NL-17-1088, Submittal of License Amendment Request, Relocation of the Emergency Operations Facility

Submittal of License Amendment Request, Relocation of the Emergency Operations Facility

ML17243A202
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	08/30/2017
From:	Hutto J Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors, Office of Nuclear Reactor Regulation
References
NL-17-1088
Download: ML17243A202 (25)

Text

t. Southern Nuclear J . J . Hutto Regulatory Affairs Director 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5872 tel 205 992 7601 fax Jjhutto@southernco.com August30,2017 Docket Nos.: 50-321 50-348 50-424 52-025 NL-17-1088 50-366 50-364 50-425 52-026 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 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 Submittal of License Amendment Request Relocation of the Emergency Operations Facility Ladies and Gentlemen:

Pursuant to 10 CFR 50, Appendix E, IV.E.8.b. and 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests amendments to the licenses for the plants listed above to relocate the consolidated Emergency Operations Facility (EOF) from the SNC Corporate Headquarters at 40 Inverness Center Parkway, Birmingham, Alabama to the new location for the SNC Headquarters at North Tower 3525 Colonnade Parkway, Birmingham, Alabama. The new proposed EOF location is a 1.3-mile straight-line distance from the current location.

Relocating the near-site EOF facilities for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), Joseph M. Farley Nuclear Plant, Units 1 and 2 (Farley) and Vogtle Electric Generating Plant, Units 1 and 2 (Vogtle) into a consolidated EOF at the SNC Corporate Headquarters in Birmingham, Alabama was approved by an NRC Exemption dated April 6, 2005 (ML050530134). The NRC Safety Evaluation Report (SER) (NUREG-1923; ML092290639) for the Early Site Permit and the NRC Safety Evaluation (SE) for the SNC Standard Emergency Plan (ML16141A090) also establishes the SNC Corporate Headquarters in Birmingham, Alabama as the EOF location for Vogtle, Units 3 and 4.

The relocated SNC Corporate Headquarters and EOF will be comparable with the existing EOF, but will also include improvements to the facility and some equipment upgrades. Consequently, the proposed changes to the consolidated EOF do not reduce the effectiveness of the SNC Standard Emergency Plan or Annexes and do not require approval under 10 CFR 50.54(q).

However, because the proposed change in location would result in EOF functions performed greater than 25 miles from the three sites, this license amendment request is required by 10 CFR 50, Appendix E, IV.E.8.b. provides a technical and regulatory evaluation of the changes. Enclosure 2 provides a diagram of the new EOF. The affected State agencies have provided their concurrence of the proposed EOF relocation, as documented in Enclosure 3.

U. S. Nuclear Regulatory Commission NL-17-1088 Page 2 Approval of the proposed amendments is requested within 9 months. SNC will implement the amendments by the end of 2018, which coincides with the end of lease for the current SNC Corporate Headquarters building at 40 Inverness Center Parkway. The requested approval time and implementation period were chosen to support personnel training, procedure revisions, and pre-implementation drills.

SNC has planned a two-site-simultaneous demonstration drill for June 2018. SNC will provide notice and the opportunity for offsite response organizations to participate and for NRC and Federal Emergency Management Agency (FEMA) to observe the drill at the new facility.

This letter contains no NRC commitments. In accordance with 10 CFR 50.91, SNC is notifying the states of Alabama and Georgia of this license amendment request by transmitting a copy of this letter to the designated state officials. If you have any questions, please contact Ken McElroy at 205.992.7369.

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

Executed on August .3.Q_, 2017.

~-

J. J. Hutto Regulatory Affairs Director Southern Nuclear Operating Company JJ H/efb/lac

Enclosures:

1. Evaluation of the Proposed Change

2. Layout Diagram - New EOF (SEP Figure H.2.A)

3. State Letters of Agreement cc: NRC Regional Administrator, Region II NRC NRR Project Manager- Vogtle 1&2 NRC NRO Project Manager- Vogtle 3&4 NRC NRR Project Manager- Farley NRC NRR Project Manager- Hatch NRC Senior Resident Inspector- Farley NRC Senior Resident Inspector- Hatch NRC Senior Resident Inspector- Vogtle 1 & 2 NRC Senior Project Inspector- Vogtle 3&4 SNC Document Control R-Types: CFA04.054; CHA02.004; CVC7000; VND.LI.LOO Alabama - State Board of Health - Director of Radiation Control Georgia - State Department of Natural Resources- Director of Environmental Protection

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 Submittal of License Amendment Request to Relocation of the Emergency Operations Facility Enclosure 1 Evaluation of the Proposed Change to NL-17-1088 Evaluation of Proposed Change EVALUATION OF THE PROPOSED CHANGE 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

6.0 REFERENCES

Page E1-1 of 15 to NL-17-1088 Evaluation of Proposed Change 1.0

SUMMARY

DESCRIPTION This evaluation supports the request to relocate the current SNC Emergency Operations Facility (EOF) . The new, proposed, relocated, Corporate EOF (hereinafter referred to as the "new EOF") is located 1.3 miles away and will coincide with a move of the entire SNC Corporate Headquarters. The new EOF will be equipped with the capabilities to provide the required emergency response functions supporting the Edwin I. Hatch (Hatch), Joseph M. Farley (Farley), Vogtle Electric Generating Plant, Units 1 and 2 and planned Units 3 and 4 (Vogtle).

The relocation does not result in reduction to the capabilities or functions as they exist in the current EOF. The new EOF provides an improved space for conference rooms and work stations along with equipment upgrades to data and communication systems.

2.0 DETAILED DESCRIPTION Pursuant to 10 CFR 50, Appendix E, IV.E.8.b. and 10 CFR 50.90, SNC requests amendments to the licenses for Farley, Hatch, and Vogtle Units 1-4 to relocate the consolidated EOF from the SNC Corporate Headquarters at 40 Inverness Center Parkway, Birmingham, Alabama to the new location for the SNC Headquarters at North Tower 3525 Colonnade Parkway, Birmingham, Alabama. The new EOF location is a 1.3-mile straight-line distance from the current location.

