Text

NEI 12-01 Phase 2 Staffing Assessment, Revision 1
	ML16047A330
Person / Time
Site:	Comanche Peak
Issue date:	01/20/2016
From:	; Luminant Power
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16047A327	List: CP-201600027, Submittal of Updated Phase 2 Staffing Assessment Regarding Recommendation 9.3 (Staffing); ML16047A330;
References
	CP-201600027, TXX-16002
	Download: ML16047A330 (29)
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Attachment to TXX-1 6002 Page 1 of 29 LUMINANT POWER COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 AND 2 NEI 12-01 PHASE 2 STAFFING ASSESSMENT Revision 1 I

COMANCHE PHASE 2 PEAK PHASE COMANCHE PEAK ON-SHIFT STAFFING 2 ON-SHIFT ASSESSMENT STAFFING ASSESSMENT 1

Attachment to TXX-1 6002 Page 2 of 29 Table of Contents 1 Introduction............................................................................................... 3 2 Analysis Overview........................................................................................ 4

Staffing Analysis Scope......................................................................... 4

Methodology ..................................................................................... 5 3 Analysis Summary ...................................................................................... 5 4 Assumptions.............................................................................................. 6

NET 12-01 Assumptions.................................................................... 6

NET 10-05 Assumptions ........................................................................ 7 5 Event Staffing Analysis................................................................................. 8

Minimum On-Shift Staffing..................................................................... 8

Scenario Overview................................................................................ 9

Staffing Analysis Summary .................................................................... 9 6 FLEX Response Analysis .............................................................................. 17

FLEX Details..................................................................................... 17

On-Site Staff Ability to Move Back-up Equipment .................................. 18

FLEX Analysis Summary ...................................................................... 18 7 Program Controls....................................................................................... 20

Emergency Response Drills & Exercise Program........................................... 20

Training........................................................................................... 20 8 Security Consideration ..................................................................... ............ 20 9 Identified Issues......................................................................................... 21 10 References................................................................................................ 22 Attachment 1, NET 10-05 Tables.................................................................... 24 2

PHASE 2 PEAK PHASE COMANCHE PEAK COMANCHE STAFFING ASSESSMENT ON-SHIFT STAFFING 2 ON-SHIFT ASSESSMENT 2

Attachment to TXX-1 6002 Pages3 of 29

1. Introduction In May, 2012, NEI published NEI 12-01, "Guidelinefor Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities".These guidelines provide criteria to assist with the preparation of assessments used to determine the required staff needed to respond to a Beyond Design Basis External Event (BDBEE) that affect multiple units at a site, and the identification of enhancements that could provide a means to power equipment needed to communicate with on-site and offsite personnel during an extended loss of AC power event. These assessments were necessary for responding to certain information requests contained in US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dal-Ichi Accident, dated March 12, 2012.

As discussed in SECY-1 1-0137, "Prioritizationof Recommended Actions to be taken in Response to Fukushima Lessons Learnedf', dated October 3, 2011, responses to the information requests will be used to inform possible future regulatory actions. A 2-phase approach was used to respond to the information requests associated with staffing.

The Phase 1 staffing assessment, performed in response to the Letter was submitted by April 30, 2013, considered all requested functions except those related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2. This Phase 2 staffing assessment considers the requested functions related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2.

Recommendation 4.2 requires a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase requires the use of installed equipment and resources to maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.

Additionally, the event analyzed impedes site access such that for the first 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months no personnel from off-site can access the site, from 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months there is limited site access and after 24+ hours there is improved site access.

Section IV.A.9 of 10 CFR 50, Appendix E, states that nuclear power reactor 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." The Nuclear Energy Institute (NEI) On-Shift ERO Staffing Task Force developed NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities"to establish a standard methodology for performing analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency. Licensees used this methodology to meet the requirement of 10 CFR 50, Appendix E, Section IV.A.9 in a manner acceptable to the US Nuclear Regulatory Commission (NRC) staff. This was Comanche Peak Nuclear Power Plant's (CPNPP) first On-Shift Staffing Assessment (OSSA), conducted in June 2012. The methodology provided in this guidance was used to perform the Phase 1 and Phase 20OSSAs.

This report provides the Phase 2 staffing assessment results for CPNPP Units 1 and 2.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT3 3

Attachment to TXX-1 6002 Page 4 of 29

2. Analysis Overview Staffing Analysis Scope All sites with one or more operating units are required to perform a Phase 2 staffing assessment no later than four months prior to the beginning of the second refueling outage (as used within the context of NRC Order EA-12-049). The Phase 2 assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2.

Licensees of multi-unit sites have two options for providing the Phase 2 staffing assessment:

Provide one Phase 2 staffing assessment applicable to all on-site units. This assessment should be provided four months prior to the first occurrence of a second refueling outage at the site (i.e., the first "second refueling outage"). This option may be used by sites that will employ essentially identical mitigation strategies for all on-site units.

Provide two or more Phase 2 staffing assessments as applicable to the different on-site units. Each assessment should be provided four months prior to the occurrence of the second refueling outage of the unit to which the assessment is applicable. This option may be used by all sites that will employ different mitigation strategies for on-site units.

CPNPP Unit 1 and Unit 2 staffing assessments were performed using the guidance of the first option to conduct one assessment applicable to both units. The intent of this assessment was to perform the following:

1. Evaluate the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, evaluate Transition Phase actions which must be performed prior to the end of the "no site access" time period.

Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

Transition Phase - Implementation of strategies involving the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling. Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.

2. Evaluate the ability of the on-shift staff to implement the Station Blackout (SBO) coping strategies in place before Extended Loss of AC Power (ELAP) is declared.

3. Evaluate the EOPs and FSGs for responding to an ELAP affecting both units. (Note: Draft FSGs and draft EOPs, revised for FLEX implementation, were used.)

4. Evaluate whether the ability of the on-shift staff to perform any required emergency response functions would be degraded or lost prior to the arrival of the augmented ERO.

5. Consistent with the site access assumption, evaluate the ability of the on-shift staff and augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" time period.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT4

Attachment to TXX-1 6002 Page 5 of 29 The staffing level determined as a result of the Phase 2 assessment will be verified and validated in the process used to reasonably assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed. Validation will be performed at a date after the submittal of the staffing assessment report per NEI guidance "FLEX Beyond Design Basis Validation Process" dated July 18, 2014. Necessary corrective actions will be tracked using the CPNPP corrective action program if the validation determines the assumed resources cannot complete a time sensitive action within the constraints identified in the Overall Integrated Plan (OIP) per NRC Order EA-12-049.

Methodology A tabletop assessment was performed to determine what operational and emergency response actions were procedurally required during an ELAP. Representatives from CPNPP Operations, Maintenance, Radiation Protection, Chemistry, Procedures, Engineering, Training, Security, and Emergency Preparedness met with an industry consultant in a tabletop exercise in February 2014.

The participants reviewed the assumptions and applied procedural guidance, including draft FLEX Support Guidelines (FSGs) for coping with a BDBEE using minimum on-shift staffing.) Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step. Because the FSGs were not yet finalized, the results of the assessment are preliminary and will require validation prior to FLEX implementation. All gaps identified will be addressed through the CPNPP corrective action program.

The team reviewed the tasks of each member of the minimum on-shift staff in responding to the ELAP and constructed a timeline (Table 5.2) recording the tasks and the approximate time at which they were performed following the event. Task duration was recorded in half-hour intervals. In reviewing on-shift staffing tasks, the team was alert to identify instances where staff members were assigned conflicting tasks or collateral duties that would distract from their ability to fulfill Emergency Plan responsibilities.

The assessment team used the guidance of NEI 10-05 to determine if the number and composition of the on-shift staff was sufficient to implement the Emergency Plan, Initial Phase actions, and, with the assistance from augmented staff, Transition Phase actions intended to maintain or restore core cooling, containment integrity, and spent fuel pool makeup for both units. The NEI 10-05 data tables (Table 5.1 ) were modified to include tasks associated with FLEX strategies.

