ML13128A014

APS Response to NRC Request for Information Regarding Licensee Emergency Preparedness Phase 1 Staffing Requirements Associated with Near-Term Task Force (NTTF) Recommendation 9.3

ML13128A014
Person / Time
Site:	Palo Verde
Issue date:	04/30/2013
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06697-DCM/MAM/TLC
Download: ML13128A014 (46)

Text

10 CFR 50.54(f)

DWIGHT C. MIMS Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 102-06697-DCM/MAM/TLC Mail Station 7605 April 30, 2013 Tel 623 393 5403 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

References:

1.

N RC 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. ML12056A046)

2. APS Letter No. 102-06523 to NRC, 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated May 11, 2012 (ADAMS Accession No. ML12139A324)

3.

NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, dated May 2012 (ADAMS Accession No. ML12125A412)

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 APS Response to NRC Request for Information Regarding Licensee Emergency Preparedness Phase 1 Staffing Requirements Associated with Near-Term Task Force (NTTF) Recommendation 9.3 On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued a letter entitled, 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 to Arizona Public Service Company (APS)

(Reference 1). Enclosure 5 of that letter contains specific Requested Actions, Requested Information, and Required Responses associated with Recommendation 9.3 for Emergency Preparedness (EP) programs.

In accordance with 10 CFR 50.54(f), addressees were requested to submit a written response to the information requests within 90 days. In Reference 2, APS proposed an alternative course of action and committed to provide, in two phases, an assessment of the EP staffing required during a multi-unit emergency event.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak - Diablo Canyon

• Palo Verde

• San Onofre ° South Texas

• Wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission PVNGS Fukushima N1TF EP Phase 1 Staffing Assessment Page 2 In Reference 2, APS committed to provide in Phase 1 the onsite and augmented staffing assessment considering all required functions except those related to NTTF Recommendation 4.2, Mitigation Strategies for Beyond-Design-Basis External Events. The Phase 1 staffing assessment was performed using the guidance provided in Reference 3.

The enclosure to this letter contains the APS Phase 1 staffing assessment results, which provides the information requested in Reference 1, Enclosure 5, Staffing, Requested Information Items 1, 2, and 6.

No commitments are being made to the NRC by this letter.

Should you have any questions concerning the content of this letter, please contact Mark McGhee, Operations Support Manager, Regulatory Affairs, at (623) 393-4972.

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

Executed on (Date)

Sincerely, DCM/MAM/TLC/hsc Enclosure - APS Response to NRC Tier 1 Near-Term Task Force Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment cc:

E. J. Leeds, A. T. Howell III J. K. Rankin M. A. Brown D. H. Jaffe NRC Director, Office of Nuclear Reactor Regulation NRC Region IV Regional Administrator NRC NRR Project Manager [send electronic]

NRC Senior Resident Inspector for PVNGS NRR/JLD

ENCLOSURE APS Response to NRC Tier 1 Near-Term Task Force Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Palo Verde Nuclear Generating Station NEI 12-01 Phase 1 Staffing Analysis Report I

-r APS Response to NRC Tier 1 NTIF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Table of Contents 1

2 2.1 3

3.1 3.2 4

4.1 4.2 4.3 4.4 5

5.1 5.2 6

6.1 6.2 7

7.1 7.2 7.3 7.4 8

9 10 INTRODUCTION..........................................................................................................................................

3 EXECUTIVE SUM M ARY............................................................................................................................

4 ENHANCEMENTS IDENTIIEED........................................................................................................................

4 STAFFING ANALYSIS PROCESS OVERVIEW................................................................................

5 ON-SHIFT STAFFING ANALYSIS PROCESS............................................................................................

5 EXPANDED ERO ANALYSIS PROCESS...........................................................................................................

5 ASSUM PTIONS..........................................................................................................................

e.................. 6 NEI 12 ASSUMPTIONS FOR STAFFING ANALYSIS..............................................................................

6 NEI 10 APPLICABLE ASSUM PTIONS..............................................................................................

7 OTHER ASSESSMENT ASSUMPT IONS.............................................................................................................

8 EVENT DESCRIPTION....................................................................................................................................

8 O N-SHIFT STAFFING ANALYSIS.....................................................................................................

9 ON-SHIFr STAFFING ANALYSIS PROCESS DETAILS.................................................................................

9 ON-SHIFT STAFFING ANALYSIS

SUMMARY

12 EXPANDED ERO RESPONSE ANALYSIS.........................................................................................

12 EXPANDED ERO RESPONSE ANALYSIS PROCESS DETAILS..................................................................... 12 EXPANDED ERO RESPONSE ANALYSIS

SUMMARY

14 PRO GRAM CO NTROLS...........................................................................................................................

26 EMERGENCY RESPONSE DRILL & EXERCISE PROGRAM.........................................................................

26 TRAINING...................................................................................................................................................

26 IMPLEMENTING GUIDANCE.........................................................................................................................

26 ON-SITE STAFF ABILITY TO M OVE BACK-UP EQUIPMENT.....................................................................

26 SECURITY CO NSIDERATIO NS..............................................................................................................

26 IMPLEMENTATION SCHEDULE FOR IDENTIFIED ENHANCEMENTS......................................

27

REFERENCES:

28 ATTACHMENT 1 ELAP STAFFING ASSESSMENT TABLES....................................................................

29 ATTACHMENT 2 QUALIFIED AUGMENTING AND EXPANDED ERO RESOURCES........................ 41 2

I P",

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 1

Introduction of Nuclear Regulatory Commission (NRC) Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-Ichi Accident, dated, March 12, 2012, requested Arizona Public Service (APS) to provide an assessment of the onsite and augmented Palo Verde Nuclear Generating Station (PVNGS) staff needed to respond to a large scale natural event meeting the conditions described in the 50.54(f) letter (Reference 1).

APS letter number 102-06523 (Reference 2), dated May 11, 2012, responded to the 50.54(f) letter and presented an alternate schedule to Reference 1 which stated that an on-site and augmented staffing assessment, considering all requested functions except those related to Near Term Task Force (NTTF) Recommendation 4.2 (Phase I staffing analysis), would be provided. This report provides the Phase 1 staffing analysis for PVNGS Units 1, 2, and 3. The analysis was conducted using the guidance in Nuclear Energy Institute (NEI) Technical Report 12-01, Revision 0, May 2012, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, NEI 10-05, Revision 0, June 2011, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, and NSIR/DPR ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants (References 3, 4, and 5 respectively).

An assessment was conducted to determine the resources required to respond to a three unit, Beyond Design Basis External Event (BDBEE), which results in an extended loss of altemating current (AC) power (ELAP) and impeded access to the site. This assessment included the numbers and composition of the augmented response personnel required to implement mitigation strategies and repair actions intended to maintain or restore functions of core cooling, containment, and spent fuel pool cooling for all three units. The on-shift staffing analysis considered applicable actions from current PVNGS procedures which include the Institute of Nuclear Power Operations (INPO) Event Reports (IER) related to Fukushima actions. The minimum on-shift staffing levels, as described in the PVNGS Emergency Plan, Revision 49, were then assessed to determine if there was an appropriate level of staffing to fill necessary positions as required by the assessment conducted.

3

4T APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 2

Executive Summary The following are the results of the assessment conducted to determine the ability of the emergency response organization (ERO) staff to respond to a large scale natural event. This assessment is based upon a current snapshot of the organization and staffing.

For the on-shift staffing, the Phase 1 assessment identified the following:

The minimum on-shift staffing, as defined in the PVNGS Emergency Plan, Revision 49, is sufficient to support the implementation of current PVNGS procedures simultaneously for Units 1, 2, and 3 in response to a BDBEE that results in an Extended Loss of AC Power (ELAP).

No conflicts, deficiencies, or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during the post event 0 to 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> "no site access" time period.

There were no unanalyzed tasks that required a time motion study.

Using existing procedures and strategies, the event response analysis did not result in conditions that necessitated entry into procedure 791S-9ZZ05, PVNGS Severe Accident Management Guidelines (SAMG).

For the expanded response capability, the Phase 1 assessment identified the following:

The number and composition of staffing necessary to support the Expanded Response Capability for the BDBEE as defined in NEI 12-01 (refer to section 6.2.2.1 for NEI 12-01, Table 3.1, Expanded Response Functions for Phase 1 Staffing Assessment).

The PVNGS staffing resources for the ERO are sufficient to implement all required coping strategies as required by NEI 12-01 guidance and to fill the expanded ERO functions.

2.1 Enhancements Identified The following enhancement actions were identified during the assessment:

Revise procedure 791S-9ZZ05, PVNGS Severe Accident Management Guidelines (SAMG), to allow any capable emergency worker to run fire hoses with direction provided by a qualified Fire Fighter.

