ML20224A464

Southern Nuclear Operating Co, Inc - Supplement to License Amendment Request to Revise the Emergency Plan to Change Staffing and Extend Staff Augmentation Times for Emergency Response Organization Positions

ML20224A464
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	08/11/2020
From:	Gayheart C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20224A464 (30)

Text

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 tel 205 992 7601 fax August 11, 2020 NL-20-0908 Docket Nos.: 50-321 50-348 50-424 52-025 50-366 50-364 50-425 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant - Units 1 and 2 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 3 and 4 Supplement To License Amendment Request to Revise the Emergency Plan to Change Staffing and Extend Staff Augmentation Times for Emergency Response Organization Positions Ladies and Gentlemen:

On June 30, 2020 (ML20192A140), pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requested amendments to the licenses for the plants and units listed above.

The license amendment request (LAR) proposed to revise the SNC Standard Emergency Plan (SEP), including the Site Annexes, to change the emergency response organization (ERO) staffing composition and extend staff augmentation times from 75 to 90 minutes.

On July 23, 2020 (ML20209A004), the U.S. Nuclear Regulatory Commission (NRC) staff provided the results of their acceptance review and concluded that technical information was not provided in sufficient detail to enable the NRC staff to complete its detailed review. In order to make the application complete, the NRC staff requested that SNC supplement the application by August 11, 2020.

SNCs response is enclosed with a general response in Enclosure 1 and a detailed technical analysis table in Enclosure 2. In preparing the enclosed Supplement, SNC decided to make one change in the original LARs ERO staffing composition. In addition to the 48 augmentation responders, SNC will augment an additional two Radiation Protection technicians. A revised mark-up of the SEP Table 1 is provided in Enclosure 3.

U. S. Nuclear Regulatory Commission NL-20-0908 Page 2 SNC requests the same approval and implementation schedule as requested in its original application.

The conclusions of the No Significant Hazards Consideration Determination Analysis and Environmental Consideration contained in the original LAR have been reviewed and are unaffected by this supplement.

This letter contains no sensitive information and no new regulatory 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 August 11, 2020.

Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Company CAG/efb/snm

Enclosures:

1. SNC Response to NRC Request for Supplemental Information

2. Supplemental Analysis Table

3. SNC Standard Emergency Plan Revised Table 1 cc: NRC Regional Administrator, Region ll NRC Project Manager - Farley, Hatch, Vogtle 1 & 2, Vogtle 3-4 NRC Senior Resident Inspector - Farley, Hatch, Vogtle 1 & 2, Vogtle 3-4 Director, Alabama Office of Radiation Control Director, Environmental Protection Division - State of Georgia SNC Document Control RTypes: CFA04.054; CHA02.004; CVC7000; VND.LI.L00

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 Supplement To License Amendment Request to Revise Standard Emergency Plan To Change Staffing and Extend Augmentation Times Enclosure 1 SNC Response to NRC Request for Supplemental Information to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Response to NRC Request for Supplemental Information NRC Request to Supplement Please provide an analysis that can be used by the NRC staff to assess the impact of the proposed changes on the relief and support functions offered by the augmenting ERO staff to effectively implement the emergency plan. Supplemental information needs to be sufficiently detailed to provide justification for extension of ERO response times and proposed changes to ERO on-shift and augmentation staffing.

SNC Response SNC appreciates the opportunity to supplement its June 30, 2020 application and agrees that the NRC staff needs additional detail to fully understand the analysis performed by SNC for the proposed changes.

The proposed SNC ERO staffing strategy for the on-shift relief and support positions and the augmentation response time is justified by the comprehensive and systematic review performed by SNC, which demonstrates that the proposed staffing is adequate to provide that initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available. SNC has compared its proposed ERO staffing against that in the Revised Table B-1 of NUREG 0654, and the strategy will be explained in detail in this Supplement. SNC has also compared its process for analyzing the proposed changes against other similar licensee submittals that have been approved by the NRC, and SNC believes that its analysis is robust and comprehensive. The analysis used to assess the impact of the proposed changes on the relief and support functions offered by the augmenting ERO staff will be explained in detail in this Supplement.

