• -=:=·Entergy 

Entergy Nuclear Operations, Inc • 

Palisades Nuclear Plant 

27780 Blue Star Memorial Highway 

Covert, MI 49043-9530 

Tel 269 764 2000 

PNP 2015-036 

May 19, 2015 

Anthony J. Vitale 

Site Vice President 

U. S. Nuclear Regulatory Commission 

A TIN: Document Control Desk 

11555 Rockville Pike 

Rockville, MD 20852 

SUBJECT: Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) 

Regarding Recommendation 9.3, Emergency Preparedness - Staffing, 

Requested Information Items 1, 2, and 6 - Phase 2 Staffing Assessment 

Palisades Nuclear Plant 

Docket 50-255 

Renewed Facility Operating License No. DPR-20 

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 (ADAMS Accession Package No. ML 12056A046). 

2. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-034, 

Entergy Nuclear Operations, Inc. 60-Day Response to the 

March 12, 2012, Information Request, Action Plan for Completing 

Emergency Communication and Staffing Assessments, dated 

May 11, 2012 (ADAMS Accession No. ML 12135A289) 

3. Nuclear Energy Institute (NEI) 12-01, Revision 0, Guideline for 

Assessing Beyond Design Basis Accident Response Staffing and 

Communications Capabilities, dated May 2012 (ADAMS 

Accession No. ML 12125A412) 

4. NRC letter to NEI, U. S. Nuclear Regulatory Commission Review 

of NEI12-01, "Guideline for Assessing Beyond-Design-Basis 

Accident Response Staffing and Communications Capabilities, 

Revision 0, dated May 2012, " dated May 15, 2012 (ADAMS 

Accession No. ML 12131A043) 
PNP 2015-036 

Page 2 of 3 

5. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-050, 

90-Day Response to the March 12,2012, Information Request, 

Action Plan for Completing Emergency Communication and 

Staffing Assessments, dated June 8, 2012 (ADAMS Accession No. 

ML 12163A546) 

6. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2014-034, 

Change of Commitments in Entergy Nuclear Operations, Inc. 

60-Day Response to the March 12,2012, Information Request, 

Action Plan for Completing Emergency Communication and 

Staffing Assessments, dated March 27, 2014 

Dear Sir or Madam: 

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a 50.54(f) letter 

to all power reactor licensees and holders of construction permits in active or deferred 

status (Reference 1). Enclosure 5 of Reference 1 contains the specific Requested 

Actions, Requested Information, and Required Response associated with Near-Term 

Task Force (NTTF) Recommendation 9.3 for Emergency Preparedness - Staffing. 

On May 11, 2012, in accordance with Reference 1, Enclosure 5, Entergy Nuclear 

Operations, Inc. (ENO) submitted an alternative course of action for performing the 

requested actions and providing the requested information (Reference 2). Attachment 

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. 

On June 8, 2012, ENO responded to the Emergency Preparedness - Staffing, 

Requested Information items 3,4, and 5 (Reference 5). 

On March 27, 2014, ENO submitted a change to the schedule for responding to the 

information requested in Reference 2 (Reference 6). 

Attachment 1 to this letter provides responses to the following information requests in 

accordance with References 2 and 6: 

• 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 

Attachment 2 to this letter provides the ENO Palisades Nuclear Plant (PNP) Phase 2 

Staffing Assessment. The ENO PNP Phase 2 Staffing Assessment follows the 

assessment process methodology described in NEI 12-01 (Reference 3) which was 

endorsed by the NRC in Reference 4. 
PNP 2015-036 

Page 3 of 3 

Summary of Commitments 

This letter contains no new or revised commitments. It documents completion of the 

following four commitments made in Reference 6: 

Provide onsite and augmented staffing assessment considering functions related to 

NTTF Recommendation 4.2 by May 19, 2015. 

Conduct the onsite and augmented staffing assessment considering functions 

related to NTTF Recommendation 4.2 by April 19, 2015. 

Provide a schedule of the time needed to implement changes associated with the 

Phase 2 staffing assessment by May 19, 2015. 

Identify changes that have been made or will be made to the emergency plan 

regarding the on-shift or augmented staffing changes associated with the Phase 2 

staffing assessment by May 19, 2015. 

I declare under penalty of perjury that the foregoing is true and correct. Executed on 

May 19, 2015. 

Sincerely, 

Attachments: 1. Responses to the Near-Term Task Force Recommendation 9.3 for 

Emergency Preparedness - Staffing, Requested Information Items 

1,2, and 6 

2. Entergy Nuclear Operations, Inc. Palisades Nuclear Plant 

NEI 12-01 Phase 2 Staffing Assessment 

cc: Director of Office of Nuclear Regulation 

Administrator, Region "I, USNRC 

Project Manager, Palisades, USNRC 

Resident Inspector, Palisades, USNRC 
Attachment 1 

Responses to the Near-Term Task Force Recommendation 9.3 for Emergency 

Preparedness - Staffing, Requested Information Items 1, 2, and 6 

4 pages follow 
Responses to the Near-Term Task Force Recommendation 9.3 for Emergency 

Preparedness - Staffing, Requested Information Items 1, 2, and 6 

Responses to the Near-Term Task Force Recommendation 9.3 for Emergency 

Preparedness - Staffing, Requested Information items 1, 2, and 6 are provided below: 

Requested Information Item 1 

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 

of Reference 1, Enclosure 5, Staffing. 

Entergy Nuclear Operations, Inc. (ENO) Response 

Attachment 2 to this letter provides the "Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant Phase 2 Staffing Assessment" conducted in 

accordance with References 2 and 6, and Nuclear Energy Institute (NEI) 

12-01. A detailed timeline was developed based on a tabletop discussion 

and review of the on-shift response to the postulated beyond-design-basis 

external event (BDBEE) extended loss of alternating current (AC) power 

(ELAP). On-shift and augmented staff response was determined based 

upon the tabletop team members' review of applicable plant procedures and 

draft diverse and flexible strategies (FLEX) guidance for the strategies 

identified at the time of the assessment. The focus of the timeline was to 

identify all onsite resources that would be required to execute each task to 

implement the initial and transition phase FLEX mitigating strategies and the 

Palisades Nuclear Plant (PNP) emergency plan. 

The tables describing the required minimum staffing, task implementation 

time lines and NEI 10-05 modified staffing analysis tables for PNP are 

included in Attachment 2. 

The Phase 2 Staffing Assessment concluded that the PNP current minimum 

shift staffing is sufficient to execute all required initial and transition phase 

tasks 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. Any changes to this conclusion 

resulting from revisions to strategies or implementation guidance would be 

documented in the Final Overall Integrated Plan. 

Requested Information Item 1 (continued) 

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: 

1 of 4 
Responses to the Near-Term Task Force Recommendation 9.3 for Emergency 

Preparedness - Staffing, Requested Information Items 1, 2, and 6 

(1a) 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 NTTF Recommendation 4.2. 

ENO Response 

Portable FLEX equipment stored in the FLEX storage buildings is planned to 

be trailer-mounted or on wheels for ease of deployment. Dedicated vehicles 

are planned to be utilized for deploying FLEX equipment from the storage 

location to the staging areas on site. These vehicles would also be used for 

debris removal. 

A FLEX support guideline would be implemented to clear debris from trailer 

paths to allow for moving and setup of FLEX portable equipment. 

(1b) 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. 