Develop an expanded ERO staffing process that ensures the appropriate responders are activated to support the limited site access period (6-24 hours post-event). This process will enable the ERO to staff necessary expanded ERO positions for a BDBEE.

Develop a process to prioritize the order in which responders are transported to the site during the limited site access period. This process will enable the ERO to specify the order in which emergency workers are transported to the site during the limited site access period for a BDBEE.

Develop an implementing process to integrate the expanded response capability into existing augmented ERO, as described in the PVNGS NEI 12-01 Phase 1 Staffing Analysis, by establishing the ability to transition to unit-specific Outage Control Centers (OCCs) for each of the affected units. The OCCs would be directed by the Operations Support Center thereby maintaining the fundamental principle of Unity of Command 4

U APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment that is required by the National Incident Management System incident command protocol.

• Evaluate the PVNGS ERO drill and exercise program to address multi-unit events and expanded response capabilities and revise the program as determined to be appropriate.

Provide appropriate training to ERO members prior to implementing the integrated expanded ERO process.

3 Staffing Analysis Process Overview 3.1 On-Shift Staffing Analysis Process The PVNGS NEI 12-01 On-Shift Staffing Analysis (OSA) Phase 1 was conducted by a multi-disciplined team using site procedures to determine if tasks have been sufficiently analyzed for performance by the minimum on-shift staff as designated in the PVNGS Emergency Plan, Revision 49. Task areas analyzed include:

Event Mitigation (as specified in Emergency Operating Procedures (EOP), Abnormal Operating Procedures (AOP), and other site procedures)

Radiation Protection (RP) and Chemistry Technician functions (as specified in site response procedures)

Emergency Preparedness functions [as described in NUREG-0654 Table B-I (Reference 12) and NSIR/DPR ISG-01 (Reference 5)]

Existing strategies for responding to an extended loss of AC power (Station Blackout) affecting all on-site units were evaluated in the OSA. The staffing analysis addressed the ability of the on-shift staff to perform any required emergency response functions that would be degraded or lost prior to the delayed arrival of the augmenting Emergency Response Organization (ERO).

3.2 Expanded ERO Analysis Process The expanded ERO analysis was conducted using the guidelines in NEI 12-01 (Reference 3),

which provides recommended staffing considerations to assess the performance of unit-specific accident assessment and mitigation functions. PVNGS assessed the ability of the current ERO staff to perform expanded ERO functions.

5

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 4

Assumptions The Phase 1 staffing assessment assumptions were based on the guidance described in NEI 12-01 (Reference 3) and NEI 10-05 (Reference 4).

4.1 NEI 12 Assumptions for Staffing Analysis

1.

A large-scale external event occurs (earthquake) that results in:

all on-site units affected extended loss of AC power impeded access to the units

2.

Initially, all on-site reactors are operating at full power and are successfully shut down.

3.

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

4.

The event impedes site access as follows:

a.

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

b.

Post-event time: 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Limited site access. Individuals may access the site by walking, personal vehicle or via alternate transportation capabilities (e.g.,

private resource providers or public sector support).

c.

Post-event time: Greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - Improved site access. Site access is restored to a near-normal status and/or augmented transportation resources are available to deliver equipment, supplies and large numbers of personnel.

Each licensee should identify transportation and site access-enhancing methods in accordance with Section 3.9 of Reference 3, and include this information in the response to Staffing Information Request number 4 of Reference 1, Enclosure 5. The response to Staffing Information Request number 4 should also include an overview discussion of how the identified methods will be implemented following a BDBEE. The discussion of how the site access-enhancing methods will be implemented is contained in section 6.2.1.2 of this report.

A staffing assessment may utilize a "no site access" end time of less than six hours and greater than or equal to four hours, 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.). The PVNGS Phase 1 Staffing Analysis did not utilize a "no-site access" end time of less than six hours.

6

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment A staffing assessment may not utilize a "no site access" end time of less than four hours.

The PVNGS Phase 1 Staffing Analysis did not utilize a "no-site access" end time of less than four hours.

5.

On-shift personnel are limited to the minimum complement allowed by the site emergency plan.

6.

The Phase 1 staffing analysis uses the applicable actions from the Station Blackout (SBO) coping strategies in place at the time of the analysis.

a.

Such actions may include the shedding of non-essential battery loads, use of portable generators or batteries, opening room and cabinet doors, water/coolant conservation or makeup using portable equipment, etc.

b.

These actions do not include those associated with cross-tying AC power sources or electrical distribution busses between units since all on-site units are experiencing an ELAP.

7.

The Phase 1 staffing analysis includes the INPO Event Reports (IER) improvement actions already implemented at the time of the analysis.

4.2 NEI 10 Applicable Assumptions

1.

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

2.

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

3.

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

Performance of the function of the on-site security organization is regularly analyzed through other station programs and will not be evaluated here, unless a role or function from another major response area is assigned as a collateral duty.

5.

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

6.

The task of making a simple and brief communication has minimal impact on the ability to perform other assigned functions/tasks and is, therefore, an acceptable collateral duty for all positions. This assumption does not apply to emergency notification to an Offsite Response Organization (ORO) or the NRC.

7.

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.

7

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment

8.

The analyzed events occur during off-normal work hours at a time when augmented ERO responders are not at the site (e.g., during a backshift, weekend or holiday). The ERO augmentation time is based on the time of event declaration and 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.

For purposes of this analysis, and consistent with assumption 4 in section 4.1, 360 minutes (six hours) was used as the time period for the conduct of on-shift ERO response actions.

4.3 Other Assessment Assumptions

1.

Equipment credited in current coping strategies remains available for use (e.g., a non-seismic water tank).

2.

For purposes of assessing augmented staffing, it is assumed that the on-shift staff successfully performs Initial Phase coping actions as described in Reference 3. No Transition Phase actions involving the use of portable equipment are required in the first six hours, based on plant conditions.

3.

Offsite facilities and staging areas are available.

4.

Actions do not include those associated with use of the SBO Generators since all units are experiencing an ELAP.

4.4 Event Description The event conditions, as described by the assumptions listed above, result in a Site Area Emergency Classification Level (ECL). The ECL escalates to a General Emergency if it has been determined that AC power cannot be restored before the coping time has been exceeded. This scenario impacts all three units resulting in an ELAP.

Initial Conditions:

All three units in Mode 1 at 100 percent reactor power.

Abnormal Conditions:

None Scenario Events:

An offsite electrical transient occurs resulting in a loss of all offsite power.

The SBO Generators are not credited and none of the Emergency Diesel Generators (EDGs) can be synchronized to any Unit 1, 2, or 3 AC busses, resulting in a three-unit ELAP.

Notes:

This scenario constitutes a three unit event whereby restoration of any AC power source is not possible.

8

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 5

On-Shift Staffing Analysis 5.1 On-Shift Staffing Analysis Process Details The Phase 1 OSA was conducted in accordance with the guidance contained in NEI 12-01 and NEI 10-05. The assessment analyzed the ability of the on-shift staff to perform the required emergency response functions that may be degraded or lost prior to the arrival of the augmented ERO.

The task analysis was conducted using a table top procedural analysis and a simulated desktop run-through with PVNGS subject matter experts and an outside consultant.

Current PVNGS procedures were utilized to determine if tasks had been sufficiently analyzed for performance by the minimum on-shift staff. The guidance and documentation in NEI 12-01 and NEI 10-05 were used to document a review of the on-shift staffing actions. The following provides a summary of the process that was utilized.

5.1.1 On-Shift Analysis Methodology The OSA was performed using NEI 12-01, section 3, and NEI 10-05, section 2.2.

Each on-shift position from the Emergency Plan minimum Shift Staffing listed in section 5.1.2 of this report was entered in NEI 10-05 Table 1, On-Shift Positions, contained in Attachment 1 of this report. For position titles with more than one position holder, a unit number followed by a sequence number was assigned to each position (e.g., RO #1-1, RO #2-1, etc.). The site emergency plan reference that describes the requirement for the position to be on-shift was then entered into column 3 of Table 1 of Attachment 1. Using only the on-shift positions entered in Table 1 of Attachment 1, the following additional tables were completed by entering the shift position that fills a described role, or performs a specific function or task. These tables are also contained in Attachment I of this report.

NEI 10-05 Table 2 - Plant Operations & Safe Shutdown. Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable

" Table 2A - Procedural Task Timing (timeline of activities corresponding to Table 2)

NEI 10-05 Table 3 - Firefighting (not applicable for this event analysis)

NEI 10-05 Table 4 - Radiation Protection & Chemistry (time line of activities)

NEI 10-05 Table 5 - Emergency Plan Implementation Following completion of each of the above tables, each on-shift position assigned to the associated table was located on Attachment 1, Table 1. For each position, the table number and associated line number was then entered in column 4, "Role in Table#/Line#". Based on a review of the information contained in the table, there were no tasks identified that required a compensatory action or time motion study (TMS).

