ML16060A330
Text
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 13 Vogtle (Units 3 and 4) Staffing-Detailed Description And Technical Evaluation (Marked-up pages)
Enclosure 13 to NL-1 6-01 69 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation Jucional ~t.Area Mt~nrR~ajrTasfoiio*il Media Response Media Response Public Information Director Nuclear Spokesperson Technical Assistant JIC Manager JIG Assistant**
Facility Coordinator**
Clerical Staff**Security**
Public Response Coordinator Public Response Staff**Media Relations_____________________
_ ___ ____ ___ ___ ___ ___ Representative
- JI Acitnt Fciiy Clorical Staff Socu...ty, and Public, Roeponco,,-
Staff do not have a 75 minute augmentation time.Minimum staff positions have been identified for each facility.
Facility activation may be completed upon filling of minimum staffing positions and completion of a briefing on the event to ensure personnel in these positions are ready to accept responsibility for their functions.
Minimum staffing positions for the TSC Organization are as follows:* TSC Emergency Director (ED)* TSC Emergency Response Facility (ERF) Communicator
- TSC Engineering Supervisor Minimum staffing positions for the Operations Support Center (OSC) Organization are as follows:* OSC Manager* OSC Emergency Response Facility (ERF) Communicator
- OSC RP/Chemistry Group Lead Minimum staffing positions for the EOF Organization are as follows:* EOF Emergency Director (ED)* EOF Emergency Response Facility (ERF) Communicator
- EOF Dose Analyst* EOF ENN Communicator Minimum staffing positions for the Joint Information Center (JIG) Organization are as follows: El13-15 Enclosure 13 to NL-1 6-01 69 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation
- Public Information Director (PID)* JIC Manager* Media Relations Representative
- Public Response Coordinator In addition to the functional analysis provided, the key Emergency Response Facilities were analyzed to determine the minimum staffing (both numbers and positions) needed for the facilities to activate the facilities and begin facility operations.
Any personnel determined to be required to support the minimum staff activation and initiation of activities were added to the revised augmented ERO.Program Enhancements The following section discusses technical aspects of plant systems, dose assessment, procedures, and training which support on-shift functions and ease operator burden. Additional information regarding on-shift and augmented positions and their responsibilities as identified in NUREG-0654/FEMA REP-Ol Revision 1 are included in Enclosure 15.Plant Computer System The VEGP Unit 3 and Unit 4 Safety Parameter Display System (SPDS) is a state of the art system integrated into the overall man-machine interface for VEGP Unit 3 and Unit 4. It provides a display of plant parameters from which the status of operation can be assessed, in the control room and in the onsite and off-site Emergency Response Facilities (ERFs).This state of the art SPDS:* Aids the control room operators in the rapid detection and identification of abnormal operating conditions.
- Provides additional specific information to analyze and diagnose the cause of abnormal operating conditions.
- Monitors plant response to corrective actions.* Provides grouping of parameters to enhance the operators' capability to assess plant status quickly without surveying all control room displays concurrently.
- Directs the operators' attention to other specific confirmatory non-SPDS control room displays.* Provides human factors engineered display formats in simple and consistent display patterns and coding.* Provides display information on a real-time basis, along with validation of data.* Provides generated selectable trend displays on a real-time basis for monitoring reactivity control, reactor core cooling and heat removal from the primary system, reactor coolant system integrity, radioactivity control, containment integrity, and other selected parameters.
The SPDS in the control room consists of displays of sets of concentrated parameters from which plant safety status can be rapidly assessed.
Duplicate SPDS displays are located in the El13-16 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 14 Vogtle (Units 3 and 4)Standard Emergency Plan Annex (Marked-up pages)
Enclosure 14 to NL-1 6-01 69 Vogtle (Units 3 & 4) Standard Emergency Plan Annex located in the near site media center in Waynesboro, GA. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security and the EOF. The available communications and data links also provide access to the SNC document management resources, work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is contained in site procedures.
5.1.5 Emergency
Operations Facility (SEP H.2.1)The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations.
The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP).Additional details of the EOF are contained in section H.2.1 of the Emergency Plan.The near site location is maintained at the Vogtle Training Center space for members of an NRC Site Team.5.1.6 Joint Information Center (JIC) (SEP H.2.2)The VEGP JIC is located in Waynesboro, Georgia adjacent to the Georgia Power Company operating headquarters.
The JIC is the central location for the coordination and dissemination of information to news media and responses to public and media inquiries.
Details of the JIC for VEGP can bo foundlare in section H of the Emergency Plan. If the decision is made to meve-activate the JIC the CMC in Atlanta, Georgia will maintain emergency communications response coordination until the JIC is ready to assume these responsibilities.
facIit, wi;1l mai;n'tain media unt÷I the lICi" at th-o site E14-20 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 15 Vogtle (Units 3 and 4)Justification Matrix (Marked-up pages)
Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.1 Normal Plant Organization EP B.1 Normal Plant Organization The commitment wording was The organizational structure shown on Figure B-i The normal onsite organization of a SNC operated nuclear standardized and relocated to represents the pool of management personnel power plant provides a staff capable of providing the initial the SNC Standard Emergency available on site during normal working hours, response to an emergency event. The On-Shift staff was Plan and Site Annex.Approximately 700 people are stationed at Units validated by performing a detailed staffing analysis as 1 and 2 during the standard workday, and required by Part 50 Appendix E.IV.9. Organizational A Staffing Analysis supporting approximately 650 people will be stationed at structures for each of the sites and the on-shift staffing the on-shift staffing design and Units 3 and 4 during the standard workday. tables are provided in the Site Specific Annex. The compliant with 10 CFR 50 The normal operating crew for each unit includes number and ERO position titles of personnel available Appendix E.IV.A.9 was a shift supervisor, licensed plant operators, and within 75 minutes following declaration of an emergency is conducted to support the non-licensed plant operators.
A Shift Manager is shown in Tables 1, 2T and submittal.
also on shift during operation (as defined in the SNC plants maintain 24-hour emergency response Technical Specifications).
Personnel from the capability.
The normal on-shift complement provides the Chemistry and Health Physics, Maintenance, and initial response to an emergency.
This group is trained to Security Departments are also on site respond to emergency situations until the augmented continuously.
Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, radiation protection, material control, fire protection, and security_______________________________Annex Table 2.2.A Minimum Shift Staffing _____________
E15-25 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _____________
B.2: During hostile action, ERO members would EP H.1.4 An Alternative Facility for staging of ERO The commitment wording was likely not have access to the onsite emergency personnel has been designated at the sites. In the event standardized and relocated to response facilities.
A security related emergency of a Security or Hostile Action threat or event, the the SNC Standard Emergency may delay the ordering of facility activation in designated Alternative Facility may also serve as an Plan and Site Annex.order to protect plant personnel from the security evacuation location for TSC and OSC personnel.
The threat. The decision to delay activation of the Alternative Facility is designed to be accessible in the The SNC Standard Emergency facilities will be made by the Emergency Director.
event of an onsite HAB event and has the capability to: Plan and Annex provide However, these events will warrant timely ERO a Communicate with the Control Room, Security, commitments to maintain the augmentation.
An alternative facility has been and the EOF. communications capabilities identified to ensure rapid access to the site by
- Conduct engineering assessment activities within the ERO, required offsite augmented staff due to its close proximity.
The including damage control team planning and responders and the public alternative facility is located in a designated area preparation through the execution of a Joint in the Joint Information Center (JIC) in The functions of Notification and PARs will be performed Information System. The Waynesboro, Georgia. This facility has been from the EOF should the Alternative Facility be activated, detailed physical description of established to minimize delays in overall site Details of Alternative Facilities can be found in the Site equipment maintaining those response by permitting ERG assembly without Specific Annex. commitments is subject to exposing responders to the danger of hostile Annex 5.1.4 During a security related event or other event change and not necessary to action. This facility functions as a staging area for that precludes onsite access, the TSC, and OSC ERG ensure effective implementation augmented ERG staff until the site is secured. staff will be directed to an alternative facility.
This facility of the Emergency Plan.is located in the near site media center in Waynesboro, .Additional dotaile on tho JIC!JIS GA. The alternative facility is equipped with the are in. ..... coparato+necessary communications and data links to support onclocuroa a.. par thi;c L' ^communications with the control room, site security and the EOF. The available communications and data links also provide access to the SNC document management resources, work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is contained in site procedures._______________
B.2.1 Emergency response organization EP H.1: SNC operated nuclear power plants have The commitment wording was ResponsibilitiesFollowing an Alert or higher established a TSC and an onsite OSC, which are staffed standardized and relocated to emergency declaration, the positions shown on and activated within 75 minutes of the declaration of an the SNC Standard Emergency Figures B-2 and B-3 will be filled by Site or SNC Alert or higher classification.
Plan.personnel as discussed below. EP H.2.1: Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification.
EP Figure B.2.B, B.2.C, B.2.D, and B.2.E: illustrates the standard Emergency Organization._______________
E15-29 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision3
[3_ _ _ _0.1: Representatives from the states of Georgia and South Carolina will be dispatched to the emergency operations facility (EOF) and the emergency news center (ENG).EP H.2.1: It is anticipated that representatives from the State(s)of Georgia, South Carolina, Alabama, or Florida may be dispatched to the EOF for an event at specific SNO site(s).EP H.2.2Joint
!nforma.tion Center (JC)orort-Mei Center (CMC)Upon notification of an Alert or higher classification, the Public Information Director and corporate staff assigned to JIG functions will assemble at the 0MG. The 0MG, located at the Atlanta/Birmingham corporate headquarters building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination of emergency communications response until the site specific JIG has been activated.
The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIG. When the decision is made to activate the JIG the 0MG will maintain emergency communications response coordination until the site specific JIG is ready to assume these responsibilities.
Once overall responsibility for emergency communications response transfers to the site specific JIG the remaining 0MG staff will provide support for the JIC as needed.hedquartersbuildin g of Goorgiat~." t oorth Company:!Alaeetbamae ts m b.eingquiriocerntdt h mx'-the is the poin,"t ofi ! cotat wi th r!'.dt~ the os ei du-ing a: dclaredtht I emergency.-
The : to facltosused to cordinato dissemlinatio of to, ithe be etablished ito pos .'ible. Followngativati~g~m!.+ton of to J ! in nt!The commitment wording was standardized and relocated to the SNC Standard Emergency Plan.The SNC Standard Emergency Plan and Annex provide commitments to maintain the communications capabilities within the ERO, required offsite responders and the public through the execution of a Joint Information System. The detailed physical description of equipment maintaining those commitments is subject to change and not necessary to ensure effective implementation of the Emergency Plan.Addi~tional deti,-;ls on the liG/JIIS E15-44 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3. Joint Information Center (JIC) The commitment wording was After the initial notification of an emergency at the Alert standardized and relocated to classification or higher, the Public Information Director will the SNC Standard Emergency coordinate with the EOF Emergency Director and affected Plan.OROs and determine whether to activate the JIG. Upon the decision to activate the JIG, the Public Information Director and JIG staff transfer from the 0MG to the site specific JIG. Once the JIG is staffed the Public Information Director will manage the emergency communications response from the JIG in coordination with ORO public information officers (PIOs).Site specific JIG is provided in the site specific Annexes.E 15-45 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _____________
F.9: In-plant monitoring teams will communicate Specific communications with the Health Physics or 0S0 communicator at frequencies between the OSC least every half hour. and dispatched response teams are event specific and determined on a case by case basis for the event. A Plan commitment is not appropriate and could actually hinder effective response.F.9: The field monitoring team radio covers the EP F Table 5 The capability to dispatch teams entire plume exposure pathway EPZ. and for those teams to function is maintained in the SNC Standard Emergency Plan. This statement of radio coverage is not required.F.9: Remote stations for communicating with the EP F.1 .1: At SNC operated nuclear power plants, several The commitment wording was field monitoring teams are located in the TSC modes of reliable communication are available, during standardized and relocated to and the EOF. both normal and emergency conditions, to transmit and the SNC Standard Emergency receive information among the Control Room, TSC, OSC, Plan and Site Annex.EOF, and at other locations onsite and off site.EP F Table 5 Table F-i: All EP F Table 5 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan.The-epemt~ienaI Section G Public Education and Information G: Georgia Power Company (GPC) and EP G,8: The goal of the public information program is to The commitment wording was Southern Nuclear Operating Company (SNC) in acquaint the general public with the emergency plans for standardized and relocated to coordination with State and local officials will the operation of APC/GPC nuclear plants, as appropriate, the SNC Standard Emergency provide information to the public at least annually and actions they should in the event of a plant emergency.
