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Radiological Emergency Response Plan (RERP) Appendix J, Callaway Plant On-Shift Staffing Analysis Report, Revision 003
	ML16358A431
Person / Time
Site:	Callaway
Issue date:	04/14/2016
From:	; Ameren Missouri, Union Electric Co
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
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ML16358A435	List: ML16358A431; ULNRC-06294, Submittal of Radiological Emergency Response Plan (RERP) Appendix J, Callaway Plant On-Shift Staffing Analysis Report, Revision 003;
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	ULNRC-06294
	Download: ML16358A431 (244)
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Attachment 1 to ULNRC-06294 RERP Appendix J, Revision 003 Page 1 of 2 Summary of Changes Section / Step Description of Change Reason for Change Reason Change will not be a Reduction in Effectiveness Number Page 16, Changed Step numbers OTO-SK-00001 was revised, and Analysis These step number changes are strictly administrative to Analysis #1, referenced in Analysis #1, #1 was revised accordingly. match the associated procedure.

Table 2A - Table 2A - OTO/EOP Actions, OTO/EOP Design Basis Threat, to match Actions, Design Steps in OTO-SK-00001.

Basis Threat Page 48, Changed Step numbers ES-1.3 was revised to implement FLEX The step number changes are strictly administrative to Analysis #5, referenced in Analysis #5, strategies, and Analysis #5 was revised match associated procedure. The additional action of Table 2A - Table 2A - OTO/EOP Actions, accordingly. monitoring for ECCS leaks was added to an existing OTO/EOP RCCA Ejection, to match Steps in continuous action step. While this is an additional burden, Actions, RCCA ES-1.3. Added Monitor ECCS for it is negligible and it does not add additional time to the step Ejection Leaks to Task section, and since it was already a continuous action step. The change changed Makeup to CST to from CST to RWST was to fix an acronym typo that was Makeup to RWST" in the Task identified; ES-1.3, "Transfer to Cold Leg Recirculation," was section. Also, added NLO3 to the always about makeup to RWST, not CST. Adding NLO3 to Assigned Resources section. the "Assigned Resources section is a result of Monitoring ECCS for leaks. NLO3 is a resource that was used earlier in the scenario, but was not being utilized at this point in the timeline.

Page 58, Changed Step numbers E-3 was revised, and Analysis #6 was The step number changes are strictly administrative to Analysis #6, referenced in Analysis #6, revised accordingly. match associated procedure. The exact same actions are Table 2A - Table 2A - OTO/EOP Actions, being performed just in a different order. (Restoring PRZ OTO/EOP SGTR, to match the Steps in E-3; heaters was moved up in the procedure thus causing the Actions, SGTR this was the result of moving the steps to be renumbered.)

action to Restore PRZ Heaters to earlier in the E-3 procedure.

Restore PRZ Heaters was also moved in the Task section.

Attachment 1 to ULNRC-06294 RERP Appendix J, Revision 003 Page 2 of 2 Summary of Changes Section / Step Description of Change Reason for Change Reason Change will not be a Reduction in Effectiveness Number Page 67, Changed Step number referenced ES-1.3 was revised to implement FLEX The step number changes are strictly administrative to Analysis #7, in Analysis #7, Table 2A - strategies, and Analysis #7 was revised match associated procedure. The additional Table 2A - OTO/EOP Actions, LB LOCA with accordingly. action of monitoring for ECCS leaks was added to an OTO/EOP Release and PARs to match existing continuous action step. While this is an Actions, LB Steps in ES-1.3. Added Monitor additional burden it is negligible and it does not add LOCA with ECCS for Leaks to Task section, additional time to the step since it was already a continuous Release and and changed Makeup to CST to action step. The change from CST to RWST was to fix an PARs Makeup to RWST in the Task acronym typo that was identified; ES-1.3 was section. Also, added NLO3 to the always about makeup to RWST, not CST. Adding NLO3 to Assigned Resources section. the Assigned Resources section is a result of Monitoring ECCS for leaks. NLO3 is a resource that was used earlier in the scenario but was not being utilized at this point in the timeline.

Page 83, Changed Step numbers OTO-SK-00002 was revised, and Analysis The step number changes are strictly administrative to Analysis #9, referenced in Analysis #9, Table #7 was revised accordingly. match associated procedure. Directing the Ops Tech to the Table 2A - 2A - OTO/EOP Actions, Aircraft switchgear instead of the switchyard will allow for a quicker OTO/EOP Probable Threat, to match Steps response; both accomplish the same purpose.

Actions, Aircraft in OTO-SK-00002. Also changed Probable Threat Switchyard and NB02 to NB02 Switchgear and NE02 in the Task section.

Pages 98 & 99, Changed Step numbers ECA-0.0 was revised, and Analysis #11 The step number changes are strictly administrative to Analysis #11, referenced in Analysis #11, Table was revised accordingly. match associated procedure. The addition of Steps 9 and Table 2A - 2A - OTO/EOP Actions, Station 17 do not add additional burden to Analysis #11, as these OTO/EOP Blackout, to match Step numbers steps utilize available resources currently not being utilized Actions, Station in ECA-0.0. Added a new Step 9 in the timeline and do not add significant burden (i.e.,

Blackout for the SM to check AC power can additional parameter to monitor). This was determined by a be restored within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and a table top review during the revision of ECA 0.0. Several new Step 17 to Monitor RCS Task descriptions, Assigned Resources, and Timeline Integrity. were modified to match the revision of ECA 0.0. These changes align Analysis #11 with ECA 0.0.