ENO Response 

The Minimum Staffing Table shown in Section 4.0 of the phase 2 

assessment report in Attachment 2 provides a table showing the on-shift 

staff responsible for each of the major functional areas of 

NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of 

Radiological Emergency Response Plans and Preparedness in Support of 

Nuclear Power Plants," Table B-1, following the BDBEE. 

(1c) New staff or functions identified as a result of the assessment. 

ENO Response 

The assessment did not identify the need for additional on-shift staff or 

changes to the Emergency Response Organization (ERO) structure. The 

assessment did not identify any new functions. 

(1d) Collateral duties (personnel not being prevented from timely performance of 

their assigned functions). 

2 of 4 
Responses to the Near-Term Task Force Recommendation 9.3 for Emergency 

Preparedness - Staffing, Requested Information Items 1, 2, and 6 

ENO Response 

The Phase 2 staffing assessment concluded that the current minimum onshift staff is sufficient to support implementation of the FLEX mitigating 

strategies as well as the required emergency plan actions with no 

unacceptable collateral duties. 

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 

associated with the Phase 2 staffing assessment. 

ENO Response 

Attachment 2 provides the Phase 2 PNP staffing assessment for a BDBEE. 

The Phase 2 onsite and augmented staffing assessment was completed on 

April 19, 2015. No modifications were identified in the Phase 2 assessment. 

Requested Information Item 6 

Identify changes associated with the Phase 2 staffing assessment 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.). 

ENO Response 

PNP is a single-unit site. Responses to the questions are provided below: 

Staff: The existing on-shift staff is sufficient to implement the 

Emergency Plan and ELAP strategies during the first six-hour 

"no site access" period. No changes to the Emergency Plan 

on-shift staffing have been identified. 

ERO: The existing augmented ERO provides sufficient staffing to fill 

the 24-hour ERO positions. No changes to the Emergency 

Plan augmented ERO staffing have been identified. 

Agreements: Further review in the Phase 2 assessment determined that no 

new or revised agreements are necessary. 

30f4 
Responses to the Near-Term Task Force Recommendation 9.3 for Emergency 

Preparedness - Staffing, Requested Information Items 1, 2, and 6 

References 

Drills: NEI 12-01 states that a licensee should determine if any 

changes are necessary to documents describing the 

emergency response drill and exercise program. No changes 

to the PNP emergency plan drill and exercise program are 

being made; however, ENO is planning to incorporate 

requirements for drills and exercises involving a BDBEE 

scenario in accordance with the guidance and implementation 

schedule of NEI 13-06, "Enhancements to Emergency 

Response Capabilities for Beyond Design Basis Accidents 

and Events," when issued. 

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 (ADAMS Accession No. ML 120S6A046). 

2. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-034, Entergy Nuclear 

Operations, Inc. 60-Day Response to the March 12,2012, Information Request, 

Action Plan for Completing Emergency Communication and Staffing Assessments, 

dated May 11, 2012 (ADAMS Accession No. ML 1213SA289) 

3. Nuclear Energy Institute (NEI) 12-01, Revision 0, Guideline for Assessing Beyond 

Design Basis Accident Response Staffing and Communications Capabilities, dated 

May 2012 (ADAMS Accession No. ML 1212SA412) 

4. NRC letter to NEI, U. S. Nuclear Regulatory Commission Review of NEI12-01, 

"Guideline for Assessing Beyond-Design-Basis Accident Response Staffing and 

Communications Capabilities, Revision 0, dated May 2012," dated May 15, 2012 

(ADAMS Accession No. ML 12131A043) 

S. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2012-0S0, 90-Day Response to 

the March 12, 2012, Information Request, Action Plan for Completing Emergency 

Communication and Staffing Assessments, dated June 8, 2012 (ADAMS Accession 

No. ML 12163AS46) 

6. Entergy Nuclear Operations, Inc. letter to NRC, PNP 2014-034, Change of 

Commitments in Entergy Nuclear Operations, Inc. 60-Day Response to the March 

12,2012, Information Request, Action Plan for Completing Emergency 

Communication and Staffing Assessments, dated March 27, 2014 

7. NE112-01, "Guideline for Assessing Beyond Design Basis Accident Response 

Staffing and Communications Capabilities," Revision O. 

8. NEI 10-0S, "Assessment of On-Shift Emergency Response Organization Staffing and 

Capabilities," Revision O. 

4 of 4 
Attachment 2 

Entergy Nuclear Operations, Inc. 

Palisades Nuclear Plant 

NE112-01 

Phase 2 Staffing Assessment 

23 pages follow 
ENTERGY NUCLEAR OPERATIONS, INC. 

PALISADES NUCLEAR PLANT 

NEI 12-01 PHASE 2 

STAFFING ASSESSMENT 

April 19, 2015 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Table of Contents 

1.0 EXECUTIVE SUMMARY ..................................................................................... 2 

2.0 INTRODUCTION ................................................................................................... 3 

3.0 SCOPE OF THE ELAP ERO STAFFING ASSESSMENT .................................... .3 

4.0 EMERGENCY PLAN MINIMUM ON-SHIFT STAFFING .................................. .4 

5.0 PHASE 2 STAFFING ASSESSMENT FOR BDBEEIELAP ................................... 5 

5.1 On-shift Staff Responsibilities ................................................................................ 5 

5.2 Methodology ........................................................................................................... 6 

5.3 NEI 12-01 General Assumptions and Limitations .................................................... 6 

5.4 Other Assumptions for Staffmg Assessment.. .......................................................... 7 

5.5 NEI 12-06 Staffing Assumptions ............................................................................ 7 

5.6 NEI 10-05 Applicable Assumptions to Support Methodology ................................. 7 

5.7 Severe Accident Management Guideline (SAMG) .................................................. 8 

5.8 Assessment of the INITIAL PHASE Coping Strategies and Capability ................... 8 

5.9 Assessment of TRANSITION PHASE Coping Strategies and Capability ................ 8 

6.0 AUGMENTED ERO ............................................................................................... 9 

6.1 ERO Response ........................................................................................................ 9 

6.2 Site Access for Augmented ERO ............................................................................ 9 

7.0 PHASE 2 STAFFING ASSESSMENT CONCLUSION ........................................ 1 0 

7.1 Staffing Level ....................................................................................................... l 0 

7.2 Task Analysis Results ........................................................................................... 10 

7.3 Time Motion Study (TMS) Results ....................................................................... 1 0 

7.4 Augmented ERO Assessment Results ................................................................. .1 0 

8.0 REFERENCES ..................................................................................................... 11 

9.0. ATTACHMENTS ................................................................................................. 11 

Attachment 1 Phase 2 Staffing Assessment NEIl 0-05 Tabletop Data ........................ .12 

Attachment 2: PNP FLEX Implementation Timelines ................................................... 19 

Page 1 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

1.0 EXECUTIVE SUMMARY 

Beyond Design Basis External Events (BDBEE) are events initiated by natural phenomena 

that either exceed the protections provided by design basis features or involve natural 

phenomena within the design basis in combination with beyond design-basis failures leading 

to an extended loss of AC power (ELAP) and/or loss of ultimate heat sink (LUHS). 

