ML16021A459

Pilgrim - Proposed License Amendment Request to Modify Emergency Response Organization (ERO) Training for the On-Shift Chemistry Technician

ML16021A459
Person / Time
Site:	Pilgrim
Issue date:	01/14/2016
From:	Dent J A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.16.001
Download: ML16021A459 (94)

Text

Entegyi Nuclear OPoer SationsIc* 600 Rocky Hill Road PyotMA 02360 John A. Dent, Jr.Site Vice President January 14, 2016 U.S. Nuclear Regulatory Commission Attn: Docuriient Control Desk Washington, DC 20555-0001

SUBJECT:

Proposed License Amendment Request to Modify Emergency Response Organization (ERO) Training for the On-shift Chemistry Technician Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 LETTER NUMBER: 2.16.001

Reference:

1. PNPS Letter to NRC,

Subject:

"Emergency Plan Changes to the Minimum Staffing Requirements for the Emergency Response Organization (ERO)", dated July 14, 2006 (2.06.062).

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) hereby proposes to amend Operating License No. DPR-35 for the Pilgrim Nuclear Power Station (PNPS).The proposed license amendment reflects a change in the Emergency Response Organization (ERO) as it relates to staff training requirements applicable to the on-shift Chemistry Technician identified in Table B-I of the Site Emergency Plan (SEP). This change was reviewed by Entergy and determined to b.e a reduction in effectiveness of the PNPS SEP. This change i~s submitted to the NRC Staff in accordance with 10 CER 50.54(q).The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1).using criteria specified in 10 CFR 50.92(c), and Entergy has determined that this change involves no significant hazards consideration.

The bases for this determination are included in Attachment 1, which provides a description of the proposed change, a background discussion, a technical analysis, a regulatory analysis, and an environmental consideration review. Attachment 2 provides a copy of the current SEP Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization." Attachment 3 provides a comparison of proposed training and training previously proposed in letter Reference

1. Attachment 4 provides the current PNPS Emergency Response On-shift Staffing Analysis (OSA).

Letter 2.16.001 Page 2 Entergy requests approval of the proposed amendment by January 14, 2017. Once approved, Entergy will implement this amendment days.If you have any questions regarding the subject matter, please contact Everett P.Perkins at (508) 830-8323.This letter contains no new or revised regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct.Executed on the /'4" day of (_/2,j z ~,2016.A. Dent, Jr.;ite Vice President Attachment 1: Analysis of Proposed License Amendment Attachment 2: PNPS Emergency Plan Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization." Attachment 3: Chemistry Technician Training, 2006 Submittal vs 2016 Submittal Attachment 4: PNPS Emergency Response Organization On-shift Staffing Analysis cc: Ms. Booma Venkataraman, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission one White Flint North O-8C2-A 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 NRC Resident Inspector Pilgrim Nuclear Power Station John Priest, Director, Massachusetts Department of Public Health Radiation Control Program Commonwealth of Massachusetts 529 Main Street, Suite 1 M2A Charlestown, MA 02129-1121 John Giarrusso, Jr.Planning and Preparedness Section Chief Mass Emergency Management Agency 400 Worcester Road Framingham, MA 01702 ATTACHMENT 1 To Entergy Letter No. 2.16.001 Analysis of Proposed License Amendment (10 Pages)

Attachment I to PNPS Letter 2.16.001 ANALYSIS OF PROPOSED LICENSE AMENDMENT TABLE OF CONTENTS 1.0 DESCRIPTION 2.0 PROPOSED CHANGE 3.0 BACKGROUND 4.0 TECHNICAL ANALYSIS 5.0 REGULATORY ANALYSIS AND ENVIRONMENTAL REVIEW 5.1 Applicable Regulatory Requirements/Criteria 5.2 No Significant Hazards Consideration Determination 5.3 Environmental Consideration

6.0 REFERENCES

1 Attachment I to PNPS Letter 2.16.001 ANALYSIS OF PROPOSED LICENSE AMENDMENT 1.0 DESCRIPTION Pursuant to 10 CFR 50.90, "Amendment of License or Construction Permit at Request of Holder," Entergy Nuclear Operations, Inc. (Entergy) requests Nuclear Regulatory Commission (NRC) Staff review and approval of a revision to the Pilgrim Nuclear Power Plant (PNPS) Site Emergency Plan (SEP) to decrease the Emergency Response Organization (ERO) staff training provided for the "on-site" Chemistry Technician.

Entergy has reviewed the proposed changes against the standards in 10 CFR 50.47(b)and requirements in 10 CER 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." 2.0 PROPOSED CHANGE Entergy is proposing to revise the Emergency Response Organization (ERO) staff training requirements identified for the "on-shift" Chemistry Technician.

Attachment 3 identifies the proposed staff training requirements and provides a comparison to the training requirements previously identified in our 2006 submittal to the NRC Staff, dated July 14, 2006 (Reference 6.1).Subsequent review of the Pilgrim On-shift Staffing Analysis (OSA) dated December 2012 (Reference 6.3) and the job performance requirements for the "on-shift" Chemistry Technician indicate that previously identified training tasks and task qualification functions listed in the 2006 ERO submittal are not necessary for the "on-shift" Chemistry Technician to support the "on-shift" RP Technician function/position at the onset of an ERO event._Proposed Trainingc Chancie We are proposing that the scope of the Chemistry Technician job training that is needed to support initial "on-shift" RP Technician functions be limited to the following general RP support tasks: o Perform on-site radiation surveys o Perform on-site contamination surveys o Set up the Operations Support Center (RP Technician work area)o Issue dosimetry A list of plant specific training to support these functions is provided in Attachment

3.3.0 BACKGROUND

The specific standard for establishing a shift emergency organization to respond to emergency events appears in 10 CFR 50.47(b)(2) which states, in part, "On-shift facility 2 Attachment I to PNPS Letter 2.16.001 licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times..." 10 CFR Part 50, Appendix E, Section IV, requires licensee emergency plans to contain, in part, the organization for coping with radiological emergencies and the activation of the emergency organization.

NUREG-0654 (Reference 6.2),Section II.B, "Onsite Emergency Organization," presents guidance for meeting these requirements.

The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-I,"Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies." This table specifies a minimum of ten on-shift responders in four Major Functional Areas. It also specifies seven on-shift response tasks where the duties may be performed by shift personnel who are assigned other tasks (i.e., there are no dedicated responders to perform these tasks). -The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the site's emergency plan commitments.

The augmenting ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus more fully on plant operations.

NUREG-0654 guidance recommends that there be, in addition to on-shift personnel, 30 and 60-minute responders.

On November 23, 2011, the NRC published a final rule in the Federal Register amending certain' emergency preparedness (EP) requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 6.5). This final rule amended 10 CFR Part 50, Appendix E, Section IV.A, "Organization," to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions.

Specifically,Section IV.A.9 states that licensees shall perform "... a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan." Coincident with the rule change in 10 CFR 50, Appendix E, Section IV.A.9, the NRC issued NSIR/DPR-ISG-01, "Interim Staff Guidance -Emergency Planning for Nuclear Power Plants" (Reference 6.6). This Interim Staff Guidance (ISG) provides information relevant to performing the on-shift staffing analysis.

The ISG states that the Nuclear Energy Institute (NEI) developed the document NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose.The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

3 Attachment I to PNPS Letter 2.16.001 4.0 TECHNICAL ANALYSIS 4.1 Pilgrim-Specific Background Information The Pilgrim SEP (Rev 0) was originally issued in 1983. The SEP Table B-I plant staffing figure, indicated that one (1) "on-shift" RP Technician and one (1) "on-shift" 1 Chemistry Technician would be available for ERO response to support in-plant surveys and radio chemistry tasks under the Radiological Accident Assessment functional area.The SEP Table B-I was updated in 1990 (rev 10) and indicated a staff change from one (1) to two (2) "on-shift" RP Technicians in the Accident Assessment Support functional area. The purpose of the revision was identified as an editorial table change to credit the additional RP Technician that was listed in the Protective Action(s) (in Plant)functional area of the table and "to better reflect the format" of NUREG 0654. This SEP revision was submitted to the NRC (Reference 6.7).In a letter dated July 14, 2006 (Reference 6.1), Entergy proposed to the NRC Staff to substitute the "on-shift" Chemistry Technician for the second "on-shift" RP Technician to handleERO responsibilities during the first thirty (30) minutes of an event. As part of that proposal, Entergy stated that PNPS would (1) provide additional training for the "on-shift" Chemistry Technician(s);

and (2) remove the second "on-shift" RP Technician from the shift when appropriate training was provided for the "on-shift" Chemistry Technicians.

This prior SEP submittal supported the removal of one (1) of two (2) "on-shift" RP Technicians listed in SEP, Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization." This Table B-i change was consistent with our original 1983 SEP and the guidance contained in NUREG 0654/FEMA-REP-I., Rev. 1, dated November 1980 (Reference 6.2).In a letter dated February 5, 2007 (Reference 6.4), the NRC Staff responded to our July 14, 2006 request. The letter stated "The NRC staff has concluded that incorporation of the proposed changes do not decrease the effectiveness of the PNPS Emergency Plan and the plan, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to Title 10 Part 50 of the Code of federal Regulations.

The basis for our conclusion is contained in the enclosed safety evaluation.

In light of the above, no NRC approval is necessary." On the top of Page 3, the NRC Staff's SE restates the conclusion that the incorporation of the proposed changes do not decrease the effectiveness of the PNPS Emergency Plan and the plan, as changed, continues to meet standards of Section 50.47(b) and the requirements of Appendix E to 10 CFR 50.At Pilgrim Station since 2007, an on-shift Chemistry Technician supplements the on-shift Radiation Protection (RP) Technician in fulfilling the RP duties of the ERO during the early phase of ERO activation.

Four (4) additional RP Technicians are currently required to report to the site within 30 minutes, with the addition of four (4) more RP Technicians reporting to the site in 60 minutes. These additional RP Technicians provide support roles in the ERO Accident Assessment functional area after the first 30 4 Attachment I to PNPS Letter 2.16.001 minutes. In Reference 6.1, Entergy outlined to the NRC Staff the specific training to be provided to the Chemistry Technicians to support their fulfillment of the RP role for the early phase of ERG activation.

Recently, Entergy discovered we were not providing the in-depth training for the on-shift Chemistry Technicians as documented in our letter dated July 14, 2006. A condition report was written and immediate actions were taken to address the issue. Specifically, a second RP Technician was added to each shift to restore the staffing levels that were defined prior to F'ebruary 5, 2007 Table B-I revision.Subsequently, Entergy has determined we could provide a reduced scope of RP training for the on-shift Chemistry Technicians from that previously proposed in our 2006 ERG submittal.

The reduction in training is supported by the 2012 SEP On-shift Staffing An alysis (GSA) which is provided in Attachment 4 (Reference 6.3). The OSA evaluated the on-shift ERG staff positions and verified that assigned personnel can complete required ERG functions/tasks in a timely manner; The GSA does not rely on the on-shift Chemistry Technician to perform the required ERG functions/tasks specifically assigned to the on-shift RP Technician.

Entergy is proposing to reduce the level of training provided to the "on-shift" Chemistry Technicians who may be relied on to perform an initial ERG RP Technician support role.*The scope of training proposed in 2006 is documented in Reference 6.1 and summarized in Attachment 3.*The scope of training proposed in 2016 is identified in Attachment 3 and involves training in the following specific task areas.o Perform on-site radiation surveys o Perform on-site contamination surveys o Set up the Operations Support Center (RP Technician work area)o Issue dosimetry This revised training scope is consistent with the responsibilities and actions that would be required of the on-shift Chemistry Technician during the first 30 minutes of an ERG event consistent with the Gn-shift Staffing Analysis.4.2 Analysis of Reduced ERG Training Requirements for the "On-shift" Chemistry Technician The GSA provides the basis for a proposed reduction in on-site Chemistry Technician Training.

Section 2.14 of NEI 10-05 states "Although developed to meet the requirements of 10 CFR 50, Appendix E, Section IV.A.9, the staffing assessment methodology may be used to evaluate proposed changes to on-shift staffing levels or augmented ERG response times. For example, an analysis could be performed with a desired response time for the augmenting ERG (e.g., 90 minutes), and the results then used to support the basis for changing a staffing or augmentation time commitment." 5 Attachment I to PNPS Letter 2.16.001 The OSA indicates that the primary responsibility of the on-shift Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry sampling tasks were noted as being time critical in the first 90 minutes of~any of the analyzed events. As such, the Chemistry Technician is available to assist the RP Technician in performance of directed RP task work in the Operations Accident Assessment or Protective Action functional areas as determined appropriate by the Shift Manager.The OSA has ensured that the PNPS ERO team members can accomplish the required mission in the first 90 minutes of ERO activation with the staffing and training of on-shift staff members proposed herein. The OSA assumed that the RP and Chemistry Technicians are qualified to perform the range of tasks expected of their position.

The OSA does not credit additional RP training for the "on-shift" Chemistry Technician in order to ensure that the "on-shift" RP Technician can complete assigned emergency plan functions in a timely manner. As such, assignment of any additional RP training to the "on-shift" Chemistry Technician is not necessary and is considered to be an enhancement to the overall ERO organization.

The OSA is included in this submittal as Attachment

4. Based on the OSA, the proposed reduction in "on-shift Chemistry Technician training is acceptable and does not adversely affect the effectiveness of the PNPS Emergency Plan or the ability of assigned on-shift personnel to perform their assigned functions.

5.0 REGULATORY ANALYSIS AND ENVIRONMENTAL REVIEW 5.1 Applicable Regulatory Requirements/Criteria The regulatory standards, requirements and guidance involving ERO staffing and augmentation are as follows:,*10 CFR 50.47(b)(2)

-On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

• 10 CFR 50, Appendix E,Section IV.A (in part) -The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

• NRC Regulatory Guide 1.101, "Emergency Response Planning and Preparedness for Nuclear Power Reactors," Revision 5, Section C, stated in part"The criteria and recommendations in this regulatory guide are methods that the 6 Attachment 1Ito PNPS Letter 2.16.001 NRC staff considers acceptable for complying with the requirements in Appendix E to 10 CFR Part 50 and the planning standards in 10 CFR 50.47(b) that must be*met in onsite and offsite emergency response plans. These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness." In NUREG-0654,Section II, "Planning Standards and Evaluation Criteria," Evaluation Criteria ll.B.1 and ll.B.5 address the 10 CFR 50.47(b)(2) planning standard.

Evaluation Criteria ll.B. 1 specifies the on-site emergency organization of plant staff personnel for all shifts, and its relation to the responsibilities and duties of the normal shift complement.

Evaluation Criteria l1.B.5 states, in part, that: Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity.

For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," November 2011, describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.54(q).

In Section C.2.a.(2), the NRC encourages licensees to arrange a conference call with the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for EP changes to ERO staffing that reduce the licensee's capability to staff positions.

Entergy completed and issued an OSA to satisfy the requirements in 10 CFR 50, Appendix E, Section IV.A.9 and standards in 10 CFR 50.47(b)(2).

The OSA was performed using the guidance in NEI 10-05, which has been reviewed by the NRC and found to be an acceptable methodology to satisfy the regulatory requirement.

As a result of the OSA, Revision 44 of the SEP increased the minimum on-shift staffing level to fourteen (14). There were no changes implemented to revise the current on-shift RP and Chemistry Technician staffing listed in Table B-I. The OSA was conducted assuming a response time of 90 minutes for the augmented ERO to allow the use of this analysis for a possible future extension in ERO augmentation times as addressed in Section 2.14 of NEI 10-05. No specific emergency response tasks requiring the augmented ERO were identified in the OSA prior to the 90-minute period following the emergency declaration.

Based on the considerations above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will continue to be conducted in accordance with the site licensing basis, and (3) the approval of the proposed change will not be inimical to the health and safety of the public.7 Attachment I to PNPS Letter 2.16.001 In conclusion, Entergy has determined that the proposed training requirement change does not require any exemptions or relief from regulatory requirements, and does not affect conformance with any regulatory requirements or criteria.5.2 No Significant Hazards Consideration Determination Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.The proposed training requirements change has no effect on normal plant operation or on any accident initiator.

The change affects the response to radiological emergencies addressed in the SEP. The ability of the emergency response organization to respond adequately to radiological emergencies has been evaluated.

Changes in the training provided to the on-shift organization, such as the reassignment of key on-shift emergency personnel to perform related RP functions, provide assurance of an effective emergency response without competing or conflicting duties. An analysis was also performed on the effect of the proposed change on the timeliness of performing major tasks for the major functional areas of the SEP. The analysis concluded that the reduction in training requirements for the"on-shift" Chemistry Technician to support the initial RP support tasks does not affect the ability to perform the required RP Technician or Chemistry Technician tasks.Therefore, the change in ERG staff training does not increase the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No.The proposed change affects the training requirements for the "on-shift" Chemistry Technician and for supplementing onsite personnel in response to a radiological emergency.

It has been evaluated and determined not to significantly affect the ability to perform required or related functions.

It has no effect on the plant design or on the normal operation of the plant and does not affect how the plant is physically operated under emergency conditions.

The reduction in ERG training requirements for the "on-shift" Chemistry Technician in the SEP does not affect the plant operating procedures which are performed by plant staff during all plant conditions.

8 Attachment I to PNPS Letter 2.16.001 No new or different accidents are postulated to occur and there are no changes in any of the accidents previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change does not affect plant design or method of operation.

10 CFR 50.47 (b) and 10 CFR 50 Appendix E establish emergency planning standards and requirements that require adequate staffing, satisfactory performance of key functional areas and critical tasks, and timely augmentation of the response capability.

Since the SEP was originally developed, there have been improvements in the technology used to support the SEP functions and in the capabilities of onsite personnel.

A functional analysis was performed on the effect of the proposed change on the timeliness of performing major tasks for the functional areas of the SEP. The analysis concluded that a reduction in training requirements for the "on-shift" Chemistry Technician would not significantly affect the ability to perform the required SEP tasks. Thus, the proposed change has been determined not to adversely affect the ability to meet the emergency planning standards as described in 10 CER 50.47 (b) and requirements in 10 CFR 50 Appendix E.The proposed ERO staff training change does not involve a reduction in any margin of safety. The proposed change is consistent with the original and current ERO staffing levels implemented at PNPS.Based on the above, Entergy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.Environmental Consideration The proposed changes do not involve (i) a significant hazards consideration, (ii) any changes in the types or any increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

9 Attachment I to PNPS Letter 2.16.001 6. REFERENCES 6.1. Entergy Letter to the NRC, "Emergency Plan Changes to the Minimum Staffing Requirements for the Emergency Response Organization (ERO)", dated July 14, 2006 (Ltr 2.06.062)6.2. NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, published November 1980.6.3. Pilgrim Nuclear Power Station, 10 CFR 50 Appendix E, On-Shift Staffing Analysis Final Report, dated December 20, 2012. Incorporated by reference in Emergency Plan Rev 40, submitted to NRC on January 14, 2013 (Ltr 2.13.001).

6.4. James Kim (USNRC) Letter to Mr. Michael Kansler (Entergy), "Pilgrim Nuclear Power Station -Revision to Emergency Plan to Change Emergency Support O~rganizatiOn Staffing", (TAC No. MD2814) dated February 5, 2007 6.5. Federal Register Volume 76, Number 226, Wednesday, November 23, 2011, Rules and Regulations, "Enhancements to Emergency Preparedness Regulations; Final Rule." 6.6. NSIR/DPR-ISG-01, "Interim Staff Guidance -Emergency Planning for Nuclear Power Plants," Revision 0, November 2011 (ADAMS Accession Number ML1l13010523).

6.7. Entergy Letter to the NRC, "10 CFR 50, Appendix E, Section V,: Submittal of Revised Emergency Plan or Emergency Plan Implementing Procedures", dated January 30, 1991 (Ltr 2.91 .007)10 ATTACHMENT 2 To Entergy Letter No. 2.16.001 PNPS Emergency Plan Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization" (1 Page)

Attachment 2 to PNP.S Letter 2.16.001 PNPS EMERGENCY PLAN Table B-1i: Minimum Staffino Renuirements for the PNPS ERO-(1)Functional Area Major Task TOnshift Position Title Rs+/-Pos.No. ________________

ponse Plant. Operations Plant Stabilization

+/- 1 Shift Manager On Shift#Assessment of Operational Accident Mitigation 2 Control Room Supervisor On Shift#Aspects 3,4 Lic. Nuc. Plant Operator (2) On Shift#______________________

5.6 Unlic. Nuc. Prant Operator (2)**FB On Shift#"Emerg'ency Direction Emergency Classification j1) Shift Manager On Shift#Emergency Control PARs t (1) Shift Manager On Shift#IEmergency Director 60 mai.

Plant Ops Supv 60 min.Notification and Notification of PNPS, Local, (1) Shift Manager On Shift#Communications Commonwealth, and Federal personnel 7 Unlic. Nuc. Plant Operator On Shift#and Maintain Communications Offsite Communicator 30 min.EOF Communicator 60 min.ENS Communicator 60 mai.Rad Accident Assessment!....

EOF Direction EOF Managter, 60 mai.Ops Accident Assessment Offsite Dose Assessment (8) RP Technician***

On Shift#Support (9) Radio Chem. Technician**" On Shift#Radiolog:ical Assessment Coord 30 mai.Offsite Surveys OMT Member (2) 30 mai.OMT Member (2) 60 min.Onsite and'ln-plan't Surveys 8 RP Technician On Shift#RP Technician (2) 30 min.RP Technician (2) 60 mmn.Chemistry

/ Radiochemistry 9 Radio Chem. Technician On Shlft#_____Radio Chem. Technician 60 mai.Plant System Engineering TSC / OSC Direction Emergency Plant Manager 60 mai.Repair and Corrective Actions Technical Support 10 Engineer (Shift Control Rm)* On Shift#Engineer (Reactor) 30 mai.Engineer (Mechanical) 60 mai._________________________Englineer (Electrical) 60 min.Eguipment Repairs _____Nuclear Maint. Technician 30 min.Corrective Actions Nuclear Maint, Technician 60 main 11 Unlic. Nuc. Plant Operator On Shift#12 Nuc. Plant Reactor Operator m*FB On Shift#Nuc. Plant Reactor Operator 60 min.Nuclear Maint. (ElectnicalX2) 30 mai.Nuclear Maint. (Electrical) 60 min.___________________

________________________________Nuclear Control Technician(2) 30 mai.Protective Actions (In Plant) Radiation Protection, Access Control, (8), (9) RP Technician (2)*0 On Shift#RP Coverage, Personnel Monitoring, RP Technician (2) 30 mai.and Dosimetry

_____RP Technician (2) 60 mai.Fire Fighting 13, 14 Fire Brigade*, (3 **, 2 [NLO or Sec]) On Shift#____________________

_____Plymouth Fire Dept. On Call Rescue Ops and First Aid On Shitt#___________________

________________________Ambulance Service ... On Call Site Access Control and Security Security Force* On Shift#Personnel Accountability

_____________________un onirt -person as saiu ro oe on snurt wnen, ounng normar or au~nonrzeo oventime nours, that person is witnin tie PNPS owner controlled areas or on the connecting roads between them with Station Management approval.* Position staffed In accordance with technical specifications.

• • Position staffed in accordance with technical specifications and station procedures.

• • May be provided by shift personnel assigned other functions.

.. .(EMP) Emergency Medical Personnel:

individuals qualified as EMPs, RNs, First Responders, and Paramedics.

NOTES: Response times are based on optimum travel conditions.

On Shift Position #7 is Assistant to Offsite Communicator and can be replaced by an SRO that is qualified for the task.On Shift Position #11 can be filled by an RO or SRO that is gualified for the task On Shift Positions

1. 13 and #14 are available to support Shift Manager, where qualified, in non-fire events.(1) Thls table B-i is incorporated Into the Emergency Plan In accordance with USNRC Generic Letter 82-33 dated 12/17/82 and Incorporates within 30 days of approval the conclusions of the PNPS On Shift Staffing Analysis Report which is a part of the Emergency Plan in accordance with 10CFR5O Appendix E,Section IV. A. 9 and maintained as a separate document.B-7 Revision 44 ATTACHMENT 3 To Entergy Letter No. 2.16.001 Chemistry Technician Training 2006 Submittal vs 2016 Submittal (3 Pages)

Attachment 3 to PNPS Letter 2.16.001 Augmented Radiological Protection (RP) Training needed for the "On-Shift" Chemistry Technician to Support Initial ERO Duties (during first 30 minutes)NUREG 0654 Chemistry Technician Training Chemistry Technician Training Justification for Reduced Training I Table B-I Identified in 2006 Submittal Identified in 2016 Comments"On-Shift" (See OSA Analysis notes below)Task On-site

• Operations Support Center Pool

• Operations Support Center Pool *The 2012 OSA ensured that PNPS and In- Member Qualification Member Qualification ERO team members can accomplish Plant

• Respirator User Qualification

• Perform Radiation Surveys the required mission in the first 90 Surveys

• Self-Contained Breathing Apparatus

• Perform Contamination Surveys minutes of ERO activation with the User Qualification

• Operate Basic Dose Rate Meters current on-shift ERO staff defined in* Walkdown EOP-4 survey point * -Operate Basic Count Rate Meters Table B-I.locations* Perform Radiation Surveys* Perform Contamination Surveys* Collect an Airborne Radioactivity Sample* Analyze Smears for contamination levels* Analyze Air Samples* Operate Basic Dose Rate Meters* Operate Basic Count Rate Meters* Operate the Scintillation Alpha Counter* Operate the Beta Counter* Operate the Gamma Spec System* Operate the Regulated Air Sample Pump* Operate the Radeco Air Sampler 1 Attachment 3 to PNPS Letter 2.16.001 Augmented Radiological Protection (RP) Training needed for the "On-Shift" Chemistry Technician to Support Initial ERO Duties (during first 30 minutes)NUREG 0654 Chemistry Technician Training Chemistry Technician Training Justification for Reduced Training /Table B-I Identified in 2006 Submittal Identified in 2016 Comments"On-Shift" (See OSA Analysis notes below)Task Access *Operations Support Center Pool

• Operations Support Center Pool *The 2012 OSA ensured that PNPS Control Member Qualification Member Qualification ERO team members can accomplish

• Control High Radiation Areas the required mission in the first 90* RWP Briefing minutes of ERO activation with the* Perform Stay Time Calculations current on-shift ERO staff defined in* Issue and Return Respirators Table B-i.RP .Operations Support Center Pool

• Operations Support Center Pool *The 2012 OSA ensured that PNPS Coverage Member Qualification Member Qualification ERO team members can accomplish for repair,

• Respirator User Qualification

• Perform Radiation Surveys the required mission in the first 90 corrective

• SCBA User Qualification

• Perform Contamination Surveys minutes of ERO activation with the actions,

• RP Job Coverage

• Operate Basic Dose Rate Meters current on-shift ERO staff defined in search and

• Control High Radiation Areas

• Operate Basic Count Rate Meters Table B-I.rescue first

• RWP Briefing aid & Perform Stay Time Calculations firefighting

• Perform Radiation Surveys* Perform Contamination Surveys* Collect an Airborne Sample* Analyze Smears* Analyze Air Samples* Operate Basic Dose Rate Meters* Operate Basic Count Rate Meters* Operate the SAC-4* Operate the BC-4* Operate the Gamma Spec System* Operate the RAS Pump* Operate the Radeco* Perform RP Duties in Response to a Plant Fire___________________

2 Attachment 3 to PNPS Letter 2.16.001 Augmented RadiologQical Protection (RP) Training needed for the "On-Shift" Chemistry Technician to SupDport Initial ERO Duties (during first 30 minutes)NUREG 0654 Chemistry Technician Training Chemistry Technician Training Justification for Reduced Training /Table B-I Identified in 2006 Submittal Identified in 2016 Comments"On-Shift" (See OSA Analysis notes below)Task Personnel

• Operations Support Center Pool

• Operations Support Center Pool

• The 2012 OSA ensured that PNPS Monitoring Member Qualification Member Qualification ERO team members can accomplish

• RP Job Coverage the required mission in the first 90* RWP Briefing minutes of ERO activation with the* Perform Personnel Decontamination current on-shift ERO staff defined in Table B-I.Dosimetry

• Operations Support Center Pool

• Operations Support Center Pool

• No effective change is identified Member Qualification Member Qualification

• Issue and Control Personnel

• Issue Dosimetry Dosimetry OSA Notes: 1. The 2012 OSA satisfies the requirements of 10 CFR 50 Appendix E Section IV.A.9. A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities.

This analysis examined the capability of the minimum staff listed in Table B-i of the PNPS Emergency Plan (E-Plan) to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-plan.2. The OSA review team determined that an on-shift staff of fourteen (14) is required to respond to the most limiting accident scenario reviewed, main control room fire and shutdown at the remote shutdown panel.3. NEI 10-05 staffing analysis of on-shift personnel to perform the required emergency planning functions and the licensing basis requirement for each on-shift position.