Relocating the near-site EOF facilities for Farley, Hatch, and Vogtle into a consolidated EOF at the SNC Corporate Headquarters in Birmingham, Alabama was approved by an NRC Exemption dated April 6, 2005 (ML050530134). The NRC SER (NUREG-1923) for the Early Site Permit and the NRC SE for the SNC Standard Emergency Plan (ML16141A090) also established the SNC Corporate Headquarters in Birmingham, Alabama as the EOF location for Vogtle, Units 3 and 4.

The relocated SNC Corporate Headquarters and EOF will be an updated facility with upgraded equipment. Consequently, the proposed changes to the consolidated EOF do not reduce the effectiveness of the SNC Standard Emergency Plan or Annexes and do not require approval under 10 CFR 50.54(q) . However, because the proposed change in location would result in EOF functions performed greater than 25 miles from the three sites, this license amendment request is required by 10 CFR 50, Appendix E, IV.E.8.b. See Table 2-1 for a comparison of distances.

Table 2-1 EOF Distances Straight-line Distance to EOF Site Existing Proposed Farley Nuclear Plant 178.5 miles 179.7 miles Hatch Nuclear Plant 274.0 miles 275.3 miles Vogtle Electric Generating Plant 286.0 miles 287.1 miles NRC Region II Office (Atlanta) 135.5 miles 136.7 miles Page E1-2 of 15 to NL-17-1088 Evaluation of Proposed Change The change in distance is insignificant, and the new EOF location is off the same major thoroughfare providing access to the current facility. The roadway capacity and relative location results in little change for the Emergency Response Organization (ERO) staff, and SNC does not request a change to the staff augmentation response time. Because SNC is moving the entire Corporate Headquarters to the new location, the availability of corporate senior management and key personnel with technical expertise remains the same.

The SNC Standard Emergency Plan and specific plant annexes do not require revision because the EOF location is referred to only as the Corporate Headquarters in Birmingham ,

Alabama. However, SNC is replacing the "typical" EOF layout diagram in Figure H.2.A of the Standard Emergency Plan to reflect the new EOF layout. The EOF description in Section H.2 remains a complete and accurate description of the EOF and will not be revised.

The current consolidated EOF since its approval in 2005 has successfully served as the consolidated EOF for the Hatch, Farley, and Vogtle plants. SNC has conducted numerous drills demonstrating effective management of emergency response from a common EOF at the SNC Corporate Headquarters in Birmingham, AL. SNC's 12 years of experience with operating a consolidated EOF from its headquarters in Birmingham, AL will aid in the operation of the new EOF.

The proposed EOF provides equivalent or improved capabilities over the existing facility.

The new EOF provides an improved space for the ERO staff and has dedicated rooms for each responding State: Alabama, Georgia, South Carolina and Florida.

SNC has planned a two-site-simultaneous demonstration drill for June 2018. SNC will provide the opportunity for offsite response organizations to participate and for NRC and FEMA to observe the drill at the new facility.

3.0 TECHNICAL EVALUATION

NUREG-0696, Functional Criteria for Emergency Response Facilities (as updated by NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants), provides an acceptable method of complying with 10 CFR 50, Appendix E, Section IV.E.8. Sections 3.1 through 3.9 of this technical evaluation will follow the NUREG-0696 format for demonstrating acceptability of the new EOF.

3.1 Functions The new EOF will have facilities and capabilities for:

3.1.1 Management of overall licensee emergency response The new EOF will continue to be the central location for management of offsite emergency response, coordination of radiological assessment, and management of initial recovery operations, including notification of events and protective action recommendations as assigned in the SNC Standard Emergency Plan. The Technical Support Center (TSC) will continue the responsibility for event classification.

The current consolidated EOF at the Corporate Headquarters in Birmingham, AL has functioned effectively since 2005 in drills, exercises and in actual emergency events. The consolidated EOF has been fully integrated into the overall Emergency Plan for the three SNC operating plants over the past 12 years. During that time, overall SNC emergency Page E1-3 of 15 to NL-17-1088 Evaluation of Proposed Change response has matured with well-developed positions and responsibilities, procedures, training, and performance demonstrations. The new EOF operations will benefit from this history in almost all respects, and the new facility will be furnished with updated equipment that monitors plant and environmental conditions to provide information required for dose assessment and development of protective action recommendations. The new EOF will continue to house offsite response organizations, including federal agencies, to coordinate information and deploy emergency resources from state and federal agencies.

3.1.2 Coordination of radiological and environmental assessment The ERO staff in the new EOF will continue to coordinate field team activities to monitor radiological activity and perform dose assessments. Personnel, staffing, equipment, and functions remain the same. Communication and dose assessment capabilities are discussed in Sections 3.6 and 3.8, respectively.

3.1.3 Determination of recommended public protective actions The ERO staff in the new EOF will continue to develop and provide Protective Action Recommendations (PAR) to offsite agencies based upon plant conditions or dose projections. Procedures with plant-specific guidance will continue to be used in making PARs and notification of offsite agencies.

3.1.4 Notification of offsite agencies The ERO staff in the new EOF will continue to make notifications to State and local agencies during emergencies, drills, and exercises for the SNC plants. These messages include initial notifications, changes in emergency classification or PARs, and periodic updates. The new EOF has enough workstations and personnel designated to communicate with offsite agencies to support communications for more than one site simultaneously.

Primary and back-up communications methods will be available including further redundant telephone capabilities through the Southern Company communications systems.

Communications methods are further described in Section 3.6.