3. Analysis Summary The assessment concluded that the on-shift staff as defined in the current CPNPP Emergency Plan and augmented ERO alone are not adequate, and that additional shift personnel as currently required by CPNPP procedure ODA-1 02, 'Conduct of Operations, Attachment 8A Minimum Shift Crew Composition" are necessary to implement existing and planned BDBEE and ELAP strategies on both units simultaneously while continuing to perform required Emergency Planning tasks without unacceptable collateral duties. 2 Additionally, the process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established. 3 These gaps were captured and will be addressed through the CPNPP corrective action program.

1 GAP #1 - The staffing assessment was not performed with the final approved versions of FLEX Support Instructions (FSi's).

2 GAP #2 - Site Administrative Procedures and the site Emergency Plan are not aligned as to the minimum shift staffing levels.

SGAP #3 - The process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 5

Attachment to TXX-1 6002 Page 6 of 29

4. Assumptions

NEI 12-01 Assumptions for Staffing Analysis The set of standard assumptions that were used in the development of this report:

1. A large-scale external event occurs that results in:

all on-site units affected

extended loss of AC power

impeded access to the units

2. All on-site reactors are operating at full power and are successfully shut down.

3. A Hostile Action directed at the affected site does not occur during the period that the site is responding to the event.

4. The event impedes site access as follows:

A. Post event time: 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - No site access. This duration reflects the time necessary to clear roadway obstructions, use different travel routes, mobilize alternate transportation capabilities (e.g., private resource providers or public sector support), etc.

B. Post event time: 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g., private resource providers or public sector support).

C. Post event time: 24+ hours - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

5. Personnel were limited to the minimum complement allowed by the site procedure ODA-1 02,

'Conduct of Operations, Attachment 8A Minimum Shift Crew Composition." This would be the minimum on-shift complement present during a backshift, weekend or holiday. Augmented ERO staff assistance was not credited until six hours following the event. 2 2 GAP #2 - Site Administrative Procedures and the site Emergency Plan are not aligned as to the minimum shift staffing levels.

6 COMANCHE PEAK COMANCHE PHASE 2 PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT ON-SHIFT STAFFING ASSESSMENT 6

Attachment to TXX(-1 6002 Page 7 of 29 NEI 10-05 Applicable Assumptions In accordance with this guidance, the following assumptions and limitations apply to the Phase 2 OSSA:

1. On-shift personnel can report to their assigned response locations within the timeframes sufficient to allow for performance of assigned actions.

2. The on-shift staff possesses the necessary Radiation Worker qualifications to obtain normal dosimetry and to enter Radiologically Controlled Areas (but not high, locked high or very high radiation areas) without the aid of a Radiation Protection Technician.

3. Personnel assigned to the major response area of Plant Operations and Safe Shutdown meet the requirements and guidance established by NRC regulations and are able to satisfactorily perform the functions and tasks necessary to achieve and maintain safe shutdown.

Note: Staff performance within this area was not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.

4. Performance of the on-site security organization's function is regularly analyzed through other station programs and was not evaluated in the OSSA, unless a role or function from another major response area was assigned as a collateral duty.

5. Individuals holding the position of Radiation Protection Technician or Chemistry Technician are qualified to perform the range of tasks expected of their position.

6. The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks, and was therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.

Communications methods will be different, i.e. Satellite phones instead of dedicated phone lines. Satellite phones require clear view of southern sky and therefore the communicator must go outside or set up an outside antenna. As such the communication to the State, Counties and the NRC will be done in series as each phone must be dialed separately. The satellite phones have simple usage cards with each phone and the use is similar to the use of a Cellular phone within the capability of the communicator.

7. The task of performing a peer check had minimal impact on the ability to perform other assigned functions/tasks, and was therefore an acceptable collateral duty for all positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to offsite authorities.

8. The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday).

COMANCHE PEAK PHASE 2 ON-SH)FT STAFFING ASSESSMENT7 7

Attachment to TXX-1 6002 Page 8 of 29

5. Event Staffingq Analysis

Minimum On-Shift Staffing The shift staffing requirements for CPNPP are listed in the Tabie 5.1 below (Reference 3). The methodology of NEI 12-01 requires that only personnel required to be on-shift complement can be credited in the staffing analysis.

Table 5.1 Minimum On-shift Staffing Functional Area Task On-Shift Position StaionOpeatins Overall command of both units Emergency Shift Manager (SM)

Stto prtos Plan implementation __________________

Station Operations Unit 1 supervision Unit Supervisor (US) #1 Station Operations Unit 2 supervision Unit Supervisor (US) #2 Station Operations Engineering oversight in the Control Room Shift Technical Advisor (STA)

Station Operations Manipulation of Unit I controls Reactor Operator (RO) #1 Station Operations Manipulation of Unit 1 controls Reactor 0perator (RO) #2 Station Operations Manipulation of Unit 2 controls Reactor Operator (RO) #3 Station Operations Manipulation of Unit 2 controls Reactor Operator (RO) #4 Station Operations Perfre oaleupeneaiultosa Nuclear Equipment Operator (NEO) #1 StaionOpeatins Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #2 StaionOpeatins needed StaionOpeatins Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #3 StaionOpeatins needed StaionOpeatins Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #4 StaionOpeatins needed Station Operations Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #5 needed StaionOpeatins Perform local equipment manipulations as Nuclear Equipment Operator (NEO) #6 StaionOpeatins needed Station Operations Perfre oaleupeneaiultosa Nuclear Equipment Operator (NEO) #7 Chem/ Radiochemistry support Perform Station Chemistry actions as directed by the Emergency Chemistry Technician (Chem) #1 Coordinator.

First Aid Team Chem/ Radiochemistry support Perform Mebractions as directed by the Emergency First Aid Team Member (Chem) #2

______________Coordinator. Provide First Aid Station Radiation SresadPoetv cin aito rtcinTcnca R)#

SrtactionRdain Surveys and Protective Actions Radiation Protection Technician (RP) #2 Protection Survys__drotctieAtiosRdiatonrotctinTchncia_(R)_#

Station Perform local equipment manipulations as Mechanical Maintenance (MM) #1 Maintenance needed Station Perform local equipment manipulations as Electrical Maintenance (EM) #1 Maintenance needed __________________

Station Perform local equipment manipulations as lCManenc(I)#

Maintenance needed I&C___Maintenance ____(__C)__#1 Station Maintenance Emergency Communicator l&C Maintenance (IC) #2 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT8 8

Attachment to TXX-1 6002 Page 9 of 29

Scenario Overview The BDBEE assumes a loss of off-site power combined with a failure of the emergency diesel generators to load. All remaining power is supplied by the station batteries. The loss of AC power to emergency buses initially results in the declaration of a Site Area Emergency (EAL SS4.1). When it becomes apparent that power will be unavailable for a prolonged period, the event classification is escalated to a General Emergency (EAL SG1.1 ).

CPNPP utilizes a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase utilizes installed equipment and resources to monitor, maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase uses offsite resources to sustain those functions indefinitely. Portable and off-site equipment location and operation during the Transition and Final Phases is addressed through the FSI's.

ECA-0.0 AIB (Unit 1 & 2 'Loss of AllIAC Rowe?' procedures) are the governing procedures for the BDBEE. Battery life to support instrumentation, with load shedding as prescribed in ECA 0.0 A/B and FSI-4.0 A/B, is at least 12 hrs. Valve and breaker operation were performed locally by Nuclear Equipment Operators (NEO). ABN-601, "Response to a 138/345KV System Malfunction," provides Operations personnel additional guidance in response to the SBO event.

The strategy employed in the event analyzed was to establish core cooling by natural circulation and to perform a plant cooldown using the steam-driven auxiliary feedwater pump. The Steam Generator Atmospheric Relief Valves (ARVs) have safety related air accumulators capable of supplying air to the valves for a minimum of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , therefore within the minimum staffing response time the ARV will have to be taken to local manual control to control the Reactor Coolant System temperature. The Auxiliary Feedwater Flow Control Valves have safety related air accumulators for 30 minutes. Therefore within the minimum staffing response time, AFW flow will have to be controlled manually from the TDAFW Pump room. Because no condenser vacuum existed due to the loss of AC power, heat removed from the steam generators was achieved by venting steam directly to the atmosphere thereby continually depleting the feedwater supply.