Supplemental Information on the SNC Staffing Strategy As an introduction, SNCs proposed staffing strategy has certain components that should be considered in the evaluation of the overall effectiveness of the SNC emergency plan.

First, SNC uses an all-call all-respond notification of the ERO members. Essentially, all ERO members come in and the first to arrive get started. The SNC Standard Emergency Plan (SEP) requires a large one-team contingent of 50 augmentation responders. However, as unannounced drills confirm, it is probable that additional augmentation staff would arrive and all three ERFs would be activated earlier than 90 minutes. Finally, a 90-minute response time will ensure that essentially all of the plant population of employees at SNC sites will be eligible for ERO duty, except for employees living in the most remote residences.

Second, SNC activates the TSC, OSC, and the EOF upon declaration of an Alert or higher classification. (The Revised Table B-1 guidance is that the EOF is activated only upon declaration of a Site Area Emergency.) As a result, the SNC strategy, in this respect, is more E1-1 to NL-20-0908 SNC Response to NRC Request for Supplemental Information conservative as the entire ERO augmentation staff performing relief and support functions are activated together from a lower-level classification. Consequently, the SNC SEP ensures that the EOF and the entire ERO augmentation team is already activated at lower-level events in case the emergency progresses to a higher classification.

Third, SNCs proposed Operations staff is large enough to ensure that the Shift Manager/ED is dedicated to performing emergency plan (EP) functions. At SNC, all SROs are trained as EDs, and the two Unit Shift Supervisors are qualified as EDs. The Shift Supervisors have the knowledge and skills to provide supplemental support to the Shift Manager/ED for EP functions as prioritized by the ED. And, while the fire brigade leader (FBL) SRO is not included in the emergency plan count, when not actively firefighting, the FBL SRO is also available to support the Shift Manager/ED. (Vogtle 3-4, with two control rooms, has one additional SRO over the staffs at FNP, HNP, and VEGP 1-2.)

SNCs on-shift non-licensed operators provide a competent staff, available from the beginning of initiating conditions, to perform initial troubleshooting and minor electrical and/or mechanical work to restore power and/or flow. SNCs analysis concludes that the initial tasks most needed in the first 90 minutes include the performance of troubleshooting, repairs and corrective action tasks for which operators are either already trained or will be appropriately trained upon implementation of the proposed staffing changes.

SNCs proposed alternate staffing approach provides that initial facility accident response in key functional areas is maintained at all times, and there is timely augmentation of response capabilities. By slightly extending the augmentation time for all responders 15 minutes and removing unnecessary personnel from on-shift, SNC gains operational efficiency, flexibility, and an expanded talent pool for ERO augmentation.

Supplemental Information on the Staffing Analysis Process In designing the proposed ERO staffing strategy for the on-shift relief and support positions and the augmentation response times, SNC reviewed, considered and evaluated the proposed changes against the NRC regulations in 10 CFR 50.47(b) and 10 CFR 50 Appendix E and the NRC guidance in NUREG 0654, RIS 2016-10, Reg Guide 1.219 and NSIR/DPR-ISG-01. SNC proposed an alternate strategy than the one in the NRC Revised Table B-1 in order to gain the efficiencies of having only one ERF activation classification (Alert or Greater) and one extended augmentation time (90 minutes).

In its July 23, 2020 letter, the NRC described the SNC Performance-Based Procedure Analysis (PBPA) as the primary basis for the proposed changes to the SNC SEP and does not address any support and relief functions that would be expected to be performed by the augmenting ERO. SNC did not intend to imply that the PBPAs were the primary basis for the proposed changes. Also, SNC did consider the EP support and relief functions when conducting the analysis. Therefore, SNC agrees that its June 30, 2020 application lacked clarity and enough detail for the NRC to gain a full understanding of the technical and functional analysis performed to support the proposed changes. SNC will provide sufficient detail in this supplement.