Attachment 2 to ULNRC-06294 RERP Appendix J, Revision 003 "Callaway Plant On-Shift Staffing Analysis Report" 241 Pages

RERP Appendix J Rev. 003 RERP Appendix J Revision 003 Callaway Plant On-Shift Staffing Analysis Report Page 1 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Table of Contents INTRODUCTION .................................................................................................................... 1 References ............................................................................................................................................................ 1 EXECUTIVE

SUMMARY

....................................................................................................... 1 TABLE 1 ................................................................................................................................... 3 TABLE 1A ................................................................................................................................ 4 TABLE 2 ................................................................................................................................... 5 ACRONYMS ............................................................................................................................ 6 APPENDIX A PHASE II ANALYSIS RESULTS ................................................................... 8 Phase II Preliminary Conclusions........................................................................................................................ 9 Phase II Recommendations: .............................................................................................................................. 10 APPENDIX B PHASE II EVENT ANALYSIS TABLES ..................................................... 11 Phase II Event Analysis Table Index ................................................................................................................. 12 On-Shift Personnel Assignments Used During Phase II Analysis ..................................................................... 13 APPENDIX C PHASE III TIME MOTION STUDY ANALYSIS RESULTS ................... 111 Phase III Time Motion Study Results ............................................................................................................... 115 i

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Introduction 10 CFR 50 Appendix E, effective on December 23, 2011 directed that a detailed study be performed by December 24, 2012, to ensure on-shift staffing was adequate to perform critical functions until relieved by the augmented Emergency Response Organization (ERO). The NRC in the published staff guidance (Reference 2) endorsed NEI 10-05 as an acceptable means of performing the required staffing analysis.

This report documents the result of that analysis for Callaway Plant (CP).

References

1. 10 CFR 50 Appendix E

2. NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants

3. NEI 10-05, Revision 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities

4. CP RERP, Revision 39, Figure 5-1, On-Shift Emergency Response

5. CP RERP, Revision 39, Table 5-1, Emergency Staffing Requirements/On-Shift Emergency

Response

6. CP FSAR Chapter 15

7. CP RERP, Revision 44, Figure 5-1, On-Shift Emergency Response

8. CP RERP, Revision 44, Table 5-1, Emergency Staffing Requirements/On-Shift Emergency

Response

Executive Summary A detailed staffing analysis performed in accordance with NEI 10-05 was conducted to document the adequacy of shift staffing as required by 10 CFR 50 Appendix E.

The minimum staff described in the Figure 5-1 and Table 5-1 of the CP Radiological Emergency Response Plan (RERP), Revision 39, was used to perform the on-shift staffing analysis. Table 1 of this report lists the on-shift staffing as described in Revision 39 of the CP RERP.

NRC staff guidance directs the scenarios that must be used to demonstrate the adequacy of on-shift staffing to perform required functions for event mitigation, radiation protection response, firefighting, chemistry and Emergency Plan functions. Those scenarios include specific design basis events as described in the FSAR as well as specific scenarios defined in the staff guidance document. Table 2 identifies the scenarios that were examined.

The next phase required of NEI 10-05 requires a dedicated team using tabletop techniques to examine the scenarios for conflicts between the functional areas that must be resolved by detailed procedural analysis.

For those scenarios where no conflicts are identified in the specified areas no further actions are required.

Table 2 also identifies the scenarios that required detailed analysis due to conflicts in response functions.

Appendix A to this report documents the results of the procedural analysis. Appendix B includes the completed event scenario analysis tables.

1 Page 3 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis The final phase of NEI 10-05, Time Motion Studies (TMS), identifies any staffing conflicts with the minimum shift that must be resolved. The TMS for Callaway Plant determined that staffing conflicts do not exist. Appendix C summarizes the results of the time motion studies (TMS).

The effective date of this staffing analysis is the date of ORC approval.

Revision 001 is incorporated into this report to support the conversion to NFPA 805, Risk Informed Performance Based Fire Protection standards from the 10CFR50 Appendix R standards. This conversion required a revision to the Control Room Evacuation procedure OTO-ZZ-00001, Control Room Inaccessibility, Revision 040. The revision to the procedure required a re-evaluation of the On-shift Staffing Analysis for the NFPA 805 Control Room Fire with Evacuation and Safe and Stable Plant Conditions event.

Revision 002 is incorporated in this report due to a change in the amount of time required to open all Control Room Cabinet Doors during a Station Blackout scenario. As documented in NRC Inspection Report 2014007, in which Callaway received a Green Non-Cited Violation (NCV) of 10 CFR Part 50.63(a)(2),due to a change that was made to Emergency Operating Procedure Addendum 20, Control Room Cabinet Door List, without any analysis or calculations performed to justify whether the electronics in the cabinets would have sufficient cooling with a minimum of one door open during a Station Blackout. Changing procedure to have the operator open all doors meets the requirement for adequate ventilation but also requires more time to accomplish than was indicated in previous analysis.