Table 5.2 illustrates this strategy by providing a timeline of each position during the event. This table lists the major activities (by position) in increments for the first seven hours of the event. Table 5.6 lists the major activities as directed by the FSI's and typically performed by the Augmented or Expanded ERO. FSI steps performed by on-shift personnel are noted.

Staffing Analysis Summary Table 5.3 provides the results to the BDBEE transient using installed plant and portable equipment and the available staffing complement. The on-shift staff performed actions required by operating and emergency plan procedures in the 6-hour period, relying only on installed structures, systems and components available in the Initial Phase of the response. Some preparation activities, as identified in the FSI's, are performed by shift personnel.

Additionally, the subject matter experts also identified the following potential impediments to implementation and/or assumptions that need to be validated:

Specific guidance to direct RP actions in response to a BDBEE needs to be developed. 4 4GAP # There is insufficient procedural guidance available to Support RP response to a BDBEE.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT9

Attachment to TXX-1 6002 Page 10 of 29 Table 5.2 On-Shift Staff Actions

(~Within the first seven hours Resources TssbTiem Prompt TeamMechnir PrmtTeaAlcrca Prompt Team l&C 2 ChemUistr TehicaI TSRkU s niteritn cmuiato.I ascnldeGhttisrsucecudprfr olaea#uie2Tss) n8 COMACHEPEA PHSE 2ON-HIF STFFIN ASESSENT10 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT

Attachment to TXX-16002 Pag e 11 of 29 Task # Table 5.3 Task Listing Start Time End Time Task Description T +_ min T+ m_

a

1. Emergency Coordinator (Control Room) 0 420

2. Engineering Oversight (Control Room) 0 420

3. Emergency Plan Comnmunicator (Control Room) 10 420

4. ECA-0.0A/FSI Implementation/Unit 1,Monitoring and Control (Control Room) 0 420

5. ECA-0.0B/FSI Implementation/Unit 2 Monitoring and Control (Control Room) 0 420

6. ABN-601 Restore Unit 1 Diesel Generators and Restore from Unit 1 6.9 KV Bus Fault (Field Activities) 0 60

7. ABN-601 Restore Unit 2 Diesel Generators and Restore from Unit 2 6.9 KV Bus Fault (Field Activities) 0 60

8. ABN-601 Unit 1 Secondary System Shutdown, Break Vacuum Unit 1 Main Condenser, Unit 1 Main Generator Hydrogen Vent and 10 60 Argon Purge (Field Activities) 120 150 ABN-60 1 Unit 2 Secondary System Shutdown, Break Vacuum Unit 2 Main Condenser, Unit 2 Main Generator Hydrogen Vent 10 60

______and Argon Purge (Field Activities) 120 150

10. ECA-0.OA Isolate Unit 1 RCP Seals (Field Activities) 10 20

11. ECA-0.0B Isolate Unit 2 RCP Seals (Field Activities) 10 20

12. ABN-601 Restoration of XST1, Restoration of XST2 or XST2A, Restoration of 345 KV Transformer Feeder Line, SOP-614 A/B 10 120 Alternate Power Generator Operation (Field Activities) ______ _____

13. Perform repair and corrective actions as assigned 10 180

14. Assist NEO with ABN-601I Unit 1 Secondary System Shutdown, Break Vacuum Unit 1 Main Condenser, Unit 1 Main Generator 10 150

________Hydrogen Vent and Argon Purge Implementation (Field Activities)

1. Assist NEO with ABN-60 1 Unit 2 Secondary System Shutdown, Break Vacuum Unit 2 Main Condenser, Unit 2 Main Generator 10 150

_________Hydrogen Vent and Argon Purge Implementation (Field Activities) ______

16. Radiation Protection Coverage for ECA-0.OA Isolate Unit 1 RCP Seals (Field Activities) 10 20

17. Radiation Protection Coverage for ECA-0.0B Isolate Unit 2 RCP Seals (Field Activities) 10 20

18. EPP-203 Emergency Notification System Communicator with NRC (Control Room) 10 Duration

19. ECA-0.0A Unit 1 DC Load Shed (Field Activities) 60 120

20. ECA-0.OB Unit 2 DC Load Shed (Field Activities) 60 120

21. ABN-601 Unit 1 Non-lE DC Load Shed (Field Activities) 60 90

22. ABN-601 Unit 2 Non-lE DC Load Shed (Field Activities) 60 90

23. ECA-0.0A Isolate Unit 1 CST (Field Activities) 20 30

24. ECA-0.OB Isolate Unit 2 CST (Field Activities) 20 30

25. ECA-0.0A Isolate Instrument Air to Unit 1 Main Steam Isolation Valves (Field Activities) 50 60

26. ECA-0.0B Isolate Instrument Air to Unit 2 Main Steam Isolation Valves (Field Activities) 50 60

27. ECA-0.0A Establish Local Control Unit 1 Turbine Driven AEW Flow Control Valves (Field Activities) 60 Duato

28. ECA-0.0B Establish Local Control Unit 2 Turbine Driven AFW Flow Control Valves (Field Activities) 30 50 60 Duration

29. ECA-0.0A Isolate Ventilation Chilled Water to Unit 1 Containment (Field Activities) 90 105

30. ECA-0.OB Isolate Ventilation Chilled Water to Unit 2 Containment (Field Activities.) 90 105

31. FSI-4.0 Defeat Source Range High Voltage for Unit l and Unit 2 (Control Room) 240 270

32. ECA-0.0A Establish Local Control Unit 1 Atmospheric Relief Valves (Field Activities) 210 Duration

33. ECA-0.0B Establish Local Control Unit 2 Atmospheric Relief Valves (Field Activities) 210 Duration

34. FSI-5.0 Block Open Fuel Building Doors/Deploy Spent Fuel Pool Makeup Spray Nozzles (Field Activities) 300 420

35. Assist NEO with FSI-5.0 Block 0pen Fuel Building Doors/Deploy Spent Fuel Pool Makeup Spray Nozzles (Field Activities) 300 420 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 11

Attachment to TXX-16002 Page 12 of 29 Task # Table 5.3 Task Listing Start Time End Time Task Description T +__ min T+ __ mmn

36. FSI-4.0A Unit 1 DC Load Shed (Field Activities) 240 300

37. FSI-4.0B Unit 2 DC Load Shed (Field Activities) 240 300

38. FSI-4.0A/B Open Block Open Unit 1 and Unit 2 UPS and Battery Room Doors 300 330

39. Monitor Sound Powered Headset for Unit 1 and Unit 2 Field Communications (Control Room) 20 Duration

40. Assist NEO with ECA-0.0A Establish Local Control Unit 1 Atmospheric Relief Valves (Field Activities) 210 300

41. Assist NEG with ECA-0.OB Establish Local Control Unit 2 Atmospheric Relief Valves (Field Activities) 210 300

42. Assist NEO with ECA-0.OA Establish Local Control Unit 1 Atmospheric Relief Valves (Field Activities) 210 Duration

43. Assist NEO with ECA-0.OB Establish Local Control Unit 2 Atmospheric Relief Valves (Field Activities) 210 Duration Notes:

Control Room tasks associated with ECA-0.0A/B and FSIs (e.g. depressurize steam generators, etc.) have not been specifically defined in this task list.

These tasks have been assessed and Control Room staff is sufficient to perform the actions within required timelines without detracting from monitoring and control activities.

Extended Loss of AC Power (ELAP) is declared within four hours of loss of all AC power to both units. Once ELAP is declared, actions and resources to recover on-site AC power sources are no longer required.

Analysis has been truncated at seven hours based on the assumption that additional resources become available and time-sensitive activities have been completed or resources have been assigned.