NEI 10-05 recommends one (1) on-shift RP Technician and one (1) on-shift Chemistry Technician.

The PNPS SEP is consistent with the NEI guidance.4. The primary responsibility for the Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being time critical or required during the first 90 minutes of any of the analyzed events.5. The 2012 OSA analysis included a review of the implementation of the requirement to maintain continuous communications with the notification source during an aircraft threat in accordance with 10CFR50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The review of the Aircraft Threat Accident identified that there are sufficient personnel on-shift to perform this action during the event, Specifically, a licensed or non-licensed nuclear plant operator, the rad protection technician, and chemistry technician were all available to fill this function.6. Augmentation time for some ERO positions is 30 minutes. The OSA analysis was completed for the 90 minute period since the emergency response facilities are required to be operational in 60 minutes. No credit was taken for current 30 minute responders.

Tasks for event response were reviewed for 90 minutes following the declaration.

No specific emergency response tasks requiring the augmented ERO were identified during the 90 minutes following the emergency declaration.

7. The 2012 OSA assumed individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.

ATTACHMENT 4 To Entergy Letter No. 2.16.001 PNPS Emergency Response Organization On-Shift Staffing Analysis (74 Pages)

PNPS ON-SHIFT STAFFING ANALYSIS REPORT ENTERGY PILGRIM NUCLEAR POWER STATION 10CFR5O APPENDIX E ON-SHIFT STAFFING ANALYSIS FINAL REPORT December 20, 2012 Prepared by: Myra Jones Fred Guynn PNPS ON-SHIFT STAFFING ANALYSIS REPORT TABLE OF CONTENTS I. INTRODUCTION.....................................................................................

4 II. ANALYSIS

SUMMARY

.............................................................................

4 A. Emergency Plan Minimum Staffing....................................................................

5 B. Other Commitments to Shift Staffing...........................................................

....... 6 C. Staffing Exceptions and Time Motion Studies (TMS) ..............................................

6 D. Emergency Plan Tasks Not Analyzed ................................................................

7 III. ANALYSIS PROCESS ..............................................................................

8 IV. ACCIDENT SCENARIOS

...... .....................................................................

9 A. Accident Selection........................................................................................

9 B. Accident Scenarios included in the Analysis ,......................................................

..9 C. Accident Scenarios Not Included in the Analysis ..................................................

10 V. GENERAL ASSUMPTIONS AND LIMITATIONS................................................

11 A. Notes and Assumptions Applicable to Pilgrim OSA: ..............................................

11 B. NEI 10-05 Assumptions

..................

.........

...................................................

11 VI. APPENDIX A -ANALYZED EVENTS AND ACCIDENTS

.....................................

14 Vii APPENDIX B -ON-SHIFT STAFFING ANALYSIS.............................................

16 A. Accident Analysis #1 -Design Basis Threat (DBT)...............................................

16 B. Design Basis Accident Analysis #2 -Control Rod Drop Accident..............................

21 C. Design Basis Accident Analysis #4 -Loss of Coolant Accident................................

27 D. Design Basis Accident Analysis #5 -Main Steam Line Break ..................................

33 E. Design Basis Accident Analysis #6 -Fuel Handling Accident ..................................

39 F. Accident Analysis #8 -Aircraft Probable Threat ..................................................

45 G. Accident Analysis #9 -Control Room Evacuation and Alternate Shutdown..................

51 H. Accident Analysis #10 -Station Blackout...........................................................

57 I. Accident Analysis #11 -LOCA/General Emergency with Release and PAR ................

63 VIIIAPPENDIX C TIME MOTIONS STUDIES.......................................................

69 A. TMS Shift Manager Safe Shutdown Task...........................................................

69 PNPS Page 2 PNPS ON-SHIFT STAFFING ANALYSIS REPORT IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED

...............

73 A. Overlap Requiring Compensatory Measures .....................................................

73 X. REFERENCES

...................................................................................

74 XI. STAFFING ANALYIS TEAM ....................................................................

74 PNPS Page 3 PNPS Page 3 PNPS ON-SHIFT STAFFING ANALYSIS REPORT I. INTRODUCTION This report is the finai report for the On-shift Staffing Analysis (OSA) that commenced at Pilgrim Nuclear Power Station (PNPS) during the week of March 19 -22, 2012. This OSA satisfies the requirement of 10 CFR 50 Appendix E Section IV.A.9, which states that nuclear power licensees shall perform "a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. "A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities.

This analysis examined the capability of the minimum staff listed in Table B-I of the PNPS Emergency Plan (E-Plan) to perform the actions for the key functional areas of events described in NSIRIDPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-plan.I. ANALYSIS

SUMMARY

The OSA team determined that an on-shift staff of fourteen (14) is required to respond to the most limiting accident scenario reviewed, main control room fire and shutdown at the remote shutdown panel. The on-shift staff consists of individuals necessary to support each of the E-Plan functional areas or tasks:* Emergency Direction and Control* Plant Operations and Safe Shutdown (SSD)* Fire Fighting (FB)* Accident Assessment

• Radiation Protection and Chemistry* Notification/Comnmunication

• Technical Support* Accountability NEI 10-05 states it is acceptable for certain functions or tasks to be assigned to personnel already assigned other primary functions/tasks.

These include Repair and Corrective Action, Rescue Operations and First Aid.PNPS Page 4 PNPS Page 4 PNPS ON-SHIFT STAFFING ANALYSIS REPORT A. Emergency Plan Minimum Staffing Per 10 CFR 50.54 (q)(1)(iii), Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV of Appendix E and, for nuclear power reactor licensees, the planning standards of § 50.47(b).The following table indicates the result of the NEI 10-05 staffing analysis of on-shift-personnel to perform the required emergency planning functions and the licensing basis requirement for each on-shift position.Licensing Basis On-Shift Position 4 Requirement E-Plan Functional Area Staffing Analysis Results 50.54m Emergency Direction and Shift Manager (SM) E-plan Table B-I Control SSD (TMS for SSD1 actions)Control Room Supervisor 50.54m (CRS) E-plan Table B-I1S Shift Control Room E-plan Table B-I1ehia upr Engineer (STA)Licensed Nuclear Plant 50.54m SSD -Operator (RO #1 ) E-plan Table B-i Licensed Nuclear Plant 50.54m SSD1 Operator (RO #2) E-plan Table B-i Non-Licensed Nuclear E-plan Table B-i SSD 2 Plant Operator (NLO #1")1 Non-Licensed Nuclear E-plan Table B-i E-Plan Communicator Plant Operator (NLO #2)______

Notifications 3 1 Non-Licensed Nuclear E-plan Table B-i1B Plant Operator (NLO #3)Non-Licensed Nuclear E-plan Table B-i1B Plant Operator (NLO #4)Non-Licensed Nuclear E-plan Table B-i1B PlantOperator_(NLO_#5)

_________Chemist E-plan Table B-1 Accident1 Assessment/Chemistry1 RP #1 E-plan Table B-i Radiation Protection 1 Fire Brigade #11 E-plan Table B-i FB 1 Fire Brigade #21 E-plan Table B-i FB 1 E-plan Table B-i Per Security Security Security Accountability Contingency

_____________

Contingency Plan _____________

Plan TOTAL 14 1 Fire Brigade #1 and Fire Brigade #2 positions did not have any actions or tasks identified in this OSA other than Fire Brigade. These on-shift members (e.g., NLO, Security) are available to support the Shift Manager, where qualified, in non-fire events.2 SSD NLO can be filled by RO or SRO.3 E-Plan Communicator can be replaced by SRO that is qualified for the task.4 One of the 5 NLOs is a Radwaste Operator PNPS Page 5 PNPS ON-SHIFT STAFFING ANALYSIS REPORT I-7 B. Other Commitments to Shift Staffing None C. Staffing Exceptions and Time Motion Studies (TMS)1. The primary responsibility for the Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being time critical or required during the first 90 minutes of any of the analyzed events. It is therefore acceptable to assign the Chemistry Technician the E-Plan function of dose assessment.

In addition, the RP Technician shares the responsibility for dose assessment.

It is recognized, however, that the Shift Manager will prioritize and utilize the on-shift staff as needed for RP, Chemistry and dose assessment.

No further analysis or TMS is required.2. The Shift Manager is assigned the responsibility to make some notifications per procedure 1.3.12. The notifications by phone are considered communications that are approximately one minute in length and are acceptable tasks for the Shift Manager. No further analysis or TMS is required.3. The analysis included a review of the implementation of the requirement to maintain continuous communications with the notification source during an aircraft threat in accordance with 10OCFR50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The review of the Aircraft Threat Accident identified that there are sufficient personnel on-shift to perform this action during the event. Specifically, a licensed or non-licensed nuclear plant operator, the rad protection technician, and chemistry technician were all available to fill this function.

No further analysis TMS is required.4. A time motion study was completed for the Shift Manager action to perform the safe shutdown actions to initiate a scram and close the MSIVs by manipulating RPS breakers and pulling fuses. The Shift Manager leaves the control room and passes the equipment on the way to the Technical Support Center. The Shift Manager demonstrated the safe shutdown actions can be completed in approximately six (6) minutes while maintaining emergency direction and control through radio contact with other operators aligning safe shutdown equipment.

Details of the TMS are found in section VIII Appendix C.PNPS Page 6 PNPS Page 6 PNPS ON-SHIFT STAFFING ANALYSIS REPORT D. Emergency Plan Tasks Not Analyzed:' 1. Repair and Corrective Action -Per the guidance of NUREG-0654, Table B-I, repair and corrective action tasks may be performed by dedicated shift personnel or qualified shift personnel assigned other functions/tasks.

Repair and corrective action is defined as:*An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete.In accordance with NEI 10-05 section 2.5, the analysis included a review of the repair and corrective action tasks. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

• Unplanned/unexpected actions that address equipment failures.

These actions are contingent in nature and cannot be specified in advance.* Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

At PNPS, a Nuclear Plant Reactor Operator on shift will primarily be available to the Shift Manager to perform actions to assist in controlling/mitigating the event.Initial corrective actions are contained in and controlled by plant operating procedures.

The Nuclear Plant Operators have been trained to perform specific actions within the Abnormal and Emergency Operating Procedures and maintenance support is not required.

Maintenance is not included in the on-shift staff. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed 2. Rescue Operations and First Aid: in accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response.

Per the guidance of NUREG-0654, Table B-i, rescue operations and first aid may be performed by shift personnel assigned other functions/tasks.

The fire brigade members (NLOs) are trained to perform rescue operations and are assigned the task should the need arise. Additionally, select Security staff members are trained to First Responder standards and meet the basic requirements to render first aid and CPR. Should first aid be required during a hostile action security event, first aid actions will be performed after the security threat is neutralized and the site is secure. Rescue operations and first aid were not required in any of the accident scenarios reviewed.

Rescue operation and first aid are acceptable collateral duties per the guidance of NEI 10-05 and was not analyzed.PNPS Page 7 PNPS Page 7 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Ill. ANALYSIS PROCESS This analysis was conducted by a joint team of corporate Emergency Preparedness (EP)personnel and station personnel from the Operations, Operations Training, EP Training, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments.

Additionally, personnel from Security provided input to the analysis when necessary.

The team members are identified in Section Xl of this report.The emergency response to each event scenario was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures.

Each scenario was reviewed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation.

These actions were then compared to the minimum staffing for Emergency Plan implementation as described in the Emergency Plan Table B-I, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate.

In cases where multiple tasks were assigned to an individual in their role, the team evaluated timing of the' tasks to ensure that they could be performed by the individual in series within any specified time requirements.

The results of the analysis for each of the scenarios are included in Section VII, APPENDIX B -ON-SHIFT STAFFING ANALYSIS.

Note that NSIR DPR-ISG-01 states that only DBA accidents"which would result in an emergency declaration" should be evaluated in the staffing assessment.

Each of PNPS DBA's were evaluated and classified according to its FSAR Chapter 14 description.

If the accident description alone did not result in a classification, the projected accident EAB dose found in the ESAR was utilized to determine if an EAL threshold would be exceeded within the first 60 minutes using the Abnormal Rad Level EAL thresholds.

In cases where several projected dose rates were provided or release data was not detailed significantly to determine an EAL, the assessment used the radiological consequences associated with the realistic case in accordance with NEI 10-05.PNPS Page 8 PNPS Page 8 PNPS ON-SHIFT STAFFING ANALYSIS REPORT IV. ACCIDENT SCENARIOS A. Accident Selection 1. The OSA scenarios were chosen using the guidance of NE1 10-05 and NSIR/DPR-ISG-01, "interim Staff Guidance -Emergency Planning for Nuclear Power Plants." The evaluation considered the station Design Basis Accidents (DBA) described in the FSAR along with additional scenarios specified by the guidance documents.

The scenarios considered were:* Design Basis Threat (DBT) ground assault* DBA Control Rod Drop Accident* DBA Loading Error Accident* DBA Loss of Coolant Accident* DBA Main Steam Line Break Accident* DBA Fuel Handling Accident* DBA Radwaste System Accident* Aircraft Probable Threat* Fire Requiring Evacuation of the Control Room and Plant Shutdown From Alternate Location,* Station Blackout, (SBO)* LOCA/General Emergency with release and PAR a LOCA with entry into Severe Accident Management

• Fire Resulting in Reactor Trip (Appendix R fire)B. Accident Scenarios included in the Analysis 1. Design Basis Threat as described in NE! 10-05* Land and/or waterborne Hostile Action directed against the Protected Area by a Hostile Force. This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed 2. Control Rod Drop Accident as described in FSAR 14.5.1* One control rod drops and reactor trips on APRM 120% flux scram.Credit is not taken for MSIV closure. Release pathway is through condenser, turbine building then to environment.

EAL is based on condenser release information in FSAR.3. Loss of Coolant Accident as described in FSAR 14.5.3* Double ended guillotine break of a recirculation line. All ECCS operate-as designed.

EAL is based on fission product barrier EALs.4. Main Steam Line Break Accident as described in FSAR 14.5.4* Break of one main steam line and followed by MSIV closure. Release is to the atmosphere through the top of the turbine building (puff release).PNPS Page 9 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Reactor coolant activity at TS limit. No EAL On the accident but on the USAR EAB 2-hr dose.5. Fuel Handling Accident as described in FSAR 14.5.5* The accident involves a dropped fuel bundle on top of the core. Initial EAL is based on the event.6. Aircraft Probable Threat (50.54hh)* Notification is received from the NRC that a probable aircraft threat exists (>5 minutes, <30 minutes)7. Control Room Fire and Alternate Shutdown* A fire occurs in the main control room requiring the evacuation and the procedure implemented to perform shutdown from the alternate shutdown panels.8. Station Blackout* A loss of all offsite AC power occurs and the failure of the emergency diesel generators.

9. General Emergency with release and "PAR* Assume GE condition with dose projection indication of a release greater than the protective action guideline (PAG).C. Accident Scenarios Not Included in the Analysis 1. Loading Error Accident as described in ESAR 14.1.5.2* Misloaded bundle in the core. No EAL condition is met.2. Radwaste System Accident as described in FSAR 14.5.6* No EAL condition is met.3. Implement SAMG* A review of the SAMGs associated with the initial site-specific Candidate High Level Actions concluded that no actions would require on-shift personnel other than licensed and non-licensed operators.

No analysis required.4. Appendix R Fire* Fire leading to reactor trip with complications.

The control room fire and alternate shutdown requires more resources and actions outside the control room than this fire. The team concluded the control room fire bounds the fire analysis.

No additional analysis required.PNPS Page 10 PNPS Page 10 PNPS ON-SHIFT STAFFING ANALYSIS REPORT V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions Applicable to Pilgrim OSA: 1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Abnormal Operating Procedures (AOP), Emergency Operating Procedures (EOP), and Emergency Implementing Procedures (EIP).Any additional tasks directed by the Technical Support Center (TSC), Operations Support Center (OSC), or Emergency Operations Facility (EOF') procedures were not reviewed.2. The augmentation time for some ERO positions is 30 minutes. The analysis was completed for the 90 minute period since the emergency response facilities are required to be operational in 60 minutes. No credit was taken for 30 minute responders.

Tasks for event response were reviewed for 90 minutes following the declaration.

No specific emergency response tasks requiring the augmented ERO were identified during the 90 minutes following the emergency declaration.

3. The OSA team determined there are no time critical RP and Chemistry tasks and that task performance is directed and prioritized by the Shift Manager. The time RP or Chemistry is directed to perform a task and the amount of time taken to complete tasks are estimated.

No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration.

Since the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.4. All crews have one individual filling the SM and one individual filling the STA roles therefore the analysis did not consider using a dual-role individual.

B. NEI 10-05 Assumptions

1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task. (60 mmn.)2. On-shift personnel complement was limited to the minimum required number and composition as described in the site emergency plan. If the plan commitments allow for different minimum staffing levels (e.g., a variance between a normal dayshift and a backshift), use the staffing with the smallest total number of personnel.

3. Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.4. Event occurred during off-normal work hours where ERO was offsite and all required minimum on-shift positions were filled.5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.PNPS Page 11 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 6. On-shift staff has necessary Radiation Worker qualification to obtain normal dosimetry and enter the RCA (but not locked high or very high radiation areas)without the aid of a RP technician.

7. Personnel assigned plant operations and safe shutdown meets the requirements and guidance (analyzed through other programs such as operator training) and was evaluated as part of this assessment unless a role/function/task from another major response area was assigned as collateral duty.8. In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain safe shutdown was done by a member of the on-shift staff as defined in the unit's Tech Specs.9. Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.10. Individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.11. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.12. Communications, briefings, and peer checks are acceptable collateral duties.13. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIRIDPR-ISG-01]14. The Staffing Analysis specified the resources available to perform "Repair and Corrective Actions" and "Rescue Operations and First Aid" but these may be assigned as collateral duty to a designated on-shift responder.

15. For assessment purposes, NRC notifications were treated as a continuous action per 10OCFR50.72(c)(3) and 73.71 (b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.16. DBA (postulated accident, Condition IV event, or limiting fault) is considered as"Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation.

As a result, a greater number and variety of actions would need to be implemented by plant personnel." 17. Unless otherwise specified in NSIR/DPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants, or by the FSAR initial conditions of a DBA analysis, it was assumed that the unit was in Mode 1, Power.PNPS Page 12 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 18. DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequen~ces to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to prevent safe shutdown or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.19. The Staffing Analysis used DBA analysis assumptions, inputs, and timing of events as documented in the FSAR.20. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began at the time of declaration of the initiating event.21. Severe Accident Management Guideline (SAMG) -It is sufficient to simply assume that the accident progressed to conditions requiring a severe accident response; it is not necessary to determine specific failures and the accident sequence.22. SAMG -The actions to be analyzed include those that implement the initial site-specific actions assuming the core is no ex-vessel (i.e., no reactor vessel failure), and there is not actual or imminent challenge to containment integrity.

PNPS Page 13 PNPS Page 13 PNPS ON-SHIFT STAFFING ANALYSIS REPORT VI. APPENDIX A -ANALYZED EVENTS AND ACCIDENTS E e t E e t S~ummary Descriptioniof~i Plant... .... ...... '"== ..:I ....:* : Refe~rence = ......' "= '

iEn t ype- ::::::: :;:, Event.Mode..Document:s)

Event ECL.1 DBT Land and/or waterborne 1 NEI 10-05 Site Area Yes HOSTILE ACTION Emergency directed against the ISG IV.C Protected Area by a HOSTILE FORCE.2 DBA Control Rod Drop Accident 1 FSAR 14.5.1 Site Area Yes Emergency 3 DBA Loading Error Accident 1 FSAR 14.5.2 None Noz (misloaded bundle in the______core) 4 DBA Loss of Coolant Accident 1 FSAR 14.5.3 General Yes______Emergency 5 DBA Main Steam Line Break 1 FSAR 14.5.4 Site Area Yes Emergency 6 DBA Fuel Handling Accident 5 FSAR 14.5.5 Site Area Yes Emergency 7 DBA Radwaste System 1 FSAR 14.5.6 None Accident 8 Assumed Aircraft Probable Threat 1 10CFR50.54hh Alert Yes for (1)analysis purpose RG 1.214 9 Assumed Control Room Evacuation 1 FSAR 14.6.1 Alert Yes for and Alternate Shutdown Analysis (fire in main control room) I0CFR50 Purpose Appendix R Fire Hazard Analysis 10 Assumed Station Blackout 1 ISG IV.C Site Area Yes for Emergency analysis purpose 11 Assumed LOCA -General 1 ISG IV.C General Yes for Emergency with Emergency Analysis radiological release and____Purpose PAR 12 Assumed LOCA with entry into 1 ISG IV.C General for severe accident Emergency Analysis procedures.

Purpose ________________________

_____PNPS Page 14 PNPS Page 1.4 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 13 Assumed Appendix R Fire I ISG IV.C AlertNo for Analysis____ Purpose _____________

____ _______1 Plant mode per FSAR or assumed for anaiysis purpose 2 No EAL met on plant condition or dose.3 pNPS does not meet the NEI110-05 intent for the analysis of implementing SAMG. NEI 10-05 Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators.

The actions assessed by NEI 10-05 are those which implement the initial site-specific Candidate High Level Action assuming the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent challenge to containment integrity.

PNPS does include maintenance qualified to perform maintenance job tasks in minimum staffing and does not have contingency actions that must be completed by maintenance in the severe accident procedures.

4 Appendix R Fire is bound by the Control Room Fire and Alternate Shutdown.

Analysis is not required.PNPS Page 15 PNPS Page 15 PNPS ON-SHIFT STAFFING ANALYSIS REPORT VII. APPENDIX B] -ON-SHIFT STAFFING ANALYSIS A. Accident Analysis #1 -Design Basis Threat (DBT)1. Accident Summary* Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat. Security Code Red condition 2. Accident Specific Assumptions Made* This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.* Assume at power in Mode 1* Security notifies the Shift Manager of condition Security Code RED.* Assume all non-security staff is located inside the protected area at their normal work station when the event occurs.* Assume all systems function and the core remains covered. No fuel damage and no release.3. Procedures Reviewed for Accident Response* Procedure 5.3.14, Security Incident* EP-IP-1 00, Classification and Notifications

• EP-IP-1 00.1, EAL* EP-IP-410, Evacuation and Assembly* Procedure 2.1.6, Reactor Scram PNPS Page 16 PNPS Page 16 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables PNPS TABLE V-ON-SHIFT POSITION T2/L1 T5/L1 T5/L3 1 Shift Manager Emergency Plan 60 T5/L5. No Yes Table B-i T5/L6 T5/L8 T5/L10________________

_______________T5/L 14 _ _ _ _ _ _ _ _2Control Room Emergency PlanN/T2LNoo Supervisor Table B-I Shift Technical EegnyPa 2L 3 Advisor/Shift Engineer ablrenc B-i n 60 T2/L3 No No (3 rd SRO) Table_____B-1

___T5___L__

Licensed Nuclear EegnyPa / 2L oN 4 Plant Operator (RO ablrenc B-iN/ 24NoN Licensed Nuclear EegnyPa 5 Plant Operator (RO ablrenc B lai N/A T2/L5 No No*Non-Licensed 6 Nuclear Plant Emergency Plan N/A T2/L6 No No O)perator (NLO #1) abe-Nlon-Licensed T5/L9 7 .cea lat Emergency Plan 60 T5/L1 1 No No Nuclea Plant able B-i Operator (NLO #2) _______ T5/L1 3 ____Non-Licensed 8 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #3) al -Non-Licensed 9 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #f4) al -Non-Licensed 10 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #5) al -ii Fire Brigade #1 Emergency Plan N/A N/A No No______________

Table B-I1________

_____12 Fire Brigade #2 Emergency Plan N/A N/A No No______________

Table B-I1________

_____13 RP / Chemistry Emergency Plan 60 N/A No No Technician Table B-I1________

_____14 RP Technician Emergency Plan 60 N/A No No_____ _____ ____ Table B-I1________

_____Security Contingenc) 15 Security Plan / E-Plan Table 60 T5/Li15 No No_____ _____ ____ B-i1_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _PNPS Page 17 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLE 2-~ PLANT OPERATIONS

& SAFE SHUTDOWN.~ One Unit-One Control Room Analysis #1 beT Security Thr~at Minimuin~Operat;ons Crew Necessary to Implement AOPs and ~9~s orSAMGs if Applicable

Licensed Operator Training 1 Shift Manager Shift Manager Program Superisoricensed Operator Training 2 Unit Supervisor Control Room Sprio Program Licensed Operator Training 3 Shift Technical Advisor Shift Engineer/STA Program 4Licensed Nuclear Plant ~Licensed Operator Training RatrOeao#1Operator

1. 1 Program 5Licensed Nuclear Plant Licensed Operator Training RatrOeao#2Operator

1. 2 Program 6 uiliry pertor#1Non-licensed Nuclear Non-Licensed Operator 6___ Auxi___iary

___Operator_______Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 IOther needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis_______________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A Nl/A 13 I&C Technician N/A Nl/A 14 Other N/A N/A 15 Other N/A Nl/A PNPS Page 18 PNPS Page 18 PNPS ON-SHIFT STAFFING ANALYSIS REPORT LinAFie PeromdbrakAayi ontetoProligramehd 1 N/A Fire Protection Program 2 N/A Fire Protection Program 3 N/A Fire Protection Program Note: This accident does not include the need for firefighting, first aid or search & rescue.1n-#ntSrvy DBTiThreati 2 n-it Srvy 1 In-lan Surveyae N/A 25On-site SRvey N/A 3 Ptersonnelseii Monitosring):

N/A N/A 6 Othermistey spectific task #1 (describe)

N/__ A__Note: No chemistry or RP job function tasks for the conditions described in the DBT assumptions.

RP and Chemistry take cover as directed.I:.. PNSTAL~5-EMERGENCY

PLAN I:MPLEMENTATION

, :: .PNPS Page 19 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Declare the emergency classification level Shift Manager Emergency Planning Training 1 ECL)Program

/ EP Drills Approve Offsite Protective Action NAEmergency Planning Training N/AcmenaiosProgram 3 Approve content of State/local notifications Shift Manager Pmrogram Plnin rann Emergency Planning Training 4 Approve extension to allowable dose N/A Program Licensed Operator Training Notification and direction to on-shift staff SitMngr Porm/EegnyPann ( e.g., to assemble, evacuate, etc.) SitMngr .raiigra P mrogram ,Pnnn Emergency Planning Training 6 ERO notification Shift Manager Program Abbreviated NRC notification for DBT SALicensed Operator Training 7event TAProgram 8 Complete State/local notification form Shift Manager Pmrogram Plnin rann EmrogenyPlninarann 9 Perform State/local notifications NLO#2 Pmrogram Plnin rann Program 11 Ativae EDS NO#2Emergency Planning Training 11 civae ERS NO#2Program N/A (per scenario Emergency Planning Training 12 Offsite radiological assessment asmtos rga Ememtns rogenyPlninarann 13 Perform NRC notifications NLO#2 Pmrogram Plnin rann Perform other site-specific event Licensed Operator Training 14 notifications (e.g., Duty Plant Manager, Shift Manager Prga INPO, ANI, etc.) Program_________________

15 Iersnne Accuntbilty SecuityOffcer Security Training Program / EP 15 Prsonel ccontablit Secrit Offcer Drills PNPS Page 20 PNPS Page 20 (PNPS ON-SHIFT STAFFING ANALYSIS REPORT B. Design Basis Accident Analysis #2 -Control Rod Drop Accident 1. Accident Summary* The control rod drop accident (CRDA) results from an assumed failure of the control rod-to-drive mechanism coupling after the control rod (very reactive rod) becomes stuck in its fully inserted position.

It is assumed that the control rod drive is then fully withdrawn before the stuck rod falls out of the core. The control rod velocity limiter, an engineered safeguard, limits the control rod drop velocity.

The resultant radioactive material release is maintained far below the guideline values of 10OCFR50.67.

• The worst case CRDA occurs during mechanical vacuum pump operation.

The mechanical vacuum pump trips and the radionuclides are trapped in the condenser at atmospheric pressure to leak directly to the environment.