The analysis for the proposed changes was performed as follows. SNC assembled a multi-disciplined team at each of the four sites who worked together with Corporate employees and E1-2 to NL-20-0908 SNC Response to NRC Request for Supplemental Information outside consultants to review and evaluate the proposed changes, procedures, training, design documents, plant emergency core cooling system equipment, communications capabilities, and software. This review included analysis of the SNC SEP functions and effectiveness during numerous accidents and events. Central to this analysis was the premise that accidents and events can occur at any time based on all possible initiating conditions and that the loss of major equipment and a radiological release could start at any time. The technical analysis specifically addressed all of the emergency plan tasks and functions that must be performed by every on-shift ERO member and every augmentation ERO responder to a) preclude an emergency from escalating to a Site Area or General Emergency and b) perform mitigation tasks should fission product barriers fail and a significant radiological release occur. Therefore, this analysis considered all functions of the SNC SEP, including classifications, offsite protective action recommendations, state/local notifications, extension of allowable dose limits, direction of the on-shift staff, ERO notification, NRC communications, documentation, activation of the emergency response data system (ERDS), offsite radiological assessment, personnel accountability, and more. After these reviews and analyses were completed, SNC concluded that the SNC Emergency Plan and Annexes, as proposed in the LAR, would be effective in responding to emergencies and would continue to meet the requirements in 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b). Supplemental details of this analysis are included in Enclosure 2.

Due to specific considerations in the NRC guidance in RIS 2016-10, SNC, in recognizing that the proposed changes represented an alternative approach to that provided by the NRC in its revised Table B-1, decided to evaluate further and perform a supplemental PBPA at each site.

RIS 2016-10 states that licensees should develop the on-shift and ERO staffing levels using a performance-based approach. This approach (a) ensures EP functions are constantly maintained, and (b) ensures that no credible accident scenarios can occur that would detract a given position from performing their assigned emergency response functions. SNCs teams designed and performed PBPAs at each site to satisfy this aspect of RIS 2016-10. By broadening the analysis to include all Emergency Operating Procedures (EOPs), Abnormal Operating Procedures (AOPs), Emergency Plan Implementing Procedures (EPIPs), and supporting procedures, SNCs supplemental PBPA approach added confidence that the proposed changes would be acceptable under almost any emergency circumstances. Again, as in the primary analysis, central to PBPAs was the premise that accidents and events can occur at any time based on all possible initiating conditions and that the loss of major equipment and a radiological release could start at any time. The PBPAs were performed under the assumption that all of the EP functions must be performed by on-shift personnel to preclude escalation of an emergency to a General Emergency or perform mitigation tasks should fission product barriers fail and a radiological release occur. Therefore, the PBPAs considered all functions of the SNC SEP, including classifications, offsite protective action recommendations, state/local notifications, extension of allowable dose limits, direction of the on-shift staff, ERO notification, NRC communications, documentation, activation of the ERDS, offsite radiological assessment, personnel accountability, etc. Uniquely, the PBPAs established a supplemental justification for relying on the training and expertise of non-licensed operators for the scope of repair and corrective actions that would be needed in the first 90 minutes after declaration of an Alert or greater emergency. According to the PBPAs, such actions would be limited to the kinds of E1-3 to NL-20-0908 SNC Response to NRC Request for Supplemental Information troubleshooting, limited maintenance, minor repairs, and actions to promptly restore a non-functional component or system (e.g. resetting a relay, opening a valve, or closing a breaker.)

The PBPAs also provided supplemental support for the conclusion that the Shift Manager/ED duties can be constantly maintained from the beginning of the event to 90 minutes, including duties that could be augmented earlier by the Revised Table B-1 guidance, such as, coordination of important EP functions (technical support, radiation protection (RP),

troubleshooting, and repair teams).

Supplemental Information on Enhancements SNCs technical evaluations, described in enclosures 3, 5, 7, and 9 of the original application, included a review of each sites ECCS systems and engineered safety features (ESF) capabilities, including protection against single failures, to establish a basis for appropriately crediting the robust plant designs in support of the proposed changes to the ERO staffing composition and extension of augmentation time. SNCs technical evaluation also included a review of each sites equipment upgrades, software enhancements, and improved technologies.

