RS-13-084, Response to March 12, 2012, Request for Information Per 10 CFR 50.45.(f) Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency..

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Response to March 12, 2012, Request for Information Per 10 CFR 50.45.(f) Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency..
ML13121A086
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 04/30/2013
From: David Helker
Exelon Generation Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-13-084
Download: ML13121A086 (43)
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Text

10 CFR 50.54(f)

RS-13-084 April 30, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Response to March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6 - Phase 1 Staffing Assessment

References:

1. 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-ichi Accident, dated March 12, 2012
2. Exelon Generation Company, LLC's 60-Day Response to March 12, 2012 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-ichi Accident, dated May 14, 2012
3. NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012
4. NRC Letter to NEI, dated May 15, 2012, USNRC Review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," Revision 0, dated May 2012
5. NRC Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012 On March 12, 2012, the NRC staff issued a letter entitled Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (Reference 1). of Reference 1 contains the specific Requested Actions, Requested Information, and Required Response associated with Recommendation 9.3 for Emergency Preparedness -

Staffing. In accordance with 10 CFR 50.54, "Conditions of licenses," paragraph (f), addressees were requested to submit a written response to the information requests within 90 days.

U.S. Nuclear Regulatory Commission Response to 50.54(f) Letter NTTF Recommendation 9.3 April 30, 2013 Page 2 In accordance with Reference 1, Enclosure Exelon Generation Company, LLC (EGG) submitted an altemative course of action for performing the requested actions and providing the requested information (Reference 2). Enclosure 1 of Reference 2 described the altemative course of action and schedule for responding to the Emergency Preparedness Staffing, Requested Information Items 1, and 6. to this letter provides the Limerick Generating Station Phase 1 Staffing Assessment Report. The Limerick Generating Station Phase 1 Staffing Assessment Report follows the assessment process methodology described in NE112-01 (Reference 3), which was endorsed by the NRC in Reference 4.

In accordance with Reference 2, Enclosure 1, this letter provides the response to the following information requests:

  • Reference 1, Enclosure 5, Staffing, Requested Information Item 1
  • Reference 1, Enclosure 5, Staffing, Requested Information Item 2
  • Reference 1, Enclosure 5, Staffing, Requested Information Item 6 Response to Information Request in Reference 1, Enclosure 5, Staffinq, Requested Information Item 1 It is requested that addressees provide an assessment of the onsite and augmented staff needed to respond to a large scale natural event meeting the conditions described in the Discussion section (Reference 1, Enclosure 5). This assessment should include a discussion of the onsite and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:
  • How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the Order regarding the NRC Near- Term Task Force (NTTF) Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-1, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.
  • New staff or functions identified as a result of the assessment.
  • Collateral duties (personnel not being prevented from timely performance of their assigned functions).

Response

Enclosure 1 provides the Limerick Generating Station on-shift staffing assessment conducted pursuant to Reference 2. A detailed timeline based upon the existing loss of AC power procedures was performed based upon Operations review of the applicable station

U.S. Nuclear Regulatory Commission Response to 50.54(1) Letter NTTF Recommendation 9.3 April30,2013 Page 3 procedures. The focus of the timeline was to identify all resources, both operators and support organizations that would be required to execute each task. Major tasks include de-energization of unnecessary DC loads to preserve battery life, reactor pressure vessel depressurization and makeup, and establishment of additional ventilation paths. Radiation Protection and Chemistry Technician Functions (as specified in site response procedures) were also assessed to identify any diScipline-specific actions required in response to a loss of all AC power. The assessment concluded that Chemistry sampling and analysis equipment would be unavailable due to the loss of power.

The data from the Operations timeline, as well as the review of Radiation Protection and Chemistry resource requirements, was analyzed by applying the methodology specified in NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities," to evaluate the capability of the minimum on-shift staffing complement to execute the actions specified for Operations, Radiation Protection and Chemistry and the required Emergency Plan responsibilities.

Based upon the minimum shift staffing, as specified in EP-AA-1008, Radiological Emergency Plan Annex for Limerick Generating Station, the required minimum shift staffing of 23 is sufficient to support the required plant actions, as well as the Emergency Plan functions, without the assignment of collateral duties that would adversely affect the ability to execute the Emergency Plan functions.

The tables describing the required minimum staffing, the Operations timeline, and the NEI 10-05 staffing analysis tables for Limerick Generating Station are included in Enclosure 1.

Regarding the staffing requirements for movement of temporary equipment, development of the procedures to support the mitigation strategies required by NRC Order EA-12-049 (Reference 5) must be completed in order to determine the applicable staffing requirements to address back-up equipment. As described in Enclosure 1, Section 4.1.4, Limerick Generating Station will perform the requested assessment as part of the Phase 2 staffing assessment to be provided four months prior to the Li2R13 Refueling Outage (Spring 2015),

as previously identified in Reference 2.

The staffing assessment provided in Enclosure 1 determined that no new staff or functions have been identified as a result of the Phase 1 assessment.

The staffing assessment provided in Enclosure 1 determined that the existing on-shift staff is sufficient to implement the existing loss of all ac power, multi-unit event response strategies, while supporting performance of the required Emergency Planning duties without unacceptable collateral duties.

Response to Information Request in Reference 1! Enclosure 5, Staffing, Requested Information Item 2 Provide an implementation schedule of the time needed to conduct the onsite and augmented staffing assessment. If any modifications are determined to be appropriate, please include in the schedule the time to implement the changes.

U.S. Nuclear Regulatory Commission Response to 50.54(f) Letter NTTF Recommendation 9.3 April 30, 2013 Page 4

Response

The Phase 1 Staffing Assessment results for Limerick Generating Station require the establishment of procedural controls to activate the Expanded Response Capability. EGC will incorporate instructions into applicable fleet procedures to activate the Expanded Response Capability and to request any necessary logistical support for site access based upon the following conditions, as described in NEI 12-01, Section 3.8:

  • Loss of ALL offsite and ALL on-site power sources to AC emergency busses at more than 1 unit, OR
  • Plant parameters or conditions require implementation of Severe Accident Management (SAM) strategies for more than 1 unit.

These procedure changes will be implemented by September 30, 2014.

Response to Information Request in Reference 1, Enclosure 5, Staffinq, Requested Information Item 6 Identify changes that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of al/ ac power, multi-unit event, including any new or revised agreements with offsite resource providers (e.g., staffing, equipment, transportation, etc.).

Response

As described in Enclosure 1, Section 8, Item 1, the existing on-shift staff is sufficient to implement the existing loss of all ac power strategies at both units. No changes to the Emergency Plan on-shift staffing have been identified.

Also as described in Enclosure 1, Section 8, Item 2, the existing augmented ERa, supplemented by site staff, provides sufficient staffing to satisfy the Expanded Capability functions defined in NEI 12-01, Table 3.1. No changes to the Emergency Plan augmented ERa staffing have been identified.

As described in Enclosure 1, Section 7.5, the existing agreements with offsite resource providers were determined to be adequate and no new or revised agreements are required.

Given that the Beyond Design Basis External Event has not been incorporated into the Exelon Emergency Plan at this time, Exelon will not be revising the drill and exercise program in response to the Phase 1 Staffing Assessment. Consideration will be given to making the appropriate changes to the drill and exercise program based upon the implementation of the mitigating strategies in response to the Order for Recommendation 4.2.

U.S. Nuclear Regulatory Commission Response to 50.54(f) Letter NTTF Recommendation 9.3 April 30, 2013 5

A list of regulatory commitments contained in this letter is provided in Enclosure 2.

