Text

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..
	ML15128A252
Person / Time
Site:	Peach Bottom
Issue date:	05/08/2015
From:	Jim Barstow; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	RS-15-114
	Download: ML15128A252 (46)
	v • d • e

Exelon Generation 10 CFR 50.54(f)

RS-15-114 May 8, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Response to March 12, 2012, Request for Information Pursuant to Title 1O 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 2 Staffing Assessment

References:

1. NRC Letter, Request for Information Pursuant to Title 1O 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, USN RC 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

6. Peach Bottom Atomic Power Station, Units 2 and 3 Letter to NRC, Response to March 12, 2012, Request for Information Pursuant to Title 1O 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 2 Staffing Assessment, dated May 8, 2015 (RS-15-115)

U.S. Nuclear Regulatory Commission Response to 50.54(f) Letter NTTF Recommendation 9.3 May 8, 2015 Page 2 On March 12, 2012, the NRC staff issued a letter entitled Request for Information Pursuant to Title 1O 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).

Enclosure 5 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.

In accordance with Reference 1, Enclosure 5, Exelon Generation Company, LLC (EGC) submitted an alternative course of action for performing the requested actions and providing the requested information (Reference 2). Enclosure 1 of Reference 2 described the alternative course of action and schedule for responding to the Emergency Preparedness - Staffing, Requested Information Items 1, 2, and 6. to this letter provides the Peach Bottom Atomic Power Station Phase 2 Staffing Assessment Report. The Peach Bottom Atomic Power Station Phase 2 Staffing Assessment Report follows the assessment process methodology described in NEI 12-01 (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, Staffing. 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 consideratio n 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/c ommunicatio n, radiological accident assessment, and support of operational accident assessment, as appropriate.

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

U.S. Nuclear Regulatory Commission Response to 50.54(f) Letter NTTF Recommendation 9.3 May 8, 2015 Page 3

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

Response

Enclosure 1 provides the Peach Bottom Atomic Power Station on-shift staffing assessment conducted pursuant to Reference 2. As described in Enclosure 1, Section 5, a detailed timeline and table-top review of the on-shift response to the postulated Beyond-Design-Basis External Event (BDBEE) Extended Loss of AC Power (ELAP) was performed based upon Operations review of the applicable station procedures. The focus of the timeline was to identify all resources, both operators and support organizations that would be required to execute each task for the Initial and Transition Phases using the FLEX mitigating strategies being implemented in accordance with NRC Order EA-12-049 (Reference 5).

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.

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

This Phase 2 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 assessment identified the need for four (4) additional personnel to support the movement of hoses, and debris removal. These personnel will be drawn from the available auxiliary site personnel. An analysis of the use of these auxiliary personnel in support of the Initial and Transition Phase actions is provided under a separate submittal (Reference 6). Tasks assigned to the auxiliary personnel will be performed under the direction of qualified Operations personnel, do not involve the configuration of plant equipment, and do not require task-specific training. The applicable program document will be revised to require that, should Security personnel be deployed to support any of the Auxiliary tasks, Security personnel would only be used when all other available staff had been deployed, and would be given first priority for return to normal duties as soon as a non-Security staff member becomes available.

The staffing assessment provided in Enclosure 1 determined that no new staff or functions have been identified as a result of the Phase 2 assessment. The analysis did not identify any non-validated tasks or potential overlap tasks that would require a Time Motion Study to be performed.

The staffing assessment provided in Enclosure 1 determined that the existing on-shift staff is sufficient to implement the FLEX mitigating strategies for the postulated BDBEE ELAP event, while supporting performance of the required Emergency Planning duties without unacceptable collateral duties.

U.S. Nuclear Regulatory Commission Response to 50.54(f) Letter NTTF Recommendation 9.3 May 8, 2015 Page4 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.

Response

The Phase 2 Staffing Assessment results for Peach Bottom Atomic Power Station require the establishment of procedural controls to activate the Expanded Response Capability for the BDBEE as defined for the Phase 2 Staffing Assessment. This staffing will be provided by the current site resources, supplemented by fleet resources, as necessary. Fleet procedural controls to activate the Expanded Response Capability have been implemented.

Response to Information Request in Reference 1, Enclosure 5, Staffing, 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 all 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 7, the existing on-shift staff is sufficient to implement the existing mitigating strategies while supporting performance of the required Emergency Planning duties without unacceptable collateral duties, provided that the staff is augmented with four (4) auxiliary personnel. No staffing changes are required.

Also as described in Enclosure 1, Section 7, the existing augmented ERO, supplemented by site staff, provides sufficient staffing to satisfy the Expanded Capability functions defined in NEI 12-01, Table 3.1. Exelon will address the expanded staffing requirements commencing at 6-hours post-event using available site resources augmented by resources from other Exelon sites and the corporate staff.

Exelon has incorporated 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 SAM strategies for more than 1 unit.

U.S. Nuclear Regulatory Commission Response to 50.54(f) Letter NTTF Recommendation 9.3 May 8, 2015 Page 5 These procedure changes have been implemented concurrent with the implementation of the mitigating strategies at the first affected Exelon site (Byron Station) in the Fall of 2014.

This action has been completed consistent with the FLEX implementation milestone schedule.

Exelon will be incorporating requirements for drills and exercises involving a BDBEE scenario in accordance with the guidance in NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events. The BDBEE requirements will be implemented in accordance with the implementation schedule for NEI 13-06.

This letter contains no new regulatory commitments.

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 81h day of May 2015.

Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Peach Bottom Atomic Power Station, Units 2 and 3 NEI 12-01 Phase 2 Staffing Assessment cc: Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I NRC Senior Resident Inspector -Peach Bottom Atomic Power Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station Mr. Peter J. Bamford, NRR/JLD/PPSD/JOMB, NRC Mr. Stephen S. Philpott, NRR/JLD/PPSD/JOMB, NRC Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

Enclosure 1 Peach Bottom Atomic Power Station, Units 2 and 3 NEI 12-01 Phase 2 Staffing Assessment Report (40 Pages)

Exelon Generation Enclosure 1 PEACH BOTTOM ATOMIC POWER STATION NEI 12-01 Phase 2 Staffing Assessment

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Table of Contents 1.0 Executive Summary .................................................................................................. 3 2.0 Background ............................................................................................................... 3 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 Expanded Response Capability ............................................................................... 20 6.1 On-Site Radiation Protection Technicians .. ....................... ... ...... .. ................... 25 6.2 Administrative Support Personnel ......................................... .......................... 25 6.3 Training for Expanded Capability .......................................... ........................ .. 26 6.4 Work Areas for Expanded Capability .............................................................. 26 7.0 Changes Required to Support Phase 2 Staffing Assessment.. ................................ 26 7 .1 Staffing Changes ................................................................ .. ............... ........... 26 7 .2 Expanded Capability Staffing .......................................................................... 26 7.3 Emergency Plan and Procedure Changes ...................................................... 27 8.0 Conclusion .................................................... .......................................... ................ 27 9.0 Attachments .......................................... ............. ..................................................... 28 10.0 References .............................................................................................................. 28 Attachment 1 .... ... ...................................................................................... .............. 30 May 2015 Page 2 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 1.0 EXECUTIVE

SUMMARY

This report provides the Phase 2 Staffing Assessment for Peach Bottom Atomic Power Station Units 2 and 3 in response to the March 12, 2012, Nuclear Regulatory lett~r. 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."

Specifically, this report provides Phase 2 information to address Staffing Request Numbers 1, 2, and 6 as committed in Exelon's 60-Day Response for Peach Bottom Atomic Power Station.

The Phase 2 Staffing Assessment was conducted using NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities; an approach endorsed by the NRC in a Letter from D. L. Skeen (NRR) to Susan Perkins-Grew (NEI) dated May 15, 2012. This report includes the results of the Phase 2 Staffing Assessment as described in NEI 12-01 . It also includes a discussion of any changes planned in response to the Phase 2 Staffing Assessment and the associated implementation schedule.

The Phase 2 Staffing Assessment concluded that the current minimum on-shift staffing as defined in EP-AA-1007, Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, is sufficient to support the implementation of the current mitigating strategies for a Beyond-Design-Basis External Event (BDBEE) on both Units 2 and 3, as well as the required Emergency Plan actions, with no unacceptable collateral duties, provided that the minimum staff is augmented with four additional auxiliary personnel on-site. The Phase 2 Staffing Assessment also identifies the staffing necessary to support the Expanded Response Capability for the BDBEE as defined in NEI 12-01, Section 3.4.

The Phase 2 Staffing Assessment was performed based upon the draft FLEX implementing procedures. The results of procedure validation will be reviewed and compared with the timeline as documented in this report. If the results of the validation alter staffing requirements or the conclusions of this report, an updated report will be submitted within 60 days of startup from P3R20 (Fall 2015), consistent with the Peach Bottom FLEX compliance submittal.

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 1O 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:

May 2015 Page 3 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 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.

The industry developed an alternative response based upon a phased approach to Recommendation 9.3. This approach was delineated in NEI 12-01 and was found acceptable by the NRC. In its letter to Susan Perkins-Grew, NEI, dated May 15, 2012, the US NRC stated, in part:

The staff has reviewed NEl-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's 60-Day Response to March 12, 2012 Request for Information Pursuant to Title 1O 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. In this letter, Exelon committed to the completion of a Phase 2 staffing assessment for Peach Bottom Atomic Power Station by December 6, 2014.

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:

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 NRG Near-Term Task Force (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.

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

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

May 2015 Page 4 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Request# Requested Information (Ref: Exelon 60- day Response to NRC Request for Information) 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:

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 NRG Near-Term Task Force (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.

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

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

18 Provide on-site and augmented staffing assessment considering all requested functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessmentl 28 Conduct the on-site and augmented staffing assessment:

The on-site and augmented staffing assessment considering all requested functions related to NTTF Recommendation 4.2. [Phase 2 staffing assessment]

20 A schedule of the time needed to implement changes will be provided as follows:

Those associated with the Phase 2 staffing assessment.

May 2015 Page 5 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 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 offsite resource providers (e.g., staffing, equipment, transportation, etc.)

6B Changes will be identified as follows:

Those associated with the Phase 2 Staffinq Assessment.

This report for Peach Bottom Atomic Power Station provides the NEI 12-01 Phase 2 Staffing Assessment, as requested by the §50.54(f) letter, conducted using the guidance in NEI 12-01 and material from NEI 10-05.

Phase 2 Staffing Assessment The industry is responding to multiple regulatory actions resulting from the recommendations contained in the Fukushima NTTF Report, as modified in related Commission Papers (SECY's) and Staff Requirements Memoranda (SRM). One of these actions, in particular, has the potential to impact emergency response staffing levels. This action is NRG Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events EA-12-049 [the Order] which addresses Fukushima NTTF Recommendation 4.2.

In accordance with the Order, each licensee must develop new strategies for mitigating the effects of BDBEEs. To ensure accurate results, the staffing assessment for response functions related to NTTF Recommendation 4.2 must be based on the actions delineated in the procedures and guidelines developed in response to the Order. Once the site-specific actions associated with the new response strategies are defined (e.g., down to the procedure or guideline step level),

the staffing needed to perform these actions can be assessed with the necessary level of accuracy. As requested, an implementation schedule for any modifications to emergency response staffing that are determined to be appropriate should be included with the Phase 2 staffing assessment.

This Peach Bottom Phase 2 Staffing Assessment Report provides the results of an assessment performed of the staffing necessary to implement actions that address the Order. The assessment was performed in conjunction with the development of procedures or guidelines that address the Order using the guidance provided in NEI 12-01.

May 201 5 Page 6 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 3.0 EMERGENCY PLAN MINIMUM STAFFING EP-AA-1007, Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, establishes the minimum on-shift staffing complement. The following table indicates the on-shift personnel necessary to perform the required emergency pIanrnng. f unctions.

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 (bl 3 Assessment of SSD Non Licensed Operator(bl 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 101 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 l&C Maintenance 1 Electrical Maintenance 1(a)

Radwaste Operator 1

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

Actions

7. Fire Fiqhtinq -- Fire Briqade(c) 5

8. First Aid and Rescue -- Plant Personnel 2\a)

Operations

9. Site Access Control Security and Security Team Personnel (d) and Personnel Accountability Accountability 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 UFSAR/Technical Specifications, as applicable (d) Function performed by on-shift security personnel (e) May be provided by RP Technician at Limerick Generating Station May 2015 Page 7 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 4.0 BEYOND DESIGN BASIS EXTERNAL EVENT CBDBEE) 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months - 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 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.