Plan.regarding how they will be notified and what their Emergency Information is disseminated each calendar actions should be in an emergency.
year for residents and transients in the plume exposure________________________________pathway Emergency Planning Zone.E15-78 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G.2: The emergency news center (ENC) will be EP H.2.2: Corporate Media Center (CMC) The commitment wording was the principal point of contact with the news media upon notification of an Alert or higher classification, the Public standardized and incorporated an emergency.
The ENC will Information Director and corporate staff assigned to JIC functions wi nolhlROSafiga during aneegny h N ilassemble at the CMC. The CMC, located at the Atlanta/Birmingham it h ~ tfiga accommodate public information representatives corporate headquarters building of Georgia Power Company/Alabamna described in Section B, Facilities from SNC, GPC, State, local and Federal Power Company, as appropriate, is the official location for coordination as described in Section H, the response agencies, of emergency communications response until the site specific JIC has Emergency Communications been activated.
The Public Information Director will coordinate with the g~EOF Emergency Director and affected ORes and determine whether to portion of Section G of the SNC activate the site specific JIC. When the decision is made to activate the Standard Emergency Plan and JIC the CMC will maintain emergency communications response Section 5.1.6 of the Vogtle 3-4 coordination until the site specific JIC is ready to assume these Annex. and relocated to the responsibilities.
Once overall responsibility for emergency sr~' St.andard,.
Emerg..nc.
communications response transfers to the site specific JIC the remaining Pn..............
Standard CMC staff will provide support for the JIC as needed. P=.h .CS~dr Annex 5.1.6. The VEGP JIC is located in Waynesboro, Georgia, Emergenc..
Pla ..nd Sit Annex..adjacent to the Georgia Power Company operating headquarters.
The ___,,,,;_.....__,,__,,_-____...__...
JIG is the central location for the coordination and dissemination of pro..id....
an .....o...tructur information to news media, and responses to public and media inquiries, an ..............
capability for Details of the JIG for VEGP are in section H of the Emergency Plan. If Infor.mation to the the decision is made to activate the JIG the CMC in Atlanta, Georgia will pub.libc in the e'vent of a claccified maintain emergency communications response coordination until the JIC emergen~cy.
The n.ew s,'tem is is ready to assume these responsibilities.
building 0f Goorgia Poer'c Cm..panV/A~abama-Poe:;r Com.-nype, a, in' the... technical_....
Tho. JIC is tho peint of contact 'with' tho dur.ing a declare'd rocpon- .... oncios..News roloa... and deofings pro media attention, the Pu-blic Direc'to.r
,:.ll dtre'=ct, that JIC operatins mo've to a for:vard near s.ite loca=tion.
If ..h. decision is made JIC is opo'rationp!
at the near cite location.ANNEXN 5.1.6 The JIC is the cental location for the coordination and facility ,-.-:! maintain cooe.Jrdition unti! the JIC is oporatinal at the E15-82 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3. Joint Information Center (JIC) The commitment wording was After the initial notification of an emergency at the Alert standardized and incorporated classification or higher, the Public Information Director will into the ERO Staffing as coordinate with the EOF Emergency Director and affected described in Section B, Facilities OROs and determine whether to activate the JIC. Upon as described in Section H, the the decision to activate the JIC, the Public Information Emergency Communications Director and JIG staff transfer from the 0MG to the site portion of Section G of the SNO specific JIG. Once the JIG is staffed the Public Information Standard Emergency Plan and Director will manage the emergency communications Section 5.1.6 of the Vogtle 3-4 response from the JIG in coordination with ORO public Annex. The commitmont information officers (PIOs). .ording , a; .. ta...d.rdiz;,o, and, Site specific JIG is provided in the site specific Annexes. rlo~cavted to the SNC Standard E15-83 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan TRevised SNC Emergency Plan Justification Revision3
__3_ _ _ _ _ _ _ _ _ _ _G.2: GPO will utilize the Corporate Headquarters Building at 241 Ralph McGill Boulevard, NE, Atlanta, Georgia, to serve as a temporary information center until the ENC in Waynesboro (Burke County Office Park) is activated.
EP H.2.2: Corporate Media Center (CMC)Upon notification of an Alert or higher classification, the Public Information Director and corporate staff assigned to JIC functions will assemble at the CMC. The 0MG, located at the Atlanta/Birmingham corporate headquarters building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination of emergency communications response until the site specific JIC has been activated.
The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities.
Once overall responsibility for emergency communications response transfers to the site specific JIG the remaining CMC staff will provide support for the JIC as needed.The commitment wording was standardized and incorporated into the ERO Staffing as described in Section B, Facilities as described in Section H, the Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. Tocmimn wording. was. s.ta.n-da-rdi--od an.'d rotl,,ca.ltod. ~the SNOl/'
headquarters building of Georgia Power Compan~'Alabama Power Company, as appropriate, is tho official location for coordination and issuance of news announcements and responses to news media !nguirios The JIC is the point of contact with the news media during a declared emergency.
The JIC facilities used to coerd~nate the dissemination of information to the med~a wil' be eetab!ishod to accommodate public information representatives from the licensee, Federal, State, and ~oca! response agencies.
News re!oasec and media briefings are coord~natod to the maximum o~ent possible.
Following activation of the JIC in Atlanta'Birmingham, the Public !nformatien Director will evaluate the nature of the event and if it is determined that the event will be a prolonged event, is Iike!y to escalate or likely to result in significant media attention, the Public Information Director will direct that JIC operations move to a for~ard near site location.
If the decision is made to move the JIC function to the near site media coordination until tho JIC is operational IGG~MOA~at..the near site E15-84 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3 Joint Information Center (JIC) The commitment wording was standardized and incorporated After the initial notification of an emergency at the Alert into the ERO Staffing as classification or higher, the Public Information Director will described in Section B, Facilities coordinate with the EOF Emergency Director and affected as described in Section H, the Emergency Communications OROs and determine whether to activate the JIG. Upon portion of Section G of the SNO the decision to activate the JIG, the Public Information Standard Emergency Plan and Director and JIG staff transfer from the 0MC to the site Section 5.1.6 of the Vogtle 3-4 specific JIG. Once the JIG is staffed the Public Information Annex. Th omimn Director will manage the emergency communications
..ording a .. tand..rdi...d..nd response from the JIG in coordination with OR0 public r.locat.d....th......S.andard information officers (PlOs). E Site specific JIG is provided in the site specific Annexes.G.2: In addition, technical brief ers have been EP B.3.1-82.9 EFl--Technical Assistant The commitment wording was designated who can provide general and The Technical Assistant reports to the Nuclear standardized and incorporated background information.
Spokesperson and is responsible for gathering accurate into the ERO Staffing as and timely information about the event and the plant's described in Section B, Facilities status via displays, tho ERF Communicator, ENN Forms, as described in Section H, the and direct contact with the EOF Manager. Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. Tho SNO Standard The now. systenm is dolsc,*-ribo a-ndl supported, l~n'E15-85 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 ______________________
____________
G.2: The Company spokesperson has access to EP B.3.1-M-2.8 EOF-Nuclear Spokesperson The commitment wording was all information and telephone contact with the The Nuclear Spokesperson speaks on behalf of the standardized and incorporated emergency director through the EOF Manager. company, providing plant status updates during news into the ERO Staffing as He briefs the media on plant status and briefings.
The Spokesperson also may do one-on-one described in Section B, Facilities Company emergency activities, media interviews.
The position works with the Technical as described in Section H, the Assistant in keeping abreast of the event status and keeps Emergency Communications the PID posted on that status. portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. The SNC Standard and functiona!
capbiit for+. ,, G.2 Th Copan spkesersn psiton s E SokeperonInf ormationtngment torn the filld b iniviual wh, uder orml Te Ncler Sokeperon seak onbehlf f te emndrgien d The inowporstemdi operations, hold supervisory positions on the company, providing plant status updates during news into the ERO Staffing as SNC Corporate or plant staff and are technically briefings.
The Spokesperson also may do one-on-one described in Section B, Facilities and professionally qualified to perform this media interviews.
The position works with the Technical as described in Section H, the important function.
Assistant in keeping abreast of the event status and keeps Emergency Communications the PID posted on that status. portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. The SNO Standard information Management to the E15-86 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _____________
G.3: GPO and SNC will provide timely and EP B.3.2.1 JIG-Public Information Director (PID) The commitment wording was accurate information to local, State and federal The PID is responsible for coordination of emergency standardized and incorporated agencies, and will seek reciprocal information information between the utility and responding offsite into the ERO Staffing as from these agencies.
organizations participating in the Corporate Media Center described in Section B, Facilities (CMC) or Joint Information Center (JIC). Additional duties as described in Section H, the include managing approval and dissemination of utility Emergency Communications news bulletins, facilitating news briefings, overseeing portion of Section G of the SNC public response, serving as liaison to the media and Standard Emergency Plan and coordinating off-site agencies.
The PID may delegate Section 5.1.6 of the Vogtle 3-4 emergency communications approval authority to other Annex. Tho SNO Standard staff,,members^"'k--.
Emergenc..
Pla ..nd St Annex^...pm,.rovid.h.
- n update },truhctur.o timel, acurate andconsstentinfomatin to ll apropiate nforationwillbe rlease as leary, stndarizedandtic toprate the pblic nd byhavin a sigle surce f coniselyand qickl as ppublic inbic thouneeennt ofo ae EROStaffngoa asdescribod and Suppctionh Emearatelcy inohemecnicalin analtion of Setion Gubmittal.N adecieinSection H,.6o the Vgl -Annex. The SNC Standard MA'Janagment tho public in the e'-ent of a classified described and4 ..upported E15-87 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _G.4
- To dispel rumors in an emergency, a rumor EP G.4 Press Briefings The commitment wording was control network will be activated.
News media Press briefings will be conducted to keep the media standardized and incorporated will be monitored to detect and respond to informed of events and activities relating to the into the ERO Staffing as misinformation.
emergency.
Briefings will provide the most current, up-to- described in Section B, Facilities date information about events and response to the as described in Section H, the incident.
Public Information Officers (PlOs) from all offsite Emergency Communications agencies responding to the emergency will be encouraged portion of Section G of the SNO to participate in the briefings to discuss their particular Standard Emergency Plan and activities.
Section 5.1.6 of the Vogtle 3-4 Annex. Tho S.NC Standard E-mo.rgncy Plan andl Sito Anney prondo an upd.at.. od ..t.ru.ctu..ro G.5: PC wll ofer a annal prgramto E G.2:A prgramwill e oferedeaandalfunctionaloThecapabilit ordigfor forobtinig iforatin bou ovral obainnginfrmaiondurng n merenc an wih teINfomto Standardomergntoyh emergecy prearednss at he VEG. Traning oerpublicrgein prharednentatofC/aPCnucleaiPlan and te rol of te emegenc newscente, abot th plamergegnccyrespnoenad therolemf th JIC as ell as pportunties toparticiatininthilltachnicals foS bannenomainaotoealcbann nomtion duin aEmergency andwihiteiNtitadar Eergnc Equipment E15-88 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3_____________________________________
Appendix 7 A.3: Offsite support personnel and EP B.3.1 .3 EOF Support Coordinator The commitment wording was equipment will be dispatched to the site The Support Coordinator reports to the EOF Manager. standardized and relocated to Operations Support Center (OSC) or Technical The duties and responsibilities of the Support Coordinator the SNC Standard Emergency Support Center (TSC) upon request from the in the EOF include providing oversight of the News Writer, Plan.specific site Emergency Director.
providing assistance to the Support Coordinator in the TSC for ordering equipment and materials needed and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware, transportation, food, and lodging._______________
Appendix 7 A.3: The corporate emergency The commitment wording was response organization will provide offsite standardized and relocated to emergency response support and resources to the SNC Standard Emergency SNC sites on a twenty-four seven basis until the Plan.emergency has been terminated.