Additional timings of this evolution were performed to verify the appropriate amount of time to be added to the Staffing Analysis. This does not affect the overall amount of time required to complete steps of the Station Blackout procedure.

Revision 003 is incorporated in this report to support changes that were made to procedures included in the staffing analysis of this document. In particular, changes were made to the Station Blackout procedure ECA-0.0, Loss of All AC Power. This was due to NRC Order EA-12-049, Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design Basis External Events (BDBEE) and CAR 201306512 Procedure Development Tracking for Fukushima Project. This does not affect the overall amount of time required to complete steps of the Station Blackout procedure.

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Conclusion The minimum staff identified in Figure 5-1 and Table 5-1 of the Callaway Plant Radiological Emergency Response Plan, Revision 39, is adequate to respond to the scenarios identified in the regulations until relieved by the augmented ERO.

Table 1 Callaway Plant On-Shift Staffing CP RERP, Rev 039 Figure 5-1, On-Shift Emergency Response Table 5-1, Emergency Staffing Requirements/

On-Shift Emergency Response Position On-Shift Shift Manager (SM) 1 Control Room Supervisor (SRO) 1 Field Supervisor (SRO) 1 Reactor Operator (RO) 2 Ops/Assistant Ops Technicians (NLO) 4 Other Operations Personnel 2 HP Operations 1 HP Technical Support (DA) 1 Chemistry Technician 1 Shift Security Supervisor 1 Total: 15 Fire Brigade 5 Search & Rescue/MERT 2 Security Sec plan 3

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis The minimum staff identified in Figure 5-1 and Table 5-1 of the Callaway Plant Radiological Emergency Response Plan, Revision 44, is adequate to respond to the NFPA 805 Control Room Fire with Evacuation and Safe and Stable Plant Conditions until relieved by the augmented ERO.

Table 1a Callaway Plant On-Shift Staffing CP RERP, Rev 044 Figure 5-1, On-Shift Emergency Response Table 5-1, Emergency Staffing Requirements/

On-Shift Emergency Response Position On-Shift Shift Manager (SM) 1 Control Room Supervisor (SRO) 1 Field Supervisor (SRO) 1 Reactor Operator (RO) 2 Ops/Assistant Ops Technicians (NLO) 5 Other Operations Personnel 2 HP Operations 1 HP Technical Support (DA) 1 Chemistry Technician 1 Shift Security Supervisor 1 Total: 16 Fire Brigade 5 Search & Rescue/MERT 2 Security Sec plan 4

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Table 2 Callaway Plant DBA/ISG Analyzed Events TMS DBA/ISG Summary Description of Event or Accident Required Event #

YES 1 Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the Design Basis Threat (DBT).

NO 2 Steam System Pipe Break (MSLB)

NO 3 Major Rupture of a Main Feedwater Line (MFLB)

NO 4 Reactor Coolant Pump Shaft Seizure (Locked Rotor)

NO 5 Reactor Coolant Pump Shaft Break 1 NO 6 Spectrum of rod cluster control assembly ejection accidents (RCCA Ejection)

NO 7 Steam Generator Tube Rupture (Stuck ADV)

NO 8 Loss-of-Coolant Accidents (LB LOCA) 2 NO 9 Fuel Handling Accident 3 NO 10 ATWS NO 11 Response actions for an aircraft probable threat in accordance with 10 CFR 50.54(hh)(1) and as discussed in RG 1.214, Guidance for Assessment of Beyond-Design-Basis Aircraft Impacts NO 12 Revised for NFPA 805 Control room fire leading to evacuation and safe and stable plant conditions, as referenced in IN 95-48 Results of On-Shift Staffing Study NO 13 Station (Unit) Blackout NO 14 NFPA 805 Fire Response 4 NO 15 SAMG 1

Per the Callaway FSAR, event consequences and response are the same as for the RCP Locked Rotor Event (Event #4). Therefore, this event is bounded by Event #4 and no further analysis is required.

2 DBA Event designated as proceeding non-mechanistically to General Emergency with release exceeding Protective Action Guides.

3 Fuel Handling Accident is not analyzed with the existing on-shift staff. The Callaway FSAR states that this event involves fuel that is decayed for 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after shutdown, therefore it is applicable to refueling conditions. Refueling operations are staffed for the evolution with additional Operations, RP, and support personnel.

4 The Control Room fire with evacuation and safe and stable plant conditions is the bounding NFPA 805 fire scenario; therefore, no further analysis of this event is required.

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Acronyms ADV Atmospheric Dump Valve ANI American Nuclear Insurers ASD Atmospheric Steam Dump BOP Balance of Plant CAS Central Alarm Station CET Core Exit Thermocouple CFR Code of Federal Regulations CP Callaway Plant CR Control Room CSF Critical Safety Function CSFST Critical Safety Function Status Tree CT Chemistry Technician DA HP Technical Support DBA Design Basis Accident DBT Design Basis Threat ECCS Emergency Core Cooling System ECL Emergency Classification Level EDG Emergency Diesel Generator ENS Emergency Notification System.

