Operator         A. Isolate Ul RCP Seal Return (in-plant ECO0 action)       JPM 20.02 (PO #2)                             B. Isolate Ul Thermal Barriers (in-plant ECO0 action)      JPM 28.02 C. Isolate Ul Seal Injection (in-plant EC0O action)        JPM 28.02 D. Close Ul MOV-0025 (in-plant ECO0 action)                Ops Training Program E. Close Ul RA-MOV-0004 & RA-MOV-0006 (in-plant            JPM 127.02 ECO0 action)
F. Verify Ul SFP Level (in-plant ECO0 action)              Ops   Training Program
: 7. Shift Technical Advisor U2 Shift Manager                    STA Tasks                                                  Ops   Training Program
: 8. Unit Supervisor #2      U2 Unit Supervisor                  Direct U2 CR operations (EOOO / ECOO)                      Ops   Training Program
: 9. Reactor Operator #3     U2 Reactor Operator (U2 Pri RO)     Perform U2 CR operations (EOOO / ECOO)                     Ops   Training Program
: 10. Reactor Operator #4     U2 Reactor Operator (U2 BOP RO)     Perform U2 CR operations (EOOO / ECOO)                     Ops   Training Program Auxiliary               U2 TGB Watch Plant Operator         Attempt to start U2 TSC DG (in-plant ECOO action)          Ops   Training Program yOperator #3  (PO #3)
: 12. Auxiliary Operator #4   U2 MAB Watch Plant Operator         A. Isolate U2 RCP Seal Return (in-plant ECO0 action)       Ops Training Program (PO #4)                             B. Isolate U2 Thermal Barriers (in-plant ECOO action)      Ops Training Program C. Isolate U2 Seal Injection (in-plant ECOO action)        Ops Training Program D. Close U2 MOV-0025 (in-plant ECO0 action)                Ops Training Program E. Close U2 RA-MOV-0004 & RA-MOV-0006 (in-plant            JPM 127.02 ECOO action)
F. Verify U2 SFP Level (in-plant ECO0 action)              0ps Training Program
: 13. Other                   ENS Communicator (RO #5)            NRC communications/notifications per site procedure        EP Training Program OERP01-ZV-IN02 Page 31

Enclosure NOC-AE-1 3003004 Page 32 of 42
'Attachment 2: ..      NEl0-05 Appendix B!On-ShiftStaffng*Anal'sisRsultsables..                                                                      .
: 14. Other                    State/County Communicator        State/County notifications per site procedure OERP01-ZV-     EP Training Program (PO #5)                          IN02
: 15. Other                    Fire Brigade Leader (PO #6)      N/A                                                          N/A
: 16. Other                    FBT Member #1 (PO #7)            N/A                                                          N/A
: 17. Other                    FBT Member #2 (PO #8)            N/A                                                          N/A
: 18. Other                    FBT Member #3 (PO #9)            A. Place SG PORV Station Blackout PWR switches to            JPM 34.02 bypass (Unit 1)                                         Ops Training Program B. Ul Load Shed (in-plant EC0O action)
: 19. Other                    FBT Member #4 (PO #10)           A. Place SG PORV Station Blackout PWR switches to            JPM 34.02 bypass (Unit 2)                                         Ops Training Program B. U2 Load Shed (in-plant EC00 action)
Other (non-Operations) Personnel Line, Gene~ric Titie/Role                 On&Shift Position:         TaskrDesciptibin.Controlling Method:,
: 20. I&C Technician                      I&C Technician             N/A                                       N/A
 -21. Electrical Technician             Electrical Maintenance     N/A                                       N/A TABLE 3 - Firefighting                                                                                    Extended Loss of All AC Power (ELAP)
   ,Line   PeiformedBy        :            Task.Description                                                      Gontrolling Method
: 1. Fire Brigade Leader (PO #6)     N/A                                                                   N/A
: 2. FBT   Member #1   (PO #7)       N/A                                                                   N/A
: 3. FBT   Member #2   (PO #8)       N/A                                                                   N/A
: 4. FBT   Member #3   (PO #9)       N/A                                                                   N/A
: 5. FBT   Member #4   (PO #10)      N/A                                                                   N/A Page 32