The SNC Standard Emergency Plan integrates the Corporate response as part of the trained and qualified ERO. A separate statement is not necessary.
Appendix 7 A.3: The EOF will be activated for an EP H.2.1 Emergency Operations Facility The commitment wording was ALERT, SITE AREA or GENERAL emergency Staffing and activation of the EOF is mandatory upon standardized and relocated to classifications.
declaration of an Alert or higher classification.
the SNC Standard Emergency Plan.Appendix 7 A.3: This facility (EOF) will be EP H.4: Although the response time will vary due to The commitment wording was operational within about an hour of the initial factors such as weather and traffic conditions, a goal of 75 standardized and relocated to notification.
minutes for minimum staffing, following the declaration of the SNC Standard Emergency an Alert or higher emergency classification, has been Plan.The change in activation established for ERO personnel responding to plant times will be justified separately emergency facilities including the TSC, and EOF in the Technical Analysis Section aP, d-JI. of this License Amendment_________________________________
__________________________________RequeReqest E15-198 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 8: All The appendix describing the Emergency Communications Plan has been standardized and incorporated into the ERO Staffing as described in Section B, Facilities as described in Section H, the Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 wo..rdi~ng. and rolocatod to the SNC Standard Appendix 9: All The SNC Standard Emergency Plan/Annex provides the agencies and descriptions as required by Appendix E in their respective sections eliminating the need for a standalone appendix.E15-2 12 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 16 Evaluation of Proposed Changes LAR for the Revision to Vogtle 3 and 4 Emergency Planning ITAAC (No Changes)
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 17 Vogtle (Units 3 and 4)Revision to Unit 3 COL Appendix C -Proposed Changes -Markups (No Changes)
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 18 Vogtle (Units 3 and 4)Revision to Unit 4 COL Appendix C -Proposed Changes -Markups.(No changes)
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 19 Off-site Response Organizations Letters of Consultation and Concurrence
- New Letters Replacing Originals**
"STATE OF ALABAMA DEPARTMENT OF PUBLIC HEALTH Thomas M. Miller, M.D.Acting State Health Officer February 8, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201
Dear Mr. Meier,
This letter is in response to the request from Southern Nuclear (SNO) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and .4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Alabama Department of Public Health I Office of Radiation Control (ADPH) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Alabama Radiological Emergency Preparedness Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how ADPH would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Alabama REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Alabama REP does not address augmentation response times for site personnel.
SNC also informed ADPH staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Alabama REP with a level of detail of the overall content of the plan consistent with a planning level document.
The ADPH staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.'The RSA Tower .201 Monroe Street.* Montgomery, AL 36104 PO. Box 303017.* Montgomery, AL 36130-3017 SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.ADPH concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of ADPH concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely, T~onya ApeadDrco Emergency Planning Branch Office of Radiation Control Alabama Department of Public Health STATE OF ALAIBAMA ~B~EMERGENCY MANAGEMENT AGENCY 5898 COUJNTY ROAD 41
- P.O. DRAWER 2160
- CLANTON. ALABAMA 35O46-2160 4 (205)280-2200 FAX # (205) 280-2495 ~4 C ROBERT BENTLEY ART FAULKN GOVEzRNOR DIRhCI OR.Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Alabama Emergency Management Agency (AEMA) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Alabama Radiological Emergency Preparedness Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how AEMA would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Alabama REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to "75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Alabama REP does not address augmentation response times for site personnel.
SNC also informed AEMA staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Alabama REP with a level of detail of the overall content of the plan consistent with a planning level document.
The AEMA staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.qER SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNO also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.AEMA concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of AEMA concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Director of Response Operations 205-280-2262 Tim.Payne@ema.alabama.gov AIKEN COUNTY M GEC Department of Emergency Services 'Emergency Management Division I I RG A C Suite 1100 .Aiken, South Carolina, 29801 V ~ ' IKEN COUNTY Telephone:
(80I3) 642-1623 FAX: (803) 642-2556 February 1I, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201
Dear Mr. Meier:
This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Aiken County, South Carolina Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs).The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Aiken County, South Carolina Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Annex Q2, Part 2, Fixed Nuclear Faclity (FNF) Radiological Emergency Response Plan (RERP)to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Annex Q2, Part 2, Fixed Nuclear Faclity (FNF) Radiological Emergency Response Plan (RERP) to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant does not address augmentation response times for site personnel.
SNC also informed Aiken County, South Carolina Emergency Management starr that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Annex Q2, Part 2, Fixed Nuclear Faclity (FNF) Radiological Emergency Response Plan (RERP) to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant with a level of detail of the overall content of the plan consistent with a planning level document.
The Aiken County, South Carolina Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of' the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received rrom the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Aiken County, South Carolina Emergency Management concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.Please consider this letter as a written indication of Aiken County, South Carolina Emergency Management concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sji 5 rely, Paul Matthews Emergency Manager Aiken County Emergency Management Division Gidget L. Stanley-Banks, Director William Robinson Jr., Asst. Director 911-B Main Street North Allendale, South Carolina 29810 803-584-4081
-Phone 803-584-3807
-Fax February 11, 2016 Mr. Mikce Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295*42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Allendale County, Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Allendale County, Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through February 11, 2016 continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant does not address augmentation response times for site personnel.
SNC also informed Allendale County, Emergency Management staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant with a level of detail of the overall content of the plan consistent with a planning level document.
The Allendale County, Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Allendale County, Emergency Management concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Allendale County, South Carolina.Please consider this letter as a written indication of Allendale County, Emergency Management concurrence with the Southem Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely Yours, Gidget L. Stanley-Banks 0 Page 2 Post Office Box 747 DANE BRUCE BAXLEY, GEORGIA 31515 DARRELL HOLCOMB Director Telephone (912) 367-8170 Deputy Director Febrary15, 016acema@bellsouth.net Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with App~ling County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (ORes) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Georgia Radiological Emergency Plan Annex A -Plant Hatch. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Appling County Emergency Management Agency would respond to a radiological emergency any of the SNC sites nor does it necessitate a change to the current Georgia Radiological Emergency Plan Annex A -Plant Hatch nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Georgia Radiological Emergency Plan Annex A -Plant Hatch does not address augmentation response times for site personnel.
SNC also informed Appling County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Georgia Radiological Emergency Plan Annex A -Plant Hatch with a level of detail of the overall content of the plan consistent with a planning level document.
The Appling County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNO fleet standard emergency plan due to changes in the title of the document.
D Post Office Box 747)ANE BRUCE BAXLEY, GEORGIA 31515 DARRELL HOLCC Director Telephone (912) 367-8170 Deputyi acema@bellsouth.net SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Appling County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Appling County, Georgia.Please consider this letter as a written indication of Appling County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.)MB}Dane Bruce, Director Appling County Emergency Management Agency February 5, 2016 Mr. Mike Meler Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Barnwefl County, South Carolina Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Barnwell County, South Carolina Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNO's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant does not address augmentation response times for site personnel.
SNC also informed Barnwell County, South Carolina Emergency Management staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant with a level of detail of the overall content of the plan consistent with a planning level document.
The Barnwell County, South Carolina Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNO emergency plan documents such that they will submit~the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Barnwell County, South Carolina Emergency Management concurs with SNO's assessment of the benefits of the proposed changes to their emergency plans.We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.
Please consider this letter as a written indication of Barnwell County, South Carolina Emergency Management concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4.Sincerely, .,./Roger Riley, Director Bamnwel[ County Emergency Management 57 Wall Street Barnwell, SC 29812 Office 1 -803-259-7013 Fax -803-259-1759 Cell -803-541-2013 Blakely-Early County Emergency Management Anthony Gentry, Director P.O. Box 7-"6 -i86io East South Blvd.Blakcly, Ga. 39823 Phone: 229-7-23-3029
/ Fax: 229-723-5908 E-MaiI-becema@windst ream.net Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Blakely -Early County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Georgia Radiological Emergency Plan Annex B-Plant Farley. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Blakely -Early County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Georgia Radiological Emergency Plan Annex B -Plant Farley nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Georgia Radiological Emergency Plan Annex B-Plant Farley does not address augmentation response times for site personnel.
SNC also informed Blakely -Early County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Georgia Radiological Emergency Plan Annex B -Plant Farley with a level of detail of the overall content of the plan consistent with a planning level document.
The Blakely -Early County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Blakely -Early County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Blakely -Early County, Georgia.Please consider this letter as a written indication of Blakely -Early County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Anthony Gentry, Director Early County EMA Burke County Emergency MAanagement Agency Fire 277 Highway 24 South EMS Waynesboro, Georgia 30830 Tel. (706) 554-6651 Fax (706) 554-4660 E-Mail: rsanders(~burkecountv-ga.geov Dedicated To The Protection Of Life And Property Rusty Sanders -Chief Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Burke County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Plant Vogtle Burke County Emergency Management Radiological Plan.Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Burke County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Plant Vogtle Burke County Emergency Management Radiological Plan nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Plant Vogtle Burke County Emergency Management Radiological Plan does not address augmentation response times for site personnel.
SNC also informed Burke County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Plant Vogtle Burke County Emergency Management Radiological Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Burke County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Burke County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Burke County, Georgia.Please consider this letter as a written indication of Burke County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Respectfully Yours, R~4~y S~vtders'Rusty Sanders -Burke County EMA Director Georgaia Department of Natural Resources Environmental Protection Division, Air Protection Branch 4244 international Parkway, Suite 120, Atlanta, Georgia 30354 404-363-7000 Judson H. Turner, Director February 8, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Georgia Department of Natural Resources, Environmental Protection Division, Environmental Radiation Program (GADNR) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan.We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs).The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the GEMA/HS Radiological Emergency Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how GADNR would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current GEMAIHS REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The GEMA/HS REP does not address augmentation response times for site personnel.
SNC also informed GADNR staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the GEMA/HS REP with a level of detail of the overall content of the plan consistent with a planning level document.
The GADNR staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.GADNR concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans.We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of GADNR concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely, Sidney B. Simonton Team Leader, Environmental Radiation Program GEORGIA EMERGENCY MANAGEMENT AGENCY GEORGIA OFFICE OF HOMELAND SECURITY NATHAN DEAL JIM BUTTERWORTH GOVER D IRECTO R February 9, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201
Dear Mr. Meier:
This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Georgia Emergency Management Agency/Homeland Security (GEMAIHS) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (ORG s) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the GEMA/US Radiological Emergency Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERG). These changes do not alter how GEMA/HS would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current GEMAIHS REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERG at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The GEMA/US REP does not address augmentation response times for site personnel.
SNC also informed GEMAIHS staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the , "S. "' Li .Post Office Box 1 8055
- Atlanta, GA 30316-0055 (404) 635-7000
- Toll Free in Georgia 1-800-TFY-GEMA -www.gema.ga.gov Mr. Mike Meier Page Two February 9, 2016 GEMAIIHS REP with a level of detail of the overall content of the plan consistent with a planning level document.