3.1.5 Coordination of event. plant. and response information provided to public information staff for dissemination to the media and public The ERO staff in the new EOF will continue to provide event, plant, and response information to public information staff for dissemination to the media and public through the appropriate plant Joint Information Center (JIC). JIC operations are unaffected by the relocation of the EOF.

3.1.6 Staffing and activation of the facility within time frames and at emergency classification levels defined in the licensee emergency plan Staffing and activation of the new EOF remains unchanged. The staffing numbers, positions and titles are unchanged. The response time remains as currently stated in the SNC Standard Emergency Plan and the same as the other response facilities for each plant. The response time remains 75 minutes from the time of an Alert or higher declaration.

Page E1-4 of 15 to NL-17-1088 Evaluation of Proposed Change 3.1. 7 Coordination of emergency response activities with Federal. State. tribal. and local agencies Coordination of SNC with Federal, State, and local agencies will remain the same as currently exists. There are no tribal agencies coordinated in the affected plant areas.

Federal and State organizations have dedicated facilities at the new EOF facility. Near-site facilities and capabilities are unchanged.

The new EOF has improved, expanded facilities for State responders with separate rooms for each affected State.

Local agencies will coordinate through State agencies as is their current mode of operation .

Local agencies do not currently respond to the consolidated EOF and that is expected to remain the same after the move to the new EOF.

3.1.8 Locating NRC and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site. Minimum provisions at this location should include the following items:

conference area with whiteboards. separate areas suitable for briefing and debriefing response personnel. telephones. site ERO contact lists. computers with internet access.

access to a copier and office supplies. and radiation monitoring capability SNC's near-site response locations are described in the Standard Emergency Plan Annexes for each affected reactor site. No changes to the near-site response locations are planned or required due to the relocation of the EOF. At each near-site location, SNC will continue to provide a functional working space for NRC, State, and FEMA representatives. SNC will also continue to provide sufficient telecommunications and habitability provisions, including telephones, ERO contact lists, standard office lighting, HVAC, furniture, copiers, office supplies, computers with internet access, electrical power outlets, conference area with whiteboards, separate areas suitable for briefing and debriefing response personnel, and radiation monitoring capability.

3.1.9 Obtaining and displaying key plant data and radiological information for each unit or plant the EOF serves Data acquisition equipment in the new EOF will allow display of key plant data, parameters, and radiological information from each plant. This information will be displayed on screens in the new EOF in a manner comparable to the current EOF. Displays will be available to permit information from more than one site to be provided at the same time.

3.1 .10 Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant The new EOF will continue to have the capability to access key plant parameters from each of the SNC plants as described in Section 3.8. The ERO staff in the new EOF includes members who are technically qualified to analyze relevant information from the plant information systems. The new EOF is equipped with conference rooms for technical briefings of licensee staff and offsite agency responders. Telephone conferencing capability is available for briefing responders not located in the EOF.

Page E1-5 of 15 to NL-17-1088 Evaluation of Proposed Change 3.1.11 Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF SNC will continue to maintain the EOF capability to support simultaneous events at two sites. The new EOF will be equipped with facilities to monitor and analyze events at more than one site. Enough workstations are available for data retrieval, and the facility has adequate display capability to simultaneously present this information to the EOF staff. In addition, the new EOF has the capability to support communications to offsite agencies for more than one event. If the EOF must respond to an event at more than one site simultaneously, the normal EOF staff complement is augmented with additional personnel as needed.

The new EOF will have provisions to have dedicated lead responders assigned for each plant should there be multiple events affecting two or more plant sites. Diverse communication pathways are provided between the plant emergency response facilities and the EOF such that management can be expanded to provide communication with multiple State organizations. The four States potentially affected by multiple plant events are provided dedicated rooms and equipment to support simultaneous response activities.

Proximity of the conference rooms for the State offices in the new EOF also facilitates close coordination between the licensee, federal and state agencies.

Due to the improved space and upgraded equipment, SNC has the capability to expand the new EOF response beyond two unit or two site events. Additional lead responders can be supported within the proposed EOF should it be necessary to expand coordination in the facility beyond two units or sites. Industry emergency preparedness activities for hostile threat and beyond design basis natural hazards continue to promote additional and scalable readiness measures.

Emergencies that could affect multiple plants include situations such as a widespread threat (e.g., aircraft) or a non-specific hostile threat (specific plant not identified). These threats require timely and close coordination with offsite response organizations. The improved space for the presence of federal and state emergency response agencies at the new EOF accelerates communication among licensee and government organizations and creates a more efficient and effective environment to plan coordinated response and protective actions. The need for this type of coordination has become more evident since the events of 9/11 and the escalation of security measures in the nuclear industry.

Other emergencies that could result in the need for a response supporting multiple units are events from significant natural disasters such as that experienced at the Fukushima-Daiichi plants in Japan. SNC plants, though less likely to experience significant flooding, could experience an extended loss of AC power event due to hazardous weather conditions or other natural disaster conditions. Such an event would require increased coordination and communication between agencies. The upgraded equipment and improved space in the new EOF will aid in facilitating this coordination.

3.2 Location, Structure, and Habitability The new EOF is located at the SNC Headquarters at the street address of North Tower 3525 Colonnade Parkway, Birmingham, Alabama. (The mailing address is 3535 Colonnade Parkway.) The new EOF location is a 1.3-mile straight-line distance from its current location at 40 Inverness Center Parkway. The new EOF meets the intent of the guidance in NUREG-0696 that the building be "well-engineered for the design life of plant." The new EOF is built Page E1-6 of 15 to NL-17-1088 Evaluation of Proposed Change to withstand wind loads and live loads of the 2009 International Building Code as adopted by the State of Alabama. The new EOF is not located in a flood plain. As the new EOF is located greater than 10 miles from any of the nuclear power reactor sites, habitability criteria in NUREG-0696 are not applicable and a backup EOF is not required under paragraph IV.E.8.b. of Appendix E to Part 50.