Enclosure NOC-AE-1 3003004 Page 33 of 42 : _NEI 10-05 Appendix-B ,.On-*hiittffing Analysis Results Tables                                  .........
TABLE 4 - Radiation Protection and Chemistry                                                                Extended Loss of All AC Power (ELAP)
Position. P*rformin,        ..                   Performance Time Period.After Emergency Declaration (minutes)
Function/Task.              0-30    30-60     60-90      9...
00-120   1.2i50* *1 50-180" 180-210 2.0740. 240-300 . 300-330           330&360.
In-Plant Survey
: 1. On-Shift Position:
HP Supervisor                          X       X         X
: 2. On-Site Radiological Survey On-Shift Position:
: 3. Personnel Monitoring On-Shift Position:
: 4. Job Coverage                           X       X         X           X         X         X          X             X      X           X        X On-Shift Position:                     X       X         X           X         X         X          X             X      X           X        X RP Technician #1 RP Technician #2
: 5. Offsite Radiological                                                                                                      X Assessment On-Shift Position:
HP Supervisor
: 6. Other RP  -
On-Shift Position:
7-   Sampling                               X       X         X           X         X         X          X             X       X          X        X On-Shift Position:
Chemistry
: 8. Other Chem - Describe:
On-Shift Position:
Note:    The basis for the selected performance time period was established by the subject matter experts during the task analysis review.
Page 33

Enclosure NOC-AE-13003004 Page 34 of 42 Aacment?2:NEI 10-05 Appendix B On-Shift Staffing AnlssResults Tables~
TABLE 5 - Emergency Plan Implementation                                                                  Extended Loss of All AC Power (ELAP)
Line FunctionITask*           ..                                                                 Positio**n:Controlling Method*
: 1. Declare the Emergency Classification Level (ECL)                                 U1 Shift Manager           EP Training Program
: 2. Approve Offsite Protective Action Recommendations                                Ul Shift Manager           EP Training Program EP Drill Program
: 3. Approve content of State/local notifications                                     U1 Shift Manager           EP Drill Program
: 4. Approve extension to allowable dose limits                                       N/A                        N/A
: 5. Notification and direction to on-shift staff (e.g., to assemble, evacuate, etc.) U1 Shift Manager           EP Drill Program
: 6. ERO notification                                                                 Security                   EP Drill Program
: 7. Abbreviated NRC notification for Design Basis Threat event                       N/A                        N/A
: 8. Complete State/local notification form                                           State/County Communicator  EP Drill Program
: 9. Perform State/local notifications                                                State/County Communicator  EP Drill Program
: 10. Complete NRC event notification form                                             ENS Communicator           EP Drill Program
: 11. Activate ERDS                                                                    N/A                        N/A
: 12. Offsite radiological assessment                                                  N/A                        N/A
: 13. Perform NRC notifications                                                        ENS Communicator           EP Drill Program
: 14. Perform other site-specific event notifications (e.g., INPO, ANI, etc.)          N/A                        N/A
: 15. Personnel accountability                                                         Security                   EP Drill Program
: 16. Implement Security Contingency Plan                                              N/A                        Security Training Program Note:  Line #3, #8 and #9 includes initial and follow-up State/local notifications.
Page 34