The condenser leakage scenario is bounding for PNPS.2. Accident Specific Assumptions Made* The FSAR assumes the MSIVs, MSL drains, and reactor water sample valves remain open.* The OSA assumes a realistic case of an immediate release from the condenser to the environment via the turbine building roof resulting in the condenser leakage EAB dose.* The EAL is based on 1-hr (1/2) of the FSAR EAB dose.3. Procedures Reviewed for Accident Response* 2.4.40, Rapid Increase in main Steam Line or Offgas Activity* EIP-IP-1 00, Classification and Notification

• EIP-100.1, EALs* EIP-EP-410, Evacuation and Assembly* 2.1.6, Reactor Scram* EOP-5, Radiological Release Control* 6.1-220, Radiological Controls for Risk Evolutions

• ARP-C904LC Alarm Response Procedure* 7.4.64, PRM Alarm Response* 7.3.11, Reactor and Hotwell Water Analysis Preparation PNPS Page 21 PNPS Page 21 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables T5/L3 T5/L5 Emergency Plan 60 No5Yes I Shift Manager Table B-I T5/L6 NoYe T5/L8 T5/L 10______ ______ ___ __ ______ ______T5/L14

______2Control Room Emergency PlanN/T/LNoo Supervisor Table B-I Shift Technical EegnyPa 2L oN 3 Advisor/Shift EmrecPan6T2L Noo Eng]ineer (3 rd SRO) Table B-I16 Licensed Nuclear EegnyPa /4 Plant Operator (RO Emrec lnNAT2/L4 No No I) ~~~~able B-I1______

Licensed Nuclear EegnyPa /5 Plant Operator (RO Emrec lnNAT2/L5 No No 2)Table B-i Non-Licensed EegnyPa /6 Nuclear Plant Emrec lnNAT2/L6 No No'O p e ra to r (N L O # 1 ) T a b le B -I1_ _ _ _ _ _ _ _ _ _ _ _ _Nlon-Licensed Emrec lnT5/L9 7 Nluclear Plant Emrec ln60 T5/L11I No No Fable B-I Operator (NLO #2) _________T5/L13 Nlon-Licensed EegnyPa / / oN 8 Nuclear Plant EegnyPa / / oN Operator (NLO #3) al -Non-Licensed Emergency PlanN/NANoo 9 Nuclear Plant aeB-N/NA Noo Operator (NLO #4) al -Non-Licensed IEmergency PlanN/Noo 10 Nuclear PlantN/NA Noo Operator (NLO #5) beB- /11 Fire Brigade #1 Emergency PlanN/NANoo

_______ _______ able B-i1/ / oN 12 Fire Brigade #2 Emergency Plan N/A N/A No No______________

Fable B-I1________

13 RP / Chemistry IEmergency Plan 60 T5/L12 No No Technician B-i1________

_____14 RP Technician Emergency Plan 60 T4/L1 No No_____ _____ _____ able B-I1_ _ _ __ _ _ _Security Contingencyl 15 Security / E-Plan Table 60 T5/L1 5 No No L PNP TABLE E2 -PLANT p OE RkTIQNS SH

° I PNPS Page 22 PNPS ON-SHIFT STAFFING ANALYSIS REPORT%

e nit ne Control R oom :,"..... ..........

= = =::; 2Anlyis#1Control Robd DroD Accident i Line # Generic TitlelRole On-Shift Position Task Analysis Controlling Method Licensed Operator Training 1 Shift Manager Shift Manager Program SuperisorLicensed Operator Training 2 U~nit Supervisor Control Room SuevsrProgram 3 Shft echicalAdvsorLicensed Operator Training 3 Sif Tchica AviorShift Engineer/STA Program Licensed Nuclear Plant Licensed Operator Training 4 Reactor Operator #1Oprtr#Prga Licensed Nuclear Plant Licensed Operator Training 5 Reactor Operator #2Oprtr2Poga 6 uiliry pertor#1Non-licensed Nuclear Non-Licensed Operator 6 uxliryOpraor#1Plant Operator #1 Training Program 7 &uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic TitlelRole On-Shift Position Task Analysis________________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A ,14 O3ther N/A N/A 15 Other N/A N/A PNPS Page 23 PNPS Page 23 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade:;: : ::::} :.: i , Analysis~#

2 Control Rod Drop

=, ;= i¢ J: 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The CRDA does not include the need for firefighting.

PNS ag 2 PNPS Page 24 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Postio Prfomig Aalyis#2 onrolRo DrpAccid I In-Plant Survey:_RP#1X X X X X X X X X X X X X X X X X X 2 On-site Survey:_-NI/A 3 Personnel Mlonitoring:

N/A _T Job Coverage: N/A 5 Offsite Rad ,ssessment: (Included in Table , 5 6 Other site specific RP (describe):

N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A*Performance Times are estimated Notes: The following RP and Chemistry tasks are performed as prioritized by the Shift Manager and are not time critical for the first 120 minutes.* Post scram in plant surveys (6.1.-220 Att 1.0) directed by the CRS (2.1.6) RB in area of scram headers and tanks. =3 hours to complete*Onsite surveys after enter EOP-5* As directed by SM from checklist (EP-IP-100), RP techs assume the responsibility for onsite radiological controls using RP coordinators procedure EP-IP-261 Att 9.6.* Chemistry secure oxygen injection to condensate pumps as directed by the CRS (2.1.6)* Rx coolant sample (7.4.64, 7.3.11) directed in 2.1.6'as one of the methods to confirm rad increase, however, ARP-C904LC directs operators to close the sample valves because of radiation indication (MSL hi-hi rad). Coolant sample cannot be obtained until conditions allow opening the sample valves. T.S coolant sample is not required until 2-6 hours after shutdown.Takes =30 minutes to complete.* Procedure2.1.6 directs Offgas sample (not time critical) but it isolates.

Sample not required during the 60 minutes.PNPS Page 25 PNPS Page 25 PNPS ON-SHIFT STAFFING ANALYSIS REPORT~.NSTBE5EMRECPLNIMPLEMENTATIOQN

-:: -i: 'Declre he mergncyclasifiatin lvelEmergency Planning Delr1h megnycasfiainivlShift Manager ' raining Program / EP (ECL) Drills 2 pprove Offsite Protective Action N/ .Emergency Planning 2 Recommendations N/Araining Program 3 Approve content of State/local notifications Shift Manager Eraining Progamnn Emrgencyg Planning 4 Approve extension to allowable dose N/A Eraining Progamnn Licensed Operator INotification and direction to on-shift staff Training Program /5 Shift Manager EegnyPann (e.g., to assemble, evacuate, etc.) TingmrenYoralang Emergency Planning 6 ERO notification Shift ManagerrangPorm Licensed Operator 7 ,bbreviated NRC notification for DBT event N/ArangPorm Emergency Planning 8 Complete State/local notification form Shift Manager Tann rga Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Lricnsed OPeraogra 10 Complete NRC event notification form Shift Manager raiicnge POgeramo 11 EnS Planning 11 ctvateERDS LO#Training Program 12 Offsite radiological assessment Chemistry Tcnia Eeraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NILO#2 Eraining Progamnn Perform other site-specific event Licensed Operator 14 notifications (e.g., Duty Plant Manager, Shift Manager Training Program INPO, ANI, etc.) __________

15 Personnel Accountability Security Security Training Program PNPS Page 26 PNPS Page 26 PNPS ON-SHIFT STAFFING ANALYSIS REPORT C. Design Basis Accident Analysis #4 -Loss of Coolant Accident 1. Accident Summary* This event involves the postulation of a spectrum of piping breaks inside containment varying in size, type, and location.

Break of a large .recirculation pipe represents the limiting pipe break inside the containment.

Reactor scram, MSIVs isolate, ECCS initiates and injects.* Radiological release to the atmosphere was assumed to occur via drywell leakage, MSIV leakage, and ECCS leakage. DW and ECCS flow through SGTS and released to the environment through the main stack.MSIV leakage is ground level, unfiltered release through the condenser and high pressure turbine.2. Accident Specific Assumptions Made* No operator action for the first 10 minutes when they initiate one RHR in Containment Cooling.* EAL is based on FSAR EAB dose.3. Procedures for Accident Response* EP-IP-1 00, Emergency Classification and Notification

• EP-IP-100.1.

Emergency Action Levels* EP-IP-300, Offsite Radiological Dose Assessment

• EOP-01, RPV Control* EOP-3, Primary Containment Control* EOP-4, Secondary Containment Control* EOP-5, Radiological Release* 2.1.6, Reactor Scram* EP-IP-240, Emergency Security Organization Activation and Response* 6.3-064, EOP-4 Surveys* EP-I P-400, Protective Action Recommendation PNPS Page 27 PNPS Page 27 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables T2/LI T5/L1 T5/L3 T5/L4 1 Shift Manager Emergency Plan Table 60 T5/L5 No Yes B-i T51L6 T5/L8 T5/L10____ ____ ____ ___ ___ ____ ____ ___ ____ ___ T5/L14_ _ _ _ _ _2 ontrol Room Emergency Plan Table N/T2LNoo Supervisor B-i Shift Technical EmrecPlnTbe 6T2LNoo 3 EmrecPlnTbe 6T2LNoo__ _Engineer (3 rd SRO) B-i Licensed Nuclear EegnyPa al / 2L oN Liceanse Nueratr(R Emergency Plan Table N/A T2/L4 No No NnLicensedNula 65 ula Plant Oeao R Emergency Plan Table N/A T2/L6 No No Operatr (NL #1) -i Non-LicensedT5L 6 Nucler Plant Emergency Plan Table NAT2LNoo Operator (NLO #2) ______ TL1 ______Non-Licensed Emrgnc/PanTal 8 Nuclear Plant B-ignc N/ATale 6 N5/A1 No No Operator (NLO #3) T5/L13____

_____________

Non-Licensed 9 ula ln Emergency Plan Table N/A N/A No No Nuclar Pant B-i Operator (NLO #4) ______Non-Licensed EegnyPa al 10 Nuclear Plant B-igny la abe N/A N/A No No Operator (NLO #4)______10 FireBiade

1. 1an Emergency Plan Table N/A N/A No No_____ _____ ____ B-i1_ _ _ _ _ _12 Fire Brigade #2 Emergency Plan Table N/A N/A No No 13 RP / Chemistry Emergency Plan Table 60 T5/L12 No No Technician B-i1______

______14 RP Technician Emergency Plan Table 60 T4/L1 No No B-i1______

T4/L2 __ ____ ______15 Security Security Contingency 60 T5/L1 5 No No______________Plan

/ E-Plan Table B-i1 ______ _______ ____________

PNPS Page 28 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Line # Generic Title/Role On-Shift Position Task Analysis 1 Shift Manager Shift Manager raiicnge POperamo______ ___ ____ ___ ___ ____ ___ ___ ___ ___ ___ ____ ___ __ TrainingProg~ram 3 Licensed Operator Shift TuehialAvisor Shiftro Engine uer/STA r Trainingl Program Licesed uclar Pant Licensed Operator 4 SReato Operhiat dior #Shperto #1inerSTraining Prog~ram 5 eco prtr# Licensed Nuclear Plant Licensed Operator RatrOeao#2Operator

1. 12 Training Program 6 uxiciary Operator #1 NnLicensed Nuclear Pl n on-Licensed Operator Pln Operator #1 Training Program 7 Auxiliary Operator #21/8 Other needed for Safe Shutdown N/A X/9 Other needed for Safe Shutdown N/A X/10 Other needed for Safe Shutdown N/A /Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic TitlelRole On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 I&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A PNPS Page 29 PNPS Page 29 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade 5 N/A N/A Note: The LOCA does not include a fire.PNPS Page 30 PNPS Page 30 PNPS ON-SHIFT STAFFING ANALYSIS REPORT LRP#1(ositionPromen requirements)

& as directed by SM _2 On-site Survey:X X X X X X X X 3 Personnel Monitoring:

N/A T Job Coverage: N/A__50Offsite Rad Assessment: (Included in Table 5 6 Other site specific RP (describe):

N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

.__N/A*Prorac Times are estimated PNPS Page 31 PNPS Page 31 PNPS ON-SHIFT STAFFING ANALYSIS REPORT i ! Func ion. Task O rrS it i P A nalysis:................

Emergency Planning 1 Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills 2 pprove Offsite Protective Action SitMngrEmergency Planning 2 Recommendations ShfTangrraining Program Emergency Planning 3 Approve content of State/local notifications Shift ManagerrangPorm Emrgencyg Planning 4 Approve extension to allowable dose Shift Manager Emraining Progamnn Notiicaionand iretio to n-siftstaf (eg.,Licensed Operator Training to assembleio evacuaireten etc.) siftff(. Shift Manager Program I Emergency_____assemb

_____e,__evacuate,______et___.___Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A Lcne prtrTann____ ___ ___ ___ ___ ___ ___ ____ ___ ___ ___ ___ ___ ___ __ rogram Emergency Planning 8 Complete State/local notification form Shift ManagerrangPorm Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civat ERD raiingProgram 11 AciTechnicianO#2Emergency Planning 12' Offsite radiological assessment Chemistry ehnca Emraining Progamnn 13 Prfom NR noifiatios NO#2Emergency Planning 13 Prfom NR noifiatios NO#2Training Program 14Perform other site-specific event notifications SitMngrLicensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) Program__________________

15 Personnel Accountability Security Security Training Program PNPS Page 32 PNPS Page 32 PNPS ON-SHIFT STAFFING ANALYSIS REPORT D. Design Basis Accident Analysis #5 -Main Steam Line Break 1. Accident Summary* This event involves the postulation of a large steam line pipe break outside containment.

It is assumed that the largest steam line instantaneously and circumferentially breaks at a location downstream of the outermost isolation valve. The plant is designed to detect immediately such an occurrence, initiate isolation of the broken line, and actuate the necessary protective features.

This postulated event represents the envelope evaluation of steam line failures outside containment.

2. Accident Specific Assumptions Made* Emergency Classification is not required based on the break of the main steam line. This analysis EAL is based on the FSAR MSLB accident EAB dose.3. Procedures for Accident Response* EP-IP-IO00, Emergency Classification and Notification

• EP-IP-1 00.1. Emergency Action Levels* EP-IP-300, Offsite Radiological Dose Assessment

• EOP-01, RPV Control* EOP-3, Primary Containment Control* EOP-5, Radiological Release* 2.1.6, Reactor Scram* EP-IP-300, Offsite Radiological Dose Assessment

• 6.3-064, EOP-4 Surveys PNPS Page 33 PNPS Page 33 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tablesi : ,,

= A P PE.N D IX B =:=:, i ::'On-shift Pos =itin E-Pan:= Reference..

=Augnmertation Role In Tlable Unana...................yzed............

T2/LI T5/L1 T5/L3 1 SitMngr Emergency Plan 60 TISNo Yes Shf aae able B-I T5/L6 T5/L8 T5/L10 T5/L 14 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Table B-i Shift Technical 3 Advisor/Shift Emergency Plan 6 2L oN____Engineer,_(3 rd SRO) Table B-I 0T/L oN Licensed Nuclear EegnyPa / 2L 4 Plant Operator (RO Tablgenc B-I/AT2L No No______ 1)Licensed Nuclear EegnyPa / 2L 5 lant Operator (RO Emrec ln NAT/5No No____2) Table B-I Non-Licensed 6 Nuclear Plant Emergenc Plan N/A T2/L6 No No____Operator (NLO #1)TalB-Non-Licensed T5/L9 7 Nuclear Plant Emergency Plan 6 5L oN Operator (NLO #2)al -T5/L1 3 _____Non-Licensed 8 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #3)TalB-Non-Licensed 9 Nuclear Plant Emergency Plan N/A NIA No No____Operator (NLO #4) al -Non-Licensed 10 NcerPat Emergency Plan N/A N/A No No____Operator (NLO #5 al -11 Fire Brigade #1 Emergency Plan NIA N/A No No_____ _____________

Table B-i1______

______12 Fire Brigade #2 Emergency Plan N/A N/A No No_____ _____________

Table B-I1______

______13 RP / Chemistry Emergency Plan 60 T5/L12 No No____echnician Table B-I 14 RP Technician Emergency Plan 60 T4/L1 No No T____________able B-I T4/L2 Security 15 Security Contingency Plan 60 T5/L15 No No___________________

/ E-Plan Table B-i1 _____________

_____________

PNPS Page 34 PNPS Page 34 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLE 2- =PLANT OPERATIONS

& SAFE SHUTDOWN=i : ;i;i Analysis # 5 MaIn SteamrLneBak(LB Minimum Operations Crew Necessary to Implement AQPs and EOPs or SAMGs if Applicable Line =# Generic Titl~elRole

'!:: : = On-Shift i :i Tsk Anialysisl , 1 Shft anaer SiftMangerLicensed Operator ShiftManagerShiftManager raining Program 2 Unit Supervisor Control Room Supervisor Licensed Operator_______Training Program 3 Licensed Operator Shift Technical Advisor Shift Engineer/STA Training Program 4 RatrOeao#1Licensed Nuclear Plant Licensed Operator RatrOeao#1Operator

1. 1 Training Program 5 RatrOeao#2Licensed Nuclear Plant Licensed Operator RatrOeao#2Operator

1. 2 Training Program 6 Auxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 jOther needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line'# Generic Title/Role On-Shift Position Task Analysis_________________________

_______________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A Nl/A PNPS Page 35 PNPS Page 35 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The MSLB analysis does not include a fire.PNPS Page 36 PNPS Page 36 PNPS ON-SHIFT STAFFING ANALYSIS REPORT: ......... ,.,:,;Analysis

1. 5 M ain Steam : Line ,Break: M

.... ..........

...I Function / Task __ __ ___;____! N 5 15 25 35 45 55 65 75 85-E 010 15 20 25 30 35 4045 50 55 60 65 70 75 8085 90 1 In-Plant Survey:_RP#1 X X X X X X 2 On-site Survey:X X X X X X X X X RP#1 3 Personnel Monitoring:

N/A_4 Job Coverage: N/A.50Offsite Rad Assessment:

Tabie 5 6 Other site specific RP (describe):

N/A 7 Chemistry Function task #1 (describe)

_N/A_8 Chemistry Function task #2 (describe)

N/A___*Performance times are estimated Notes: RP Survey RX bldg. around scram valves (6.2-064) then performs onsite surveys Chemistry secure oxygen injection as directed by SM PNPS Page 37 PNPS Page 37 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLEIF 5-TEMERGNCY PANAMLYSISREPORT I a;I~ plI Q Line#iucto

.......OnShif PostionTask Analys Emergency Planning Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills 2 pprove Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program 3 Approve content of State/local notifications Shift Manager Eraining Progamnn I Emergency Planning 4 Approve extension to allowable dose IN/ArangPorm Licensed Operator Training Notification and direction to on-shift staff Shift Manager Program /Emergency

,(e.g., to assemble, evacuate, etc.) Planning Training Program 6 IEO ntifcaton SiftMangerEmergency Planning 6 ER notficaionShif Mangerraining Program Licensed Operator Training 7 Abbreviated NRC notification for DBT event NI/APrga Emrogenya lnnn 8 Complete State/local notification form Shift Manager Eeraining Progamnn 9 P)erform State/local notifications NLO#2 Emergency Planning_____________________________

________________

Training Program" Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 EDS NO#2Emergency Planning 11 ctvateERDS LO#Training Program Techncian Emergency Planning 12 Offsite radiological assessment Chemistryi Tcnia Training Program 13 Prfom NR noifiatios NO#2Emergency Planning 13 Prfom NR noifiatios NO#Training Program 14 Perform other site-specific event notifications Shift Manager Licensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) ___________Program 15 Personnel Accountability Security Security Training Program PNPS Page 38 PNPS Page 38 PNPS ON-SHIFT STAFFING ANALYSIS REPORT E. Design Basis Accident Analysis #6 -Fuel Handling Accident 1. Accident Summary* The fuel handling accident is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism, resulting in the dropping of a raised fuel assembly onto the core. The drop causes mechanical damage to the bundle being dropped.* The drywell and reactor building are open with ventilation running. All releases to the environment are through the reactor building ventilation.

• The drop of a fuel bundle in containment over the reactor pressure vessel bounds a drop of a fuel bundle in the fuel building due to the greater drop height.2. Accident Specific Assumptions Made* Onsite personnel will be in accordance with the refuel outage staffing plan that includes additional SROs, ROs, NLOs, RP Techs, and Maintenance.

3. Procedures for Accident Response* EOP-5, Radioactive Release Control* 5.4.3, Refueling Floor High Radiation PNPS Page 39 PNPS Page 39 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables APPENDX B! TABL I N-SHIFT POSITIONS; inel Au m naio... ... ....Ro....l in.. Unana..yzed TMSII T2/L1 T5/L1 T5/L3 Emergency Plan 60T5/L5 No Yes I Shift Manager Table B-i16 T5/L6 T51L8 T5/L1 0____ ___ ___ ___ __ ___ ___ ___ __ ___ ___ ___ ___ T5/L 14 2 Control Room Supervisor Emergency Plan N/A T2/L2 No No Table B-i Shift Technical EegnyPa 3 Advisor/Shift Engineer Table B-i2/ / / /___(3 rd SRO)__ ______4Licensed Nuclear Plant Emergency Plan N/A T21L4 No No Operator (RO #1) Table B-i1_________

_____Licensed Nuclear Plant Emergency PlanN/T2LNoo Operator (RO #2) Table B-i1____ ______ _____6Non-Licensed Nuclear Emergency Plan N/A T21L6 No No Plant Operator (NLO #1) Table B-i______

__________

_____T5/L9 7Non-Licensed Nuclear Emergency Plan 60 T5/L11I No No Plant Operator (NLO #2) 'able B-i T5/L1 3_____ ____8 Nlon-Licensed Nuclear iEmergency Plan N/A N/A No No Plant Operator (NLO #3) Fable B-i1________

____ ___________

Non-Licensed Nuclear Emergency Plan N/A N/A No No Pl:)ant Operator (NLO #4) B-i1________

___________

10 Non-Licensed Nuclear IEmergency Plan N/A N/A No No Plant Operator (NLO #5) rable B-i1________

____ ___________

11 Fire Brigade #1 Emergenc Plan N/A N/A No No 12Fr rgd 2Emergency Plan N/A N/A No No__2 __ire _Brigade_#2_Table B-i1________

_ _ _ _ ______ _____13 RP / Chemistry Emergency Plan 60 T5/L12 No No Technician Iable B-i_________

_____ ___ ____ _____14 RPTechnician Emergenfcy Plan 60 T4/L3 No No able B-i1_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _Security 15 Security Contingency Plan / 60 T5/L1 5 No No_________________E-Plan Table B-I_______

_____PNPS Page 40 PNPS Page 40 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNS.A.E2-PLN OPERATION

& SAF SHU.TDOWN " .........

.. ...I J.. ........ .. ...................

........I LO neI ...UItI -l O n e.. n tro R o o m. ..... ....I ...... .... ...I [. .:::: ::,,:... ...

1. 8 -F elH nd ig.c id n Line # Generic Title/Role On-Shift Position task Analysis_________________________________________

ontrolling Method Licensed Operator I Shift Manager Shift Manager Training Program 2 Unt Speriso CotrolRoo SuervsorLicensed Operator___ nit Supervisor______ontrol__Roo__

Supervisor_____

Training Program 3 Licensed Operator Shift Technical Advisor ]Shift Engineer/STA Training Program 4 Ractr Oeraor 1Licensed Nuclear Plant Licensed Operator 4 RatrOeao#1Operator

1. 1 Training Program.5 Leco prtr# icensed Nuclear Plant Licensed Operator RatrOeao#2Operator

1. 2 Training Program 6 ,uxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator_____ _______________________Plant Operator #1 Training Program 7 ,uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other' needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis________________________

_______________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A PNPS Page 41 PNPS Page 41 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade:i:~~~~PNPS ,TABLE :3'-:FIREFIGHTING::I, .:, I N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A-5 N/A N/A Note: FHA does not include a fire.PNPS Page 42 PNPS Page 42 PNPS ON-SHIFT STAFFING ANALYSIS REPORT N ; 5 30-: 35 45- 50-" 55-' 60 :70 80- I In-Plant Survey: N/A___2 On-site Survey: N/A 3 Personnel Monitoring:

RP#1X X X X X T Job Coverage: N/A 50Offsite Rad Assessment: (Included in Table 6 IOther site specific RP (,describe):N/A

.7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A _*Times are estimated Note: RP#1 assist in monitoring and decon Of building evacuees at the Green Line.Additional RP on shift for refueling/outage to assist with tasks PNPS Page 43

.PNPS ON-SHIFT STAFFING ANALYSIS REPORT i =iio: PN=: PS TABLE EMERGENCY IM PLEM ENTATION~i:; i LieFuncto I Tsk*I On-Shift Positio 1 Declare the emergency classification level ShftMaagrraining ProgamnniEP (ECL) Drills 2 ,pprove Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program 3 &pprove content of State/local notifications Shift Manager Emraining Progamnn Emrgencyg Planning 4 &pprove extension to allowable dose N/A Emraining Progamnn LcneOprtrTrainingPrga Notification and direction to on-shift staff (e.g., ShitcanaerProra OpEergerrancy g t o assemble, evacuate, etc.) SitMngrPlanigTra inin Pmrogramy EegnyPlanning Tann rga 6 ERO notification Shift Manager Emraining Progamnn Licensed Operator Training 7 /bbreviated NRC notification for DBT event N/APrga Emrogenya lnnn 8 Complete State/local notification form Shift Manager Emraining Progamnn Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 raningProgram 11 Planning 12 Offsite radiological assessment Chemistry Tcnia Emraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NLO#2 Emraining Progamnn 14Perform other site-specific event notifications SitMngrLicensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) rga 15 Personnel Accountability Security Security Training Program PNPS Page 44 PNPS Page 44 PNPS ON-SHIFT STAFFING ANALYSIS REPORT F. Accident Analysis #8 -Aircraft Probable Threat 1. Accident Summary* The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 minutes, but less than 30 minutes from the site, and considers the dispersal of the site fire brigade away from target areas for firefighting.

• The analysis does not include a scenario or response actions taken during or after a crash.2. Accident Specific Assumptions Made* The Shift Manager receives the call from the NRC of probable aircraft threat.* All non-security on-shift personnel are inside the protected area fence at their normal workstation.

3. Procedures for Accident Response* 5.3.1 4.1, Airborne Threat PNP Pae 4 PNPS Page 45 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables i ,:-________Aayi

_________

,.

; : :: ::: A ugme:ntation Role :in Table # !

i TMS Required?Line # On-shift Position E-Plan Reference ;Time I ::Line #:I T :;:ask? ' :,, T2/L1 T5/LI T5/L3 1Shift Manager Emergency Plan 60 T15No Yes Table B-I T5/L6 T5/L8._ T5/L1 0________________

T5/L14 _ _ _ _ _ _2 Control Room Emergency Plan N/A T2/L2 No No__ _Supervisor Table B-i _______ _______ ______Shift Technical EegnyPa 3 Advisor/Shift Emrec ln60 T2/L3 No No___Engineer (3 rd SRO) TaleB-Licensed Nuclear EegnyPa / 2L 4 Plant Operator (RO ablrenc B-I/AT2L No No Licensed Nuclear EegnyPa / 2L 5 Plant Operator (RO ablrenc B-i /AT2 No No#___ 2) _________Non-Licensed EegnyPa oN 6 Nuclear Plant EegnyPa / 2L oN___Operator (NLO #1) al -/ 2L Non-Licensed T5/L9 7 lant Emergency Plan60T/1Noo 7 Nucler Plant Table B-i10T/I oN___)perator (NLO #2) ________T5/L1 3 _____ _____Non-Licensed EegnyPa / 3L oN 8 Nuclear Plant EegnyPa / 3L oN___Operator (NLO #3) al -Non-Licensed EegnyPa / 3L oN 9 Nuclear Plant EegnyPa / 3L oN___Operator (NLO #4) al -Non-Licensed EegnyPa 10 Nuclear Plant EegnyPa / 3L oN Operator (NLO #5 al -/ 3L oN 11Fr rgd 1 Emergency Plan N/A T3/L4 No No 11 _FireBrigade#1 Table B-i1______

______12 Fire Brigade #2 Emergency Plan N/A T3/L5 "No No T________

able B-i _______ _ __ _ _ _13 RP / Chemistry Emergency Plan 60 N/A No No Technician Table B-i1______

14 RPehiin Emergency Plan 60 T4/L6 No No RP Technician able B-I1______

______Security Contingency 15 Security Plan / E-Plan Table 60 N/A No No____ _______________

EB-I__ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _PNPS Page 46 PNPS Page 46 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Line # Generic TitlelRole

'On-Shift Position Task Analysis_____ _________________________

________________Controlling Method 1 Ishift Manager Ishift Manager Licensed Operator______ __________________________

________________Training Program 2 Jnit Supervisor Control Room Supervisor Lricnsed OPeraogra 3 hitTechnical Advisor Shift Engineer/STA Licensed Operator ShiftTraining Program 4 Ractr pertor#1Licensed Nuclear Plant Licensed Operator 4 ecorOeatr#

perator #1 Training Program 5 Reactor Operator #2 Licensed Nuclear Plant Licensed Operator____uiiayOeao Operator #2 Nuler raining Program 6 uxliryOpraor#1Non-licensed Ncer Non-Licensed Operator P~lant Operator #1 Training Program 7

1. 2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis____ _ _ ___ ___ ____ ___ ___ ___ ___ ___ ___ ___ ___ ___ Controlling Method 11 Mechanic N/A NI/A 12 Electrician N/A N/A 13 I&C Technician N/A N,/A 14 Other N/A N/A 15 Other N/A Nl/A PNPS Page 47 PNPS Page 47 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade i! PN

, :ii!':ii: : B LEicr f:: :: 3 -..... rob beEFaIG HT........ .IN G: ....:i == : ,.' :=' :,;: :...:::::..