If you have any questions regarding this submittal, please contact Ron Gaston at (630) 657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 30th day of April 2013.

Respectfully, David P. Helker Manager Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosures:

1. Limerick Generating Station NEI 12-01 Phase 1 Staffing Assessment
2. Summary of Regulatory Commitments cc: Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I NRC Senior Resident Inspector Limerick Generating Station NRC Project Manager, NRR - Limerick Generating Station Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection Commonwealth of Pennsylvania

Enclosure 1 Limerick Generating Station NEI 12-01 Phase 1 Staffing Assessment Report (35 Pages)

Enclosure 1 LIMERICK GENERATING STATION NEI 12-01 Phase 1 Staffing Assessment

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Table of Contents 1.0 Executive Summary.......... ............................. ............. ..... ..... 2 2.0 Background..................................................... ...................... 2 3.0 Emergency Plan Minimum Staffing ................................................... 7 4.0 Beyond Design Basis External Event. ............................................... 8 4.1 General Assumptions and Limitations ................... , ...................... 8 4.2 Scope/Sequence of Events ....................................................... 12 5.0 On-Shift Staffing Task Analysis Results ............................................ 13 6.0 On-Shift Staffing Time Motion Study ................................................ 15 7.0 Expanded Response Capability.... ........ ... ......... .......... .... ..... . .......... 15 7.1 On-Site Radiation Protection Technicians................................... 19 7.2 Administrative Support Personne!.......... ... ..... ... .......... .... ....... 19 7.3 Training ............................................. , ...... .... ... ........ ........ ... 20 7.4 Work Areas for Expanded Capability .......................................... 20 7.5 Site Access for Expanded Capability .......................................... 20 8.0 Changes Required to Support Phase 1 Staffing Assessment.... ..... ........... 22 9.0 Conclusion ................................................................................. 23 10.0 Attachments................................................................................ 23 11.0 References................................................................................. 24 ......................................................................................... 25 March 2013 Page 1 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 1.0 EXECUTIVE

SUMMARY

This report provides the responses to the March 12,2012, Nuclear Regulatory 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-ichi Accident," as committed in Exelon Generation Company, LLC's 60-Day Response for Limerick Generating Station. This response includes the results of the Phase 1 Staffing Assessment, as described in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities. The report also includes a discussion of any changes planned in response to the Phase 1 Staffing Assessment and the associated implementation schedule.

The Phase 1 Staffing Assessment concluded that the current minimum on-shift staffing as defined in EP-AA-1 008, Radiological Emergency Plan Annex for Limerick Station, is sufficient to support the implementation of the current station blackout (SBO) strategies on both Units 1 and 2, as well as the required Emergency Plan actions, with no unacceptable collateral duties. The Phase 1 assessment also identifies the staffing necessary to support the Expanded Response Capability for the Beyond Design Basis External Event (BDBEE) as defined in NEI 12-01, Section 3.4.

The Phase 1 Staffing Assessment will require the establishment of fleet procedural controls to activate the Expanded Response Capability. These controls will be established by September 30, 2014.

2.0 BACKGROUND

Response to Near-Term Task Force Recommendation 9.3, Staffing In response to the Fukushima Dai-ichi accident, US Nuclear Regulatory Commission (NRC) issued a 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-ichi Accident,"

dated March 12, 2012. The information requests related to Emergency Preparedness (EP) are contained in Enclosure 5, "Recommendation 9.3: Emergency Preparedness" of this §50.54(f) Letter. Within this enclosure are two Requested Actions (Communications and Staffing). Both Requested Actions involve performance of an assessment. The action for the staffing assessment is summarized below:

It is requested that addressees assess their current staffing levels and determine the appropriate staff to fill all necessary pOSitions for responding to a multi-unit event during a beyond design basis natural event and determine if any enhancements are appropriate given the considerations of Near- Term Task Force (NTTF) Recommendation 9.3.

March 2013 Page 2 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear The industry developed an alternative response based upon a phased approach to Recommendation 9.3. This phased approach was developed with recognition of 1) the higher priority placed upon the completion of licensee actions necessary to comply with the EP Rule promulgated in Federal Register Volume 76, Number 226; dated November 23,2011; Pages 72560-72600; and 2) the dependency of certain assessment elements upon future definition of new response requirements associated with Fukushima NTTF Recommendation 4.2, as subsequently modified by the staff and issued as NRC Order EA-12-049. This phased approach was defined in NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities.

NEI 12-01 Executive Summary states, in part:

... A licensee should be able to provide the staffing necessary for responding to a beyond design basis external event affecting all units on a site. The number and composition of the response staff should be sufficient to implement mitigation strategies and repair actions intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling for aI/ affected units...

In its letter to Susan Perkins-Grew, NEI, dated May 15, 2012, the US NRC states, in part:

The staff has reviewed NEI 12-01, Revision 0, dated May 2012, and has found this guidance to be an acceptable method for licensees to employ when responding to the 10 CFR 50. 54(f) letters regarding NTTF Recommendation 9.3.

The phased approach and associated schedule was submitted to the NRC under Exelon Generation Company, LLC's 60-Day Response to March 12, 2012 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-ichi Accident, dated May 11, 2012 and May 14, 2012 (corrected). In this letter, Exelon committed to the completion of a Phase 1 staffing assessment by March 29, 2013, and submittal of the assessment to the NRC by April 30, 2013. Per this letter, the April 30 submittal is required to provide the requested information for Phase 1 (all functions except those related to NTTF Recommendation 4.2) of the Staffing Assessment (Staffing Request Nos. 1A, 2C and 6A). Specifically, these items are:

1 Provide an assessment of the on-site and augmented staff needed to respond to a large scale natural event meeting the conditions described in the Discussion section. This assessment should include a discussion of the on-site and augmented staff available to implement the strategies as discussed in the emergency plan and/or described in plant operating procedures. The following functions are requested to be assessed:

March 2013 Page 3 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 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 NRC Near-Term Task Force (NTTF) Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table B-1, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate.

New staff or functions identified as a result of the assessment.

Collateral duties (personnel not being prevented from timely performance of their assigned functions).

1A Provide on-site and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment]

2A Conduct the on-site and augmented staffing assessment:

The on-site and augmented staffing assessment considering all requested functions except those related to NTTF Recommendation 4.2. [Phase 1 staffing assessment] (March 29, 2013) 2C A schedule of the time needed to implement changes will be provided as follows:

Those associated with the Phase 1 staffing assessment (April 30, 2013) 6 Identify changes that have been made or will be made to your emergency plan regarding the on-shift or augmented staffing changes necessary to respond to a loss of all AC power, multi-unit event, including any new or revised agreements with oftsite resource providers (e.g., staffing, equipment, transportation, etc.).

6A Changes will be identified as follows:

Those associated with the Phase 1 staffing assessment. (April 30, 2013)

This report for Limerick Station provides the NEI 12-01 Phase 1 Staffing Assessment, as requested by the §50.54(f) letter, conducted using the guidance in NEI 12-01 and material from NEI 10-05. This report addresses items 1A, 2A, and 6A, as described in Exelon's letter of May 14, 2012.

March 2013 Page 4 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Relation to EP Rulemaking The requirements for an on-shift and augmented emergency response organization (ERO) are provided in 10 CFR 50.47(b) and 10 CFR 50 Appendix

§50.47(b)(1) states, in part:

... each principal response organization has staff to respond and to augment its initial response on a continuous basis.

§50.47(b)(2) states, in part:

On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available ...

