ML16060A328
Text
Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.4 40 Inverness Center Parkway SOUTH ERN .Post Office Box 1295 Birmingham, AL 35242 NUCLEAR Tel 205.992.7872 Fax 205.992.7601 A SOUTHERN NL-16-0169 FEBl 1 2016 10 CER 50.90 Docket Nos.: 50-32 1 50-348 50-424 52-025 50-366 50-364 50-425 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2;Edwin I. Hatch Nuclear Plant Units 1 and 2;Vogtle Electric Generating Plant Units 1 and 2;Vogtle Electric Generating Plant Units 3 and 4 Resp~onse to First Request for Additional Information Regardingq Standard Emergqency Plan Ladies and Gentlemen:
By letter dated August 31, 2015 (NL-1 5-1392), Southern Nuclear Operating Company (SNC) requested license amendments (LARs) for approval of a fleet standard emergency plan for Edwin I. Hatch Nuclear Plant Units 1 and 2, Joseph M. Farley Nuclear Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 1, 2, 3 and 4 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15246A045).
By letter dated December 2, 2015, the U.S. Nuclear Regulatory Commission (NRC) requested additional information (ADAMS Accession Number ML 15334A009).
Specifically, SNC proposed to change the current Joint Information Centers (JICs)described in the respective site emergency plans to incorporate an SNC fleet standard approach for a JIC/Joint Information System (JIS). The NRC's request for additional information (RAI), in regards to the SNC LAR Enclosure 3, "Corporate Joint Information Center Description and Technical Evaluation," was issued to support the NRC staff's Continued technical review of the proposed change.The NRC RAI and the SNC response is provided below. Additional information, including revisions to SNO documents submitted on August 31, 2015 that support the SNC response to the RAI, is attached in the enclosures.
SNC is notifying the states of Georgia and Alabama of this response to the NRC RAI by transmitting a copy of this letter and enclosures to the designated state official.This letter contains no new regulatory commitments.
If you have any questions, please contact Ken McElroy at (205) 992-7369. --
U. S. Nuclear Regulatory Commission NL-1 6-0169 Page 2 This letter contains no new regulatory commitments.
If you have any questions, please contact Ken McElroy at (205) 992-7369.Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.Respectfully sub :itted, C. R. Pierce 'Regulatory Affairs Director 'CRP/EFB/lac Sworn to and subscribed before me this JZiday , 2016.v /NtaryPublic My commission expires: V -2 "'o(" Attachment 1 -NRC RAI and SNC Response
Enclosures:
- 1. Evaluation of the Proposed Changes -LAR for the Adoption of a Standard Emergency Plan for the SNO Fleet (Marked-up pages)2. SNC Standard Emergency Plan. (Marked-up pages)3. Corporate Joint Information Center Staffing -Detailed Description and Technical Evaluation. (Deleted)4. Farley Staffing -Detailed Description and Technical Evaluation. (Marked-up pages)5. Farley Standard Emergency Plan Annex. (Marked-up pages)6. Farley Justification Matrix (Marked-up pages)7. Hatch Staffing -Detailed Description and Technical Evaluation. (Marked-up pages)8. Hatch Standard Emergency Plan Annex (Marked-up pages)9. Hatch Justification Matrix. (Marked-up pages)10. Vogtle (Units 1 and 2) Staffing -Detailed Description and Technical Evaluation. (Marked-up pages)11. .Vogtle (Units 1 and 2) Standard Emergency Plan Annex. (Marked-up pages)12. Vogtle (Units 1 and 2) Justification Matrix. (Marked-up pages)
U. S. Nuclear Regulatory Commission NL-16-0169 Page 3 13. Vogtle (Units 3 and 4) Staffing -Detailed Description and Technical Evaluation.(Marked-up pages)14. Vogtle (Units 3 and 4) Standard Emergency Plan Annex. (Marked-up pages)15. Vogtle (Units 3 and 4) Justification Matrix. (Marked-up pages)16. Evaluation of Proposed Changes -LAR for the Revision to Vogtle 3 and 4 Emergency Planning ITAAC. (No changes)17. Vogtle (Units 3 and 4) Revision to Unit 3 COL Appendix C -Proposed Changes-Markups. (No changes)18. Vogtle (Units 3 and 4) Revision to Unit 4 COL Appendix C -Proposed Changes-Markups. (No changes)19. Off-site Response Organizations
-Letters of Consultation and Concurrence (New Letters Replacing Originals)
- 20. SNC Standard Emergency Plan LAR (Updated clean version of Enclosures 1-19)cc: Nuclear Reciulatory Commission Ms. C. Haney, Regional Administrator Ms. J. Uhle, Director, Office of New Reactors Mr. M. Delligatti, Deputy Division Director, DNRL Mr. L. Burkhart, Branch Chief, LB4, DNRL Mr. M. E. Ernstes, Branch Chief, DRP, RII Mr. J. McKirgan, Branch Chief Mr. W. C. Gleaves Mr. T. E. Chandler Ms. P. Braxton, Resident Inspector
-Vogtle 3 & 4 Mr. R. E. Martin, NRR Senior Project Manager -Vogtle 1 & 2 Mr. S. A. Williams, NRR Project Manager -Farley Mr. M. D. Orenak, NRR Project Manager -Hatch Mr. C. Patel, NRO Project Manager -Vogtle 3 & 4 Mr. P. Kallan, Senior Project Manager -Vogtle 3 & 4 Mr. B. M. Bavol, Project Manager -Vogtle 3 & 4 Ms. R. Reyes, Project Manager -Vogtle 3 & 4 Ms. M. A. Sutton, Project Manager -Vogtle 3 & 4 Mr. D. H. Hardage, Senior Resident Inspector
-Hatch Mr. L. M. Cain, Senior Resident Inspector-Vogtle 1 & 2 Mr. P. K. Niebaum, Senior Resident Inspector-Farley Mr. J. D. Fuller, Senior Resident Inspector, Vogtle 3 & 4 Mr. C. B. Abbott, Resident Inspector
-Vogtle 3 & 4 Ms. S. Temple, Resident Inspector
-Vogtle 3 & 4 Alabama Department of Public Health Dr. T. M. Miller, State Health Officer State of Georgia Mr. J. H. Turner, Director-Environmental Protection Division U. S. Nuclear Regulatory Commission NL-1 6-01 69 Page 4 Blind Copyv List (without enclosures unless noted): Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President
& CEO Mr. D. G. Bost, Executive Vice President
& Chief Nuclear Officer Mr. J. T. Gasser, Executive V.P. Operational Readiness
-Vogtle 1-4 Mr. D. L. McKinney, Vice President, Nuclear Development.