9

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 5.1.2 Minimum On-Shift Complement The shift staffing table below identifies the functional areas, position/function title, and emergency positions required to be on-shift and used as input to the staffing analysis. The on-shift personnel complement is the minimum required number and composition as described in the PVNGS Emergency Plan, Revision 49.

SHIFT STAFFING (Immediate Response) ed Site Site Staffing MAJOR FUNCTIONAL AREA POSITION/FUNCTION TITLE StaffingfUnit Shar ISt Shift Manager / Emergency Coordinator I

Control Room Supervisor I

Control Room Operators 2

ed Site Site Staffing firing Totals 3

6 1

Plant Operations and Assessment of Operational Aspects Fire Team Advisor Auxiliary Operators (AO) 4-12 Radiation Protection Monitor Shift Technical Advisor Satellite Technical Support Center Notification/

(STSC) Communicator (Covered by Communications Affected Unit)

ENS Communicator Chemistry Technician (OSC)

Electrical Technician (OSC)

Mechanical Technician (OSC)

I&C Technician (OSC)

Radiological Field Assessment Team (RFAT) Driver Support Staff Radiation Protection Technician (OSC)

Radiation Monitoring Technician RM or RP Technician (OSC)

Survey Qualified Position (OSC)

Security Section Leader/Director (TSC)

(not committed to armed response)

Plant Fire Department /Emergency Fire Suppression /

Medical Technicians (EMT) (At least 2 Rescue Operations and Fire Techs are EMT qualified by position qualifications)

Site Access Control and Personnel Accountability See AO above 1

1 2

2 1

1 2

2 3

3 2

2 1

1 3

3 1

1 1

1 1

1 Staffing per Staffing per Security Plan Security Plan 26 Shared Total 50 TOTALS 8/Unit =24 10"

APS Response to NRC Tier 1 NITF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 5.1.3 Tabletop Procedural Analysis of On-Shift Staffing for ELAP A tabletop review of on-shift actions for an ELAP for all three units was performed using the guidance and documentation in NEI 10-05, Section 2. This review included the identification of needed resources and the time required to complete identified actions for the first six hours of the ELAP. The review team consisted of the personnel listed in the table below.

Organization/Department Personnel (Position or Title)

Emergency Preparedness Director of Security and Emergency Preparedness Operations - SRO/SM Shift Manager Operations - STA Shift Technical Advisors Radiation Protection Radiation Protection Sr. Technical Advisor Chemistry Chemistry Sr. Technical Advisor Security Team Leader Nuclear Security Operations - Fire Brigade Response Sr. Program Advisor Engineering Sr. Engineer (Electrical/I&C)

Engineering Reactor Engineering Engineering Engineer HI Probabilistic Risk Assessment EP Consulting, LLC Consultant Prior to conducting the table top review, initial conditions and event assumptions were reviewed for basic understanding of the event. The senior reactor operator (SRO) reviewed emergency operating procedures (EOP) and other operating procedure actions and identified them to the team. Other team members, such as the RP and Chemistry Technicians, identified functions that would be required to support in-plant mitigation activities in accordance with PVNGS procedures. Emergency Plan functions were reviewed and assigned to the appropriate on-shift resources. Attachment 1, Table 1, identifies the resulting on-shift resources and their applicable actions. The following PVNGS procedures were referenced during the tabletop review:

EP-0900, EMERGENCY RESPONSE ORGANIZATION (ERO) POSITION CHECKLISTS EP-0901, CLASSIFICATIONS EP-0902, NOTIFICATIONS EP-0903, ACCIDENT ASSESSMENT EP-0904, ERO/ERF ACTIVATION AND OPERATION EP-0905, PROTECTIVE ACTIONS 40EP-9EO01, STANDARD POST TRIP ACTIONS 20SK-0SK08, COMPENSATORY MEASURES FOR LOSS OF SECURITY EQUIPMENT/EFFECTIVENESS 40EP-9EO 10, STANDARD APPENDICES 40EP-9EO08, BLACKOUT 40EP-9EO09, FUNCTIONAL RECOVERY 40AO-9ZZ23, LOSS OF SFP LEVEL OR COOLING 791S-9ZZ05, PVNGS SEVERE ACCIDENT MANAGEMENT GUIDELINES 11

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 5.2 On-Shift Staffing Analysis Summary The following are the results of the assessment conducted to determine the ability of the ERO staff to respond to a large scale natural event.

For the on-shift staffing, the Phase 1 assessment identified the following:

The minimum on-shift staffing, as defined in the PVNGS Emergency Plan Revision 49, is sufficient to support the implementation of current PVNGS procedures simultaneously for Units 1, 2, and 3 in response to a BDBEE that results in an ELAP.

No conflicts, deficiencies, or overlaps in functions or tasks required to be performed by on-shift operations and support personnel were identified during the post event 0 to 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> "no site access" time period.

There were no unanalyzed tasks that required a time motion study.

Using existing procedures and strategies, the event response did not result in conditions that necessitated entry into procedure 791S-9ZZ05, PVNGS Severe Accident Management Guidelines (SAMG).

6 Expanded ERO Response Analysis The augmenting ERO, which is currently established for a single-unit event and consists of five ERO teams plus pooled RP Technicians, was assessed to determine prioritization of augmented response capabilities during the period of limited site access for the post event time of 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The purpose of this assessment was to determine the ability of the augmenting ERO to perform the additional functions that would be required during a multi-unit BDBEE.

The assumption is that the augmented ERO for a multi-unit site would be challenged to effectively respond to a BDBEE that resulted in an ELAP 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 PVNGS is to enable the performance of unit-specific accident assessment and mitigation functions across multiple units.

6.1 Expanded ERO Response Analysis Process Details For purposes of assessing augmenting and expanded ERO staffing, it is assumed that the on-shift staff successfully performs Initial Phase, and any required Transition Phase, coping actions in accordance with Reference 3.

6.1.1 Augmenting ERO Response Analysis Methodology The current augmenting ERO roster positions and Emergency Plan required augmenting pooled RP technician positions were obtained from the PVNGS Emergency Plan, Revision 49, and entered into the table in this section titled, Augmenting ERO Positions Described in the Emergency Plan.

The PVNGS augmenting ERO consists of five teams staffed with qualified ERO members and pooled RP Technician positions as described in the table below:

12

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Augmenting ERO Positions Described in the Emergency Plan EMERGENCY TECHNICAL JOINT OPERATIONS STATE EMERGENCY OPERATIONS FACILITY SUPPORT CENTER INFORMATION SUPPORT CENTER OPERATIONS CENTER (EOF)

(TSC)

CENTER (JIC)

(OSC)

(EOC)

POSITION TITLE POSITION TITLE POSITION TITLE POSITION TITLE POSITION TITLE Offsite Technical Emergency Operations Emergency Coordinator JIC Manager OSC Manager Representative Director Assistant Emergency Ops Manager PVNGS Spokesperson Repairs Coordinator Operations Director Electrical Engineer Spokesperson ERF Communicator -

NAN Communicator Coordinator OSC Radiological Assessment Mechanical Engineer RP Group Leader Coordinator ERF Communicator -

JIC Engineering Director Reactor Analyst Research/Writing Coordinator Administrative Support HPN Communicator Security Director Distribution Services p

Coordinator 6 RP Techian Admin & Logistics RP Coordinator Coordinator Video/Photo Coordinator Dose Assessment Health ENS Communicator Physicist ERF Communicator - EOF Chemistry Coordinator Information Coordinator EC Technical Assistant IS Manager Engineering Manager Rad Assessment Maintenance Manager Communicator Security Manager Ops Advisor (STSC)

Systems Engineering ERF Communicator -

TSC Administrative Support Safety Analysis Engineer Administrative Support 6.1.2 Expanded ERO Response Analysis Methodology The expanded ERO analysis was conducted in accordance with NEI 12-01, section 3.4, which provides recommended staffing considerations for the postulated event to enable the performance of unit-specific accident assessment and mitigation functions at a multi-unit site.

PVNGS has been regularly conducting design basis multi-unit drills since June 2011. Insights and lessons learned from these multi-unit drills were used to assist with the development of the proposed enhancements.

13

APS Response to NRC Tier 1 NTrF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment The capability of the current ERO staffing at PVNGS to perform these expanded ERO functions was assessed as described below:

I. Number and composition of personnel required to perform the expanded ERO response functions of NEI 12-01, Table 3. 1, Expanded Response Functions for Phase 1 Staffing Assessment (see pages 18-21), were determined by performing a SAMG assessment. The purpose of this assessment was to identify the two strategies for each unit that require the greatest number of staff to implement within time periods compatible with successful performance and the corresponding total number and composition of staff to implement them.

2. Work areas for the expanded ERO were identified for the expanded response functions.

3. Transportation and access to the site were assessed to reasonably ensure that the expanded ERO may arrive onsite by the sixth hour of the event.