Enclosure NOC-AE-1 3003004 Page 35 of 42 Attachment*3*YNEI100,ppendixD&E,.Shift                         Staffing Analysis ResultsTabIes Extended Loss of All Power (ELAP)                                                  Position: U1 MAB Watch Plant Operator (PO #2)                  Line #:1-6 Appendix D: Function / Responsibility (Task) Analysis Actin                      2....Duration Function. =.                   . Responsibility(Task)                                                 Action Step                  :        .. Dmion) 1.1 Isolate U1 RCP Seal Return (2/6.A)                               1.1.1 ECOO  Step  4.c                          3 1.2 Isolate U1 Thermal Barriers (2/6.B)                              1.2.1 ECO0  Step  8.b                          9
: 1. Plant Operations (status         1.3 Isolate U1 Seal Injection (2/6.C)                                1.3.1 ECO0  Step  8.c                          9 monitoring and EOP actions)      1.4 Close U1 MOV-0025 (2/6.D)                                        1.4.1 ECO0  Step  20.b                         5 1.5 Close Ul RA-MOV-0004 & RA-MOV-0006 (2/6.E)                       1.4.1 ECOO  Step  21.a                        10 1.6 Verify U1 Spent Fuel Pool Level (2/6.F)                          1.5.1 ECO0 Step 24.a                          15 Timing for Isolate RCP Seal Return, Isolate Thermal Barriers, Isolate Seal Injection and Verify CVCS Charging line isolated (MOV-0025) were taken from Ops walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."
Timing for closure for RA-MOV-0004 & RA-MOV-0006 is taken from JPM 127.02.
Timing for Verify Spent Fuel Pool Level is taken from operator experience (a visual check of SFP level from the operating deck is a non-technical general operator rounds task).
Page 35

Enclosure NOC-AE-1 3003004 Page 36 of 42 Atta     ment.3::     NEai 1-051ppendiO** A&E On-Shift Stafing AnaiysisRes....                                            .   .......
Extended Loss of All Power (ELAP)                                                   Position: U1 MAB Watch Plant Operator (PO #2)                  Line #:11-6 Appendix E: Work Activities Analysis
     &#x17d;i
     =     Plant/equipment/environmental events and conditions                TaskW/
T      Action Step description..,.
applicable:to the functions and tasks:::."                         (start & stop)
Actions completed at U1 MAB 29'. Refer to section 4.3 for          Perform U1 in-plant ECQO actions: Isolate U1 RCP Seal Return event and conditions description                                   (00:00 - 00:03)
Actions completed at U1 MAB 41' penetration space. Refer to        Perform U1 in-plant ECO0 actions: Isolate U1 Thermal Barriers section 4.3 for event and conditions description                   (00:04 - 00:13)
Actions completed at U1 MAB 29'. Refer to section 4.3 for          Perform U1 in-plant ECOO actions: Isolate Ul Seal Injection event and conditions description                                   (00:14 - 00:23)
Perform U1 in-plant ECOO actions: Verify U1 CVCS Charging line isolated 00:24    Actions event andcompleted  at description conditions  U1 MAB 29'. Refer to section 4.3 for        (MOV-0025)
(00:24 - 00:29)
Actions completed at U1 MAB 41' penetration space. Refer to        Perform U1 in-plant ECOO actions: Close U1 RA-MOV-0004 & RA-MOV-0006 section 4.3 for event and conditions description                   (00:30 - 00:40) 00:41    Actions completed at U1 FHB operating deck. Refer to section       Perform U1 in-piant ECO0 actions: Verify Ul Spent Fuel Pool Level 4.3 for event and conditions description                           (00:41 - 00:56)
Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.
Page 36

Enclosure NOC-AE-1 3003004 Page 37 of 42 :        NEI 10-05 Appendix D&EpiOn-Shift Staffing                 y     Results Tables            ....                  .....
Extended Loss of All Power (ELAP)                                                   Position: U2 MAB Watch Plant Operator (PO #4)              Line #:1-12 Appendix D: Function / Responsibility (Task) Analysis Function
                                                                                                                                   ...... ..      Duration
                       .Responsibility               (Task).                                             Action Step                                (min)to 1.1 Isolate U2 RCP Seal Return (2/12.A)                             1.1.1    ECO0 Step 4.c                        3 1.2 Isolate U2 Thermal Barriers (2/12.B)                            1.2.1    ECO0 Step 8.b                        9
: 1. Plant Operations (status          1.3 Isolate U2 Seal Injection (2/12.C)                              1.3.1    ECO0 Step 8.c                        9 monitoring and EOP actions)       1.4 Close U2 MOV-0025 (2/12.D)                                      1.4.1    ECOO Step 20.b                       5 1.5  Close U2 RA-MOV-0004 & RA-MOV-0006 (2/12.E)                     1.4.1    ECOO Step 21.a                      10 1.6  Verify U2 Spent Fuel Pool Level (2/12.F)                        1.5.1    ECOO Step 24.a                      15 Timing for Isolate RCP Seal Return, Isolate Thermal Barriers, Isolate Seal Injection and Verify CVCS Charging line isolated (MOV-25) were taken from Operations walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."
Timing for closure for RA-MOV-0004 & RA-MOV-0006 is taken from JPM 127.02.
Timing for Verify Spent Fuel Pool Level is taken from operator experience (a visual check of SFP level from the operating deck is a non-technical general operator rounds task).
Page 37