A staffing assessment may utilize a "no site access" end time of less than 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and greater than or equal to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , if supported by a documented 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 the assessment. These resources and capabilities could be provided by Company-internal, 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

May 2015 Page 8 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 4.1.2 NEI 12-01 Assumptions for Staffing Assessment For multi-unit plants, the Phase 1 staffing assessment performed in response to the Letter will be performed by March 29, 2013, and provided by April 30, 2013. This assessment will consider all requested functions except those related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2. An assessment considering these functions will be performed in Phase 2.

Each licensee should determine a date for completing the Phase 2 staffing assessment; the assessment will be provided no later than 4 months prior to beginning of second refueling outage (as used within the context of NRC Order EA-12-049). This assessment will consider the requested functions related to Fukushima Near-Term Task Force (NTTF) Recommendation 4.2.

The industry will be responding to multiple regulatory actions resulting from the recommendations contained in the Fukushima NTTF Report, as modified in related Commission Papers (SECY's) and Staff Requirements Memoranda (SRM). One of these actions, in particular, has the potential to impact emergency response staffing levels. This action is NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events EA-12-049 [the Order] which addresses Fukushima NTTF Recommendation 4.2. A summary of the Order is provided below.

This Order requires a three-phase approach for mitigating BDBEEs. 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.

In accordance with the Order, each licensee must develop new strategies for mitigating the effects of BDBEEs. To ensure accurate results, the staffing assessment for response functions related to NTTF Recommendation 4.2 must be based on the actions delineated in the procedures and guidelines developed in response to the Order. Once the site-specific actions associated with the new response strategies are defined (e.g., down to the procedure or guideline step level), the staffing needed to perform these actions can be assessed with the necessary level of accuracy.

Based on a review of the planned actions necessary to comply with the Order, an assessment of the staffing for the functions related to NTTF Recommendation 4.2 can be provided by 4 months prior to beginning of the second refueling outage (as used within the context of NRC Order EA-12-049).

Licensees of single-unit sites should adhere to this submittal milestone.

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 4 months prior to the first occurrence of a May 2015 Page 9 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 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 4 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 sites that will employ different mitigation strategies for on-site units.

As requested, an implementation schedule for any modifications that are determined to be appropriate should be included with the Phase 2 staffing assessment.

The Phase 2 staffing assessment is one component of an overall licensee work plan to support implementation of the requirements of the Order. As stated in the Order, all holders of operating licenses issued under Part 50 shall complete full implementation no later than two (2) refueling cycles after submittal of the overall integrated plan, as required in Condition C.1.a, or December 31, 2016, whichever comes first. Full compliance shall include procedures, guidance, training, and acquisition, staging, or installing of equipment needed for the strategies.

4.1.3 Additional Assumptions for Minimum Staffing On-shift personnel are limited to the minimum complement allowed by the site regulatory requirements (e.g., Emergency Plan and Security Plan) and commitments. This would typically be the on-shift complement present during a backshift, weekend, or holiday.

4.1.4 Additional Guidance for Staffing Assessment Per NEI 12-01, Section 3.1, 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.

4.1.5 NEI 10-05 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 May 2015 Page 10 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment (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. Individuals holding the position of radiation protection or chemistry technician are qualified to perform the range of tasks expected of their position.

5. 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.

6. 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 offsite authorities.

7. The analyzed event occurs during off-normal work hours at a time when augmented Emergency Response Organization (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 turnover of the function/responsibility. Specifically, any time needed by the augmenting ERO to acquire materials or prepare for turnover 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 offsite notifications during a OBA 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.

May 2015 Page 11 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 4.2 Scope/Sequence of Events 4.2.1 Beyond Design Basis External Event CBDBEE): 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).

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 MS1, with a subsequent escalation to a General Emergency based on EAL MG1.

4.2.2 On-shift Response Peach Bottom has a common Control Room for the operation of Units 2 and 3 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 (STA/IA), 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 STA/IA provides independent safety function status assessment (for both units during a dual unit event). The SM provides oversight and is also the 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 portable radio or other available communications.

For the Phase 2 Staffing Assessment, on-shift personnel respond to the initiating events in accordance with plant procedures.

May 2015 Page 12 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment The following procedures and documents support the event response:

EP-AA-112-1 OO-F-01, Shift Emergency Director Checklist

T-100, SCRAM

T-101, RPV Control

T-102, Secondary Containment Control

T-261, Placing the Backup Instrument Nitrogen Supply from CAD Tank in Service

SE-11, Loss of Offsite Power

SE-11, Attachment B, Responding to a Diesel Generator Trip or Failure to Start

SE-11, Attachment T, DC Load Shed

SE-11, Attachment U, Opening Secondary Containment Doors to Support Long-term HPCl/RCIC Operation

FSG-001, FLEX Equipment Deployment Location Assessment

FSG-002, Debris Removal

FSG-004, FLEX F-750 Truck Operations

FSG-010, Aligning FLEX Generator to Panel 3AS1061

FSG-011, Aligning FLEX Generator to Panel 3BS1061

FSG-012, ELAP DC Load Shed

FSG-013, ELAP AC Load Shed

FSG-014, Energizing AC Loads from FLEX Generator

FSG-020, Deploying Alternate Radio Communications Antenna

FSG-030, Establishing Control Room Ventilation and Lighting

FSG-031, Establishing Battery Room Ventilation and Lighting

FSG-032, Establishing HPCl/RCIC/Sump Room Ventilation, Lighting and Water Removal

FSG-033, Establishing Refuel Floor Ventilation

FSG-040, Aligning the FLEX Pump from the ECT to RHR

FSG-041, Aligning the FLEX Pump from the Pump Bay to HPSW

FSG-042, RPV, Torus and Fuel Pool Make-up Using the FLEX Pump

FSG-043, Defeating RCIC Interlocks

FSG-044, Bypassing Backup Instrument Nitrogen SV-9130A and SV-9130B 5.0 On-Shift Staffing Task Analysis Results Peach Bottom 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 FLEX mitigating strategies. Resources needed to perform initial event response actions were identified from the Emergency Operating Procedures (EOPs), Abnormal Operating Procedures (AOPs), FLEX Support Guidelines (FSGs), or other supporting procedures. This assessment was extended to include the establishment of injection prior to T = 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to provide additional assurance that all required transition phase actions initiated during the initial 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months period can be completed within the times specified in the Peach Bottom Overall Integrated Plan (Reference 10.14).