4. Position specific guidance was assessed in accordance with NEI 12-01, section 3.5.

6.2 Expanded ERO Response Analysis Summary Based on the results of the staffing assessment, sufficient augmenting ERO resources are available to perform the expanded ERO functions. The ability of the responding ERO members to implement coping strategies required after the end of the post event 0 to 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> "no site access" time period has been assessed and determined to be adequate. Refer to the Qualified Augmenting and Expanded ERO table in Attachment 2 of this report for additional documentation of the expanded ERO staffing resources.

Sufficient expanded ERO resources exist to implement the two most resource intensive SAMG strategies simultaneously in all three units.

The following enhancement actions were identified during the assessment:

Revise procedure 791S-9ZZ05, PVNGS Severe Accident Management Guidelines (SAMG), to allow any capable emergency worker to run fire hoses with direction provided by a qualified Fire Fighter.

Develop an expanded ERO staffing process that ensures the appropriate responders are activated to support the limited site access period (6-24 hours post-event). This process will enable the ERO to staff necessary expanded ERO positions for a BDBEE.

Develop a process to prioritize the order in which responders are transported to the site during the limited site access period. This process will enable the ERO to specify the order in which emergency workers are transported to the site during the limited site access period for a BDBEE.

" Develop an implementing process to integrate the expanded response capability into existing augmented ERO, as described in the PVNGS NEI 12-01 Phase 1 Staffing Analysis, by establishing the ability to transition to unit-specific Outage Control Centers (OCCs) for each of the affected units. The OCCs would be directed by the Operations Support Center thereby maintaining the fundamental principle of Unity of Command that is required by the National Incident Management System incident command protocol.

14

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Evaluate the PVNGS ERO drill and exercise program to address multi-unit events and expanded response capabilities and revise the program as determined to be appropriate.

Provide appropriate training to ERO members prior to implementing the integrated expanded ERO process.

6.2.1 Mobilization of Expanded Response Staffing Capability 6.2.1.1 Notification of the ERO The PVNGS ERO augmentation process consists of an all call / all respond expectation including the pooled RP Technicians. When the ERO notification system is activated, all qualified ERO members are contacted and expected to report if fit for duty.

Anytime the ERO becomes aware (e.g., direct observation, media posts, word-of-mouth) of an area-wide disaster (e.g., loss-of-grid, natural or man-made disaster, etc.) that may impact the safe operation of PVNGS and ERO pagers, cell phones, and home phones are being challenged or are not working, the ERO is expected to report to their respective Emergency Response Facility.

During this response, if the ERO members discover that the site is inaccessible due to the event (e.g., bridges damaged, roads blocked with debris, etc.) the ERO will report to the Energy Education Center as the Alternative Facility.

6.2.1.2 Site Access/Alternate Transportation Capability It is assumed that there is limited site access during the post-event time period of 6 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by roadway and ground transportation or air.

In accordance with the State of Arizona, Maricopa County Offsite Emergency Plan, dated December 2012, in the event of a release or potential for release of a radioactive plume from PVNGS, transportation and other resources may be required by emergency responders. The State Emergency Operations Center (EOC) Logistics Section is responsible for providing coordination and mobilizing transportation and non-radiological technical equipment, along with equipment operators and drivers needed for the government's offsite emergency response activities. State transportation equipment and operators will be used to augment local resources for the government's emergency response. All equipment will be available within six hours of the request (Reference 11).

In accordance with procedure EP-0900, Emergency Response Organization (ERO) Position Checklists, Appendix B, the Administrative/Logistics Coordinator will contact the Offsite Technical Representative at the State EOC if National Guard ground or air transportation is required to transport supplies, material, or ERO personnel to the site.

Roadway and ground access includes:

Major area access:

Interstate 10 (Eastbound): From California and the northwest Interstate 17: From Nevada and New Mexico via Highway 40 Interstate 10 (Westbound): From Tucson, New Mexico and Texas 15

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Local access:

Interstate 10 from the west or the east and then south on Wintersburg Rd.

From State Route 85: West on Old U.S. 80 and then west on Salome Highway to the north plant alternate access road.

Ground transportation:

PVNGS operates approximately 170 pool vans for ground transportation. These vans have pre-established protocols for pick-up or assembly locations. The use of personal vehicles is also anticipated. PVNGS is located on a large site (4,250 acres) and there are several access points from which to reach the Owner Controlled Area.

Air access can be provided from pre-identified staging areas that include:

Luke Air Force Base Phoenix-Mesa Gateway Airport Phoenix-Goodyear Municipal Airport Falcon Field Airport (Mesa)

Stellar Airpark - Chandler Pinal Airpark Airport / Evergreen Buckeye Municipal Airport (State of Arizona and PVNGS have a field office at this location)

Silverbell Army Heliport, Western Army National Guard Aviation Training Site (WAATS)

Available aircraft include active-duty and reserve National Guard resources which include medium duty (Blackhawk rotary-wing for personnel transport and medi-vac) and heavy-lift operations (i.e., transport large vehicles to the site via air). Additionally, an air ambulance is available with Air-Evac and Native American Air via Letters of Agreement delineated in the PVNGS Emergency Plan, Revision 49.

6.2.1.3 Work Areas for Personnel Performing Expanded Response Functions The sizes and capabilities of the work areas were determined to be sufficient. The Energy Education Center (EEC), which is located approximately 21 miles from the site, houses the EOF and JIC. The EEC is available as a staging facility and is provided with a diesel generator for back-up power to the facility during a loss of normal power.

For the on-site expanded response, there is an Outage Control Center located on the fourth floor of each Operations Support Building with sufficient size and capability for repair team staging and dispatch.

6.2.2 Expanded ERO Response Analysis 6.2.2.1 Expanded ERO Response Functions To be effective, the expanded response capability at PVNGS will 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.

16

APS Response to NRC Tier 1 NTTIF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 12-01, Table 3.1, Expanded Response Functions for Phase 1 Staffing Assessment, lists the emergency response functions identified by the NEI Beyond Design Basis Event Response Staffing Study Task Force as meeting these requirements. This table further provides key roles and staffing considerations for each expanded response function and specifies the staffing necessary to support the simultaneous deployment of emergency repair and corrective action teams to each affected unit.

The personnel required for implementation of strategies for a BDBEE may vary depending upon several factors. However, the process should facilitate a flexible response strategy that can be applied in a graded approach for unit specific response by the ERO personnel (i.e., the extent and type of BDBEE determines the associated event challenges, which then influences the assignment of unit specific expanded ERO response functions and unit specific resources).

17

APS Response to NRC Tier 1 NTFF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 12-01, Table 3.1 Expanded Response Functions for Phase 1 Staffing Assessment (Page 1 of 4)

Expanded Response Typical Key Roles and Staffing Considerations Position Performing this Resources Resources Function Location Function and Location Required Available Unit Response TSC

• Overall cognizance of the activities related to

• TSC Emergency Coordination implementation of repair and corrective actions, and Coordinator implementation of Transition Phase coping and Severe Accident Management (SAM) strategies for 3

5 an assigned unit

• One individual per unit; individuals should not be e Shift Outage Manager, assigned other functions each Unit OCC*

Operations TSC

• Provides coordination of Operations staff and

• TSC Operations Manager Coordination support for an assigned unit

• One individual per unit; individuals should not be e Operations Outage 3

5 assigned other functions Manager, each Unit OCC*

Maintenance TSC

• Provides coordination of Maintenance staff and 9 TSC Maintenance Coordination support for an assigned unit Manager

• One individual per unit; individuals should not be

• Maintenance Outage 3

5 assigned other functions Manager, each Unit OCC*

Engineering TSC

• Provides coordination of Engineering staff and e TSC Engineering Coordination support for an assigned unit Manager

• One individual per unit; individuals should not be

• Engineering Outage 3

assigned other functions Manager, each unit OCC*

• Note: This position does not exist under the current ERO. It will be developed for the expanded ERO. See Section 9, PVNGS Enhancement 5.

18

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 12-01, Table 3.1 Expanded Response Functions for Phase 1 Staffing Assessment (Page 2 of 4)

Expanded Response Typical Key Roles and Staffing Considerations Position Performing this Resources Resources Function Location Function and Location Required Available Engineering TSC

• One team for each unit to perform engineering

• Mechanical, Electrical, 9

15 Assessments assessments in support repair and corrective actions and System Engineer 9 Team composition (i.e., number and represented disciplines) as described in the emergency plan e Team may include personnel responsible for performing other functions for the same assigned unit Evaluation of Severe TSC

• One team for each unit to evaluate selection of

• TSC Engineering 6

Eng Mgr 5 Accident Management SAM strategies; team performs evaluations not Manager, and Shift STA 15 (SAM) Strategies done by Control Room personnel Technical Advisor 9 Team composition (i.e., number and represented disciplines) as described in governing site programs, procedures and guidelines

• Team may include personnel responsible for performing other functions for the same assigned unit Unit In-Plant Team OSC e Overall cognizance of on-site and in-plant teams 9 OSC Manager Coordination performing or supporting repair and corrective actions for an assigned unit

• Shift Outage Director,

• One individual per unit; individuals should not be each unit OCC*

assigned other functions

• Note: This position does not exist under the current ERO. It will be developed for the expanded ERO. See Section 9, PVNGS Enhancement 5.