Using the methodology of (Nuclear Energy Institute) NEI 12-0 I, Guideline for Assessing 

Beyond Design Basis Accident Response Staffing and Communications Capabilities, this 

report presents the results of an assessment of the capability of the Palisades Nuclear Plant 

(PNP) on-shift staff and augmented Emergency Response Organization (ERO) to respond to 

a BDBEE. The assumptions for the NEI 12-01 Phase 2 scenario postulate that the BDBEE 

involves a large-scale external event that results in: 

• an extended loss of AC power 

• an extended loss of access to the ultimate heat sink 

• impact on the unit (unit is operating at full power at the time of the event unless 

procedurally directed to shutdown) 

• impeded access to the unit by off-site responders as follows: 

(1) 0 to 6 Hours Post Event - No site access. 

(2) 6 to 24 Hours Post Event - 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). 

(3) 24 Hours Post Event - 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. 

To conduct the on-shift portion of the assessment, a team of subject matter experts from 

Operations, Radiation Protection, Security, Training, Emergency Planning, Chemistry, and 

the FLEX Project Team performed a tabletop in February, 2015. The participants reviewed 

the assumptions and applied procedural guidance, including applicable draft FLEX Support 

Guidelines (FSGs) and FLEX Implementation Guidelines (FIGs) for coping with a BDBEE 

using minimum on-shift staffing. Particular attention was given to the sequence and timing of 

each procedural step, its duration, and the on-shift individual performing the step to account 

for both the task and the estimated time to prepare for and perform the task. 

The Phase 2 Staffmg Assessment concluded that the current minimum on-shift staffing as 

defined in the Palisades Site Emergency Plan (SEP) is sufficient to support the 

implementation of the mitigating strategies (FLEX strategies) as well as the required SEP 

actions, with no unacceptable collateral tasks assigned to the on-shift personnel during the 

first 6 hours. The assessment concluded that the on-shift staffing, with assistance from 

augmented staff, is capable of implementing the FLEX strategies necessary after the 6 hour 

period within the constraints. It was concluded that the Emergency response function would 

not be degraded or lost. 

Page 2 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

2.0 INTRODUCTION 

The Nuclear Regulatory Commission (NRC) issued a Letter to All Power Reactor Licensees 

and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, 

Request/or In/ormation Pursuant to Title 10 o/the Code o/Federal Regulations SO.S4(f) 

Regarding Recommendation 2.1,2.3, and 9.3, o/the Near-Term Task Force Review 0/ 

Insights from the Fukushima Dai-ichi Accident. Information requests related to Emergency 

Preparedness were contained in Enclosure 5 of the §50.54(f) letter. Enclosure 5 contained two 

requested actions; one involving performance of a staffing assessment and the other a 

communications assessment. The communications assessment is independent of the staffing 

assessment and not included as part of this report. The Phase 2 staffmg assessment addresses 

Requested Information Items 1,2, and 6 ofNTTF Recommendation 9.3. The actions for the 

staffmg assessment are summarized as follows: 

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. 

A two-phased approach was established by the industry to respond to the information 

requests contained in the §50.54(f) letter associated with staffing. Additionally, NEI 

developed a technical report (NEI 12-01 , Guidelinefor Assessing Beyond Design Basis 

Accident Response Staffing and Communications Capabilities) that includes the 

recommended criteria for use in performing the staffing assessment for a BDBEE. 

Note - Use of the term ELAP throughout this report also assumes a loss of the ultimate heat 

sink as part of the event. The use of the terms Phases I, 2, and 3 refers to Initial Phase, 

Transition Phase and Final Phase respectively as referenced in the Mitigating Strategies 

Order and NRC JLD-ISG-2012-1. 

3.0 SCOPE OF THE ELAP ERO STAFFING ASSESSMENT 

All sites with one or more operating units are required to perform a Phase 2 staffing 

assessment no later than 4 months prior to beginning of the second refueling outage (as used 

within the context of NRC Order EA-12-049). The Phase 2 assessment considers the staffmg 

necessary to implement actions that address functions related to Fukushima NTTF 

Recommendation 4.2. 

Single unit sites should provide the requested information as it pertains to an Extended Loss 

of all AC Power, and impeded access to the site. 

The PNP staffing assessment was performed per the guidance ofNEI 12-01 with a required 

submittal date no later than May 19,2015. The assessment performed the following: 

• Evaluated the ability of the on-shift staff to implement Initial Phase coping actions and, 

consistent with the site access assumption, evaluated Transition Phase actions that must 

be performed prior to the end of the "no site access" time period. 

Initial Phase - Implementation of strategies that generally rely upon installed 

plant equipment. 

Page 3 of22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

- Transition Phase - Implementation of strategies that involve the use of on-site 

portable equipment and consumables to extend the coping period, and prevent a 

loss of functions needed for core cooling, containment, and spent fuel pool 

makeup. Setup for these strategies may be performed prior to the end of the 

Initial Phase as determined by procedure. 

• Evaluated the ability of the on-shift staff to implement the Station Blackout (SBO) 

coping strategies before ELAP is declared. 

• Evaluated the EOPs, FSGs, and FIGs for responding to an ELAP. (Note: Draft EOPs, 

FSGs, and FIGs revised for FLEX implementation, were used for this assessment). 

• Evaluated whether the ability of the on-shift staff to perform any required emergency 

response functions would be degraded or lost prior to the arrival of the augmented ERO. 

• Consistent with the site access assumption, evaluated the ability of the on-shift staff and 

augmented staff to implement Transition Phase coping strategies performed after the end 

of the "no site access" time period. 

The staffing level determined as a result of the Phase 2 assessment will be verified and 

validated in the process used to reasonably assure required tasks, manual actions and 

decisions for FLEX strategies are feasible and may be executed within the constraints 

identified in the Overall Integrated Plan (OIP) or order EA 12-049. Validation will be 

performed at a date after the submittal of the staffing assessment per NEI guidance "FLEX 

Beyond Design Basis Validation Process". 

4.0 EMERGENCY PLAN MINIMUM ON-SHIFT STAFFING 

The SEP establishes the licensing basis for the on-shift staffing complement as determined by 

the staffing assessment performed as part of the overall Emergency Preparedness rulemaking 

published in November of2011. Only personnel required to be on shift are credited in the 

staffing for the initial 6 hours of the event. The following table indicates the on-shift 

personnel necessary to perform Initial Phase plant operations and the required emergency 

planning functions. 

Minimum Staffing Table 

Position NUREG-06S4 Functional ArealTasks On-Shift Staffing 

Shift Manager (SM) Emergency Direction and Control / 1 Assessment of Operational Aspects 

Control Room Supervisor Plant Operations/Safe Shutdown 1 (CRS) Assessment of Operational Aspects 

Shift Technical Advisor / Plant System Engineering / Technical 1 Shift Engineer (SE) Support 

Nuclear Control Operator Plant Operations/Safe Shutdown / 2 (NCO) Assessment of Operational Aspects 

Nuclear Plant Operator Plant Operations/Safe Shutdown / Fire 6 (NPO) Brigade / Corrective Actions 

Communicator Communications / Notifications 1 

Chemistry Chemistry / Radiochemistry 1 

Page 4 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Minimum Staffing Table 

Position NUREG-06S4 Functional ArealTasks On-Shift Staffing 

Radiation Protection (RP) Radiological Assessment / Onsite and 2 In-plant Surveys 

Security Access Control and Accountability Per Security Plan 

Emergency plan tasks of firefighting, first aid and rescue operations are provided by 

personnel assigned other functions as allowed by NUREG-0654 Table B-1 and NEI 10-05. 

For the purpose of this staffing assessment, it is assumed firefighting, first aid and rescue are 

not required. The SM provides emergency direction and control of plant operations and 

assessment of operational aspects. 