Per NEI 12-01, Peach Bottom performed an assessment of the ability to execute the required EP functions using the methodology specified in NEI 10-05. Per NEI 10-05, May 2015 Page 13 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 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 documented in Attachment 1, 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 Phase 2 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 assessment identified the need for 4 additional personnel to support debris removal and the movement of hoses. These personnel will be drawn from the available auxiliary site personnel. An analysis of the use of these auxiliary personnel in support of the Initial and Transition Phase actions is provided under a separate submittal. Tasks assigned to the auxiliary personnel will be performed under the direction of qualified Operations personnel, do not involve the manipulation of plant equipment, and do not require task-specific training. The applicable program document will be revised to require that, should Security personnel be deployed to support any of the Auxiliary tasks, Security personnel would only be used when all other available staff had been deployed, and would be given first priority for return to normal duties as soon as a non-Security staff member becomes available.

The Operating tasks were assigned as shown in Table 5.1. None of these operating tasks require the use of the Shift Manager I Shift Emergency Director, STA, or the dedicated shift communicator. As such, no unacceptable collateral duties were identified. Refer to Attachment 1, NEI 10-05 Staffing Tables for Peach Bottom, for documentation of the on-shift staffing analysis results. The analysis did not identify any non-validated tasks or potential overlap tasks that would require a Time Motion Study to be performed.

May 2015 Page 14 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Table 5.1: Peach Bottom Staffing Timeline Time (Mins.) 0-15 15-30 30-45 45-60 60-75 75-90 90-105 105-120 Position Shift Manager Emergency Director - Emergency Director - Escalate from EAL MSl to General Emergency Director - Declare ELAP; Invoke 50.54(x) to support use of Security personnel, as required Declare EAL MSl Emers:~encv MGl UnitSupv Direct TRIPs I SE-11 Direct TRIPs I SE-11 I FSGs STA Independent assessment Shift Communicator State I Local Notification Perform State I Local follow-up notifications as required /Unit assist field communications (as available)

NRC Communicator NRC Notification I Maintain open line with NRC PRO Unit assist field communications U2RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 Maintain Level I Pressure I Containment control per TRIPs I SE-11 I FSGs U3RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 Maintain Level I Pressure I Containment control per TRIPs I SE-11 I FSGs R2 I T2 FBL (EO) EDG start attempt per SE-11 Att B Connect N2 for ADS per FSG-044 Strip AC loads per FSG-013 R3/T3/FB#1 (EO) EDG start attempt per SE-11 Att B FLEX building Debris removal per FSG-002 (F750 driver)

RW (EO) I Open U2 and U3 RCIC I HPCI doors per SE-11 Deploy antenna per FSG-020 Open doors I Hatches per FSG-033 Debris removal per FSG-002 Att U SSD #1 (EO or SRO) DC load shed SE-11 Att T DC Deep load shed per FSG-012 Debris removal per FSG-002 (F750 driver)

SSD #2 (EO or SRO) I Vent Generator per SE-11 Att S FLEX Building Debris removal per FSG-002 (F750 driver)

SSD #3 ( EO, SRO, or RO) Site assessment per FSG-001 FLEX Building Debris removal per FSG-002 (F750 driver)

FB#2 (EO) Backup N2 perT-261 Connect N2 for ADS per FSG-044 Strip AC loads per FSG-013 FB#3 Distribute keys I lights FLEX building Debris removal per FSG-002 FB#4 Vent Generator per SE-11 Att S FLEX building Debris removal per FSG-002 Install RCIC jumpers per Debris removal per FSG-002 I&C Tech#l FSG-043 Install RCIC jumpers per Debris removal per FSG-002 l&C Tech#2 FSG-043 Chemistry FLEX building Work trailer I F750 assist RP Tech#l I Open U2 and U3 RCIC I HPCI doors per SE-11 Open doors I hatches per FSG-033 Att U Backup N2 perT-261 FLEX building Debris removal per FSG-002 RP Tech#2 FLEX building Debris removal per FSG-002 Auxiliary 1 FLEX building Debris removal per FSG-002 Auxiliary 2 FLEX building Debris removal per FSG-002 Auxiliary 3 FLEX building Debris removal per FSG-002 Auxiliary 4 May 2015 Page 15 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Time (Mins.) 120-135 135-150 150-165 165-180 180-195 195-210 210-225 225-240 Position Shift Manager Emergency Director UnitSupv Direct TRIPs I SE-11 I FSGs STA Independent Assessment Shift Communicator Perform State I Local follow-up notifications as required /Unit assist field communications (as available)

NRC Communicator NRC Notification I Maintain open line with NRC PRO Unit assist field communications U2RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 I FSGs U3RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 I FSGs R2 I T2 FBL (EO) RCIC Vent per FSG-032 RCIC Vent per FSG-032 R3/T3/FB#l (EO) Debris removal per FSG-002 Transport cable then diesels and lay cable per FSG-010/011 RW(EO) Debris removal per FSG-002 Transport cable then diesels and lay cable per FSG-010/011 SSD #1 (EO or SRO) Debris removal per FSG-002 (F750 driver) Transport work trailer SSD #2 (EO or SRO) Debris removal per FSG-002 (F750 driver) Transport cable then diesels and lay cable per FSG-0101011 SSD #3 ( EO, SRO, or RO) Debris removal per FSG-002 (F750 driver) Transport cable then diesels and lay cable per FSG-010 /011 FB#2 (EO) RCIC Vent per FSG-032 Transport cable then diesels and lay cable per FSG-0 I 0 1011 FB#3 Debris removal per FSG-002 Transport cable then diesels and lay cable per FSG-010 /011 FB#4 Debris removal per FSG-002 Transport cable then diesels and lay cable per FSG-0 l 0 1011 Debris removal per FSG-002 Transport cable then diesels and lay cable per FSG-0l01011 I&C Tech#l Debris removal per FSG-002 Transport cable then diesels and lay cable per FSG-010 1011 I&C Tech#2 Chemistry Work trailer I F750 assist RCIC Vent per FSG-032 RCIC Vent per FSG-032 RPTech#l Debris removal per FSG-002 Transport cable then diesels and lay cable per FSG-010 /011 RP Tech #2 Debris removal per FSG-002 Auxiliary 1 Debris removal per FSG-002 Auxiliary 2 Debris removal per FSG-002 Auxiliary 3 Debris removal per FSG-002 Auxiliary 4 May 2015 Page 16 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Time (Mins.) 240-255 255-270 270-285 285-300 300-315 315-330 330-345 345-360 Position Shift Manager Emergency Director UnitSupv Direct TRIPs I SE-11 I FSGs STA Independent Assessment Shift Communicator Perform State I Local follow-up notifications as required /Unit assist field communications (as available)