-Vogtle 3-4 Mr. M. D. Rauckhorst, Vice President, Construction
-Vogtle 3-4 Mr. D. H. Jones, Vice President Technical Compliance
-Vogtle 3-4 Ms. K. D. Fili -Vice President
-Operational Readiness Ms. C. A. Gayheart, Vice President
-Farley Mr. D. R. Vineyard, Vice President
-Hatch Mr. B. K. Taber, Vice President
-Vogtle 1-2 Mr. D. R. Madison, Vice President
-Fleet Operations Mr. M. D. Meier, Vice President
-Regulatory Affairs Mr. B. J. Adams, Vice President
-Engineering Mr. C. R. Pierce, Regulatory Affairs Director -Fleet Mr. B. H. Whitley, Regulatory Affairs Director -Nuclear Development Mr. M. J. Yox, Regulatory Affairs Director -Vogtle 3-4 Ms. B. L. Taylor, Regulatory Affairs Manager -Farley Mr. G. L. Johnson, Regulatory Affairs Manager -Hatch Mr. G. W. Gunn, Regulatory Affairs Manager -Vogtle 1-2 Mr. W. A. Sparkman, Licensing Manager -Nuclear Development Mr. T. W. Yelverton
-Commercial Director -Vogtle 3-4 Mr. J. C. Hasweli, Regulatory Manager -Vogtle 3-4 Ms. K. A. Roberts, Licensing Supervisor
-Vogtle 3-4 Mr. D. L. Fulton -Nuclear Development Environmental Manager Mr. T. R. Takats -Engineering Supervisor Mr. J. P. Redd -Licensing Supervisor RTYPEs: CFA04.054; CHA02.004; CVC7000; VND.LI.L00 (w/enclosures)
File AR.01 .02.06 (w/enclosures)
Oglethorpe Power Corporation Mr. M. W. Price Mr. Ms. K. T. Haynes Ms. A Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros U. S. Nuclear Regulatory Commission NL-16-0 169 Page 5 Westinqhouse Electric Company. LLC Mr. R. Easterling Mr. J. W. Crenshaw Mr. C. D. Churchman Mr. L. Woodcock Mr. P. A. Russ Mr. G. F. Couture Mr. M. Y. Shaqqo Ms. K. Stoner Mr. C. A.Castell Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham Mr. R Grumbir, APOG Mr. J. R. Bouknight, South Carolina Electric & Gas Company Mr. D. Kersey, South Carolina Electric & Gas Company Mr. B. Kitchen, Duke Energy Mr. S. Franzone, Florida Power & Light Ms. A. Rice, South Carolina Electric & Gas Company ATTACHMENT 1 To NL-16-0169 SNC Response to NRC RAI-1 Fleet Standard Emergency Plan NRC RAI-1 The letters provided in Enclosure 19, "Off-site Response Organizations Letters of Consultation and Concurrence," provides the following "boilerplate language" describing the level of changes discussed with applicable State and local governmental authorities:
This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.Please provide documentation that the offsite response organizations have reviewed and concur on the proposed changes with respect to the relocation of the JICs and its potential impact on their respective radiological emergency preparedness (REP) plans. Additionally, please identify whether other proposed changes to the respective site emergency plans were evaluated for their impact the State and local response organizations ability to effectively implement their FEMA-approved REP plans, specifically in regards to licensee interface and coordination with State and local response organizations.
If so, please provide evaluation performed and documentation regarding discussions with affected State and local response organizations used in making this determination.
[NOTE: Per 10 CFR 50/54 (s) (3), any change to the licensee's emergency plan that impacts or has the potential to impact State and local REP plans will be provided to FEMA for review to verify that continued reasonable assurance exists that State and local emergency plans can be implemented.
As such, an adequate evaluation and documentation of coordination with offsite response organization needs to be provided as part of licensee's submittal.]
SNC Response SNC performed a detailed review of the relevant off-site response organization (ORO) emergency plans to identify potential impacts resulting from the proposed SNC fleet standard emergency plan. Only minor editorial changes related to the SNC emergency plan document titles were identified.
Nonetheless, SNC held additional discussions with the OROs to provide further clarification and answer any questions.
Specifically, in addition to covering the specific changes that would be needed to the ORO emergency plans, SNC and the OROs discussed details of the personnel interfaces and coordination necessary to effectively implement the plans during an emergency.