The new EOF is in the same facility as the new SNC Corporate Headquarters, which allows for corporate support and management personnel to quickly staff the EOF with expertise from various disciplines. The new EOF will include upgrades to improve the effectiveness of the SNC emergency response capabilities. Some key features of the upgraded facility include improved working spaces, new computers, new flat-screen displays, glass-walled rooms, and work-stations and displays that support a multi-site event. If necessary, additional work areas in the seven-story building housing the Corporate Headquarters can be made available to the new EOF, including a video conference center.

Because the corporate EOF is further than 25 miles from the SNC nuclear stations, the EOF functions would not be interrupted during radiation releases for which it was necessary to recommend protective actions for the public to offsite officials.

Being only a 1.3-mile straight-line distance from the current EOF, the new EOF is served by the same major highway thoroughfare and is essentially the same distance from staff residences. Therefore, staff response times will continue to meet the emergency plan requirements.

Access control to the new EOF is provided by a security service. Electronic card readers are used and allow entry only to authorized personnel. Use of the new EOF during normal daily operations is limited to activities that will not degrade EOF activation, readiness, operations, or reliability.

The new EOF has primary commercial electric service by Alabama Power's underground distribution system in the Colonnade area and a diesel-generator back-up supply sized to carry the electrical load for the entire SNC Corporate Headquarters building. Therefore, electrical outlets, HVAC, lighting fixtures, and circuits that support both the voice and data communications in the new EOF have backup power available. In addition to the backup diesel-generator power, voice communication systems in the new EOF are provided with 2-hour back-up power by a stand-alone uninterruptible power supply (UPS) .

3.3 Staffing and Training The ERO staff positions in the new EOF remain the same as the current EOF, including their associated training and drill requirements. The ERO roles and responsibilities and response times have not changed and the functions of the EOF remain the same. No revisions to the staffing and training requirements in the SNC Standard Emergency Plan or Annexes are necessary for this relocation of the EOF.

Facility walk-through activities and familiarization drills will be conducted to provide existing staff an opportunity to occupy and implement the facility. SNC has planned a two-site-simultaneous demonstration drill for June 2018. SNC will provide the opportunity for offsite response organizations to participate and for NRC and FEMA to observe the drill at the new EOF.

Page E1-7 of 15 to NL-17-1088 Evaluation of Proposed Change 3.4 Size The total usable space and working space of the new EOF is sized to meet the guidance in NUREG 0696, section 4.4 to provide for the ERO staff as specified in the Standard Emergency Plan, including State and NRC responders at the maximum level of occupancy without crowding. Further, additional space is factored in to provide for sufficient personnel to respond to multi-unit events.

As with the existing EOF, space in the new EOF is allocated for functional activities of accident assessment, radiation assessment, offsite monitoring, offsite communications, command and control, conferences, NRC personnel, and storage. Space is sufficient for service of equipment, displays, and instrumentation within the new facility. Phones and special communications equipment are provided as needed throughout the new facility at personnel workstations. Individuals needing access to plant data are provided access via personal computers with Internet access. Functional displays of EOF data are made available through use of computer monitors and video display monitors.

The EOF facilities and equipment for the new EOF remain as described in the SNC Standard Emergency Plan Section H.2.1 and no revisions are necessary. However, SNC is replacing the "typical" EOF layout diagram in Figure H.2.A of the Standard Emergency Plan to reflect the new EOF layout. This diagram is included in Enclosure 2.

3.5 Radiological Monitoring The new EOF remains further than 10 miles from the SNC plants. Consequently, radiological monitoring capabilities for EOF personnel, as described in NUREG-0696, are not applicable.

3.6 Communications The EOF facilities and equipment related to communications for the new EOF remain as described in the SNC Standard Emergency Plan Section H.2.1 and no revisions are necessary. The SNC communication systems at the new EOF enable the plant control rooms, TSCs, simulator control rooms, and alternative emergency response facilities for the eight SNC nuclear units to communicate with the required Offsite Response Organizations and with each other.

The emergency communications systems and testing at the proposed EOF are designed to ensure the reliable, timely flow of information between all parties having an emergency response role. The new EOF has sufficient internal and external telecommunications capabilities to support EOF functions for simultaneous events involving multiple sites. The new EOF has reliable voice communication capability to TSCs, plant control rooms, the NRC, State and local emergency operations centers , NSSS suppliers, the Federal Emergency Management Agency, the US Department of Energy, and Joint Information Centers.

The communications systems and testing in the new EOF remain as described in Section F of the SNC Standard Emergency Plan, are equivalent to the existing EOF, and are comprised of the following:

Page E1-8 of 15 to NL-17-1088 Evaluation of Proposed Change The primary means of emergency notification between the new EOF, the site Control Rooms and the offsite response organizations is the Emergency Notification Network (ENN).

The backup means of emergency notification between the new EOF, the site Control Rooms and the offsite response organizations is the commercial telephone system.

Personnel in the new EOF may communicate with the sites using the SNC intra-plant phone system and portable radio systems.

A radio system for communication with field monitoring teams to coordinate radiological monitoring is provided in the new EOF.

The NRC Federal Telecommunication System (FTS) telephones (Emergency Notification System, Health Physics Network, Protective Measures Counterpart Link, Reactor Safety Counterpart Link, Management Counterpart Link, and Operations Center LAN) is provided in the new EOF.

Facsimile (fax) transmission capability between the EOF, TSC, and NRC Operations Center is provided in the new EOF.

Internet connections, long distance calling networks, satellite connectivity, Local Area Network (LAN) connections, and the number of telephones and facsimile machines in the new EOF are equal to or superior than the existing EOF location.

At the new EOF, commercial telephone service and fax will continue to serve as a backup means of communications in the event of a failure of a primary system. Telephones are provided for the respective federal and state representatives. Also, telephones for the NRC Emergency Telecommunications System (ETS), the Emergency Notification System (ENS),

and Health Physics Network (HPN), are available in the NRC work area. Multifunction machines with fax capability are available in the new EOF to support the transmission of information between the emergency response facilities and with state, local, and federal authorities.