NRC Communicator NRC Notification I Maintain open line with NRC PRO Unit assist field communications U2RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 I FSGs U3RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 I FSGs R2 / T2 FBL (EO) Battery room vent per FSG-031 Control room vent per FSG-030 Prep pump per FSG-042 R3/T3/FB#l (EO) Plug in diesels per FSG- Start diesels per FSG-014 SFP hoses per FSG-042 010 /011 RW(EO) Plug in diesels per FSG- Start diesels per FSG-014 Connect hose per FSG-040/041 010 /011 SSD #1 (EO or SRO) Transport cable then diesels and lay cable per FSG-010 /011 Energize AC loads Transport hose and pump per FSG-040 /041 (Tractor) Prep pump per FSG-042 per FSG-014 SSD #2 (EO or SRO) Transport cable then diesels and lay cable per FSG-0 I 0 1011 Energize AC loads Transport hose and pump per FSG-040 /041 (Tractor) per FSG-014 SSD #3 ( EO, SRO, or RO) Transport work trailer Transport hose then pumps per FSG-040/041 Connect hose per FSG-040/041 Commence refueling activities perFSG-050 FB#2 (EO) Transport cable then Transport hose then pumps per FSG-040/041 SFP hoses per FSG-042 diesels and lay cable per FSG-010 /011 FB#3 Transport cable then Transport hose then pumps per FSG-040/041 Monitor diesel diesels and lay cable per FSG-0101011 FB#4 Transport cable then Transport hose then pumps per FSG-040/041 Monitor diesel diesels and lay cable per FSG-010 /011 Transport cable then Transport hose then pumps per FSG-040/041 Connect hose per FSG-040/041 I&C Tech#l diesels and lay cable per FSG-010 /011 Plug in diesels per FSG- Transport hose then pumps per FSG-040/041 Connect hose per FSG-040/041 I&C Tech#2 010 /011 Chemistry Work trailer I F750 assist Battery room vent per FSG-03 1 Control room vent per FSG-030 Monitor dose RP Tech #1 Plug in diesels per FSG- Transport hose then pumps per FSG-040/041 Connect hose per FSG-040/041 RPTech#2 010 /011 Debris removal per FSG- Assist hose deployment per FSG-040/041 Auxiliary 1 002 Debris removal per FSG- Assist hose deployment per FSG-040/041 Auxiliary 2 002 Debris removal per FSG- Assist hose deployment per FSG-040/04 1 Auxiliary 3 002 Debris removal per FSG- Assist hose deployment per FSG-040/041 Auxiliary 4 002 May 2015 Page 17 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Time (Mins.) 360- 375 375 - 390 390-405 405 -420 Position Shift Manager Emergency Director UnitSupv Direct TRIPs I SE-11 I FSGs STA Independent Assessment Shift Communicator Perform State I Local follow-up notifications as required /Unit assist field communications (as available)

NRC Communicator NRC Notification I Maintain open line with NRC PRO Unit assist field communications U2RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 / FSGs U3RO Maintain Level I Pressure I Containment control per TRIPs I SE-11 I FSGs R2 I T2 FBL (EO) Prep pump per FSG-042 Start I run pump per Monitor pump FSG-042 R3/T3/FB#l (EO) SFP hoses per FSG-042 Establish injection per FSG-042 RW(EO) Connect hose per FSG-040/041 Establish injection per FSG-042 SSD #1 (EO or SRO) Prep pump per FSG-042 Start I run pump per Monitor pump FSG-042 SSD #2 (EO or SRO) Transport hose and pump per FSG-040 /041 Establish injection per FSG-042 SSD #3 ( EO, SRO, or RO) Commence refueling activities per FSG-050 FB#2 (EO) SFP hoses per FSG-042 Establish injection per FSG-042 FB#3 Monitor diesel FB#4 Monitor diesel Connect hose per FSG-040/041 Establish injection per FSG-I&C Tech#l 042 Connect hose per FSG-040/041 Establish injection per FSG-I&C Tech#2 042 Chemistry Work trailer I F750 assist Monitor dose RPTech#l Connect hose per FSG-040/041 Establish injection per FSG-RPTech#2 042 Auxiliary 1 Auxiliary 2 Auxiliary 3 Auxiliary 4 May 2015 Page 18 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Notes:

Gray highlight indicates unassigned time period

Shift Emergency Communicator (SEC) will make all required follow-up notifications.

The SEC will assist with communications to in-plant personnel when not performing required notifications.

Security will support access points for FLEX equipment in accordance with the Security Plan May 2015 Page 19 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 6.0 EXPANDED RESPONSE CAPABILITY A typical augmented ERO for a multi-unit site would be challenged to effectively respond to a BDBEE 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 Peach Bottom 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, Tables 3.1 and 3.2, list the emergency response functions identified by the NEI Beyond Design Basis Event Response Staffing Study Task Force as meeting these requirements. These tables provide key roles and staffing considerations for each expanded response function and specify the staffing necessary to support the simultaneous deployment of emergency repair and corrective action teams to each affected unit.

Table 6.1 of this report describes the recommended expanded response capability staffing for Peach Bottom, based upon the NEI 12-01 guidance for the phase 2 staffing assessment.