SNC provides the following supplemental information on these enhancements.

a. Improved Remote Monitoring Since 2017, SNC has improved remote monitoring programs inside the stations. Two new systems are in use. One uses 900 MHz radio signals to monitor dose rates and a new expanded WiFi system that provides expanded visual monitoring of rooms/equipment. The radio system gives RP personnel the capability to remotely monitor individuals using their electronic dosimeter as a sending unit back to a central monitoring station. This effectively allows all individuals wearing electronic dosimeters to be remotely monitored and provides RP with immediate indication of dose rates throughout the plants. The WiFi system allows Operations to place cameras in most areas of the plant based on their needs with no external support required. Other areas are accessible via cable that does not require an engineering modification for installation. These capabilities provide the Emergency Director with both real time visual monitoring of key emergency plan equipment (i.e. ECCS equipment) and dose rates for troubleshooting/repair teams.

b. Improved Communications Systems Mobile communications along with defined bridge lines allow augmented staff to be in communication with on-shift personnel from the time they are alerted of an emergency at the stations. Augmented staff can communicate as they are in route to the stations and aid on-shift personnel even before they arrive at their emergency facilities. Common hands-free technologies with mobile phones allow ERO members to safely communicate and can increase the effectiveness of information sharing and turnover from the on-shift staff.

c. Improved Document and Record Retrieval SNC has made improvements to systems that provide direct access to engineering and vendor documents in a short period of time. The documents are accessible E1-4 to NL-20-0908 SNC Response to NRC Request for Supplemental Information remotely. These capabilities improve access and timing of access to information for technical support, troubleshooting and repair activities.

d. Improved Dose Assessment Program This program has been improved to provide an automatic method that greatly reduces the effort to run a dose projection. With minimal data entry, the program will perform the assessment and provide the recommended protective action recommendations. This eliminates a significant amount of time for the on-shift personnel to perform these functions including looking up PARs in procedures.

e. Procedure Improvements Station operating procedures have been updated to reflect modifications to station equipment and to align with the reactor owners group recommendations. These changes add focus for diagnosing symptoms of events which allows for more efficient implementation of emergency plan troubleshooting and repair functions. The entire set of emergency preparedness implementing procedures were rewritten to support implementation of the SEP. This effort resulted in substantial procedural improvements, including use of simplified, focused actions which lead to a more efficient and effective emergency preparedness program.

Supplemental Information on Relief & Support Functions offered by Augmenting Staff SNC performed a comprehensive and detailed function-by-function analysis assessing the impact of the proposed changes on the relief and support functions offered by the augmenting ERO staff to implement the emergency plan. This analysis considers the functions performed by the augmenting ERO staff to relieve and support the on-shift staffing and provides the basis for extending the ERO response time.

Using this analysis, SNC has compiled a table to document how the guidance on functions/resources from NUREG 0654 Revised Table B-1 and RIS 2016-10 align with the proposed SNC ERO staffing to demonstrate and document an assessment of the impact of the proposed changes on the relief and support functions offered by the augmenting ERO staff. The table includes the SNC basis, justification, and conclusions for each EP functional area. See .

In summary, SNC, considering NRC guidance, has performed a comprehensive and rigorous process to develop an alternate ERO staffing approach. The Revised Table B-1 and supporting RIS were used as templates to evaluate and document SNCs proposed changes. Variations from the NRC guidance are compensated for as discussed in Enclosure 2.

E1-5

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 License Amendment Request to Revise Standard Emergency Plan To Change Staffing and Extend Augmentation Times Enclosure 2 Supplemental Analysis Table to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018)

Notification and Communications Communication To adequately support the Communicate EAL and In alignment with the RIS 2016-10 guidance for extending two 60- SNCs proposed 90-elimination or extension of PAR classifications to minutes responders to 90 minutes, SNC has 2 dedicated on-shift minute augmentation the two 60-minute offsite response communicators, one for communicating EALs and PARs to the offsite responders are listed in responders, the licensee organizations (OROs), agencies (ENN Communicator), and one for communicating with the Table 1 of the revised should show that two on- including the NRC, until NRC on an open line (ENS Communicator). The on-shift ENN SNC Standard shift positions are identified relieved. Communicator function is normally performed by the unaffected units Emergency Plan in the to fill the 60-minute unit operator (UO). The UO is a licensed reactor operator and can LAR. SNC augments a responders role to Notify On-shift - One perform this intermittent function because the primary operation of minimum of 50 total licensee, State, local and Communicator (other the unaffected unit is being accomplished by the unaffected units responders. SNCs Federal personnel [and] personnel may be assigned operator-at-the-controls (OATC). The ENS Communicator is normally proposed augmentation maintain communication. this function if no collateral performed by the unaffected units Shift Supervisor or another SRO. staff for this function The licensee should show duties are assigned that are SNC studies have confirmed that the 2 on-shift communicators are meets the NRC guidance that these positions are not beyond that individuals able to perform their E-plan roles effectively and are not assigned in the Revised Table B-1.