Normal power service to the new EOF is provided by the Alabama Power underground primary distribution in the Colonnade area. Backup power for the new EOF is supplied by an onsite emergency diesel generator. Essential equipment is backed up by the diesel generator. In addition to the backup diesel-generator power, voice communication systems in the new EOF are provided with 2-hour back-up power by a stand-alone uninterruptible power supply (UPS).

In addition to the public long distance network, SNC maintains an intra-company telephone network that serves to connect the new EOF to each SNC nuclear plant.

EOF Communications for the new EOF relocation remain as described in the SNC Standard Emergency Plan Section F and no revisions to the Standard Emergency Plan or site-specific Annexes are necessary.

Page E1-9 of 15 to NL-17-1088 Evaluation of Proposed Change 3.71nstrumentation, Data System Equipment, and Power Supplies The facilities and equipment related to instrumentation, data system equipment, and power supplies for the new EOF remain as described in the SNC Standard Emergency Plan Section H.2.1 and no revisions are necessary.

Data communication networks are installed to provide secure access to plant data and parameters for display in the new EOF. These networks are installed in accordance with the requirements of NUREG-0696, Sections 4.7 and 4.8, and 10 CFR 73.54, the cybersecurity rule. Data acquisition is achieved through a secure proxy server. The server allows the new EOF to access displays that are representative of the displays in the Control Room via the SNC Wide and Local Area Networks fYVAN and LAN). The new EOF has access to the data points and parameters that are available to the operators in the control rooms and emergency responders in the TSC and OSC. The new EOF video display system presents the graphics on screens in the main EOF area.

Because the new EOF is located offsite, its electrical equipment loads cannot affect any safety related power source at the sites.

Loss of primary commercial power would not cause loss of any stored data vital to the new EOF functions. The LAN/WAN equipment and core computer network equipment in the new EOF have a backup AC power supply and historical data and information is retrievable.

The new EOF has primary commercial electric service by Alabama Power's underground distribution system in the Colonnade area and a diesel-generator back-up supply sized to carry the electrical load for the entire SNC Corporate Headquarters building . Therefore, instrumentation and data system equipment in the new EOF has backup power available.

3.8 Technical Data and Data System The new EOF data system is unchanged from the current EOF and continues to comply with data display and data storage requirements discussed in NUREG-0696 Section 4.8, including sensor data of the Reg. Guide 1.97 Type A, B, C, D, and E variables, and meteorological variables required by Reg . Guide 1.23 and NUREG-0654.

At the new EOF, SNC can receive, store, process, and display information needed to perform assessments of actual and potential offsite consequences of an emergency. The new EOF has access to the same data points that are available to operators in each respective site's control room and emergency responders in the TSC and OSC. The new EOF data set includes radiological, meteorological, and other environmental data needed to assess environmental conditions, coordinate radiological monitoring activities, and recommend implementation of offsite protective actions.

At the new EOF, offsite dose assessment continues to be performed for the operating SNC sites using dose assessment software programs. The dose assessment computer analysis program is used at the nuclear generating stations and other emergency response facilities in the event of an actual or potential release of airborne radioactivity to the environment. The program is further used to determine if release levels warrant declaration of an emergency specified in the emergency action levels.

Page E1-10 of 15 to NL-17-1088 Evaluation of Proposed Change 3.9 Records Availability and Management The new EOF is located near SNC Document Services. Key reference materials will be kept up to date and readily available for ease of access under emergency conditions in the new EOF. Examples include:

• Plant Technical Specifications

• Selected plant operating procedures

• Emergency operating procedures

• Final Safety Analysis Reports

• Emergency plans - Standard Plan, Annexes, and State emergency plans.

• Emergency Plan Implementing Procedures

• Evacuation plans

• Selected plant drawings, diagrams, and other design information

4.0 REGULATORY EVALUATION

4.1. Applicable Regulatory Requirements/Criteria This evaluation supports the request to relocate the current SNC Emergency Operations Facility (EOF). The new, proposed, relocated, Corporate EOF (hereinafter referred to as the "new EOF") is located 1.3 miles away and will coincide with a move of the entire SNC Corporate Headquarters. The new EOF will be equipped with the capabilities to provide the required emergency response functions supporting the Edwin I. Hatch (Hatch), Joseph M.

Farley (Farley), Vogtle Electric Generating Plant, Units 1 and 2 and planned Units 3 and 4 (Vogtle).

10 CFR 50, Appendix E, IV.E.8.b requires a licensee desiring to locate an EOF more than 25 miles from a nuclear reactor site to request prior Nuclear Regulatory Commission approval by applying for an amendment to its license. A backup facility is not required because the new EOF is located greater than 10 miles from any site.

Section IV.E.8.b of Appendix E and NSIR/DPR-ISG-01 require that, for an EOF located more than 25 miles from a nuclear reactor site, provisions be made for locating NRC and offsite responders closer to the reactor site to facilitate face-to-face interaction with emergency personnel entering and leaving the site. This regulation also describes the requirements for space and equipment:

• Space for members of an NRC site team and Federal, State, and local responders

• Additional space for conducting briefings with emergency response personnel

• Communication with other licensee and offsite emergency response facilities

• Access to plant data and radiological information

• Access to copying equipment and office suppliesSection IV.E.8.c of Appendix E establishes requirements for data acquisition and display, technical analysis of event conditions, and support response for multiple reactor sites.

Page E1-11 of 15 to NL-17-1088 Evaluation of Proposed Change 10 CFR 50.47(b)(1) requires that primary responsibilities of emergency response for the licensee, State, local, and supporting organizations have been assigned/established and each organization has staff to respond and to augment on a continuous basis.