12 COMANCHE PEAK PHASE 2 PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT ON-SHIFT STAFFING ASSESSMENT 12

Attachment to TXX-16002 Page 13 of 29 Table 5.4 Augmented staff in the OSC per EPP-205, "Activation and Operation of the Operations Support Center (OSC),"

OSC Manager OSC One individual assigned from the ERO ERDC Team Coordinator OSC One individual assigned from the ERO Rad Status Board Recorder OSC One individual assigned from the ERO SOE Board Recorder OSC One individual assigned from the ERO Chemistry Coordinator OSC One individual assigned from the ERO Team Communicator OSC One individual assigned from the ERO ERDC Electrician OSC One individual assigned from the ERO ERDC Mechanic OSC One individual assigned from the ERO ERDC_____I&C ____Techni______ian____ OSC One individual assigned from the ERO First ________Ai_______Team______ OSC One individual assigned from the ERO Chemistry ________Technician________ OSC One individual assigned from the ERO On-site Monitoring Team OSC One individual assigned from the ERO

__a____Pro ______oordinator_________ OSC One individual assigned from the ERO Clerk_________Ma_____ager_______ OSC One individual assigned from the ERO Operations _________Perso_____nel___ OSC As assigned by Operations personnel Radiation Protection Personnel OSC As assigned by Radiation Protection personnel Table 5.5 Expanded staff in the OSC, for dual unit response 3 Unit In-Plant Team Coordination OSC

One additional individual per unit; individuals should not be assigned other functions.

Non-Licensed Operators (NEO's) OSC

Two additional individuals per unit to assist with implementation of repair and corrective actions.

Mechanical Maintenance Repair and Corrective Action OSC

Two additional individuals per unit to implement repair and corrective actions.

Electrical Maintenance Repair and Corrective Action OSC

Two additional individuals per unit to implement repair and corrective actions.

l&C Repair and Corrective Action OSC

Two additional individuals per unit to implement repair and corrective actions.

Implementation of SAM Strategies OSC

Number and composition of personnel capable of simultaneous implementation of any 2 SAM strategies at each unit. Operations and RP personnel are called out by department management.

GAP #3 - The process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT COMACHEPEA PHSE 2ON-HIF STFFIN ASESSENT13

Attachment to TXX-16002 Page 14 of 29 Table 5.6 Staff Actions performed via FSI's (With the Augmented and Expanded Staff available)

Procedure FLEX Support Instructions (FSr's) were not finalized at the time of the

tabletop. (GAP #1)

FSI-5.0 Block Open FB Doors to Establish Ventilation (Shift Task #35) T+6 hours-6.5 NEO 6 Complete by 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months hours FSI-5.0 Establish Control Room Ventilation (Open Rack Doors, Back Door, Missile Door, T+6 hours-30 CR Staff (Based on Temperature)

Establish 1/2/lighting) minutes (30 minutes after exceeding pre-established temperatures for both Units)

FSI-5.0 Block open Unit 1 TDAFWP Room Door (Shift Task #27) T+4 hours. NEO 5 Complete by 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months 0 min AFW 1 Performed by on-shift personnel FSI-5.0 Block open Unit 2 TDAFWP Room Door (Shift Task #28) T+4 hours NEO 7 Complete by 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months 0 mai AFW 2 Performed by on-shift personnel FSI-5.0 Clear Debris Route 1 or 2 FLEX Bldg to AAP T+6 hours Augmented Staff Complete by 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months (To support Phase 2 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (2 personnel) 480 VAC Generator deployment)

FSJ-5.0 Clear Debris AAP to Staging Area Al (Also includes A2) T+7.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Augmented Staff Complete by 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months (To support Phase 2 1.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (2 personnel) 480 VAC Generator deployment)

FSI-5.0 Clear Debris Route from AAP to Unit 2 DG FOST Fueling Station T+9 hours Augmented Staff Complete by 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months (To support FLEX 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (2 personnel) equipment fueling)

FSI-5.0 Clear Debris Route from AAP to Unit I SG AFW FLEX Pump parking area T+9.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Augmented Staff One for each unit (Contingency) 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (2 personnel)

FSI-5.0 Clear Debris Route from Staging Area Al to West North-South Road T>1 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Augmented Staff Complete before Staging West Side Tank 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (2 personnel) Pumps (must clear 3.3 or 3.4)

-FSI-5.0 Clear Debris Route from Unit 1SG AFW FLEX Pump parking around to West T>10.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Augmented Staff Complete before Staging West Side Tank Side Tanks 1 hour~ (2 personnel) Pumps (must clear 3.3 or 3.4)

FSI-5.0 Clear Debris Route Southeast Corner of Perimeter road to SSI T>_12.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Augmented Staff Complete before placing Multipurpose Pump 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (2 personnel) in service FSI-5.0 Step Perform damage assessments T>6 hours Augmented Staff Complete within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 40 hours (2 personnel)

FSI-5.0 Move FLEX Equipment to Staging Areas (Diesel Fuel Transfer Equipment) T+9.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Augmented Staff Complete to support all other equipment 45 minutes (2 personnel) placement FSI-5.0 Move FLEX Equipment to Staging Areas (UPS Room 12 KW Generators) T_>12 hours Augmented Staff Complete prior to establishing forced 30 minutes (2 personnel) ventilation at 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 14

Attachment to TXX-1 6002 Page 15 of 29 Table 5.6 Staff Actions performed via FSI's (With the Augmented and Expanded Staff available)

FSl-5.0 Move FLEX Equipment to Staging Areas (SG AFW Pumps) T > 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months Augmented Staff Contingency for TDAFWP Failure 30 minutes (2 personnel)

FSI-5.0 Move FLEX Equipment to Staging Areas (West Side Tanks Multipurpose Pumps) T>1 0 hours0 days 0 hours 0 weeks 0 months Augmented Staff Contingency if West Side Tanks Available 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (2 personnel) Complete prior to CST empty at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months FSI-5.0 Move FLEX Equipment to Staging Areas (SSI Multipurpose Pump) T>12 hours Augmented Staff Complete prior to CST empty at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 1 hour (2 personnel)

FSI-5.0 Move FLEX Equipment to Staging Areas (Control Room 12 KW Generators) T>12 hours Augmented Staff Complete prior to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to support Control 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (2 personnel) Room Ventilation Requires Pettibone to place on TB 830 Deck FSI-5.0 Move FLEX Equipment to Staging Areas (FLEX Pump to Fill SFPs) T>10 hours Augmented Staff Complete prior to makeup to SFP prior to 15 1 hot~r (2 personnel) hours FSI-5.0 Align RCS HP Boration FLEX Pumps (Unit 1) T< 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Augmented Staff Complete prior to 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months 2 hours (2 personnel)NEO Mechanic FSI-5.0 Align RCS HP Boration FLEX Pumps (Unit 2) T< 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Augmented Staff Complete prior to 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months 2 hours (2 personnel)NEO Mechanic FSI-5.0 Establish UPS Room Forced Ventilation T>12 hours Augmented Staff Complete prior to 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months 2 hours (3 personnel)

FSI-5.0 Engineering Assistance in Evaluating Available Water T > 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Augmented Staff Complete within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Supplies/Structures/Components 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months (2 personnel)

FSI-4.OA First DC Load Shed (Shift Task #36) 30 min NEO 2 Must be completed at 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Performed by on-shift personnel FSI-4.0B First DC Load Shed (Shift Task #37) 30 min NEO 4 Must be completed at 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months Performed by on-shift personnel FSI-4.OA IOpen UPS/Battery Room Doors Attachment (Unit 1 and Unit 2 ) (Shift Task #38) 30 min NEO 4 Must be complete at 5.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months - 1 person for both Units Performed by on-shift personnel FSI-4.0A Defeat SR HV Cutout (Shift Task #31) 10 min Prompt Team I&C Performed by on-shift personnel FSI-4.0B Defeat SR HV Cutout (Shift Task #31) 10 min Prompt Team l&C Performed by on-shift personnel FSI-4.0A Disable Both Trains of SSPS (After SI Reset) (Shift Task #4 & 5) 10 min RO 3 Performed by on-shift personnel 15 COMANCHE PEAK COMANCHE PHASE 2 PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT ON-SHIFT STAFFING ASSESSMENT 15