§50 Appendix EIV, Content of Emergency Plans, subsection A states, in part:

The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensee's emergency organization and the means for notification of such individuals in the event of an emergency. ..

As part of the overall Emergency Preparedness rulemaking published in November of 2011, the Commission amended §50, Appendix Section IV.A, "Organization" to address concerns regarding the assignment of tasks or responsibilities to on-shift ERO personnel that would potentially overburden them and prevent the timely performance of their emergency plan functions. §50 Appendix E.IV subsection A.9 was added to state:

By December 24, 2012, for nuclear power reactor licensees, 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.

In conjunction with the new rule, the NRC issued, Interim Staff Guidance (ISG)

NSIR/DPR-ISG-01. ISG Section IV.C provides specific detail on the criteria and acceptable methods for the conduct of the on-shift staffing analysis, including the endorsement of NEI 10-05. The NEI analysis methodology is composed of the following:

  • Identification of the on-shift ERO staffing and response time requirements.
  • Identification of the site specific event scenarios described in the ISG.
  • Documentation of an On-shift Staffing Analysis (OSA) for each event scenario.

March 2013 Page 5 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear

  • Documentation of a Time Motion Study (TMS), if deemed necessary.

While NSIRlDPR-ISG-01! Section IV.C, and NEI 10-05 address a Station Blackout (SBO) affecting a single-unit site, and one unit on a multi-unit they do not consider the scenario of an extended loss of AC power affecting all units on a multi-unit site. Licensees of multi-unit sites should perform an assessment of this scenario using the assumptions listed in NEI 12-01 and the methodology provided in NEI 10-

05. In particular, the assessment should determine the ability of the on-shift staff to implement Initial Phase coping actions and, consistent with the site access assumptions, any Transition Phase actions that must be performed prior to the end of the "no site access" time period.

March 2013 Page 6 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 3.0 EMERGENCY PLAN MINIMUM STAFFING Revision 25 of the Limerick Station Emergency Plan Annex establishes the licensing basis for the on-shift staffing complement Only personnel required to be on-shift are credited in the staffing analysis. The following table indicates the on-shift personnel necessary to perform the required emergency planning functions.

Functional Area Major Tasks Emergency Positions Minimum Shift Size

1. Plant Control Room Staff Shift Manager 1 Operations/Safe Shift Supervisor 1 Shutdown and Reactor Operator (b) 3 Assessment of SSD Non Licensed Operator(b) 3 Operational Aspects
2. Emergency Direction Command and Shift Emergency Director 1(a) and Control Control
3. Notification and Emergency Plant Shift Personnel 2 Communication Communications
4. Radiological Offsite Dose RP Personnel(S) 1 Assessment Assessment Off-site Field Team (RP) 1 Off-site Field Team (Driver) 1 In-Plant Surveys RP Personnel 1 Chemistry Chemistry Personnel 1
5. Plant System Technical Support STA or Incident Assessor 1 Engineering Repair and Repair and Mech Maintenance 1(a)

Corrective Action Corrective Actions I&C Maintenance 1 Electrical Maintenance 1(a)

Radwaste Operator 1

6. In Plant Protective Radiation Protection RP Personnel 2(a)

Actions

7. Fire Fighting -- Fire Brigade(C) 5
8. First Aid and Rescue -- Plant Personnel 2(a)

Operations

9. Site Access Control Security and Security Team Personnel (d) and Personnel Accou ntabi Iity Accountability I Total: 23 (a) May be provided by personnel assigned other functions (b) Safe Shutdown per Fire Protection Report or per Technical Specifications. A Reactor Operator who maintains a Non Licensed Operator (NLO) qualification may fill an NLO position.

(c) Fire Brigade per FSARITRM as applicable (d) Function performed by on-shift security personnel (e) May be provided by RP Technician at Peach Bottom Atomic Power Station March 2013 Page 7 of 35 NEI 12-01 Phase 1 Report

limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 4.0 BEYOND DESIGN BASIS EXTERNAL EVENT (BDBEE) 4.1 General Assumptions and Limitations 4.1.1 NEI 12-01 Assumptions Common to Both Assessments (Staffing and Communications)

1. A large-scale external event occurs that results in:
a. all on-site units affected
b. extended loss of AC power
c. impeded access to the units
2. Initially. 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - No site access. This duration reflects the time necessary to clear road way 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - 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.

Each licensee should identify transportation and site access-enhancing methods in accordance with Section 3.9 of NEI 12-01, and include this information in the response to Staffing Information Request #4. The Staffing Information Request #4 response should also include an overview discussion of how the identified methods will be implemented following a beyond design basis external event.

A staffing assessment may utilize a "no site access" end time of less than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and greater than or equal to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, if supported by a documented March 2013 Page 8 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear basis. This basis should include a discussion of the site-specific transportation-related resources and capabilities, and related supporting arrangements, which provide assurance that augmented staff would be available on the site starting at the time used in assessment These resources and capabilities could be provided by Company-intemal, private or public sources (including vehicles and aircraft, such as helicopters from military and National Guard organizations). All arrangements with the anticipated service providers should be documented (e.g., Letter of Agreement, contract, etc.).

A staffing assessment may not utilize a "no site access" end time of less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

4.1.2 NEI 12-01 Assumptions for Staffing Assessment

1. On-shift personnel are limited to the minimum complement allowed by the site emergency plan (I.e., the minimum required number for each required position). This would typically be the on-shift complement present during a backshift, weekend, or holiday.
2. The NEI 12-01, Phase 1 Staffing Assessment considered the applicable actions from the Station Blackout (SBO) coping strategies in place at the time of the assessment
a. Such actions may include the shedding of non-essential battery loads, use of portable generators or batteries, opening room and cabinet doors, water/coolant conservation or makeup using portable equipment, etc.
b. These actions do not include those associated with cross-tying AC power sources or electrical distribution busses between units since all on-site units are experiencing an extended loss of AC power.

Following the accident at Fukushima Oai-ichi, the Institute of Nuclear Power Operations (INPO) issued three Event Reports (referred to as IERs) requiring the assessment and implementation of a range of actions intended to improve the capabilities for responding to a beyond design basis event and an extended loss of AC power, including events that impact the cooling of spent fuel. The staffing assessments performed in response to the NRC letter should include consideration of those I ER improvement actions already implemented at the time of the assessment (e.g., incorporated into plant procedures).

Sites with existing strategies for responding to an extended loss of AC power affecting all on-site units should consider those actions in their NEI 12-01 Phase 1 staffing assessment March 2013 Page 9 of 35 NEI 12-01 Phase 1 Report

limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 4.1.3 Additional Guidance for Staffing Assessment

1. For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs all Initial Phase, and any Transition Phase, coping actions.

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

Transition Phase - Implementation of strategies that involve the use of portable equipment and consumables to extend the coping period, and maintain or restore the functions of core cooling, containment, and spent fuel pool cooling.

4.1.4 NE110-05 Applicable Assumptions to Support Methodology

1. On-shift personnel can report to their assigned response locations within 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. It is assumed that personnel assigned to the major response area of Plant Operations & Safe Shutdown meet the requirements and guidance established by NRC regulations. Staff performance within this area is not evaluated as part of this assessment, unless a role/function/task from another major response area is assigned as a collateral duty.
4. The on-site security organization is able to satisfactorily perform all tasks related to Site and Protected Area Access Controls, under all event or accident conditions. Performance of this function is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.
5. Individuals holding the position of radiation protection 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 is therefore an acceptable collateral duty for all positions. Examples include making a plant page announcement or placing a call for assistance to an offsite resource such as local law enforcement. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.