10 CFR 50.47(b)(3) requires that arrangements to accommodate State and local staff at the licensee's Emergency Operations Facility (EOF) have been made.

10 CFR 50.47(b)(8) and NUREG-0696 criteria, as modified by NSIR/DPR-ISG-01, requires that adequate emergency facilities and equipment to support the emergency response are provided and maintained.

10 CFR 50.47(b)(9) requires that adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

Section 4 of NUREG-0696 provides guidance on the overall criteria for the EOF:

• Functions

• Location, structure, and habitability

• Staffing and training

• Size

• Radiological monitoring

• Communications

• Instrumentation, data system equipment, and power supplies

• Technical data and data system

• Records availability and management NUREG-0696 expands on the Function criteria by providing the following requirements (this is the expanded list included in NSIR/DPR-ISG-01):

• Management of overall licensee emergency response

• Coordination of radiological and environmental assessment

• Determination of recommended public protective actions

• Notification of offsite agencies

• Coordination of event, plant, and response information provided to public information staff for dissemination to the media and public

• Staffing and activation of the facility within time frames and at emergency classification levels defined in the licensee emergency plan

• Coordination of emergency response activities with Federal, State, tribal, and local agencies

• Locating NRC and offsite agency staff closer to a site if the EOF is greater than 25 miles from the site

• Obtaining and displaying key plant data and radiological information for each unit or plant the EOF serves

• Analyzing plant technical information and providing technical briefings on event conditions and prognosis to licensee staff and offsite agency responders for each type of unit or plant

• Effectively responding to and coordinating response efforts for events occurring simultaneously at more than one site for a consolidated EOF Page E1-12 of 15 to NL-17-1088 Evaluation of Proposed Change The relocation of the SNC Corporate Headquarters EOF does not result in reduction to the capabilities or functions as they exist in the current EOF. The new EOF provides an improved space for conference rooms and work stations along with equipment upgrades to data and communication systems.

The Technical Evaluation in Section 3 of the 10 CFR 50.90 license amendment request describes in greater detail how SNC's technical analysis satisfies the applicable regulatory requirements and criteria.

4.2 Precedent Applicable precedent is the initial NRC exemption provided to SNC for consolidation and location of the existing EOF (reference ML050530134, dated April 6, 2005).

The most recent applicable precedent is the Duke Power Charlotte, NC EOF application.

See SECY-17-0050 dated April14, 2017 (ML16363A431) and Duke Power application submittals: Original LAR: ML16120A076; RAI response: ML16277A521; and supplement:

ML17017A210.

4.3 No Significant Hazards Consideration Determination The proposed amendment would relocate the consolidated Southern Nuclear Operating Company (SNC) Emergency Operations Facility (EOF) from the SNC Corporate Headquarters at 40 Inverness Center Parkway, Birmingham, Alabama to the new location for the SNC Headquarters at North Tower 3525 Colonnade Parkway, Birmingham, Alabama .

The proposed EOF location is a 1.3-mile straight-line distance from the current location.

SNC has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

4.3.1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to relocate the consolidated EOF within Birmingham, Alabama, requires no change to the required staff response time for supplementing onsite personnel in response to a radiological emergency. The relocated EOF is along the same major roadway and response personnel will be able to access the facility, using for the most part, the same path they currently use to travel to the corporate office. The license amendment does not request a change to the response time and the facility will be functional within the same timeframe as for the existing EOF. The functions and capabilities of the relocated EOF will continue to meet the applicable regulatory requirements. The proposed change has no effect on normal plant operation or on any accident initiator or precursors and does not impact the function of plant structures, systems, or components. The proposed change does not alter or prevent the ability of the emergency response organization to perform its intended functions to mitigate the consequences of an accident or event.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page E1-13 of 15 to NL-17-1088 Evaluation of Proposed Change 4.3.2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change only concerns implementation of the standard emergency plan by relocating the Corporate EOF a short distance (1 .3 miles) from its current location. The new location will not change the time the facility will be functional to provide emergency response. The functions and capabilities of the relocated EOF will continue to meet the applicable regulatory requirements. The proposed change will not change the design function or operation of SSCs. The change does not impact the accident analysis for any of the SNC nuclear plants. The change does not involve a physical alteration of any of the plants, a change in the method of plant operation, or new operator actions. The proposed change does not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in safety analyses.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

4.3.3 Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change only impacts the implementation of the emergency plan by relocating the Corporate EOF a short distance (1.3 miles) within Birmingham, Alabama. The change does not the affect staff response time or the time it takes to make the facility operational to perform its intended emergency response functions. The functions and capabilities of the relocated EOF will continue to meet the applicable regulatory requirements. Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed change is associated with the emergency plan and does not impact operation of the plant or its response to transients or accidents. The change does not affect Technical Specifications. The change does not involve a change in the method of plant operation, and accident analyses will not be affected by the proposed change. Safety analyses acceptance criteria are not affected. The standard emergency plan and the plant annexes will continue to provide the required response staff for performing major tasks for the functional areas of the emergency plans.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, SNC concludes the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Page E1-14 of 15 to NL-17-1088 Evaluation of Proposed Change

5.0 ENVIRONMENTAL CONSIDERATION

In accordance with 10 CFR 51, the following information is provided in support of a finding that the license amendment request to relocate the Southern Nuclear Operating Company (SNC) Emergency Offsite Facility (EOF) has no significant effect on the quality of the human environment.

Pursuant to 10 CFR 50.90, SNC has requested amendments to the licenses for Joseph M.

Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2. and Vogtle Electric Generating Plant Units 3 and 4.

Specifically, the proposed changes would revise each plant's license to relocate the consolidated EOF to a new location a short distance (1.3 miles) from the existing location in Birmingham, AL. SNC has determined that the proposed change does not individually or cumulatively have a significant effect on the human environment.