',: ' ..1 NLO #3 Fire Brigade Training 2 NLO #4 Fire Brigade Training 3 NLO #5 Fire Brigade Training 4 FB #1 Fire Brigade Training 5 FB #2 Fire Brigade Training Note: FB goes to hardened facility outside the reactor building after performing tasks directed by the CRS.PNPS Page 48 PNPS Page 48 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Lv PoitonPefomance Time Period After. Emergency Declarato (mnte)I In-Plant Survey: 2 On-site Survey: 3 Personnel Monitoring:

____T Job Coverage: 5 Offsite Rad Assessment: (Included in Table 5 6Other site specific RP#1 goes to outside PA TChemistry Function task #1 (,describe) 8Chemistry Function task #2 (describe)

Note: RP relocates to outside the protected area but stays on PNPS property and Chemistry evacuates the process building and takes cover in a secure area.PNPS Page 49 PNPS Page 49 PNPS ON-SHIFT STAFFING ANALYSIS REPORT'I!"i;:~PN PS TABLE 5- E MERGENCY PLAN IMPLEM ENTATION!

i !,.: =.' :;Function.ITask*

Position:

! l i"Task " " ....

Co tr lln M ethod Emergency Planning Declare the emergency classification level SitMngrriigPormIE (ECL)Drills 2 Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program] Emergency Planning 3 &pprove content of State/local notifications Shift Manager Training Program 4 &prov exenson o alowale oseN/AEmergency Planning 4 ppove xtesionto llowbledoseN/Araining Program Licensed Operator Training 5 Notification and direction to on-shift staff (e.g., Shift Manager Program I Emergency to assemble, evacuate, etc.) Planning Training Program 6 ER notficaionShif MangerEmergency Planning 6 ER notficaionShif Mangerraining Program Licensed Operator Training 7 Abbreviated NRC notification for DBT event N/APrga Emergency Planning 8 Complete State/local notification form Shift ManagerrangPorm Emrgencyg Planning 9 Perform State/local notifications NLO#2 Eraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae EDS NO#2raiingProgram ChemistryteTechnician#2Emergency Planning 12 Ofsie raiolgicl asessentraining Program Emergency Planning 13 Perform NRC notifications NILO#2 Emraining Progamnn Perform other site-specific event notifications Licensed Operator Training 14 Shift ManagerPrga (e.g., Duty Plant Manager, INPO, ANI, etC.) Program_____

____________

15 Personnel Accountability N/A Security Training Program PNPS Page 50 PNPS Page 50 PNPS ON-SHIFT STAFFING ANALYSIS REPORT G. Accident Analysis #9 -Control Room Evacuation and Alternate Shutdown 1. Accident Summary* Fire in the Main Control occurs that requires control room evacuation.

• Station personnel evacuate the control room taking time only for those immediate actions within the control room that can be accomplished in seconds. Station personnel take all subsequent action required to bring the reactor to a cold shutdown condition using controls and equipment located outside the control room.2. Accident Specific Assumptions Made* The ATC operator will perform the immediate actions of the procedure to initiate a manual scram and verify all rods in before evacuating the control room.* Subsequent actions are performed from outside the control room.3. N Procedures for Accident Response* 2.4.143, Shutdown From Outside the Main Control Room* EP-IP-1 00, Classification and .Notifications

• EP-IP-1 00.1, EALs PNPS Page 51 PNPS Page 51 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables ILine # On-shift Reference Elapsed Yim+e!.

1. i Task?,:;::