March 2013 Page 10 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear The task of performing a peer check has minimal impact on the ability to perform other assigned functions/tasks, and is therefore an acceptable collateral duty for all positions. Examples include performing a peer check on a recommended emergency classification or notification form for transmittal to of1site authorities.

8. The analyzed event occurs during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday). The ERO augmentation time is based on the time of event declaration until the time of tumover of the function/responsibility. Specifically, any time needed by the augmenting ERO to acquire materials or prepare for tumover is accounted for.

Facility activation includes the turnover of functions from the on-shift staff. For purposes of this analysis, 360 minutes will be used as the time period for the conduct of on-shift ERO response actions.

Per NEI 10-05, the analysis methodology allows flexibility in the assignment of on-shift response functions and tasks, dependent upon the event or accident. For example, members of a fire brigade may be assigned other response duties if the event or accident does not include a fire. Likewise, a security officer might be assigned to perform of1slte notifications during a DBA but not the DBT. For the purposes of this assessment, members of the fire brigade are utilized to perform actions during the initial and transition phases of the response.

On March 12, 2012, the NRC issued the 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-ichi Accident. It requested licensees perform the following assessment:

"How onsite staff will move back-up equipment (e.g., pumps, generators) from alternate onsite storage facilities to repair locations at each reactor as described in the Order regarding the NTTF Recommendation 4.2. It is requested that consideration be given to the major functional areas of NUREG-0654, Table 8-1, such as plant operations and assessment of operational aspects, emergency direction and control, notification/communication, radiological accident assessment, and support of operational accident assessment, as appropriate. "

The response to this request requires that the procedures to support the mitigating strategies, as described in the Order regarding the NTTF Recommendation 4.2, be developed to determine the applicable staffing.

The schedule for the response to the order does not support the timing requirements of the Phase 1 staffing assessment. Therefore, Limerick will perform the requested assessment as part of the Phase 2 Staffing Assessment. The Phase 2 Staffing Assessment will be submitted four months prior to Limerick refueling outage Li2R13, scheduled for the spring of 2015.

March 2013 Page 11 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 4.2 Scope/Sequence of Events 4.2.1 Beyond Desiqn Basis External Event (BDBEE): Station Blackout (SBO)

Per NEI 12-01, Section 2.2, a large-scale external event occurs that results in:

  • All on-site units affected
  • Extended loss of AC power
  • Impeded access to the units Initially, both on-site reactors are operating at full power and are successfully shut down.
  • Both units experience a loss of offsite power and a failure of all emergency AC power sources resulting in a Station Blackout (Loss of all AC power).
  • For the Phase 1 Staffing Assessment, it is assumed that any systems/components that are not reliant upon AC power remain available for use in existing mitigation strategies.
  • The BDBEE occurs such that restoration of any AC power source is not possible before the arrival of the augmented ERO personnel. (e.g., 360 minutes)
  • The event initially results in a Site Area Emergency based on EAL MS 1, with subsequent escalation to a General Emergency based on EAL MG1.

4.2.2 On-shift Response Limerick has a common Control Room for the operation of Units 1 and 2 with one Shift Manager (SRO) providing Operations oversight of both units, and one Control Room Supervisor (SRO) who directs the activities for both units. In addition, minimum staffing includes a Shift Technical Advisor or Incident Assessor (ST AliA), and three Reactor Operators (ROs).

During a plant transient, manual or automatic shutdown, the Control Room Supervisor directs implementation of response actions per applicable abnormal operating or emergency operating procedures. The STAliA provides independent oversight and safety function status assessment (for both units during a dual unit event). The Shift Manager provides independent oversight and is also the Interim Emergency Director when plant conditions reach emergency action declaration criteria.

Non-licensed plant operators, on-shift Radiation Protection and Chemistry technicians will report to the control room for direction or direction will be provided to them via telephone or portable radio.

March 2013 Page 12 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear For the Phase 1 Staffing Assessment, on-shift personnel respond to the initiating events in accordance with plant procedures. The initial response relies upon RCIC for vessel injection. Transition phase actions include preparations for the establishment of temporary DC power for the safety relief valves and staging of portable pumps for vessel injection.

The following procedures and guidelines were referenced during the event review:

  • T-100, Scram/Scram Recovery
  • T-101, RPV Control
  • 1, Loss of All AC Power (Station Blackout)
  • E-10/20, Loss of Offsite Power
  • TSG-4.1 Operational Contingency Guidelines
  • S55.2A, HPCI Shutdown From Automatic or Manual Initiation
  • OP-LG-1 02-1 06, Operator Response Time Program at Limerick Station
  • EP-AA-112-1 00-F-01, Shift Emergency Director Checklist

The BDBEE response required the on-shift personnel to implement actions to provide alternate power to operate safety-relief valves for depressurization and connection of portable pumps to provide vessel injection prior to ERO augmentation. This on-shift assessment concluded that sufficient personnel are available to support these actions prior to the availability of additional personnel.

5.0 ON-SHIFT STAFFING TASK ANALYSIS RESULTS Limerick Operations personnel conducted a table-top review of the on-shift response to the postulated BDBEE and extended loss of AC power for the Initial and Transition Phases using the current SBO strategies. Resources needed to perform initial event response actions were identified from the Emergency Operating Procedures (EOPs),

Abnormal Operating Procedures (AOPs), or other operations procedures.

Per NEI 12-01, Corporate EP performed an assessment of the ability to execute the required EP functions using the methodology specified in NEI 10-05. Per NEI 10-05, the analysis is performed using five tables to evaluate the on-shift staffing and functions. The on-shift resources were entered in the appropriate tables (Attachment 1, Tables 2 and 3). Applicable RP and Chemistry tasks and the time required to perform expected emergency plan functions were entered in Table 4. This information was documented on the applicable tables from N EI 10-05 located in Attachment 1 of this report. The Emergency Plan functions for the event were reviewed and assigned to the on-shift resource responsible for performance of the identified function and documented as per NEI 12-01 using the NEI 10-05 documentation (Table 5). Finally, the on-shift resources and their actions were summarized in Table 1 using the NEI 10-05 documentation process.

March 2013 Page 13 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear This Phase 1 Staffing Assessment concluded that the current shift staffing is sufficient to execute all required initial and transition phase tasks prior to the arrival of additional site personnel. The most resource-intensive positions were determined to be the Equipment Operators (EO). The EO tasks were assigned as shown in Table 5.1 below. None of these operating tasks requires the use of the Shift Manager

/ Shift Emergency Director or the dedicated shift communicators. As such, no unacceptable collateral duties were identified. Refer to Attachment 1, NEI 10-05 Staffing Table for Limerick Station , for documentation of the on-shift staffing analysis results.