The proposed change has no direct impacts on land use or water resources, including terrestrial and aquatic biota as the proposed action involves no new construction or modification of plant operational systems, as defined in 10 CFR 51. There are no changes to the quality or quantity of non-radiological effluents. No changes to the plants' National Pollutant Discharge Elimination System permits are needed. Changes in staff response to emergencies and drills could conceivably result in minor changes in vehicular traffic and associated air pollutant emissions, but no significant changes in ambient air quality would be expected. In addition, there would be no noticeable effect on socioeconomic conditions in the region, no environment justice impacts, and no impacts to historic and cultural resources. Therefore, there would be no significant non-radiological impacts associated with the proposed action. SNC has concluded that the proposed action would not significantly affect plant safety and would not have a significant adverse effect on the probability of an accident occurring . There would be no change to radioactive effluents that affect radiation exposures to plant workers and members of the public. No changes would be made to plant buildings or the site property. Therefore, the proposed action would not result in a change to the radiation exposures to the public or radiation exposure to plant workers. Therefore, SNC concludes that the proposed action will not have a significant effect on the quality of the human environment.

6.0 REFERENCES

1. USNRC, NUREG-0696, Functional Criteria for Emergency Response Facilities

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

3. USNRC, NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants

4. NRC Exemption dated April 6, 2005 (ML050530134).

5. The NRC Safety Evaluation Report (NUREG-1923) for the Early Site Permit for Vogtle, Units 3 and 4 and the SE for the Standard Emergency Plan establish the SNC Corporate headquarters EOF location for Vogtle, Units 3 and 4.

Page E1 -15 of 15 to NL-17-1088 Layout Diagram - New EOF Enclosure 2 Layout Diagram - New EOF Standard Emergency Plan Figure H.2.A (1 page)

F1gure . Fac**rty H*2*A - Emergency Operations . I)

• Layout (Typ*ca Page E2-1 of 1 to NL-17-1088 State Letters of Agreement Enclosure 3 State Letters of Agreement (4 pages)

Soul~rn  :\uclear Opernli~ ( "ompan~ ~ Southern Nuclear P. 0 . Ho'\ l :!<15 Hinning.lcmL AI. 15201

....... ::!115_')9::!50C.Jil July 14, 2017 Log Number: EP-17-1290 Marteke Fendley Alabama Emergency Management Agency 5898 County Road 41 PO Drawer 2160 aanton Alabama 35046

Dear Ms. Fendley,

Pursuant to Nuclear Regulatory Commission (NRC) regulations, Southern Nuclear Operating Company (SNC) is requesting amendments to the licenses for Edwin 1. Hatch Nuclear Plant, Units 1 and 2 (Hatch), Joseph M. Farley Nuclear Plant, Units 1 and 2 (Farley) and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 (Vogtle) to relocate the consolidated Emergency Operations Facility (EOF) from the SNC Corporate Headquarters at 40 Inverness Center Parkway, Birmingham, Alabama to a proposed new location for the SNC Headquarters at North Tower 3525 Colonnade Parkway, Birmingham, Alabama .

The new EOF location is only a 1.3-mile straight-line distance from the current location.

The lease for SNC's Corporate Headquarters Building at 40 Inverness Center Parkway will expire on December 31, 2018.

SNC has already signed the lease for the new building at North Tower 3525 Colonnade Parkway and construction of the new facility is well underway. Construction of the new EOF will be completed in early 2018. SNC will then begin training and practice drills followed by a full demonstration drill, with NRC observing, which is scheduled for June 20, 2018. The official cutover to the new facility will take place in late 2018 following NRC approval of the license amendments.

The new EOF location offers several advantages over the existing facility. The new EOF location will be larger and will have new, updated equipment and attendant facilities. The location is readily accessible to the Highway 280 and Interstate 459 interchange. Moving to the new location will have no impact on any existing SNC agreements with or commitments to the State of Alabama.

If you have any questions regarding the proposed new location for the EOF, please feel free to contact Ricky Collings, Emergency Planning Coordinator, at 205.992.5855. Otherwise, if you concur with the proposed relocation of the EOF, please evidence your agency's concurrence by signing this letter below and returning to me in the self-addressed, stamped envelope.

As always, your continued support of SNC's Emergency Preparedness program is greatly appreciated.

Sincerely,

~*

lee Mansfield Director- Emergency Planning

Suutlwrn Nuclcm* Operating Clllllfl<\11~* A Southern Nuclear P. 0. BoJ< 1295 Bi1m1nghJ 111 . A L 15201 Tl'l 205.'l92 .."i000 July 14, 2017 Log Number: EP-17-1292 Stephen Clark Program Director Radiological Emergency Preparedness Office of Homeland Security-GEMA P. 0. Box 18055 Atlanta, GA 30316

Dear Mr. Clark,

Pursuant to Nuclear Regulatory Commission (NRC) regulations, Southern Nuclear Operating Company (SNC) is requesting amendments to the licenses for Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), Joseph M . Farley Nuclear Plant, Units 1 and 2 (Farley) and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 (Vogtle) to relocate the consolidated Emergency Operations Facility (EOF) from the SNC Corporate Headquarters at 40 Inverness Center Parkway, Birmingham, Alabama to a proposed new location for the SNC Headquarters at North Tower 3525 Colonnade Parkway, Birmingham, Alabama .

The new EOF location is only a 1.3-mile straight-line distance from the current location.

The lease for SNC's Corporate Headquarters Building at 40 Inverness Center Parkway will expire on December 31, 2018.

SNC has already signed the lease for the new building at North Tower 3525 Colonnade Parkway and construction of the new facility is well underway. Construction of the new EOF will be completed in early 2018. SNC will then begin training and practice drills followed by a full demonstration drill, with NRC observing, which is scheduled for June 20, 2018. The official cutover to the new facility will take place in late 2018 following NRC approval of the license amendments.