Enclosure NOC-AE-13003004 Page 38 of 42 MAtachment3:"         NEI 10-05Appendix D & E On-Shift Staffing Analysis Results Tables                  __.._-
Extended Loss of All Power (ELAP)                                                   Position: U2 MAB Watch Plant Operator (P0 #4)                 Line #:1-12 Appendix E: Work Activities Analysis Time     Plantl.equ ipment'environmental.event8sand conditions              Task / Action Step description                 :
     > <<appIicable to thelfunctionsand :tasks                                 (start &stop)
Actions completed at U2 MAB 29'. Refer to section 4.3 for          Perform U2 in-plant ECOO actions: Isolate U2 RCP Seal Return 00:00 event and conditions description                                      (00:00 - 00:03) 00:04    Actions completed at U2 MAB 41' penetration space. Refer to        Perform  U2 in-plant ECO0 actions: Isolate U2 Thermal Barriers section 4.3 for event and conditions description                   (00:04 - 00:13)
Actions completed at U2 MAB 29'. Refer to section 4.3 for          Perform  U2 in-plant ECOO actions: Isolate U2 Seal Injection event and conditions description                                   (00:14 - 00:23) 0:4Actions completed at U2 MAB 29'. Refer to section 4.3 for           Perform U2 in-plant ECO0 actions: Verify U2 CVCS Charging line isolated (MOV-0025) 00:24    event and conditions description                                   (002-0029) 1                                                 (00:24 - 00:29) 00:30    Actions completed at U2 MAB 41' penetration space. Refer to        Perform U2 in-plant ECOO actions: Close U2 RA-MOV-0004 & RA-MOV-0006 section 4.3 for event and conditions description                   (00:30 - 00:35) 00:41    Actions completed at U2 FHB operating deck. Refer to section       Perform U2 in-plant ECOO actions: Verify U2 Spent Fuel Pool Level 4.3 for event and conditions description                           (00:41 - 00:56)
Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.
Page 38

I Enclosure NOC-AE-13003004 Page 39 of 42 Atta~ch-ment 3:,.... INEV_10-05 Agmpdix D & E On-Shift Saffing Analysis Results Tables                                        __      -_
Extended Loss of All Power (ELAP)                                                 Position: Fire Brigade Member #3 (PO #9)             Line #:1-18 Appendix D: Function / Responsibility (Task) Analysis
                                                                                                            ~ Actin StepDuration~
Function                           Responsibility (Task)                                           Action Step 1.1 Ensure the SG PORV Station Blackout power switches are in "BYP" (2/19.A)                                                                                        2.5 PWR
* Place U1 Train "A"SG PORV Station Blackout switch to Bypass                                                                                   2
                                       " Place U1 Train "D"SG PORV Station Blackout PWR            1.1.1 ECOO Conditional Information switch to Bypass                                               Page (CIP)                          2
                                       " Place U1 Train "B" SG PORV Station Blackout PWR switch to Bypass                                                                                  2.5
: 1. Plant Operations (status
* switch Place U1  Train "C"SG PORV Station Blackout PWR to Bypass monitoring and EOP actions)    1.2tU L oSepass h
1.2 U1 Load Shed (2/18.13)
* De-energize  ESF Load Sequencers (ECO Addendum 4,                                                 3 Step 1.)
* De-energize  DP1 201 Components (ECO0 Addendum 4,                                                 3 Step 2.b)                                               1.2.1 ECOO Step 7.a
* De-energize  DP1 204 Components (ECOO Addendum 4,                                                 3 Step 2.c)
                                       "    De-energize  120 VAC Non-lE Loads (ECO0 Addendum 4,                                              4.5 Step 3.)
Note: Duration times are rounded up to the nearest half-minute Timing for Load Shed actions and for placing SG PORV Station Blackout switches in bypass were taken from Operations walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."
Page 39