assigned other tasks that capability.) other tasks that would prevent timely performance of their may prevent the timely communication duties. Because SNC uses All-performance of their Within 60 minutes from an Call/All-Respond from an assigned notification or Alert or Greater, augment Technological advances have made the ENN communication process Alert, SNC can augment communication functions, with two Communicators in more efficient, thereby reducing the impact to on-shift this function with more as specified in the the TSC. One personnel. Offsite agency notification has progressed from being personnel, as needed.

emergency plan. The communicator for the NRC performed using paper copies with each line communicated aloud licensee should discuss and one communicator for (line-by-line) to the point that the ENN Communicator can now Within 90 minutes of an how communication OROs. connect/communicate with all offsite agencies instantly and confirm Alert or higher, SNC technologies employed by receipt promptly using a bridge line. The software used to create the provides relief for the two the proposed on-shift staff Within 60 minutes from a electronic form (WebEOC) allows for easy population of information dedicated on-shift will support timely, Site Area Emergency or using drop-down lists and other features (e.g. the EAL description is Communicators in the effective, and reliable Greater, augment with one automatically populated when the appropriate EAL number is TSC and the EOF.

notifications. Additionally, Communicator in the EOF. selected, auto population of time/date, etc.). The software also the communications improves accuracy through features that highlight omitted information In the TSC, SNC technologies should be As needed: and provide for validation prior to submittal. These tools allow the augments with an ENS referenced in the Within 90 minutes of Alert ENN communication process to be completed in an effective and Communicator who emergency plan to ensure or Greater, augment with reliable manner well within the time requirements for the task.

E2-1 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) that future changes are one Communicator for NRC reports to an augmented reviewed using the RG Communications if needed. The ENS communicator can use a wireless headset that is dialed in Operations Supervisor.

1.219 change process, as as an open line to the NRC. This allows the individual to not be tied to they were used as the a wired telephone. This individual can fulfil the ENS communication In the EOF, SNC basis for the proposed function while assisting as needed with other prioritized tasks. The augments with both an change. intermittent nature of the communications needed by the NRC during ENS Communicator and the onset of an event (prior to augmentation), along with an ENN Communicator technological advances (wireless headset), allows the ENS who report to an Communicator function to be accomplished by the unaffected units Emergency Shift Supervisor or another SRO, without disrupting other duties. Communication Coordinator, as the offsite Communication technologies are appropriately documented in the agency notification SNC Emergency Plan or procedures and subject to SNCs 50.54(q) function shifts to the EOF.

change process that follows the guidance in R.G. 1.219.

SNC has concluded that the proposed changes are effective and the addition of augmented support for the period from 60-90 minutes is not necessary.

Emergency Operations Command & Control Facility Director Per the guidance in 1) Provide overall ERO 1) The Emergency Director role is filled at beginning of event SNCs proposed 90-NUREG-0654, Table B-1, command and control until classification by the Shift Manager. The primary function of overall minute augmentation an augmented Senior relieved. ERO command and control resides with the Shift Manager until they responders are listed in Manager should fulfill the 2) Approve emergency are relieved by the augmented team in the TSC and EOF. Oversight Table 1 of the revised Emergency Operations action level (EAL) and/or of the individual units remain with the unit Shift Supervisors. All SNC Standard Facility Director major task PAR classifications until SROs on-shift are trained as Emergency Directors, so the opportunity Emergency Plan in the at 60 minutes. A licensee relieved. for assistance and peer checking exists as well as other needed LAR. SNC augments a requesting a change in staff 3) Authorize personnel support. minimum of 50 total augmentation requirements dose extensions until responders. SNCs that would have the lead relieved. Other SROs (including the two unit Shift Supervisors and the Shift proposed augmentation manager unavailable to Support Supervisor filling the Fire Brigade Leader role) provide staff for this function assume command and supervision and direction for other functions (e.g. plant response, E2-2 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) control within 60 minutes of On-shift - One Operations EOP/AOP actions, fire response, dispatch and tracking of personnel meets the NRC guidance the initial emergency Shift Manager sent to perform troubleshooting/repair actions) while the Shift in the Revised Table B-1.