The OROs concur there are no adverse impacts to their respective emergency plans from the proposed SNC A1-1 ATTACHMENT 1 To NL-16-0169 SNC Response to NRC RAI-1 Fleet Standard Emergency Plan fleet standard emergency plan and have responded via letters to this effect.These letters of concurrence are provided in Enclosure 19 and replace the ORO concurrence letters originally submitted.
Savannah River Site (SRS) has elected not to provide a follow-up response to their initial acknowledgement letter in keeping with SRS's position that, as a Department of Energy facility, a simple"acknowledgement" letter is appropriate rather than a "concurrence" letter.The August 31, 2015 SNC submittal contained provisions for designating the Alabama Power Company and Georgia Power Company Corporate Media Centers (CMCs) located in Birmingham, Alabama and Atlanta, Georgia respectively as the official Joint Information Center (JiC) until such time as the near site JIC could be established.
This proposal included prescribing a minimum activation time for this facility of 75 minutes. Moving the JIC to the CMC locations was intended to facilitate meeting the 75 minute minimum staff augmentation time.The SNC proposal to add a minimum staff augmentation time was predicated on proposed changes to NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. However, based on recent input from NRC staff, the current version of NUREG-0654 (Revision 1), which does not require a minimum staff augmentation time, will continue to be an acceptable means of meeting the requirements of 10 CFR 50.47 even after issuance of the proposed changes to NUREG-0654 (Revision 2).Consequently, SNC has decided not to propose these changes to the JIC as originally described to the NRC in Enclosure 3 of the SNC submittal on August 31, 2015. SNC's practice for coordination and dissemination of information to the public as provided in the current SNC emergency plans and the State and County emergency plans via the near site JICs will remain unchanged in the SNC fleet standard emergency plan. Accordingly, SNC has enclosed the corresponding changes, including marked-up pages, to the original enclosures and has enclosed a clean revised copy of the entire submittal in Enclosure 20 for convenience.
A few minor editorial and typographical corrections are also included.
These revisions reflect the deletion of the 75 minute JIC augmentation commitment, the re-assignment of the SNC Spokesperson and Technical Assistant from the EOF to the JIC as described in the current emergency plans, and the description of the JIC and CMC as separate facilities.
A1-2 Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2;Edwin I. Hatch Nuclear Plant Units 1 and 2;Vogtle Electric Generating Plant Units 1 and 2;Vogtle Electric Generating Plant Units 3 and 4 Enclosure 1 Evaluation of the Proposed Changes (Marked -up pages)
Evaluation of Proposed Changes Table of Contents 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION and TECHNICAL EVALUATION
- 3. REGULATORY EVALUATION
3.1 Applicable
Regulatory Requirements
3.2 Precedent
3.3 No Significant Hazards Consideration Determination
- 4. STATE CONSULTATION
- 5. ENVIRONMENTAL ASSESSMENT El-i F Enclosure 1 to NL-16-0169 Evaluation of the Proposed Changes 1.
SUMMARY
DESCRIPTION Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests amendments to the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 3 and 4.Specifically, the proposed changes would revise each plant's license in order to adopt a fleet SNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishes an updated licensing basis for the SNO operating plants that complies with current NRC regulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.By standardizing emergency plans, SNC will make improvements to the fleet by increasing consistency of organizations, duties and responsibilities, procedures, and training.
SNC also will align the plants using consistent standards and definitions.
Among the more notable proposed changes are a) the adoption of a standard staff augmentation time period of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b) changes in staffing numbers, and c) changes in staffing and, d) .... ncol÷d"io of tho oint,,, Informatio Although SNC has implemented significant improvements in overall staffing, procedures, training, and technology since the NRC's initial approval of the plant emergency plans, SNC has conservatively evaluated the proposed changes as reductions in effectiveness requiring NRC approval.2. DETAILED DESCRIPTION and TECHNICAL EVALUATION The SNC SEP is attached as Enclosure
- 2. A-The detailed description and technical evaluation of the Corporate Joint Information Center sformerly documented in Enclosure 3 has been deleted because SNC has determined that no changes are necessary.
Detailed descriptions and technical evaluations of the site emergency plan staffing changes are documented in Enclosures 4 (Farley), 7 (Hatch), 10 (Vogtle 1-2), and 13 (Vogtle 3-4).The SNC Standard Emergency Plan is supplemented by plant-specific annexes documented in Enclosures 5 (Farley), 8 (Hatch), 11 (Vogtle 1-2), and 14 (Vogtle 3-4).A Justification Matrix for each plant identifies the wording in the current plant emergency plan sections, the revised wording and location in the Standard Emergency Plan or Annex, and the reasoning behind or justification for the change. The matrices are documented in Enclosures 6 (Farley), 9 (Hatch), 12 (Vogtle 1-2), and 15 (Vogtle 3-4).At the end of each Justification Matrix are two additional tables for the Site On-Shift and Site Augmented Emergency Response Organization that compare the number of persons performing major tasks in each major functional area with the guidance in NUREG 0654, the emergency plan first approved by the NRC, the current emergency plan, and the proposed SNC Standard Emergency Plan.El1-2 Enclosure i to NL-1 6-01 69 Evaluation of the Proposed Changes 3. REGULATORY EVALUATION
3.1 Applicable
Regulatory Requirements The SNC Standard Emergency Plan establishes an updated licensing basis for the SNC plants that complies with current NRC regulations in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. In addition, the SNC plan complies with NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.3.2 Precedent The SNC SEP was modeled generally after the Exelon Standardized Radiological Emergency Plan. (See ML1 3200A1 24.) The NRC has previously approved increases in staff augmentation times. (See, e.g., ML112450464.)