T2/LI T5/Ll T5/L3 1 Shift Manager Emergency Plan 60T5/L5 N e Table B-I 6 T5/L6 N e T5/L8 T5/LI10________________

~~~T5/L 14 __ _ _ _ __ _ _ _ _ _ _2Control Room Emergency PlanN/T2LNoo Supervisor Table B-i / 2L oN Shift Technical EegnyPa 3 Advisor/Shift EegnyPa___Tnier(r R) able B-i 60 T2/L3 No No Licensed Nuclear 4 Plant Operator (RO Emrec lnNAT/4No No#1 ) able B-i Licensed Nuclear 5 Plant Operator (RO Emergency PlanN/T2LNoo Table B-1i/ 2L oN Non-Licensed 6 Nuclear Plant Emergency PlanN/T26Noo

___Operator (NLO #1) al -Non-Licensed T51L9 7 Nuclear Plant Emergency Plan60T/iNoo Table B-i 0T/1 oN Operator (NLO #2) _______T5/L13______

Non-Licensed 8 Nuclear Plant Emergency PlanN/T3LNoo Operator (NLO #3) al -Non-Licensed 9 Nuclear Plant Emergency PlanN/T32Noo

___Operator (NLO #/4) al -Non-Licensed EegnyPa 10 Nuclear Plant NoegecNola

___Operator (NLO #5) al -/ 3L 11 Fire Brigade #1 Emergency PlanNAT34Noo T_________

able B-i N__AT3/L4

_ No______ No_____12 Fire Brigade #2 Emergency Plan N/A T3/L5 No No_____ _____ ___ Table B-I1_ _ _ _ _ _ _ _ _ _ _ _ _ ______13 RP / Chemistry Emergency Plan 6 / oN Technician Table B-i 60______ N/A_____ No____No _14 RP Technician Emergenc Plan 60 T4/L4 No No Security 15 Security Contingency Plan/I 60 N/A No No______________E-Plan Table B-1 _______ ______ ______ ______PNPS Page 52 PNPS ON-SHIFT STAFFING ANALYSIS REPORT*PNPS TABLE 2 _-: PLANT OPERATIONS

& SAFE SHUTDOWN : , i:: : :i illAnalysis

1. 9- CR,,Evacuation

&Alternate Minimu'm Operations Crew Necessary to Im plemnent AOPs :an~d EOs o=r =SAMGs !if Applicable

,= Line # Generic Title/Role On-Shift Position Task Analysis_________________________Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program SuperisorLicensed Operator 2 Unit Supervisor Control Room Sprio Training Program Shift Technical Advisor Shift Engineer/STA Lricnsed OPeraogra 4 Ractr pertor#1Licensed Nuclear Plant Licensed Operator 4 eco peao 1Operator

1. 1 Training Program 5 Ractr pertor#2Licensed Nuclear Plant Licensed Operator 5 eco peao 2Operator

1. 2 Training Program 6 Auxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator_______________________Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role IOn-Shift Position Task Analysis_____ __________________________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 I&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A PNPS Page 53 PNPS Page 53 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade: .. ..i: :': : ::.... ...i : : : P : NPS TABLE .. .. ...C ~~3:- FIREFIGHTIT NG : at n it r te$ " ' : ::o. :., :: L .. ...ne ..... Per......

fo iirmed llllil by ' i Taski A ay is Co toln Method 1 NLO#3 Fire Brigade Training 2 NO4Fire Brigade Training 5 FB2Fire Brigade Training PNPS Page 54 PNPS Page 54 PNPS ON-SHIFT STAFFING ANALYSIS REPORT:: .....PNPS.TABLE 4- RADIATION PROTECTION ANDi CHEMISTRY/,,:,=

.. ,:=,=..... Analysis #9 CR Evacuation

& Alternate E 0-5atigfas:i:

2.:: 10- :i 1'5- 20-.125. 35 '45- 50-~ 55 i65- 70-1"75-180- ______.___

"., 101::f5.20.'25;-30=:

35: '40 4:5: :50: 55 :601 6570 ,o:75'80 o/85,:90: 1 In-Plant Survey: 2 On-site Survey: 3 Personnel Monitoring:

___4 Job Coverage: RP#lSupport X X X X X X X X X X X X X X X X X FB 50Offsite Rad Assessment: (Included in Table 5 6 Other site specific RP (describe):

7 Chemistry Function task #1 (describe) 8 Chemistry-Function task #2 (describe)

PNPS Page 55 PNPS ON-SHIFT STAFFING ANALYSIS REPORT! ":PN PS 5- ERGEN CYi PLEAN I1M PLEM ENTATI O i, Declre he mergncyclasifiatin lvelEmergency Planning DECLar)h mrec lasfcto ee Shift Manager Training Program i EP (ECL)Drills ,pprove Offsite Protective Action Emergency Planning 2 Recommendations N/A Training Program 3 Approve content of State/local notifications Shift Manager Emraining Progamnn Emrgencyg Planning 4 Approve extension to allowable dose N/A Emraining Progamnn Notiicaionand iretio to n-siftstaf.(eg.,Licensed Operator Training Noiia5naddrcin oo-hf tf egShift Manager Program / Emergency to assemble, evacuate, etc.) Planning Training Program Emergency Planning 6 ERO notification Shift ManagerrangPorm Licensed Operator Training 7 Abbreviated NRC notification for DBT event N/APrga 8 Complete State/local notification form Shift Manager Emraining Progamnn 9 Perform State/local notifications NLO#2 Emergency Planning Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae EDS NO#2raiingProgram 11 Ativae EDS NO#2Emergency Planning 12 Offsite radiological assessment N/A Emraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NLO#2 Emraining Progamnn 14Perform other site-specific event notifications SitMngrLicensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) _______rogram____________

15 Personnel Accountability N/A Security Training Program PNPS Page 56 PNPS Page 56 PNPS ON-SHIFT STAFFING ANALYSIS REPORT H. Accident Analysis #10 -Station Blackout 1. Accident Summary* At power, normal lineups and no additionai events* RCIC starts to restore level and SRVs lift in the relief mode to control pressure 2. Accident Specific Assumptions Made* Assume the Shift Manager recognizes power cannot be restored within 15 minutes after the loss before the 15 minute SBO EAL period has expired.3. Procedures for Accident Response* 5.3.31, Station Blackout* EP-IP-1 00, Classification and Notifications

• EP-IP-1 00.1, EALs* EP-IP-410, Evacuation and Assembly PNPS Page 57 PNPS Page 57 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables i

,: PN PS:; :)i E ON DS I :

i:; ':-___________

Anaysis#10 Staton BackoT2/L1___

T5/L5 T5/L8 T5/L31 T5/L14 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Table B-I 3AvsrShiftTehia Emergency Plan 60 T2/L3 No, No Engineer (3 rd SRO) Table B-I iLcensed Nuclear 4 Plant Operator (RO Emergency Plan N/A T2/L4 No No-~Table B-i Licensed Nuclear EegnyPa 5 Plant Operator (RO ablrenc B-i n N/A T2/L5 No No Non-Licensed EegnyPa /6 Nluclear Plant Emrec lnNAT2/L6 No No Operator (NLO #1) al -Non-Licensed EegnyPa60T5/L9 7 Nuclear Plant -EegnyPa60T5/LI I No No Table B-I Operator (NLO #2) T5/L13_____

Non-Licensed EegnyPa / / oN 8 Nuclear Plant EegnyPa / / oN Operator (NLO #3) al -Non-Licensed EegnyPa / oN 9 Nuclear Plant EegnyPa / / oN Operator (NLO #4) al -/Non-Licensed 10 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #5) al -11Fr rgd 1 Emergency Plan N/A N/A No No 12 Fire Brigade #2 ,Emergency PlanN/NANoo

_______ _____ Table B-I1/ / oN 13RP / Chemistry Emergency Plan 60 N/A No No 13 Technician Fable B-I1________

____ _____14 RP Technician Emergency Plan 60 N/A No No_____________

TableB-I1_____________

Security 15 Security Contingency Plan / 60 T5/L15 No No______________E-Plan Table B-i1 ________ _____ ______ _____PNPS Page 58 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLE 2 ~- PLANT OPERATIONS

& SAPE SHUTPOWN One Unit -One Control Room Analysis #10 -Station Blackout.Mnim~um Oper#ations Cirew N e essary: to Imple6m ent: AO Ps .and EOPs or .SA Ms Iif

i;Line # Generic Title/Role On-Shift Position Task Analysis________________Controlling Method 1 Shft anaer SiftMangerLicensed Operator I Shft Mnage Shit Maagerraining Program 2 Unit Supervisor Control Room Supervisor Licensed Operator Training Program Licensed Operator 3 Shift Technical Advisor Shift Engineer/STA Training Program 4 Ractr pertor#1Licensed Nuclear Plant Licensed Operator 4 RatrOeao#1Operator

1. 1 Program ,5 RatrOperator

1. 2 Licensed Nuclear Plant Licensed Operator RatrOperator

1. 2 Training Program 6 Auxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator_____ _______________________Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis_____ _______________

ontrolling Method 1 1 Mechanic N/A N/A 1 2 Electrician N/A N/A 1 3 l&C Technician N/A N/A 1 4 Other N/A N/A 1 5 Other N/A N/A PNPS Page 59 PNPS Page 59 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade TABLE

L:f¸ilG 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The Station Blackout Analysis does not include the need for firefighting.

PNPS Page 60 PNPS Page 60 PNPS ON-SHIFT STAFFING ANALYSIS REPORT E -, :10 ,:15i i25 30: 35!: 40 4:5 150' :55; 75 80 :85': 90,-1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring:

_N/A T Job Coverage: N/A__50Offsite Rad Assessment:

._Included in Table 5 6 Other site specific RP (describe):

N/A 7 Chemistry----------------------------

---

Function task #1 (describe)

N/A___8 Chemistry Function task #2 (describe)

N/A__Note: RP and Chemistry do not have an assigned task for SBO. Chemistry is available for dose assessment if a release occurs.PNPS Page 61 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Declre te emrgeny ca nsfialyisn

1. 10e EmStationBlackout Delr1h megnycasfiainlvl Shift Manager Training Program I EP (ECL) D:rills 2 pprove Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program 3 Approve content of State/local notifications Shift Manager Emraining Progamnn Emergencyg Planning 4 Approve extension to allowable dose N/A Emraining Progamnn Lricnsed OPeraorgra inn Notification and direction to on-shift staff (e.g., ShitcanaerProra

/OEergerrancy g 5 to assemble, evacuate, etc.) SitMngrPlanigTra inin Pmrogramy EegnyPlanning Tann rga 6 ERO notification Shift Manager Emraining Progamnn Licensed Operator Training 7 Abbreviated NRC notification for DBT event N/APrga Emrogenya lnnn 8 Complete State/local notification form Shift Manager Emraining Progamnn Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae EDS NO#2raiingProgram 11 EDS kLO#2Emergency Planning 12 Offsite radiological assessment Nl/A Emraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NiLO#2 Emraining Progamnn Perform other site-specific event notifications Licensed Operator Training (4re.g., Duty Plant Manager, INPO, ANI, etc.) __hift ____Manager_____Program___

15 Personnel Accountability Security Security Training Program PNPS Page 62 PNPS Page 62 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Accident Analysis #11 -LOCA/General Emergency with Release and PAR 1. Accident Summary (Assumed for Staffing Analysis Purpose)* The unit is in a Site Area Emergency ASI when the Shift Manager is given a dose assessment update that projects >1 Rem TEDE dose at the site boundary.2. Accident Specific Assumptions Made* All actions for SAE are complete.* No transients other than LOCA are considered.

• The ERO would be activated at an Alert or SAE. For Staffing Analysis purpose, the T=0 clock is used for the emergency plan actions to evaluate the capability to implement the GE classification, PAR and notification functions before the ERO arrives.3. Procedures for Accident Response* EP-IP-1 00, Emergency Classification and Notification

• EP-IP-1 00.1, Emergency Action Levels* EP-IP-300, Offsite Radiological Dose Assessment

• EOP-05, Radiological Release* EOP-01, RPV Control* EOP-03, Primary Containment Control* EOP-04, Secondary Containment Control* EP-IP-400, PAR PNPS Page 63 PNPS Page 63 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables::' : * !:

!I P EN I B !: : :: : APPENDIX

Role inTable #

TMS Req'uired?

T2/L1 T5/L1 T5/L2 T5/L3 1 Shift Manager Emergency Plan 60 T5/L4 No No Fable B-i T5/L5 T5/L8 T5/LI10____ ____ ____ __ _ ____ ____ ___ ____ ____ ___ T5/L14 _ _ _ _ _ _ _ _ _ _ _ _ _2 Control Room Emergency Plan N/A T2/L2 No No____Supervisor Fable B-I1______

______Shift Technical EegnyPa oN 3 Advisor/Shift EerecPan6T2LNoo

___Eng]ineer (3 rd SRO) 'able B-i10T2L Licensed Nuclear EegnyPa / 2L 4 Plant Operator (RO Emrec lnNAT/4No No_____ 1)able B-I Licensed Nuclear 5 Plant Operator (RO Emergency PlanN/T2LNoo T__ )able B-I / 2L oN Non-Licensed EegnyPa / 2L oN 6 Nuclear Plant EegnyPa / 2L oN___Operator (NLO #1) al -Non-Licensed -mrec lnT5/L9 7 EmergencyPPlan 60 T5/L1 1 No No Nuclear Plantable B-i15L3 _______ _________Operator (NLO #2) TS/L13_________________

Non-Licensed 8 Nuclear Plant Emergency Plan N/A N/A No No___Operator (NLO #3) al -Non-Licensed 9 Nuclear Plant Emergency Plan N/A N/A No No'O p e ra to r (N L O # 4 ) _ __ab le_ _ _ _ _ __B-1_ _ _Non-Licensed EegnyPa 10 Nuclear Plant Emrec lnNANANo No___Operator (NLO #5) ___able_ _ __ _ __ __ _ ___-1_ __ _Emergency PlanN/NANoo 11 Fire Brigade #1 Nobl No" ~~~Emergency PlanNAN/Noo 12 Fire Brigade #2 Nobl No 13RP / Chemistry Emergency Plan 6T5L2No No 13 rechnician Table B-i1______

______ ______14 RP Technician Emergency Plan 60T4/L2Noo

___able____

B-1_____ ________ T4/L6Noo 15 Security Contingency Plan / 60 N/A No No______________E-Plan Table B-i1 _______PNPS Page 64 PNPS Page 64 PNPS ON-SHIFT STAFFING ANALYSIS REPORT: ...... PNPS.- T.ABLE 2- IPL'ANT OPERATIONS SAFE SHUTDOWN:i ":: :*i : , M.nim m .Opeation Crew. Ne.essar to....mpl........e.....

..A.. ..... a ....d EO " ...r ......fA plcal.. .. ....I Line # Generic Title/Role On-Shift Position Task Analysis_____ ________________________________________Controlling Method 1 Shft anaer SiftMangerLicensed Operator 1__ iftMange Shift_______________

Manager_______Training Program 2 Unit Supervisor Control Room Supervisor Lricnsed OPeraogra 3 Shift Technical Advisor Shift Engineer/STA Lricnsed OPeraogra 4 RatrOeao#1Licensed Nuclear Plant Licensed Operator RatrOeao#1Operator

1. 1 Training Program 5 Reactor Operator #2 Licensed Nuclear Plant Licensed Operator______________________Operator

1. 2 Nuler raining Program 6 &uxiliary Operator #1 Non-licensed Ncer Non-Licensed Operator Plant Operator #1 Training Program 7 &uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis_____ _______________Controlling Method 11 IMechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 O:ther N/A N/A PNPS Page 65 PNPS Page 65 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade..........

'" ...... ... "..... "' ... PN , 3 -. F REFIGHTiNG.':::

1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The LOCA/GE with PAR Analysis does not include the need for firefighting.

PNPS Page 66 PNPS Page 66 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNP TBLE4-RADIATION PROTECTION AND'CHEI'ASTRY, ': I In-Plant Survey: N/A___2 On-site Survey: RP#1 onsite & XX XX XX XX X__SB surveys 3 'Personnel Monitoring:

N/A T Job Coverage:

_N/A 5 Offsite Rad Ssessment:

Se._e Tble 5 6 Other site specific RP (describe):

RP#1 Issue X X X X X KI 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A*Times are estimated.

Note: RP tasks are as directed by the Shift Manager and are not time critical.Chemistry does not have an assigned chemistry task for LOCA with PAR. Chemistry is available for dose assessment.

PNPS Page 67 PNPS Page 67 PNPS ON-SHIFT STAFFING ANALYSIS REPORT L ine

On-Shift

ii'!:Task Analysis'

, Emergency Planning 1 Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills 2 ,pprove Ofisite Protective Action SitMngrEmergency Planning 2 Recommendations ShfTangrraining Program Emergency Planning 3 Approve content of State/local notifications Shift Manager Training Program Emergency Planning 4 Approve extension to allowable dose Shift ManagerrangPorm Licensed Operator Training 5 Notification and direction to on-shift staff (e.g., Shift Manager Program / Emergency to assemble, evacuate, etc.) Planning Training Program 6 ER notfictionN/AEmergency Planning 6 ER notfictionN/Araining Program 7 Abbreviated NRC notification for DBT event N/A Lcne prtrTann Program Emergency Planning 8 Complete State/local notification form Shift ManagerrangPorm Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae ERS NO#2 ainng rogram ChemAcstrytTechnician#2Emergency Planning 12 Ofsie raiolgicl asessentraining Program 12 Ofsie rdiolgicl asessentCheistr Tehniian Emergency Planning 13 Perform NRC notifications NLO#2 Emraining Progamnn Perform other site-specific event notifications Licensed Operator Training 14 (,e.g., Duty Plant Manager, INPO, ANI, etc.) Shift Manager Program 15 Personnel Accountability N/A Security Training Program PNPS Page 68 PNPS Page 68 PNPS ON-SHIFT STAFFING ANALYSIS REPORT VIII, APPENDIX C TIME MOTIONS STUDIES A. TMS Shift Manager Safe Shutdown Task PILGRIM NUCLEAR POWER STATION TIME MOTION STUDY OF OVERLAPPING TASKS TASK 1: PERFORM THE ASSIGNED SAFE SHUTDOWN ACTIONS JOB: SHIFT MANAGER TASK 2: PERFORM EMERGENCY DIRECTION AND CONTROL JOB: SHIFT MANAGER PNPS Page 69 PNPS Page 69 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PURPOSE: Perform a Time Motion Study to evaluate whether the performance of safe shutdown actions assigned to the Shift Manager is an acceptable task overlap to the Shift Manager's primary emergency plan function of emergency direction and control.NOTE The Time Motion Study should be completed by simulation of performing the safe shutdown steps while the Shift Manager is demonstrating the Emergency Director function.LOCATION: Control Room to TB 23' RPS MG room to 23' Cable Spreading Room to TSC REQUIRED TOOLS/EQUIPMENT:

A. Procedure 2.4.143, Shutdown from Outside Control Room B. Stopwatch or watch to time actions PNPS Page 70 PNPS Page 70 PNPS ON-SHIFT STAFFING ANALYSIS REPORT APPENDIX D (NEI 10-05)Function I Responsibility (Task) Analysis Template Event: #9 Control Room Evacuation and Alternate Shutdown Site: PNPS Position:

Shift Mana~qer Line #: 1 Function jResponsibility (Task) Action Step ]Duration 1 .Safe Shutdown 1.1 Perform the procedure steps assigned the Shift Manager in procedure 2.4.143 Rev 48, Shutdown from Outside the Control Room.T=0 SM leaves the CR and directs his staff to implement assigned shutdown tasks[step 16(a), (b)] SM arrives at 1 minute power supply panel C511I (TB 23' (T=+I)RPS MG Room) and* Opens Reactor Protection System (RPS) logic Channel A, breaker A3* Opens RPS Channel B, breaker B3* Closes RPS Channel A, breaker A3* Closes RPS Channel B, breaker B3+2 -SM leaves 23' RPS MG 1 minute Room and obtains fuse pullers (T=+2)and safety equipment from the 23'Switchgear Room-SM leaves 23' Switchgear Room 1 minute________________________ (T=+3)[Step 16(d)] T+3 -SM arrives at 23' Cable Spreading Room.Opens panels C941 and C942* Removes fuse 1 6A-F10OA* Removes fuse 16A-F11A* Removes fuse 1 6A-FI12A* Removes fuse 16A-F10B* Removes fuse 16A-F11B* Removes fuse 1 6A-F1 2B SM verbalizes all fuses removed, reactor scrammed and MSIV's closed[step 16(g)] SM arrives and gains access to the TSC. SM confirms status of HCU scram valve position from field reports or EPIC.TASK : :,, :, 1 minute (T=+4)PNPS Page 71 PNPS Page 71 PNPS ON-SHIFT STAFFING ANALYSIS REPORT TOTAL TASK DURATION:

6 minutes Function Responsibility (Task) Action Step Duration 2.Emergency 2.1 Maintain emergency 1 The Shift Direction and direction and control of the Oversight of the emergency Manager Control event response.

response.

maintains radio 2 contact with crew Initiate any emergency actions, for updates and NOTE directions The TMS is for the overlap period.The total time considered for this task should be concurrent with Task 1.....D..FEMERGENCY

.......

TASK DURATION 6 Miue RESULT: Explain why it is acceptable or not acceptable for the Shift Manager to perform the safe shutdown tasks: The procedure Subsequent Action step 13(a) states that the performance of the procedure is an Alert classification and to activate the ERO per EP-IP-100 from the TSC. In step 13(e), the Shift Manager is assigned the tasks to initiate scram, EAL notifications, MSIV closure, and verify scram valve positions.

The Shift Manager passes the RPS panels to initiate the scram and close MSIVs when traveling to the TSC from the control room. The Shift Manager performs steps 16(a), 16(c), 16(d), and 16(g) which take approximately 6 minutes. Verification of control rod position may be verified from the TSC using EPIC.The performance of the SSD steps does not delay the classification of the emergency and the Shift Manager is able to maintain emergency direction and control by communicating with the crew by radio while they are aligning the alternate shutdown panels. Therefore, performing the safe shutdown steps is an acceptable overlapping task.Task Performer Richard Probasco Shift Manager August 23, 2012 Evaluators Stephen Reid Operations Training August 23, 2012 Fred Guynn Fleet EP Project August 23, 2012 S______________________

Manager ___________

SThomas Diorio Pilgrim I&C (EP) August 23, 2012 PNPS Page 72 PNPS Page 72 PNPS ON-SHIFT STAFFING ANALYSIS REPORT IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures 1. The Shift Engineer / STA has a collateral duty to fill out the notification message forms and to make all notifications which may detract the STA from the performance of his/her primary STA function.

It is acceptable for the STA to make the abbreviated NRC notification in a Design Basis Threat but may not maintain the open line with the NRC.2. The Shift Engineer has a collateral task to perform safe shutdown actions which may detract from the capability to perform the primary STA function.3. The Shift Engineer has a collateral task to perform dose assessment which may detract from the capability to perform the primary STA function.PNPS Page 73 PNPS Page 73 PNPS ON-SHIFT STAFFING ANALYSIS REPORT X. " REFERENCES

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

• NSIR DPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants* PNPS Emergency Plan, Rev 39 XI. STAFFING ANALYIS TEAM* Fred Guynn, Entergy ECH Sr Project Manager, EP* Myra Jones, CMCG Contractor

• Tom White, PNPS Manager -EP* Mike McDonnell, PNPS AOM, Operations Support* Barbara Nadeau, PNPS Radiation Protection

• Kenneth Sejkora, PNPS Chemistry* Ashley Ohrenberger, PNPS Ops Training* Karen Sullivan, PNPS EP Planner* Robert Emmitt, PNPS ERO Training PNPS Page 74 PNPS Page 74 Entegyi Nuclear OPoer SationsIc* 600 Rocky Hill Road PyotMA 02360 John A. Dent, Jr.Site Vice President January 14, 2016 U.S. Nuclear Regulatory Commission Attn: Docuriient Control Desk Washington, DC 20555-0001

SUBJECT:

Proposed License Amendment Request to Modify Emergency Response Organization (ERO) Training for the On-shift Chemistry Technician Entergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 LETTER NUMBER: 2.16.001

Reference:

1. PNPS Letter to NRC,

Subject:

"Emergency Plan Changes to the Minimum Staffing Requirements for the Emergency Response Organization (ERO)", dated July 14, 2006 (2.06.062).

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) hereby proposes to amend Operating License No. DPR-35 for the Pilgrim Nuclear Power Station (PNPS).The proposed license amendment reflects a change in the Emergency Response Organization (ERO) as it relates to staff training requirements applicable to the on-shift Chemistry Technician identified in Table B-I of the Site Emergency Plan (SEP). This change was reviewed by Entergy and determined to b.e a reduction in effectiveness of the PNPS SEP. This change i~s submitted to the NRC Staff in accordance with 10 CER 50.54(q).The proposed change has been evaluated in accordance with 10 CFR 50.91 (a)(1).using criteria specified in 10 CFR 50.92(c), and Entergy has determined that this change involves no significant hazards consideration.

The bases for this determination are included in Attachment 1, which provides a description of the proposed change, a background discussion, a technical analysis, a regulatory analysis, and an environmental consideration review. Attachment 2 provides a copy of the current SEP Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization." Attachment 3 provides a comparison of proposed training and training previously proposed in letter Reference

1. Attachment 4 provides the current PNPS Emergency Response On-shift Staffing Analysis (OSA).

Letter 2.16.001 Page 2 Entergy requests approval of the proposed amendment by January 14, 2017. Once approved, Entergy will implement this amendment days.If you have any questions regarding the subject matter, please contact Everett P.Perkins at (508) 830-8323.This letter contains no new or revised regulatory commitments.

I declare under penalty of perjury that the foregoing is true and correct.Executed on the /'4" day of (_/2,j z ~,2016.A. Dent, Jr.;ite Vice President Attachment 1: Analysis of Proposed License Amendment Attachment 2: PNPS Emergency Plan Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization." Attachment 3: Chemistry Technician Training, 2006 Submittal vs 2016 Submittal Attachment 4: PNPS Emergency Response Organization On-shift Staffing Analysis cc: Ms. Booma Venkataraman, Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission one White Flint North O-8C2-A 11555 Rockville Pike Rockville, MD 20852 Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 NRC Resident Inspector Pilgrim Nuclear Power Station John Priest, Director, Massachusetts Department of Public Health Radiation Control Program Commonwealth of Massachusetts 529 Main Street, Suite 1 M2A Charlestown, MA 02129-1121 John Giarrusso, Jr.Planning and Preparedness Section Chief Mass Emergency Management Agency 400 Worcester Road Framingham, MA 01702 ATTACHMENT 1 To Entergy Letter No. 2.16.001 Analysis of Proposed License Amendment (10 Pages)

Attachment I to PNPS Letter 2.16.001 ANALYSIS OF PROPOSED LICENSE AMENDMENT TABLE OF CONTENTS 1.0 DESCRIPTION 2.0 PROPOSED CHANGE 3.0 BACKGROUND 4.0 TECHNICAL ANALYSIS 5.0 REGULATORY ANALYSIS AND ENVIRONMENTAL REVIEW 5.1 Applicable Regulatory Requirements/Criteria 5.2 No Significant Hazards Consideration Determination 5.3 Environmental Consideration

6.0 REFERENCES

1 Attachment I to PNPS Letter 2.16.001 ANALYSIS OF PROPOSED LICENSE AMENDMENT 1.0 DESCRIPTION Pursuant to 10 CFR 50.90, "Amendment of License or Construction Permit at Request of Holder," Entergy Nuclear Operations, Inc. (Entergy) requests Nuclear Regulatory Commission (NRC) Staff review and approval of a revision to the Pilgrim Nuclear Power Plant (PNPS) Site Emergency Plan (SEP) to decrease the Emergency Response Organization (ERO) staff training provided for the "on-site" Chemistry Technician.

Entergy has reviewed the proposed changes against the standards in 10 CFR 50.47(b)and requirements in 10 CER 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." 2.0 PROPOSED CHANGE Entergy is proposing to revise the Emergency Response Organization (ERO) staff training requirements identified for the "on-shift" Chemistry Technician.

Attachment 3 identifies the proposed staff training requirements and provides a comparison to the training requirements previously identified in our 2006 submittal to the NRC Staff, dated July 14, 2006 (Reference 6.1).Subsequent review of the Pilgrim On-shift Staffing Analysis (OSA) dated December 2012 (Reference 6.3) and the job performance requirements for the "on-shift" Chemistry Technician indicate that previously identified training tasks and task qualification functions listed in the 2006 ERO submittal are not necessary for the "on-shift" Chemistry Technician to support the "on-shift" RP Technician function/position at the onset of an ERO event._Proposed Trainingc Chancie We are proposing that the scope of the Chemistry Technician job training that is needed to support initial "on-shift" RP Technician functions be limited to the following general RP support tasks: o Perform on-site radiation surveys o Perform on-site contamination surveys o Set up the Operations Support Center (RP Technician work area)o Issue dosimetry A list of plant specific training to support these functions is provided in Attachment

3.3.0 BACKGROUND

The specific standard for establishing a shift emergency organization to respond to emergency events appears in 10 CFR 50.47(b)(2) which states, in part, "On-shift facility 2 Attachment I to PNPS Letter 2.16.001 licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times..." 10 CFR Part 50, Appendix E, Section IV, requires licensee emergency plans to contain, in part, the organization for coping with radiological emergencies and the activation of the emergency organization.

NUREG-0654 (Reference 6.2),Section II.B, "Onsite Emergency Organization," presents guidance for meeting these requirements.

The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-I,"Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies." This table specifies a minimum of ten on-shift responders in four Major Functional Areas. It also specifies seven on-shift response tasks where the duties may be performed by shift personnel who are assigned other tasks (i.e., there are no dedicated responders to perform these tasks). -The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the site's emergency plan commitments.

The augmenting ERO responders assume many managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus more fully on plant operations.

NUREG-0654 guidance recommends that there be, in addition to on-shift personnel, 30 and 60-minute responders.

On November 23, 2011, the NRC published a final rule in the Federal Register amending certain' emergency preparedness (EP) requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 6.5). This final rule amended 10 CFR Part 50, Appendix E, Section IV.A, "Organization," to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions.

Specifically,Section IV.A.9 states that licensees shall perform "... a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan." Coincident with the rule change in 10 CFR 50, Appendix E, Section IV.A.9, the NRC issued NSIR/DPR-ISG-01, "Interim Staff Guidance -Emergency Planning for Nuclear Power Plants" (Reference 6.6). This Interim Staff Guidance (ISG) provides information relevant to performing the on-shift staffing analysis.

The ISG states that the Nuclear Energy Institute (NEI) developed the document NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose.The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

3 Attachment I to PNPS Letter 2.16.001 4.0 TECHNICAL ANALYSIS 4.1 Pilgrim-Specific Background Information The Pilgrim SEP (Rev 0) was originally issued in 1983. The SEP Table B-I plant staffing figure, indicated that one (1) "on-shift" RP Technician and one (1) "on-shift" 1 Chemistry Technician would be available for ERO response to support in-plant surveys and radio chemistry tasks under the Radiological Accident Assessment functional area.The SEP Table B-I was updated in 1990 (rev 10) and indicated a staff change from one (1) to two (2) "on-shift" RP Technicians in the Accident Assessment Support functional area. The purpose of the revision was identified as an editorial table change to credit the additional RP Technician that was listed in the Protective Action(s) (in Plant)functional area of the table and "to better reflect the format" of NUREG 0654. This SEP revision was submitted to the NRC (Reference 6.7).In a letter dated July 14, 2006 (Reference 6.1), Entergy proposed to the NRC Staff to substitute the "on-shift" Chemistry Technician for the second "on-shift" RP Technician to handleERO responsibilities during the first thirty (30) minutes of an event. As part of that proposal, Entergy stated that PNPS would (1) provide additional training for the "on-shift" Chemistry Technician(s);

and (2) remove the second "on-shift" RP Technician from the shift when appropriate training was provided for the "on-shift" Chemistry Technicians.

This prior SEP submittal supported the removal of one (1) of two (2) "on-shift" RP Technicians listed in SEP, Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization." This Table B-i change was consistent with our original 1983 SEP and the guidance contained in NUREG 0654/FEMA-REP-I., Rev. 1, dated November 1980 (Reference 6.2).In a letter dated February 5, 2007 (Reference 6.4), the NRC Staff responded to our July 14, 2006 request. The letter stated "The NRC staff has concluded that incorporation of the proposed changes do not decrease the effectiveness of the PNPS Emergency Plan and the plan, as changed, continues to meet the standards of Section 50.47(b) and the requirements of Appendix E to Title 10 Part 50 of the Code of federal Regulations.

The basis for our conclusion is contained in the enclosed safety evaluation.

In light of the above, no NRC approval is necessary." On the top of Page 3, the NRC Staff's SE restates the conclusion that the incorporation of the proposed changes do not decrease the effectiveness of the PNPS Emergency Plan and the plan, as changed, continues to meet standards of Section 50.47(b) and the requirements of Appendix E to 10 CFR 50.At Pilgrim Station since 2007, an on-shift Chemistry Technician supplements the on-shift Radiation Protection (RP) Technician in fulfilling the RP duties of the ERO during the early phase of ERO activation.

Four (4) additional RP Technicians are currently required to report to the site within 30 minutes, with the addition of four (4) more RP Technicians reporting to the site in 60 minutes. These additional RP Technicians provide support roles in the ERO Accident Assessment functional area after the first 30 4 Attachment I to PNPS Letter 2.16.001 minutes. In Reference 6.1, Entergy outlined to the NRC Staff the specific training to be provided to the Chemistry Technicians to support their fulfillment of the RP role for the early phase of ERG activation.

Recently, Entergy discovered we were not providing the in-depth training for the on-shift Chemistry Technicians as documented in our letter dated July 14, 2006. A condition report was written and immediate actions were taken to address the issue. Specifically, a second RP Technician was added to each shift to restore the staffing levels that were defined prior to F'ebruary 5, 2007 Table B-I revision.Subsequently, Entergy has determined we could provide a reduced scope of RP training for the on-shift Chemistry Technicians from that previously proposed in our 2006 ERG submittal.

The reduction in training is supported by the 2012 SEP On-shift Staffing An alysis (GSA) which is provided in Attachment 4 (Reference 6.3). The OSA evaluated the on-shift ERG staff positions and verified that assigned personnel can complete required ERG functions/tasks in a timely manner; The GSA does not rely on the on-shift Chemistry Technician to perform the required ERG functions/tasks specifically assigned to the on-shift RP Technician.

Entergy is proposing to reduce the level of training provided to the "on-shift" Chemistry Technicians who may be relied on to perform an initial ERG RP Technician support role.*The scope of training proposed in 2006 is documented in Reference 6.1 and summarized in Attachment 3.*The scope of training proposed in 2016 is identified in Attachment 3 and involves training in the following specific task areas.o Perform on-site radiation surveys o Perform on-site contamination surveys o Set up the Operations Support Center (RP Technician work area)o Issue dosimetry This revised training scope is consistent with the responsibilities and actions that would be required of the on-shift Chemistry Technician during the first 30 minutes of an ERG event consistent with the Gn-shift Staffing Analysis.4.2 Analysis of Reduced ERG Training Requirements for the "On-shift" Chemistry Technician The GSA provides the basis for a proposed reduction in on-site Chemistry Technician Training.

Section 2.14 of NEI 10-05 states "Although developed to meet the requirements of 10 CFR 50, Appendix E, Section IV.A.9, the staffing assessment methodology may be used to evaluate proposed changes to on-shift staffing levels or augmented ERG response times. For example, an analysis could be performed with a desired response time for the augmenting ERG (e.g., 90 minutes), and the results then used to support the basis for changing a staffing or augmentation time commitment." 5 Attachment I to PNPS Letter 2.16.001 The OSA indicates that the primary responsibility of the on-shift Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry sampling tasks were noted as being time critical in the first 90 minutes of~any of the analyzed events. As such, the Chemistry Technician is available to assist the RP Technician in performance of directed RP task work in the Operations Accident Assessment or Protective Action functional areas as determined appropriate by the Shift Manager.The OSA has ensured that the PNPS ERO team members can accomplish the required mission in the first 90 minutes of ERO activation with the staffing and training of on-shift staff members proposed herein. The OSA assumed that the RP and Chemistry Technicians are qualified to perform the range of tasks expected of their position.

The OSA does not credit additional RP training for the "on-shift" Chemistry Technician in order to ensure that the "on-shift" RP Technician can complete assigned emergency plan functions in a timely manner. As such, assignment of any additional RP training to the "on-shift" Chemistry Technician is not necessary and is considered to be an enhancement to the overall ERO organization.

The OSA is included in this submittal as Attachment

4. Based on the OSA, the proposed reduction in "on-shift Chemistry Technician training is acceptable and does not adversely affect the effectiveness of the PNPS Emergency Plan or the ability of assigned on-shift personnel to perform their assigned functions.

5.0 REGULATORY ANALYSIS AND ENVIRONMENTAL REVIEW 5.1 Applicable Regulatory Requirements/Criteria The regulatory standards, requirements and guidance involving ERO staffing and augmentation are as follows:,*10 CFR 50.47(b)(2)

-On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

• 10 CFR 50, Appendix E,Section IV.A (in part) -The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency.

• NRC Regulatory Guide 1.101, "Emergency Response Planning and Preparedness for Nuclear Power Reactors," Revision 5, Section C, stated in part"The criteria and recommendations in this regulatory guide are methods that the 6 Attachment 1Ito PNPS Letter 2.16.001 NRC staff considers acceptable for complying with the requirements in Appendix E to 10 CFR Part 50 and the planning standards in 10 CFR 50.47(b) that must be*met in onsite and offsite emergency response plans. These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness." In NUREG-0654,Section II, "Planning Standards and Evaluation Criteria," Evaluation Criteria ll.B.1 and ll.B.5 address the 10 CFR 50.47(b)(2) planning standard.

Evaluation Criteria ll.B. 1 specifies the on-site emergency organization of plant staff personnel for all shifts, and its relation to the responsibilities and duties of the normal shift complement.

Evaluation Criteria l1.B.5 states, in part, that: Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity.

For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, "Minimum Staffing Requirements for Nuclear Power Plant Emergencies." Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," November 2011, describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.54(q).

In Section C.2.a.(2), the NRC encourages licensees to arrange a conference call with the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for EP changes to ERO staffing that reduce the licensee's capability to staff positions.

Entergy completed and issued an OSA to satisfy the requirements in 10 CFR 50, Appendix E, Section IV.A.9 and standards in 10 CFR 50.47(b)(2).

The OSA was performed using the guidance in NEI 10-05, which has been reviewed by the NRC and found to be an acceptable methodology to satisfy the regulatory requirement.

As a result of the OSA, Revision 44 of the SEP increased the minimum on-shift staffing level to fourteen (14). There were no changes implemented to revise the current on-shift RP and Chemistry Technician staffing listed in Table B-I. The OSA was conducted assuming a response time of 90 minutes for the augmented ERO to allow the use of this analysis for a possible future extension in ERO augmentation times as addressed in Section 2.14 of NEI 10-05. No specific emergency response tasks requiring the augmented ERO were identified in the OSA prior to the 90-minute period following the emergency declaration.