19

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 12-01, Table 3.1 Expanded Response Functions for Phase 1 Staffing Assessment (Page 3 of 4)

Expanded Response Typical Position Performing this Resources Resources Function Location Key Roles and Staffing Considerations Function and Location Required Available Non-Licensed OSC

• Two individuals per unit to assist with e Auxiliary Operators, each 6

121 Operators implementation of repair and corrective actions unit OCC 9 Should not include members of the on-shift staff Mechanical OSC 9 Two individuals per unit to implement repair and

• Mechanical Maintenance 6

70 Maintenance Repair corrective actions Technician, each unit and Corrective Action

• Staffing may include an on-shift individual (i.e., 2 OCC individuals for a unit composed of 1 on-shift and 1 augmented)

Electrical Maintenance OSC 9 Two individuals per unit to implement repair and

• Electrical Maintenance 6

52 Repair and Corrective corrective actions Technicians, each unit Action

• Staffing may include an on-shift individual (i.e., 2 OCC individuals for a unit composed of I on-shift and 1 augmented)

I&C Repair and OSC

• Two individuals per unit to implement repair and

• I&C Technician, each 6

33 Corrective Action corrective actions unit OCC

• Staffing may include an on-shift individual (i.e., 2 individuals for a unit composed of 1 on-shift and I augmented) 20

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 12-01, Table 3.1 Expanded Response Functions for Phase 1 Staffing Assessment (Page 4 of 4)

Expanded Response Typical Position Performing this Resources Resources Function Location Key Roles and Staffing Considerations Function and Location Required Available Implementation of

OSC,

• Number and composition of personnel capable of 0

(6) Control Room 66 RO 83 SAM Strategies

TSC, simultaneous implementation of any 2 SAM Operators AO 115 Control strategies at each unit 0

(9) Auxiliary Operators Sec >3 Room Should not include personnel assigned to other (3) Security I&C 27 functions (e.g., emergency repair and corrective 0

(6) I&C Technicians Mech 64 actions); however, may include members of the on-(3) Mechanical FF 25 shift staff and personnel responsible for Maintenance R

57 implementation of Transition Phase coping Technicians strategies (18) Fire Fighters (21) RP Technicians

• Resources available exclude personnel used for repair and corrective actions.

21

APS Response to NRC Tier 1 NTrF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 6.2.2.2 On-Site Radiation Protection Technicians The equation in Section 3.5.1 of NEI 12-01 was used to determine the required number of on-site Radiation Protection (RP) Technicians (on-shift plus augmented ERO RP Technicians that perform on-site response functions) for PVNGS.

The equation in NEI 12-01, Section 3.5.1 is as follows:

RPTT = RPTcoP + RPTRCA + RPTNC Where:

RPTT

= Total required number of on-site RP Technicians.

RPTcop = Number needed to support implementation of the two extended loss of AC power coping strategies that require the greatest number of staff 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.

10 (RPTT) = 1 (RPTcop) + 6 (RPTRCA) + 3 (RPTNc)

RPTcop = 1 The RPTcop number is based upon the coping strategies of currently implemented EOPs and AOPs which were evaluated during the task analysis. Coping strategies of procedure 40AO-9ZZ23, Loss of SFP Level or Cooling, requires one RP Technician to monitor Fuel Building radiation levels assuming SFP boiling and loss of level occurs in only one unit approximately 11.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the beginning of the event (Reference 8).

RPTRCA = 6 Based on the number needed for repair and corrective actions, two are required per unit.

RPTNC = 3 The RPTNc number is based upon PVNGS Emergency Plan, Revision 49, which requires one RP Technician to perform dose assessment, one RP Technician to perform off site radiological monitoring activities and one RP Technician (Radiation Monitoring Technician) to perform in-plant area surveys as necessary which would preclude them from performing job coverage for extended loss of AC power coping, repair or corrective action teams.

The minimum number of RPTs required for expanded response is 10. To account for 24-hours of coverage, the total required number of RPTs is 20 based on 12-hour shifts.

Following a BDBEE, more than 20 RP Technicians are available to support performance of assigned emergency plan functions and the expanded response capability as listed in Attachment 2, Table 1 of this report, Qualified Augmenting and Expanded ERO Resources.

22

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment In the event of fuel damage, prevailing dose rates would likely require the site's RP Technician complement to be augmented with technicians from outside sources. The PVNGS Emergency Plan, Revision 49, identifies INPO, service companies, and contract support as non-licensee support, and in accordance with procedure EP-0900, Emergency Response Organization (ERO)

Position Checklists, Appendix M, the EOF Emergency Operations Director (EOD) is responsible for directing the Administrative/Logistics Coordinator to obtain any required offsite assistance.

6.2.2.3 Administrative Support Personnel PVNGS has administrative support personnel assigned to each Emergency Response Facility (ERF). PVNGS maintains five ERO teams with qualified administrative support ERO members on each team. This analysis determined the current assignments and locations of administrative support personnel are adequate for implementation of the expanded response capability.

6.2.2.4 Severe Accident Management Guideline Implementation The ELAP event analysis concludes that SAMG entry conditions would not be reached for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. However, for purposes of assessing the emergency response functions identified in Reference 3, the assessment considered the number and qualifications of SAMG implementation personnel required for simultaneous implementation of the two most task intensive SAMG strategies in Units 1, 2, and 3. This analysis relies on the use of the expanded ERO because implementation of the SAMGs is not assumed to occur during the post event 0 to 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> "no site access" time period. The following two SAMG strategies were determined to be the most resource intensive:

791S-9ZZ05, PVNGS Severe Accident Management Guidelines, Appendix 15, Depressurize Steam Generator (SG) and Feed With Fire Pump (FP) o 5A, Preferred Strategy Circulating Water (CW) Feed to SGs 791S-9ZZ05, PVNGS Severe Accident Management Guidelines, Appendix 12, Makeup to Refueling Water Tank (RWT) o 2A, CWMakeup to RWT Resource INumber per unit I Number per site IFunction Control Room Respond to recommendations Ontr 1

3 from the TSC for actions to take Operator and monitor indications Manual operate the Atmospheric Auxiliary Operator 1

3 Dump Valves Auxiliary Operator 1

3 Align feed water Connect required fire hose Auxiliary Operator 1

3 adapters Monitor Steam Generator Level I&C Technician 2

6 adPesr and Pressure Fire Fighters 3

9 Operate Fire Truck and fire hoses Job coverage for Auxiliary RP Technician 5

15 Operators, I&C Technician, Fire TOTAL 14 J

42 23

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Resource Number per unit Number per site Function Control Room Respond to recommendations Ontr 1

3 from the TSC for actions to take Operator and monitor indications Present for removal of RWT Security 1

3 Drain Valve (CHEVO 11) security barrier Mechanical Remove the blind flange and Maintenance 1

3 install the 6" flange at RWT Technician Drain Valve (CHEVO 11)

Fire Fighters 3

9 Operate Fire Truck and run fire hoses Monitor dose rates in the RP Technician 2Radwaste yards and job coverage for Fire Fighters, Mechanical Maintenance and Security TOTAL 8

24w Resource Number per unit Number per site Control Room 2

6 Operator Auxiliary Operator 3

9 Security 1

3 I&C Technician 2

6 Mechanical Maintenance 1

3 Technician Fire Fighters 5

15 RP Technician 7

21 TOTAL 22 66 24

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment The following enhancement was identified to address the current use of Fire Fighters for routing of hoses while implementing SAMG strategies.

Revise procedure 791S-9ZZ05, P VNGS Severe Accident Management Guidelines (SAMG). to allow any capable emergency workers to run fire hoses with direction provided by a Fire Fighter.

6.2.3 Activating the Expanded Response Capability In accordance with PVNGS Policy Guide 1503-01, Emergency Preparedness, all qualified ERO members that are fit for duty and capable of responding are required to respond to their Emergency Response Facility for an event classification of Alert or higher.

Procedure EP-0900, Emergency Response Organization (ERO) Position Checklists, Appendix B, Administrative/Logistics Coordinator Checklist has instructions to contact additional ERO support personnel for duty as directed by the Emergency Operations Director.

The following enhancements were identified to address expanded response capabilities:

Develop an expanded ERO staffing process that ensures the appropriate responders are activated to support the limited site access period (6-24 hours post-event). This process will enable the ERO to staff necessary expanded ERO positions for a BDBEE.