5.0 PHASE 2 STAFFING ASSESSMENT FORBDBEElELAP 

5.1 On-shift Staff Responsibilities 

Responsibilities of the on-shift staff shown in Section 4 are assumed as follows for the 

purpose of the tabletop conducted for this assessment: 

• SM assumed the Emergency Director (ED) function. 

• Communicator was available to perform off-site notifications. 

• The CRS, 2 NCOs and 6 NPOs were available to perform plant operations to establish 

and maintain core cooling, spent fuel pool makeup, and containment integrity as directed 

by the CRS using EOPs, FSGs, and FIGs. 

• Two RP Technicians and one Chemistry Technician were available to perform their 

emergency plan function and other tasks as directed by the SM. 

The Chemistry Technician was responsible for the task of dose assessment should 

a release occur. Otherwise, the Chemistry Technician was available to perform 

tasks as directed by the SM. Chemistry samples and analysis could not be 

performed due to loss of power. 

The two RP Technicians were available to perform job support, in-plant surveys, 

and onsite surveys as directed by the Shift Manager. The RP technicians could be 

called upon for the task when needed; otherwise, they were available to perform 

tasks as directed by the SM. 

• Since the emergency diesel generators were assumed to be unavailable for the event, 

limited time was spent attempting to troubleshoot /repair. 

• Existing strategies do not anticipate the use of security officers to perform duties 

unrelated to their assigned security roles. Tasks performed by security officers in 

response to FLEX actions are consistent with their normal duties such as monitoring and 

controlling site access, providing site access for FLEX equipment staging, and providing 

compensating measures for vital area doors that may need to remain open to facilitate 

room environmental conditions or staging and operation of FLEX equipment. 

Page 5 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

• It was assumed that the Emergency Director and Communicator functions and 

responsibilities remained in the Control Room for the duration of this assessment. It is 

recognized, however, that the augmented ERO would be expected to arrive on-site or at 

their designated off-site facilities and assume these functions from the Control Room as 

soon as possible. 

5.2 Methodology 

• The Phase 2 staffing assessment 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 to ensure accurate results. Once the site specific actions associated 

with the FLEX implementation response strategies are defined (Le., down to the 

procedure or guideline step level), the staffmg needed to perform these actions can be 

assessed with the necessary level of accuracy. 

• Draft EOP, FSG and FIG documents were used during the conduct of the Phase 2 staffing 

assessment and the development of this report. 

• A tabletop assessment was used to determine what plant actions and emergency plan 

implementation actions were required based on procedures during an ELAP. In cases 

where mUltiple tasks were assigned to an individual, the team evaluated timing of the 

tasks to ensure that they could be performed by the individual in series within any 

specified time constraints. A team consisting of personnel from Operations, Radiation 

Protection, Security, Training, Emergency Plarming, Chemistry, and the FLEX Project 

Team completed the assessment of the on-shift staff's response to the event. 

• The guidance ofNEI 10-05 was used to determine if the number and composition of the 

on-shift staff is sufficient to implement the Emergency Plan, Initial Phase actions and, 

with assistance from augmented staff, implement Transition Phase mitigation strategies 

and repair or corrective actions intended to maintain or restore the functions of core 

cooling, containment integrity, and spent fuel pool cooling. 

• The guidance ofNE! 10-05 was used but the tables were modified to include tasks to 

implement the FLEX strategies. 

• Due to the lead time before Phase 3, it was assumed that offsite equipment would arrive 

on site and appropriate staff would be available to receive, stage, and operate the 

equipment. Therefore, the staffing assessment did not consider Phase 3 FLEX strategies. 

5.3 NEI 12-01 General Assumptions and Limitations 

• A large-scale external event occurs that results in: 

onsite unit affected 

extended loss of AC power with simultaneous L UHS 

impeded access to unit 

• Initially, the reactor was operating at full power and was successfully shut down. 

• A Hostile Action directed at the affected site does not occur during the period that the site 

is responding to the event. 

• The event impedes site access as follows: 

Post event time: 0 to 6 hours - No site access. This duration reflects the time 

necessary to clear road way obstructions, use different travel routes, mobilize 

alternate transportation capabilities, etc. 

Page 6 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Post event time: 6 to 24 hours - Limited site access. Individuals may access the 

site by walking, personal vehicle or via alternate transportation capabilities. 

Post event time: 24 hours - Improved site access. Site access is restored to a nearnormal status and/or augmented transportation resources are available to deliver 

equipment, supplies, and large numbers of personnel. 

5.4 Other Assumptions for Staffmg Assessment 

• The result of the beyond-design-basis event may place the plant in a condition where it 

cannot comply with certain Technical Specifications and/or with its Security Plan, and as 

such, may warrant invocation of 10 CFR 50.54(x) and/or 10 CFR 73.55(p). 

• F or purposes of assessing augmented staffing, it is assumed that the on-shift staff 

successfully performs all Initial Phase and any necessary Transition Phase coping actions 

during the 0-6 hour period. It is assumed an adequate number of augmented ERO 

members arrive on site between 6 hours and 24 hours to assist the on-shift staff to 

successfully implement the appropriate FLEX strategies and FSGs. 

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 integrity, and spent fuel pool cooling. 

• 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. 

• Off-site emergency response facilities and staging areas are available, including those 

located within the 25 mile telecommunications blackout range. 

5.5 NEI 12-06 Staffing Assumptions 

• The FLEX strategies documented in the event sequence analysis assume: 

No independent, concurrent events 

All personnel onsite are available to support site response 

The reactor is initially operating at power, unless site has procedural direction to 

shut down due to the impending event. 

5.6 NEI 10-05 Applicable Assumptions to Support Methodology 

• On-Shift personnel can report to their assigned response locations within timeframes 

sufficient to allow for performance of assigned actions. 

• 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 unless allowed by procedure or the SEP) without the aid of a 

Radiation Protection Technician. 

• Performance of site and protected area access control function is regularly analyzed 

through other station programs and will not be evaluated here, unless a role or function 

from the major response area is assigned as a collateral duty. 

Page 7 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

• 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. 

• 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. 

• 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). 

S.7 Severe Accident Management Guideline (SAMG) 

• It was concluded in the Phase 2 Staffing Assessment that the on shift staff and augmented 

ERO would not be called upon to perform SAMG activities for the event analyzed for 

this report. 

S.B Assessment of the INITIAL PHASE Coping Strategies and Capability 

• The Phase 2 staffing assessment for the Initial Phase actions during the first 6-hours 

concluded there were no task overlaps for the activities assigned to the on-shift staff and 

the ability of the on-shift staff to perform any required emergency response functions 

were not degraded or lost. Refer to Attachment 1, Phase 2 Staffing Assessment NEI 10-

OS Tabletop Data and Attachment 2, PNP FLEX Implementation Timelines. 

S.9 Assessment of TRANSITION PHASE Coping Strategies and Capability 

• On-shift Staff Transition Phase Coping Actions (Hours 0 - 6 ) 

The Transition Phase requires providing sufficient, portable, on-site equipment and 

consumables to maintain or restore functions until they can be accomplished with 

resources brought from off site. Actions include: 

(1) DC Load Shed (EOP-3.0); DC Deep Load Shed (FSG-4) 

(2) Debris removal from the path to retrieve FLEX equipment from the selected 

storage location to the staging areas (FSG-S) 

(3) Deploy FLEX DG and cables from the selected storage location to the staging 

area and connect DG in preparation for re-powering battery chargers and 

electrical buses (FIG-I, FSG-4, and FSG-S) 

(4) Deploy FLEX Pump and hoses from the selected storage location to the staging 

area and connect in preparation for providing water to the steam generators, PCS 

make-up, and SFP make-up (FSG-S, FIG-2, FIG-3, and FIG-4) 

(S) Establish Fuel Handling Building Ventilation (FIG-B) 

• Augmented ERO and On-shift Staff Transition Phase Coping Actions 

Page 8 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

The following tasks are assumed to be performed by the on-shift and augmented staff, 

if available, after the 6 hour no access period as shown in Attachment 2. 