3.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests amendments to the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 3 and 4.Specifically, the proposed changes would revise each plant's license in order to adopt a fleet SNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishes an updated licensing basis for the SNC operating plants that complies with current NRC regulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.By standardizing emergency plans, SNC will make improvements to the fleet by increasing consistency of organizations, duties and responsibilities, procedures, and training.
SNC also will align the plants using consistent standards and definitions.
Put simply, the changes will make SNC's emergency plan easier to follow and understand.
Among the more notable changes are a) the adoption of a standard staff augmentation time period of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b)changes in staffing numbers, and c) changes in staffing duties, and d) consolidation of tho Joint Information Contor. Although SNC has implemented significant improvements in overall staffing, procedures, training, and technology since the NRC's initial approval of the plant emergency plans, SNC has conservatively evaluated these changes as reductions in effectiveness requiring NRC approval per 10 CER 50.54(q).SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92,"Issuance of amendment," as discussed below: El1-3 Enclosure i to NL-16-0169 Evaluation of the Proposed Changes 1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response:
No.The proposed changes have no effect on normal plant operation or on any accident initiator or precursors, and do not impact the function of plant structures, systems, or components (SSCs).The proposed changes do not alter or prevent the ability of the emergency response organization to perform its intended functions to mitigate the consequences of an accident or event. The ability of the emergency response organization to respond adequately to radiological emergencies has been demonstrated as acceptable through a staffing analysis as required by 10 CFR 50 Appendix E.IV.A.9.Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response:
No.The proposed changes will not change the design function or operation of SSCs. The changes do not impact the accident analysis.
The changes do not involve a physical alteration of the plant, a change in the method of plant operation, or new operator actions. The proposed changes do not introduce failure modes that could result in a new accident, and the changes do not alter assumptions made in the safety analysis.
As demonstrated by the SNC staffing analysis performed in accordance with 10 CFR 50 Appendix E.IV.A.9, the proposed changes do not alter or prevent the ability of the emergency response organization to perform its intended functions to mitigate the consequences of an accident or event.Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3) Does the proposed amendment involve a significant reduction in a margin of safety?Response:
No.Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the Emergency Plan and do not impact operation of the plant or its response to transients or accidents.
The changes do not affect the Technical Specifications.
The changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes.Safety analysis acceptance criteria are not affected.
The Standard Emergency Plan will continue to provide the necessary response staff for emergencies as demonstrated by staffing and functional analyses including the necessary timeliness of performing major tasks for the functional areas of the Emergency Plan. The proposed changes do not adversely affect SNC's ability to meet the requirements of 10 CFR 50 Appendix E and the emergency planning standards of 10 CFR 50.47.El1-4 Enclosure i to NL-16-0169 Evaluation of the Proposed Changes Therefore, the proposed change does not involve a significant reduction in the margin of safety.Based on the above evaluation, SNC has determined that operation of the subject facilities in accordance with the proposed changes does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it does not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated;
- 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.4. STATE CONSULTATION SNC has consulted with the appropriate state and county officials from Alabama, Georgia, and South Carolina and has received their support for the SEP.5. ENVIRONMENTAL ASSESSMENT In accordance with 10 CFR 51, the following information is provided in support of a finding that the adoption of the SNC Standard Emergency Plan has no significant effect on the quality of the human environment.
Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) has requested amendments to the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2. and Vogtle Electric Generating Plant Units 3 and 4.Specifically, the proposed changes would revise each plant's license in order to adopt a fleet SNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishes an updated licensing basis for the SNC operating plants that complies with current NRC regulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.By standardizing emergency plans, SNC will make improvements to the fleet by increasing consistency of organizations, duties and responsibilities, procedures, and training.
SNC also will align the plants using consistent standards and definitions.
Put simply, the changes will make SNC's emergency plan easier to follow and understand.
Among the more notable changes are a) the adoption of a standard staff augmentation time period of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b)changes in staffing numbers, and c) changes in staffing duties, an"d d) con~clidation of the Joint Information Center. Although SNC has implemented significant improvements in overall staffing, procedures, training, and technology since the NRC's initial approval of the plant emergency plans, SNC has conservatively evaluated the proposed changes as reductions in effectiveness requiring NRC approval per 10 CFR 50.54(q).SNC has determined that the proposed changes do not individually or cumulatively have a significant effect on the human environment.
The proposed amendment updates the licensing El-5 Enclosure i to NL-16-0169 Evaluation of the Proposed Changes basis for the plants and creates a standardized emergency plan. The associated changes to the organization, staffing, and augmentation times will not affect the quality of the human environment.
As described above, SNC has determined that operation of the subject facilities in accordance with the proposed changes does not involve a significant hazards consideration, in that it does not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated;
- 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.SNC has determined that operation of the subject facilities in accordance with the proposed changes does not authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite. The proposed changes are unrelated to any aspects of plant construction or operation that would introduce any changes to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, or other effluents) or affect any plant radiological or non-radiological effluent release quantities.
Furthermore, these changes do not diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation.
SNC has determined that operation of the subject facilities in accordance with the proposed changes does not result in a significant increase in individual or cumulative occupational radiation exposure.
The proposed changes will not affect how a structure, system, or component will be used to meet the design bases of the nuclear plant. The proposed changes will have no effect on the construction or operation of the nuclear plants, and therefore would not introduce any changes to the amount of occupational radiation exposure.In conclusion, SNC has determined that anticipated construction and operational effects of the proposed amendment do not involve 1) a significant hazards consideration, 2) a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or 3) a significant increase in the individual or cumulative occupational radiation exposure.
Consequently, the proposed amendment will not have a significant effect on the quality of the human environment.