Based on the considerations above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will continue to be conducted in accordance with the site licensing basis, and (3) the approval of the proposed change will not be inimical to the health and safety of the public.7 Attachment I to PNPS Letter 2.16.001 In conclusion, Entergy has determined that the proposed training requirement change does not require any exemptions or relief from regulatory requirements, and does not affect conformance with any regulatory requirements or criteria.5.2 No Significant Hazards Consideration Determination Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response:

No.The proposed training requirements change has no effect on normal plant operation or on any accident initiator.

The change affects the response to radiological emergencies addressed in the SEP. The ability of the emergency response organization to respond adequately to radiological emergencies has been evaluated.

Changes in the training provided to the on-shift organization, such as the reassignment of key on-shift emergency personnel to perform related RP functions, provide assurance of an effective emergency response without competing or conflicting duties. An analysis was also performed on the effect of the proposed change on the timeliness of performing major tasks for the major functional areas of the SEP. The analysis concluded that the reduction in training requirements for the"on-shift" Chemistry Technician to support the initial RP support tasks does not affect the ability to perform the required RP Technician or Chemistry Technician tasks.Therefore, the change in ERG staff training does not increase the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:

No.The proposed change affects the training requirements for the "on-shift" Chemistry Technician and for supplementing onsite personnel in response to a radiological emergency.

It has been evaluated and determined not to significantly affect the ability to perform required or related functions.

It has no effect on the plant design or on the normal operation of the plant and does not affect how the plant is physically operated under emergency conditions.

The reduction in ERG training requirements for the "on-shift" Chemistry Technician in the SEP does not affect the plant operating procedures which are performed by plant staff during all plant conditions.

8 Attachment I to PNPS Letter 2.16.001 No new or different accidents are postulated to occur and there are no changes in any of the accidents previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.The proposed change does not affect plant design or method of operation.

10 CFR 50.47 (b) and 10 CFR 50 Appendix E establish emergency planning standards and requirements that require adequate staffing, satisfactory performance of key functional areas and critical tasks, and timely augmentation of the response capability.

Since the SEP was originally developed, there have been improvements in the technology used to support the SEP functions and in the capabilities of onsite personnel.

A functional analysis was performed on the effect of the proposed change on the timeliness of performing major tasks for the functional areas of the SEP. The analysis concluded that a reduction in training requirements for the "on-shift" Chemistry Technician would not significantly affect the ability to perform the required SEP tasks. Thus, the proposed change has been determined not to adversely affect the ability to meet the emergency planning standards as described in 10 CER 50.47 (b) and requirements in 10 CFR 50 Appendix E.The proposed ERO staff training change does not involve a reduction in any margin of safety. The proposed change is consistent with the original and current ERO staffing levels implemented at PNPS.Based on the above, Entergy concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.Environmental Consideration The proposed changes do not involve (i) a significant hazards consideration, (ii) any changes in the types or any increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

9 Attachment I to PNPS Letter 2.16.001 6. REFERENCES 6.1. Entergy Letter to the NRC, "Emergency Plan Changes to the Minimum Staffing Requirements for the Emergency Response Organization (ERO)", dated July 14, 2006 (Ltr 2.06.062)6.2. NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, published November 1980.6.3. Pilgrim Nuclear Power Station, 10 CFR 50 Appendix E, On-Shift Staffing Analysis Final Report, dated December 20, 2012. Incorporated by reference in Emergency Plan Rev 40, submitted to NRC on January 14, 2013 (Ltr 2.13.001).

6.4. James Kim (USNRC) Letter to Mr. Michael Kansler (Entergy), "Pilgrim Nuclear Power Station -Revision to Emergency Plan to Change Emergency Support O~rganizatiOn Staffing", (TAC No. MD2814) dated February 5, 2007 6.5. Federal Register Volume 76, Number 226, Wednesday, November 23, 2011, Rules and Regulations, "Enhancements to Emergency Preparedness Regulations; Final Rule." 6.6. NSIR/DPR-ISG-01, "Interim Staff Guidance -Emergency Planning for Nuclear Power Plants," Revision 0, November 2011 (ADAMS Accession Number ML1l13010523).

6.7. Entergy Letter to the NRC, "10 CFR 50, Appendix E, Section V,: Submittal of Revised Emergency Plan or Emergency Plan Implementing Procedures", dated January 30, 1991 (Ltr 2.91 .007)10 ATTACHMENT 2 To Entergy Letter No. 2.16.001 PNPS Emergency Plan Table B-I, "Minimum Staffing Requirements for the Emergency Response Organization" (1 Page)

Attachment 2 to PNP.S Letter 2.16.001 PNPS EMERGENCY PLAN Table B-1i: Minimum Staffino Renuirements for the PNPS ERO-(1)Functional Area Major Task TOnshift Position Title Rs+/-Pos.No. ________________

ponse Plant. Operations Plant Stabilization

+/- 1 Shift Manager On Shift#Assessment of Operational Accident Mitigation 2 Control Room Supervisor On Shift#Aspects 3,4 Lic. Nuc. Plant Operator (2) On Shift#______________________

5.6 Unlic. Nuc. Prant Operator (2)**FB On Shift#"Emerg'ency Direction Emergency Classification j1) Shift Manager On Shift#Emergency Control PARs t (1) Shift Manager On Shift#IEmergency Director 60 mai.

Plant Ops Supv 60 min.Notification and Notification of PNPS, Local, (1) Shift Manager On Shift#Communications Commonwealth, and Federal personnel 7 Unlic. Nuc. Plant Operator On Shift#and Maintain Communications Offsite Communicator 30 min.EOF Communicator 60 min.ENS Communicator 60 mai.Rad Accident Assessment!....

EOF Direction EOF Managter, 60 mai.Ops Accident Assessment Offsite Dose Assessment (8) RP Technician***

On Shift#Support (9) Radio Chem. Technician**" On Shift#Radiolog:ical Assessment Coord 30 mai.Offsite Surveys OMT Member (2) 30 mai.OMT Member (2) 60 min.Onsite and'ln-plan't Surveys 8 RP Technician On Shift#RP Technician (2) 30 min.RP Technician (2) 60 mmn.Chemistry

/ Radiochemistry 9 Radio Chem. Technician On Shlft#_____Radio Chem. Technician 60 mai.Plant System Engineering TSC / OSC Direction Emergency Plant Manager 60 mai.Repair and Corrective Actions Technical Support 10 Engineer (Shift Control Rm)* On Shift#Engineer (Reactor) 30 mai.Engineer (Mechanical) 60 mai._________________________Englineer (Electrical) 60 min.Eguipment Repairs _____Nuclear Maint. Technician 30 min.Corrective Actions Nuclear Maint, Technician 60 main 11 Unlic. Nuc. Plant Operator On Shift#12 Nuc. Plant Reactor Operator m*FB On Shift#Nuc. Plant Reactor Operator 60 min.Nuclear Maint. (ElectnicalX2) 30 mai.Nuclear Maint. (Electrical) 60 min.___________________

________________________________Nuclear Control Technician(2) 30 mai.Protective Actions (In Plant) Radiation Protection, Access Control, (8), (9) RP Technician (2)*0 On Shift#RP Coverage, Personnel Monitoring, RP Technician (2) 30 mai.and Dosimetry

_____RP Technician (2) 60 mai.Fire Fighting 13, 14 Fire Brigade*, (3 **, 2 [NLO or Sec]) On Shift#____________________

_____Plymouth Fire Dept. On Call Rescue Ops and First Aid On Shitt#___________________

________________________Ambulance Service ... On Call Site Access Control and Security Security Force* On Shift#Personnel Accountability

_____________________un onirt -person as saiu ro oe on snurt wnen, ounng normar or au~nonrzeo oventime nours, that person is witnin tie PNPS owner controlled areas or on the connecting roads between them with Station Management approval.* Position staffed In accordance with technical specifications.

• • Position staffed in accordance with technical specifications and station procedures.

• • May be provided by shift personnel assigned other functions.

.. .(EMP) Emergency Medical Personnel:

individuals qualified as EMPs, RNs, First Responders, and Paramedics.

NOTES: Response times are based on optimum travel conditions.

On Shift Position #7 is Assistant to Offsite Communicator and can be replaced by an SRO that is qualified for the task.On Shift Position #11 can be filled by an RO or SRO that is gualified for the task On Shift Positions

1. 13 and #14 are available to support Shift Manager, where qualified, in non-fire events.(1) Thls table B-i is incorporated Into the Emergency Plan In accordance with USNRC Generic Letter 82-33 dated 12/17/82 and Incorporates within 30 days of approval the conclusions of the PNPS On Shift Staffing Analysis Report which is a part of the Emergency Plan in accordance with 10CFR5O Appendix E,Section IV. A. 9 and maintained as a separate document.B-7 Revision 44 ATTACHMENT 3 To Entergy Letter No. 2.16.001 Chemistry Technician Training 2006 Submittal vs 2016 Submittal (3 Pages)

Attachment 3 to PNPS Letter 2.16.001 Augmented Radiological Protection (RP) Training needed for the "On-Shift" Chemistry Technician to Support Initial ERO Duties (during first 30 minutes)NUREG 0654 Chemistry Technician Training Chemistry Technician Training Justification for Reduced Training I Table B-I Identified in 2006 Submittal Identified in 2016 Comments"On-Shift" (See OSA Analysis notes below)Task On-site

• Operations Support Center Pool

• Operations Support Center Pool *The 2012 OSA ensured that PNPS and In- Member Qualification Member Qualification ERO team members can accomplish Plant

• Respirator User Qualification

• Perform Radiation Surveys the required mission in the first 90 Surveys

• Self-Contained Breathing Apparatus

• Perform Contamination Surveys minutes of ERO activation with the User Qualification

• Operate Basic Dose Rate Meters current on-shift ERO staff defined in* Walkdown EOP-4 survey point * -Operate Basic Count Rate Meters Table B-I.locations* Perform Radiation Surveys* Perform Contamination Surveys* Collect an Airborne Radioactivity Sample* Analyze Smears for contamination levels* Analyze Air Samples* Operate Basic Dose Rate Meters* Operate Basic Count Rate Meters* Operate the Scintillation Alpha Counter* Operate the Beta Counter* Operate the Gamma Spec System* Operate the Regulated Air Sample Pump* Operate the Radeco Air Sampler 1 Attachment 3 to PNPS Letter 2.16.001 Augmented Radiological Protection (RP) Training needed for the "On-Shift" Chemistry Technician to Support Initial ERO Duties (during first 30 minutes)NUREG 0654 Chemistry Technician Training Chemistry Technician Training Justification for Reduced Training /Table B-I Identified in 2006 Submittal Identified in 2016 Comments"On-Shift" (See OSA Analysis notes below)Task Access *Operations Support Center Pool

• Operations Support Center Pool *The 2012 OSA ensured that PNPS Control Member Qualification Member Qualification ERO team members can accomplish

• Control High Radiation Areas the required mission in the first 90* RWP Briefing minutes of ERO activation with the* Perform Stay Time Calculations current on-shift ERO staff defined in* Issue and Return Respirators Table B-i.RP .Operations Support Center Pool

• Operations Support Center Pool *The 2012 OSA ensured that PNPS Coverage Member Qualification Member Qualification ERO team members can accomplish for repair,

• Respirator User Qualification

• Perform Radiation Surveys the required mission in the first 90 corrective

• SCBA User Qualification

• Perform Contamination Surveys minutes of ERO activation with the actions,

• RP Job Coverage

• Operate Basic Dose Rate Meters current on-shift ERO staff defined in search and

• Control High Radiation Areas

• Operate Basic Count Rate Meters Table B-I.rescue first

• RWP Briefing aid & Perform Stay Time Calculations firefighting

• Perform Radiation Surveys* Perform Contamination Surveys* Collect an Airborne Sample* Analyze Smears* Analyze Air Samples* Operate Basic Dose Rate Meters* Operate Basic Count Rate Meters* Operate the SAC-4* Operate the BC-4* Operate the Gamma Spec System* Operate the RAS Pump* Operate the Radeco* Perform RP Duties in Response to a Plant Fire___________________

2 Attachment 3 to PNPS Letter 2.16.001 Augmented RadiologQical Protection (RP) Training needed for the "On-Shift" Chemistry Technician to SupDport Initial ERO Duties (during first 30 minutes)NUREG 0654 Chemistry Technician Training Chemistry Technician Training Justification for Reduced Training /Table B-I Identified in 2006 Submittal Identified in 2016 Comments"On-Shift" (See OSA Analysis notes below)Task Personnel

• Operations Support Center Pool

• Operations Support Center Pool

• The 2012 OSA ensured that PNPS Monitoring Member Qualification Member Qualification ERO team members can accomplish

• RP Job Coverage the required mission in the first 90* RWP Briefing minutes of ERO activation with the* Perform Personnel Decontamination current on-shift ERO staff defined in Table B-I.Dosimetry

• Operations Support Center Pool

• Operations Support Center Pool

• No effective change is identified Member Qualification Member Qualification

• Issue and Control Personnel

• Issue Dosimetry Dosimetry OSA Notes: 1. The 2012 OSA satisfies the requirements of 10 CFR 50 Appendix E Section IV.A.9. A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities.

This analysis examined the capability of the minimum staff listed in Table B-i of the PNPS Emergency Plan (E-Plan) to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-plan.2. The OSA review team determined that an on-shift staff of fourteen (14) is required to respond to the most limiting accident scenario reviewed, main control room fire and shutdown at the remote shutdown panel.3. NEI 10-05 staffing analysis of on-shift personnel to perform the required emergency planning functions and the licensing basis requirement for each on-shift position.

NEI 10-05 recommends one (1) on-shift RP Technician and one (1) on-shift Chemistry Technician.

The PNPS SEP is consistent with the NEI guidance.4. The primary responsibility for the Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being time critical or required during the first 90 minutes of any of the analyzed events.5. The 2012 OSA analysis included a review of the implementation of the requirement to maintain continuous communications with the notification source during an aircraft threat in accordance with 10CFR50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The review of the Aircraft Threat Accident identified that there are sufficient personnel on-shift to perform this action during the event, Specifically, a licensed or non-licensed nuclear plant operator, the rad protection technician, and chemistry technician were all available to fill this function.6. Augmentation time for some ERO positions is 30 minutes. The OSA analysis was completed for the 90 minute period since the emergency response facilities are required to be operational in 60 minutes. No credit was taken for current 30 minute responders.

Tasks for event response were reviewed for 90 minutes following the declaration.

No specific emergency response tasks requiring the augmented ERO were identified during the 90 minutes following the emergency declaration.

7. The 2012 OSA assumed individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.

ATTACHMENT 4 To Entergy Letter No. 2.16.001 PNPS Emergency Response Organization On-Shift Staffing Analysis (74 Pages)

PNPS ON-SHIFT STAFFING ANALYSIS REPORT ENTERGY PILGRIM NUCLEAR POWER STATION 10CFR5O APPENDIX E ON-SHIFT STAFFING ANALYSIS FINAL REPORT December 20, 2012 Prepared by: Myra Jones Fred Guynn PNPS ON-SHIFT STAFFING ANALYSIS REPORT TABLE OF CONTENTS I. INTRODUCTION.....................................................................................

4 II. ANALYSIS

SUMMARY

.............................................................................

4 A. Emergency Plan Minimum Staffing....................................................................

5 B. Other Commitments to Shift Staffing...........................................................

....... 6 C. Staffing Exceptions and Time Motion Studies (TMS) ..............................................

6 D. Emergency Plan Tasks Not Analyzed ................................................................

7 III. ANALYSIS PROCESS ..............................................................................

8 IV. ACCIDENT SCENARIOS

...... .....................................................................

9 A. Accident Selection........................................................................................

9 B. Accident Scenarios included in the Analysis ,......................................................

..9 C. Accident Scenarios Not Included in the Analysis ..................................................

10 V. GENERAL ASSUMPTIONS AND LIMITATIONS................................................

11 A. Notes and Assumptions Applicable to Pilgrim OSA: ..............................................

11 B. NEI 10-05 Assumptions

..................

.........

...................................................

11 VI. APPENDIX A -ANALYZED EVENTS AND ACCIDENTS

.....................................

14 Vii APPENDIX B -ON-SHIFT STAFFING ANALYSIS.............................................

16 A. Accident Analysis #1 -Design Basis Threat (DBT)...............................................

16 B. Design Basis Accident Analysis #2 -Control Rod Drop Accident..............................

21 C. Design Basis Accident Analysis #4 -Loss of Coolant Accident................................

27 D. Design Basis Accident Analysis #5 -Main Steam Line Break ..................................

33 E. Design Basis Accident Analysis #6 -Fuel Handling Accident ..................................

39 F. Accident Analysis #8 -Aircraft Probable Threat ..................................................

45 G. Accident Analysis #9 -Control Room Evacuation and Alternate Shutdown..................

51 H. Accident Analysis #10 -Station Blackout...........................................................

57 I. Accident Analysis #11 -LOCA/General Emergency with Release and PAR ................

63 VIIIAPPENDIX C TIME MOTIONS STUDIES.......................................................

69 A. TMS Shift Manager Safe Shutdown Task...........................................................

69 PNPS Page 2 PNPS ON-SHIFT STAFFING ANALYSIS REPORT IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED

...............

73 A. Overlap Requiring Compensatory Measures .....................................................

73 X. REFERENCES

...................................................................................

74 XI. STAFFING ANALYIS TEAM ....................................................................

74 PNPS Page 3 PNPS Page 3 PNPS ON-SHIFT STAFFING ANALYSIS REPORT I. INTRODUCTION This report is the finai report for the On-shift Staffing Analysis (OSA) that commenced at Pilgrim Nuclear Power Station (PNPS) during the week of March 19 -22, 2012. This OSA satisfies the requirement of 10 CFR 50 Appendix E Section IV.A.9, which states that nuclear power licensees shall perform "a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. "A structured approach was utilized to perform this analysis using the guidance found in NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities.

This analysis examined the capability of the minimum staff listed in Table B-I of the PNPS Emergency Plan (E-Plan) to perform the actions for the key functional areas of events described in NSIRIDPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the E-plan.I. ANALYSIS

SUMMARY

The OSA team determined that an on-shift staff of fourteen (14) is required to respond to the most limiting accident scenario reviewed, main control room fire and shutdown at the remote shutdown panel. The on-shift staff consists of individuals necessary to support each of the E-Plan functional areas or tasks:* Emergency Direction and Control* Plant Operations and Safe Shutdown (SSD)* Fire Fighting (FB)* Accident Assessment

• Radiation Protection and Chemistry* Notification/Comnmunication

• Technical Support* Accountability NEI 10-05 states it is acceptable for certain functions or tasks to be assigned to personnel already assigned other primary functions/tasks.

These include Repair and Corrective Action, Rescue Operations and First Aid.PNPS Page 4 PNPS Page 4 PNPS ON-SHIFT STAFFING ANALYSIS REPORT A. Emergency Plan Minimum Staffing Per 10 CFR 50.54 (q)(1)(iii), Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV of Appendix E and, for nuclear power reactor licensees, the planning standards of § 50.47(b).The following table indicates the result of the NEI 10-05 staffing analysis of on-shift-personnel to perform the required emergency planning functions and the licensing basis requirement for each on-shift position.Licensing Basis On-Shift Position 4 Requirement E-Plan Functional Area Staffing Analysis Results 50.54m Emergency Direction and Shift Manager (SM) E-plan Table B-I Control SSD (TMS for SSD1 actions)Control Room Supervisor 50.54m (CRS) E-plan Table B-I1S Shift Control Room E-plan Table B-I1ehia upr Engineer (STA)Licensed Nuclear Plant 50.54m SSD -Operator (RO #1 ) E-plan Table B-i Licensed Nuclear Plant 50.54m SSD1 Operator (RO #2) E-plan Table B-i Non-Licensed Nuclear E-plan Table B-i SSD 2 Plant Operator (NLO #1")1 Non-Licensed Nuclear E-plan Table B-i E-Plan Communicator Plant Operator (NLO #2)______

Notifications 3 1 Non-Licensed Nuclear E-plan Table B-i1B Plant Operator (NLO #3)Non-Licensed Nuclear E-plan Table B-i1B Plant Operator (NLO #4)Non-Licensed Nuclear E-plan Table B-i1B PlantOperator_(NLO_#5)

_________Chemist E-plan Table B-1 Accident1 Assessment/Chemistry1 RP #1 E-plan Table B-i Radiation Protection 1 Fire Brigade #11 E-plan Table B-i FB 1 Fire Brigade #21 E-plan Table B-i FB 1 E-plan Table B-i Per Security Security Security Accountability Contingency

_____________

Contingency Plan _____________

Plan TOTAL 14 1 Fire Brigade #1 and Fire Brigade #2 positions did not have any actions or tasks identified in this OSA other than Fire Brigade. These on-shift members (e.g., NLO, Security) are available to support the Shift Manager, where qualified, in non-fire events.2 SSD NLO can be filled by RO or SRO.3 E-Plan Communicator can be replaced by SRO that is qualified for the task.4 One of the 5 NLOs is a Radwaste Operator PNPS Page 5 PNPS ON-SHIFT STAFFING ANALYSIS REPORT I-7 B. Other Commitments to Shift Staffing None C. Staffing Exceptions and Time Motion Studies (TMS)1. The primary responsibility for the Chemistry Technician is chemistry/radiochemistry sampling; however no chemistry job tasks were noted as being time critical or required during the first 90 minutes of any of the analyzed events. It is therefore acceptable to assign the Chemistry Technician the E-Plan function of dose assessment.

In addition, the RP Technician shares the responsibility for dose assessment.

It is recognized, however, that the Shift Manager will prioritize and utilize the on-shift staff as needed for RP, Chemistry and dose assessment.

No further analysis or TMS is required.2. The Shift Manager is assigned the responsibility to make some notifications per procedure 1.3.12. The notifications by phone are considered communications that are approximately one minute in length and are acceptable tasks for the Shift Manager. No further analysis or TMS is required.3. The analysis included a review of the implementation of the requirement to maintain continuous communications with the notification source during an aircraft threat in accordance with 10OCFR50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. The review of the Aircraft Threat Accident identified that there are sufficient personnel on-shift to perform this action during the event. Specifically, a licensed or non-licensed nuclear plant operator, the rad protection technician, and chemistry technician were all available to fill this function.

No further analysis TMS is required.4. A time motion study was completed for the Shift Manager action to perform the safe shutdown actions to initiate a scram and close the MSIVs by manipulating RPS breakers and pulling fuses. The Shift Manager leaves the control room and passes the equipment on the way to the Technical Support Center. The Shift Manager demonstrated the safe shutdown actions can be completed in approximately six (6) minutes while maintaining emergency direction and control through radio contact with other operators aligning safe shutdown equipment.

Details of the TMS are found in section VIII Appendix C.PNPS Page 6 PNPS Page 6 PNPS ON-SHIFT STAFFING ANALYSIS REPORT D. Emergency Plan Tasks Not Analyzed:' 1. Repair and Corrective Action -Per the guidance of NUREG-0654, Table B-I, repair and corrective action tasks may be performed by dedicated shift personnel or qualified shift personnel assigned other functions/tasks.

Repair and corrective action is defined as:*An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g., open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete.In accordance with NEI 10-05 section 2.5, the analysis included a review of the repair and corrective action tasks. For the purpose of this analysis, the tasks were considered to fall into two broad categories:

• Unplanned/unexpected actions that address equipment failures.

These actions are contingent in nature and cannot be specified in advance.* Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.

At PNPS, a Nuclear Plant Reactor Operator on shift will primarily be available to the Shift Manager to perform actions to assist in controlling/mitigating the event.Initial corrective actions are contained in and controlled by plant operating procedures.

The Nuclear Plant Operators have been trained to perform specific actions within the Abnormal and Emergency Operating Procedures and maintenance support is not required.

Maintenance is not included in the on-shift staff. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed 2. Rescue Operations and First Aid: in accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response.

Per the guidance of NUREG-0654, Table B-i, rescue operations and first aid may be performed by shift personnel assigned other functions/tasks.

The fire brigade members (NLOs) are trained to perform rescue operations and are assigned the task should the need arise. Additionally, select Security staff members are trained to First Responder standards and meet the basic requirements to render first aid and CPR. Should first aid be required during a hostile action security event, first aid actions will be performed after the security threat is neutralized and the site is secure. Rescue operations and first aid were not required in any of the accident scenarios reviewed.

Rescue operation and first aid are acceptable collateral duties per the guidance of NEI 10-05 and was not analyzed.PNPS Page 7 PNPS Page 7 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Ill. ANALYSIS PROCESS This analysis was conducted by a joint team of corporate Emergency Preparedness (EP)personnel and station personnel from the Operations, Operations Training, EP Training, Radiation Protection, Chemistry and Emergency Preparedness (EP) departments.

Additionally, personnel from Security provided input to the analysis when necessary.

The team members are identified in Section Xl of this report.The emergency response to each event scenario was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures.

Each scenario was reviewed by the cross disciplinary team to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation.

These actions were then compared to the minimum staffing for Emergency Plan implementation as described in the Emergency Plan Table B-I, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency plan role or their dedicated operational role as appropriate.

In cases where multiple tasks were assigned to an individual in their role, the team evaluated timing of the' tasks to ensure that they could be performed by the individual in series within any specified time requirements.

The results of the analysis for each of the scenarios are included in Section VII, APPENDIX B -ON-SHIFT STAFFING ANALYSIS.

Note that NSIR DPR-ISG-01 states that only DBA accidents"which would result in an emergency declaration" should be evaluated in the staffing assessment.

Each of PNPS DBA's were evaluated and classified according to its FSAR Chapter 14 description.

If the accident description alone did not result in a classification, the projected accident EAB dose found in the ESAR was utilized to determine if an EAL threshold would be exceeded within the first 60 minutes using the Abnormal Rad Level EAL thresholds.

In cases where several projected dose rates were provided or release data was not detailed significantly to determine an EAL, the assessment used the radiological consequences associated with the realistic case in accordance with NEI 10-05.PNPS Page 8 PNPS Page 8 PNPS ON-SHIFT STAFFING ANALYSIS REPORT IV. ACCIDENT SCENARIOS A. Accident Selection 1. The OSA scenarios were chosen using the guidance of NE1 10-05 and NSIR/DPR-ISG-01, "interim Staff Guidance -Emergency Planning for Nuclear Power Plants." The evaluation considered the station Design Basis Accidents (DBA) described in the FSAR along with additional scenarios specified by the guidance documents.

The scenarios considered were:* Design Basis Threat (DBT) ground assault* DBA Control Rod Drop Accident* DBA Loading Error Accident* DBA Loss of Coolant Accident* DBA Main Steam Line Break Accident* DBA Fuel Handling Accident* DBA Radwaste System Accident* Aircraft Probable Threat* Fire Requiring Evacuation of the Control Room and Plant Shutdown From Alternate Location,* Station Blackout, (SBO)* LOCA/General Emergency with release and PAR a LOCA with entry into Severe Accident Management

• Fire Resulting in Reactor Trip (Appendix R fire)B. Accident Scenarios included in the Analysis 1. Design Basis Threat as described in NE! 10-05* Land and/or waterborne Hostile Action directed against the Protected Area by a Hostile Force. This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed 2. Control Rod Drop Accident as described in FSAR 14.5.1* One control rod drops and reactor trips on APRM 120% flux scram.Credit is not taken for MSIV closure. Release pathway is through condenser, turbine building then to environment.

EAL is based on condenser release information in FSAR.3. Loss of Coolant Accident as described in FSAR 14.5.3* Double ended guillotine break of a recirculation line. All ECCS operate-as designed.

EAL is based on fission product barrier EALs.4. Main Steam Line Break Accident as described in FSAR 14.5.4* Break of one main steam line and followed by MSIV closure. Release is to the atmosphere through the top of the turbine building (puff release).PNPS Page 9 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Reactor coolant activity at TS limit. No EAL On the accident but on the USAR EAB 2-hr dose.5. Fuel Handling Accident as described in FSAR 14.5.5* The accident involves a dropped fuel bundle on top of the core. Initial EAL is based on the event.6. Aircraft Probable Threat (50.54hh)* Notification is received from the NRC that a probable aircraft threat exists (>5 minutes, <30 minutes)7. Control Room Fire and Alternate Shutdown* A fire occurs in the main control room requiring the evacuation and the procedure implemented to perform shutdown from the alternate shutdown panels.8. Station Blackout* A loss of all offsite AC power occurs and the failure of the emergency diesel generators.

9. General Emergency with release and "PAR* Assume GE condition with dose projection indication of a release greater than the protective action guideline (PAG).C. Accident Scenarios Not Included in the Analysis 1. Loading Error Accident as described in ESAR 14.1.5.2* Misloaded bundle in the core. No EAL condition is met.2. Radwaste System Accident as described in FSAR 14.5.6* No EAL condition is met.3. Implement SAMG* A review of the SAMGs associated with the initial site-specific Candidate High Level Actions concluded that no actions would require on-shift personnel other than licensed and non-licensed operators.

No analysis required.4. Appendix R Fire* Fire leading to reactor trip with complications.

The control room fire and alternate shutdown requires more resources and actions outside the control room than this fire. The team concluded the control room fire bounds the fire analysis.

No additional analysis required.PNPS Page 10 PNPS Page 10 PNPS ON-SHIFT STAFFING ANALYSIS REPORT V. GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions Applicable to Pilgrim OSA: 1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Abnormal Operating Procedures (AOP), Emergency Operating Procedures (EOP), and Emergency Implementing Procedures (EIP).Any additional tasks directed by the Technical Support Center (TSC), Operations Support Center (OSC), or Emergency Operations Facility (EOF') procedures were not reviewed.2. The augmentation time for some ERO positions is 30 minutes. The analysis was completed for the 90 minute period since the emergency response facilities are required to be operational in 60 minutes. No credit was taken for 30 minute responders.

Tasks for event response were reviewed for 90 minutes following the declaration.

No specific emergency response tasks requiring the augmented ERO were identified during the 90 minutes following the emergency declaration.

3. The OSA team determined there are no time critical RP and Chemistry tasks and that task performance is directed and prioritized by the Shift Manager. The time RP or Chemistry is directed to perform a task and the amount of time taken to complete tasks are estimated.

No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration.

Since the Shift Manager directs when the tasks are performed, there are no overlapping RP or chemistry tasks.4. All crews have one individual filling the SM and one individual filling the STA roles therefore the analysis did not consider using a dual-role individual.

B. NEI 10-05 Assumptions

1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task. (60 mmn.)2. On-shift personnel complement was limited to the minimum required number and composition as described in the site emergency plan. If the plan commitments allow for different minimum staffing levels (e.g., a variance between a normal dayshift and a backshift), use the staffing with the smallest total number of personnel.

3. Although the temporary absence of a position may be allowed by Tech Specs, the analysis was performed assuming that all required on-shift positions are filled.4. Event occurred during off-normal work hours where ERO was offsite and all required minimum on-shift positions were filled.5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.PNPS Page 11 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 6. On-shift staff has necessary Radiation Worker qualification to obtain normal dosimetry and enter the RCA (but not locked high or very high radiation areas)without the aid of a RP technician.

7. Personnel assigned plant operations and safe shutdown meets the requirements and guidance (analyzed through other programs such as operator training) and was evaluated as part of this assessment unless a role/function/task from another major response area was assigned as collateral duty.8. In-plant (manual) safety related operator actions to manipulate components and equipment from locations outside the control room to achieve and maintain safe shutdown was done by a member of the on-shift staff as defined in the unit's Tech Specs.9. Fire brigade (FB) staff performance is analyzed through other station programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.10. Individuals holding the position of RP technician or Chemistry technician are qualified to perform the range of tasks expected of their position.11. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.12. Communications, briefings, and peer checks are acceptable collateral duties.13. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIRIDPR-ISG-01]14. The Staffing Analysis specified the resources available to perform "Repair and Corrective Actions" and "Rescue Operations and First Aid" but these may be assigned as collateral duty to a designated on-shift responder.

15. For assessment purposes, NRC notifications were treated as a continuous action per 10OCFR50.72(c)(3) and 73.71 (b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.16. DBA (postulated accident, Condition IV event, or limiting fault) is considered as"Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation.

As a result, a greater number and variety of actions would need to be implemented by plant personnel." 17. Unless otherwise specified in NSIR/DPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants, or by the FSAR initial conditions of a DBA analysis, it was assumed that the unit was in Mode 1, Power.PNPS Page 12 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 18. DBT assumed a hostile force breached the protected area fence but was neutralized with no adverse consequen~ces to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to prevent safe shutdown or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.19. The Staffing Analysis used DBA analysis assumptions, inputs, and timing of events as documented in the FSAR.20. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began at the time of declaration of the initiating event.21. Severe Accident Management Guideline (SAMG) -It is sufficient to simply assume that the accident progressed to conditions requiring a severe accident response; it is not necessary to determine specific failures and the accident sequence.22. SAMG -The actions to be analyzed include those that implement the initial site-specific actions assuming the core is no ex-vessel (i.e., no reactor vessel failure), and there is not actual or imminent challenge to containment integrity.

PNPS Page 13 PNPS Page 13 PNPS ON-SHIFT STAFFING ANALYSIS REPORT VI. APPENDIX A -ANALYZED EVENTS AND ACCIDENTS E e t E e t S~ummary Descriptioniof~i Plant... .... ...... '"== ..:I ....:* : Refe~rence = ......' "= '

iEn t ype- ::::::: :;:, Event.Mode..Document:s)