(1) Energize electrical buses and battery chargers (FIG-l and FSG-4) 

(2) Complete deployment of and connection of hoses and initiate SFP makeup and 

cooling (FIG-3) 

(3) Initiate low pressure feedwater for steam generator make-up (FIG-4) 

(4) Initiate Long Term Inventory Control (FSG-l) 

(5) Provide backup control air for atmospheric dump valves (FIG-9) 

(6) Refuel FLEX equipment (FIG-lO) 

(7) Establish battery room ventilation (FIG-8) 

(8) Batch boron additions as needed for PCS Inventory control (FIG-5) 

6.0 AUGMENTED ERO 

6.1 ERO Response 

• The methods to notify and augment the ERO was identified in Entergy Nuclear 

Operations, Inc.(ENO) letter to the NRC dated June 8, 2012, 90-Day Response to the 

March 12, 2012 Information Request, Action Plan for Completing Emergency 

Communication and Staffmg Assessments (pNP Letter PNP 2012-050). 

• The ERO is trained to report to their assigned emergency response facilities when made 

aware of an area wide loss of electrical grid that results in degraded communications 

capability. If access to the assigned facilities is not possible, personnel should report to 

the pre-established alternate offsite facilities. 

6.2 Site Access for Augmented ERO 

• The methods of site access for the augmented ERO was identified in an ENO letter to the 

NRC dated June 8,2012, 90-Day Response to the March 12,2012 Information Request, 

Action Plan for Completing Emergency Communication and Staffmg Assessments (pNP 

Letter PNP 2012-050). 

• Various types of transport to PNP are applicable including: walking, personal vehicle, 

helicopter, and watercraft. 

• PNP has designated the Emergency Operations Facility, located in downtown Benton 

Harbor and approximately 16 miles south-southwest from the Plant, as the staging area if 

impediments prevent site access. Additionally, pursuant to Michigan Public Act 390 of 

1976, known as the Michigan Emergency Management Act, the Michigan State Police 

Emergency Management Homeland Security Division (MSPIEMHSD) is required by 

state law to provide support, consistent with competing priorities, to PNP in the event of 

a large-scale natural disaster that inhibits site access. MSPIEMHSD is the central 

coordinating agency for mutual aid in Michigan for all state, local and federal resources. 

Should MSPIEMHSD be unable to provide support, the Michigan National Guard will 

assist in all areas except the removal of down power lines. This support may include 

enabling plant emergency responders to gain access to the nuclear plant site by clearing 

roads, or coordinating air or water transportation as needed. 

Page 9 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

7.0 PHASE 2 STAFFING ASSESSMENT CONCLUSION 

7.1 Staffmg Level 

This assessment concluded that the current minimum on-shift staffmg as defined in the SEP 

is sufficient to support the implementation of the ELAP strategies, as well as the required 

SEP actions, with no unacceptable collateral duties. The staffing assessment did not identify 

the need for additional on-shift staff. 

The non-licensed operators performed tasks in series when necessary and were able to timely 

perform all assigned functions. The operators performed actions to ensure core cooling, 

containment integrity, and spent fuel pool cooling. The performance of coping strategies 

does not impact the ability of the on-shift staff to perform any required emergency response 

function. Emergency response functions will not be degraded or lost prior to the arrival of 

the augmented ERO. 

The SEP will not be changed as a result of the shift staffing assessment. No interim actions 

have been taken or are planned as a result of this assessment. 

7.2 Task Analysis Results 

Refer to Attachment 1, Phase 2 Staffing Assessment NEI 1-05 Tabletop Data, and 

Attachment 2, PNP FLEX Implementation Timelines, for the analysis of on-shift staffing 

tasks. 

• The task analysis did not identify any unassigned tasks. 

• The task analysis did not identify any task overlaps that were performed by the on-shift 

staff. 

• The time to perform the task was best estimate of the assessment team based on operating 

experience. 

7.3 Time Motion Study (TMS) Results 

Collateral tasks were not identified, therefore a time motion study was not required. 

Refer to Attachment 2, PNP FLEX Implementation Timelines, for the on-shift staffing task 

timing and sequence analysis results. 

7.4 Augmented ERO Assessment Results 

The existing ERO is sufficient to fill the augmented ERO positions and assist the on-shift 

staff response to a BDBEE. PNP has four ERO teams that have been trained to respond to the 

site. No changes to the SEP augmented ERO staffing have been identified. 

Page 10 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

8.0 REFERENCES 

8.1 NEI 12-01, Rev 0, Guideline for Assessing Beyond Design Basis Accident Response Staffing 

and Communications Capabilities 

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

Capabilities 

8.3 NSIR DPR-ISG-Ol, Interim Staff Guidance - Emergency Planningfor Nuclear Power Plants 

8.4 NRC Letter to All Power Reactor Licensees and Holders of Construction Permits in Active or 

Deferred Status, dated March 12,2012, Requestfor Information Pursuant to Title 10 of the 

Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1,2.3, and 9.3, of the 

Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident. 

8.5 NRC Order Number EA-12-049, dated March 12, 2012, Order to Modify Licenses with 

Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 

8.6 ENO letter (Palisades Letter PNP 2012-034) to the NRC dated May 11, 2012, Entergy 

Nuclear Operations, Inc. 60-Day Response to the March 12,2012, Information Request, 

Action Plan for Completing Emergency Communication and Staffing Assessments 

(ML12135A289) 

8.7 ENO Letter (Palisades Letter PNP 2012-050) to the NRC dated June 8, 2012, 90-Day 

Response to the March 12,2012, Information Request, Action Planfor Completing 

Emergency Communication and Staffing Assessments (ML12163A546) 

8.8 ENO Letter (palisades Letter PNP 2014-034) to the NRC dated March 27, 2014, Change of 

Commitments in Entergy Nuclear Operations, Inc. 60-Day Response to the March 12, 2012, 

Information Request, Action Planfor Completing Emergency Communication and Staffing 

Assessments. 

8.9 NRC Interim Staff Guidance JLD-ISG-2012-01, Rev. 0, dated August 29,2012, Compliance 

with Order EA-12-049, Order Modifying Strategies for Beyond-Design-Basis External 

Events 

8.10 NEI 12-06 Rev. 0, August 2012, Diverse and Flexible Coping Strategies (FLEX) 

Implementation Guide 

8.11 EC-0000046464, PNP FLEX Strategy Development 

8.12 Palisades Site Emergency Plan 

9.0. ATTACHMENTS 

A IT ACHMENT I 

A IT ACHMENT 2 

PHASE 2 STAFFING ASSESSMENT NEI 1 0-05 TABLETOP 

DATA 

PNP FLEX IMPLEMENTATION TIMELINES 

Page 11 of 22 
Attachment 1 

Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 1 

Phase 2 Staffmg Assessment NEI 10-05 Tabletop Data 

Note 

NEI-IO-05 Tables are modified to include the Emergency Plan and FLEX 

implementation tasks. 

l. Accident Summary: 

• A large-scale external event occurs that results in: 

- The unit is affected 

- Extended loss of AC power (ELAP) and access to Ultimate Heat Sink 

(LUHS) 

- Impeded access to the unit 

• Initially, the reactor is operating at full power and is successfully shut down. 