The GEMA/HS staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also infonmed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.GEMA/HS concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of GEMA/HS concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely, Stephen Clark Program Director Radiological Emergency Preparedness
/sc Henry County Emergency Management Agency 101 North Doswell St. Abbeville, Al 36310 (334)-585-6702 (334)-585-1616 (fax)Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Henry County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emer~gency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Alabama Radiological Emergency Preparedness Plan. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERa). These changes do not alter how Henry County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Alabama Radiological Emergency Preparedness Plan nor does it alter the existing points of interface with the utility.We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common OEO from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Alabama Radiological Emergency Preparedness Plan does not address augmentation response times for site personnel.
SNC also informed Henry County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Alabama Radiological Emergency Preparedness Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Henry County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Henry County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of Henry County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Ronnie Dollar Director Dothan/Houston County Emergency Management Steve Carlisle Director Leigh Adams Deputy Director Charles Finney Plannin Kris Ware Support/PIO P.O. Drawer 6406 Dotban, Alabama 36302 (Phone) 334.794.9720 (Fax) 334.793.3550 February 8, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Dothan/Houston County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents.
Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Houston County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents nor does it alter the existing points of interface with the utility.
Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.Page 2 We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents, does not address augmentation response times for site personnel.
SNC also informed Dothan/Houston County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents with a level of detail of the overall content of the plan consistent with a planning level document.
Dothan/Houston County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Dothan/Houston County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of Dothan/Houston County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Regards, stteve Director Dothan/Houston County Emergency Management Agency CHARLES DIRECTC j JEFF DAVIS COUNTY EMERGENCY MANAGEMENT AGENCY 2 10 PUBLIC SAFETY DRIVE HAZLEHURST, GEORGIA 31539 rASDiN KATHY W. LORDCLERK PHONE (912) 375-6628 Mr. Mike Meier, Vice-President Regulatory Affairs Southern Nuclear Operating Company, Inc.P. 0. Box 1295 42 Inverness Center Parkway Birmingham, Alabama 35201
Dear Mr. Meier:
This letter is in response to the request from Southern Nuclear (S NC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Jeff Davis County Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Jeff Davis County Emergency Management Agency Emergency Operations Plan. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Jeff Davis County Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Jeff Davis County Emergency Management Agency Emergency Operations Plan nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Jeff Davis County Emergency Management Agency Emergency Operations Plan does not address augmentation response times for site personnel.
SNC also informed Jeff Davis County Emergency Management staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Jeff Davis County Emergency Management Agency Emergency Operations Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Jeff Davis County Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNO's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Jeff Davis County Emergency Management concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.Please consider this letter as a written indication of Jeff Davis County Emergency Management concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely yours, Charles Wasdin, Director Jeff Davis County EMA PROM IOTE PROTE! p P! OS, P R Cadrierine E. Hei~el, Director February 16, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 RE: Southern Nuclear consolidation of emergency pians Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with South Carolina Department of Health and Environmental Control (SCDHEC) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title oi" Emergency Director vested with the cormnand and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and SCDHEC. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how SCDHEC would respond to a radiological emergency at any of the SNC sites nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs)to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. SNC also informed SCDHEC staff that the format of the SNC emergency plan would include a base document and site specific annexes with a level of detail of the overall content of the plan consistent with a planning level document.
No changes will need to be made in DHEC's plans/SOPs (SC Technical Radiological Emergency Response Plan/SC Technical Radiological Operating Procedures) to support the implementation of the proposed SNC fleet standard emergency plan.2(3(X) Bull Suic *ee ( olimnhiaSC292t0!
Phione:(8(33) 898-3 132
- www.scdhlc-.gov SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance;however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.SCDHEC concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.Please consider this letter as a written indication of SCDHEC concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4. If you have any additional questions, you may contact me at 803.896.4111 or Respectf ,ly Chris Staton, Director Division of Emergency Response Bureau of Environmental Health Services 2600 Bill SIrcee * (k:OIilumia.,SC 29201
- 1'hoic: (803) 898-3132
- www.scdhicc.gov 2!1Page
~'aeof 'outhi Carotiia OFFICE OF THE ADJUTANT GENERAL THE ADJUTANT' GENERAL February 16, 2016 MrT. Mike Mejer Vice President' Regulatory Affairs SouflhernNuclear Operating
'Company, Inc.P.O. Box 1295Inverness C(enter Parkway Birmingham, AL 3520_1
Dear Mr~. Thifs letter i's -in response to the request:
from' Southern Nuclear I(SNC) for written concurrence on the proposal 'to consolidate the Plant Farley, .Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3- and 4 em'etgency plans into a singie common emergen~cy plan wi~th s iteg'specific.
annexes to address emnergcncy plan elements unique to the specific-sites.
A member the Soulthern Nuclear Emergency Preparedniess staff met with South Carolina Emergency Managemenit Divi'sion (SCEMP) and discus sed this proposal in detail-and allowed us to provide feedback on the proposed fleet standard emergency plan. 'We discussed
'the changes ;to the EOE staffing, most notably the addition of a senior decision maker wvith the title of Emnergency Dir-ector vested with' the command and control authority for -approving notifications to off-site response organizations (OROs) and f'or approval of Protecetive Action Recommendati~ons (PARs). The addition of this new leadership position' will 'not alter the interface bet~ween thle utility and 'the 'state oQ" South carolina aS described in 'the South Carolina Operational Radiological Emergency ReSponse Plan (SCORERP), Additionally, we discussed SN.C's proposed 'changes 'to' their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC si'tes with a common emergency respon~se organizatioh (ERO).These chianges .not alter how SCEMD would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current SCORERP nor does it alter the existi'ng points of interface with the utility. We further understand that part; of the staffing changes includes transitionin3g from three radiological -field monitoring teams (FMTs)'to two FMTs. Through continued coordination the State and utility radiological assessment organizations,, adequate monitoring will be maintained.
We also discussed SNC's proposal Emergency Management Division 2779'Fish Hatchery Road West Columbia, South Carolina 291-72'(803) 737-8500 Fax (803) 737-8570.
to change ,he definition for augmentatiotn time for their ERO -at Plant Hatch, Plant Vo'gtie and, the common EOF' from 60 minutes from notification of an Alert- or high~er emergency with 1 5 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency, We recognize this. augmentation time is effectively the same time period. The SCORERP does not address augmentation response times for site p ersontiel.
SNC also. informed SCEMD staff that the format of thae S'NC emergencY, plan would include :a base document and 'sit:e specific .annexes similar to that of the SCORERP with a level of detail of thne overall content of the plan consistent with a planning level document.
The SCEMD .staff does recognize that minor administrative changes will nee~d to be made to support the implementation of the proposed SNC :fleet standard emergency plan due to ch~anges ini thle title of the document.SNC disc:ussed with our staf'f how thle proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emnergenc~y response efforts to. better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes, are consistent With curr'ent regu~latory requirements and applicable guidance; however they do constitute .a sign~ificant charige in the, SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. (NRC). SN.C also informed our staff that implemerntation of the new S'NC fleet, standard emergency plan.wou~ld not occur Until final approval was received Were properly traine~d and prepared to transitionj to the new emergency plan.SCEMD ,concUrs with SNC's assesstnert of the, benefits, o~f the proposed changes to their emergency plans. We also agree that .it is appropriate and .prudent to request a full review and approval of the proposed changes to 'the. SNC emer~gency iplans by the NRC to ensure the SNC enmergenicy plan continues to reasonable assurance of their ability to pr~otect the safety and health of the cit-izens of South Carolina.Please consider thils as a written indication of SCEMD concurrence with the Southern NUclear proposal to a common emnergency plan for Plant Farley, Plant Hatch', 'Plant Vogtle Units I and 2 and Planto Vogtle Units 3 and 4.Sincerely, Kim Stenson Director KS/jlt From: Cla rissa .waller~srs.pov To: Grant, Judly D.Cc: debra~foutch~srs~gov
Subject:
-
SRS Agreement with SNC Emergency Plan Date: Friday, February 12, 2016 10:04:02 AM Ms. Grant, Per the teleconference on Tuesday, and as promised, SRS has looked at the update to the SNC Emergency Plan and reviewed the changes. We have no further comments, and the letter submitted in Dec 2015 is still applicable.
Please let me know if you have any further questions.
Thanks, Crissy Wailer Savannah River Site Office of Safeguards, Security and Emergency Services Emergency Management Specialist Building 730-2B, #2040 803-952-8531 Office 803-507-5439 Cell Tattnall County Fire & Rescue Walt D. Rogers, Chief POB 905 194 John 0. Parker Drive Office: (912) 557-6820 Reidsville, GA. 30453 Fax: (912) 557-6937 tattnallema(dwindstream.net February 5, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Tattnall County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Tattnall County Emergency Management Agency Emergency Operations Plan. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Tattnall County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Tattnall County Emergency Management Agency Emergency Operations Plan nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs.Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EQF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Tattnall County Emergency Management Agency Emergency Operations Plan does not address augmentation response times for site personnel.
SNC also informed Tattnall County Emergency Management Page 1 of 2 Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Tattnall County Emergency Management Agency Emergency Operations Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Tattnall County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Tattnall County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of Tattnall County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4.Sincerely, Walt Rogers, Director Tattnall County Emergency Management Page 2 of 2 Toombs County Emergency Management Agency P.O Box 487 Lyons, Ga. 30436 Date : 02/11/2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Toombs County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of'Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Georgia Radiological Emergency Plan, Annex A -Plant Hatch, Additionally, we discussed SNO's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Toombs County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Georgia Radiological Emergency Plan, Annex A -Plant Hatch nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC'S proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to-- ----- .- -S.
complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Georgia Radiological Emergency Plan, Annex A -Plant Hatch does not address augmentation response times for site personnel.
SNC also informed Toombs County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the GEMAIHS REP with a level of detail of the overall content of the plan consistent with a planning level document.
The Toombs County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNO fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Toombs County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNO emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of Toombs County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Toombs County EMA Director Lynn Moore 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 13 Vogtle (Units 3 and 4) Staffing-Detailed Description And Technical Evaluation (Marked-up pages)
Enclosure 13 to NL-1 6-01 69 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation Jucional ~t.Area Mt~nrR~ajrTasfoiio*il Media Response Media Response Public Information Director Nuclear Spokesperson Technical Assistant JIC Manager JIG Assistant**
Facility Coordinator**
Clerical Staff**Security**
Public Response Coordinator Public Response Staff**Media Relations_____________________
_ ___ ____ ___ ___ ___ ___ Representative
- JI Acitnt Fciiy Clorical Staff Socu...ty, and Public, Roeponco,,-
Staff do not have a 75 minute augmentation time.Minimum staff positions have been identified for each facility.
Facility activation may be completed upon filling of minimum staffing positions and completion of a briefing on the event to ensure personnel in these positions are ready to accept responsibility for their functions.
Minimum staffing positions for the TSC Organization are as follows:* TSC Emergency Director (ED)* TSC Emergency Response Facility (ERF) Communicator
- TSC Engineering Supervisor Minimum staffing positions for the Operations Support Center (OSC) Organization are as follows:* OSC Manager* OSC Emergency Response Facility (ERF) Communicator
- OSC RP/Chemistry Group Lead Minimum staffing positions for the EOF Organization are as follows:* EOF Emergency Director (ED)* EOF Emergency Response Facility (ERF) Communicator
- EOF Dose Analyst* EOF ENN Communicator Minimum staffing positions for the Joint Information Center (JIG) Organization are as follows: El13-15 Enclosure 13 to NL-1 6-01 69 Vogtle (Units 3 & 4) Staffing -Detailed Description and Technical Evaluation
- Public Information Director (PID)* JIC Manager* Media Relations Representative
- Public Response Coordinator In addition to the functional analysis provided, the key Emergency Response Facilities were analyzed to determine the minimum staffing (both numbers and positions) needed for the facilities to activate the facilities and begin facility operations.