E1-6 Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.4 40 Inverness Center Parkway SOUTH ERN .Post Office Box 1295 Birmingham, AL 35242 NUCLEAR Tel 205.992.7872 Fax 205.992.7601 A SOUTHERN NL-16-0169 FEBl 1 2016 10 CER 50.90 Docket Nos.: 50-32 1 50-348 50-424 52-025 50-366 50-364 50-425 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2;Edwin I. Hatch Nuclear Plant Units 1 and 2;Vogtle Electric Generating Plant Units 1 and 2;Vogtle Electric Generating Plant Units 3 and 4 Resp~onse to First Request for Additional Information Regardingq Standard Emergqency Plan Ladies and Gentlemen:
By letter dated August 31, 2015 (NL-1 5-1392), Southern Nuclear Operating Company (SNC) requested license amendments (LARs) for approval of a fleet standard emergency plan for Edwin I. Hatch Nuclear Plant Units 1 and 2, Joseph M. Farley Nuclear Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 1, 2, 3 and 4 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML15246A045).
By letter dated December 2, 2015, the U.S. Nuclear Regulatory Commission (NRC) requested additional information (ADAMS Accession Number ML 15334A009).
Specifically, SNC proposed to change the current Joint Information Centers (JICs)described in the respective site emergency plans to incorporate an SNC fleet standard approach for a JIC/Joint Information System (JIS). The NRC's request for additional information (RAI), in regards to the SNC LAR Enclosure 3, "Corporate Joint Information Center Description and Technical Evaluation," was issued to support the NRC staff's Continued technical review of the proposed change.The NRC RAI and the SNC response is provided below. Additional information, including revisions to SNO documents submitted on August 31, 2015 that support the SNC response to the RAI, is attached in the enclosures.
SNC is notifying the states of Georgia and Alabama of this response to the NRC RAI by transmitting a copy of this letter and enclosures to the designated state official.This letter contains no new regulatory commitments.
If you have any questions, please contact Ken McElroy at (205) 992-7369. --
U. S. Nuclear Regulatory Commission NL-1 6-0169 Page 2 This letter contains no new regulatory commitments.
If you have any questions, please contact Ken McElroy at (205) 992-7369.Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.Respectfully sub :itted, C. R. Pierce 'Regulatory Affairs Director 'CRP/EFB/lac Sworn to and subscribed before me this JZiday , 2016.v /NtaryPublic My commission expires: V -2 "'o(" Attachment 1 -NRC RAI and SNC Response
Enclosures:
- 1. Evaluation of the Proposed Changes -LAR for the Adoption of a Standard Emergency Plan for the SNO Fleet (Marked-up pages)2. SNC Standard Emergency Plan. (Marked-up pages)3. Corporate Joint Information Center Staffing -Detailed Description and Technical Evaluation. (Deleted)4. Farley Staffing -Detailed Description and Technical Evaluation. (Marked-up pages)5. Farley Standard Emergency Plan Annex. (Marked-up pages)6. Farley Justification Matrix (Marked-up pages)7. Hatch Staffing -Detailed Description and Technical Evaluation. (Marked-up pages)8. Hatch Standard Emergency Plan Annex (Marked-up pages)9. Hatch Justification Matrix. (Marked-up pages)10. Vogtle (Units 1 and 2) Staffing -Detailed Description and Technical Evaluation. (Marked-up pages)11. .Vogtle (Units 1 and 2) Standard Emergency Plan Annex. (Marked-up pages)12. Vogtle (Units 1 and 2) Justification Matrix. (Marked-up pages)
U. S. Nuclear Regulatory Commission NL-16-0169 Page 3 13. Vogtle (Units 3 and 4) Staffing -Detailed Description and Technical Evaluation.(Marked-up pages)14. Vogtle (Units 3 and 4) Standard Emergency Plan Annex. (Marked-up pages)15. Vogtle (Units 3 and 4) Justification Matrix. (Marked-up pages)16. Evaluation of Proposed Changes -LAR for the Revision to Vogtle 3 and 4 Emergency Planning ITAAC. (No changes)17. Vogtle (Units 3 and 4) Revision to Unit 3 COL Appendix C -Proposed Changes-Markups. (No changes)18. Vogtle (Units 3 and 4) Revision to Unit 4 COL Appendix C -Proposed Changes-Markups. (No changes)19. Off-site Response Organizations
-Letters of Consultation and Concurrence (New Letters Replacing Originals)
- 20. SNC Standard Emergency Plan LAR (Updated clean version of Enclosures 1-19)cc: Nuclear Reciulatory Commission Ms. C. Haney, Regional Administrator Ms. J. Uhle, Director, Office of New Reactors Mr. M. Delligatti, Deputy Division Director, DNRL Mr. L. Burkhart, Branch Chief, LB4, DNRL Mr. M. E. Ernstes, Branch Chief, DRP, RII Mr. J. McKirgan, Branch Chief Mr. W. C. Gleaves Mr. T. E. Chandler Ms. P. Braxton, Resident Inspector
-Vogtle 3 & 4 Mr. R. E. Martin, NRR Senior Project Manager -Vogtle 1 & 2 Mr. S. A. Williams, NRR Project Manager -Farley Mr. M. D. Orenak, NRR Project Manager -Hatch Mr. C. Patel, NRO Project Manager -Vogtle 3 & 4 Mr. P. Kallan, Senior Project Manager -Vogtle 3 & 4 Mr. B. M. Bavol, Project Manager -Vogtle 3 & 4 Ms. R. Reyes, Project Manager -Vogtle 3 & 4 Ms. M. A. Sutton, Project Manager -Vogtle 3 & 4 Mr. D. H. Hardage, Senior Resident Inspector
-Hatch Mr. L. M. Cain, Senior Resident Inspector-Vogtle 1 & 2 Mr. P. K. Niebaum, Senior Resident Inspector-Farley Mr. J. D. Fuller, Senior Resident Inspector, Vogtle 3 & 4 Mr. C. B. Abbott, Resident Inspector
-Vogtle 3 & 4 Ms. S. Temple, Resident Inspector
-Vogtle 3 & 4 Alabama Department of Public Health Dr. T. M. Miller, State Health Officer State of Georgia Mr. J. H. Turner, Director-Environmental Protection Division U. S. Nuclear Regulatory Commission NL-1 6-01 69 Page 4 Blind Copyv List (without enclosures unless noted): Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President
& CEO Mr. D. G. Bost, Executive Vice President
& Chief Nuclear Officer Mr. J. T. Gasser, Executive V.P. Operational Readiness
-Vogtle 1-4 Mr. D. L. McKinney, Vice President, Nuclear Development.