May 2015 Page 20 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Table 6.1 Expanded Response Functions for Peach Bottom Phase 2 Staffing Assessment Expanded Typical I Key Roles and Staffing Considerations I Required Function Response Location Staffing Fulfilled By Function Unit Response TSC

Overall cognizance of the activities related to implementation of 2 Station ED -

Coordination repair and corrective actions, and implementation of Transition Normal ERO Phase coping and Severe Accident Management (SAM) Response strategies for an assigned unit (Required

One individual per unit; individuals should not be assigned other staffing* + 1) functions Operations TSC

Provides coordination of Operations staff and support for an 2 Operations Coordination assigned unit Manager -

One individual per unit; individuals should not be assigned other Normal ERO functions Response (Required staffing* + 1)

Maintenance TSCor

Provides coordination of Maintenance staff and support for an 2 Maintenance Coordination osc assigned unit Manager -

One individual per unit; individuals should not be assigned other Normal ERO functions Response (Required staffing* + 1)

Engineering TSCor

Provides coordination of Engineering staff and support for an 2 Technical Coordination osc assigned unit Manager -

One individual per unit; individuals should not be assigned other Normal ERO functions Response (Required staffinQ* + 1)

Engineering TSC or

One team for each unit to perform engineering assessments in 6 Core Th/Hyd Assessments osc support of repair and corrective actions Eng

Team composition (i.e., number and represented disciplines) as Mech Eng described in the emergency plan Elect Eng

Team may include personnel responsible for performing other Normal ERO May 2015 Page 21of40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Expanded Typical Key Roles and Staffing Considerations Required Function Response Location Staffing Fulfilled By Function functions for the same assigned unit Response (Required staffing* + 1)

Evaluation of Severe TSCor

One team for each unit to evaluate selection of SAM strategies; (4) Technical Accident osc team performs evaluations not done by Control Room personnel Duty Manager I Management (SAM)

Team composition (i.e., number and represented disciplines) as concurrent Operations Strategies described in governing site programs, procedures and with Manager guidelines Technical

Team may include personnel responsible for performing other Manager functions for the same assigned unit and /or Operations Manager Unit In-Plant Team osc

Overall cognizance of on-site and in-plant teams performing or 2 OSC Director Coordination supporting repair and corrective actions for an assigned unit Asst OSC

One individual per unit; individuals should not be assigned other Director functions Normal ERO

Response

(Required staffinQ + 1)

Non-Licensed osc

Two individuals per unit to implement repair and corrective 4 Site NLOs Operators actions and/or

Should not include members of the on-shift staff regional NLO resources Mechanical osc

Two individuals per unit to implement repair and corrective 4 Site Maintenance Repair actions Technicians and Corrective Action

Staffing may include an on-shift individual (i.e., 2 individuals for and/or a unit composed of 1 on-shift and 1 augmented) regional resources Electrical osc

Two individuals per unit to implement repair and corrective 4 Site May 2015 Page 22 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Expanded Typical Key Roles and Staffing Considerations Required Function Response Location Staffing Fulfilled By Function Maintenance Repair actions Technicians and Corrective Action

Staffing may include an on-shift individual (i.e., 2 individuals for and/or a unit composed of 1 on-shift and 1 augmented) regional resources l&C Repair and osc

Two individuals per unit to implement repair and corrective 4 l&C Tech #1 Corrective Action actions and Site

Staffing may include an on-shift individual (i.e., 2 individuals for Technicians a unit composed of 1 on-shift and 1 augmented) and/or regional resources Implementation of osc

Number and composition of personnel capable of simultaneous 2 ROs, 2 ROs and 4 SAM Strategies implementation of any 2 SAM strategies at each unit (See Note 4 EOs, EOs, 2 l&C 1 below) 4 l&C Techs Techs from

Should not include personnel assigned to other functions (e.g., on-shift crew; emergency repair and corrective actions); however, may include 2 l&C Techs members of the on-shift staff and personnel responsible for from Site staff implementation of Transition Phase coping strategies and/or regional resources Evaluation of TSCor

One team for each unit to evaluate selection of Transition (4) Technical Transition Phase EOF Coping strategies; team performs evaluations not done by Duty Manager I Coping Strategies Control Room personnel concurrent Operations

Team composition (i.e., number and represented disciplines) as with Manager I described in governing site programs, procedures and Technical Core Thermal guidelines Manager I Engineer

Team may include personnel responsible for performing other Operations functions for the same assigned unit Manager I Core Thermal Engineer NOTE: Site FLEX May 2015 Page 23 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Expanded Typical Key Roles and Staffing Considerations Required Function Response Location Staffing Fulfilled By Function strategy structure does not include an evaluator function Implementation of osc

Number and composition of personnel capable of simultaneous 10 NLOs/ 9 6 NLOs from Transition Phase implementation of any 2 Transition Phase coping strategies at non- on-shift crew, Coping Strategies each unit (see Note 2 below) discipline supplemented

Should not include personnel assigned to other functions (e.g., specific with 4 NLOs emergency repair and corrective actions); however, may include labor and 9 members of the on-shift staff and personnel responsible for additional implementation of SAM strategies personnel from site staff and/or regional resources

-The required staffing for each position is specified in EP-AA-1007, Radiological Emergency Plan Annex for Peach Bottom Station. Normal augmentation is the required staffing plus one additional qualified individual.

Notes:

1 The SAM strategies selected for Peach Bottom were T-261, Placing the Backup Instrument Nitrogen Supply from CAD Tank In Service, and T-202-2(3), Primary Containment Nitrogen Injection for Combustible Gas Control.

2 The transition phase coping strategies selected for Peach Bottom were FSG-010/011, Aligning FLEX Generator to Panel 3A(B)S1061 and FSG-42, RPV, Torus and Fuel Pool Make-up Using the FLEX Pump.

May 2015 Page 24 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 6.1 On-Site Radiation Protection Technicians Following a beyond design basis external event, on-site Radiation Protection (RP)

Technicians should be 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 Peach Bottom 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 Peach Bottom, the complement of RP Technicians specified in the augmented ERO per EP-AA-1007 is 8. 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.

6.2 Administrative Support Personnel Administrative support personnel positions are not required for the Peach Bottom 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.

May 2015 Page 25 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 6.3 Training for Expanded Capability No new ERO tasks or functions are required for implementing the expanded response capability. There are a sufficient number of qualified ERO personnel to implement the expanded response; qualification of additional personnel will not be required.

6.4 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.

7.0 CHANGES REQUIRED TO SUPPORT PHASE 2 STAFFING ASSESSMENT 7.1 Staffing Changes This Phase 2 Staffing Assessment concluded that the existing on-shift staff is sufficient to implement the existing mitigating strategies on both units, simultaneously, while supporting performance of the required Emergency Planning duties without unacceptable collateral duties, provided that the staff is augmented with 4 auxiliary personnel. No staffing changes are required.