Any personnel determined to be required to support the minimum staff activation and initiation of activities were added to the revised augmented ERO.Program Enhancements The following section discusses technical aspects of plant systems, dose assessment, procedures, and training which support on-shift functions and ease operator burden. Additional information regarding on-shift and augmented positions and their responsibilities as identified in NUREG-0654/FEMA REP-Ol Revision 1 are included in Enclosure 15.Plant Computer System The VEGP Unit 3 and Unit 4 Safety Parameter Display System (SPDS) is a state of the art system integrated into the overall man-machine interface for VEGP Unit 3 and Unit 4. It provides a display of plant parameters from which the status of operation can be assessed, in the control room and in the onsite and off-site Emergency Response Facilities (ERFs).This state of the art SPDS:* Aids the control room operators in the rapid detection and identification of abnormal operating conditions.
- Provides additional specific information to analyze and diagnose the cause of abnormal operating conditions.
- Monitors plant response to corrective actions.* Provides grouping of parameters to enhance the operators' capability to assess plant status quickly without surveying all control room displays concurrently.
- Directs the operators' attention to other specific confirmatory non-SPDS control room displays.* Provides human factors engineered display formats in simple and consistent display patterns and coding.* Provides display information on a real-time basis, along with validation of data.* Provides generated selectable trend displays on a real-time basis for monitoring reactivity control, reactor core cooling and heat removal from the primary system, reactor coolant system integrity, radioactivity control, containment integrity, and other selected parameters.
The SPDS in the control room consists of displays of sets of concentrated parameters from which plant safety status can be rapidly assessed.
Duplicate SPDS displays are located in the El13-16 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 14 Vogtle (Units 3 and 4)Standard Emergency Plan Annex (Marked-up pages)
Enclosure 14 to NL-1 6-01 69 Vogtle (Units 3 & 4) Standard Emergency Plan Annex located in the near site media center in Waynesboro, GA. The alternative facility is equipped with the necessary communications and data links to support communications with the control room, site security and the EOF. The available communications and data links also provide access to the SNC document management resources, work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is contained in site procedures.
5.1.5 Emergency
Operations Facility (SEP H.2.1)The EOF is the central location for management of the offsite emergency response, coordination of radiological assessment, and management of initial recovery operations.
The EOF is a dedicated facility located in Birmingham, Alabama, and serves as the EOF for SNC sites (VEGP, FNP, and HNP).Additional details of the EOF are contained in section H.2.1 of the Emergency Plan.The near site location is maintained at the Vogtle Training Center space for members of an NRC Site Team.5.1.6 Joint Information Center (JIC) (SEP H.2.2)The VEGP JIC is located in Waynesboro, Georgia adjacent to the Georgia Power Company operating headquarters.
The JIC is the central location for the coordination and dissemination of information to news media and responses to public and media inquiries.
Details of the JIC for VEGP can bo foundlare in section H of the Emergency Plan. If the decision is made to meve-activate the JIC the CMC in Atlanta, Georgia will maintain emergency communications response coordination until the JIC is ready to assume these responsibilities.
facIit, wi;1l mai;n'tain media unt÷I the lICi" at th-o site E14-20 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 15 Vogtle (Units 3 and 4)Justification Matrix (Marked-up pages)
Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 B.1 Normal Plant Organization EP B.1 Normal Plant Organization The commitment wording was The organizational structure shown on Figure B-i The normal onsite organization of a SNC operated nuclear standardized and relocated to represents the pool of management personnel power plant provides a staff capable of providing the initial the SNC Standard Emergency available on site during normal working hours, response to an emergency event. The On-Shift staff was Plan and Site Annex.Approximately 700 people are stationed at Units validated by performing a detailed staffing analysis as 1 and 2 during the standard workday, and required by Part 50 Appendix E.IV.9. Organizational A Staffing Analysis supporting approximately 650 people will be stationed at structures for each of the sites and the on-shift staffing the on-shift staffing design and Units 3 and 4 during the standard workday. tables are provided in the Site Specific Annex. The compliant with 10 CFR 50 The normal operating crew for each unit includes number and ERO position titles of personnel available Appendix E.IV.A.9 was a shift supervisor, licensed plant operators, and within 75 minutes following declaration of an emergency is conducted to support the non-licensed plant operators.
A Shift Manager is shown in Tables 1, 2T and submittal.
also on shift during operation (as defined in the SNC plants maintain 24-hour emergency response Technical Specifications).
Personnel from the capability.
The normal on-shift complement provides the Chemistry and Health Physics, Maintenance, and initial response to an emergency.
This group is trained to Security Departments are also on site respond to emergency situations until the augmented continuously.
Emergency Response Organization (ERO) arrives. The ERO is composed of personnel with specialties in operations, maintenance, engineering, radiochemistry, radiation protection, material control, fire protection, and security_______________________________Annex Table 2.2.A Minimum Shift Staffing _____________
E15-25 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _____________
B.2: During hostile action, ERO members would EP H.1.4 An Alternative Facility for staging of ERO The commitment wording was likely not have access to the onsite emergency personnel has been designated at the sites. In the event standardized and relocated to response facilities.
A security related emergency of a Security or Hostile Action threat or event, the the SNC Standard Emergency may delay the ordering of facility activation in designated Alternative Facility may also serve as an Plan and Site Annex.order to protect plant personnel from the security evacuation location for TSC and OSC personnel.
The threat. The decision to delay activation of the Alternative Facility is designed to be accessible in the The SNC Standard Emergency facilities will be made by the Emergency Director.
event of an onsite HAB event and has the capability to: Plan and Annex provide However, these events will warrant timely ERO a Communicate with the Control Room, Security, commitments to maintain the augmentation.
An alternative facility has been and the EOF. communications capabilities identified to ensure rapid access to the site by
- Conduct engineering assessment activities within the ERO, required offsite augmented staff due to its close proximity.
The including damage control team planning and responders and the public alternative facility is located in a designated area preparation through the execution of a Joint in the Joint Information Center (JIC) in The functions of Notification and PARs will be performed Information System. The Waynesboro, Georgia. This facility has been from the EOF should the Alternative Facility be activated, detailed physical description of established to minimize delays in overall site Details of Alternative Facilities can be found in the Site equipment maintaining those response by permitting ERG assembly without Specific Annex. commitments is subject to exposing responders to the danger of hostile Annex 5.1.4 During a security related event or other event change and not necessary to action. This facility functions as a staging area for that precludes onsite access, the TSC, and OSC ERG ensure effective implementation augmented ERG staff until the site is secured. staff will be directed to an alternative facility.
This facility of the Emergency Plan.is located in the near site media center in Waynesboro, .Additional dotaile on tho JIC!JIS GA. The alternative facility is equipped with the are in. ..... coparato+necessary communications and data links to support onclocuroa a.. par thi;c L' ^communications with the control room, site security and the EOF. The available communications and data links also provide access to the SNC document management resources, work planning resources for performing engineering assessment activities including damage control team planning and preparation for return to the site. Guidance for use of the facility is contained in site procedures._______________
B.2.1 Emergency response organization EP H.1: SNC operated nuclear power plants have The commitment wording was ResponsibilitiesFollowing an Alert or higher established a TSC and an onsite OSC, which are staffed standardized and relocated to emergency declaration, the positions shown on and activated within 75 minutes of the declaration of an the SNC Standard Emergency Figures B-2 and B-3 will be filled by Site or SNC Alert or higher classification.
Plan.personnel as discussed below. EP H.2.1: Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification.
EP Figure B.2.B, B.2.C, B.2.D, and B.2.E: illustrates the standard Emergency Organization._______________
E15-29 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision3
[3_ _ _ _0.1: Representatives from the states of Georgia and South Carolina will be dispatched to the emergency operations facility (EOF) and the emergency news center (ENG).EP H.2.1: It is anticipated that representatives from the State(s)of Georgia, South Carolina, Alabama, or Florida may be dispatched to the EOF for an event at specific SNO site(s).EP H.2.2Joint
!nforma.tion Center (JC)orort-Mei Center (CMC)Upon notification of an Alert or higher classification, the Public Information Director and corporate staff assigned to JIG functions will assemble at the 0MG. The 0MG, located at the Atlanta/Birmingham corporate headquarters building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination of emergency communications response until the site specific JIG has been activated.
The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIG. When the decision is made to activate the JIG the 0MG will maintain emergency communications response coordination until the site specific JIG is ready to assume these responsibilities.
Once overall responsibility for emergency communications response transfers to the site specific JIG the remaining 0MG staff will provide support for the JIC as needed.hedquartersbuildin g of Goorgiat~." t oorth Company:!Alaeetbamae ts m b.eingquiriocerntdt h mx'-the is the poin,"t ofi ! cotat wi th r!'.dt~ the os ei du-ing a: dclaredtht I emergency.-
The : to facltosused to cordinato dissemlinatio of to, ithe be etablished ito pos .'ible. Followngativati~g~m!.+ton of to J ! in nt!The commitment wording was standardized and relocated to the SNC Standard Emergency Plan.The SNC Standard Emergency Plan and Annex provide commitments to maintain the communications capabilities within the ERO, required offsite responders and the public through the execution of a Joint Information System. The detailed physical description of equipment maintaining those commitments is subject to change and not necessary to ensure effective implementation of the Emergency Plan.Addi~tional deti,-;ls on the liG/JIIS E15-44 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3. Joint Information Center (JIC) The commitment wording was After the initial notification of an emergency at the Alert standardized and relocated to classification or higher, the Public Information Director will the SNC Standard Emergency coordinate with the EOF Emergency Director and affected Plan.OROs and determine whether to activate the JIG. Upon the decision to activate the JIG, the Public Information Director and JIG staff transfer from the 0MG to the site specific JIG. Once the JIG is staffed the Public Information Director will manage the emergency communications response from the JIG in coordination with ORO public information officers (PIOs).Site specific JIG is provided in the site specific Annexes.E 15-45 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _____________
F.9: In-plant monitoring teams will communicate Specific communications with the Health Physics or 0S0 communicator at frequencies between the OSC least every half hour. and dispatched response teams are event specific and determined on a case by case basis for the event. A Plan commitment is not appropriate and could actually hinder effective response.F.9: The field monitoring team radio covers the EP F Table 5 The capability to dispatch teams entire plume exposure pathway EPZ. and for those teams to function is maintained in the SNC Standard Emergency Plan. This statement of radio coverage is not required.F.9: Remote stations for communicating with the EP F.1 .1: At SNC operated nuclear power plants, several The commitment wording was field monitoring teams are located in the TSC modes of reliable communication are available, during standardized and relocated to and the EOF. both normal and emergency conditions, to transmit and the SNC Standard Emergency receive information among the Control Room, TSC, OSC, Plan and Site Annex.EOF, and at other locations onsite and off site.EP F Table 5 Table F-i: All EP F Table 5 The commitment wording was standardized and relocated to the SNC Standard Emergency Plan.The-epemt~ienaI Section G Public Education and Information G: Georgia Power Company (GPC) and EP G,8: The goal of the public information program is to The commitment wording was Southern Nuclear Operating Company (SNC) in acquaint the general public with the emergency plans for standardized and relocated to coordination with State and local officials will the operation of APC/GPC nuclear plants, as appropriate, the SNC Standard Emergency provide information to the public at least annually and actions they should in the event of a plant emergency.
Plan.regarding how they will be notified and what their Emergency Information is disseminated each calendar actions should be in an emergency.
year for residents and transients in the plume exposure________________________________pathway Emergency Planning Zone.E15-78 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 G.2: The emergency news center (ENC) will be EP H.2.2: Corporate Media Center (CMC) The commitment wording was the principal point of contact with the news media upon notification of an Alert or higher classification, the Public standardized and incorporated an emergency.
