NL-18-1514, Response to Request for Information Regarding License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-Shift.

Response to Request for Information Regarding License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-Shift.

ML19031C836
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	01/31/2019
From:	Gayheart C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-18-1514
Download: ML19031C836 (5)

Text

A Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 tel 205 992 7601 fax JAN 3 1 2019 cagayhea@ southernco.com Docket Nos.: 50-321 50-348 50-424 NL-18-1514 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk 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 Response to Request for Information Regarding License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Ladies and Gentlemen:

By letter dated August 9, 2018, Southern Nuclear Operating Company (SNC) submitted a license amendment request to revise Technical Specification 5.2.2.g, "Unit Staff," for the Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, and the Vogtle Electric Generating Plant (Vogtle), Units 1 and 2.

Additionally, SNC requested the approval of a revision to the minimum on-shift staffing tables in annexes associated with the SNC Standard Emergency Plan (SEP) and an accompanying editorial change in the SEP for Hatch and Farley. The proposed changes would eliminate the dedicated Shift Technical Advisor (STA) from the on-shift emergency response organization.

By letters dated December 6, 2018, and January 4, 2019, the Nuclear Regulatory Commission (NRC) staff requested additional information regarding the SNC request. The Enclosure to this letter provides the SNC responses to the NRC requests for additional information.

This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1i day of January 2019.

Respectfully submitted, C. A. ~

Director, Regulatory Affairs Southern Nuclear Operating Company CAG/RMJ

U. S. Nuclear Regulatory Commission NL-18-1514 Page 2

Enclosure:

SNC Responses to NRC Requests for Additional Information cc: Regional Administrator, Region II NRR Project Manager- Farley, Hatch, Vogtle 1 & 2 Senior Resident Inspector- Farley, Hatch, Vogtle 1 & 2 Director, Alabama Office of Radiation Control Director, Environmental Protection Division - State of Georgia RType: CFA04.054; CHA02.004; CVC7000

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 Response to Request for Information Regarding License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Enclosure SNC Response to NRC Requests for Additional Information

Enclosure to NL-18-1514 SNC Responses to NRC Requests for Additional Information NRC RAI (December 6, 2018)

SNC proposes to eliminate a dedicated STA position at Farley and Hatch by allowing the STA functions to be combined with one or more of the required senior reactor operator positions.

SNC further proposes a revision to the on-shift staffing tables in the Farley and Hatch annexes associated with the SNC Standard Emergency Plan to allow the on-shift Shift Support Supervisor to perform the STA function in addition to currently assigned emergency response organization duties. As proposed, this individual is designated as the Shift Support Supervisor/Fire Brigade Leader.

Please explain how Farley and Hatch will ensure that an individual that meets the Commission Policy Statement of Engineering Expertise on Shift (50 FR 43621) and is also the fire brigade leader will be available to provide advisory technical support for events concurrent with manning the fire brigade.

SNC Response to NRC RAI After implementation, the number of senior reactor operators (SROs) for minimum shift staffing at Farley and Hatch will be consistent with the current requirements for Vogtle. Vogtle procedure 00012-C "Shift Manning Requirements" prohibits an individual from being assigned to both shift technical advisor duties and fire brigade duties. There is an item in the SNC corrective action program tracking database to provide fleet governance to apply the Vogtle requirements to Farley and Hatch upon implementation, including the requirements to prohibit an individual from being assigned to both shift technical advisor duties and fire brigade duties.

NRC RAI (January 4, 2019)

Please clarify if the proposed LAR intends to allow the Shift Manager to simultaneously fulfill the role of Emergency Director while being responsible for the STA function, post-event. If so, please justify how the Shift Manager can effectively perform the duties of the Emergency Director while simultaneously fulfilling the general duties, typical responsibilities, and accountabilities associated with the STA function as described in Appendix C of NUREG-0737.

SNC Response to NRC RAI The staffing study to support the proposed LAR was performed in accordance with NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities,"

Revision 0, dated June 2011 (ADAMS Accession No. ML111751698). This document establishes a standard methodology for licensees to perform the required emergency plan staffing analysis. As documented in Interim Staff Guidance (ISG) NSIR/DPR-ISG-01, "Emergency Planning for Nuclear Power Plants," the NRC has reviewed NEI 10-05 and found it to be an acceptable methodology to perform the required staffing analysis. Per NEI 10-05, the Shift Manager may be assigned the role of STA. NEI 10-05 further clarifies that this is an acceptable collateral duty assignment per Generic Letter 86-04, Policy Statement on Engineering Expertise On-Shift.

While NEI 10-05 does not specifically address the role of Emergency Director, it does describe tasks associated with the Emergency Director (e.g. declaring emergency classification level, approving offsite protective action recommendations). The staffing study to support the proposed LAR verified all required tasks per NEI 10-05 (including those typically associated with E-1

Enclosure to NL-18-1514 SNC Responses to NRC Requests for Additional Information the Emergency Director and those previously associated with the dedicated STA) could be performed as required.

Appendix C of NUREG-0737 describes the STA position and identifies specific areas of formal education, plant training and experience necessary to assure an advanced level of analytical ability on shift. Generic Letter 86-04 offers the option of combining one of the required Senior Reactor Operator (SAO) positions with the STA position into a dual-role (SRO/STA) position for meeting the current requirements for providing engineering expertise on shift (NUREG-0737, Item I.A.1.1) and meeting licensed operator staffing requirements (1 0 CFR 50.54 (m)(2)). As previously stated, NEI 10-05 clarifies the Shift Manager may fulfill this dual-role SRO/STA position for the staffing analysis.

To summarize, the Emergency Plan staffing analysis supporting the proposed LAR does provide the allowance for the Shift Manager to simultaneously fulfill the role of Emergency Director while being responsible for the STA function, this allowance is consistent with NEI 10-05 guidance as endorsed by ISG NSIR/DPR-ISG-01.

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