-Vogtle 3-4 Mr. M. D. Rauckhorst, Vice President, Construction
-Vogtle 3-4 Mr. D. H. Jones, Vice President Technical Compliance
-Vogtle 3-4 Ms. K. D. Fili -Vice President
-Operational Readiness Ms. C. A. Gayheart, Vice President
-Farley Mr. D. R. Vineyard, Vice President
-Hatch Mr. B. K. Taber, Vice President
-Vogtle 1-2 Mr. D. R. Madison, Vice President
-Fleet Operations Mr. M. D. Meier, Vice President
-Regulatory Affairs Mr. B. J. Adams, Vice President
-Engineering Mr. C. R. Pierce, Regulatory Affairs Director -Fleet Mr. B. H. Whitley, Regulatory Affairs Director -Nuclear Development Mr. M. J. Yox, Regulatory Affairs Director -Vogtle 3-4 Ms. B. L. Taylor, Regulatory Affairs Manager -Farley Mr. G. L. Johnson, Regulatory Affairs Manager -Hatch Mr. G. W. Gunn, Regulatory Affairs Manager -Vogtle 1-2 Mr. W. A. Sparkman, Licensing Manager -Nuclear Development Mr. T. W. Yelverton
-Commercial Director -Vogtle 3-4 Mr. J. C. Hasweli, Regulatory Manager -Vogtle 3-4 Ms. K. A. Roberts, Licensing Supervisor
-Vogtle 3-4 Mr. D. L. Fulton -Nuclear Development Environmental Manager Mr. T. R. Takats -Engineering Supervisor Mr. J. P. Redd -Licensing Supervisor RTYPEs: CFA04.054; CHA02.004; CVC7000; VND.LI.L00 (w/enclosures)
File AR.01 .02.06 (w/enclosures)
Oglethorpe Power Corporation Mr. M. W. Price Mr. Ms. K. T. Haynes Ms. A Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros U. S. Nuclear Regulatory Commission NL-16-0 169 Page 5 Westinqhouse Electric Company. LLC Mr. R. Easterling Mr. J. W. Crenshaw Mr. C. D. Churchman Mr. L. Woodcock Mr. P. A. Russ Mr. G. F. Couture Mr. M. Y. Shaqqo Ms. K. Stoner Mr. C. A.Castell Other Mr. J. E. Hesler, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham Mr. R Grumbir, APOG Mr. J. R. Bouknight, South Carolina Electric & Gas Company Mr. D. Kersey, South Carolina Electric & Gas Company Mr. B. Kitchen, Duke Energy Mr. S. Franzone, Florida Power & Light Ms. A. Rice, South Carolina Electric & Gas Company ATTACHMENT 1 To NL-16-0169 SNC Response to NRC RAI-1 Fleet Standard Emergency Plan NRC RAI-1 The letters provided in Enclosure 19, "Off-site Response Organizations Letters of Consultation and Concurrence," provides the following "boilerplate language" describing the level of changes discussed with applicable State and local governmental authorities:
This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.Please provide documentation that the offsite response organizations have reviewed and concur on the proposed changes with respect to the relocation of the JICs and its potential impact on their respective radiological emergency preparedness (REP) plans. Additionally, please identify whether other proposed changes to the respective site emergency plans were evaluated for their impact the State and local response organizations ability to effectively implement their FEMA-approved REP plans, specifically in regards to licensee interface and coordination with State and local response organizations.
If so, please provide evaluation performed and documentation regarding discussions with affected State and local response organizations used in making this determination.
[NOTE: Per 10 CFR 50/54 (s) (3), any change to the licensee's emergency plan that impacts or has the potential to impact State and local REP plans will be provided to FEMA for review to verify that continued reasonable assurance exists that State and local emergency plans can be implemented.
As such, an adequate evaluation and documentation of coordination with offsite response organization needs to be provided as part of licensee's submittal.]
SNC Response SNC performed a detailed review of the relevant off-site response organization (ORO) emergency plans to identify potential impacts resulting from the proposed SNC fleet standard emergency plan. Only minor editorial changes related to the SNC emergency plan document titles were identified.
Nonetheless, SNC held additional discussions with the OROs to provide further clarification and answer any questions.
Specifically, in addition to covering the specific changes that would be needed to the ORO emergency plans, SNC and the OROs discussed details of the personnel interfaces and coordination necessary to effectively implement the plans during an emergency.