EOL End of Live EOP Emergency Operating Procedure EP Emergency Preparedness ERDS Emergency Response Data System ERO Emergency Response Organization ESF Engineered Safety Feature FB Fire Brigade FS Field Supervisor FSAR Final Safety Analysis Report HP Health Physics IC Instrument and Control INPO Institute of Nuclear Power Operations ISG Interim Staff Guidance LB LOCA Large Break Loss of Coolant Accident LOOP Loss of Offsite Power MERT Medical Emergency Response Team MFLB Major Rupture of Main Feedwater Line MSIV Main Steam Line Isolation Valve MSLB Steam System Pipe Break NEI Nuclear Energy Institute NLO Ops/Assistant Ops Technician NRC Nuclear Regulatory Commission OATC Operator at the Controls OCA Owner Controlled Area Ops Operations ORC Onsite Review Committee OTO Off-Normal Procedure PA Protected Area PAR Protective Action Recommendation PORV Power Operated Relief Valve 6

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis PRZR Pressurizer RCCA Rod Control Cluster Assembly RCP Reactor Coolant Pump RCS Reactor Coolant System RO Reactor Operator RP Radiological Protection RERP Radiological Emergency Response Plan RVLIS Reactor Vessel Level Indicating System Rx Reactor SAMG Severe Accident Mitigating Guideline SAS Secondary Alarm Station SB LOCA Small Break Loss of Coolant Accident SG Steam Generator SGTR Steam Generator Tube Rupture SI Safety Injection SM Shift Manager SRO Senior Reactor Operator/Control Room Supervisor/Field Supervisor SSO Safe Shutdown Operator SSS Security Shift Supervisor STA Shift Technical Advisor T-G Turbine Generator TMS Time Motion Studies WPA Workman's Protection Assurance 7

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Appendix A Phase II Analysis Results 8

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis A multi-disciplined team of subject matter experts from Callaway Plant was assembled October 3-5, 2012 to provide input into the shift staffing analysis of events identified by NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants. This team consisted of: the Assistant Operations Manager (Shift Manager/SRO); a Reactor Operator; an Operations Technician (NLO);

Chemistry Supervisor; an RP General Supervisor; a Fire Marshal; a Security Supervisor; a Safety Analysis Engineer; and Emergency Planning staff (station and consultants). The team provided analysis support during the Phase II Shift Staffing Analysis as follows:

Table 1 On-Shift Staffing Analysis Team Team Member Subject Matter Expertise Assistant Operations Manager Emergency Operating Procedure (EOP) actions for SROs and ROs Off-Normal Technical Operating Procedure (OTO) actions for SROs and ROs Operating Procedure actions Site Emergency Director (E Plan) Actions for Shift Manager Fire response actions Reactor Operator EOP actions for ROs OTO actions for ROs Operating Procedure actions Fire response actions Operations Technician (NLO) EOP actions for NLOs OTO actions for NLOs Operating Procedure actions for NLOs Fire response actions for NLOs Fire Marshal Fire Brigade Response actions Chemistry Supervisor Chemistry Technician response actions RP Supervisor HP Technician response actions Security Supervisor Security Response actions Accountability Response actions Safety Analysis Engineer DBA Event response actions Emergency Planning Emergency Plan response actions The Phase II Analysis was conducted in three steps: identification of events for analysis; minimum shift staffing complement determination; and, a table top analysis of the on-shift staffing resources required for response to the identified events. The team reviewed a total of twelve (12) events. The results and recommendations of the Phase II Shift Staffing Analysis are documented in this report.

Phase II Preliminary Conclusions

1. A Time Motion Study (TMS) of the Shift Manager position is required for the Design Basis Threat Event due to competing Emergency Plan functions/tasks - State/Local Notifications and NRC Notifications. The TMS will determine if these functions can be performed by the Shift Manager during an event.

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RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Phase II Recommendations:

1. Determine most effective methodologies to perform remaining scenarios requiring detailed time motion studies (Simulator based Drill, timed in-plant response, combinations, other).

2. Schedule and conduct Phase III analysis for the following event:

a. Design Basis Threat 10 Page 12 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Appendix B Phase II Event Analysis Tables 11 Page 13 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Phase II Event Analysis Table Index Analysis FSAR DBA/

Page (Scenario ISG Event # Title Source Number Number) (Appendix A) 1 1 Design Basis Threat ISG 12 2 2 Steam System Piping Failure (MSLB) FSAR 19 Condition IV 3 3 Major Rupture of a Main Feedwater Line FSAR 27 (MFLB) Condition IV 4 4 Reactor Coolant Pump Shaft Seizure FSAR (Locked Rotor) Including Loss Of Offsite Condition IV 35 Power 5 6 Spectrum of Rod Cluster Control FSAR 42 Assembly (RCCA) Ejection Accidents Condition IV 6 7 Steam Generator Tube Rupture (Stuck FSAR 51 ADV) Condition IV 7 8 Loss of Coolant Accident (LB LOCA) FSAR 61 with release and resulting PARs Condition IV 8 10 ATWS ISG 70 9 11 Response actions for an aircraft probable ISG threat in accordance with 10 CFR 77 50.54(hh)(1) and as discussed in RG 1.214 10 12 NFPA 805 Control room fire leading to ISG evacuation and safe and stable plant 85 condition, as referenced in IN 95-48.