• The event results in a Site Area Emergency based on EAL SS 1.1. The event is 

upgraded to a General Emergency SG 1.1 once it has been determined that power 

cannot be restored before the station blackout coping time will be exceeded. 

• The most limiting hazard for on-shift staffing resources was used for the 

assessment. On-shift personnel respond as shown in Attachment 2. 

2. Accident Specific Assumptions: 

• Attachment 2 assumptions include: 

- SM/CRS are expected to use available staff to provide periodic relief (if 

needed) for individuals working in extreme environmental conditions or 

under high physical stress conditions (Ex., work in high heat areas, staging 

cables and hoses, etc.). 

- Estimated task times include expected pre-job and safety briefings 

• Assumptions are identified in Section 5.0 of this document. 

3. Procedures Reviewed for Accident Response Include: 

• EI-l, Emergency Classification and Actions 

• EI-3, Communication and Notification 

• EI-12.1, Personnel Accountability and Assembly 

• EI-2.2, E Emergency Staff Augmentation 

• EI-6.13, Protective Action Recommendations for Offsite Populations 

• SEP SUPP 1, Site Emergency Plan Supplement 1- EAL Wall Charts 

• EOP-1.0, Standard Post-Trip Actions 

• EOP-3.0, Station Blackout Recovery 

• FSG-l, Long Term Inventory Control 

• FSG-3, Low Pressure Feedwater 

• FSG-4, ELAP DC Bus Load Shed And Management 

• FSG-S, Initial Assessment and FLEX Equipment Staging 

• FSG-ll, Alternate SFP Makeup and Cooling 

• FSG-l00, BDBEE HAP Emergency Response 

• FSG-l0l, BDBEE / EP Communications 

Page 12 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 1 

• FIG-l, flEX Generator Staging and Operation 

• FIG-2, FLEX Pump Staging and Operation 

• FIG-3, Alternate SFP Makeup and Cooling 

• FIG-4, Low Pressure Feedwater Alignment 

• FIG-7, flEX PCS Injection 

• FIG-8, Alternate Ventilation 

• FIG-9, FLEX Air Compressor Staging and Operation 

• FIG-10, Fuel Oil Transfer 

Page 13 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 1 

NOTE: NEI 10-05 Tables 1-5 shown here are modified to include Emergency Plan and 

FLEX implementation tasks 

NEI 10-05 TABLES 

PNP TABLE 1 - ON-SHIFf POSITIONS 

Single Unit ELAPILUHS 

Role in Table # I CoUateral Tasks? 

~ine# On-shift Position Line # Unanalyzed Task? (See Attachment 2 for Task 

sequence & timeline) 

T2ILI 

T5ILI 

1 SM T51L2 No No T51L3 

T51L5 

T51L8 

2 CRS T21L2 No No 

3 SE T21L3 No No 

4 NCO #1 T21L4 No No 

5 NCO #2 T21L5 No No 

6 NPO#1 T21L6 No No 

7 NPO#2 T21L7 No No 

8 NPO#3 T21L8 No No 

9 NPO#4 T2/L9 No No 

10 NPO#5 T2ILI0 

No No 

11 NPO#6 T21L11 No No 

T51L6 

12 Communicator T51L9 No No 

T51L13 

13 Chemistry T2a1L12 No No 

14 RP#1 T2a1L13 No No 

(Refer to Attachment 2) 

15 RP#2 T2a1Ll4 No No 

(Refer to Attachment 2) 

Security T51L15 No No 

Page 14 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 1 

PNP TABLE 2 - PLANT OPERATIONS & SAFE SHUTDOWN 

Single Unit ELAP/LUHS 

Minimum Operations Crew Necessary to Implement EOPs, SAMGs, FSGs or FIGs as Applicable 

Line # Generic Title/Role On-Shift Position * Task Analysis 

(Note 1) ControUing Method 

(Note 2) 

1 Shift Manager SM Licensed Operator 

Trainin~ Program 

2 Unit Supervisor CRS Licensed Operator 

Training Program 

3 Shift Technical Advisor I Shift SE Licensed Operator 

Engineer Training Program 

4 Nuclear Control Operator # 1 NCO #1 Licensed Operator 

Training Program 

5 Nuclear Control Operator #2 NCO #2 Licensed Operator 

Training Program 

6 Nuclear Plant Operator # 1 NPO#1 Non-Licensed Operator 

Training Program 

7 Nuclear Plant Operator #2 NPO#2 Non-Licensed Operator 

Training Program 

8 Nuclear Plant Operator #3 NPO#3 Non-Licensed Operator 

Training Program 

9 Nuclear Plant Operator #4 NPO#4 Non-Licensed Operator 

Training Program 

10 Nuclear Plant Operator #5 NPO#5 Non-Licensed Operator 

Training Program 

11 Nuclear Plant Operator #6 NPO#6 Non-Licensed Operator 

Training Program 

*The Commumcator NPO does not perform EOP, SAMG, FSG or FIG procedures and IS not 

shown in Table 2. 

Note 1: During a BDBEE that results in an ELAP/LUHS, these positions are expected to be 

available to implement or assist in the implementation of FLEX strategies using FLEX 

Support Guidelines (FSG) and FLEX Implementation Guideline (FIG) under the 

direction of the Control Room Supervisor and oversight by the Shift Manager. 

Note 2: Each position will receive as a minimum, the INPO initiated NANTEL Generic Basic 

FLEX Initial Course (CBT-ERTD-FLEX-INITIAL). Shift Managers, Control Room 

Supervisors, Shift Technical Advisors/Shift Engineers, and Licensed Operators will also 

receive the NANTEL Generic Advanced FLEX Training Course (CBT-ERTD-FLEXADVANCED) as specified in EN-TQ-II0-0l, Fleet E-Plan Training Course Summary. 

All training was developed using the Systematic Approach to Training (SAT) process in 

addition to other FLEX training. The controlling method put in place when FLEX is 

implemented will follow the guidance recommended by the industry. 

Page 15 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 1 

PNPTable 2a 

Other on-shift staff available to perform (or assist Operators) FLEX related tasks (not safe 

shutdown) 

lLine # Generic TitieIRole On-Shift Position Task Analysis 

12 

13 

14 

Line 

# 

1 

2 

3 

4 

5 

(Note 1) Controlling Method 

(Note2) 

Chemistry Chemistry N/A 

Radiation Protection # 1 RP#1 N/A 

Radiation Protection #2 RP#2 N/A 

Note 1: During a BDBEE that results in an ELAP/LUHS, these positions are expected to be 

utilized to assist in the implementation of FLEX strategies using FSGs under the 

instructions of Operations as necessary. 

Note 2: The controlling method put in place when FLEX is implemented will follow the guidance 

recommended by the industry. 

PNP TABLE 3 - FIREFIGHTING* 

Single Unit ELAP/LUHS 

Performed by Task Analysis Controlling Method 

I 

N/A N/A 

N/A N/A 

N/A N/A 

N/A N/A 

N/A N/A 

*Frre BrIgade (No firefightmg tasks are mcluded m thiS accldent.). 