The ENC will Information Director and corporate staff assigned to JIC functions wi nolhlROSafiga during aneegny h N ilassemble at the CMC. The CMC, located at the Atlanta/Birmingham it h ~ tfiga accommodate public information representatives corporate headquarters building of Georgia Power Company/Alabamna described in Section B, Facilities from SNC, GPC, State, local and Federal Power Company, as appropriate, is the official location for coordination as described in Section H, the response agencies, of emergency communications response until the site specific JIC has Emergency Communications been activated.
The Public Information Director will coordinate with the g~EOF Emergency Director and affected ORes and determine whether to portion of Section G of the SNC activate the site specific JIC. When the decision is made to activate the Standard Emergency Plan and JIC the CMC will maintain emergency communications response Section 5.1.6 of the Vogtle 3-4 coordination until the site specific JIC is ready to assume these Annex. and relocated to the responsibilities.
Once overall responsibility for emergency sr~' St.andard,.
Emerg..nc.
communications response transfers to the site specific JIC the remaining Pn..............
Standard CMC staff will provide support for the JIC as needed. P=.h .CS~dr Annex 5.1.6. The VEGP JIC is located in Waynesboro, Georgia, Emergenc..
Pla ..nd Sit Annex..adjacent to the Georgia Power Company operating headquarters.
The ___,,,,;_.....__,,__,,_-____...__...
JIG is the central location for the coordination and dissemination of pro..id....
an .....o...tructur information to news media, and responses to public and media inquiries, an ..............
capability for Details of the JIG for VEGP are in section H of the Emergency Plan. If Infor.mation to the the decision is made to activate the JIG the CMC in Atlanta, Georgia will pub.libc in the e'vent of a claccified maintain emergency communications response coordination until the JIC emergen~cy.
The n.ew s,'tem is is ready to assume these responsibilities.
building 0f Goorgia Poer'c Cm..panV/A~abama-Poe:;r Com.-nype, a, in' the... technical_....
Tho. JIC is tho peint of contact 'with' tho dur.ing a declare'd rocpon- .... oncios..News roloa... and deofings pro media attention, the Pu-blic Direc'to.r
,:.ll dtre'=ct, that JIC operatins mo've to a for:vard near s.ite loca=tion.
If ..h. decision is made JIC is opo'rationp!
at the near cite location.ANNEXN 5.1.6 The JIC is the cental location for the coordination and facility ,-.-:! maintain cooe.Jrdition unti! the JIC is oporatinal at the E15-82 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3. Joint Information Center (JIC) The commitment wording was After the initial notification of an emergency at the Alert standardized and incorporated classification or higher, the Public Information Director will into the ERO Staffing as coordinate with the EOF Emergency Director and affected described in Section B, Facilities OROs and determine whether to activate the JIC. Upon as described in Section H, the the decision to activate the JIC, the Public Information Emergency Communications Director and JIG staff transfer from the 0MG to the site portion of Section G of the SNO specific JIG. Once the JIG is staffed the Public Information Standard Emergency Plan and Director will manage the emergency communications Section 5.1.6 of the Vogtle 3-4 response from the JIG in coordination with ORO public Annex. The commitmont information officers (PIOs). .ording , a; .. ta...d.rdiz;,o, and, Site specific JIG is provided in the site specific Annexes. rlo~cavted to the SNC Standard E15-83 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan TRevised SNC Emergency Plan Justification Revision3
__3_ _ _ _ _ _ _ _ _ _ _G.2: GPO will utilize the Corporate Headquarters Building at 241 Ralph McGill Boulevard, NE, Atlanta, Georgia, to serve as a temporary information center until the ENC in Waynesboro (Burke County Office Park) is activated.
EP H.2.2: Corporate Media Center (CMC)Upon notification of an Alert or higher classification, the Public Information Director and corporate staff assigned to JIC functions will assemble at the CMC. The 0MG, located at the Atlanta/Birmingham corporate headquarters building of Georgia Power Company/Alabama Power Company, as appropriate, is the official location for coordination of emergency communications response until the site specific JIC has been activated.
The Public Information Director will coordinate with the EOF Emergency Director and affected OROs and determine whether to activate the site specific JIC. When the decision is made to activate the JIC the CMC will maintain emergency communications response coordination until the site specific JIC is ready to assume these responsibilities.
Once overall responsibility for emergency communications response transfers to the site specific JIG the remaining CMC staff will provide support for the JIC as needed.The commitment wording was standardized and incorporated into the ERO Staffing as described in Section B, Facilities as described in Section H, the Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. Tocmimn wording. was. s.ta.n-da-rdi--od an.'d rotl,,ca.ltod. ~the SNOl/'
headquarters building of Georgia Power Compan~'Alabama Power Company, as appropriate, is tho official location for coordination and issuance of news announcements and responses to news media !nguirios The JIC is the point of contact with the news media during a declared emergency.
The JIC facilities used to coerd~nate the dissemination of information to the med~a wil' be eetab!ishod to accommodate public information representatives from the licensee, Federal, State, and ~oca! response agencies.
News re!oasec and media briefings are coord~natod to the maximum o~ent possible.
Following activation of the JIC in Atlanta'Birmingham, the Public !nformatien Director will evaluate the nature of the event and if it is determined that the event will be a prolonged event, is Iike!y to escalate or likely to result in significant media attention, the Public Information Director will direct that JIC operations move to a for~ard near site location.
If the decision is made to move the JIC function to the near site media coordination until tho JIC is operational IGG~MOA~at..the near site E15-84 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 H.2.3 Joint Information Center (JIC) The commitment wording was standardized and incorporated After the initial notification of an emergency at the Alert into the ERO Staffing as classification or higher, the Public Information Director will described in Section B, Facilities coordinate with the EOF Emergency Director and affected as described in Section H, the Emergency Communications OROs and determine whether to activate the JIG. Upon portion of Section G of the SNO the decision to activate the JIG, the Public Information Standard Emergency Plan and Director and JIG staff transfer from the 0MC to the site Section 5.1.6 of the Vogtle 3-4 specific JIG. Once the JIG is staffed the Public Information Annex. Th omimn Director will manage the emergency communications
..ording a .. tand..rdi...d..nd response from the JIG in coordination with OR0 public r.locat.d....th......S.andard information officers (PlOs). E Site specific JIG is provided in the site specific Annexes.G.2: In addition, technical brief ers have been EP B.3.1-82.9 EFl--Technical Assistant The commitment wording was designated who can provide general and The Technical Assistant reports to the Nuclear standardized and incorporated background information.
Spokesperson and is responsible for gathering accurate into the ERO Staffing as and timely information about the event and the plant's described in Section B, Facilities status via displays, tho ERF Communicator, ENN Forms, as described in Section H, the and direct contact with the EOF Manager. Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. Tho SNO Standard The now. systenm is dolsc,*-ribo a-ndl supported, l~n'E15-85 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 ______________________
____________
G.2: The Company spokesperson has access to EP B.3.1-M-2.8 EOF-Nuclear Spokesperson The commitment wording was all information and telephone contact with the The Nuclear Spokesperson speaks on behalf of the standardized and incorporated emergency director through the EOF Manager. company, providing plant status updates during news into the ERO Staffing as He briefs the media on plant status and briefings.
The Spokesperson also may do one-on-one described in Section B, Facilities Company emergency activities, media interviews.
The position works with the Technical as described in Section H, the Assistant in keeping abreast of the event status and keeps Emergency Communications the PID posted on that status. portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. The SNC Standard and functiona!
capbiit for+. ,, G.2 Th Copan spkesersn psiton s E SokeperonInf ormationtngment torn the filld b iniviual wh, uder orml Te Ncler Sokeperon seak onbehlf f te emndrgien d The inowporstemdi operations, hold supervisory positions on the company, providing plant status updates during news into the ERO Staffing as SNC Corporate or plant staff and are technically briefings.
The Spokesperson also may do one-on-one described in Section B, Facilities and professionally qualified to perform this media interviews.
The position works with the Technical as described in Section H, the important function.
Assistant in keeping abreast of the event status and keeps Emergency Communications the PID posted on that status. portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 Annex. The SNO Standard information Management to the E15-86 Enclosure 15 to NL-1 6-01 69 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _____________
G.3: GPO and SNC will provide timely and EP B.3.2.1 JIG-Public Information Director (PID) The commitment wording was accurate information to local, State and federal The PID is responsible for coordination of emergency standardized and incorporated agencies, and will seek reciprocal information information between the utility and responding offsite into the ERO Staffing as from these agencies.
organizations participating in the Corporate Media Center described in Section B, Facilities (CMC) or Joint Information Center (JIC). Additional duties as described in Section H, the include managing approval and dissemination of utility Emergency Communications news bulletins, facilitating news briefings, overseeing portion of Section G of the SNC public response, serving as liaison to the media and Standard Emergency Plan and coordinating off-site agencies.
The PID may delegate Section 5.1.6 of the Vogtle 3-4 emergency communications approval authority to other Annex. Tho SNO Standard staff,,members^"'k--.
Emergenc..
Pla ..nd St Annex^...pm,.rovid.h.
- n update },truhctur.o timel, acurate andconsstentinfomatin to ll apropiate nforationwillbe rlease as leary, stndarizedandtic toprate the pblic nd byhavin a sigle surce f coniselyand qickl as ppublic inbic thouneeennt ofo ae EROStaffngoa asdescribod and Suppctionh Emearatelcy inohemecnicalin analtion of Setion Gubmittal.N adecieinSection H,.6o the Vgl -Annex. The SNC Standard MA'Janagment tho public in the e'-ent of a classified described and4 ..upported E15-87 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _G.4
- To dispel rumors in an emergency, a rumor EP G.4 Press Briefings The commitment wording was control network will be activated.
News media Press briefings will be conducted to keep the media standardized and incorporated will be monitored to detect and respond to informed of events and activities relating to the into the ERO Staffing as misinformation.
emergency.
Briefings will provide the most current, up-to- described in Section B, Facilities date information about events and response to the as described in Section H, the incident.
Public Information Officers (PlOs) from all offsite Emergency Communications agencies responding to the emergency will be encouraged portion of Section G of the SNO to participate in the briefings to discuss their particular Standard Emergency Plan and activities.
Section 5.1.6 of the Vogtle 3-4 Annex. Tho S.NC Standard E-mo.rgncy Plan andl Sito Anney prondo an upd.at.. od ..t.ru.ctu..ro G.5: PC wll ofer a annal prgramto E G.2:A prgramwill e oferedeaandalfunctionaloThecapabilit ordigfor forobtinig iforatin bou ovral obainnginfrmaiondurng n merenc an wih teINfomto Standardomergntoyh emergecy prearednss at he VEG. Traning oerpublicrgein prharednentatofC/aPCnucleaiPlan and te rol of te emegenc newscente, abot th plamergegnccyrespnoenad therolemf th JIC as ell as pportunties toparticiatininthilltachnicals foS bannenomainaotoealcbann nomtion duin aEmergency andwihiteiNtitadar Eergnc Equipment E15-88 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3_____________________________________
Appendix 7 A.3: Offsite support personnel and EP B.3.1 .3 EOF Support Coordinator The commitment wording was equipment will be dispatched to the site The Support Coordinator reports to the EOF Manager. standardized and relocated to Operations Support Center (OSC) or Technical The duties and responsibilities of the Support Coordinator the SNC Standard Emergency Support Center (TSC) upon request from the in the EOF include providing oversight of the News Writer, Plan.specific site Emergency Director.
providing assistance to the Support Coordinator in the TSC for ordering equipment and materials needed and logistics arrangements for support personnel called in to assist in the emergency, including communications hardware, transportation, food, and lodging._______________
Appendix 7 A.3: The corporate emergency The commitment wording was response organization will provide offsite standardized and relocated to emergency response support and resources to the SNC Standard Emergency SNC sites on a twenty-four seven basis until the Plan.emergency has been terminated.
The SNC Standard Emergency Plan integrates the Corporate response as part of the trained and qualified ERO. A separate statement is not necessary.