Attachment to TXX-16002 Page 16 of 29 Table 5.6 Staff Actions performed via FSI's (With the Augmented and Expanded Staff available)

FSI-4.0B Disable Both Trains of SSPS (After SI Reset) (Shift Task #4 & 5) 10 min RO 4 Performed by on-shift personnel FSJ-4.0A Remove Two Batteries From Service (Shift Task #36) 15 min NEO 2 Performed by on-shift personnel FSI-4.0B Remove Two Batteries From Service (Shift Task #37) 15 mai NEO 4 Performed by on-shift personnel FSI-4.0A ITransport/Connect Phase 2 480 VAC FLEX generator T+9 hours Augmented Staff Must be complete prior to placing battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (5 personnel) chargers in service 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FSI-4.0A Align 25 KV Loop for 480 VAC FLEX generator 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Augmented Staff Must be complete prior to placing battery (1 personnel) chargers in service 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FSI-4.0A Place Battery Chargers/Battery Exhaust Fans in Service T+9 hours Augmented Staff Must have 480 VAC FLEX Generator in 30 mai (1 personnel) service Must be complete at 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FSI-4.0B Place Battery Chargers/Battery Exhaust Fans in Service T+9 hours Augmented Staff Must have 480 VAC FLEX Generator in 30 min (1 personnel) service Must be complete at 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FSI General Support miscellaneous activities for FSI implementation (e.g., diesel fueling T+6 Augmented Staff Activities required to be performed for activities, Phase 3 equipment inspections/connections, flooding inspections) (10 personnel) duration of limited site access (-24 hours) 16 COMANCHE PEAK COMANCHE PHASE 22 ON-SHIFT PEAK PHASE STAFFING ASSESSMENT ON-SHIFT STAFFING ASSESSMENT 16

Attachment to TXX-1 6002 Page 17 of 29

6. FLEX Response Analysis

FLEX Details The focus of this "expanded response capability" at CPNPP is to enable the performance of unit-specific accident assessment and mitigation functions across multiple units.

The methods to notify and augment the ERO were described in the Phase 1 Staffing Analysis Report submitted to the NRC on April 30, 2013. The report was submitted as an Enclosure to CPNPP letter TXX-1 3081 entitled "Revised Phase 1 Staffing Assessment Submitted in Response to Request for Information Pursuantto 10 CFR 50.54(0 Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights" (ADAMS Accession No. ML13128A077). The report also addressed site access for the augmented ERO. 5

.Expanded ERO The positions for the Expanded Response were identified in the Phase 1 staffing assessment referenced above. Emergency Plan Procedures and associated training has not been completed. 6 There were no new skills identified through the assessment that had to be developed.

Work Location for the Expanded ERO If access to designated emergency response facilities is not possible, ERO members are trained to report to the alternate location. In the event the Expanded ERG is utilized, current facilities would be crowded. 7 5GAP #5 - Identify and Integrate into the ERO notification/activation protocol those non-ERO response personnel (e~g., Operations and Maintenance) necessary to support expanded response capability functions.

6GAP #6 - Training for the expanded ERO has not been completed.

7GAP #7 - Facility plans to house the Expanded ERO have not been completed.

17 COMANCHE PEAK COMANCHE PHASE 22 ON-SHIFT PEAK PHASE ON-SHIFT STAFFING ASSESSMENT STAFFING ASSESSMENT 17

Attachment to TXX-1 6002 Page 18 of 29

On-Site Ability to Move Back-up Equipment US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident, dated March 12, 2012, states in part:

The following functions are requested to be assessed:

How on-site staff will move back-up equipment (e.g., pumps, generators) from alternate on-site storage facilities to repair locations at each reactor as described in the Order regarding the NTIF Recommendation 4.2.

Following the guidance in the draft FSI's, FSI-5, Step 11, personnel were directed to move FLEX equipment to designated spaces. When discussed in the tabletop, it was identified that the skills and proficiency to move and set up equipment were within the skill levels of personnel assigned to the ERO rosters. To strengthen the response, an individual to assess the specific skill sets necessary will evaluate and assign as needed. 8

FLEX Analysis Summary The assessment considered the number and qualifications of personnel required for simultaneous implementation of the two FSG strategies for each unit that require the greatest number of staff to implement. Due to unit similarities, the most labor intensive FSG strategies are the same for Unit 1 and Unit 2.

The FLEX Support Instructions (FSI's), in their present state of completion, were used to support the tabletop analysis of actions taken in response to the BDBEE; these results are provided in Table 5.6.

FSI-4.0A/B, DC BUS LOAD MANAGEMENT AND PHASE 2 480 VAC GENERATOR ALIGNMENT is the most time critical activity and is also task intensive. As noted in Tables 5.2 and 5.3, FSI-4.0A/B activities start after declaration of ELAP and adequate staffing exists to perform these activities. As noted in Table 5.6, FSI-4.0A/B activities starting at T+9 hours were determined to require 5 augmented staff. The FSI-4.0A/B activities were performed during strategy validation using a staff of 4; 2 NEOs, I Electrician, and 1 Mechanic with a completion of time of 1.1 hours1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Even though the FSI-4.0A/B activities were conservatively performed with 4 augmented staff, the analysis of 5 augmented staff in Table 5.6 remains unchanged. Declaration of ELAP prior to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months could allow the FSI-4.0A/B activities to start earlier than T+9 hours. With the actions that will stop based on declaration of ELAP, adequate staffing is available to start the FSI-4.0A/B activities prior to the arrival of augmented staff. However, it will be necessary to coordinate use of the on shift crew members to ensure that other critical actions are completed as required. In order for the FSI-4.0A/B activities to start prior to T+9 hours, debris clearing activities would have to be complete for movement of the generator and support equipment to its staging area. As discussed in Section 8.0, Security will be able to start debris clearing prior to T+6 hours if requested by the Shift Manager.

GAP #8 - A position needs to be identified that can assess the knowledge and skills necessary for the on-shift, augmented and expanded staff to implement the procedures and tasks necessary to respond to a BDBEE.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 18

Attachment to TXX-1 6002 Page 19 of 29 Other activities requiring augmented staff have start times beyond T+9 hours and completion times beyond T+12 hours. The Diesel Fuel Transfer Equipment completion time in Table 5.6 has moved to T+24 hours based on storing all FLEX equipment fully fueled.

SAMG Implementations The assessment considered the number and qualifications of SAMG implementers required for simultaneous implementation of the two most intensive SAMG strategies on both units.

The assessment considered the number and qualifications of SAMG implementation personnel required for simultaneous implementation of the two most task intensive SAMG strategies on both units. Two strategies were evaluated:

Control Containment Conditions SAG-6

Flood Containment SAG-8 Implementation of the Control Containment Conditions SAG-6 strategy requires the following resources.

Table 6.1 Resource Number per Unit Function Augmented Staff 2Implement EDMG A.4-1 for RWST 2 Makeup as needed Augmented Staff 2 Implement EDMG A.4.7 for Portable

+ Spray if Containment is breached.

1 common for Fire protection water

______________ source RP Technician I Monitor Dose rates.

Implementation of the Flood Containment SAG-8 Strategy requires the following resources.

Table 6.2 Resource Number per Unit Function Augmented 2 Implemenlt EDMG A.4-1 for RWST Staff Makeup as needed Augmented 2Implement EDMG A.4-6 Containment Staff Flooding with Portable Pump.

Augmented Removing blank flange from Staff Containment spray line for EDMG A.4-6 2 Containment flooding with Portable

___________Pump.

RPMoioDoerts Technician - oio oerts COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 19

Attachment to TXX-16002 Page 20 of 29 Implementation of strategies SAG-6 and SAG-8 simultaneously would require the following personnel resources:

21 Augmented Staff

4 RP Technicians Based on evaluations performed, implementation of SAMG strategies, SAG-6 and SAG-8, are not anticipated within the first twenty four hours following the event under any circumstances. All emergency response facilities are expected to be staffed and activated by that time, therefore no staffing limitations will be encountered.