Table 5.1: Limerick EO Utilization

~

0-15 15-30 30-45 45-60 60-75 75-90 90-105 105-120 Position EO #1 EOO Starts Local E-I DC Load Shed EO #2 EOO Starts Local E- I DC Load Shed EO #3 Establish RCIC Natural Ventilatio n Supply Backup Bottles for Refuel Floor Seals EO #4 Establish RCIC Natural Ventilation Supply Backup BoUl es for Refuel Floor Seals EO #5 Establi sh RCIC Natural Ventilation Tran sport Portable Equipment with Truck EO #6 Establish RClC Natural Ventil ation Transport Portable Equipment with Tru ck EO #7 E- I Additio nal Load Shed EO #8 E- I Additional Load Shed I&C#l Drywell Te mp Monitoring I&C#2 Drywell Temp Mo nitoring

~

120-135 135-150 150-165 165-180 180-195 195-210 210-225 225-240 Position EO#1 Obtain SRV Cart Co nn ect SRV Cart Generator EO #2 Obtai n SR V Cart Co nnect SRV Cart Generator EO #3 Supply Backup Bottles for Refuel Floor Seals Setup for Manual Co ntainment Vent EO #4 Supply Backup Bottl es for Refuel Floor Seals Setup for Manual Co ntainment Ven t EO #5 Transport Portable Equipment with Truck EO #6 Transport Portable Equipment with Truck EO#7 Connect Obtain N2 Bottle Portable Pump EO #8 Connect Obtain N2 Bottle Portable Pump I&C#l I&C#2 March 2013 Page 14 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear

~

240-255 255-270 270-285 285-300 300-315 315-330 330-345 345-360 Position EO #1 Obtain SR V Cart EO #2 Obtain SRV Can EO #3 Setup for M anual Containment Vent EO #4 Setup for M anual Containment Vent EO #5 Transpon Ponable Equipmen t with Truck EO #6 Transport Portable Equipment wi th Truck EO #7 Connec t Portable Pump Connect Portable Pump EO #8 Connect Port able Pump Connect Port able Pump I&C#l Connect SR V Cart Generator I&C#2 Connect SR V Cart Generator 6.0 ON-SHIFT STAFFING TIME MOTION STUDY The analysis did not identify any non-validated tasks or potential overlap tasks that would require a Time Motion Study to be performed.

7.0 EXPANDED RESPONSE CAPABILITY A typical augmented ERO for a mUlti-unit site would be challenged to effectively respond to a beyond design basis external event that resulted in an extended loss of AC power affecting more than one unit. In an event of this magnitude, it would be necessary to "expand" the capability of the augmented ERO in order to facilitate timely and effective performance of critical emergency response functions. The focus of this "expanded response capability" at Limerick should be to enable the performance of unit-specific accident assessment and mitigation functions.

In accordance with NEI 12-01 , to be effective, the expanded response capability should encompass those functions necessary for preventing damage to irradiated fuel, or if such damage occurs, minimizing radiological releases . Selected functions must directly support the assessment and implementation of a range of mitigation strategies intended to maintain or restore the functions of core cooling, containment, and spent fuel pool cooling.

NEI 12-01, Table 3.1 lists the emergency response functions identified by the NEI Beyond Design Basis Event Response Staffing Study Task Force as meeting these requirements. NEI 12-01, Table 3.1 further provides key roles and staffing considerations for each expanded response function and specifies the staffing necessary to support the simultaneous deployment of emergency repair and corrective action teams to each affected unit.

Table 7.1 of this report describes the recommended expanded response capability staffing for Limerick Station based upon the NEI 12-01 guidance for the Phase 1 assessment.

March 2013 Page 15 of 35 NEI 12-01 Phase 1 Report

Limerick Station NE112-01 Phase 1 Staffing Assessment Exelon Nuclear Table 7.1 EXDanded ResDonse Functions for Limerick Phase 1 Staffin Assessment Expanded Response Typical Key Roles and Staffing Considerations Req Function Function Location Staffin Fulfilled B Unit Response TSC I. Overall cognizance of the activities related to and 2 Station ED Coordination corrective actions, and implementation of Transition Phase coping and Severe Accident Management (SAM) strategies for an assigned unit

  • One individual per unit; individuals should not be assigned other functions Normal ERO Operations Coordination TSC Provides coordination of Operations staff and support for an assigned unit 2 I*
  • One individual per unit; individuals should not be assigned other functions Normal ERO (Required

+ I)

Note 1 Maintenance Coordination I TSC Of OSC I

  • Provides coordination of Maintenance staff and support for an assigned unit 2 Maintenance
  • One individual per unit; individuals should not be assigned other functions Normal ERO (Required staffing* + I)

Engineering Coordination I TSC or OSC I

  • Provides coordination of Engineering staff and support for an assigned unit 2 Technical
  • One individual per unit; individuals should not be assigned other functions Normal ERO Engineering Assessments I TSC or OSC I. One team for each unit to perform engineering assessments in support of 6 Core repair and corrective actions
  • Team composition (i.e., number and represented disciplines) as described in the emergency plan
  • Team may include personnel responsible for performing other functions for March 2013 Page 16 of 35 NEI 12-01 Phase 1

Limerick Station NE112-01 Phase 1 Staffing Assessment Exelon Nuclear Expanded Response Typical Key Roles and Staffing Considerations Required Function Function Location Staffin Fulfilled B'l the same assigned unit Normal ERO Evaluation of Severe TSC orOSC I. One team for each unit to evaluate selection of SAM team Accident Management evaluations not done by Control Room personnel (SAM) Strategies concurrent

  • Team composition (i.e., number and represented as described in with governing site programs, procedures and Technical
  • Team may include personnel responsible for other functions for 4 additional the same assigned unit and Note 1 Manager Unit In-Plant Team OSC
  • Overall cognizance of on-site and in-plant teams 2 OSC Coordination repair and corrective actions for an assigned unit Ass! OSC
  • One individual per unit; individuals should not be assigned other functions Director Normal ERO Non-Licensed OSC
  • Two individuals per unit to implement repair and corrective actions 4
  • Should not include members of the on-shift staff Mechanical Maintenance OSC
  • Two individuals per unit to implement repair and corrective actions 4 Site and Corrective
  • Staffing may include an on-shift individual /i.e .. 2 individuals for a unit Action composed of lon-shift and 1 augmented)

Electrical Maintenance OSC

  • Two individuals per unit to implement repair and corrective actions 4 Site Technicians Repair and Corrective
  • Staffing may include an on-shift individual Ii.e .. 2 individuals for a unit and/or Action composed of lon-shift and 1 March 2013 Page 17 of 35 NEI 12-01 1 Report

Limerick Station NE112-01 Phase 1 Staffing Assessment Exelon Nuclear Expanded Response Typical Key Roles and Staffing Considerations Requir Function Location Staffi I&C and OSC

  • Two individuals per unit to and corrective actions 4 Corrective Action
  • Staffing may include an on-shift individual (i.e .. 2 individuals for a unit composed of lon-shift and 1 of SAM OSC
  • Nllmhpr ;mrJ rnmpOSttlon of capable of simultaneous 4 ROs.

Strategies of any 2 SAM at each unit Note 2 6

  • Should not include emergency 4 J'vlaint repair and corrective may include members of the on-shift Tcchs.

staff and personnel responsible for of Transition Phase 4I&C EOF; strategies 2 ROs. 4 2 RP Techs Techs. I&C 2 Chem Techs. 2 RP Tcchs. I Chem Dose Assessor

  • - The required staffing for each position is specified in EP-AA-1008, Radiological Emergency Plan Annex for Limerick Station. Normal augmentation is the required staffing plus one additional qualified individual.

Notes:

1 -The SAMG Decision Maker position requires two individuals qualified as SAMG Decision Maker. The SAMG Evaluator position requires four individuals qualified as SAMG Evaluator. Per EP-AA-1008, Table 2-1, the SAMG Decision Maker and SAMG Evaluator functions may be assigned as concurrent duties.

2 - The SAM strategies selected for Limerick were T-228, Inerting/Purging Primary Containment, and T-260, Reactor Pressure Vessel DepressurizationNenting March 2013 Page 18 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 7.1 On-Site Radiation Protection Technicians Following a beyond design basis external event, on-site Radiation Protection (RP) Technicians are available in sufficient numbers to support performance of assigned emergency plan functions and the expanded response capability.