declaration should show Manager is dedicated to the ED role. If a fire emergency is not that the on-shift staff Within 60 minutes from an occurring, the SRO filling the Fire Brigade Leader role will be able to Because SNC uses All-includes enough qualified Alert or Greater, augment provide additional support regarding oversight, peer checks and other Call/All-Respond from an supervision such that one with one Emergency support. Alert, SNC can augment supervisor will assume the Coordinator. Prior to 90 minutes, advanced communication capabilities (e.g. using this function with more emergency director role. mobile devices) are available to support the on-shift ED. personnel, as needed.

The licensee should show Within 60 minutes from a that the on-shift supervisor Site Area Emergency or 2) The ED determines classifications and approves Emergency performing the manager Greater, augment with one Action Level (EAL) and PAR notifications supported by peer checks Within 90 minutes of an actions will not have any Emergency Director in the from the other SROs in the control room. The on-shift ED regularly Alert or higher, SNC additional duties (e.g., each EOF. practices these functions to ensure proficiency, and they are provides relief for the unit under the direction of a evaluated regularly during Licensed Operator Continuing Training. Shift Manager/ED with a unit supervisor, a shift For General Emergencies, PARs are available from the automated TSC ED and an EOF ED.

manager providing dose assessment program or from the associated procedure based The TSC ED will assume oversight of the plant on dose assessment or plant-based default determinations using command and control for response, and a designated wind speed and direction. all non-delegable duties emergency director with the exception of off-responsible for emergency 3) The non-delegable responsibility to authorize emergency site notification and PAR plan implementation). exposures in excess of federal limits resides with the ED. It is highly unlikely that a personnel dose extension would be required in the first development and 90 minutes following declaration. However, if one is required, the on- approval which is shift RP develops documentation for the subject individual(s), dose assumed by the EOF ED.

rates in the area and time expected to be expended in the area, and the amount of dose the individual has available without extension.

The extension is then presented to the ED for approval. The need for dose extensions (and possibly KI) is evaluated based on the need to:

• Temporarily repair needed equipment preventing or mitigating further damage to the plant

• Stopping or limiting radioactive releases to the environment.

E2-3 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018)

SNC has concluded that the proposed Operations staff is effective and that augmenting this position for the period from 60-90 minutes is not necessary.

Emergency Classifications Evaluate plant conditions The Emergency Director owns the non-delegable duty of event SNCs proposed 90-and recommend emergency classification, including approval and notification. The advisory minute augmentation classifications, until functions of evaluation of plant conditions and recommendations responders are listed in relieved. regarding event classification is a continuous shared responsibility Table 1 of the revised owned by the entire on-shift Main Control Room operating crew. All SNC Standard On-shift - Emergency Licensed Operators (SROs and ROs) are trained to evaluate plant Emergency Plan in the Classification Advisor (other LAR. SNC augments a conditions and recognize important parameters that can impact personnel may be assigned minimum of 50 total emergency classification levels. This information is shared among this function if no collateral responders. SNCs duties are assigned that are the entire Main Control Room staff, including the ED, by use of formal proposed augmentation beyond that individuals updates or 3-way Communication when conditions are staff for this function capability.) identified. Therefore, SNC believes that a dedicated resource in an meets the NRC guidance advisory capacity is not required to adequately fulfill the emergency in the Revised Table B-1.

classification function.

Within 60 minutes from an Because SNC uses All-Alert or Greater, augment Operator aids such as human factored classification wall-boards are Call/All-Respond from an with one Emergency available in the Control Rooms, TSCs and EOF, and are used to Alert, SNC can augment Classification advisor in the improve classification efficiency. Multiple wall-boards are available in this function with more TSC. Licensees should order to allow personnel to review potential classifications personnel, as needed.

consider having a liaison concurrently.

between Operations (Control Room) and the SNC has concluded that the proposed Operations staff for this Within 90 minutes of an TSC to perform this function is effective and that augmenting this position for the period Alert or higher, SNC function. from 60-90 minutes is not necessary. provides relief for the Shift Manager/ED with a E2-4 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018)

TSC ED and an EOF ED, along with other Operations supervision that can assess the plant from the TSC. This advisory function is not officially transferred to augmented staff, as the evaluation of and response to plant conditions remains a core role of the Main Control Room team at all times.