11 14 Station Blackout (Current Licensing ISG 94 Basis) 12 15 SAMG ISG 103 12 Page 14 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis On-Shift Personnel Assignments Used During Phase II Analysis Position Designation Assignment Shift Manager Shift Manager Shift Manager/Emergency Coordinator Control Room Supervisor SRO #1 Control Room Supervisor/STA Field Supervisor SRO #2 Field Supervisor /STA Reactor Operator RO #1 Reactor Operator Reactor Operator RO #2 Balance of Plant (BOP) Operator Ops/Assistant Ops Technician NLO #1 Secondary NLO/Fire Brigade Member Ops/Assistant Ops Technician NLO #2 Inside NLO/Fire Brigade Member Ops/Assistant Ops Technician NLO #3 Polisher NLO/Fire Brigade Member Ops/Assistant Ops Technician NLO #4 Radwaste NLO/Fire Brigade Member Other Operations Personnel NLO #5 Offsite Communicator Outside NLO Other Operations personnel NLO #6 Primary NLO /FBL Reactor Operator RO #3 WPA RO/CSF Monitor Other On-Shift Assignments Used During Analysis Position Designation Assignment HP Technician HP #1 HP Operations HP Technician HP #2 Offsite Dose Assessment Chemistry Technician CT #1 Chemistry Sampling/Count Room On-Shift Personnel Assignments Used During the NFPA 805 Control Room Fire Leading to Evacuation and Safe and Stable Plant Conditions (Analysis 10).

Position Designation Assignment Shift Manager Shift Manager Shift Manager/Emergency Coordinator Control Room Supervisor SRO1 Control Room Supervisor/STA Field Supervisor SRO2 Field Supervisor /STA Reactor Operator RO1 Reactor Operator Reactor Operator RO2 Balance of Plant (BOP) Operator Ops/Assistant Ops Technician NLO1 Secondary NLO/Fire Brigade Member/FBL Ops/Assistant Ops Technician NLO2 Inside NLO/Fire Brigade Member/FBL Ops/Assistant Ops Technician NLO3 Polisher NLO/Fire Brigade Member/FBL Ops/Assistant Ops Technician NLO4 Radwaste NLO/Fire Brigade Member/FBL Other Operations Personnel NLO5 Outside Operator / Offsite Communicator Safe Shutdown Operator SSO1 WPARO or NLO (extra NLO position staffed if only 2 ROs)

Ops/Ass Ops Technician NLO6 Primary NLO /FBL Other On-Shift Assignments Used During the NFPA 805 Control Room Fire Leading to Evacuation and Safe and Stable Plant Conditions (Analysis 10).

Position Designation Assignment Security Officer SEC1 Medical Emergency Response (MERT)

Security Officer SEC2 Medical Emergency Response (MERT)

Security Shift Supervisor SSS Fire Response Secondary Alarm Station Operator SAS Fire Response 13 Page 15 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Appendix B Analysis #1: DBA/ISG Event #1 - DBT ECL: Site Area Emergency TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

1. Shift Manager CP RERP, Figure 5-1, Table 5-1 T2/L1 No Yes T5/L1 T5/L3 T5/L7 N/A T5/L8 T5/L9 T5/L10 T5/L13

2. Operating Supervisor - CR (SRO #1) CP RERP, Figure 5-1, Table 5-1 N/A T2/L2 No No

3. Operating Supervisor - FS (SRO #2) 1 CP RERP, Figure 5-1, Table 5-1 T2/L3 No No N/A T5/L11

4. Reactor Operator (RO #1) CP RERP, Figure 5-1, Table 5-1 N/A T2/L4 No No

5. Reactor Operator (RO #2) CP RERP, Figure 5-1, Table 5-1 T2/L5 No No N/A T5/L5

6. Security Shift Supervisor CP RERP, Figure 5-1, Table 5-1 75 T2/L7 No No

7. SAS Operator CP RERP, Figure 5-1, Table 5-1 N/A T5/L6 No No 1

Notes: STA is a function and not a position. STA is a collateral duty of the Operating Supervisors (CR or FS).

14 Page 16 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 2 - Plant Operations & Safe Shutdown Analysis # 1 One Unit - One Control Room Minimum Operations Crew Necessary to Implement OTOs and EOPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation

1. Shift Manager Shift Manager Operator Training

2. Shift Supervisor Operating Supervisor - CR (SRO #1) Operator Training

3. Shift Supervisor Operating Supervisor - FS (SRO #2) 1 Operator Training

4. Reactor Operator (OATC) Reactor Operator (RO #1) Operator Training

5. Reactor Operator (BOP) Plant Operator (RO #2) Operator Training Notes: See Table 2A for OTO/EOP actions 1

STA function is a collateral duty of the Operating Supervisor.