7. Procqram Controls

Emergency Response Drills & Exercise Program NEI 12-01, states that 'a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. In particular, standard objectives and extent-of-play may need to be revised to clarify the expected demonstration of functions that are dependent upon the type of scenario event or accident (i.e., within or beyond design basis, and number of affected units). For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit. 9

Training The FSI's at CPNPP were in draft at the time of the tabletop assessment. Once the training has been established, the requisite knowledge necessary to perform the tasks required by the FSI's by on-shift, augmented and expanded staff can be determined.1 °

8. Security Considerations Security is not specifically credited as a staffing resource in Section 5 "Event Staff Analysis." However, as an enhancement to increase margins for time critical activities, Security Coping strategies were reviewed and determined to be able to support the tasks of debris removal and Flex equipment staging during the initial phase of the response. The task of communication to the plant site for the response to the emergency is incorporated into the appropriate security procedure 1 1. The security support (auxiliary responder) does not impact the resources required for the Security Plan.

9GAP #t9 - Current CPNPP drill and exercise procedures do not include evaluation objectives or demonstration criteria for dual unit events or expanded ERO activities.

10 GAP #10 - Training was not performed with the final approved versions of FLEX Support Instructions (FSI's).

11GAP #11 - Update the applicable security procedure for communication to the plant site.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 20

Attachment to TXX-1 6002 Page 21 of 29

9. Identified Issues The assessment team noted the following issues during the course of the staffing analysis.

Table 9.1 GAP # Description Condition Report #

The staffing assessment was not performed with the final approved AI-CR-2013-versions of FLEX Support Instructions (FSI's). 035-CR-201 5-0 04563

2. Site Administrative Procedures and the site Emergency Plan are not CR-2015-004566

2. aligned as to the minimum shift staffing levels. CR-201 5-004567 The process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been AI-CR-201 3-established. 003355-30 There is insufficient procedural guidance available to support RP AI-CR-2013-response to a BDBEE. 003355-10 identify and Integrate into the ERO notification/activation protocol those

5. non-ERO response personnel (e.g., Operations and Maintenance) AI-CR-2013-necessary to support expanded response capability functions. 003355-14 AI-CR-00201 3-

6. Training for the expanded ERO has not been completed. 003355-16

7. Facility plans to house the Expanded ERO have not been completed. AI-CR-2013-003355-17 A position needs to be identified that can assess the knowledge and

8. skills necessary for the on-shift, augmented and expanded staff to AI-CR-2013-implement the procedures and tasks necessary to respond to a BDBEE. 003355-18 Current CPNPP drill and exercise procedures do not include evaluation

9. objectives or demonstration criteria for dual unit events or expanded AI-CR-201 3-ERO activities. 003355-19 AI-CR-201 3-003106-32 AI-CR-201 3-

10. Training was not performed with the final approved versions of FLEX 012473-1 Support Instructions (FSIl's). EV-CR-201 5-003357-1 EV-CR-201 5-

_________003357-2 11 Update the applicable security procedure for communication to the plant AI-CR-2013-site. 003355-31 Identify new or revised agreements with offsite providers (e.g. City of Granbury, City of Cleburne, Oncor Distribution, Department of Public

12. Safety) (This issue is not specifically discussed in the sections aboveAIC203 but addresses Commitment 4392956 in letter TXX-1 4067 dated May 15,03552

________2014)

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 21

Attachment to TXX-1 6002 Page 22 of 29 REFERENCES

1. Letter from E. J. Leeds (NRC) and M. R. Johnson, (NRC) to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dal-ichi Accident

2. Letter from D. L. Skeen (NRR) to Susan Perkins-Grew (NEI) dated May 15, 2012, U.S. Nuclear Regulatory Commission Review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, May 2012

3. ODA-1 02, "Conduct of Operations, Attachment 8A Minimum Shift Crew Composition", Revision 27

4. EOP-0.0A/B, "Reactor Trip Or Safety lnjection", Revision 8

5. ABN-601, "Response To A 138/345KV System Malfunction", Revision 12

6. ABN-602 "Response To A 6900/480 Volt System Malfunction", Revision 8

7. ECA-0.0A/B, "Loss Of Al/AC Power', Revision 8

8. ECA-TP-1 1-001AIB, "Loss Of All AC Power Recovery Without SI Required and APG Supplying Power', Revision 1

9. SOP-614A/B, "Alternate Power GeneratorOperation", Revision 13/12

10. FSI-4.0A/B, "DC Bus Load Management and Phase 2 480 VAC Generator Alignment', Revision Draft

11. FSl-5.0, "Initial Assessment and FLEX Equipment Staging", Revision Draft

12. SAG-6, "Severe Accident Management Guidance - Control Containment Conditions", Revision 2

13. SAG-8, "Severe Accident Management Guidance - Flood Containment",

Revision 2

14. EPP-201,"Assessment Of Emergency Action Levels Emergency Classification And Plan Activation", Revision 12

15. EPP-303, "Operation of Computer Based, Emergency Dose Assessment System", Revision 13

16. EPP-304, "ProtectiveAction Recommendations", Revision 21

17. EPP-314, "Evacuation and Accountability', Revision 9 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 222

Attachment to TXX-1 6002 Page 23 of 29

18. NE! 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities", Revision 0.

19. Letter from Luminant to Nuclear Regulatory Commission, "Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, 90-Day Response to March 12, 2012 Information Request Regarding Recommendation 9.3 of the Near-Term Task Force" Letter dated June 7, 2012.

20. NSIR/DPR ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants, Revision 0, November 2011

21. NEI 10-05, Revision 0, June 2011, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities

22. NEI 12-01, Revision 0, May 2012, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities

23. Luminant Generation Company, LLC's 60-Day Response, dated May 10, 2012, to NRC Letter Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near Term Task Force Review of insights from the Fukushima Dia-ichi Accident, dated March 12, 2012 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 23

Attachment to TXX-1 6002 Page 24 of 29 NE1 10-05 TABLE I ON-SHIFT POSITIONS Lie On-shift Lie Position SoreRfrne SoreRfrne EaugmenTaion EasdTmen Role in Table#/Line# Unanalyzed Task?? Required T2/ Li T5/ LI T51/L2 CPNPP E-Plan T5/L3 Shift Manager N/A No No TABLE 1.1 T5/L5 T5/L7 T5/L8 T5/L 10 2 Unit Supervisor CPNPP E-Plan NAT/2N

1 TABLE 1.1 No Unit uperisor ODA-1 02, Att. 8A 3 ntSpevsrMinimum Shift Crew N/A T2/L3 No No

2 Composition Shift Technical CPNPP E-PlanNA 2LNoo Reco PP -lnN/A T2/L4 No No Operator #1TABLE 1.1 Reactor CPNPP E-Plan 6N/A T2/L5 No No Operator #2 TABLE 1.1 Reactor CPANPP Att.laA Oprtr#iiu hf rwN/A T2/L7 No No Reactor ODA-1 02, Att. 8A 8 prto 3 Minimum Shift Crew N/A T2/L7 No No Operaor~ Composition Nueatr CDAN02 E~Ant8 9inEquipmentCrewN/A T2/L8 No No Operator #1 TABLEsition Nuclear CPNPP E-Plan 10 Equipment N/A T2/L9O No No Operator #2 TABLE 1.1 Nuclear CPNPP E-Plan 11 Equipment N/A T2/L10 No No Operator #2 TABLE 1.1 Nuclear CPNPP E-Plan 12 Equipment N/A T2/L12 No No Operator #4 TABLE 1.1 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 24