7.2 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. Due to the initiating event, personnel close to the plant (nominally, within a 25 mile radius of the site), may not be able to respond. Exelon has multiple resources available to address the impact of such conditions. These include site personnel residing outside the 25 mile radius, as well as personnel resources from other Exelon sites and the Corporate organization. It is standard practice for Exelon sites to share Operator, Maintenance, RP, and technical staff during outages. This has provided organizational flexibility that would support additional staffing in response to a BDBEE. Similarly, the Corporate organization maintains technical expertise in the Engineering, Maintenance, RP, and Chemistry disciplines that are shared during outages and emergent plant issues. Based upon the available pool of resources outside of the site organization with the requisite skill set, Exelon will address the expanded staffing requirements commencing at 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months post-event using available site resources augmented by resources from other Exelon sites and the Corporate staff.

May 2015 Page 26 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 7.3 Emergency Plan and Procedure Changes Per NEI 12-01, Section 3.1 O, the capability for responding to a BDBEE 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 has incorporated 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 SAM strategies for more than 1 unit.

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-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.

Exelon will be incorporating requirements for drills and exercises involving a BDBEE scenario in accordance with the guidance in NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events.

8.0 CONCLUSION

This Phase 2 Staffing Assessment concluded that the current minimum on-shift staffing as defined in EP-AA-1007, Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, as augmented by site auxiliary personnel, is sufficient to support the implementation of the current mitigating strategies for a BDBEE on Units 2 and 3, as well as the required Emergency Plan actions, with no unacceptable collateral duties.

The Phase 2 Staffing Assessment also identified the staffing necessary to support the Expanded Response Capability for the BOB EE as defined for the Phase 2 staffing assessment. This staffing will be provided by the current site resources, supplemented by fleet resources, as necessary.

May 2015 Page 27 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 9.0 ATTACHMENTS 9.1 Attachment 1, NEI 10-05 Staffing Tables for Peach Bottom Atomic Power Station.

10.0 REFERENCES

10.1 NEI 12-01, Rev 0, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities" 10.2 NEI 10-05, Rev 0, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities" 10.3 NEI 13-06, Enhancements to Emergency Response Capabilities for Beyond Design Basis Accidents and Events 10.4 EP-AA-1000, Exelon Nuclear Standardized Radiological Emergency Plan, Rev. 21 10.5 EP-AA-1007, Exelon Nuclear Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station 10.6 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.

10.7 Exelon Generation Company, LLC Letter to NRC, "60-Day Response to March 12, 2012 Request for Information Pursuant to Title 1O 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).

10.8 EA-12-049, NRC Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 10.9 HU-AA-1081-F-15, Emergency Response Organization Fundamentals 10.1 O EP-AA-1007, Addendum 1, Peach Bottom Atomic Power Station On-shift Staffing Technical Basis 10.11 Exelon Generation Company, LLC Letter to NRC, "Exelon Generation Company, LLC's (EGC) 90-Day Response to March 12, 2012 Request for Information Pursuant to Title 1O 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-lchi Accident; dated March 12, 2012 (Emergency Preparedness)," dated June 11, 2012.

10.12 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 O, dated May 15, 2012.

May 2015 Page 28 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 10.13 Exelon Generation Company, LLC Letter to NRC, "Response to March 12, 2012, Request for Information Pursuant to Title 1O 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," dated April 30, 2013.

10.14 Exelon Generation Company, LLC Letter to NRC, "Response to March 12, 2012, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013.

10.15 EP-AA-1007, Addendum 3, Emergency Action Levels for Peach Bottom Atomic Power Station May 2015 Page 29 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 NEI 10-05 Staffing Tables For Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment May 2015 Page 30 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 NEI 12-01 Phase 2 On-shift Staffing Assessment (OSA)

1. Accident Summary:

A Beyond Design Basis External Event results in a loss of all offsite AC power coincident with the trip of both units. All station emergency diesel generators fail to start.

2. Procedures Reviewed for Accident Response Include:

Refer to Section 4.2.2 of the report for the list of procedures used in this assessment.

May 2015 Page 31 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 Peach Bottom This OSA is applicable to Analysis NEI 12-01 Phase 2.

TABLE 1 - On-shift Positions Augment at ion Role in Lin Emergency Plan Elapsed On-shift Position Table#/Line e Reference Time (min)

Note2 Shift Manager I Shift ED EP-AA-1007, Table 2-1 NIA T21L 1 T51L 1 T5IL2 T5IL3 1.

T51L4 T5IL5 T5IL8 T51L 10 2.

U2 Control Room Supv EP-AA-1007, Table 2-1 NIA T21L2 (SRO) .

3. STA EP-AA-1007, Table 2-1 NIA T2IL3

4. U2 Reactor Operator (RO #1) EP-AA-1007, Table 2-1 NIA T21L4

5. U3 Reactor Operator (RO #2) EP-AA-1007, Table 2-1 NIA T2IL5 Plant Reactor Operator EP-AA-1007, Table 2-1 NIA T2IL6 6.

(PRO) (RO #3)

SSD #1 (EO or SRO)

7. EP-AA-1007, Table 2-1 NIA T2/L7 SSD #2 (EO or SRO) EP-AA-1007, Table 2-1

8. NIA T2/L8 SSD #3 ( EO, SRO, or RO)

9. EP-AA-1007, Table 2-1 NIA T2/L9 Fire Brigade Leader (R2/T2 EP-AA-1007, Table 2-1 NIA T2/L 10 10.

EO)

11. Fire Brigade #1 (R3/T3 EO) EP-AA-1007, Table 2-1 NIA T21L 11

12. Fire Brigade # 2(EO) EP-AA-1007, Table 2-1 NIA T21L12

13. Fire Brigade #3 EP-AA-1007, Table 2-1 NIA T21L 17

14. Fire Brigade #4 EP-AA-1007, Table 2-1 NIA T21L 18

15. NRG Communicator EP-AA-1007, Table 2-1 NIA T5IL 13 May 2015 Page 32 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Augment ation Role in Lin Emergency Plan Elapsed On-shift Position Table#/Line e Reference Time (min)

Note2 Note 1 Shift Communicator EP-AA-1007, Table 2-1 N/A T5/L6 16.

Note 1 T5/L9

17. Radwaste Operator (EO) EP-AA-1007, Table 2-1 N/A T2/L 15

18. Rad Pro Tech #1 EP-AA-1007, Table 2-1 N/A T4/L1

19. Rad Pro Tech #2 EP-AA-1007, Table 2-1 N/A -

20. Rad Pro Tech #3 (Limerick) EP-AA-1007, Table 2-1 N/A --

21. Chem Tech EP-AA-1007, Table 2-1 N/A -

22. l&C Tech #1 EP-AA-1007, Table 2-1 N/A -

23. l&C Tech #2 EP-AA-1007, Table 2-1 N/A -

Security EP-AA-1007, Table 2-1 N/A T5/L 15 (Function performed by 24.

on-shift security personnel)

Notes:

1. The Shift EP Communicator can be filled by any available qualified individual who is not assigned STA, Fire Brigade, SSD or Shift Emergency Director.