Other (non-Operations) Personnel Necessary to Implement OTOs and EOPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation

7. Security Shift Supervisor Security Shift Supervisor Security Training Notes: Notify and remain available to Shift Manager 15 Page 17 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Analysis #1, Table 2A - OTO/EOP Actions Design Basis Threat Procedure Step/Actions Performance Time (mins) After Procedure Implementation Assigned 60- 65- 70-Proc/Step Task 0-5 5-10 10-15 15-20 20-25 25-30 30-35 35-40 40-45 45-50 50-55 55-60 Resource 65 70 75 OTO-SK-00001, Close CR Doors, Plant SRO1 x

Attachment A Announcement RO2 SRO1 OTO-SK-00001, Step 10- Trip the Reactor, Actuate CRVIS, RO1 x 13 Start Both Diesels RO2 SRO1 E-0, Steps 1-4 Verify Reactor Trip x RO1 Perform CSF Status Tree CSF-0.1 SRO2 x Monitoring NA STA Functions SRO2 x SRO1 ES-0.1, Steps 1-7 Verify Reactor Trip Response RO1 x RO2 Transfer Pressure Control to SRO1 ES-0.1, Steps 8 x Steam Pressure Mode RO2 SRO1 ES-0.1, Steps 9-10 Verify Reactor Trip Response RO1 x RO2 EOP Addendum 10, Secure SRO1 ES-0.1, Steps 11 x Unnecessary Equipment RO1 SRO1 ES-0.1, Steps 12 Throttle Auxiliary Feedwater x RO2 SRO1 Transition to OTG-ZZ-00005: Hot ES-0.1, Steps 13 RO1 x Standby Procedure RO2 SRO1 Initiate RCS Cooldown using OTO-SK-00001, Step 20 RO1 x Steam Dumps RO2 16 Page 18 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 3 - Firefighting Analysis #1 Task Analysis Line Performed By Controlling Method

1. N/A N/A

2. N/A N/A

3. N/A N/A

4. N/A N/A

5. N/A N/A Notes: N/A no Fire Brigade response required 17 Page 19 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 4 - Radiation Protection & Chemistry Analysis #1 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0 10 20 30 40 50 60 70 80 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1. In-Plant Survey On-Shift Position: HP #1

2. Out of Plant Survey On-Shift Position: HP #1

3. Personnel Monitoring On-Shift Position:

4. Job Coverage On-Shift Position:

5. Offsite Radiological Assessment On-Shift Position: HP #2

6. Other Site-Specific RP - Describe:

On-Shift Position:

7. Chemistry function/task #1 - Describe:

On-Shift Position: CT #1

8. Chemistry function/task #2 - Describe:

On-Shift Position: CT #1 Notes: No response - Chemistry and HP in duck and cover 18 Page 20 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 5 - Emergency Plan Implementation Analysis #1 Task Analysis Line Function/Task On-Shift Position Controlling Method

1. Declare the Emergency Shift Manager EP/Ops Training and EP Classification Level (ECL) Drill Program

2. Approve Offsite Protective Action N/A N/A Recommendations

3. Approve content of State/local Shift Manager EP/Ops Training and EP notifications Drill Program

4. Approve extension to allowable N/A N/A dose limits

5. Notification and direction to on- RO#2 EP/Ops Training and EP shift staff (e.g., to assemble, Drill Program evacuate, etc.)

6. ERO notification SAS Operator EP/Security Training and EP Drill Program

7. Abbreviated NRC notification for Shift Manager EP/Ops Training and EP DBT event Drill Program

8. Complete State/local notification Shift Manager EP/Ops Training and EP form Drill Program

9. Perform State/local notifications Shift Manager EP Training and EP Drill Program

10. Complete NRC event notification Shift Manager EP/Ops Training and EP form Drill Program

11. Activate ERDS SRO#2 EP/Ops Training and EP Drill Program

12. Offsite radiological assessment N/A N/A

13. Perform NRC notifications Shift Manager EP/Ops Training and EP Drill Program

14. Perform other site-specific event N/A N/A notifications (e.g., INPO, ANI, etc.)

15. Personnel accountability N/A - after ERO N/A augmentation Notes: Site Area Emergency, EAL HS4.1 EIP-ZZ-00101, Classification of Emergencies EIP-ZZ-00102, Emergency Implementing Actions EIP-ZZ-00200, Augmentation of the Emergency Organization EIP-ZZ-00201, Notifications EIP-ZZ-00217, Emergency Data System Activation 19 Page 21 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Event Timelines and Assumptions Event #1 Design Basis Threat Initial Conditions:

Time: Sunday @0230 Unit @ 100% Power RCS @ normal operating temperature and pressure Sequence of Events:

0235 Adversary force assaults Callaway and attempts to breach the protected area fence Security engages adversaries and notifies Shift Manager 0236 CR personnel initiate Security Event response OTO Rx manually tripped On-site protective actions initiated Emergency Plan entered 0240 Security informs Shift Manager that PA has been breached 0245 Security informs Shift Manager that adversaries have been neutralized No injuries to site personnel No fires or collateral damage to plant equipment No adverse consequences to plant safety 20 Page 22 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Appendix B Analysis #2: DBA/ISG Event #2 - Steam Line Break ECL: Unusual Event TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