Staff filling fire brigade positions are shown in the minimum staffing table in Section 4.0. 

Page 16 of 22 
L 

I 

N 

E 

1 

2 

3 

4 

5 

6 

7 

Position 

Performing 

Function / 

rrask 

n-Plant 

Survey: 

RP#1 & #2 

n-Plant 

Survey: 

RP#1 & #2 

lPersonnel 

Monitoring: 

~ob 

Coverage: 

FLEX 

'eauinment 

~et1JQ 

Off site Rad 

IAssessment: 

If See Table 

15- Chern) 

Other site 

ispecific RP 

Chemistry 

lFunction task 

Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 1 

PNP TABLE 4 - RADIATION PROTECTION AND CHEMISTRY 

Single-Unit ELAPILUHS 

Performance Time Period After Station Blackout (hours)* 

0- .5- 1.0- 2.0- 3.0- ~.O- 5.0- 6.0- 7.0- 8.0- 9.0- 10.0 11.0 12.0- 13.0 14.0-

.5 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0 13.0 14.0 15.0 

As directed by SM* 

(See Attachment 2 of this report) 

As directed by SM* 

(See Attachment 2 of this report) 

As directed by SM* 

(See Attachment 2 ofthis report) 

As directed by SM* 

15.0-

16.0 

.. *The team determmed there are no tIme sensItIve RP or ChemIstry tasks and that task 

performance is directed and prioritized by the Shift Manager. The time RP or Chemistry is 

directed to perform a task and the amount oftime taken to complete tasks are estimated. No 

Chemistry samples are taken due to the loss of power to the equipment necessary to analyze 

samples. No fuel damage or release is anticipated since core cooling, containment integrity, and 

spent fuel pool cooling are maintained. RP and Chemistry are available to assist with staging and 

setup of FLEX equipment when not performing dose assessment, surveys, or job support. 

Page 17 of 22 

16.0-

24.0 

I 
PNP TABLE S - EMERGENCY PLAN IMPLEMENTATION 

Sil!gle Unit ELAP/LUHS 

~ine# Function / Task On-Shift Task Analysis Controlling 

Position Method 

1 

Declare the emergency classification level SM IEmergency Planning Training 

(ECL) IProgram / EP Drills 

2 Approve Off site Protective Action SM IEmergency Planning Training 

Recommendations IProgram / EP Drills 

3 IApprove content of State/local notifications SM IEmergency Planning Training 

IProgram 

4 IApprove extension to allowable dose N/A N/A 

Notification and direction to on-shift staff fL'icensed Operator Training 

5 ~e.g., to assemble, evacuate, etc.) SM Program / Emergency Planning 

Training Program 

6 ~RO notification Communicator Emergency Planning Training 

Program 

7 

!Abbreviated NRC notification for DBT N/A N/A 

event 

8 Complete State/local notification form SM Emergency Planning Training 

Program 

9 Perform State/local notifications Communicator Emergency Planning Training 

Program 

10 Complete NRC event notification form (Note 1) N/A 

11 Activate EROS (Note 2) N/A 

12 Offsite radiological assessment (Note 3) IEmergency Planning Training 

Program 

13 Perform NRC notifications Communicator IEmergency Planning Training 

Program 

Perform other site-specific event 

14 notifications (e.g., Duty Plant Manager, (Note 4) N/A 

~NPO, ANI, etc.) 

15 lPersonnel Accountability Security Security Training Program / EP 

Drills 

Note 1: NRC Event notificatIOn required due to the declaration of an Emergency ClassificatIOn 10 accordance With 

10 CFRSO.72 is made verbally to the NRC. A written event notification form is not generated by on-shift 

staff for this notification. Formal written notifications to the NRC as may be required by 10 CFR 50.72 

resulting from this event may be generated by the augmented staff. 

Note 2: IfERD8 capability is lost, critical information would be communicated directly to the NRC over other 

communication paths, such as satellite phones. 

Note 3: Chemistry will report to the Control Room to assist the 8M1ED as directed and be available for offsite 

radiological assessment if needed. A significant release is not anticipated since core cooling, spent fuel 

pool makeup and containment integrity are maintained during the 24 hour period. Ifno significant release 

is expected, the 8M is expected to direct Chemistry to assist with other tasks. 

Note 4: The 8M will not make these communications. The Duty Plant Manager will report to the site or the staging 

area and make these communications. 

Page 18 of 22 
Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 2 

ATI ACHMENT 2: PNP FLEX IMPLEMENTATION TIMELINES 

Timeline 

It is assumed on-shift staff will be augmented and/or relieved after +6 hours as personnel are able to access the site. The relie

tasks for the job position as shown. The intent ofthis table is to identify the job position, tasks, and estimated timeline to comp

initial phase and transition phase tasks and to demonstrate that no collateral duties have an adverse impact on implementing 

FLEX strategies. 

JOB ' . TIME TASK 

: POSITION 

.' .- ... -., " 

Shift Manager (I) T = 0 - 15min (1) Assess event and declare SAE; EI -1, SEP Supp 1 

(2) T= 15- 30 min (2) Approve Notification Message Form and direct communicator to make 

(3) T = 1 hr. notifications / Direct SAE evacuation & accountability: EI-3, EI-12.1 

(4) T = I - I.5hr. (3) Declare ELAP / Declare GE / Develop PAR; EOP 3.0, EI-l , SEP Supp. 1, EI-

(5) T = 0 - until EOF is (4) Approve Notification Message Form and direct communicator to make 

operational notifications / Call SAFER / Direct Security to enable FLEX equipment access 

ED responsibilities; EI-3, FSG-l 00 

(5) Perform oversight and ED responsibilities 

Control Room (1) T = 0 - 1 hr. (1) Direct immediate plant actions; EOP-3 

Supervisor (2) T = 1 hr. - duration (2) Direct and coordinate EOP / ELAP actions: FSGs 

Shift Technical (1) T = 0 - until mode 4 (1) Technical Support / Plant monitoring and assessment including performance o

Advisor / Shift safety function checks; EOP-l, EOP-3 

Engineer 

NCO #1 (1) T = 0 - 0.5 hr. (1) Immediate plant actions including reactor trip response / Isolate controlled blee

(2) T = 2 - 5 hr. off; EOP-l, EOP-3 

(3) T = 7 - 8 hr. (2) Perform PCS Cooldown; EOP-3 

(4) T = 0.5 - duration (3) Coordinate Steam Generator makeup; FIG-4 

(4) Plant monitoring 

NCO #2 (1) T = 0 - 1 hr. (1) Immediate plant actions including reactor trip response / Coordinate alignmen

(2) T = 4 - 6 hr. gravity feed from T-81 to T-2; EOP-l, EOP-3 

(3) T = 7 - 8 hr. (2) Perform FLEX generator breaker alignment; FIG-l 

(4) T = 10 - llhr. (3) Coordinate PCS makeup through installed charging pumps; FSG-l 

(5) T = 0.5 - duration (4) Coordinate SFP fill / spray; FIG-l 

--

(5) Plant monitoring 

Page 19 of 22 
JOB 

POS:iTION 

NPO#I 

NPO#2 

NPO#3 

NPO#4 

Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 2 

. TIME TASK 

. :..: ". > 

.. 