Appendix 7 A.3: The EOF will be activated for an EP H.2.1 Emergency Operations Facility The commitment wording was ALERT, SITE AREA or GENERAL emergency Staffing and activation of the EOF is mandatory upon standardized and relocated to classifications.
declaration of an Alert or higher classification.
the SNC Standard Emergency Plan.Appendix 7 A.3: This facility (EOF) will be EP H.4: Although the response time will vary due to The commitment wording was operational within about an hour of the initial factors such as weather and traffic conditions, a goal of 75 standardized and relocated to notification.
minutes for minimum staffing, following the declaration of the SNC Standard Emergency an Alert or higher emergency classification, has been Plan.The change in activation established for ERO personnel responding to plant times will be justified separately emergency facilities including the TSC, and EOF in the Technical Analysis Section aP, d-JI. of this License Amendment_________________________________
__________________________________RequeReqest E15-198 Enclosure 15 to NL-16-0169 Vogtle (Units 3 & 4) Justification Matrix Current Vogtle 3&4 Emergency Plan Revised SNC Emergency Plan Justification Revision 3 Appendix 8: All The appendix describing the Emergency Communications Plan has been standardized and incorporated into the ERO Staffing as described in Section B, Facilities as described in Section H, the Emergency Communications portion of Section G of the SNC Standard Emergency Plan and Section 5.1.6 of the Vogtle 3-4 wo..rdi~ng. and rolocatod to the SNC Standard Appendix 9: All The SNC Standard Emergency Plan/Annex provides the agencies and descriptions as required by Appendix E in their respective sections eliminating the need for a standalone appendix.E15-2 12 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 16 Evaluation of Proposed Changes LAR for the Revision to Vogtle 3 and 4 Emergency Planning ITAAC (No Changes)
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 17 Vogtle (Units 3 and 4)Revision to Unit 3 COL Appendix C -Proposed Changes -Markups (No Changes)
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 18 Vogtle (Units 3 and 4)Revision to Unit 4 COL Appendix C -Proposed Changes -Markups.(No changes)
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 19 Off-site Response Organizations Letters of Consultation and Concurrence
- New Letters Replacing Originals**
"STATE OF ALABAMA DEPARTMENT OF PUBLIC HEALTH Thomas M. Miller, M.D.Acting State Health Officer February 8, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201
Dear Mr. Meier,
This letter is in response to the request from Southern Nuclear (SNO) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and .4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Alabama Department of Public Health I Office of Radiation Control (ADPH) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Alabama Radiological Emergency Preparedness Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how ADPH would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Alabama REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Alabama REP does not address augmentation response times for site personnel.
SNC also informed ADPH staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Alabama REP with a level of detail of the overall content of the plan consistent with a planning level document.
The ADPH staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.'The RSA Tower .201 Monroe Street.* Montgomery, AL 36104 PO. Box 303017.* Montgomery, AL 36130-3017 SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.ADPH concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of ADPH concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely, T~onya ApeadDrco Emergency Planning Branch Office of Radiation Control Alabama Department of Public Health STATE OF ALAIBAMA ~B~EMERGENCY MANAGEMENT AGENCY 5898 COUJNTY ROAD 41
- P.O. DRAWER 2160
- CLANTON. ALABAMA 35O46-2160 4 (205)280-2200 FAX # (205) 280-2495 ~4 C ROBERT BENTLEY ART FAULKN GOVEzRNOR DIRhCI OR.Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Alabama Emergency Management Agency (AEMA) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Alabama Radiological Emergency Preparedness Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how AEMA would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Alabama REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to "75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Alabama REP does not address augmentation response times for site personnel.
SNC also informed AEMA staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Alabama REP with a level of detail of the overall content of the plan consistent with a planning level document.
The AEMA staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.qER SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNO also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.AEMA concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of AEMA concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Director of Response Operations 205-280-2262 Tim.Payne@ema.alabama.gov AIKEN COUNTY M GEC Department of Emergency Services 'Emergency Management Division I I RG A C Suite 1100 .Aiken, South Carolina, 29801 V ~ ' IKEN COUNTY Telephone:
(80I3) 642-1623 FAX: (803) 642-2556 February 1I, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201
Dear Mr. Meier:
This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Aiken County, South Carolina Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs).The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Aiken County, South Carolina Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Annex Q2, Part 2, Fixed Nuclear Faclity (FNF) Radiological Emergency Response Plan (RERP)to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Annex Q2, Part 2, Fixed Nuclear Faclity (FNF) Radiological Emergency Response Plan (RERP) to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant does not address augmentation response times for site personnel.
SNC also informed Aiken County, South Carolina Emergency Management starr that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Annex Q2, Part 2, Fixed Nuclear Faclity (FNF) Radiological Emergency Response Plan (RERP) to the Aiken County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant with a level of detail of the overall content of the plan consistent with a planning level document.
The Aiken County, South Carolina Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of' the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received rrom the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Aiken County, South Carolina Emergency Management concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.Please consider this letter as a written indication of Aiken County, South Carolina Emergency Management concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sji 5 rely, Paul Matthews Emergency Manager Aiken County Emergency Management Division Gidget L. Stanley-Banks, Director William Robinson Jr., Asst. Director 911-B Main Street North Allendale, South Carolina 29810 803-584-4081
-Phone 803-584-3807
-Fax February 11, 2016 Mr. Mikce Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295*42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Allendale County, Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Allendale County, Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through February 11, 2016 continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant does not address augmentation response times for site personnel.
SNC also informed Allendale County, Emergency Management staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Allendale County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant with a level of detail of the overall content of the plan consistent with a planning level document.
The Allendale County, Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Allendale County, Emergency Management concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Allendale County, South Carolina.Please consider this letter as a written indication of Allendale County, Emergency Management concurrence with the Southem Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely Yours, Gidget L. Stanley-Banks 0 Page 2 Post Office Box 747 DANE BRUCE BAXLEY, GEORGIA 31515 DARRELL HOLCOMB Director Telephone (912) 367-8170 Deputy Director Febrary15, 016acema@bellsouth.net Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with App~ling County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (ORes) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Georgia Radiological Emergency Plan Annex A -Plant Hatch. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Appling County Emergency Management Agency would respond to a radiological emergency any of the SNC sites nor does it necessitate a change to the current Georgia Radiological Emergency Plan Annex A -Plant Hatch nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Georgia Radiological Emergency Plan Annex A -Plant Hatch does not address augmentation response times for site personnel.
SNC also informed Appling County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Georgia Radiological Emergency Plan Annex A -Plant Hatch with a level of detail of the overall content of the plan consistent with a planning level document.
The Appling County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNO fleet standard emergency plan due to changes in the title of the document.
D Post Office Box 747)ANE BRUCE BAXLEY, GEORGIA 31515 DARRELL HOLCC Director Telephone (912) 367-8170 Deputyi acema@bellsouth.net SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Appling County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Appling County, Georgia.Please consider this letter as a written indication of Appling County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.)MB}Dane Bruce, Director Appling County Emergency Management Agency February 5, 2016 Mr. Mike Meler Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Barnwefl County, South Carolina Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Barnwell County, South Carolina Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNO's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Annex Q2, Part 2, Fixed Nuclear Facility (FNF) Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant does not address augmentation response times for site personnel.
SNC also informed Barnwell County, South Carolina Emergency Management staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Annex Q2, Part 2, Fixed Nuclear Facility (FNF)Radiological Emergency Response Plan (RERP) to the Barnwell County Emergency Operations Plan (EOP) Vogtle Electric Generating Plant with a level of detail of the overall content of the plan consistent with a planning level document.
The Barnwell County, South Carolina Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNO emergency plan documents such that they will submit~the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Barnwell County, South Carolina Emergency Management concurs with SNO's assessment of the benefits of the proposed changes to their emergency plans.We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.
Please consider this letter as a written indication of Barnwell County, South Carolina Emergency Management concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4.Sincerely, .,./Roger Riley, Director Bamnwel[ County Emergency Management 57 Wall Street Barnwell, SC 29812 Office 1 -803-259-7013 Fax -803-259-1759 Cell -803-541-2013 Blakely-Early County Emergency Management Anthony Gentry, Director P.O. Box 7-"6 -i86io East South Blvd.Blakcly, Ga. 39823 Phone: 229-7-23-3029
/ Fax: 229-723-5908 E-MaiI-becema@windst ream.net Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Blakely -Early County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Georgia Radiological Emergency Plan Annex B-Plant Farley. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Blakely -Early County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Georgia Radiological Emergency Plan Annex B -Plant Farley nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Georgia Radiological Emergency Plan Annex B-Plant Farley does not address augmentation response times for site personnel.
SNC also informed Blakely -Early County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Georgia Radiological Emergency Plan Annex B -Plant Farley with a level of detail of the overall content of the plan consistent with a planning level document.
The Blakely -Early County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Blakely -Early County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Blakely -Early County, Georgia.Please consider this letter as a written indication of Blakely -Early County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Anthony Gentry, Director Early County EMA Burke County Emergency MAanagement Agency Fire 277 Highway 24 South EMS Waynesboro, Georgia 30830 Tel. (706) 554-6651 Fax (706) 554-4660 E-Mail: rsanders(~burkecountv-ga.geov Dedicated To The Protection Of Life And Property Rusty Sanders -Chief Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Burke County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Plant Vogtle Burke County Emergency Management Radiological Plan.Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Burke County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Plant Vogtle Burke County Emergency Management Radiological Plan nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Plant Vogtle Burke County Emergency Management Radiological Plan does not address augmentation response times for site personnel.
SNC also informed Burke County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Plant Vogtle Burke County Emergency Management Radiological Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Burke County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Burke County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Burke County, Georgia.Please consider this letter as a written indication of Burke County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Respectfully Yours, R~4~y S~vtders'Rusty Sanders -Burke County EMA Director Georgaia Department of Natural Resources Environmental Protection Division, Air Protection Branch 4244 international Parkway, Suite 120, Atlanta, Georgia 30354 404-363-7000 Judson H. Turner, Director February 8, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Georgia Department of Natural Resources, Environmental Protection Division, Environmental Radiation Program (GADNR) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan.We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs).The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the GEMA/HS Radiological Emergency Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how GADNR would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current GEMAIHS REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The GEMA/HS REP does not address augmentation response times for site personnel.
SNC also informed GADNR staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the GEMA/HS REP with a level of detail of the overall content of the plan consistent with a planning level document.
The GADNR staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.GADNR concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans.We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of GADNR concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely, Sidney B. Simonton Team Leader, Environmental Radiation Program GEORGIA EMERGENCY MANAGEMENT AGENCY GEORGIA OFFICE OF HOMELAND SECURITY NATHAN DEAL JIM BUTTERWORTH GOVER D IRECTO R February 9, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201
Dear Mr. Meier:
This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Georgia Emergency Management Agency/Homeland Security (GEMAIHS) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (ORG s) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the GEMA/US Radiological Emergency Plan (REP). Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERG). These changes do not alter how GEMA/HS would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current GEMAIHS REP nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERG at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The GEMA/US REP does not address augmentation response times for site personnel.
SNC also informed GEMAIHS staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the , "S. "' Li .Post Office Box 1 8055
- Atlanta, GA 30316-0055 (404) 635-7000
- Toll Free in Georgia 1-800-TFY-GEMA -www.gema.ga.gov Mr. Mike Meier Page Two February 9, 2016 GEMAIIHS REP with a level of detail of the overall content of the plan consistent with a planning level document.
The GEMA/HS staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also infonmed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.GEMA/HS concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of GEMA/HS concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely, Stephen Clark Program Director Radiological Emergency Preparedness
/sc Henry County Emergency Management Agency 101 North Doswell St. Abbeville, Al 36310 (334)-585-6702 (334)-585-1616 (fax)Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Henry County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emer~gency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Alabama Radiological Emergency Preparedness Plan. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERa). These changes do not alter how Henry County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Alabama Radiological Emergency Preparedness Plan nor does it alter the existing points of interface with the utility.We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common OEO from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Alabama Radiological Emergency Preparedness Plan does not address augmentation response times for site personnel.