1. Shift Manager CP RERP, Figure 5-1, Table 5-1 N/A T2/L1 No No T5/L1 T5/L3 T5/L5

2. Operating Supervisor - CR (SRO #1) CP RERP, Figure 5-1, Table 5-1 N/A T2/L2 No No

3. Operating Supervisor - FS (SRO #2) 1 CP RERP, Figure 5-1, Table 5-1 N/A T2/L3 No No

4. Reactor Operator (RO #1) CP RERP, Figure 5-1, Table 5-1 N/A T2/L4 No No

5. Reactor Operator (RO #2) CP RERP, Figure 5-1, Table 5-1 N/A T2/L5 No No

6. Ops/Asst Ops Technician (NLO #1) CP RERP, Figure 5-1, Table 5-1 N/A T2/L6 No No

7. Ops/Asst Ops Technician (NLO #3) CP RERP, Figure 5-1, Table 5-1 N/A T2/L7 No No

8. Offsite Communicator (NLO #5) CP RERP, Figure 5-1, Table 5-1 75 T5/L8 No No T5/L9 T5/L10 T5/L13

9. Ops Technician (NLO #6) CP RERP, Figure 5-1, Table 5-1 N/A T2/L8 No No

10. HP Technician (HP #1) CP RERP, Figure 5-1, Table 5-1 75 T4/L1 No No

11. HP Technician (HP #2) CP RERP, Figure 5-1, Table 5-1 75 T4/L5 No No

12. Chemistry Technician (CT #1) CP RERP, Figure 5-1, Table 5-1 75 T4/L7 No No 1

Notes: STA is a function and not a position. STA is a collateral duty of the Operating Supervisors (CR or FS).

21 Page 23 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 2 - Plant Operations & Safe Shutdown Analysis # 2 One Unit - One Control Room Minimum Operations Crew Necessary to Implement OTOs and EOPs, or SAMGs if applicable Task Performance Line Generic Title/Role On-Shift Position Validation

1. Shift Manager Shift Manager Operator Training

2. Shift Supervisor Operating Supervisor - CR (SRO #1) Operator Training

3. Shift Supervisor Operating Supervisor - FS (SRO #2) 1 Operator Training

4. Reactor Operator (OATC) Reactor Operator (RO #1) Operator Training

5. Reactor Operator (BOP) Plant Operator (RO #2) Operator Training

6. Auxiliary Operator Ops/Asst Ops Technician (NLO #1) Operator Training

7. Auxiliary Operator Ops/Asst Ops Technician (NLO #3) Operator Training

8. Auxiliary Operator Ops Technician (NLO #6) Operator Training Notes: See Table 2A for OTO/EOP actions 1

STA function is a collateral duty of the Operating Supervisor.

22 Page 24 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Analysis #2, Table 2A - OTO/EOP Actions Main Steam Line Break Procedure Step/Actions Performance Time (mins) After Procedure Implementation 60 65 70 5- 10- 15- 20- 25- 30- 35- 40 50- 55-Proc/Step Task Assigned 0-5 - - -

10 15 20 25 30 35 40 45 50 55 60 Resource 65 70 75 SRO1 E-0 Immediate Actions Perform Reactor Trip Immediate Actions RO1 x RO2 SRO1 E-0-FOP-2 Isolate AFW to Faulted SG x RO2 SRO1 E-0, Steps 1-4 Verify Reactor Trip/SI x RO1 NA STA Functions SRO2 x Perform Attachment A - Actuation SRO1 E-0, Step 5 x Verification RO2 SRO1 E-0, Steps 6-12 Verify Equipment Conditions x RO1 SRO1 E-0, Step 13 Throttle AFW to Reduce RCS Cooldown x RO2 SRO1 E-0, Step 14 Transition to E-2 due to Faulted SG x RO1 CSF-0.1 Perform CSF Status Tree Monitoring SRO2 x SRO1 Check Conditions, Verify SG Isolated, RO1 E-2, Steps 1-7 x Restore Instrument Air RO2 NLO6 CT1 E-2, Step 6 Sample SGs and Survey Steam Lines x HP1 SRO1 E-2, Steps 8-9 Reset SI x RO1 E-2, Step 9 Transition to ES-1.1 SI Termination SRO1 x SRO1 ES-1.1, Steps 3-4 Reset Containment Isolation Phase A x RO1 Isolate Boron Injection Header & SRO1 ES-1.1, Steps 5-8 x Establish Charging RO1 SRO1 ES-1.1, Steps 9-12 Secure SI, RHR and Containment Spray x RO2 ES-1.1, Step 13 Restore Breakers for Boric Acid Pumps NLO1 x 23 Page 25 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Main Steam Line Break Procedure Step/Actions Performance Time (mins) After Procedure Implementation 60 65 70 5- 10- 15- 20- 25- 30- 35 45- 50- 55-Proc/Step Task Assigned 0-5 - - -