The OROs concur there are no adverse impacts to their respective emergency plans from the proposed SNC A1-1 ATTACHMENT 1 To NL-16-0169 SNC Response to NRC RAI-1 Fleet Standard Emergency Plan fleet standard emergency plan and have responded via letters to this effect.These letters of concurrence are provided in Enclosure 19 and replace the ORO concurrence letters originally submitted.
Savannah River Site (SRS) has elected not to provide a follow-up response to their initial acknowledgement letter in keeping with SRS's position that, as a Department of Energy facility, a simple"acknowledgement" letter is appropriate rather than a "concurrence" letter.The August 31, 2015 SNC submittal contained provisions for designating the Alabama Power Company and Georgia Power Company Corporate Media Centers (CMCs) located in Birmingham, Alabama and Atlanta, Georgia respectively as the official Joint Information Center (JiC) until such time as the near site JIC could be established.
This proposal included prescribing a minimum activation time for this facility of 75 minutes. Moving the JIC to the CMC locations was intended to facilitate meeting the 75 minute minimum staff augmentation time.The SNC proposal to add a minimum staff augmentation time was predicated on proposed changes to NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. However, based on recent input from NRC staff, the current version of NUREG-0654 (Revision 1), which does not require a minimum staff augmentation time, will continue to be an acceptable means of meeting the requirements of 10 CFR 50.47 even after issuance of the proposed changes to NUREG-0654 (Revision 2).Consequently, SNC has decided not to propose these changes to the JIC as originally described to the NRC in Enclosure 3 of the SNC submittal on August 31, 2015. SNC's practice for coordination and dissemination of information to the public as provided in the current SNC emergency plans and the State and County emergency plans via the near site JICs will remain unchanged in the SNC fleet standard emergency plan. Accordingly, SNC has enclosed the corresponding changes, including marked-up pages, to the original enclosures and has enclosed a clean revised copy of the entire submittal in Enclosure 20 for convenience.
A few minor editorial and typographical corrections are also included.
These revisions reflect the deletion of the 75 minute JIC augmentation commitment, the re-assignment of the SNC Spokesperson and Technical Assistant from the EOF to the JIC as described in the current emergency plans, and the description of the JIC and CMC as separate facilities.
A1-2 Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2;Edwin I. Hatch Nuclear Plant Units 1 and 2;Vogtle Electric Generating Plant Units 1 and 2;Vogtle Electric Generating Plant Units 3 and 4 Enclosure 1 Evaluation of the Proposed Changes (Marked -up pages)
Evaluation of Proposed Changes Table of Contents 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION and TECHNICAL EVALUATION
- 3. REGULATORY EVALUATION
3.1 Applicable
Regulatory Requirements
3.2 Precedent
3.3 No Significant Hazards Consideration Determination
- 4. STATE CONSULTATION
- 5. ENVIRONMENTAL ASSESSMENT El-i F Enclosure 1 to NL-16-0169 Evaluation of the Proposed Changes 1.
SUMMARY
DESCRIPTION Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests amendments to the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 3 and 4.Specifically, the proposed changes would revise each plant's license in order to adopt a fleet SNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishes an updated licensing basis for the SNO operating plants that complies with current NRC regulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.By standardizing emergency plans, SNC will make improvements to the fleet by increasing consistency of organizations, duties and responsibilities, procedures, and training.
SNC also will align the plants using consistent standards and definitions.
Among the more notable proposed changes are a) the adoption of a standard staff augmentation time period of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b) changes in staffing numbers, and c) changes in staffing and, d) .... ncol÷d"io of tho oint,,, Informatio Although SNC has implemented significant improvements in overall staffing, procedures, training, and technology since the NRC's initial approval of the plant emergency plans, SNC has conservatively evaluated the proposed changes as reductions in effectiveness requiring NRC approval.2. DETAILED DESCRIPTION and TECHNICAL EVALUATION The SNC SEP is attached as Enclosure
- 2. A-The detailed description and technical evaluation of the Corporate Joint Information Center sformerly documented in Enclosure 3 has been deleted because SNC has determined that no changes are necessary.
Detailed descriptions and technical evaluations of the site emergency plan staffing changes are documented in Enclosures 4 (Farley), 7 (Hatch), 10 (Vogtle 1-2), and 13 (Vogtle 3-4).The SNC Standard Emergency Plan is supplemented by plant-specific annexes documented in Enclosures 5 (Farley), 8 (Hatch), 11 (Vogtle 1-2), and 14 (Vogtle 3-4).A Justification Matrix for each plant identifies the wording in the current plant emergency plan sections, the revised wording and location in the Standard Emergency Plan or Annex, and the reasoning behind or justification for the change. The matrices are documented in Enclosures 6 (Farley), 9 (Hatch), 12 (Vogtle 1-2), and 15 (Vogtle 3-4).At the end of each Justification Matrix are two additional tables for the Site On-Shift and Site Augmented Emergency Response Organization that compare the number of persons performing major tasks in each major functional area with the guidance in NUREG 0654, the emergency plan first approved by the NRC, the current emergency plan, and the proposed SNC Standard Emergency Plan.El1-2 Enclosure i to NL-1 6-01 69 Evaluation of the Proposed Changes 3. REGULATORY EVALUATION
3.1 Applicable
Regulatory Requirements The SNC Standard Emergency Plan establishes an updated licensing basis for the SNC plants that complies with current NRC regulations in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. In addition, the SNC plan complies with NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.3.2 Precedent The SNC SEP was modeled generally after the Exelon Standardized Radiological Emergency Plan. (See ML1 3200A1 24.) The NRC has previously approved increases in staff augmentation times. (See, e.g., ML112450464.)