Event ECL.1 DBT Land and/or waterborne 1 NEI 10-05 Site Area Yes HOSTILE ACTION Emergency directed against the ISG IV.C Protected Area by a HOSTILE FORCE.2 DBA Control Rod Drop Accident 1 FSAR 14.5.1 Site Area Yes Emergency 3 DBA Loading Error Accident 1 FSAR 14.5.2 None Noz (misloaded bundle in the______core) 4 DBA Loss of Coolant Accident 1 FSAR 14.5.3 General Yes______Emergency 5 DBA Main Steam Line Break 1 FSAR 14.5.4 Site Area Yes Emergency 6 DBA Fuel Handling Accident 5 FSAR 14.5.5 Site Area Yes Emergency 7 DBA Radwaste System 1 FSAR 14.5.6 None Accident 8 Assumed Aircraft Probable Threat 1 10CFR50.54hh Alert Yes for (1)analysis purpose RG 1.214 9 Assumed Control Room Evacuation 1 FSAR 14.6.1 Alert Yes for and Alternate Shutdown Analysis (fire in main control room) I0CFR50 Purpose Appendix R Fire Hazard Analysis 10 Assumed Station Blackout 1 ISG IV.C Site Area Yes for Emergency analysis purpose 11 Assumed LOCA -General 1 ISG IV.C General Yes for Emergency with Emergency Analysis radiological release and____Purpose PAR 12 Assumed LOCA with entry into 1 ISG IV.C General for severe accident Emergency Analysis procedures.

Purpose ________________________

_____PNPS Page 14 PNPS Page 1.4 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 13 Assumed Appendix R Fire I ISG IV.C AlertNo for Analysis____ Purpose _____________

____ _______1 Plant mode per FSAR or assumed for anaiysis purpose 2 No EAL met on plant condition or dose.3 pNPS does not meet the NEI110-05 intent for the analysis of implementing SAMG. NEI 10-05 Section 2.11 states that the analysis of the ability to implement SAMG focuses on the reasonably expected initial mitigation action that would be performed by on-shift personnel other than licensed and non-licensed operators.

The actions assessed by NEI 10-05 are those which implement the initial site-specific Candidate High Level Action assuming the core is not ex-vessel (i.e., no reactor vessel failure), and there is no actual or imminent challenge to containment integrity.

PNPS does include maintenance qualified to perform maintenance job tasks in minimum staffing and does not have contingency actions that must be completed by maintenance in the severe accident procedures.

4 Appendix R Fire is bound by the Control Room Fire and Alternate Shutdown.

Analysis is not required.PNPS Page 15 PNPS Page 15 PNPS ON-SHIFT STAFFING ANALYSIS REPORT VII. APPENDIX B] -ON-SHIFT STAFFING ANALYSIS A. Accident Analysis #1 -Design Basis Threat (DBT)1. Accident Summary* Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat. Security Code Red condition 2. Accident Specific Assumptions Made* This event assumes the threat is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.* Assume at power in Mode 1* Security notifies the Shift Manager of condition Security Code RED.* Assume all non-security staff is located inside the protected area at their normal work station when the event occurs.* Assume all systems function and the core remains covered. No fuel damage and no release.3. Procedures Reviewed for Accident Response* Procedure 5.3.14, Security Incident* EP-IP-1 00, Classification and Notifications

• EP-IP-1 00.1, EAL* EP-IP-410, Evacuation and Assembly* Procedure 2.1.6, Reactor Scram PNPS Page 16 PNPS Page 16 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables PNPS TABLE V-ON-SHIFT POSITION T2/L1 T5/L1 T5/L3 1 Shift Manager Emergency Plan 60 T5/L5. No Yes Table B-i T5/L6 T5/L8 T5/L10________________

_______________T5/L 14 _ _ _ _ _ _ _ _2Control Room Emergency PlanN/T2LNoo Supervisor Table B-I Shift Technical EegnyPa 2L 3 Advisor/Shift Engineer ablrenc B-i n 60 T2/L3 No No (3 rd SRO) Table_____B-1

___T5___L__

Licensed Nuclear EegnyPa / 2L oN 4 Plant Operator (RO ablrenc B-iN/ 24NoN Licensed Nuclear EegnyPa 5 Plant Operator (RO ablrenc B lai N/A T2/L5 No No*Non-Licensed 6 Nuclear Plant Emergency Plan N/A T2/L6 No No O)perator (NLO #1) abe-Nlon-Licensed T5/L9 7 .cea lat Emergency Plan 60 T5/L1 1 No No Nuclea Plant able B-i Operator (NLO #2) _______ T5/L1 3 ____Non-Licensed 8 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #3) al -Non-Licensed 9 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #f4) al -Non-Licensed 10 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #5) al -ii Fire Brigade #1 Emergency Plan N/A N/A No No______________

Table B-I1________

_____12 Fire Brigade #2 Emergency Plan N/A N/A No No______________

Table B-I1________

_____13 RP / Chemistry Emergency Plan 60 N/A No No Technician Table B-I1________

_____14 RP Technician Emergency Plan 60 N/A No No_____ _____ ____ Table B-I1________

_____Security Contingenc) 15 Security Plan / E-Plan Table 60 T5/Li15 No No_____ _____ ____ B-i1_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _PNPS Page 17 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLE 2-~ PLANT OPERATIONS

& SAFE SHUTDOWN.~ One Unit-One Control Room Analysis #1 beT Security Thr~at Minimuin~Operat;ons Crew Necessary to Implement AOPs and ~9~s orSAMGs if Applicable

Licensed Operator Training 1 Shift Manager Shift Manager Program Superisoricensed Operator Training 2 Unit Supervisor Control Room Sprio Program Licensed Operator Training 3 Shift Technical Advisor Shift Engineer/STA Program 4Licensed Nuclear Plant ~Licensed Operator Training RatrOeao#1Operator

1. 1 Program 5Licensed Nuclear Plant Licensed Operator Training RatrOeao#2Operator

1. 2 Program 6 uiliry pertor#1Non-licensed Nuclear Non-Licensed Operator 6___ Auxi___iary

___Operator_______Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 IOther needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis_______________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A Nl/A 13 I&C Technician N/A Nl/A 14 Other N/A N/A 15 Other N/A Nl/A PNPS Page 18 PNPS Page 18 PNPS ON-SHIFT STAFFING ANALYSIS REPORT LinAFie PeromdbrakAayi ontetoProligramehd 1 N/A Fire Protection Program 2 N/A Fire Protection Program 3 N/A Fire Protection Program Note: This accident does not include the need for firefighting, first aid or search & rescue.1n-#ntSrvy DBTiThreati 2 n-it Srvy 1 In-lan Surveyae N/A 25On-site SRvey N/A 3 Ptersonnelseii Monitosring):

N/A N/A 6 Othermistey spectific task #1 (describe)

N/__ A__Note: No chemistry or RP job function tasks for the conditions described in the DBT assumptions.

RP and Chemistry take cover as directed.I:.. PNSTAL~5-EMERGENCY

PLAN I:MPLEMENTATION

, :: .PNPS Page 19 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Declare the emergency classification level Shift Manager Emergency Planning Training 1 ECL)Program

/ EP Drills Approve Offsite Protective Action NAEmergency Planning Training N/AcmenaiosProgram 3 Approve content of State/local notifications Shift Manager Pmrogram Plnin rann Emergency Planning Training 4 Approve extension to allowable dose N/A Program Licensed Operator Training Notification and direction to on-shift staff SitMngr Porm/EegnyPann ( e.g., to assemble, evacuate, etc.) SitMngr .raiigra P mrogram ,Pnnn Emergency Planning Training 6 ERO notification Shift Manager Program Abbreviated NRC notification for DBT SALicensed Operator Training 7event TAProgram 8 Complete State/local notification form Shift Manager Pmrogram Plnin rann EmrogenyPlninarann 9 Perform State/local notifications NLO#2 Pmrogram Plnin rann Program 11 Ativae EDS NO#2Emergency Planning Training 11 civae ERS NO#2Program N/A (per scenario Emergency Planning Training 12 Offsite radiological assessment asmtos rga Ememtns rogenyPlninarann 13 Perform NRC notifications NLO#2 Pmrogram Plnin rann Perform other site-specific event Licensed Operator Training 14 notifications (e.g., Duty Plant Manager, Shift Manager Prga INPO, ANI, etc.) Program_________________

15 Iersnne Accuntbilty SecuityOffcer Security Training Program / EP 15 Prsonel ccontablit Secrit Offcer Drills PNPS Page 20 PNPS Page 20 (PNPS ON-SHIFT STAFFING ANALYSIS REPORT B. Design Basis Accident Analysis #2 -Control Rod Drop Accident 1. Accident Summary* The control rod drop accident (CRDA) results from an assumed failure of the control rod-to-drive mechanism coupling after the control rod (very reactive rod) becomes stuck in its fully inserted position.

It is assumed that the control rod drive is then fully withdrawn before the stuck rod falls out of the core. The control rod velocity limiter, an engineered safeguard, limits the control rod drop velocity.

The resultant radioactive material release is maintained far below the guideline values of 10OCFR50.67.

• The worst case CRDA occurs during mechanical vacuum pump operation.

The mechanical vacuum pump trips and the radionuclides are trapped in the condenser at atmospheric pressure to leak directly to the environment.

The condenser leakage scenario is bounding for PNPS.2. Accident Specific Assumptions Made* The FSAR assumes the MSIVs, MSL drains, and reactor water sample valves remain open.* The OSA assumes a realistic case of an immediate release from the condenser to the environment via the turbine building roof resulting in the condenser leakage EAB dose.* The EAL is based on 1-hr (1/2) of the FSAR EAB dose.3. Procedures Reviewed for Accident Response* 2.4.40, Rapid Increase in main Steam Line or Offgas Activity* EIP-IP-1 00, Classification and Notification

• EIP-100.1, EALs* EIP-EP-410, Evacuation and Assembly* 2.1.6, Reactor Scram* EOP-5, Radiological Release Control* 6.1-220, Radiological Controls for Risk Evolutions

• ARP-C904LC Alarm Response Procedure* 7.4.64, PRM Alarm Response* 7.3.11, Reactor and Hotwell Water Analysis Preparation PNPS Page 21 PNPS Page 21 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables T5/L3 T5/L5 Emergency Plan 60 No5Yes I Shift Manager Table B-I T5/L6 NoYe T5/L8 T5/L 10______ ______ ___ __ ______ ______T5/L14

______2Control Room Emergency PlanN/T/LNoo Supervisor Table B-I Shift Technical EegnyPa 2L oN 3 Advisor/Shift EmrecPan6T2L Noo Eng]ineer (3 rd SRO) Table B-I16 Licensed Nuclear EegnyPa /4 Plant Operator (RO Emrec lnNAT2/L4 No No I) ~~~~able B-I1______

Licensed Nuclear EegnyPa /5 Plant Operator (RO Emrec lnNAT2/L5 No No 2)Table B-i Non-Licensed EegnyPa /6 Nuclear Plant Emrec lnNAT2/L6 No No'O p e ra to r (N L O # 1 ) T a b le B -I1_ _ _ _ _ _ _ _ _ _ _ _ _Nlon-Licensed Emrec lnT5/L9 7 Nluclear Plant Emrec ln60 T5/L11I No No Fable B-I Operator (NLO #2) _________T5/L13 Nlon-Licensed EegnyPa / / oN 8 Nuclear Plant EegnyPa / / oN Operator (NLO #3) al -Non-Licensed Emergency PlanN/NANoo 9 Nuclear Plant aeB-N/NA Noo Operator (NLO #4) al -Non-Licensed IEmergency PlanN/Noo 10 Nuclear PlantN/NA Noo Operator (NLO #5) beB- /11 Fire Brigade #1 Emergency PlanN/NANoo

_______ _______ able B-i1/ / oN 12 Fire Brigade #2 Emergency Plan N/A N/A No No______________

Fable B-I1________

13 RP / Chemistry IEmergency Plan 60 T5/L12 No No Technician B-i1________

_____14 RP Technician Emergency Plan 60 T4/L1 No No_____ _____ _____ able B-I1_ _ _ __ _ _ _Security Contingencyl 15 Security / E-Plan Table 60 T5/L1 5 No No L PNP TABLE E2 -PLANT p OE RkTIQNS SH

° I PNPS Page 22 PNPS ON-SHIFT STAFFING ANALYSIS REPORT%

e nit ne Control R oom :,"..... ..........

= = =::; 2Anlyis#1Control Robd DroD Accident i Line # Generic TitlelRole On-Shift Position Task Analysis Controlling Method Licensed Operator Training 1 Shift Manager Shift Manager Program SuperisorLicensed Operator Training 2 U~nit Supervisor Control Room SuevsrProgram 3 Shft echicalAdvsorLicensed Operator Training 3 Sif Tchica AviorShift Engineer/STA Program Licensed Nuclear Plant Licensed Operator Training 4 Reactor Operator #1Oprtr#Prga Licensed Nuclear Plant Licensed Operator Training 5 Reactor Operator #2Oprtr2Poga 6 uiliry pertor#1Non-licensed Nuclear Non-Licensed Operator 6 uxliryOpraor#1Plant Operator #1 Training Program 7 &uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic TitlelRole On-Shift Position Task Analysis________________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A ,14 O3ther N/A N/A 15 Other N/A N/A PNPS Page 23 PNPS Page 23 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade:;: : ::::} :.: i , Analysis~#

2 Control Rod Drop

=, ;= i¢ J: 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The CRDA does not include the need for firefighting.

PNS ag 2 PNPS Page 24 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Postio Prfomig Aalyis#2 onrolRo DrpAccid I In-Plant Survey:_RP#1X X X X X X X X X X X X X X X X X X 2 On-site Survey:_-NI/A 3 Personnel Mlonitoring:

N/A _T Job Coverage: N/A 5 Offsite Rad ,ssessment: (Included in Table , 5 6 Other site specific RP (describe):

N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A*Performance Times are estimated Notes: The following RP and Chemistry tasks are performed as prioritized by the Shift Manager and are not time critical for the first 120 minutes.* Post scram in plant surveys (6.1.-220 Att 1.0) directed by the CRS (2.1.6) RB in area of scram headers and tanks. =3 hours to complete*Onsite surveys after enter EOP-5* As directed by SM from checklist (EP-IP-100), RP techs assume the responsibility for onsite radiological controls using RP coordinators procedure EP-IP-261 Att 9.6.* Chemistry secure oxygen injection to condensate pumps as directed by the CRS (2.1.6)* Rx coolant sample (7.4.64, 7.3.11) directed in 2.1.6'as one of the methods to confirm rad increase, however, ARP-C904LC directs operators to close the sample valves because of radiation indication (MSL hi-hi rad). Coolant sample cannot be obtained until conditions allow opening the sample valves. T.S coolant sample is not required until 2-6 hours after shutdown.Takes =30 minutes to complete.* Procedure2.1.6 directs Offgas sample (not time critical) but it isolates.

Sample not required during the 60 minutes.PNPS Page 25 PNPS Page 25 PNPS ON-SHIFT STAFFING ANALYSIS REPORT~.NSTBE5EMRECPLNIMPLEMENTATIOQN

-:: -i: 'Declre he mergncyclasifiatin lvelEmergency Planning Delr1h megnycasfiainivlShift Manager ' raining Program / EP (ECL) Drills 2 pprove Offsite Protective Action N/ .Emergency Planning 2 Recommendations N/Araining Program 3 Approve content of State/local notifications Shift Manager Eraining Progamnn Emrgencyg Planning 4 Approve extension to allowable dose N/A Eraining Progamnn Licensed Operator INotification and direction to on-shift staff Training Program /5 Shift Manager EegnyPann (e.g., to assemble, evacuate, etc.) TingmrenYoralang Emergency Planning 6 ERO notification Shift ManagerrangPorm Licensed Operator 7 ,bbreviated NRC notification for DBT event N/ArangPorm Emergency Planning 8 Complete State/local notification form Shift Manager Tann rga Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Lricnsed OPeraogra 10 Complete NRC event notification form Shift Manager raiicnge POgeramo 11 EnS Planning 11 ctvateERDS LO#Training Program 12 Offsite radiological assessment Chemistry Tcnia Eeraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NILO#2 Eraining Progamnn Perform other site-specific event Licensed Operator 14 notifications (e.g., Duty Plant Manager, Shift Manager Training Program INPO, ANI, etc.) __________

15 Personnel Accountability Security Security Training Program PNPS Page 26 PNPS Page 26 PNPS ON-SHIFT STAFFING ANALYSIS REPORT C. Design Basis Accident Analysis #4 -Loss of Coolant Accident 1. Accident Summary* This event involves the postulation of a spectrum of piping breaks inside containment varying in size, type, and location.

Break of a large .recirculation pipe represents the limiting pipe break inside the containment.

Reactor scram, MSIVs isolate, ECCS initiates and injects.* Radiological release to the atmosphere was assumed to occur via drywell leakage, MSIV leakage, and ECCS leakage. DW and ECCS flow through SGTS and released to the environment through the main stack.MSIV leakage is ground level, unfiltered release through the condenser and high pressure turbine.2. Accident Specific Assumptions Made* No operator action for the first 10 minutes when they initiate one RHR in Containment Cooling.* EAL is based on FSAR EAB dose.3. Procedures for Accident Response* EP-IP-1 00, Emergency Classification and Notification

• EP-IP-100.1.

Emergency Action Levels* EP-IP-300, Offsite Radiological Dose Assessment

• EOP-01, RPV Control* EOP-3, Primary Containment Control* EOP-4, Secondary Containment Control* EOP-5, Radiological Release* 2.1.6, Reactor Scram* EP-IP-240, Emergency Security Organization Activation and Response* 6.3-064, EOP-4 Surveys* EP-I P-400, Protective Action Recommendation PNPS Page 27 PNPS Page 27 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables T2/LI T5/L1 T5/L3 T5/L4 1 Shift Manager Emergency Plan Table 60 T5/L5 No Yes B-i T51L6 T5/L8 T5/L10____ ____ ____ ___ ___ ____ ____ ___ ____ ___ T5/L14_ _ _ _ _ _2 ontrol Room Emergency Plan Table N/T2LNoo Supervisor B-i Shift Technical EmrecPlnTbe 6T2LNoo 3 EmrecPlnTbe 6T2LNoo__ _Engineer (3 rd SRO) B-i Licensed Nuclear EegnyPa al / 2L oN Liceanse Nueratr(R Emergency Plan Table N/A T2/L4 No No NnLicensedNula 65 ula Plant Oeao R Emergency Plan Table N/A T2/L6 No No Operatr (NL #1) -i Non-LicensedT5L 6 Nucler Plant Emergency Plan Table NAT2LNoo Operator (NLO #2) ______ TL1 ______Non-Licensed Emrgnc/PanTal 8 Nuclear Plant B-ignc N/ATale 6 N5/A1 No No Operator (NLO #3) T5/L13____

_____________

Non-Licensed 9 ula ln Emergency Plan Table N/A N/A No No Nuclar Pant B-i Operator (NLO #4) ______Non-Licensed EegnyPa al 10 Nuclear Plant B-igny la abe N/A N/A No No Operator (NLO #4)______10 FireBiade

1. 1an Emergency Plan Table N/A N/A No No_____ _____ ____ B-i1_ _ _ _ _ _12 Fire Brigade #2 Emergency Plan Table N/A N/A No No 13 RP / Chemistry Emergency Plan Table 60 T5/L12 No No Technician B-i1______

______14 RP Technician Emergency Plan Table 60 T4/L1 No No B-i1______

T4/L2 __ ____ ______15 Security Security Contingency 60 T5/L1 5 No No______________Plan

/ E-Plan Table B-i1 ______ _______ ____________

PNPS Page 28 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Line # Generic Title/Role On-Shift Position Task Analysis 1 Shift Manager Shift Manager raiicnge POperamo______ ___ ____ ___ ___ ____ ___ ___ ___ ___ ___ ____ ___ __ TrainingProg~ram 3 Licensed Operator Shift TuehialAvisor Shiftro Engine uer/STA r Trainingl Program Licesed uclar Pant Licensed Operator 4 SReato Operhiat dior #Shperto #1inerSTraining Prog~ram 5 eco prtr# Licensed Nuclear Plant Licensed Operator RatrOeao#2Operator

1. 12 Training Program 6 uxiciary Operator #1 NnLicensed Nuclear Pl n on-Licensed Operator Pln Operator #1 Training Program 7 Auxiliary Operator #21/8 Other needed for Safe Shutdown N/A X/9 Other needed for Safe Shutdown N/A X/10 Other needed for Safe Shutdown N/A /Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic TitlelRole On-Shift Position Task Analysis Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 I&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A PNPS Page 29 PNPS Page 29 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade 5 N/A N/A Note: The LOCA does not include a fire.PNPS Page 30 PNPS Page 30 PNPS ON-SHIFT STAFFING ANALYSIS REPORT LRP#1(ositionPromen requirements)

& as directed by SM _2 On-site Survey:X X X X X X X X 3 Personnel Monitoring:

N/A T Job Coverage: N/A__50Offsite Rad Assessment: (Included in Table 5 6 Other site specific RP (describe):

N/A 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

.__N/A*Prorac Times are estimated PNPS Page 31 PNPS Page 31 PNPS ON-SHIFT STAFFING ANALYSIS REPORT i ! Func ion. Task O rrS it i P A nalysis:................

Emergency Planning 1 Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills 2 pprove Offsite Protective Action SitMngrEmergency Planning 2 Recommendations ShfTangrraining Program Emergency Planning 3 Approve content of State/local notifications Shift ManagerrangPorm Emrgencyg Planning 4 Approve extension to allowable dose Shift Manager Emraining Progamnn Notiicaionand iretio to n-siftstaf (eg.,Licensed Operator Training to assembleio evacuaireten etc.) siftff(. Shift Manager Program I Emergency_____assemb

_____e,__evacuate,______et___.___Planning Training Program Emergency Planning 6 ERO notification Shift Manager Training Program 7 Abbreviated NRC notification for DBT event N/A Lcne prtrTann____ ___ ___ ___ ___ ___ ___ ____ ___ ___ ___ ___ ___ ___ __ rogram Emergency Planning 8 Complete State/local notification form Shift ManagerrangPorm Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civat ERD raiingProgram 11 AciTechnicianO#2Emergency Planning 12' Offsite radiological assessment Chemistry ehnca Emraining Progamnn 13 Prfom NR noifiatios NO#2Emergency Planning 13 Prfom NR noifiatios NO#2Training Program 14Perform other site-specific event notifications SitMngrLicensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) Program__________________

15 Personnel Accountability Security Security Training Program PNPS Page 32 PNPS Page 32 PNPS ON-SHIFT STAFFING ANALYSIS REPORT D. Design Basis Accident Analysis #5 -Main Steam Line Break 1. Accident Summary* This event involves the postulation of a large steam line pipe break outside containment.

It is assumed that the largest steam line instantaneously and circumferentially breaks at a location downstream of the outermost isolation valve. The plant is designed to detect immediately such an occurrence, initiate isolation of the broken line, and actuate the necessary protective features.

This postulated event represents the envelope evaluation of steam line failures outside containment.

2. Accident Specific Assumptions Made* Emergency Classification is not required based on the break of the main steam line. This analysis EAL is based on the FSAR MSLB accident EAB dose.3. Procedures for Accident Response* EP-IP-IO00, Emergency Classification and Notification

• EP-IP-1 00.1. Emergency Action Levels* EP-IP-300, Offsite Radiological Dose Assessment

• EOP-01, RPV Control* EOP-3, Primary Containment Control* EOP-5, Radiological Release* 2.1.6, Reactor Scram* EP-IP-300, Offsite Radiological Dose Assessment

• 6.3-064, EOP-4 Surveys PNPS Page 33 PNPS Page 33 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tablesi : ,,

= A P PE.N D IX B =:=:, i ::'On-shift Pos =itin E-Pan:= Reference..

=Augnmertation Role In Tlable Unana...................yzed............

T2/LI T5/L1 T5/L3 1 SitMngr Emergency Plan 60 TISNo Yes Shf aae able B-I T5/L6 T5/L8 T5/L10 T5/L 14 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Table B-i Shift Technical 3 Advisor/Shift Emergency Plan 6 2L oN____Engineer,_(3 rd SRO) Table B-I 0T/L oN Licensed Nuclear EegnyPa / 2L 4 Plant Operator (RO Tablgenc B-I/AT2L No No______ 1)Licensed Nuclear EegnyPa / 2L 5 lant Operator (RO Emrec ln NAT/5No No____2) Table B-I Non-Licensed 6 Nuclear Plant Emergenc Plan N/A T2/L6 No No____Operator (NLO #1)TalB-Non-Licensed T5/L9 7 Nuclear Plant Emergency Plan 6 5L oN Operator (NLO #2)al -T5/L1 3 _____Non-Licensed 8 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #3)TalB-Non-Licensed 9 Nuclear Plant Emergency Plan N/A NIA No No____Operator (NLO #4) al -Non-Licensed 10 NcerPat Emergency Plan N/A N/A No No____Operator (NLO #5 al -11 Fire Brigade #1 Emergency Plan NIA N/A No No_____ _____________

Table B-i1______

______12 Fire Brigade #2 Emergency Plan N/A N/A No No_____ _____________

Table B-I1______

______13 RP / Chemistry Emergency Plan 60 T5/L12 No No____echnician Table B-I 14 RP Technician Emergency Plan 60 T4/L1 No No T____________able B-I T4/L2 Security 15 Security Contingency Plan 60 T5/L15 No No___________________

/ E-Plan Table B-i1 _____________

_____________

PNPS Page 34 PNPS Page 34 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLE 2- =PLANT OPERATIONS

& SAFE SHUTDOWN=i : ;i;i Analysis # 5 MaIn SteamrLneBak(LB Minimum Operations Crew Necessary to Implement AQPs and EOPs or SAMGs if Applicable Line =# Generic Titl~elRole

'!:: : = On-Shift i :i Tsk Anialysisl , 1 Shft anaer SiftMangerLicensed Operator ShiftManagerShiftManager raining Program 2 Unit Supervisor Control Room Supervisor Licensed Operator_______Training Program 3 Licensed Operator Shift Technical Advisor Shift Engineer/STA Training Program 4 RatrOeao#1Licensed Nuclear Plant Licensed Operator RatrOeao#1Operator

1. 1 Training Program 5 RatrOeao#2Licensed Nuclear Plant Licensed Operator RatrOeao#2Operator

1. 2 Training Program 6 Auxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 jOther needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line'# Generic Title/Role On-Shift Position Task Analysis_________________________

_______________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A Nl/A PNPS Page 35 PNPS Page 35 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The MSLB analysis does not include a fire.PNPS Page 36 PNPS Page 36 PNPS ON-SHIFT STAFFING ANALYSIS REPORT: ......... ,.,:,;Analysis

1. 5 M ain Steam : Line ,Break: M

.... ..........

...I Function / Task __ __ ___;____! N 5 15 25 35 45 55 65 75 85-E 010 15 20 25 30 35 4045 50 55 60 65 70 75 8085 90 1 In-Plant Survey:_RP#1 X X X X X X 2 On-site Survey:X X X X X X X X X RP#1 3 Personnel Monitoring:

N/A_4 Job Coverage: N/A.50Offsite Rad Assessment:

Tabie 5 6 Other site specific RP (describe):

N/A 7 Chemistry Function task #1 (describe)

_N/A_8 Chemistry Function task #2 (describe)

N/A___*Performance times are estimated Notes: RP Survey RX bldg. around scram valves (6.2-064) then performs onsite surveys Chemistry secure oxygen injection as directed by SM PNPS Page 37 PNPS Page 37 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLEIF 5-TEMERGNCY PANAMLYSISREPORT I a;I~ plI Q Line#iucto

.......OnShif PostionTask Analys Emergency Planning Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills 2 pprove Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program 3 Approve content of State/local notifications Shift Manager Eraining Progamnn I Emergency Planning 4 Approve extension to allowable dose IN/ArangPorm Licensed Operator Training Notification and direction to on-shift staff Shift Manager Program /Emergency

,(e.g., to assemble, evacuate, etc.) Planning Training Program 6 IEO ntifcaton SiftMangerEmergency Planning 6 ER notficaionShif Mangerraining Program Licensed Operator Training 7 Abbreviated NRC notification for DBT event NI/APrga Emrogenya lnnn 8 Complete State/local notification form Shift Manager Eeraining Progamnn 9 P)erform State/local notifications NLO#2 Emergency Planning_____________________________

________________

Training Program" Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 EDS NO#2Emergency Planning 11 ctvateERDS LO#Training Program Techncian Emergency Planning 12 Offsite radiological assessment Chemistryi Tcnia Training Program 13 Prfom NR noifiatios NO#2Emergency Planning 13 Prfom NR noifiatios NO#Training Program 14 Perform other site-specific event notifications Shift Manager Licensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) ___________Program 15 Personnel Accountability Security Security Training Program PNPS Page 38 PNPS Page 38 PNPS ON-SHIFT STAFFING ANALYSIS REPORT E. Design Basis Accident Analysis #6 -Fuel Handling Accident 1. Accident Summary* The fuel handling accident is assumed to occur as a consequence of a failure of the fuel assembly lifting mechanism, resulting in the dropping of a raised fuel assembly onto the core. The drop causes mechanical damage to the bundle being dropped.* The drywell and reactor building are open with ventilation running. All releases to the environment are through the reactor building ventilation.

• The drop of a fuel bundle in containment over the reactor pressure vessel bounds a drop of a fuel bundle in the fuel building due to the greater drop height.2. Accident Specific Assumptions Made* Onsite personnel will be in accordance with the refuel outage staffing plan that includes additional SROs, ROs, NLOs, RP Techs, and Maintenance.

3. Procedures for Accident Response* EOP-5, Radioactive Release Control* 5.4.3, Refueling Floor High Radiation PNPS Page 39 PNPS Page 39 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables APPENDX B! TABL I N-SHIFT POSITIONS; inel Au m naio... ... ....Ro....l in.. Unana..yzed TMSII T2/L1 T5/L1 T5/L3 Emergency Plan 60T5/L5 No Yes I Shift Manager Table B-i16 T5/L6 T51L8 T5/L1 0____ ___ ___ ___ __ ___ ___ ___ __ ___ ___ ___ ___ T5/L 14 2 Control Room Supervisor Emergency Plan N/A T2/L2 No No Table B-i Shift Technical EegnyPa 3 Advisor/Shift Engineer Table B-i2/ / / /___(3 rd SRO)__ ______4Licensed Nuclear Plant Emergency Plan N/A T21L4 No No Operator (RO #1) Table B-i1_________

_____Licensed Nuclear Plant Emergency PlanN/T2LNoo Operator (RO #2) Table B-i1____ ______ _____6Non-Licensed Nuclear Emergency Plan N/A T21L6 No No Plant Operator (NLO #1) Table B-i______

__________

_____T5/L9 7Non-Licensed Nuclear Emergency Plan 60 T5/L11I No No Plant Operator (NLO #2) 'able B-i T5/L1 3_____ ____8 Nlon-Licensed Nuclear iEmergency Plan N/A N/A No No Plant Operator (NLO #3) Fable B-i1________

____ ___________

Non-Licensed Nuclear Emergency Plan N/A N/A No No Pl:)ant Operator (NLO #4) B-i1________

___________

10 Non-Licensed Nuclear IEmergency Plan N/A N/A No No Plant Operator (NLO #5) rable B-i1________

____ ___________

11 Fire Brigade #1 Emergenc Plan N/A N/A No No 12Fr rgd 2Emergency Plan N/A N/A No No__2 __ire _Brigade_#2_Table B-i1________

_ _ _ _ ______ _____13 RP / Chemistry Emergency Plan 60 T5/L12 No No Technician Iable B-i_________

_____ ___ ____ _____14 RPTechnician Emergenfcy Plan 60 T4/L3 No No able B-i1_ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _Security 15 Security Contingency Plan / 60 T5/L1 5 No No_________________E-Plan Table B-I_______

_____PNPS Page 40 PNPS Page 40 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNS.A.E2-PLN OPERATION

& SAF SHU.TDOWN " .........

.. ...I J.. ........ .. ...................

........I LO neI ...UItI -l O n e.. n tro R o o m. ..... ....I ...... .... ...I [. .:::: ::,,:... ...

1. 8 -F elH nd ig.c id n Line # Generic Title/Role On-Shift Position task Analysis_________________________________________

ontrolling Method Licensed Operator I Shift Manager Shift Manager Training Program 2 Unt Speriso CotrolRoo SuervsorLicensed Operator___ nit Supervisor______ontrol__Roo__

Supervisor_____

Training Program 3 Licensed Operator Shift Technical Advisor ]Shift Engineer/STA Training Program 4 Ractr Oeraor 1Licensed Nuclear Plant Licensed Operator 4 RatrOeao#1Operator

1. 1 Training Program.5 Leco prtr# icensed Nuclear Plant Licensed Operator RatrOeao#2Operator

1. 2 Training Program 6 ,uxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator_____ _______________________Plant Operator #1 Training Program 7 ,uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other' needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis________________________

_______________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A PNPS Page 41 PNPS Page 41 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade:i:~~~~PNPS ,TABLE :3'-:FIREFIGHTING::I, .:, I N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A-5 N/A N/A Note: FHA does not include a fire.PNPS Page 42 PNPS Page 42 PNPS ON-SHIFT STAFFING ANALYSIS REPORT N ; 5 30-: 35 45- 50-" 55-' 60 :70 80- I In-Plant Survey: N/A___2 On-site Survey: N/A 3 Personnel Monitoring:

RP#1X X X X X T Job Coverage: N/A 50Offsite Rad Assessment: (Included in Table 6 IOther site specific RP (,describe):N/A

.7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A _*Times are estimated Note: RP#1 assist in monitoring and decon Of building evacuees at the Green Line.Additional RP on shift for refueling/outage to assist with tasks PNPS Page 43

.PNPS ON-SHIFT STAFFING ANALYSIS REPORT i =iio: PN=: PS TABLE EMERGENCY IM PLEM ENTATION~i:; i LieFuncto I Tsk*I On-Shift Positio 1 Declare the emergency classification level ShftMaagrraining ProgamnniEP (ECL) Drills 2 ,pprove Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program 3 &pprove content of State/local notifications Shift Manager Emraining Progamnn Emrgencyg Planning 4 &pprove extension to allowable dose N/A Emraining Progamnn LcneOprtrTrainingPrga Notification and direction to on-shift staff (e.g., ShitcanaerProra OpEergerrancy g t o assemble, evacuate, etc.) SitMngrPlanigTra inin Pmrogramy EegnyPlanning Tann rga 6 ERO notification Shift Manager Emraining Progamnn Licensed Operator Training 7 /bbreviated NRC notification for DBT event N/APrga Emrogenya lnnn 8 Complete State/local notification form Shift Manager Emraining Progamnn Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 raningProgram 11 Planning 12 Offsite radiological assessment Chemistry Tcnia Emraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NLO#2 Emraining Progamnn 14Perform other site-specific event notifications SitMngrLicensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) rga 15 Personnel Accountability Security Security Training Program PNPS Page 44 PNPS Page 44 PNPS ON-SHIFT STAFFING ANALYSIS REPORT F. Accident Analysis #8 -Aircraft Probable Threat 1. Accident Summary* The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 minutes, but less than 30 minutes from the site, and considers the dispersal of the site fire brigade away from target areas for firefighting.

• The analysis does not include a scenario or response actions taken during or after a crash.2. Accident Specific Assumptions Made* The Shift Manager receives the call from the NRC of probable aircraft threat.* All non-security on-shift personnel are inside the protected area fence at their normal workstation.

3. Procedures for Accident Response* 5.3.1 4.1, Airborne Threat PNP Pae 4 PNPS Page 45 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables i ,:-________Aayi

_________

,.

; : :: ::: A ugme:ntation Role :in Table # !

i TMS Required?Line # On-shift Position E-Plan Reference ;Time I ::Line #:I T :;:ask? ' :,, T2/L1 T5/LI T5/L3 1Shift Manager Emergency Plan 60 T15No Yes Table B-I T5/L6 T5/L8._ T5/L1 0________________

T5/L14 _ _ _ _ _ _2 Control Room Emergency Plan N/A T2/L2 No No__ _Supervisor Table B-i _______ _______ ______Shift Technical EegnyPa 3 Advisor/Shift Emrec ln60 T2/L3 No No___Engineer (3 rd SRO) TaleB-Licensed Nuclear EegnyPa / 2L 4 Plant Operator (RO ablrenc B-I/AT2L No No Licensed Nuclear EegnyPa / 2L 5 Plant Operator (RO ablrenc B-i /AT2 No No#___ 2) _________Non-Licensed EegnyPa oN 6 Nuclear Plant EegnyPa / 2L oN___Operator (NLO #1) al -/ 2L Non-Licensed T5/L9 7 lant Emergency Plan60T/1Noo 7 Nucler Plant Table B-i10T/I oN___)perator (NLO #2) ________T5/L1 3 _____ _____Non-Licensed EegnyPa / 3L oN 8 Nuclear Plant EegnyPa / 3L oN___Operator (NLO #3) al -Non-Licensed EegnyPa / 3L oN 9 Nuclear Plant EegnyPa / 3L oN___Operator (NLO #4) al -Non-Licensed EegnyPa 10 Nuclear Plant EegnyPa / 3L oN Operator (NLO #5 al -/ 3L oN 11Fr rgd 1 Emergency Plan N/A T3/L4 No No 11 _FireBrigade#1 Table B-i1______

______12 Fire Brigade #2 Emergency Plan N/A T3/L5 "No No T________

able B-i _______ _ __ _ _ _13 RP / Chemistry Emergency Plan 60 N/A No No Technician Table B-i1______

14 RPehiin Emergency Plan 60 T4/L6 No No RP Technician able B-I1______

______Security Contingency 15 Security Plan / E-Plan Table 60 N/A No No____ _______________

EB-I__ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _PNPS Page 46 PNPS Page 46 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Line # Generic TitlelRole

'On-Shift Position Task Analysis_____ _________________________

________________Controlling Method 1 Ishift Manager Ishift Manager Licensed Operator______ __________________________

________________Training Program 2 Jnit Supervisor Control Room Supervisor Lricnsed OPeraogra 3 hitTechnical Advisor Shift Engineer/STA Licensed Operator ShiftTraining Program 4 Ractr pertor#1Licensed Nuclear Plant Licensed Operator 4 ecorOeatr#

perator #1 Training Program 5 Reactor Operator #2 Licensed Nuclear Plant Licensed Operator____uiiayOeao Operator #2 Nuler raining Program 6 uxliryOpraor#1Non-licensed Ncer Non-Licensed Operator P~lant Operator #1 Training Program 7

1. 2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis____ _ _ ___ ___ ____ ___ ___ ___ ___ ___ ___ ___ ___ ___ Controlling Method 11 Mechanic N/A NI/A 12 Electrician N/A N/A 13 I&C Technician N/A N,/A 14 Other N/A N/A 15 Other N/A Nl/A PNPS Page 47 PNPS Page 47 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade i! PN

, :ii!':ii: : B LEicr f:: :: 3 -..... rob beEFaIG HT........ .IN G: ....:i == : ,.' :=' :,;: :...:::::..

',: ' ..1 NLO #3 Fire Brigade Training 2 NLO #4 Fire Brigade Training 3 NLO #5 Fire Brigade Training 4 FB #1 Fire Brigade Training 5 FB #2 Fire Brigade Training Note: FB goes to hardened facility outside the reactor building after performing tasks directed by the CRS.PNPS Page 48 PNPS Page 48 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Lv PoitonPefomance Time Period After. Emergency Declarato (mnte)I In-Plant Survey: 2 On-site Survey: 3 Personnel Monitoring:

____T Job Coverage: 5 Offsite Rad Assessment: (Included in Table 5 6Other site specific RP#1 goes to outside PA TChemistry Function task #1 (,describe) 8Chemistry Function task #2 (describe)

Note: RP relocates to outside the protected area but stays on PNPS property and Chemistry evacuates the process building and takes cover in a secure area.PNPS Page 49 PNPS Page 49 PNPS ON-SHIFT STAFFING ANALYSIS REPORT'I!"i;:~PN PS TABLE 5- E MERGENCY PLAN IMPLEM ENTATION!

i !,.: =.' :;Function.ITask*

Position:

! l i"Task " " ....

Co tr lln M ethod Emergency Planning Declare the emergency classification level SitMngrriigPormIE (ECL)Drills 2 Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program] Emergency Planning 3 &pprove content of State/local notifications Shift Manager Training Program 4 &prov exenson o alowale oseN/AEmergency Planning 4 ppove xtesionto llowbledoseN/Araining Program Licensed Operator Training 5 Notification and direction to on-shift staff (e.g., Shift Manager Program I Emergency to assemble, evacuate, etc.) Planning Training Program 6 ER notficaionShif MangerEmergency Planning 6 ER notficaionShif Mangerraining Program Licensed Operator Training 7 Abbreviated NRC notification for DBT event N/APrga Emergency Planning 8 Complete State/local notification form Shift ManagerrangPorm Emrgencyg Planning 9 Perform State/local notifications NLO#2 Eraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae EDS NO#2raiingProgram ChemistryteTechnician#2Emergency Planning 12 Ofsie raiolgicl asessentraining Program Emergency Planning 13 Perform NRC notifications NILO#2 Emraining Progamnn Perform other site-specific event notifications Licensed Operator Training 14 Shift ManagerPrga (e.g., Duty Plant Manager, INPO, ANI, etC.) Program_____

____________

15 Personnel Accountability N/A Security Training Program PNPS Page 50 PNPS Page 50 PNPS ON-SHIFT STAFFING ANALYSIS REPORT G. Accident Analysis #9 -Control Room Evacuation and Alternate Shutdown 1. Accident Summary* Fire in the Main Control occurs that requires control room evacuation.

• Station personnel evacuate the control room taking time only for those immediate actions within the control room that can be accomplished in seconds. Station personnel take all subsequent action required to bring the reactor to a cold shutdown condition using controls and equipment located outside the control room.2. Accident Specific Assumptions Made* The ATC operator will perform the immediate actions of the procedure to initiate a manual scram and verify all rods in before evacuating the control room.* Subsequent actions are performed from outside the control room.3. N Procedures for Accident Response* 2.4.143, Shutdown From Outside the Main Control Room* EP-IP-1 00, Classification and .Notifications

• EP-IP-1 00.1, EALs PNPS Page 51 PNPS Page 51 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables ILine # On-shift Reference Elapsed Yim+e!.

1. i Task?,:;::

T2/LI T5/Ll T5/L3 1 Shift Manager Emergency Plan 60T5/L5 N e Table B-I 6 T5/L6 N e T5/L8 T5/LI10________________