10 15 20 25 30 35 40 45 50 55 60 Resource 65 70 75 SRO1 ES-1.1, Steps 13-15 Restore VCT and Excess Letdown x RO1 Check Equipment, Use ASDs for SRO1 ES-1.1, Steps 16-18 x Temperature Control RO2 EOP Addendum 7: Emergency Purge H2 R02 ES-1.1, Step 19 x from Main Generator NLO1 RO1 EOP Addendum 8: Load Equipment on ES-1.1, Step 19 NLO3 x AC Buses NLO6 ES-1.1, Steps 19-20 Continuous Action to Restore Power RO2 Hold for Power Restoration Secure Unnecessary Equipment and SRO1 ES-1.1, Steps 21-30 x Restore Normal Lineups RO2 24 Page 26 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 3 - Firefighting Analysis # 2 Task Analysis Line Performed By Controlling Method

1. N/A N/A

2. N/A N/A

3. N/A N/A

4. N/A N/A

5. N/A N/A Notes: No Fire Brigade response for this event.

25 Page 27 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 4 - Radiation Protection & Chemistry Analysis # 2 Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 0 10 20 30 40 50 60 70 80 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90

1. In-Plant Survey X

On-Shift Position: HP #1

2. Out of Plant Survey On-Shift Position: HP #1

3. Personnel Monitoring On-Shift Position:

4. Job Coverage On-Shift Position:

5. Offsite Radiological Assessment X

On-Shift Position: HP #2

6. Other Site-Specific RP - Describe:

On-Shift Position:

7. Chemistry function/task #1 - Describe:

SG sampling and analysis X On-Shift Position: CT #1

8. Chemistry function/task #2 - Describe:

On-Shift Position: CT #1 Notes: EIP-ZZ-01211, Accident Dose Assessment CTP-ZZ-02590, Primary to Secondary Leak Rate Determination 26 Page 28 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis TABLE 5 - Emergency Plan Implementation Analysis # 2 Task Analysis Line Function/Task On-Shift Position Controlling Method

1. Declare the Emergency Shift Manager EP/Ops Training and EP Classification Level (ECL) Drill Program

2. Approve Offsite Protective Action N/A N/A Recommendations

3. Approve content of State/local Shift Manager EP/Ops Training and EP notifications Drill Program

4. Approve extension to allowable N/A N/A dose limits

5. Notification and direction to on- Shift Manager EP/Ops Training and EP shift staff (e.g., to assemble, Drill Program evacuate, etc.)

6. ERO notification N/A N/A

7. Abbreviated NRC notification for N/A N/A DBT event

8. Complete State/local notification NLO #5 EP/Ops Training and EP form Drill Program

9. Perform State/local notifications NLO #5 EP Training and EP Drill Program

10. Complete NRC event notification NLO #5 EP/Ops Training and EP form Drill Program

11. Activate ERDS N/A N/A

12. Offsite radiological assessment N/A N/A

13. Perform NRC notifications NLO #5 EP/Ops Training and EP Drill Program

14. Perform other site-specific event N/A N/A notifications (e.g., INPO, ANI, etc.)

15. Personnel accountability N/A N/A Notes: NUE, EAL SU1.1 EIP-ZZ-00101, Classification of Emergencies EIP-ZZ-00102, Emergency Implementing Actions EIP-ZZ-00200, Augmentation of the Emergency Organization EIP-ZZ-00201, Notifications EIP-ZZ-00212, Protective Action Recommendations EIP-ZZ-00217, Emergency Data System Activation EIP-ZZ-00230, Accountability 27 Page 29 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Event Timelines and Assumptions Event #2 Steam System Pipe Break (Main Steam Line Break)

Initial Conditions:

Time: Saturday @ 0250 Unit @ Mode 3, Hot Zero Power; EOL RCS @ Hot Zero Power operating temperature (Tavg = 557 F) and pressure Sequence of Events:

0250 SG B Main Steam Line fails (double-ended rupture), outside of containment but upstream of MSIV.

LOOP occurs coincident with steam line break EDGs start and load supplying power to ESF busses MSIVs closed within 17 seconds Rx Trip initiated on low steamline pressure signal Most reactive RCCA stuck in full withdrawn position SI initiated A High Head Safety Injection Pump starts and supplies flow B Train of SI fails 0255 Emergency Plan Initiated 28 Page 30 of 241 ULNRC-06294 Attachment 2

RERP Appendix J Rev. 003 Callaway Plant On-Shift Staffing Analysis Appendix B Analysis #3: DBA/ISG Event #3 - Main Feedwater Line Break ECL Unusual Event TABLE 1 - On-shift Positions Augmentation Role in Unanalyzed TMS Line On-shift Position Emergency Plan Reference Elapsed Time Table#/Line# Task? Required?

(min)

1. Shift Manager CP RERP, Figure 5-1, Table 5-1 N/A T2/L1 No No T5/L1 T5/L3 T5/L5

2. Operating Supervisor - CR (SRO #1) CP RERP, Figure 5-1, Table 5-1 N/A T2/L2 No No 1

3. Operating Supervisor - FS (SRO #2) CP RERP, Figure 5-1, Table 5-1 N/A T2/L3 No No