Attachment to TXX-1 6002 Page 25 of 29 NEI 10-05 TABLE 1 ON-SHIFT POSITIONS OnsitAugmentation Role in Unanalyzed TMS Lin nPshitio Source Reference Elapsed Time Tal#Ln# Ts? Required Nuclear ODA-1 02, Att. 8A 13 Equipment Minimum Shift Crew N/A T2/L13 No No Operator #5 Composition Nuclear ODA-1 02, Att. 8A 14 Equipment Minimum Shift Crew N/A T2/L14 No No Operator #6 Composition Nuclear ODA-1 02, Aft. 8A 15 Equipment Minimum Shift Crew N/A T2/L15 No No Operator #7 Composition 16 Chemistry CPNPP E-Plan NIA T2L0No No Technician TABLE 1.1 T4/L5 RP Technician CPNPP E-Plan T2/L21 17 N/A No No 1TABLE 1.1 T4/L2 RP Technician CPNPP E-Plan T2/L22 18 N/A No No 2 TABLE 1.1 T4/L3 19 Security CPNPP E-PlanN/T2L5Noo 19 Supervisor TABLE 1.1 T5/L 15 20 Security CPNPP E-Plan N/A T2/L24 No No Officers TABLE 1.1 T2/L 16 CPNPP E-Plan T5/L6 21 Communicator N/A No No TABLE 1.1 T5/L13 T5/L14 CPNPP E-Plan 22 Mechanic N/A T2/L18 No No TABLE 1.1 CPNPP E-Plan 23 Electrician NIA T2/L 17 No No TABLE 1.1 CPNPP E-Plan 24 I&C Technician N/A T2/L19 No No TABLE 1.1 First Aid team CPNPP E-Plan T2/L23 25 N/A No No Member TABLE 1.1 T4/L6 COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 25

Attachment to TXX-1 6002 Page 26 of 29 NEI 10-05 TABLE 2 PLANT OPERATIONS & SAFE SHUTDOWN Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 1 Shift Manager Shift Manager Operations & EP Training 2 Unit Supervisor #1 Unit Supervisor Operations & EP Training 3 Unit Supervisor #2 Unit Supervisor Operations & EP Training 4 Shift Technical Advisor STA Operations & EP Training 5 Reactor Operator #1 Reactor 0perator 0perations & EP Training 6 Reactor Operator #2 Reactor Operator 0perations & EP Training 7 Reactor Operator #3 Reactor Operator Operations & EP Training 8 Reactor Operator #4. Reactor Operator Operations & EP Training 9 Station 0perator #1 NOOeain PTann 10 Station 0perator #2 NEO Operations & EP Trainin 11 Station Operator #3 NOOeain PTann 12 Station Operator #4 __EO__Operations____ &_EP__Training__

13 Station Operator #5 NEOOperations_&_EPTraining 14 Station Operator #6 NOOperations & EP Training 15 Station Operator #7 NEO Operations & EP Training Other Personnel Necessary to Implement AOPs, EOPs, SAMGs, or FSIs Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 16 Emergency Communicator I&C Tech Maintenance & EP 17 Electrician Electrician Maintenance & EP 18 Mechanic Mechanic Maintenance & EP 19 I&C Technician I&C Tech Maintenance & EP Training 20 Chemistry Technician Chemistry Tech Chemistry & EP Training 21 RP Technician RP Tech RP & EP Training 22 RP Technician RP Tech RP & EP Training 23 First Aid ... /First Aid Team Safety Training "Member ...

24 Security Officer Security Officer Security Training 25 Security Supervisor Security Supervisor Security Training NEI 10-05 TABLE 3 FIREFIGHTING Line Performed By Task Analysis Controlling Method 1 N/A N/A COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 26

Attachment to TXX-16002 Page 27 of 29 NE1 10-05 TABLE 4

______________RADIATION PROTECTION & CHEMISTRY Line lPosition0- 1- 2-13-14 6- 7- 9-10-12 15- 10 24- 0-160 performing ji 20 3 14 15 16 75 9 1012 11018 24 30 301420 Function/ TaskI

, In-Plant Survey On-Shift Position: I I I ) I 21 On-Site Survey On-Shift Position:

RP Technician 1 31 Personnel Monitoring On-Shift Position:

___RP Technician 2 41 Job Coverage

___On-Shift 51 Chemistry Position: II function/task # 1 -

Describe:

On-Shift Position:

Chemistry

___Technician 61 Chemistry function/task #2 -

Describe:

On-Shift Position:

First Aid Team

___Member COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 27

Attachment to TXX-1 6002 Page 28 of 29 NE1 10-05 TABLE 5 EMERGENCY PLAN IMPLEMENTATION Line Function/Task On-Shift Position Task Analysis Controlling Method 1 Declare the Emergency SitMngrOperations Training and Classification Level (ECL) SitMngrEP Training/Drill Program 2 Approve Offsite Protective Action Shift Manager Operations Training and Recommendations EP Training/Drill Program 3 Approve content of State/local SitMngrOperations Training and notifications SitMngrEP Training/Drill Program 4 Approve extension to allowable N/A - no radiological dose limits release 5 Notification and direction to on-OprtosTangad shift staff (e.g., to assemble, Shift Manager Epeain Training/rl Prgamd evacuate, etc.)EPTang/rlPorm 6 EOntfctoComnatrMaintenance Training and ERO otifcatin ComuniatorEP Training/Drill Program 7 Abbreviated NRC notification for hitMngrOperations Training and DBT event SitMngrEP Training/Drill Program 8 Complete State/local notification Shift Manager Operations Training and Form EP Training/Drill Program 9 Perform State/local notifications Communicator Maintenance Training and EP Training/Drill Program 10 Complete NRC event notification Shift Manager Operations Training and form EP Training/Drill Program 11 Activate ERSTSC ERF Computer EP Training/ Drill Program ERDS ~~~~~Operator ______________

12 Operations Training and 12 Offsite radiological assessment Shift Technical Advisor EP Training/Drill Program 13 Pefr R oiiain omnctrMaintenance Training and Perfrm RC otifcatonsCommnictorEP Training/Drill Program 14 Perform other site-specific event ComnctrMaintenance Training and

_____notifications (e.g., INPO, ANI, etc.) ComnctrEP Training/Drill Program 15 Personnel accountability Security Security Training and

_________________________________________________ EP Training/Drill Program COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 28

Attachment to TXX-1 6002 Page 29 of 29 Record of Revisions IRevision 0 IInitial issuance by TXX(-1 5084 Revision 1 Added Record of Revisions Page. Updated Sections 6 and 8 to address NRC request for additional information. (issued by TXX-16002)

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 229

Attachment to TXX-1 6002 Page 1 of 29 LUMINANT POWER COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 AND 2 NEI 12-01 PHASE 2 STAFFING ASSESSMENT Revision 1 I

COMANCHE PHASE 2 PEAK PHASE COMANCHE PEAK ON-SHIFT STAFFING 2 ON-SHIFT ASSESSMENT STAFFING ASSESSMENT 1

Attachment to TXX-1 6002 Page 2 of 29 Table of Contents 1 Introduction............................................................................................... 3 2 Analysis Overview........................................................................................ 4

Staffing Analysis Scope......................................................................... 4

Methodology ..................................................................................... 5 3 Analysis Summary ...................................................................................... 5 4 Assumptions.............................................................................................. 6

NET 12-01 Assumptions.................................................................... 6

NET 10-05 Assumptions ........................................................................ 7 5 Event Staffing Analysis................................................................................. 8

Minimum On-Shift Staffing..................................................................... 8

Scenario Overview................................................................................ 9

Staffing Analysis Summary .................................................................... 9 6 FLEX Response Analysis .............................................................................. 17

FLEX Details..................................................................................... 17

On-Site Staff Ability to Move Back-up Equipment .................................. 18

FLEX Analysis Summary ...................................................................... 18 7 Program Controls....................................................................................... 20

Emergency Response Drills & Exercise Program........................................... 20

Training........................................................................................... 20 8 Security Consideration ..................................................................... ............ 20 9 Identified Issues......................................................................................... 21 10 References................................................................................................ 22 Attachment 1, NET 10-05 Tables.................................................................... 24 2

PHASE 2 PEAK PHASE COMANCHE PEAK COMANCHE STAFFING ASSESSMENT ON-SHIFT STAFFING 2 ON-SHIFT ASSESSMENT 2

Attachment to TXX-1 6002 Pages3 of 29

1. Introduction In May, 2012, NEI published NEI 12-01, "Guidelinefor Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities".These guidelines provide criteria to assist with the preparation of assessments used to determine the required staff needed to respond to a Beyond Design Basis External Event (BDBEE) that affect multiple units at a site, and the identification of enhancements that could provide a means to power equipment needed to communicate with on-site and offsite personnel during an extended loss of AC power event. These assessments were necessary for responding to certain information requests contained in US Nuclear Regulatory Commission (NRC) letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dal-Ichi Accident, dated March 12, 2012.