2. Augmentation Elapsed Time - Per the site access assumptions in NEI 12-01, augmentation will begin at T =6 hours. This assessment is based upon the ability to execute the required functions for the initial 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months following the initiating event.

Attachment 1 Peach Bottom May 2015 Page 33 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment TABLE 2- Plant Operations & Safe Shutdown Analysis NEI 12-01 Phase 2 Two Units - One Control Room Applicable to site unit(s) # 2 & 3 Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Line Generic Title/Role Task Performance On-Shift Position Validation Shift Manager Shift Manager Ops Training Program 1

Unit Supervisor U2 Control Room Supv Ops Training Program 2

(SRO) 3 Shift Technical Advisor STA (SRO) Ops Training Program Reactor Operator #1 U2 Reactor Operator Ops Training Program 4

(RO #1)

Reactor Operator #2 U3 Reactor Operator Ops Training Program 5

(RO #2)

Reactor Operator #3 Plant Reactor Operator Ops Training Program 6

(PRO) (RO #3)

Auxiliary Operator #1 SSD #1 (EO or SRO) Ops Training Program 7

Auxiliary Operator #2 SSD #2 (EO or SRO) Ops Training Program 8

9 Auxiliary Operator #3 SSD #3 ( EO, SRO, or RO) Ops Training Program Auxiliary Operator #4 Fire Brigade Leader (R2!T2 Ops Training Program 10 EO) 11 Auxiliary Operator #5 Ops Training Program Fire Brigade (R3!T3 EO) 12 Auxiliary Operator #6 Fire Brigade (EO) Ops Training Program Auxiliary Operator #1 O Radwaste Operator Ops Training Program 13 (EO #10)

Other (non-Operations) Personnel Necessary to Implement AOPs and EOPs, or SAMGs if r bl e app11ca Line Task Performance Generic Title/Role On-Shift Position Validation 14 Mechanic n/a n/a May 2015 Page 34 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment 15 Electrician n/a n/a 16 l&C Technician n/a n/a 17 Other Fire Brigade #3 Operations Training 18 Other Fire Brigade #4 Operations Training May2015 Page 35 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 Peach Bottom TABLE 3 - Firefighting Analysis NEI 12-01 Phase 2 Line Performed By Task Performance Validation 1 n/a n/a 2 n/a n/a 3 n/a n/a 4 n/a n/a 5 n/a n/a Notes:

1. Fire Brigade not utilized for this scenario.

May 2015 Page 36 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 Peach Bottom TABLE 4 - Radiation Protection & Chemistry Analysis NEI 12-01 Phase 2 Performance Time Period After Emergencv Declaration (minutes)

Position Performing Line 0- 5 15 25 35 45 55 65 75- 80 Function/Task 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 On-Site Survey 2 On-Shift Position: x x x x x x x x x x x x Procedure support Personnel Monitoring 3

On-Shift Position:

Job Coverage 4 On-Shift Position: RP#2 x x x x x x See Notes Offsite Radiological Assessment 5

On-Shift Position: x x x x x x x x x x x x Procedure Support Other Site-Specific RP 6 Describe:

On-Shift Position:

Chemistry function/task

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

2 - Describe: Procedure 8

On-Shift Position:Support x x x x x x May 2015 Page 37 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 Peach Bottom TABLE 4 - Radiation Protection & Chemistry Cont'd Analysis NEI 12-01 Phase 2 Performance Time Period After Emergency Declaration (minutes)

Position Performing Line Function!Task 90-120 120- 150- 180- 210- 240- 270- 300- 330- 360-150 180 210 240 270 300 330 360 390 In-Plant Survey 1 On-Shift Position: RP#1 On-Site Survey 2 On-Shift Position: x x x x x x x x Procedure support Personnel Monitoring 3 On-Shift Position: x x Job Coverage 4 On-Shift Position: RP#2 See Notes Offsite Radiological 5 Assessment On-Shift Position:

Other Site-Specific RP -

6 Describe:

On-Shift Position:

x x x x x x x x x x Procedure Support Chemistry function/task #1 7 - Describe: See Notes On-Shift Position: Ch Tech Chemistry function/task #2 8 - Describe: Procedure x x x x x x x x x x On-Shift Position:Suooort May 2015 Page 38 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 Peach Bottom TABLE 4 - Radiation Protection & Chemistry Analysis NEI 12-01 Phase 2 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 1.1O - An RP tech is assigned to the MCR to support emergency response. This RP Tech will support Operations activities as necessary and as prioritized by the Shift Emergency Director. However, there are no specific actions for RP identified under this procedure step.

RP#2 o RP-PB-300-1004, Use of RP Response Cards directs RP Tech to survey Scram Discharge Volume and other plant areas. There is no time requirement for this action.

Chemistry - no immediate actions.

May2015 Page 39 of 40 NEI 12-01 Phase 2 Report

Peach Bottom Atomic Power Station NEI 12-01 Phase 2 Staffing Assessment Attachment 1 Peach Bottom TABLE 5 - Emergency Plan Implementation Analysis NEI 12-01 Phase 2 Line Function!Task On-Shift Position Task Performance 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 DST event Complete State/local Shift Manager Ops Training Program 8 notification form l

Perform State/local notifications Shift EP Communicator Ops Training Program/

9 EP Drills and Exercises Complete N RC event Shift Manager Ops Training Program 10 notification form Activate EROS n/a n/a 11 Offsite radiological n/a n/a 12 assessment**

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 and Exercises 15 Other: Specify n/a n/a 16

Shift Manager non-delegable duty

- Offsite radiological assessment for Peach Bottom is performed by an on-shift RP Technician at Limerick Generating Station May 2015 Page 40 of 40 NEI 12-01 Phase 2 Report

v t e Letter Sequence Request
TAC:MF6271, (Open)
Initiation Request Acceptance... Supplement Administration Questions Answers Results Approval... Other: ML15268A424
MONTHYEAR2015-08-28 [Table View]

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