Per NEI 12-01, the equation is used to determine the required number of on-site RP Technicians (RPTs):

RPTT = RPTCOP + RPTRCA + RPTNC Where:

RPTT Total required number of on-site RP Technicians RPTCOP = Number needed to support implementation of any 2 extended loss of AC power coping strategies per unit Determine this number by reviewing strategies for each unit.

RPTRCA = Number needed for repair and corrective action

=2 x the number of units RPTNC Number of on-site RP Technicians performing other emergency plan functions that would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams.

For Limerick Station:

RPTCOP = 2 RP Technicians (Assessment of Radiological Conditions)

RPTRCA = 4 RP Technicians (2 per Unit)

RPTNC = 2 RP Technician (Off-site Surveys)

RPTT = 8 RP Technicians For Limerick, the complement of RP Technicians specified in the augmented ERO per EP-AA-1008 is 10. Therefore, sufficient RP Technicians are anticipated to be available from Site resources to support the initial staffing of the Expanded Capability. Additional RP Technician resources are available from the Site staff, as well as other Exelon sites.

7.2 Administrative Support Personnel Administrative support personnel positions are not required for the Limerick On-call ERO Staffing Requirements. Should the need for administrative support arise, this support would be obtained through a combination of site personnel and personnel from the Corporate organization, as well as other regional Exelon nuclear sites. Therefore, no enhancements have been identified in the assessment of administrative support personnel.

March 2013 Page 19 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear 7.3 Training No new ERO tasks or functions are required for implementing the expanded capability. There are a sufficient number of qualified ERO personnel to implement the expanded response; qualification of additional personnel will not be required.

7.4 Work Areas for Expanded Capability The site has multiple locations that can be utilized to support the expanded response capabilities if available. These areas include the Outage Control Center and Maintenance Shop. Should these locations not be available due to the BDBEE, other available office space may be utilized, as appropriate, based upon the nature and effects of the event.

7.5 Site Access for Expanded Capability 7.5.1 Activation of Expanded Response Capability Emergency Response Organization members are instructed to respond to their assigned Emergency Response Facility (ERF) or, if that facility is inaccessible, to the alternate facility. In support of this requirement, HU-AA-1081-F-15, Emergency Response Organization Fundamentals, has been revised to direct individuals to take the following actions if they become aware of a grid disturbance or significant natural disaster (e.g., earthquake, tornado, flood):

  • Monitor local radio communications for impact on the Grid structure and local roads.
  • Should the situation appear to be a major disturbance to the Grid structure, ensure your home and family is safe, and then report to your emergency response facility (ERF). If your ERF is not accessible, report to your alternate reporting location.

Direction has also been added to ensure that cell phones are maintained in a charged condition to support potential emergency communications for personnel not affected by the loss of communications.

7.5.2 Support for Expanded Capability Site Access Various methods of access would apply to each site, depending upon the nature of the natural disaster affecting the site, including walking, personal vehicle, helicopter, ATV and water craft. Logistical support for site access under adverse conditions would be provided under the mutual aid structure. For the Commonwealth of Pennsylvania, the provision of emergency support is governed by Title 35, Chapter 73, Commonwealth Services, Subchapter A, The Governor and Disaster Emergencies, Subchapter B, Pennsylvania Emergency Management Agency, and Subchapter C, Intrastate Mutual Aid.

These statutes assign the Governor the authority, under a declared state of March 2013 Page 20 of 35 NEI 12-01 Phase 1 Report

limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear emergency! to utilize all available resources of the Commonwealth Govemment and each political subdivision of this Commonwealth as reasonably necessary to cope with the disaster emergency. The Govemor has the authority for the deployment and use of any forces to which the plan or plans apply and for use or distribution of any supplies, equipment and materials and facilities assembled, stockpiled or arranged to be made available pursuant to this part or any other provision of law relating to disaster emergencies, and is the Commander in Chief of the Pennsylvania military forces.

In addition to the applicable state statutes, site-specific letters of agreements

/ memoranda of understanding are in place with local law enforcement and fire/rescue. These entities may be called upon to assist in site access:

  • Linfield Fire Company
  • Limerick Fire Company State and Local authorities are expected to provide the primary source of support to facilitate facility access. In addition, there may be some heavy equipment under the control of the off-site electrical distribution companies that could be applied during a natural disaster and resultant grid emergency.

It is important to note that the primary focus of the distribution companies would be restoration of AC power, in accordance with PJM Manual 39, Nuclear Plant Interface Coordination, PJM Manual 36, System Restoration, and PJM Manual 13, Emergency Operations. The normal Exelon Corporate structure provides the primary conduit for requesting support from PECO to support nuclear station emergencies. In addition, Limerick maintains an interface agreement with PECO governing the conduct of work at the site.

This interface provides an additional communications interface between the sites and the distribution companies. Based upon a review of the existing manuals and procedures, no revisions are required at this time. A review of the relationships with the electrical distribution companies has concluded that no additional agreements are required.

March 2013 Page 21 of 35 NEI 12-01 Phase 1 Report

Limerick Station NE112-01 Phase 1 Staffing Assessment Exelon Nuclear 8.0 CHANGES REQUIRED TO SUPPORT PHASE 1 STAFFING ASSESSMENT

1. Staffing Changes This Phase 1 Staffing Assessment concluded that the existing on-shift staff is sufficient to implement the existing SBO strategies on both units, simultaneously, while supporting performance of the required Emergency Planning duties without unacceptable collateral duties. No staffing changes are required.

Resources needed to perform initial event response actions were identified from the EOP, AOP, or other operations procedures and documented as per the guidance in NEI 12-01 using the NEI 10-05 documentation process (Attachment 1, Tables 2 and 3). The team determined when other on-shift resources, such as the RP or Chemistry Technician, would be required and identified the time required to perform expected emergency plan functions (Table 4). This information was documented on the applicable tables from NEI 10-05 located in Attachment 1 of this report. The Emergency Plan functions for the event were reviewed and assigned to the on-shift resource responsible for performance of the identified function and documented as per NEI 12-01 using the NEI 10-05 documentation (Table 5). Finally, the on-shift resources and their actions were summarized in Table 1 using the NEI 10-05 documentation process. This review concluded that the personnel assigned to the required Emergency Plan functions are not required to execute the initial event response actions. As such, no unacceptable collateral duties were identified.

2. Expanded Capability Staffing The existing augmented ERO, supplemented by site staff, provides sufficient staffing to satisfy the Expanded Capability functions as defined in NEI 12-01, Table 3.1. Additional staffing support is available from fleet resources.

Resources, including Operations, Maintenance, Instrumentation and Controls, Radiation Protection, and Engineering, are routinely shared during refueling outages. This experience, along with the common structure of Exelon's processes enables personnel shared between sites to support site-specific activities.

3. Emergency Plan and Procedure Changes Per NEI 12-01, Section 3.10, the capability for responding to a beyond design basis external event does not need to be described in the emergency plan. A licensee may, however, choose to incorporate implementing instructions for expanded response functions into emergency plan implementing procedures, and/or extended loss of AC power, SAM or other program documents.

Exelon will incorporate instructions into applicable fleet procedures to activate the Expanded Response Capability and to request any necessary logistical support for site access based upon the following conditions, as described in NEI 12-01, Section 3.8:

March 2013 Page 22 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear

  • Loss of ALL oftsite and ALL on-site power sources to AC emergency busses at more than 1 unit, OR
  • Plant parameters or conditions require implementation of Severe Accident Management (SAM) strategies for more than 1 unit.