SNC also informed Henry County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Alabama Radiological Emergency Preparedness Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Henry County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Henry County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of Henry County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Ronnie Dollar Director Dothan/Houston County Emergency Management Steve Carlisle Director Leigh Adams Deputy Director Charles Finney Plannin Kris Ware Support/PIO P.O. Drawer 6406 Dotban, Alabama 36302 (Phone) 334.794.9720 (Fax) 334.793.3550 February 8, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Dothan/Houston County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Alabama as described in the Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents.
Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Houston County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents nor does it alter the existing points of interface with the utility.
Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.Page 2 We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents, does not address augmentation response times for site personnel.
SNC also informed Dothan/Houston County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Dothan/Houston County Emergency Management Agency Standard Operating Guidelines for Joseph M. Farley Nuclear Power Plant Incidents with a level of detail of the overall content of the plan consistent with a planning level document.
Dothan/Houston County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Dothan/Houston County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.Please consider this letter as a written indication of Dothan/Houston County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Regards, stteve Director Dothan/Houston County Emergency Management Agency CHARLES DIRECTC j JEFF DAVIS COUNTY EMERGENCY MANAGEMENT AGENCY 2 10 PUBLIC SAFETY DRIVE HAZLEHURST, GEORGIA 31539 rASDiN KATHY W. LORDCLERK PHONE (912) 375-6628 Mr. Mike Meier, Vice-President Regulatory Affairs Southern Nuclear Operating Company, Inc.P. 0. Box 1295 42 Inverness Center Parkway Birmingham, Alabama 35201
Dear Mr. Meier:
This letter is in response to the request from Southern Nuclear (S NC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Jeff Davis County Emergency Management and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of South Carolina as described in the Jeff Davis County Emergency Management Agency Emergency Operations Plan. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Jeff Davis County Emergency Management would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Jeff Davis County Emergency Management Agency Emergency Operations Plan nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Jeff Davis County Emergency Management Agency Emergency Operations Plan does not address augmentation response times for site personnel.
SNC also informed Jeff Davis County Emergency Management staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Jeff Davis County Emergency Management Agency Emergency Operations Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Jeff Davis County Emergency Management staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNO's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Jeff Davis County Emergency Management concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.Please consider this letter as a written indication of Jeff Davis County Emergency Management concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Sincerely yours, Charles Wasdin, Director Jeff Davis County EMA PROM IOTE PROTE! p P! OS, P R Cadrierine E. Hei~el, Director February 16, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 RE: Southern Nuclear consolidation of emergency pians Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with South Carolina Department of Health and Environmental Control (SCDHEC) and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title oi" Emergency Director vested with the cormnand and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and SCDHEC. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how SCDHEC would respond to a radiological emergency at any of the SNC sites nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs)to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. SNC also informed SCDHEC staff that the format of the SNC emergency plan would include a base document and site specific annexes with a level of detail of the overall content of the plan consistent with a planning level document.
No changes will need to be made in DHEC's plans/SOPs (SC Technical Radiological Emergency Response Plan/SC Technical Radiological Operating Procedures) to support the implementation of the proposed SNC fleet standard emergency plan.2(3(X) Bull Suic *ee ( olimnhiaSC292t0!
Phione:(8(33) 898-3 132
- www.scdhlc-.gov SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance;however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.SCDHEC concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.Please consider this letter as a written indication of SCDHEC concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4. If you have any additional questions, you may contact me at 803.896.4111 or Respectf ,ly Chris Staton, Director Division of Emergency Response Bureau of Environmental Health Services 2600 Bill SIrcee * (k:OIilumia.,SC 29201
- 1'hoic: (803) 898-3132
- www.scdhicc.gov 2!1Page
~'aeof 'outhi Carotiia OFFICE OF THE ADJUTANT GENERAL THE ADJUTANT' GENERAL February 16, 2016 MrT. Mike Mejer Vice President' Regulatory Affairs SouflhernNuclear Operating
'Company, Inc.P.O. Box 1295Inverness C(enter Parkway Birmingham, AL 3520_1
Dear Mr~. Thifs letter i's -in response to the request:
from' Southern Nuclear I(SNC) for written concurrence on the proposal 'to consolidate the Plant Farley, .Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3- and 4 em'etgency plans into a singie common emergen~cy plan wi~th s iteg'specific.
annexes to address emnergcncy plan elements unique to the specific-sites.
A member the Soulthern Nuclear Emergency Preparedniess staff met with South Carolina Emergency Managemenit Divi'sion (SCEMP) and discus sed this proposal in detail-and allowed us to provide feedback on the proposed fleet standard emergency plan. 'We discussed
'the changes ;to the EOE staffing, most notably the addition of a senior decision maker wvith the title of Emnergency Dir-ector vested with' the command and control authority for -approving notifications to off-site response organizations (OROs) and f'or approval of Protecetive Action Recommendati~ons (PARs). The addition of this new leadership position' will 'not alter the interface bet~ween thle utility and 'the 'state oQ" South carolina aS described in 'the South Carolina Operational Radiological Emergency ReSponse Plan (SCORERP), Additionally, we discussed SN.C's proposed 'changes 'to' their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC si'tes with a common emergency respon~se organizatioh (ERO).These chianges .not alter how SCEMD would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current SCORERP nor does it alter the existi'ng points of interface with the utility. We further understand that part; of the staffing changes includes transitionin3g from three radiological -field monitoring teams (FMTs)'to two FMTs. Through continued coordination the State and utility radiological assessment organizations,, adequate monitoring will be maintained.
We also discussed SNC's proposal Emergency Management Division 2779'Fish Hatchery Road West Columbia, South Carolina 291-72'(803) 737-8500 Fax (803) 737-8570.
to change ,he definition for augmentatiotn time for their ERO -at Plant Hatch, Plant Vo'gtie and, the common EOF' from 60 minutes from notification of an Alert- or high~er emergency with 1 5 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency, We recognize this. augmentation time is effectively the same time period. The SCORERP does not address augmentation response times for site p ersontiel.
SNC also. informed SCEMD staff that the format of thae S'NC emergencY, plan would include :a base document and 'sit:e specific .annexes similar to that of the SCORERP with a level of detail of thne overall content of the plan consistent with a planning level document.
The SCEMD .staff does recognize that minor administrative changes will nee~d to be made to support the implementation of the proposed SNC :fleet standard emergency plan due to ch~anges ini thle title of the document.SNC disc:ussed with our staf'f how thle proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emnergenc~y response efforts to. better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes, are consistent With curr'ent regu~latory requirements and applicable guidance; however they do constitute .a sign~ificant charige in the, SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. (NRC). SN.C also informed our staff that implemerntation of the new S'NC fleet, standard emergency plan.wou~ld not occur Until final approval was received Were properly traine~d and prepared to transitionj to the new emergency plan.SCEMD ,concUrs with SNC's assesstnert of the, benefits, o~f the proposed changes to their emergency plans. We also agree that .it is appropriate and .prudent to request a full review and approval of the proposed changes to 'the. SNC emer~gency iplans by the NRC to ensure the SNC enmergenicy plan continues to reasonable assurance of their ability to pr~otect the safety and health of the cit-izens of South Carolina.Please consider thils as a written indication of SCEMD concurrence with the Southern NUclear proposal to a common emnergency plan for Plant Farley, Plant Hatch', 'Plant Vogtle Units I and 2 and Planto Vogtle Units 3 and 4.Sincerely, Kim Stenson Director KS/jlt From: Cla rissa .waller~srs.pov To: Grant, Judly D.Cc: debra~foutch~srs~gov
Subject:
-
SRS Agreement with SNC Emergency Plan Date: Friday, February 12, 2016 10:04:02 AM Ms. Grant, Per the teleconference on Tuesday, and as promised, SRS has looked at the update to the SNC Emergency Plan and reviewed the changes. We have no further comments, and the letter submitted in Dec 2015 is still applicable.
Please let me know if you have any further questions.
Thanks, Crissy Wailer Savannah River Site Office of Safeguards, Security and Emergency Services Emergency Management Specialist Building 730-2B, #2040 803-952-8531 Office 803-507-5439 Cell Tattnall County Fire & Rescue Walt D. Rogers, Chief POB 905 194 John 0. Parker Drive Office: (912) 557-6820 Reidsville, GA. 30453 Fax: (912) 557-6937 tattnallema(dwindstream.net February 5, 2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Tattnall County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Tattnall County Emergency Management Agency Emergency Operations Plan. Additionally, we discussed SNC's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Tattnall County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Tattnall County Emergency Management Agency Emergency Operations Plan nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs.Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC's proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EQF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Tattnall County Emergency Management Agency Emergency Operations Plan does not address augmentation response times for site personnel.
SNC also informed Tattnall County Emergency Management Page 1 of 2 Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the Tattnall County Emergency Management Agency Emergency Operations Plan with a level of detail of the overall content of the plan consistent with a planning level document.
The Tattnall County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNC fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Tattnall County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNC emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of Tattnall County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4.Sincerely, Walt Rogers, Director Tattnall County Emergency Management Page 2 of 2 Toombs County Emergency Management Agency P.O Box 487 Lyons, Ga. 30436 Date : 02/11/2016 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear (SNC) for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.A member of the Southern Nuclear Emergency Preparedness staff met with Toombs County Emergency Management Agency and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. We discussed the changes to the EOF staffing, most notably the addition of a senior decision maker with the title of'Emergency Director vested with the command and control authority for approving notifications to off-site response organizations (OROs) and for approval of Protective Action Recommendations (PARs). The addition of this new leadership position will not alter the interface between the utility and the state of Georgia as described in the Georgia Radiological Emergency Plan, Annex A -Plant Hatch, Additionally, we discussed SNO's proposed changes to their on-shift staffing and augmented response staffing positions, titles, and duties to align the SNC sites with a common emergency response organization (ERO). These changes do not alter how Toombs County Emergency Management Agency would respond to a radiological emergency at any of the SNC sites nor does it necessitate a change to the current Georgia Radiological Emergency Plan, Annex A -Plant Hatch nor does it alter the existing points of interface with the utility. We further understand that part of the staffing changes includes transitioning from three radiological field monitoring teams (FMTs) to two FMTs. Through continued coordination between the State and utility radiological assessment organizations adequate in field monitoring will be maintained.
We also discussed SNC'S proposal to change the definition for augmentation time for their ERO at Plant Hatch, Plant Vogtle and the common EOF from 60 minutes from notification of an Alert or higher emergency with 15 minutes to-- ----- .- -S.
complete notification, to 75 minutes from declaration of an Alert or higher emergency.
We recognize this augmentation time is effectively the same time period. The Georgia Radiological Emergency Plan, Annex A -Plant Hatch does not address augmentation response times for site personnel.
SNC also informed Toombs County Emergency Management Agency staff that the format of the SNC emergency plan would include a base document and site specific annexes similar to that of the GEMAIHS REP with a level of detail of the overall content of the plan consistent with a planning level document.
The Toombs County Emergency Management Agency staff does recognize that minor administrative changes will need to be made to support the implementation of the proposed SNO fleet standard emergency plan due to changes in the title of the document.SNC discussed with our staff how the proposed consolidation of the SNC emergency plans and the changes contained therein will serve to standardize SNC's emergency response efforts to better leverage resources to respond in the unlikely event of a radiological emergency.
SNC also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance; however they do constitute a significant change in the SNC emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission (NRC). SNC also informed our staff that implementation of the new SNC fleet standard emergency plan would not occur until final approval was received from the NRC and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.Toombs County Emergency Management Agency concurs with SNC's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the SNO emergency plans by the NRC to ensure the SNC emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.Please consider this letter as a written indication of Toombs County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.Toombs County EMA Director Lynn Moore