Enclosure NOC-AE-1 3003004 Page 40 of 42 :..       N.E/110-05 AppendixD & E n-fff                    ngAnalysis Results Tables ..
Extended Loss of All Power (ELAP)                                                     Position: Fire Brigade Member #3 (PO #9)                    Line #:1-18 Appendix E: Work Activities Analysis Time       Plant e.qu Ipmentlenvironmental events and conditions           Task. Action"Step description.
            ~ap licable tothefjunci'dibns and tasks                          (stairt &,stop)
Perform Ul in-plant ECO0 actions: Place Ul Train "A"SG PORV Station 00:00     Actions completedi at     EAB 10'. Refer to section 4.3 for      Blackout PWR switch to Bypass event and conditions description                                (00:00 - 00:02:30) 1EAB 10'. Refer to section 4.3 for     Perform U1 in-plant EC0O actions: Place U1 Train "D"SG PORV Station 00:03:30    Actions completed at Udesripeo                                   Blackout PWR switch to Bypass event and conditions description                                 (00:03:30- 00:05:30)
Perform Ul in-plant ECOO actions:   Place U1 Train "B"SG PORV Station 00:06:30     Actions completed at Ui EAB 35'. Refer to section 4.3 for       Blackout PWR switch to Bypass event and conditions description                                (00:06:30- 00:08:30)
Actions completed at U1 EAB 60'. Refer to section 4.3 for        Perform Ul in-plant ECOO actions:   Place Ul Train "C" SG PORV Station 00:09:30    event and conditions description                                 Blackout PWR switch to Bypass (00:09:30- 00:12)
Perform U1 in-plant ECO0 actions:   U1 Load Shed - De-energize ESF Load 00:13     Actions completed at U1 EAB 10'. Refer to section 4.3 for        Sequencers event and conditions description                                 (00:13 - 00:16)
Actions  completed at UI1 EAB 10'. Refer to section 4.3 for      Perform U1 in-plant ECOO actions:   U1 Load Shed - De-energize DP1201 00:17     Actiondcondit U1                                                 Components event and conditions description                                (00:17 - 00:20)
Perform U1 in-plant ECO0 actions: U1 Load Shed - De-energize DP1204 00:21     Actions completed at Ui EAB 60'. Refer to section 4.3 for        Components 2event and conditions description                                (00:21 - 00:24)
Perform U1 in-plant ECO0 actions: U1 Load Shed - De-energize 120 VAC Non-00:25      Actions completed at U1 EAB 10'. Refer to section 4.3 for       1E Loads event and conditions description                                (00:25 - 00:29:30)
Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.
Page 40