< ; -"---' . ..:. -

(1) T = 0 - 0.5 hr. (I) SBO Load shed (15 min.); EOP-3 

(2) T = 1 - 2 hr. (2) Conduct debris removal assessment / setup portable lighting at FLEX bldg. (as 

(3) T = 2 - 4 hr. needed); FSG-5 (4) T = 4 - 6hr. (3) Support movement of FLEX equipment to staging areas; FIG-I, FIG-2 

(5) T = 6 - 7 hr. (4) Layout and connect FLEX generator cables; FIG-I 

(6) T = 7 - duration (5) Start FLEX generator and energize electrical buses / Energize battery chargers; 

FIG-I, FSG-4 

(6) Monitor FLEX generator operation; FIG-I 

(I) T = 0 - 0.5 hr. (I) Reports to CR. Available for plant response actions 

(2) T = 0.5 - 1 hr. (2) Perform Supplement 28 actions; EOP-3 

(3) T = 1 - 2 hr. (3) Obtain safety gear needed to access SFP roof hatch; FIG-8 

(4) T = 2 - 3 hr. (4) Establish FHB ventilation; FIG-8 

(5) T = 3 - 4hr. (5) Layout and connect SFP spray - makeup hoses (SFP area only); FIG-3 

(6) T = 4 - 6 hr. (6) Layout and connect feedwater hoses for FLEX pump; FIG-4 

(7) T = 6 - 7 hr. (7) Connect FLEX pump and manifold; FIG-2 

(8) T = 7 - 8 hr. (8) Start FLEX pump and vent lines; FIG-2 

(9) T = 8 - duration (9) Monitor FLEX pump operation; FIG-2 

(1) T = 0 - 0.5 hr. (1) Reports to CR. Available for plant response actions 

(2) T = 0.5 - 1 hr. (2) Perform Supplement 28 actions; EOP-3 

(3) T = 1 - 3 hr. (3) Conduct debris removal assessment and perform debris removal; FSG-5, FSG-

(4) T = 3 - 4hr. (4) Layout and connect SFP spray- makeup hoses (SFP area only); FIG-3 

(5) T = 4 - 6 hr. (5) Layout and connect feedwater hoses for FLEX pump; FIG-4 

(6) T = 6 - 7hr. (6) Connect FLEX pump and manifold; FIG-2 

(7) T = 7 - duration (7) Support steam generator makeup; FIG-4 

(1) T = 0 - 0.5 hr. (1) Reports to CR. Available for plant response actions 

(2) T = 0.5 - 1 hr. (2) Perform Supplement 28 actions; EOP-3 

(3) T = 1 - 3 hr. (3) Conduct debris removal assessment and perform debris removal; FSG-5, FSG-

(4) T = 4 - 6hr. (4) Layout and connect feedwater hoses for FLEX pump; FIG-4 

(5) T = 7 - 8 hr. (5) Support initial lineup and start of installed charging pump for PCS makeup; FS

(6) T = 12 - duration. (6) Begin and be available to support boron batching operations as required for PC

inventory control. (FIG-5) 

Page 20 of 22 
JOB 

___ POSI;IlON"., .'. 

NPO#5 

NPO#6 

Communicator 

Chemistry 

Technician 

RP#I 

Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 2 

" TASK 

':< -\; . " :;' -, -- ,_. _. . --.- - ·-··-.-_c --

(1) T = O- I hr. (1) Investigates EDGs failure to start 

(2) T = 1 - 2 hr. (2) Perform electrical deep load shed; FSG-4 

(3) T = 4 - 6 hr. (3) Layout and connect FLEX generator cables; FIG-I 

(4) T = 6 - 8 hr. (4) Stage, hookup and start FLEX air compressor; FIG-9 

(5) T = 8 - 11 hr. (5) Layout and connect SFP hoses (stairwell to pump) / Commence spray-makeup 

(6) T = 11 - duration needed; FIG-3 

(6) Support SFP spray - makeup as needed 

(1) T - 0 - 1 hr. (1) Align gravity feed from T-8I to T-2; EOP-3 

(2) T = 1 - 2 hr. (2) Valve-in nitrogen bank 9; EOP-3 

(3) T = 3 - 4 hr. (3) Layout and connect SFP spray- makeup hoses (SFP area only); FIG-3 (4) T = 4 - 6hr. (4) Layout and connect feedwater hoses for FLEX pump; FIG-4 

(5) T = 6 - 7 hr. (5) Connect FLEX generator and energize electrical buses / Energize battery charg(6) T = 7 - 8 hr. FIG-I, FSG-4 (7) T = 8 - 11 hr. (6) Establish battery room ventilation; FIG-8 

(8) T = 12 - duration (7) Layout and connect SFP spray-makeup hoses (stairwell to pump); FIG-3 

(8) Begin and be available to support boron batching operations as required for PC

inventory control. (FIG-5) 

(1) T = 0 - 0.5 hr. (1) Performs off-site notifications for SAE declaration; EI-3 

(2) T = 0.5 - 1 hr. (2) Performs off-site notifications for GE declaration; EI-3 

(3) T = 1 - duration (3) Performs periodic off-site notifications and communications as needed 

(1) T = 0 - 1 hr. (1) Report to CR to be available for dose assessment ifneeded 

(2) T = 1 - 2 hr. (2) Support debris removal assessment / Setup portable lighting at FLEX building 

(3) T = 2 - 4hr. needed); FSG-5 

(4) T = 4 - 6hr. (3) Support movement of FLEX equipment to staging areas; FIG-I, FIG-2 (4) Support layout and connection of FLEX generator cables; FIG-I (5) T = 6 - 8 hr. (5) Support staging and hookup of FLEX air compressor; FIG-9 

(1) T- 0 - 1 hr. (1) Lock and revise posting for select Auxiliary and Ctmt. Building doors; W-RSD

(2) T = 2 - 3 hr. 018 / Stage monitoring equipment for personnel contamination monitoring 

(3) T = 3 - 4 hr. (2) Support establishing FHB ventilation; FIG-8 

(4) T = 4 - 6hr. (3) Support layout and connection ofSFP spray-makeup hoses (SFP area only); F

(5) T = 7 - 8 hr. (4) Support layout and connection of feed water hoses for FLEX pump ; FIG-4 

(5) Support establishing battery room ventilation; FIG-8 

Page 21 of 22 
JOB . 

. _ PoSITiON " 

RP#2 

Security 

(2) Augmented 

Staff 

(2) Augmented 

Staff 

. 

-

Palisades Nuclear Plant Phase 2 Staffing Assessment 

Attachment 2 

.TIME - -,"-' TASK - '< ... 

. - . .'. . 

... ... '"'-'-' ',',""" ., .. - ... ,.-.--. .. ..... r ...... 

(1) T = 0 - duration (1) Available for in-plant and on-site surveys and job coverage as needed and dire

by the SM 

(2) T = 0 - duration (2) Access control and onsite personnel accountability 

(3) T = 1 - 2 hr. (3) Initiate security actions to open FLEX equipment access paths 

(I) T = 8 - 10 hr. (I) Obtain fuel transfer trailer, set-up transfer pumps, and commence FLEX refuel

(2) T = to - duration strategy per FIG-to 

(2) Implement FLEX equipment refuel strategy; FIG-to 

(1) T = 8 - llhr. (I) Support layout and connection of SFP spray-makeup hoses (stairwell to pump

(2) T = 11 - 15 hr. FIG-3 

(3) T = 17- 20 hr. (2) Perform follow-up debris clearing of site access road (as needed); FSG-5, FSG

100 

(3) Setup communications generators and equipment; FSG-I01. 

Page 22 of 22