3.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests amendments to the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 3 and 4.Specifically, the proposed changes would revise each plant's license in order to adopt a fleet SNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishes an updated licensing basis for the SNC operating plants that complies with current NRC regulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.By standardizing emergency plans, SNC will make improvements to the fleet by increasing consistency of organizations, duties and responsibilities, procedures, and training.
SNC also will align the plants using consistent standards and definitions.
Put simply, the changes will make SNC's emergency plan easier to follow and understand.
Among the more notable changes are a) the adoption of a standard staff augmentation time period of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b)changes in staffing numbers, and c) changes in staffing duties, and d) consolidation of tho Joint Information Contor. Although SNC has implemented significant improvements in overall staffing, procedures, training, and technology since the NRC's initial approval of the plant emergency plans, SNC has conservatively evaluated these changes as reductions in effectiveness requiring NRC approval per 10 CER 50.54(q).SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92,"Issuance of amendment," as discussed below: El1-3 Enclosure i to NL-16-0169 Evaluation of the Proposed Changes 1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response:
No.The proposed changes have no effect on normal plant operation or on any accident initiator or precursors, and do not impact the function of plant structures, systems, or components (SSCs).The proposed changes do not alter or prevent the ability of the emergency response organization to perform its intended functions to mitigate the consequences of an accident or event. The ability of the emergency response organization to respond adequately to radiological emergencies has been demonstrated as acceptable through a staffing analysis as required by 10 CFR 50 Appendix E.IV.A.9.Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response:
No.The proposed changes will not change the design function or operation of SSCs. The changes do not impact the accident analysis.
The changes do not involve a physical alteration of the plant, a change in the method of plant operation, or new operator actions. The proposed changes do not introduce failure modes that could result in a new accident, and the changes do not alter assumptions made in the safety analysis.
As demonstrated by the SNC staffing analysis performed in accordance with 10 CFR 50 Appendix E.IV.A.9, the proposed changes do not alter or prevent the ability of the emergency response organization to perform its intended functions to mitigate the consequences of an accident or event.Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3) Does the proposed amendment involve a significant reduction in a margin of safety?Response:
No.Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the Emergency Plan and do not impact operation of the plant or its response to transients or accidents.
The changes do not affect the Technical Specifications.
The changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes.Safety analysis acceptance criteria are not affected.
The Standard Emergency Plan will continue to provide the necessary response staff for emergencies as demonstrated by staffing and functional analyses including the necessary timeliness of performing major tasks for the functional areas of the Emergency Plan. The proposed changes do not adversely affect SNC's ability to meet the requirements of 10 CFR 50 Appendix E and the emergency planning standards of 10 CFR 50.47.El1-4 Enclosure i to NL-16-0169 Evaluation of the Proposed Changes Therefore, the proposed change does not involve a significant reduction in the margin of safety.Based on the above evaluation, SNC has determined that operation of the subject facilities in accordance with the proposed changes does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it does not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated;
- 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.4. STATE CONSULTATION SNC has consulted with the appropriate state and county officials from Alabama, Georgia, and South Carolina and has received their support for the SEP.5. ENVIRONMENTAL ASSESSMENT In accordance with 10 CFR 51, the following information is provided in support of a finding that the adoption of the SNC Standard Emergency Plan has no significant effect on the quality of the human environment.
Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) has requested amendments to the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2. and Vogtle Electric Generating Plant Units 3 and 4.Specifically, the proposed changes would revise each plant's license in order to adopt a fleet SNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishes an updated licensing basis for the SNC operating plants that complies with current NRC regulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.By standardizing emergency plans, SNC will make improvements to the fleet by increasing consistency of organizations, duties and responsibilities, procedures, and training.
SNC also will align the plants using consistent standards and definitions.
Put simply, the changes will make SNC's emergency plan easier to follow and understand.
Among the more notable changes are a) the adoption of a standard staff augmentation time period of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b)changes in staffing numbers, and c) changes in staffing duties, an"d d) con~clidation of the Joint Information Center. Although SNC has implemented significant improvements in overall staffing, procedures, training, and technology since the NRC's initial approval of the plant emergency plans, SNC has conservatively evaluated the proposed changes as reductions in effectiveness requiring NRC approval per 10 CFR 50.54(q).SNC has determined that the proposed changes do not individually or cumulatively have a significant effect on the human environment.
The proposed amendment updates the licensing El-5 Enclosure i to NL-16-0169 Evaluation of the Proposed Changes basis for the plants and creates a standardized emergency plan. The associated changes to the organization, staffing, and augmentation times will not affect the quality of the human environment.
As described above, SNC has determined that operation of the subject facilities in accordance with the proposed changes does not involve a significant hazards consideration, in that it does not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated;
- 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.SNC has determined that operation of the subject facilities in accordance with the proposed changes does not authorize a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite. The proposed changes are unrelated to any aspects of plant construction or operation that would introduce any changes to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, or other effluents) or affect any plant radiological or non-radiological effluent release quantities.
Furthermore, these changes do not diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation.
SNC has determined that operation of the subject facilities in accordance with the proposed changes does not result in a significant increase in individual or cumulative occupational radiation exposure.
The proposed changes will not affect how a structure, system, or component will be used to meet the design bases of the nuclear plant. The proposed changes will have no effect on the construction or operation of the nuclear plants, and therefore would not introduce any changes to the amount of occupational radiation exposure.In conclusion, SNC has determined that anticipated construction and operational effects of the proposed amendment do not involve 1) a significant hazards consideration, 2) a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or 3) a significant increase in the individual or cumulative occupational radiation exposure.
Consequently, the proposed amendment will not have a significant effect on the quality of the human environment.
E1-6