Enclosure NOC-AE-1 3003004 Page 41 of 42 Attach-ment 3:           10-05 Appendix D& E On-Shift: :Staff!ing AnalysiRsoul5 ResuktsTaJeks:I .......
0NE!
Extended Loss of All Power (ELAP)                                                Position: Fire Brigade Member #4 (P0 #10)               Line #:1-19 Appendix D: Function / Responsibility (Task) Analysis Function                       ':  Respbnsibility (Task)                              ....... .. Action Step .Duration= ,,
H*::     :*... .   , ii! (m in) ,
1.1 Ensure the SG PORV Station Blackout power switches are in "BYP" (2/19.A)                                                                                            2.5
* Place U2 Train "A"SG PORV Station Blackout PWR switch to Bypass                                                                                      2
* Place U2 Train "D"SG PORV Station Blackout PWR             1.1.1 ECOO Conditional Information switch to Bypass                                              Page (CIP)                              2
* Place U2 Train "B" SG PORV Station Blackout PWR switch to Bypass                                                                                     2.5
: 1. Plant Operations (status            1 switch Place U2  Train "C" SG PORV Station Blackout PWR to Bypass monitoring and EOP actions)     1.2      Lo tchSepasB 1.2 U2 Load Shed (2/18.13)
* De-energize  ESF Load Sequencers (ECO0 Addendum 4,                                                    3 Step 1.)
                                       "    De-energize  DP1 201 Components (ECOO Addendum 4,                                                     3 Step 2.b)                                               1.2.1 ECO0 Step 7.a
* De-energize  DP1 204 Components (ECO0 Addendum 4,                                                     3 Step 2.c)
                                       "    De-energize  120 VAC Non-1 E Loads (ECO0 Addendum 4,                                                 4.5 Step 3.)
Note: Duration times are rounded up to the nearest half-minute Timing for Load Shed actions and for placing SG PORV Station Blackout switches in bypass were taken from Operations walkthroughs documented on STI # 33099634, "EOP Local Actions, General Operator Action Transit Times."
Page 41

Enclosure NOC-AE-1 3003004 Page 42 of 42
.Attachment 3-        NEI 1-05'Appen'dix             &EnSitgnlyiReus...-
Extended Loss of All Power (ELAP)                                                   Position: Fire Brigade Member #4 (PO #10)                     Line #:1-19 Appendix E: Work Activities Analysis PlantiequLipmentIenvironmental~events and conditions           Task I Action Step description I applicableto thefunctions andjtasks           ,                (start & stop)        :..........   ..... .
Actions completed at U2 EAB 10'. Refer to section 4.3 for      Perform U2 in-plant ECOO actions: Place U2 Train "A"SG PORV Station 00:00      Actiondcondit U2                                               Blackout PWR switch to Bypass event and conditions description                               (00:00 - 00:02:30)
Actions completed at U2 EAB 10'. Refer to section 4.3 for      Perform U2 in-plant ECOO actions: Place U2 Train "D"SG PORV Station Actiond                                                        Blackout PWR switch to Bypass 00:03:30     event andcondit conditions d2 description                              (00:03:30- 00:05:30)
Actions completed at U2 EAB 35'. Refer to section 4.3 for      Perform U2 in-plant ECOO actions: Place U2 Train "B"SG PORV Station 00:06:30     Actiondcondit d2                                               Blackout PWR switch to Bypass event and conditions description                               (00:06:30- 00:08:30)
Actions completed at U2 EAB 60'. Refer to section 4.3 for      Perform U2 in-plant ECOO actions: Place U2 Train "C"SG PORV Station 00:09:30     eeti ndconditi        deAr6p'.R           t      i             Blackout PWR switch to Bypass event and conditions description                               (00:09:30- 00:12)
Actions completed at U2 EAB 10'. Refer to section 4.3 for      Perform U2 in-plant ECO0 actions: U2 Load Shed - De-energize ESF Load 00:13      event and conditions description                      .        Sequencers (00:13 - 00:16)
Perform U2 in-plant ECO actions: U2 Load Shed - De-energize DP1201 00:17      Actions completed at U2 EAB 10'. Refer to section 43 for       Components event and conditions description                               (00:17 - 00:20)
Perform U2 in-plant ECO0 actions: U2 Load Shed - De-energize DP1204 00:21      Actions completed at U2 EAB 60'. Refer to section 4.3 for      Components event and conditions description                               (00:21 - 00:24)
Actions completed at U2 EAB 10'. Refer to section 4.3 for      Perform U2 in-plant ECOO actions: U2 Load Shed - De-energize 120 VAC Non-00:25      event and conditions description                               1E Loads (00:25 - 00:29:30)
Note: Time 00:00 is the time an action is first assigned to the Plant Operator. This table documents the total time for the Plant Operator to perform all of their assigned actions - the actions are not necessarily performed in direct sequence.
Page 42}}