These procedure changes will be implemented concurrent with the implementation of the mitigating strategies at the first affected Exelon site in the fall of 2014. This action will be completed by September 30, 2014.

NEI 12-01 further 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-ot-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.

Given that the BDBEE has not been incorporated into the Exelon Emergency Plan, at this time, Exelon will not be revising the drill and exercise program in response to the Phase 1 assessment. Consideration will be given to making the appropriate changes to the drill and exercise program based upon the implementation of the mitigating strategies in response to the order for recommendation 4.2.

9.0 CONCLUSION

This Phase 1 Staffing Assessment concluded that the current minimum on-shift staffing as defined in EP-AA-1008, Radiological Emergency Plan Annex for Limerick Generating Station, is sufficient to support the implementation of the current station blackout (SBO) strategies on Units 1 and 2, as well as the required Emergency Plan actions, with no unacceptable collateral duties.

The Phase 1 Staffing Assessment also identified the staffing necessary to support the Expanded Response Capability for the Beyond Design Basis External Event (BDBEE) as defined for the Phase 1 assessment. This staffing will be provided by the current site resources, supplemented by fleet resources, as necessary.

The Phase 1 Staffing Assessment concluded that an action is required to establish fleet procedural controls to activate the Expanded Response Capability. These controls will be established by September 30, 2014.

10.0 ATTACHMENTS 10.1 Attachment 1, NEI 10-05 Staffing Tables for Limerick Station March 2013 Page 23 of 35 NEI 12-01 Phase 1 Report

limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear

11.0 REFERENCES

11.1 NEI 12-01, Rev 0, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities" 11.2 NEI 10-05, Rev 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" 11.3 NSIR DPR-ISG-01, "Interim Staff Guidance Emergency Planning for Nuclear Power Plants."

11.4 EP-AA-1000, Exelon Nuclear Standardized Radiological Emergency Plan, Rev. 21 11 EP-AA-1008, Exelon Nuclear Radiological Emergency Plan Annex For Limerick Generating Station, Rev 25 11.6 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-ichi Accident," dated March 12,2012.

11.7 Exelon Generation Company, LLC Letter to NRC, "60-Day Response to March 12, 2012 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-ichi Accident," dated May 11,2012 and May 14, 2012 (corrected).

11.8 T -228, Inerting/Purging Primary Containment 11.9 T-260, Reactor Pressure Vessel DepressurizationlVenting 11.10 HU-AA-1 081-F-15, Emergency Response Organization Fundamentals 11.11 EP-AA-1008 Addendum 1, Limerick Generating Station On-shift Staffing Technical Basis 11.12 Exelon Generation Company, LLC Letter to NRC, "Exelon Generation Company, LLC's (EGC) gO-Day Response to March 12, 2012 Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendation 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident; dated March 12,2012 (Emergency Preparedness) ," dated June 11, 2012.

11.13 NRC Letter to Susan Perkins-Grew, NEI, "U.S. Nuclear Regulatory Commission Review of NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities,"

Revision 0, dated May 2012," dated May 15, 2012 March 2013 Page 24 of 35 NEI 12-01 Phase 1 Report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 NEI 10-05 Staffing Tables For Limerick Station NE112-01 Phase 1 March 2013 Page 25 of 35 NEI 12-01 Phase 1 report

limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 NEI 12-01 Phase lOn-shift Staffing Assessment (OSA)

1. Accident Summary:
  • A loss of all offsite AC power occurs coincident with the trip of both units.

All emergency diesel generators fail to start.

2. Accident Specific Assumptions:
  • There was no other plant damage and all equipment operates as designed.
3. Procedures Reviewed for Accident Response Include:
  • T-100, Scram/Scram Recovery
  • T-101, RPV Control
  • E-1, Loss of All AC Power (Station Blackout)
  • E-10/20, Loss of Offsite Power
  • TSG-4.1 Operational Contingency Guidelines
  • S55.2.A, HPCI Shutdown From Automatic or Manual Initiation
  • OP-LG-1 02-1 06, Operator Response Time Program at Limerick Station
  • EP-AA-112-1 OO-F-01, Shift Emergency Director Checklist
  • RP-LG-301-2001, Radiation Protection Response Card March 2013 Page 26 of 35 NEI 12-01 Phase 1 report

limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 Limerick This OSA is applicable to Analysis NEI 12-01 Phase 1.

TABLE 1 - On-shift Positions Augmentation Emergency Plan Elapsed Time Role in Line On-shift Position (min)

Reference Table#/Line#

Note 2 T2/L1 Shift I Shift ED EP-AA-1008, Table 2-1 N/A T5/L1 T5/L2 T5/L3

1. T5/L4 T5/L5 T5/L8 T5/L 10
2. U1 Control Room Supv (SRO) EP-AA-1008, Table 2-1 N/A T2/L2
3. STA EP-AA-1008, Table 2-1 N/A T2/L3
4. U1 Reactor Operator (RO #1) EP-AA-1008, Table 2-1 N/A T2/L4
5. U2 Reactor Operator (RO #2) EP-AA-1008, Table 2-1 N/A T2/L5
6. Plant Reactor Operator (RO #3) EP-AA-1008, Table 2-1 N/A T2/L6
7. SSD Equipment Operator (EO #1) EP-AA-1008, Table 2-1 N/A T2/L7

-~

8. SSD Equipment Operator (EO #2) EP-AA-1008, Table 2-1 N/A T2/L8
9. SSD Equipment Operator (EO #3) EP-AA-1008, Table 2-1 N/A T2/L9
10. Fire Brigade Leader (EO #4) EP-AA-1008, Table 2 N/A T2/L 10
11. Fire Brigade EO (EO #5) EP-AA-1008, Table 2-1 N/A T2IL 11
12. Fire Brigade EO (EO #6) EP-AA-1008, Table 2-1 N/A T2/L 12
13. Fire Brigade EO (EO #7) EP-AA-1008, Table 2-1 N/A T2/L 13
14. Fire Brigade EO (EO #8) EP-AA-1008, Table 2-1 N/A T2/L 14 T5/L6 Shift EP Communicator (EO #9) EP-AA-1008, Table 2-1 N/A
15. T5/L9 Note 1 Shift NRC Communicator (RO EP-AA-1008, Table 2-1 N/A T5/L 13
16. #4) Note 1 March 2013 Page 27 of 35 NEI 12-01 Phase 1 report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Augmentation Emergency Plan Elapsed Time Role in Line On-shift Position Reference (min) Table#/Line#

Note 2 T2/L 15

17. Radwaste Operator (EO #10) EP-AA-1008, Table 2-1 N/A
18. Rad Pro Tech #1 EP-AA-1008, Table 2-1 N/A T4/L 1
19. Rad Pro Tech #2 EP-AA-1008, Table 2-1 N/A -

Rad Pro Tech #3 (Peach Bottom) EP-AA-1008, Table 2-1 N/A -

21. Chern Tech EP-AA-1008, Table 2-1 N/A -
22. I&C Tech #1 EP-AA-1008, Table 2-1 N/A T2/L 18
23. I&C Tech #2 EP-AA-1008, Table 2-1 N/A T2/L 19
24. Security EP-AA-1008, Table 2-1 N/A T5/L 15 Notes:
1. The Shift EP Communicator can be filled by any available qualified individual who is not assigned ST A, Fire Brigade, SSD or Shift Emergency Director.
2. Augmentation Elapsed Time - Per the site access assumptions in NEI12-01, augmentation will begin at T = 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This assessment is based upon the ability to execute the required functions for the initial 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following the initiating event.