0 Develop a process to prioritize the order in which responders are transported to the site during the limited access period. This process will enable the ERO to specify the order in which emergency workers are transported to the site during the limited site access period for a BDBEE.

25

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 7

Program Controls 7.1 Emergency Response Drill & Exercise Program NEI 12-01 states that a licensee should determine if any changes are necessary to documents describing the emergency response drill and exercise program. In particular, standard objectives and extent-of-play may need to be revised to clarify the expected demonstration of functions that are dependent upon the type of scenario event or accident (i.e., within or beyond design basis, and number of affected units). For example, functions associated with an expanded response capability would not be demonstrated during a drill or exercise that involved a design basis accident affecting only one unit.

The current PVNGS list of master objectives contains a broad set of objectives that are capable of evaluating performance of multi-unit activities including SAMG. The following enhancement was identified to address expanded response capabilities:

Evaluate the PVNGS ERO drill and exercise program to address multi-unit events and expanded response capabilities and revise the program as determined to be appropriate.

7.2 Training The following enhancement was identified to address expanded response capabilities:

Provide appropriate training to ERO members prior to implementing the integrated expanded ERO process 7.3 Implementing Guidance The following enhancement was identified to address expanded response capabilities:

0 Develop an implementing process to integrate the expanded response capability into existing augmented ERO, as described in the PVNGS NEI 12-01 Phase 1 Staffing Analysis, by establishing the ability to transition to unit-specific Outage Control Centers (OCCs) for each of the affected units. The OCCs would be directed by the Operations Support Center thereby maintaining the fundamental principle of Unity of Command that is required by the National Incident Management System incident command protocol.

7.4 On-site Staff Ability to Move Back-up Equipment A description of the methodology that will be used to move back-up portable equipment (e.g.,

pumps, generators) from alternate on-site storage facilities to repair locations at each reactor will be provided in the Phase 2 staffing analysis.

8 Security Considerations Existing coping strategies do not anticipate the use of Security Officers to perform duties unrelated to their assigned roles. Security Officers will perform functions within their current roles such as monitoring and controlling site access and providing compensatory measures for any vital area doors that may need to remain open to facilitate improved room environmental conditions.

26

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 9

Implementation Schedule for Identified Enhancements PVNGS Enhancement Completion Date Revise procedure 791S-9ZZ05, PVNGS Severe Accident 12/31/2013 Management Guidelines (SAMG), to allow any capable emergency workers to run fire hoses with direction provided by a Fire Fighter.

2 Develop an expanded ERO staffing process that ensures the 10/31/2014 appropriate responders are activated to support the limited site access period (6-24 hours post-event). This process will enable the ERO to staff necessary expanded ERO positions for a BDBEE.

3 Develop a process to prioritize the order in which responders are 10/31/2014 transported to the site during the limited access period. This process will enable the ERO to specify the order in which emergency workers are transported to the site during the limited site access period for a BDBEE.

4 Provide appropriate training to ERO members prior to implementing 10/31/2014 the integrated expanded ERO process.

5 Develop an implementing process to integrate the expanded 10/31/2014 response capability into existing augmented ERO, as described in the PVNGS NEI 12-01 Phase 1 Staffing Analysis, by establishing the ability to transition to unit-specific Outage Control Centers (OCCs) for each of the affected units. The OCCs would be directed by the Operations Support Center thereby maintaining the fundamental principle of Unity of Command that is required by the National Incident Management System incident command protocol.

6 Evaluate the PVNGS ERO drill and exercise program to 10/31/2014 address multi-unit events and expanded response capabilities and revise the program as determined to be appropriate.

27

APS Response to NRC Tier 1 NT'rF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment 10

References:

1.

NRC letter from E. J. Leeds and M. R. Johnson, to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, dated March 12, 2012, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(J)

Regarding Recommendation 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

2.

APS letter number 102-06523, dated May 11, 2012, 60-Day Response to NRC Letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12. 2012

3.

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

4.

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

5.

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

6.

APS letter number 102-06529, dated June 8, 2012, 90-Day Response to Emergency Preparedness Information Requested by 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

7.

NRC letter from D. L. Skeen to Susan Perkins-Grew (NEI) dated May 15, 2012, U.S.

Nuclear Regulatory Commission Review of NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0.

dated May 2012

8.

APS letter number 102-06670, dated February 28, 2013, APS 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)

9.

Updated Final Safety Analysis Report (UFSAR) Revision 16

10.

PVNGS Emergency Plan, Revision 49, December 2012

11.

State of Arizona-Maricopa County Offsite Emergency Plan, December 2012

12.

NUREG 0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.

28

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment ELAP Staffing Assessment Tables 29

APS Response to NRC Tier 1 NTrF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 1 - On-Shift Positions Role in Compensatory Line On-Shift Position Emergency Plan Reference Action Table#/Line#

Reurd Required?

T2/L 1 T5/Ll T5/L2 1

Shift Manager #1-I PVNGS Emergency Plan Rev 49 Table 1 T5/1_

No T5/1_3 T5/L4 T51L7 2

Shift Manager #2-1 PVNGS Emergency Plan Rev 49 Table 1 T2/L2 No 3

Shift Manager #3-1 PVNGS Emergency Plan Rev 49 Table 1 T2/L3 No 4

Control Room Supervisor #1-1 PVNGS Emergency Plan Rev 49 Table 1 T2/L4 No 5

Control Room Supervisor #2-1 PVNGS Emergency Plan Rev 49 Table 1 T2/L5 No 6

Control Room Supervisor #3-1 PVNGS Emergency Plan Rev 49 Table I T2/L6 No 7

Control Room Operator #I-1 PVNGS Emergency Plan Rev 49 Table 1 T2/L9 No 8

Control Room Operator #1-2 PVNGS Emergency Plan Rev 49 Table I T2/L10 No 9

Control Room Operator #2-1 PVNGS Emergency Plan Rev 49 Table I T2/L 11 No 10 Control Room Operator #2-2 PVNGS Emergency Plan Rev 49 Table I T2/L12 No 11 Control Room Operator #3-1 PVNGS Emergency Plan Rev 49 Table 1 T2/L13 No 12 Control Room Operator #3-2 PVNGS Emergency Plan Rev 49 Table 1 T2/LI4 No T2/L15 13 Fire Team Advisor (RO)

PVNGS Emergency Plan Rev 49 Table I T3/L 1 No 14 Auxiliary Operator #1-1 PVNGS Emergency Plan Rev 49 Table I T2/L16 No T2/17 15 Auxiliary Operator #1-2 PVNGS Emergency Plan Rev 49 Table 1 T5/L6 No T5/L8 16 Auxiliary Operator #1-3 PVNGS Emergency Plan Rev 49 Table I T2/L18 No 17 Auxiliary Operator #1-4 PVNGS Emergency Plan Rev 49 Table I T2/LI9 No 18 Auxiliary Operator #2-1 PVNGS Emergency Plan Rev 49 Table 1 T2/L20 No 19 Auxiliary Operator #2-2 PVNGS Emergency Plan Rev 49 Table 1 T2/L21 No 20 Auxiliary Operator #2-3 PVNGS Emergency Plan Rev 49 Table I T2/L22 No 21 Auxiliary Operator #2-4 PVNGS Emergency Plan Rev 49 Table t T2/L23 No 30

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 1 - On-Shift Positions (continued)

Role in Compensatory Line On-Shift Position Emergency Plan Reference Table#ILine#

Action Required?

22 Auxiliary Operator #3-1 PVNGS Emergency Plan Rev 49 Table I T2/L24 No 23 Auxiliary Operator #3-2 PVNGS Emergency Plan Rev 49 Table 1 T2/L25 No 24 Auxiliary Operator #3-3 PVNGS Emergency Plan Rev 49 Table 1 T2/L26 No 25 Auxiliary Operator #3-4 PVNGS Emergency Plan Rev 49 Table 1 T2/L27 No T2/L7 26 Shift Technical Advisor #1 PVNGS Emergency Plan Rev 49 Table I T51L5 No 27 Shift Technical Advisor #2 PVNGS Emergency Plan Rev 49 Table I T2/L8 No T2/L28 28 ENS Communicator PVNGS Emergency Plan Rev 49 Table I T5/L9 No T5/LI2 29 Chemistry Technician #1 PVNGS Emergency Plan Rev 49 Table I T4/L9 No 30 Chemistry Technician #2 PVNGS Emergency Plan Rev 49 Table I T4/Ll0 No 31 Radiation Protection Monitor PVNGS Emergency Plan Rev 49 Table 1 T4/L5 No T4/L6 32 Radiation Protection Technician #1 PVNGS Emergency Plan Rev 49 Table I T2/L37 No T4/L4 33 Radiation Protection Technician #2 PVNGS Emergency Plan Rev 49 Table I T2/L38 No T4/L8 34 Radiation Protection Technician #3 PVNGS Emergency Plan Rev 49 Table 1 T2/L3 No T2/L39 35 Radiation Monitoring Technician PVNGS Emergency Plan Rev 49 Table 1 T4/L7 No 36 RM or RP Technician PVNGS Emergency Plan Rev 49 Table 1 T4/L1 No 37 Survey Qualified Position (OSC)

PVNGS Emergency Plan Rev 49 Table 1 T4/L2 No 38 RFAT Driver PVNGS Emergency Plan Rev 49 Table 1 T4/L I No T2/L29 39 Security Section Leader/Director PVNGS Emergency Plan Rev 49 Table 1 T5/L6 No 40 Electrical Technician #1 PVNGS Emergency Plan Rev 49 Table 1 T2/L31 No 41 Electrical Technician #2 PVNGS Emergency Plan Rev 49 Table 1 T2/L32 No 31

APS Response to NRC Tier 1 N7I'F Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 1 - On-Shift Positions (continued)

Role in Compensatory Line On-Shift Position Emergency Plan Reference Table#ILine#

Action Required?

