ML15106A204

April 22, 2015, Meeting with Southern Nuclear Company, Slide Presentation

ML15106A204
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	04/22/2015
From:	Southern Co, Southern Nuclear Operating Co
To:	Division of Operating Reactor Licensing
Williams S
Shared Package
ML15106A195	List: ML15106A204 ML15106A223 ML15106A265 ML15106A361
References
Download: ML15106A204 (11)

Text

Southern Nuclear Operating Company (SNC) Standard Emergency Plan (SEP)

SNC/Nuclear Regulatory Commission (NRC) Pre-submittal Interaction April, 22, 2015

Agenda

• July 2014 Interaction Recap

• Change in Submittal Scope

• Status of Fleet SEP

• Construction/Testing Schedule Milestones Update

• License Amendment Scope and Schedule

• Key Features of the Submittal

• Effect on EP Inspection Tests Analyses and Acceptance Criteria (ITAAC)

• Licensing Considerations

• Questions/Feedback 2

July 2014 Interaction Recap

• Described current status of and history of Vogtle 3-4 emergency plan

• Discussed options for combining the two Vogtle emergency plans into a single plan

• Agreed that the option of adopting the fleet SEP on a limited basis to include Vogtle only was the option of choice

• Agreed that future interactions would be desirable 3

Change in Submittal Scope

• Initial submittal to include SNC SEP base for all SNC plants, and annexes for Farley, Hatch, Vogtle 1-2 and Vogtle 3-4

• Vogtle 1-2 annex will be submitted using the current Technical Support Center (TSC) and Operations Support Center (OSC)

• Vogtle 3-4 will be submitted using the Vogtle common TSC and OSC

• When approved and SNC personnel trained on new SNC Fleet SEP then Farley, Hatch, Vogtle 1-2 and Vogtle 3-4 will implement

• Impacts to Emergency Operations Facility (EOF) and EOF staffing require all SNC plants to implement concurrently, with exception of Vogtle 3-4

• A separate License Amendment Request (LAR) will be submitted for Vogtle 1-2 to transition to the common TSC and OSC

• The LAR for use of the common Vogtle TSC and OSC by all Vogtle units will be implemented prior to 10 CFR 52.103(g) 4

Status of Fleet SEP

• Fleet SEP drafted

- Includes all emergency plan information common to SNC plants (Farley, Hatch and Vogtle)

• EOF

• Communication plan

• Annexes for Farley, Hatch, Vogtle 1-2 and Vogtle 3-4 drafted

- Include EP information unique to each site

- Much information for each Vogtle annex identical, but separate information for treatment of Emergency Action Level (EALs) and associated technical bases 5

VEGP 3 and 4 EP Related Construction/Testing Schedule Milestones

• VEGP 3 fuel load

• VEGP 10 CFR 52.103(g) finding - EP required to be followed and effectiveness maintained (10 CFR 50.54(q)(2))

• VEGP 3 exercise - completion of EP ITAAC

• VEGP TSC and OSC available for training/drills

• Final EALs submitted for approval - 180 days before fuel load -

License Condition (Following SCANA approach)

• Staffing assessment submitted - 180 days before fuel load - License Condition (Staffing analysis completed December 2014)

• Implementing procedures submitted - 180 days before fuel load -

ITAAC 6

License Amendment Scope and Schedule

• Amend all eight licenses to incorporate a SNC SEP with site specific annexes

• Applies the common TSC and OSC to Vogtle 3-4

• Includes conforming changes to affected EP ITAAC

• Submittal planned for June 2015

• Requesting approval by June 2016

• Submit LAR for Vogtle site common TSC and OSC in June 2016 immediately following approval of SNC SEP

• Implement SNC SEP for entire SNC Fleet (except Vogtle 3-4) in June 2017

• Implement Common TSC and OSC for Vogtle site at or near the 103(g) for Unit 3 7

Key Features of the Submittal

• Conforms to NUREG 0654 Rev. 1

• Removes unnecessary detail

• Leverages fleet standard procedures and processes

• Requests a 90 minute augmentation time

• Revises EOF organization to include Emergency Director

• Standardizes on-shift and augmented ERO for the SNC fleet with minor exceptions for Vogtle 3-4 8

Effect on EP ITAAC

• Some conforming changes to EP ITAAC required

- 90 minute augmentation time

- Use of tone alert radio as back-up notification method

• SEP refers to implementing procedures as Emergency Plan Implementing Procedure (EPIPs)

• Existing emergency plan uses the term Emergency Implementing Procedure (EIP)

• EP ITAAC will retain the EIP nomenclature 9

Licensing Considerations Submittal contents

• LAR Considerations

- One letter with separate enclosures for Farley, Hatch, Vogtle 1-2 and Vogtle 3-4

- Separate enclosures with change justification matrices for Farley, Hatch, Vogtle 1-2 and Vogtle 3-4

- Separate enclosures with ERO Augmentation Technical Document for Farley, Hatch, Vogtle 1-2 and Vogtle 3-4

• Separate LAR for Vogtle site common TSC and OSC submitted after NRC approval of SNC SEP 10

Questions/Feedback 11