~~~T5/L 14 __ _ _ _ __ _ _ _ _ _ _2Control Room Emergency PlanN/T2LNoo Supervisor Table B-i / 2L oN Shift Technical EegnyPa 3 Advisor/Shift EegnyPa___Tnier(r R) able B-i 60 T2/L3 No No Licensed Nuclear 4 Plant Operator (RO Emrec lnNAT/4No No#1 ) able B-i Licensed Nuclear 5 Plant Operator (RO Emergency PlanN/T2LNoo Table B-1i/ 2L oN Non-Licensed 6 Nuclear Plant Emergency PlanN/T26Noo

___Operator (NLO #1) al -Non-Licensed T51L9 7 Nuclear Plant Emergency Plan60T/iNoo Table B-i 0T/1 oN Operator (NLO #2) _______T5/L13______

Non-Licensed 8 Nuclear Plant Emergency PlanN/T3LNoo Operator (NLO #3) al -Non-Licensed 9 Nuclear Plant Emergency PlanN/T32Noo

___Operator (NLO #/4) al -Non-Licensed EegnyPa 10 Nuclear Plant NoegecNola

___Operator (NLO #5) al -/ 3L 11 Fire Brigade #1 Emergency PlanNAT34Noo T_________

able B-i N__AT3/L4

_ No______ No_____12 Fire Brigade #2 Emergency Plan N/A T3/L5 No No_____ _____ ___ Table B-I1_ _ _ _ _ _ _ _ _ _ _ _ _ ______13 RP / Chemistry Emergency Plan 6 / oN Technician Table B-i 60______ N/A_____ No____No _14 RP Technician Emergenc Plan 60 T4/L4 No No Security 15 Security Contingency Plan/I 60 N/A No No______________E-Plan Table B-1 _______ ______ ______ ______PNPS Page 52 PNPS ON-SHIFT STAFFING ANALYSIS REPORT*PNPS TABLE 2 _-: PLANT OPERATIONS

& SAFE SHUTDOWN : , i:: : :i illAnalysis

1. 9- CR,,Evacuation

&Alternate Minimu'm Operations Crew Necessary to Im plemnent AOPs :an~d EOs o=r =SAMGs !if Applicable

,= Line # Generic Title/Role On-Shift Position Task Analysis_________________________Controlling Method Licensed Operator 1 Shift Manager Shift Manager Training Program SuperisorLicensed Operator 2 Unit Supervisor Control Room Sprio Training Program Shift Technical Advisor Shift Engineer/STA Lricnsed OPeraogra 4 Ractr pertor#1Licensed Nuclear Plant Licensed Operator 4 eco peao 1Operator

1. 1 Training Program 5 Ractr pertor#2Licensed Nuclear Plant Licensed Operator 5 eco peao 2Operator

1. 2 Training Program 6 Auxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator_______________________Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role IOn-Shift Position Task Analysis_____ __________________________Controlling Method 11 Mechanic N/A N/A 12 Electrician N/A N/A 13 I&C Technician N/A N/A 14 Other N/A N/A 15 Other N/A N/A PNPS Page 53 PNPS Page 53 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade: .. ..i: :': : ::.... ...i : : : P : NPS TABLE .. .. ...C ~~3:- FIREFIGHTIT NG : at n it r te$ " ' : ::o. :., :: L .. ...ne ..... Per......

fo iirmed llllil by ' i Taski A ay is Co toln Method 1 NLO#3 Fire Brigade Training 2 NO4Fire Brigade Training 5 FB2Fire Brigade Training PNPS Page 54 PNPS Page 54 PNPS ON-SHIFT STAFFING ANALYSIS REPORT:: .....PNPS.TABLE 4- RADIATION PROTECTION ANDi CHEMISTRY/,,:,=

.. ,:=,=..... Analysis #9 CR Evacuation

& Alternate E 0-5atigfas:i:

2.:: 10- :i 1'5- 20-.125. 35 '45- 50-~ 55 i65- 70-1"75-180- ______.___

"., 101::f5.20.'25;-30=:

35: '40 4:5: :50: 55 :601 6570 ,o:75'80 o/85,:90: 1 In-Plant Survey: 2 On-site Survey: 3 Personnel Monitoring:

___4 Job Coverage: RP#lSupport X X X X X X X X X X X X X X X X X FB 50Offsite Rad Assessment: (Included in Table 5 6 Other site specific RP (describe):

7 Chemistry Function task #1 (describe) 8 Chemistry-Function task #2 (describe)

PNPS Page 55 PNPS ON-SHIFT STAFFING ANALYSIS REPORT! ":PN PS 5- ERGEN CYi PLEAN I1M PLEM ENTATI O i, Declre he mergncyclasifiatin lvelEmergency Planning DECLar)h mrec lasfcto ee Shift Manager Training Program i EP (ECL)Drills ,pprove Offsite Protective Action Emergency Planning 2 Recommendations N/A Training Program 3 Approve content of State/local notifications Shift Manager Emraining Progamnn Emrgencyg Planning 4 Approve extension to allowable dose N/A Emraining Progamnn Notiicaionand iretio to n-siftstaf.(eg.,Licensed Operator Training Noiia5naddrcin oo-hf tf egShift Manager Program / Emergency to assemble, evacuate, etc.) Planning Training Program Emergency Planning 6 ERO notification Shift ManagerrangPorm Licensed Operator Training 7 Abbreviated NRC notification for DBT event N/APrga 8 Complete State/local notification form Shift Manager Emraining Progamnn 9 Perform State/local notifications NLO#2 Emergency Planning Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae EDS NO#2raiingProgram 11 Ativae EDS NO#2Emergency Planning 12 Offsite radiological assessment N/A Emraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NLO#2 Emraining Progamnn 14Perform other site-specific event notifications SitMngrLicensed Operator Training (e.g., Duty Plant Manager, INPO, ANI, etc.) _______rogram____________

15 Personnel Accountability N/A Security Training Program PNPS Page 56 PNPS Page 56 PNPS ON-SHIFT STAFFING ANALYSIS REPORT H. Accident Analysis #10 -Station Blackout 1. Accident Summary* At power, normal lineups and no additionai events* RCIC starts to restore level and SRVs lift in the relief mode to control pressure 2. Accident Specific Assumptions Made* Assume the Shift Manager recognizes power cannot be restored within 15 minutes after the loss before the 15 minute SBO EAL period has expired.3. Procedures for Accident Response* 5.3.31, Station Blackout* EP-IP-1 00, Classification and Notifications

• EP-IP-1 00.1, EALs* EP-IP-410, Evacuation and Assembly PNPS Page 57 PNPS Page 57 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables i

,: PN PS:; :)i E ON DS I :

i:; ':-___________

Anaysis#10 Staton BackoT2/L1___

T5/L5 T5/L8 T5/L31 T5/L14 2 Control Room Emergency Plan N/A T2/L2 No No Supervisor Table B-I 3AvsrShiftTehia Emergency Plan 60 T2/L3 No, No Engineer (3 rd SRO) Table B-I iLcensed Nuclear 4 Plant Operator (RO Emergency Plan N/A T2/L4 No No-~Table B-i Licensed Nuclear EegnyPa 5 Plant Operator (RO ablrenc B-i n N/A T2/L5 No No Non-Licensed EegnyPa /6 Nluclear Plant Emrec lnNAT2/L6 No No Operator (NLO #1) al -Non-Licensed EegnyPa60T5/L9 7 Nuclear Plant -EegnyPa60T5/LI I No No Table B-I Operator (NLO #2) T5/L13_____

Non-Licensed EegnyPa / / oN 8 Nuclear Plant EegnyPa / / oN Operator (NLO #3) al -Non-Licensed EegnyPa / oN 9 Nuclear Plant EegnyPa / / oN Operator (NLO #4) al -/Non-Licensed 10 Nuclear Plant Emergency Plan N/A N/A No No Operator (NLO #5) al -11Fr rgd 1 Emergency Plan N/A N/A No No 12 Fire Brigade #2 ,Emergency PlanN/NANoo

_______ _____ Table B-I1/ / oN 13RP / Chemistry Emergency Plan 60 N/A No No 13 Technician Fable B-I1________

____ _____14 RP Technician Emergency Plan 60 N/A No No_____________

TableB-I1_____________

Security 15 Security Contingency Plan / 60 T5/L15 No No______________E-Plan Table B-i1 ________ _____ ______ _____PNPS Page 58 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNPS TABLE 2 ~- PLANT OPERATIONS

& SAPE SHUTPOWN One Unit -One Control Room Analysis #10 -Station Blackout.Mnim~um Oper#ations Cirew N e essary: to Imple6m ent: AO Ps .and EOPs or .SA Ms Iif

i;Line # Generic Title/Role On-Shift Position Task Analysis________________Controlling Method 1 Shft anaer SiftMangerLicensed Operator I Shft Mnage Shit Maagerraining Program 2 Unit Supervisor Control Room Supervisor Licensed Operator Training Program Licensed Operator 3 Shift Technical Advisor Shift Engineer/STA Training Program 4 Ractr pertor#1Licensed Nuclear Plant Licensed Operator 4 RatrOeao#1Operator

1. 1 Program ,5 RatrOperator

1. 2 Licensed Nuclear Plant Licensed Operator RatrOperator

1. 2 Training Program 6 Auxiliary Operator #1 Non-licensed Nuclear Non-Licensed Operator_____ _______________________Plant Operator #1 Training Program 7 Auxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis_____ _______________

ontrolling Method 1 1 Mechanic N/A N/A 1 2 Electrician N/A N/A 1 3 l&C Technician N/A N/A 1 4 Other N/A N/A 1 5 Other N/A N/A PNPS Page 59 PNPS Page 59 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade TABLE

L:f¸ilG 1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The Station Blackout Analysis does not include the need for firefighting.

PNPS Page 60 PNPS Page 60 PNPS ON-SHIFT STAFFING ANALYSIS REPORT E -, :10 ,:15i i25 30: 35!: 40 4:5 150' :55; 75 80 :85': 90,-1 In-Plant Survey: N/A 2 On-site Survey: N/A 3 Personnel Monitoring:

_N/A T Job Coverage: N/A__50Offsite Rad Assessment:

._Included in Table 5 6 Other site specific RP (describe):

N/A 7 Chemistry----------------------------

---

Function task #1 (describe)

N/A___8 Chemistry Function task #2 (describe)

N/A__Note: RP and Chemistry do not have an assigned task for SBO. Chemistry is available for dose assessment if a release occurs.PNPS Page 61 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Declre te emrgeny ca nsfialyisn

1. 10e EmStationBlackout Delr1h megnycasfiainlvl Shift Manager Training Program I EP (ECL) D:rills 2 pprove Offsite Protective Action NAEmergency Planning 2 Recommendations N/Araining Program 3 Approve content of State/local notifications Shift Manager Emraining Progamnn Emergencyg Planning 4 Approve extension to allowable dose N/A Emraining Progamnn Lricnsed OPeraorgra inn Notification and direction to on-shift staff (e.g., ShitcanaerProra

/OEergerrancy g 5 to assemble, evacuate, etc.) SitMngrPlanigTra inin Pmrogramy EegnyPlanning Tann rga 6 ERO notification Shift Manager Emraining Progamnn Licensed Operator Training 7 Abbreviated NRC notification for DBT event N/APrga Emrogenya lnnn 8 Complete State/local notification form Shift Manager Emraining Progamnn Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae EDS NO#2raiingProgram 11 EDS kLO#2Emergency Planning 12 Offsite radiological assessment Nl/A Emraining Progamnn Emrgencyg Planning 13 Perform NRC notifications NiLO#2 Emraining Progamnn Perform other site-specific event notifications Licensed Operator Training (4re.g., Duty Plant Manager, INPO, ANI, etc.) __hift ____Manager_____Program___

15 Personnel Accountability Security Security Training Program PNPS Page 62 PNPS Page 62 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Accident Analysis #11 -LOCA/General Emergency with Release and PAR 1. Accident Summary (Assumed for Staffing Analysis Purpose)* The unit is in a Site Area Emergency ASI when the Shift Manager is given a dose assessment update that projects >1 Rem TEDE dose at the site boundary.2. Accident Specific Assumptions Made* All actions for SAE are complete.* No transients other than LOCA are considered.

• The ERO would be activated at an Alert or SAE. For Staffing Analysis purpose, the T=0 clock is used for the emergency plan actions to evaluate the capability to implement the GE classification, PAR and notification functions before the ERO arrives.3. Procedures for Accident Response* EP-IP-1 00, Emergency Classification and Notification

• EP-IP-1 00.1, Emergency Action Levels* EP-IP-300, Offsite Radiological Dose Assessment

• EOP-05, Radiological Release* EOP-01, RPV Control* EOP-03, Primary Containment Control* EOP-04, Secondary Containment Control* EP-IP-400, PAR PNPS Page 63 PNPS Page 63 PNPS ON-SHIFT STAFFING ANALYSIS REPORT 4. Tables::' : * !:

!I P EN I B !: : :: : APPENDIX

Role inTable #

TMS Req'uired?

T2/L1 T5/L1 T5/L2 T5/L3 1 Shift Manager Emergency Plan 60 T5/L4 No No Fable B-i T5/L5 T5/L8 T5/LI10____ ____ ____ __ _ ____ ____ ___ ____ ____ ___ T5/L14 _ _ _ _ _ _ _ _ _ _ _ _ _2 Control Room Emergency Plan N/A T2/L2 No No____Supervisor Fable B-I1______

______Shift Technical EegnyPa oN 3 Advisor/Shift EerecPan6T2LNoo

___Eng]ineer (3 rd SRO) 'able B-i10T2L Licensed Nuclear EegnyPa / 2L 4 Plant Operator (RO Emrec lnNAT/4No No_____ 1)able B-I Licensed Nuclear 5 Plant Operator (RO Emergency PlanN/T2LNoo T__ )able B-I / 2L oN Non-Licensed EegnyPa / 2L oN 6 Nuclear Plant EegnyPa / 2L oN___Operator (NLO #1) al -Non-Licensed -mrec lnT5/L9 7 EmergencyPPlan 60 T5/L1 1 No No Nuclear Plantable B-i15L3 _______ _________Operator (NLO #2) TS/L13_________________

Non-Licensed 8 Nuclear Plant Emergency Plan N/A N/A No No___Operator (NLO #3) al -Non-Licensed 9 Nuclear Plant Emergency Plan N/A N/A No No'O p e ra to r (N L O # 4 ) _ __ab le_ _ _ _ _ __B-1_ _ _Non-Licensed EegnyPa 10 Nuclear Plant Emrec lnNANANo No___Operator (NLO #5) ___able_ _ __ _ __ __ _ ___-1_ __ _Emergency PlanN/NANoo 11 Fire Brigade #1 Nobl No" ~~~Emergency PlanNAN/Noo 12 Fire Brigade #2 Nobl No 13RP / Chemistry Emergency Plan 6T5L2No No 13 rechnician Table B-i1______

______ ______14 RP Technician Emergency Plan 60T4/L2Noo

___able____

B-1_____ ________ T4/L6Noo 15 Security Contingency Plan / 60 N/A No No______________E-Plan Table B-i1 _______PNPS Page 64 PNPS Page 64 PNPS ON-SHIFT STAFFING ANALYSIS REPORT: ...... PNPS.- T.ABLE 2- IPL'ANT OPERATIONS SAFE SHUTDOWN:i ":: :*i : , M.nim m .Opeation Crew. Ne.essar to....mpl........e.....

..A.. ..... a ....d EO " ...r ......fA plcal.. .. ....I Line # Generic Title/Role On-Shift Position Task Analysis_____ ________________________________________Controlling Method 1 Shft anaer SiftMangerLicensed Operator 1__ iftMange Shift_______________

Manager_______Training Program 2 Unit Supervisor Control Room Supervisor Lricnsed OPeraogra 3 Shift Technical Advisor Shift Engineer/STA Lricnsed OPeraogra 4 RatrOeao#1Licensed Nuclear Plant Licensed Operator RatrOeao#1Operator

1. 1 Training Program 5 Reactor Operator #2 Licensed Nuclear Plant Licensed Operator______________________Operator

1. 2 Nuler raining Program 6 &uxiliary Operator #1 Non-licensed Ncer Non-Licensed Operator Plant Operator #1 Training Program 7 &uxiliary Operator #2 N/A N/A 8 Other needed for Safe Shutdown N/A N/A 9 Other needed for Safe Shutdown N/A N/A 10 Other needed for Safe Shutdown N/A N/A Other (non-Operations)

Personnel Necessary to Implement AOPs and EOPs or SAMGs if Applicable Line # Generic Title/Role On-Shift Position Task Analysis_____ _______________Controlling Method 11 IMechanic N/A N/A 12 Electrician N/A N/A 13 l&C Technician N/A N/A 14 Other N/A N/A 15 O:ther N/A N/A PNPS Page 65 PNPS Page 65 PNPS ON-SHIFT STAFFING ANALYSIS REPORT Fire Brigade..........

'" ...... ... "..... "' ... PN , 3 -. F REFIGHTiNG.':::

1 N/A N/A 2 N/A N/A 3 N/A N/A 4 N/A N/A 5 N/A N/A Note: The LOCA/GE with PAR Analysis does not include the need for firefighting.

PNPS Page 66 PNPS Page 66 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PNP TBLE4-RADIATION PROTECTION AND'CHEI'ASTRY, ': I In-Plant Survey: N/A___2 On-site Survey: RP#1 onsite & XX XX XX XX X__SB surveys 3 'Personnel Monitoring:

N/A T Job Coverage:

_N/A 5 Offsite Rad Ssessment:

Se._e Tble 5 6 Other site specific RP (describe):

RP#1 Issue X X X X X KI 7 Chemistry Function task #1 (describe)

N/A 8 Chemistry Function task #2 (describe)

N/A*Times are estimated.

Note: RP tasks are as directed by the Shift Manager and are not time critical.Chemistry does not have an assigned chemistry task for LOCA with PAR. Chemistry is available for dose assessment.

PNPS Page 67 PNPS Page 67 PNPS ON-SHIFT STAFFING ANALYSIS REPORT L ine

On-Shift

ii'!:Task Analysis'

, Emergency Planning 1 Declare the emergency classification level Shift Manager Training Program / EP (ECL) Drills 2 ,pprove Ofisite Protective Action SitMngrEmergency Planning 2 Recommendations ShfTangrraining Program Emergency Planning 3 Approve content of State/local notifications Shift Manager Training Program Emergency Planning 4 Approve extension to allowable dose Shift ManagerrangPorm Licensed Operator Training 5 Notification and direction to on-shift staff (e.g., Shift Manager Program / Emergency to assemble, evacuate, etc.) Planning Training Program 6 ER notfictionN/AEmergency Planning 6 ER notfictionN/Araining Program 7 Abbreviated NRC notification for DBT event N/A Lcne prtrTann Program Emergency Planning 8 Complete State/local notification form Shift ManagerrangPorm Emrgencyg Planning 9 Perform State/local notifications NLO#2 Emraining Progamnn Licensed Operator Training 10 Complete NRC event notification form Shift ManagerPrga 11 civae ERS NO#2 ainng rogram ChemAcstrytTechnician#2Emergency Planning 12 Ofsie raiolgicl asessentraining Program 12 Ofsie rdiolgicl asessentCheistr Tehniian Emergency Planning 13 Perform NRC notifications NLO#2 Emraining Progamnn Perform other site-specific event notifications Licensed Operator Training 14 (,e.g., Duty Plant Manager, INPO, ANI, etc.) Shift Manager Program 15 Personnel Accountability N/A Security Training Program PNPS Page 68 PNPS Page 68 PNPS ON-SHIFT STAFFING ANALYSIS REPORT VIII, APPENDIX C TIME MOTIONS STUDIES A. TMS Shift Manager Safe Shutdown Task PILGRIM NUCLEAR POWER STATION TIME MOTION STUDY OF OVERLAPPING TASKS TASK 1: PERFORM THE ASSIGNED SAFE SHUTDOWN ACTIONS JOB: SHIFT MANAGER TASK 2: PERFORM EMERGENCY DIRECTION AND CONTROL JOB: SHIFT MANAGER PNPS Page 69 PNPS Page 69 PNPS ON-SHIFT STAFFING ANALYSIS REPORT PURPOSE: Perform a Time Motion Study to evaluate whether the performance of safe shutdown actions assigned to the Shift Manager is an acceptable task overlap to the Shift Manager's primary emergency plan function of emergency direction and control.NOTE The Time Motion Study should be completed by simulation of performing the safe shutdown steps while the Shift Manager is demonstrating the Emergency Director function.LOCATION: Control Room to TB 23' RPS MG room to 23' Cable Spreading Room to TSC REQUIRED TOOLS/EQUIPMENT:

A. Procedure 2.4.143, Shutdown from Outside Control Room B. Stopwatch or watch to time actions PNPS Page 70 PNPS Page 70 PNPS ON-SHIFT STAFFING ANALYSIS REPORT APPENDIX D (NEI 10-05)Function I Responsibility (Task) Analysis Template Event: #9 Control Room Evacuation and Alternate Shutdown Site: PNPS Position:

Shift Mana~qer Line #: 1 Function jResponsibility (Task) Action Step ]Duration 1 .Safe Shutdown 1.1 Perform the procedure steps assigned the Shift Manager in procedure 2.4.143 Rev 48, Shutdown from Outside the Control Room.T=0 SM leaves the CR and directs his staff to implement assigned shutdown tasks[step 16(a), (b)] SM arrives at 1 minute power supply panel C511I (TB 23' (T=+I)RPS MG Room) and* Opens Reactor Protection System (RPS) logic Channel A, breaker A3* Opens RPS Channel B, breaker B3* Closes RPS Channel A, breaker A3* Closes RPS Channel B, breaker B3+2 -SM leaves 23' RPS MG 1 minute Room and obtains fuse pullers (T=+2)and safety equipment from the 23'Switchgear Room-SM leaves 23' Switchgear Room 1 minute________________________ (T=+3)[Step 16(d)] T+3 -SM arrives at 23' Cable Spreading Room.Opens panels C941 and C942* Removes fuse 1 6A-F10OA* Removes fuse 16A-F11A* Removes fuse 1 6A-FI12A* Removes fuse 16A-F10B* Removes fuse 16A-F11B* Removes fuse 1 6A-F1 2B SM verbalizes all fuses removed, reactor scrammed and MSIV's closed[step 16(g)] SM arrives and gains access to the TSC. SM confirms status of HCU scram valve position from field reports or EPIC.TASK : :,, :, 1 minute (T=+4)PNPS Page 71 PNPS Page 71 PNPS ON-SHIFT STAFFING ANALYSIS REPORT TOTAL TASK DURATION:

6 minutes Function Responsibility (Task) Action Step Duration 2.Emergency 2.1 Maintain emergency 1 The Shift Direction and direction and control of the Oversight of the emergency Manager Control event response.

response.

maintains radio 2 contact with crew Initiate any emergency actions, for updates and NOTE directions The TMS is for the overlap period.The total time considered for this task should be concurrent with Task 1.....D..FEMERGENCY

.......

TASK DURATION 6 Miue RESULT: Explain why it is acceptable or not acceptable for the Shift Manager to perform the safe shutdown tasks: The procedure Subsequent Action step 13(a) states that the performance of the procedure is an Alert classification and to activate the ERO per EP-IP-100 from the TSC. In step 13(e), the Shift Manager is assigned the tasks to initiate scram, EAL notifications, MSIV closure, and verify scram valve positions.

The Shift Manager passes the RPS panels to initiate the scram and close MSIVs when traveling to the TSC from the control room. The Shift Manager performs steps 16(a), 16(c), 16(d), and 16(g) which take approximately 6 minutes. Verification of control rod position may be verified from the TSC using EPIC.The performance of the SSD steps does not delay the classification of the emergency and the Shift Manager is able to maintain emergency direction and control by communicating with the crew by radio while they are aligning the alternate shutdown panels. Therefore, performing the safe shutdown steps is an acceptable overlapping task.Task Performer Richard Probasco Shift Manager August 23, 2012 Evaluators Stephen Reid Operations Training August 23, 2012 Fred Guynn Fleet EP Project August 23, 2012 S______________________

Manager ___________

SThomas Diorio Pilgrim I&C (EP) August 23, 2012 PNPS Page 72 PNPS Page 72 PNPS ON-SHIFT STAFFING ANALYSIS REPORT IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures 1. The Shift Engineer / STA has a collateral duty to fill out the notification message forms and to make all notifications which may detract the STA from the performance of his/her primary STA function.

It is acceptable for the STA to make the abbreviated NRC notification in a Design Basis Threat but may not maintain the open line with the NRC.2. The Shift Engineer has a collateral task to perform safe shutdown actions which may detract from the capability to perform the primary STA function.3. The Shift Engineer has a collateral task to perform dose assessment which may detract from the capability to perform the primary STA function.PNPS Page 73 PNPS Page 73 PNPS ON-SHIFT STAFFING ANALYSIS REPORT X. " REFERENCES

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

• NSIR DPR-ISG-01, Interim Staff Guidance -Emergency Planning for Nuclear Power Plants* PNPS Emergency Plan, Rev 39 XI. STAFFING ANALYIS TEAM* Fred Guynn, Entergy ECH Sr Project Manager, EP* Myra Jones, CMCG Contractor

• Tom White, PNPS Manager -EP* Mike McDonnell, PNPS AOM, Operations Support* Barbara Nadeau, PNPS Radiation Protection

• Kenneth Sejkora, PNPS Chemistry* Ashley Ohrenberger, PNPS Ops Training* Karen Sullivan, PNPS EP Planner* Robert Emmitt, PNPS ERO Training PNPS Page 74 PNPS Page 74