42 Electrical Technician #3 PVNGS Emergency Plan Rev 49 Table 1 T2/L33 No 43 Mechanical Technician #1 PVNGS Emergency Plan Rev 49 Table 1 T2/L34 No 44 Mechanical Technician #2 PVNGS Emergency Plan Rev 49 Table 1 T2/L35 No 45 I&C Technician #1 PVNGS Emergency Plan Rev 49 Table 1 T2/L36 No 46 Fire/Rescue Staff #1 PVNGS Emergency Plan Rev 49 Table 1 T3/L2 No 47 Fire/Rescue Staff #2 PVNGS Emergency Plan Rev 49 Table 1 T3/L3 No 48 Fire/Rescue Staff #3 PVNGS Emergency Plan Rev 49 Table 1 T3/L4 No 49 Fire/Rescue Staff #4 PVNGS Emergency Plan Rev 49 Table 1 T3/L5 No 50 Fire/Rescue Staff #5 PVNGS Emergency Plan Rev 49 Table 1 T3/L6 No T2/L30 51 Plant Security PVNGS Emergency Plan Rev 49 Table 1 T5/L14 No 32

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 2 - Plant Operations & Safe Shutdown Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Line Generic Title/Role On-Shift Position Task Analysis Controlling Method I

Shift Manager Shift Manager #1-1 Operator Training 2

Shift Manager Shift Manager #2-1 Operator Training 3

Shift Manager Shift Manager #3-1 Operator Training 4

Unit Supervisor Control Room Supervisor #1 -I Operator Training 5

Unit Supervisor Control Room Supervisor #2-1 Operator Training 6

Unit Supervisor Control Room Supervisor #3-1 Operator Training 7

Shift Technical Advisor Shift Technical Advisor #1 Operator Training 8

Shift Technical Advisor Shift Technical Advisor #2 Operator Training 9

Reactor Operator Control Room Operator #1-1 Operator Training 10 Reactor Operator Control Room Operator #1-2 Operator Training 11 Reactor Operator Control Room Operator #2-1 Operator Training 12 Reactor Operator Control Room Operator #2-2 Operator Training 13 Reactor Operator Control Room Operator #3-1 Operator Training 14 Reactor Operator Control Room Operator #3-2 Operator Training 15 Fire Team Advisor (RO)

Fire Team Advisor Operator Training 16 Auxiliary Operator Auxiliary Operator #1-1 Operator Training 17 Auxiliary Operator Auxiliary Operator #1-2 Operator Training 18 Auxiliary Operator Auxiliary Operator #1-3 Operator Training 19 Auxiliary Operator Auxiliary Operator #1-4 Operator Training 20 Auxiliary Operator Auxiliary Operator #2-I Operator Training 21 Auxiliary Operator Auxiliary Operator #2-2 Operator Training 22 Auxiliary Operator Auxiliary Operator #2-3 Operator Training 23 Auxiliary Operator Auxiliary Operator #2-4 Operator Training 24 Auxiliary Operator Auxiliary Operator #3-1 Operator Training 25 Auxiliary Operator Auxiliary Operator #3-2 Operator Training 26 Auxiliary Operator Auxiliary Operator #3-3 Operator Training 27 Auxiliary Operator Auxiliary Operator #3-4 Operator Training 28 Communicator ENS Communicator Operator Training Emergency Preparedness 29 Security Director Security Director Training 30 Security Force Security Force (number not Security Training 30____Se____urity______Force

_____ designated)

SecurityTraining 33

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 2 - Plant Operations & Safe Shutdown (continued)

Minimum Operations Crew Necessary to Implement AOPs and EOPs, or SAMGs if applicable Line Generic Title/Role On-Shift Position Task Analysis Controlling Method 31 Electrical Technician Electrical Technician #1 Accredited Craft Training 32 Electrical Technician Electrical Technician #2 Accredited Craft Training 33 Electrical Technician Electrical Technician #3 Accredited Craft Training 34 Mechanical Technician Mechanical Technician #1 Accredited Staff Training 35 Mechanical Technician Mechanical Technician #2 Accredited Staff Training 36 I&C Technician I&C Technician #1 Accredited Staff Training 37 Radiation Technician Radiation Technician #1 Accredited Staff Training 38 Radiation Technician Radiation Technician #2 Accredited Staff Training 39 Radiation Technician Radiation Technician #3 Accredited Staff Training 34

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment TABLE 2A - Procedural Task Timing Procedure Steps/Actions Performance Time (Mins) After Procedure Implementation Proc/Step Task Resource 0-10 10-20 20-30 30-40 40-50 50-60 60-75 75-90 90-105 105-120 120-150 150-180 180-240 240-300 300-360 RO #1-2, RO #2-2, RO #3-2 Post Trip CRS #1-1 Actions Standard Post Trip CRS #2-1 40EP-Actions CRS #3-1 9E001 SM #1-1 SM #2-1 SM #3-1 STA #1 40EP-STA Post Trip STA #2 9E001 Actions all the all three units Loss of All AC Security Comp Sec. Force 20SP-OSK08 Measures All Three X

X X

X X

X Until 54x is Units implemented Safety Function 4OEP-Status Check 9E008 Acceptance Criteria STA #2 X

X X

X X

X X

X X

X X

X X

Step 1:

Satisfied (Every 15 minutes)

Step 2:

Classify Event SM #1-X X

EP- 0902 STSCComm.to AO#1-2 X

X X

X X

X X

X X

X X

X X

Control Room RO #1-I Step 4:

Initiate MSIS RO #2-1 X

RO #3-1 Notify Energy ENS X

Step 5 Control Center Comm.

Step 6 CAS Notification for Step____6 access to SBO RO#1-1 X

Dispatch AO to SBO AO#1-1 X

X X

X Step 7 Generator 35

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment TABLE 2A - Procedural Task Timing (continued)

Procedure Steps/Actions Performance Time (Mins) After Procedure Implementation Proc/Step Task Resource 0-10 10-20 20-30 30-40 40-50 50-60 60-75 75-90 90-105 105-120 120-150 150-180 180-240 240-300 300-360 Place Charging RO #1-1 Step 8 Pumps in Pull to RO #2-1 X

Lock RO #3-1 RO #1-1 Minimize RCS RO #2-1 Step 9 Leakage RO #3-1 RO #31-Maintain T cold to RO#1-2 Step 10 less than 570 RO #2-2 X

X X

X X

X X

X X

X X

X x

RO #3-2 Notify RP of CRS #1-1 Step 11 steaming to CRS #2-1 X

atmosphere CRS #3-1 Maintain SG Level RO#1-2 Step 12 (AFW Pump A)

RO #2-2 X

X X

X X

X X

X X

X X

X X

X X

RO #3-2 Appendix 80 -

RO #1-1 Step 13 Aligning SBO Gen.