As discussed in SECY-1 1-0137, "Prioritizationof Recommended Actions to be taken in Response to Fukushima Lessons Learnedf', dated October 3, 2011, responses to the information requests will be used to inform possible future regulatory actions. A 2-phase approach was used to respond to the information requests associated with staffing.

The Phase 1 staffing assessment, performed in response to the Letter was submitted by April 30, 2013, considered all requested functions except those related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2. This Phase 2 staffing assessment considers the requested functions related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2.

Recommendation 4.2 requires a three-phase approach for mitigating beyond-design-basis external events. The Initial Phase requires the use of installed equipment and resources to maintain or restore the functions of core cooling, containment and spent fuel pool cooling. The Transition Phase requires providing sufficient, portable, on-site equipment and consumables to maintain or restore these functions until they can be accomplished with resources brought from off site. The Final Phase requires obtaining sufficient offsite resources to sustain those functions indefinitely.

Additionally, the event analyzed impedes site access such that for the first 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months no personnel from off-site can access the site, from 6 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months there is limited site access and after 24+ hours there is improved site access.

Section IV.A.9 of 10 CFR 50, Appendix E, states that nuclear power reactor 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." The Nuclear Energy Institute (NEI) On-Shift ERO Staffing Task Force developed NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities"to establish a standard methodology for performing analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency. Licensees used this methodology to meet the requirement of 10 CFR 50, Appendix E, Section IV.A.9 in a manner acceptable to the US Nuclear Regulatory Commission (NRC) staff. This was Comanche Peak Nuclear Power Plant's (CPNPP) first On-Shift Staffing Assessment (OSSA), conducted in June 2012. The methodology provided in this guidance was used to perform the Phase 1 and Phase 20OSSAs.

This report provides the Phase 2 staffing assessment results for CPNPP Units 1 and 2.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT3 3

Attachment to TXX-1 6002 Page 4 of 29

2. Analysis Overview Staffing Analysis Scope All sites with one or more operating units are required to perform a Phase 2 staffing assessment no later than four months prior to the beginning of the second refueling outage (as used within the context of NRC Order EA-12-049). The Phase 2 assessment considers the staffing necessary to implement actions that address functions related to Fukushima NTTF Recommendation 4.2.

Licensees of multi-unit sites have two options for providing the Phase 2 staffing assessment:

Provide one Phase 2 staffing assessment applicable to all on-site units. This assessment should be provided four months prior to the first occurrence of a second refueling outage at the site (i.e., the first "second refueling outage"). This option may be used by sites that will employ essentially identical mitigation strategies for all on-site units.

Provide two or more Phase 2 staffing assessments as applicable to the different on-site units. Each assessment should be provided four months prior to the occurrence of the second refueling outage of the unit to which the assessment is applicable. This option may be used by all sites that will employ different mitigation strategies for on-site units.

CPNPP Unit 1 and Unit 2 staffing assessments were performed using the guidance of the first option to conduct one assessment applicable to both units. The intent of this assessment was to perform the following:

1. Evaluate the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumption, evaluate Transition Phase actions which must be performed prior to the end of the "no site access" time period.

Initial Phase - Implementation of strategies that generally rely upon installed plant equipment.

Transition Phase - Implementation of strategies involving the use of on-site portable equipment and consumables to extend the coping period, and prevent a loss of functions needed for core cooling, containment integrity, and spent fuel pool cooling. Setup for these strategies may be performed prior to the end of the Initial Phase as determined by procedure.

2. Evaluate the ability of the on-shift staff to implement the Station Blackout (SBO) coping strategies in place before Extended Loss of AC Power (ELAP) is declared.

3. Evaluate the EOPs and FSGs for responding to an ELAP affecting both units. (Note: Draft FSGs and draft EOPs, revised for FLEX implementation, were used.)

4. Evaluate whether the ability of the on-shift staff to perform any required emergency response functions would be degraded or lost prior to the arrival of the augmented ERO.

5. Consistent with the site access assumption, evaluate the ability of the on-shift staff and augmented staff to implement Transition Phase coping strategies performed after the end of the "no site access" time period.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT4

Attachment to TXX-1 6002 Page 5 of 29 The staffing level determined as a result of the Phase 2 assessment will be verified and validated in the process used to reasonably assure required tasks, manual actions and decisions for FLEX strategies are feasible and may be executed. Validation will be performed at a date after the submittal of the staffing assessment report per NEI guidance "FLEX Beyond Design Basis Validation Process" dated July 18, 2014. Necessary corrective actions will be tracked using the CPNPP corrective action program if the validation determines the assumed resources cannot complete a time sensitive action within the constraints identified in the Overall Integrated Plan (OIP) per NRC Order EA-12-049.

Methodology A tabletop assessment was performed to determine what operational and emergency response actions were procedurally required during an ELAP. Representatives from CPNPP Operations, Maintenance, Radiation Protection, Chemistry, Procedures, Engineering, Training, Security, and Emergency Preparedness met with an industry consultant in a tabletop exercise in February 2014.

The participants reviewed the assumptions and applied procedural guidance, including draft FLEX Support Guidelines (FSGs) for coping with a BDBEE using minimum on-shift staffing.) Particular attention was given to the sequence and timing of each procedural step, its duration, and the on-shift individual performing the step. Because the FSGs were not yet finalized, the results of the assessment are preliminary and will require validation prior to FLEX implementation. All gaps identified will be addressed through the CPNPP corrective action program.

The team reviewed the tasks of each member of the minimum on-shift staff in responding to the ELAP and constructed a timeline (Table 5.2) recording the tasks and the approximate time at which they were performed following the event. Task duration was recorded in half-hour intervals. In reviewing on-shift staffing tasks, the team was alert to identify instances where staff members were assigned conflicting tasks or collateral duties that would distract from their ability to fulfill Emergency Plan responsibilities.

The assessment team used the guidance of NEI 10-05 to determine if the number and composition of the on-shift staff was sufficient to implement the Emergency Plan, Initial Phase actions, and, with the assistance from augmented staff, Transition Phase actions intended to maintain or restore core cooling, containment integrity, and spent fuel pool makeup for both units. The NEI 10-05 data tables (Table 5.1 ) were modified to include tasks associated with FLEX strategies.

3. Analysis Summary The assessment concluded that the on-shift staff as defined in the current CPNPP Emergency Plan and augmented ERO alone are not adequate, and that additional shift personnel as currently required by CPNPP procedure ODA-1 02, 'Conduct of Operations, Attachment 8A Minimum Shift Crew Composition" are necessary to implement existing and planned BDBEE and ELAP strategies on both units simultaneously while continuing to perform required Emergency Planning tasks without unacceptable collateral duties. 2 Additionally, the process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established. 3 These gaps were captured and will be addressed through the CPNPP corrective action program.

1 GAP #1 - The staffing assessment was not performed with the final approved versions of FLEX Support Instructions (FSi's).

2 GAP #2 - Site Administrative Procedures and the site Emergency Plan are not aligned as to the minimum shift staffing levels.

SGAP #3 - The process to assign and utilize an expanded ERO, and the facilities and resources needed by them to perform their functions have not been established.

COMANCHE PEAK PHASE 2 ON-SHIFT STAFFING ASSESSMENT 5

Attachment to TXX-1 6002 Page 6 of 29

4. Assumptions

NEI 12-01 Assumptions for Staffing Analysis The set of standard assumptions that were used in the development of this report:

1. A large-scale external event occurs that results in:

all on-site units affected

extended loss of AC power

impeded access to the units