March 2013 Page 28 of 35 NEI 12-01 Phase 1 report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 Limerick This OSA is applicable to Analysis NEI 12-01 Phase 1.

Two Units - One Control Room Applicable to site unit(s) # _..!.-:::::~_

Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable TABLE 2 - PI ant 0'pera f Ions & Sae f Sh utd own Generic Title/Role Task Performance Line On-Shift Position Validation 1 Shift Manager Shift Manager Ops Training Program Unit Supervisor U 1 Control Room SUpv Ops Training Program 2

(SRO) 3 Shift Technical Advisor STA (SRO) Ops Training Program Reactor Operator #1 U 1 Reactor Operator Ops Training Program 4

(RO #1)

Reactor Operator #2 U2 Reactor Operator Ops Training Program 5

(RO #2)

Reactor Operator #3 Plant Reactor Operator Ops Training Program 6

(RO #3)

Auxiliary Operator #1 SSD Equipment Operator Ops Training Program 7

(EO #1)

Auxiliary Operator #2 SSD Equipment Operator Ops Training Program 8

(EO #2)

Auxiliary Operator #3 SSD Equipment Operator Ops Training Program 9 (EO #3) 10 Auxiliary Operator #4 FBL (EO #4) Ops Training Program 11 Auxiliary Operator #5 FBM (EO #5) Ops Training Program 12 Auxiliary Operator #6 FBM (EO #6) Ops Training Program 13 Auxiliary Operator #7 FBM (EO #7) Ops Training Program 14 Auxiliary Operator #8 FBM (EO #8) Ops Training Program 15 Auxiliary Operator #10 Radwaste Operator (EO #10) Ops Training Program Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs If r bl e appllca Task Performance Line Generic Title/Role On-Shift Position Validation 16 Mechanic n/a n/a 17 Electrician n/a n/a March 2013 Page 29 of 35 NEI 12-01 Phase 1 report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear March 2013 Page 30 of 35 NEI 12-01 Phase 1 report

Limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 Limerick This OSA is applicable to Analysis NEI 12-01 Phase 1.

TABLE 3 - Firefighting Line Performed By Task Performance Validation 1 nfa nfa 2 nfa nfa 3 nfa nfa 4 nfa nfa 5 nfa nfa Notes:

Fire Brigade not utilized for this scenario.

March 2013 Page 31 of 35 NEI 12-01 Phase 1 report

Limerick Station NE112-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 Limerick This OSA is applicable to Analysis NEI 12-01 Phase 1.

TABLE 4 - Radiation Protection & Chemistry Performance Time Period After Emergency Declaration (minutes) I Position Performing Line 0- 5 15 25 35 45 55 65 75- 80 FunctionfTask 5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 *.

In-Plant Survey 1

On-Shift Position: RP#1 X X X X X X X X X X X X X X X X X X On-Site Survey 2

On-Shift Position:

Personnel Monitoring 3

On-Shift Position:

Job Coverage 4

On-Shift Position: RP#2 X X X X X X X X X X X X X X X X X X Offsite Radiological 5 Assessment On-Shift Position:

Other Site-Specific RP 6 Describe:

On-Shift Position:

Chemistry function/task

  1. 1 - Describe:

7 See Notes X X X X X X X X X X X X X X X X X X On-Shift Position: Chem Tech #1 Chemistry function/task 8 #2 - Describe:

On-Shift Position:

March 2013 Page 32 of 35 NEI 12-01 Phase 1 Report

Limerick Station NE112-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 Limerick This OSA is applicable to Analysis NE112-01 Phase 1.

TABLE 4 - Radiation Protection & Chemistrv Cont'd Performance Time Period After Emergency Declaration (minutes)

Position Performing Line FunctionfTask 90-120 120- 150- 180- 210- 240- 270- 300- 330- 360-150 180 210 240 270 300 330 360 390 In-Plant Survey 1 X X X X X X X X X X On-Shift Position: RP#1 On-Site Survey 2

On-Shift Position:

Personnel Monitoring 3 On-Shift Position: I Job Coverage 4 X X X X X X X X X X On-Shift Position: RP#2 Offsite Radiological 5 Assessment On-Shift Position: I Other Site-Specific RP- I 6 Describe:

On-Shift Position:

Chemistry function/task #1

- Describe:

7 See Notes X X X X X X X X X X On-Shift Position: Chem Tech #1 Chemistry function/task #2 8 - Describe:

On-Shift Position: ~-~

L -________

-- ~

March 2013 Page 33 of 35 NEI 12-01 Phase 1

Limerick Station NE112-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 Limerick This OSA is applicable to Analysis NEI 12-01 Phase 1 TABLE 4 - Radiation Protection & Chemistry Notes:

When not performing specific tasks noted below, RP and Chemistry personnel will perform assignments at the direction of the Shift Manager.

RP Techs

  • RP #1 o EP-AA-112-1 OO-F-01, Step 1.10 - An RP tech is assigned to the MCR to support emergency rO"' .....I"\".,

Tech will support Operations activities as necessary and as prioritized by the Shift Emergency there are no specific actions for RP indentified under this procedure step.

o RP-LG-301-2001, Radiation Protection Response Card, directs RP Tech to survey Scram Discharge Volume and other plant areas. There is no time requirement for this action.

Chemistry - no immediate actions.

March 2013 Page 34 of 35 NEI 12-01 Phase 1 Report

limerick Station NEI 12-01 Phase 1 Staffing Assessment Exelon Nuclear Attachment 1 Limerick This OSA is applicable to Analysis NEI 12-01 Phase 1.

TABLE 5 - Emergency PI an mpi emen t af Ion Task Performance Line FunctionlTask On-Shift Position Validation Declare the Emergency Shift Manager Ops Training Program 1

Classification Level (ECL)*

Approve Offsite Protective Shift Manager Ops Training Program 2

Action Recommendations*

Approve content of State/local Shift Manager Ops Training Program 3

notifications*

Approve extension to allowable Shift Manager Ops Training Program/

4 dose limits* EP Drills and Exercises Notification and direction to on- Shift Manager Ops Training Program 5 shift staff (e.g., to assemble, evacuate, etc.)

ERO notification Shift EP Communicator Ops Training Program/

6 EP Drills and Exercises Abbreviated NRC notification n/a n/a 7 for DBT event Complete State/local Shift Manager Ops Training Program 8 notification form Perform State/local notifications Shift EP Communicator Ops Training Program/

9 EP Drills and Exercises Complete NRC event Shift Manager Ops Training Program 10 notification form Activate EROS n/a n/a 11 Offsite radiological assessment n/a nfa 12 Perform NRC notifications Shift NRC Ops Training Program/

13 Communicator EP Drills and Exercises Perform other site-specific n/a n/a 14 event notifications (e.g., INPO, ANI, etc.)

Personnel accountability Security EP Drills 15 Other: Specify n/a n/a 16

  • Shift Manager non-delegable duty March 2013 Page 35 of 35 NEI 12-01 Phase 1 Report

Enclosure 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No) (Yes/No)

EGC will incorporate instructions into applicable September 30, No Yes fleet procedures to activate the Expanded 2014 Response Capability and to request any necessary logistical support for site access based upon the following conditions, as described in NEI 12-01, Section 3.8:

  • Loss of ALL offsite and ALL on-site power sources to AC emergency busses at more than 1 unit, OR
  • Plant parameters or conditions require implementation of Severe Accident Management (SAM) strategies for more than 1 unit.
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