RO #2-1 X

X X

X AligningRO

1. 3-1 Appendix 53 -

RO #1-1 Step 14 Aligning RO #2-1 X

X X

X Deenergized busses RO #3-1 1

1 AO #1-3 Appendix 98 - Open AO #2-3 X

Step 18 DoorsAO#-

X X

X X

XX AO #3-3 Appendix 31 - Local AO #1-4 Step 19 Monitoring of AO #2-4 X

X X

X X

X X

X X

X X

X Instrument Air AO #3-4 RO#1-1 Step 20 PA Announcement RO #2-1 X

X X

X X

X X

RO #3-1 RO#1-1 Step 21 Verify Natural Circ RO #2-1 X

X X

X X

X X

X X

X X

X RO #3-1 1

1 36

APS Response to NRC Tier 1 NT7F Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment TABLE 2A - Procedural Task Timing (continued)

Procedure Steps/Actions Performance Time (Mins) After Procedure Implementation Proc/Step Task Resource 0-10 10-20 20-30 30-40 40-50 50-60 60-75 75-90 90-105 105-120 120-150 150-180 180-240 240-300 300-360 RO #1-2 Step 22 Appendix 4-Verify RO #2-2 X

X X

X X

X X

X X

X X

X CST Inventory RO #3-2 RO #1-2 Step 23 Initiate Cooldown RO #2-2 X

X X

X X

X X

X X

RO #3-2 1

1 1_1_1_

Calculate Shutdown STA #1 Step 2 Margin STA #2 X

X X

X X

X X

X X

RO#1-2 Step 25 Lower SIAS Setpoint RO #2-2 X

X X

X X

X X

X x

RO #3-2 RO #1-2 Step 26 Break Vacuum RO #2-2 X

RO #3-2 Appendix 62 - Vent AO#1-2 Main Generator AO #2-2 X

X X

X AO #3-2 Appendix 8 - Boron RO #1-4 Step 28 Dilution Alarm RO #2-4 X

Check RO #3-1l_11__

Transition to Enter functional CRS #14 Functional rcvrpoedes CRS #2-1 Recovery recovery procedures CRS #3-1 X

X X

X X

Procedure (No additional STA #1 Procedure actions available)

STA #2 40EP-STA #2 9EO09 Assumptions:

1. CST designed to last for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> - Standard Appendix 4 of 40EP-9EO 10, STANDARD APPENDICES)

2. Class Batteries available for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - Engineering Calculation 1/2/3-EC-PK-0207

3. Spent Fuel Pool actions are unnecessary (Spent Fuel Pool time to boil is greater than 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />) 37

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 3 - Firefighting Line Performed By Task Analysis Controlling Method 1

Fire Team Advisor Operations Training 2

Fire Fighter #1 Fire Department Training 3

Fire Fighter #2 Fire Department Training 4

Fire Fighter #3 Fire Department Training 5

Fire Fighter #4 Fire Department Training 6

Fire Fighter #5 Fire Department Training Notes: No fire in this scenario. Resources may be used to assist other operations.

38

APS Response to NRC Tier 1 N'lTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 4 - Radiation Protection & Chemistry Performance Time Period After Emergency Declaration (minutes)

Line Position Performing Function/Task 105-180-240-300-0-10 10-20 20-30 30-40 40-50 50-60 60-75 75-90 90-105 10 120-150 150-180 240 3003 120 240 300 360 1

In-Plant Survey On-Shift Position:RM or RPT 2

On-Site Survey On-Shift Position: Survey Qualified (OSC)

Personnel Monitoring On-Shift Position:

4 Job Coverage -

On-Shift Position: RPT#2 Offsite Radiological Assessment On-Shift Position: RP Monitor 6

Other Site-Specific RP - Describe:

x x

x x

x x

x x

x x

x x

On-Shift Position: RPT#I Off Site Surveys Other Site-Specific RP - Describe:

On-Shift Position:RM Other Site-Specific RP - Describe:

8 On-Shift Position: RPT#3 Repair, Search and Rescue 9

Chemistry function/task #1 - Describe:

On-Shift Position:

10 Chemistry function/task #2 - Describe:

On-Shift Position:

Other Site-Specific - Describe:

On-Shift Position: RFAT Driver Notes:

Chem Techs report to STSC Unit 1 for assignment.

Chemistry sampling capability is unavailable until cooling water for sample coolers is restored.

Radiation Protection Technician (RPT)

Radiological Field Assessment Team (RFAT)

Radiation Monitoring Technician (RM) 39

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment NEI 10-05 TABLE 5 - Emergency Plan Implementation Line Function/Task On-Shift Position 1

Declare the Emergency Classification Level Shift Manager Unit 1 1 (ECL)*

SitMngrUi 2

Approve Offsite Protective Action Shift Manager Unit 1 I Recommendations*

3 Approve content of State/local notifications*

Shift Manager Unit 1 4

Approve extension to allowable dose limits*

Shift Manager Unit 1 5

Notification and direction to on-shift staff STA #1 (e.g., to assemble, evacuate, etc.)

6 ERO Notification STSC Communicator (AO #1-2)/ Security Director 7

Complete State/local notification form Shift Manager Unit 1 8

Perform State/local notifications STSC Communicator (AO #1-2) 9 Complete NRC event notification form ENS Communicator 10 Activate ERDS Not performed due to loss of AC power 11 Offsite radiological assessment See Table 4/Line 6 12 Perform NRC notifications ENS Communicator Perform other site-specific event notifications Performed by Emergency Operations Facility (EOF)

(e.g., INPO, ANI, etc.)

personnel 14 Personnel Accountability Plant Security

• Shift Manager non-delegable duty 40

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Qualified Augmenting and Expanded ERO Resources1

'The data for Qualified Augmenting and Expanded ERO Resources was obtained from the Training database on 4/30/13.

41

APS Response to NRC Tier 1 NTIF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Position Number Qualfied Qualification Emergency Operations Director or Asst 10 EP: EOF: EOD/ASST EOD Emergency Operations Director NAN Communicator 5

EP: EOF: NAN COMM Radiological Assessment Coord 5

EP: EOF: RAD ASSMT COORD Engineering Director 5

EP: EOF: ENG DIR HPN Communicator 6

EP: EOF: HPN COMM Admin & Logistic Coordinator 5

EP: EOF: ADMIN LOGISTIC CORD Dose Assessment Health Physicist 5

EP: EOF: DOSE ASSESSMENT HP EOF ERF Communicator 6

EP: EOF: ERF COMM Information Coordinator 4

EP: EOF: INFO COORD Information Services Manager 4

EP: EOF: IS MANAGER Rad Assessment Communicator 5

EP: EOF: RAD ASST COMM Security Manager 7

EP: EOF: SECURITY MANAGER System Engineering 5

EP: EOF: SYSTEMS ENG Emergency Coordinator 6

EP: TSC: EMERGENCY COORD Operations Manager 4

EP: TSC: OPS MGR Electrical Engineer 5

EP: TSC: ELEC ENG Mechanical Engineer 5

EP: TSC: MECH ENG Reactor Analyst 6

EP: TSC: RX ANALYST Security Director 29 EP: TSC: SECURITY DIR RP Coordinator 5

EP: TSC: RP COORD ENS Communicator 5

EP: TSC: ENS COMM Chemistry Coordinator 6

EP: TSC: CHEMISTRY COORD Emergency Coordinator Technical Asst 6

EP: TSC: EC TECH ASST Engineering Manager 5

EP: TSC: ENG MGR Maintenance Manager 5

EP: TSC: MNTC MGR Operations Advisor 6

EP: STSC: OPS ADV TSC Emergency Response Facility 5

EP: TSC: ERF COMM Communicator Safety Analyst Engineer 6

EP: TSC: SAFETY ANALYSIS ENG 42

APS Response to NRC Tier 1 NTTF Recommendation 9.3 Emergency Preparedness Phase 1 Staffing Assessment Position Number Qualified Qualification OSC Manager 4

EP: OSC: OSC MGR Repairs Coordinator 10 EP: OSC: REPARS COORD RP Group Leader 5

EP: OSC: RP GROUP LEAD OSC Emergency Response Facility 5

EP: OSC: ERF COMM Communicator Offsite Technical Rep 6

EP: EOC: OFFSITE TECH REP JIC Manager 6

EP: JIC: JIC MGR PVNGS Spokesperson 5

EP: JIC: PV SPOKESPERSON Spokesperson Coordinator 4

EP: JIC: SPOKESPERSON COORD JIC Emergency Response Facility 5

EP: JIC: ERF COMM Communicator Research/Writing Coordinator 5

EP: JIC: RESEARCH CH/WRITING CR Distribution Services Coordinator 5

EP: JIC: DIST SERVICES COOR JIC Video/Photo Coordinator 5

EP: JIC: VIDEO/PHOTO COORD Emergency Response Facility 20 EP: ERF ADMIN Administrative Support Staff Mechanic E-Plan 70 MECH: EPLAN Electrician E-Plan 52 ELEC: EPLAN I&C Technician E-Plan 33 IC: EPLAN Advanced Radiation Protection RP: ADVANCED RP TECH Technician Auxiliary Operator 121 OPS: AO-9 Fire Fighter E-Plan 25 FIRE DEPf./E-PLAN Shift Technical Advisor 15 OPS: STA Chemistry Tech E-Plan 21 CHEM: EPLAN ERO System Engineering 12 General Engineering Qualifications*

Civil Engineering 7

General Engineering Qualifications*

Mechanical Engineering 26 General Engineering Qualifications*

Electrical Engineering 16 General Engineering Qualifications*

Notes:

These positions do not have specific EPLAN training but have engineering qualifications that can be used for event response 43