The new EOF location offers several advantages over the existing facility. The new EOF location will be larger and will have new, updated equipment and attendant facilities. The location is readily accessible to the Highway 280 and Interstate 459 interchange. Moving to the new location will have no impact on any existing SNC agreements with or commitments to the State of Georgia.

If you have any questions regarding the proposed new location for the EOF, please feel free to contact Ricky Collings, Emergency Planning Coordinator, at 205.992.5855. Otherwise, if you concur with the proposed relocation of the EOF, please evidence your agency's concurrence by signing this letter below and returning to me in the self-addressed, stamped envelope.

s;?t #at£ As always, your continued support of SNC's Emergency Preparedness program is greatly appreciated.

ACKNOWLEDGED AND AGREED Stat* of ~or-f-Lee Mansfield Name: 5t.eJhtfl I

&rL Director - Emergency Planning

Title:

~gnvn 'D.*re~r Date: 1/~t/17

Snuthcrn Nuclear Opcraliu;.: CnmpUII} ..;. Southern Nuclear I'. 0. Box I :!9"i llirmingiiJill. AL 15:!01 Tl'I.!05.992 'iOOO July 14, 2017 Log Number: EP-17-1293 Nathan Nienhius Fixed Nuclear Facility Manager 2779 Fish Hatchery Road West Columbia, SC 29172

Dear Mr. Nienhius,

Pursuant to Nuclear Regulatory Commission (NRC) regulations, Southern Nuclear Operating Company (SNC) is requesting amendments to the licenses for Edwin r. Hatch Nuclear Plant, Units 1 and 2 (Hatch), Joseph M. Farley Nuclear Plant, Units 1 and 2 (Farley) and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 (Vogtle) to relocate the consolidated Emergency Operations Facility (EOF) from the SNC Corporate Headquarters at 40 Inverness Center Parkway, Birmingham, Alabama to a proposed new location for the SNC Headquarters at North Tower 3525 Colonnade Parkway, Birmingham, Alabama.

The new EOF location is only a 1.3-mlle straight-line distance from the current location.

The lease for SNC's Corporate Headquarters Building at 40 Inverness Center Parkway will expire on December 31, 2018.

SNC has already signed the lease for the new building at North Tower 3525 Colonnade Parkway and construction of the new facility is well underway. Construction of the new EOF will be completed in early 2018. SNC will then begin training and practice drills followed by a full demonstration drill, with NRC observing, which is scheduled for June 20, 2018. The official cutover to the new facility will take place in late 2018 following NRC approval of the license amendments.

The new EOF location offers several advantages over the existing facility. The new EOF location will be larger and will have new, updated equipment and attendant facilities. The location is readily accessible to the Highway 280 and Interstate 459 interchange. Moving to the new location will have no impact on any existing SNC agreements with or commitments to the State of South Carolina .

If you have any questions regarding the proposed new location for the EOF, please feel free to contact Ricky Collings, Emergency Planning Coordinator, at 205.992.5855. Otherwise, if you concur with the proposed relocation of the EOF, please evidence your agency's concurrence by signing this letter below and returning to me in the self-addressed, stamped envelope.

As always, your continued support of SNC's Emergency Preparedness program is greatly appreciated.

Sincerely, ACKNOWLEDGED AND AGREED State of  :$.&o f. "'~

Name:f\.k...fL~ ..... .tJ:~""k.; v_s Director- Emergency Planning

Soutbrrn Xudear Opet-ating Company ,--t. Southern Nuclear P. 0. lkn: 1295 Hirmi~Jum. AL 15201 Td 205 99250011 July 14, 2017 Log Number: EP-17-1291 Kimberly Sharkey Florida Division of Emergency Management Lead Radiological Emergency Planner 2555 Shumard Oak Boulevard Tallahassee, Florida 32399-2100

Dear Ms. Sharkey,

Pursuant to Nuclear Regulatory Commission (NRC) regulations, Southern Nuclear Operating Company (SNC) is requesting amendments to the licenses for Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch), Joseph M. Farley Nuclear Plant, Units 1 and 2 (Farley) and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 {Vogtle) to relocate the consolidated Emergency Operations Facility (EOF) from the SNC Corporate Headquarters at 40 Inverness Center Parkway, Birmingham, Alabama to a proposed new location for the SNC Headquarters at North Tower 3525 Colonnade Parkway, Birmingham, Alabama .

The new EOF location is only a 1.3-mile straight-line distance from the current location.

The lease for SNC's Corporate Headquarters Building at 40 Inverness Center Parkway will expire on December 31, 2018.

SNC has already signed the lease for the new building at North Tower 3525 Colonnade Parkway and construction of the new facility is well underway. Construction of the new EOF will be completed in early 2018. SNC will then begin training and practice drills followed by a full demonstration drill, with NRC observing, which is scheduled for June 20, 2018. The official cutover to the new facility will take place in late 2018 following NRC approval of the license amendments.

The new EOF location offers several advantages over the existing facility. The new EOF location will be larger and will have new, updated equipment and attendant facilities. The location is readily accessible to the Highway 280 and Interstate 459 interchange. Moving to the new location will have no impact on any existing SNC agreements with or commitments to the State of Florida.

If you have any questions regarding the proposed new location for the EOF, please feel free to contact Ricky Collings, Emergency Planning Coordinator, at 205.992.5855. Otherwise, if you concur with the proposed relocation of the EOF, please evidence your agency's concurrence by signing this letter below and returning to me in the self-addressed, stamped envelope.

As always, your continued support of SNC's Emergency Preparedness program is greatly appreciated.

Sincerely, ACKNOWLEDGED AND AGREED

((. State o~b~_ u_ 1 1 J ~ ju~Jvci3dd Lee Mansfield Name: ~,-*~JO..:J Director- Emergency Planning

Title:

LetaJ 'teP 22 ~~ hlf 81 lOr LIOZ Date: J{J.IR/1"1 03M3:J3~