Supervision of Repair Team Activities On-Shift: Not applicable Repair Team Supervisor duties would change in that the SNCs proposed 90-Maintenance positions would be removed from on-shift, and the SNC minute augmentation Within 60 minutes of an staffing strategy shifts these functions to being performed by the on- responders are listed in Alert or Greater, augment shift operating crew. For supervision of repair team activities in the Table 1 of the revised with one Lead OSC first 90 minutes, the Unit Shift Supervisor directs operators to perform SNC Standard Supervisor. necessary repair and corrective action tasks and follow the priorities Emergency Plan in the set by the ED. Additionally, all on-shift SROs are capable of LAR. SNC augments a Within 90 minutes of an providing the repair team supervisor function. minimum of 50 total Alert or Greater, augment responders. SNCs with one Electrical/I&C The Operations SROs performing repair team supervisor duties direct proposed augmentation Supervisor to the OSC, one the operations staff on a daily basis. They direct and supervise on- staff for this function Mechanical Supervisor to shift resources to perform procedure-driven actions (e.g. reset a meets the NRC guidance the OSC, and one RP breaker to restore power to a safety injection pump) and provides in the Revised Table B-1.

Supervisor to the OSC. direction to troubleshoot and report field conditions (e.g. going to a pump to determine if there is any visible damage, to check power availability, evaluate local indications, etc.). Their focus is on overall Because SNC uses All-control of the site. The ED is in command and primarily focused on Call/All-Respond from an E2-5 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) implementation of the Emergency Plan and the associated mitigation Alert, SNC can augment actions, which includes restoration of equipment to mitigate an this function with more accident. These problem-solving and trouble-shooting principles are personnel, as needed.

well understood by on-shift Operations SROs. Per procedures, SRO duties include signing-off on troubleshooting forms on a regular basis. SNC augments with a full The ED is thus informed on typical elements of troubleshooting but contingent of applies them via the emergency plan implementing procedure (EPIP) Maintenance and RP process. Supervisors (Group Leads) and technicians SNCs analysis concludes that the initial tasks most needed in the within 90 minutes. SNC first 90 minutes include the performance of numerous augments in the OSC troubleshooting, repair and corrective action tasks for which with an OSC Manager, operators are already trained or will be appropriately trained upon implementation of the proposed staffing changes. Many of the repair Electrical, Mechanical, and corrective actions that go beyond the skill of the craft for NLOs and I/C Maintenance are more likely significant or complex enough that work sequence Supervisors and at least planning and tagging would be required. Tagging and work order one electrician, planning is a rigorous process; rigor must be maintained during an mechanic, and I/C emergency (e.g., to ensure the health and safety of our technicians). technician assigned to If required, Shift SROs would prepare tagging orders during the 90- each.

minute augmentation period. The timing is such that repair activities that necessitate tagging would likely not be tagged out within 60 Within 90 minutes, SNC minutes even if technicians were on site. SNCs PBPA approach also augments with a provides confidence that repairs beyond the capabilities of on-shift TSC Maintenance operators may be delayed and performed by qualified augmented Supervisor, whose technicians, which therefore supports that the supervision of these primary function is to repair team activities is also not needed prior to the 90-minute ensure clear direction is augmentation time. Training operators to perform relevant first- provided to the OSC response tasks, as described above, within the first 90-minutes Coordinators for provides for timely and effective response. Therefore, augmenting an troubleshooting/repair OSC lead supervisor for the period from 60-90 minutes is not actions, status team necessary.

actions and to provide input to the TSC ED on E2-6 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018)

In conclusion, supervision by the on-shift ED with the support of other results to allow an on-shift SROs from the beginning of initiating conditions and informed decision on throughout the first 90 minutes provides for timely and effective priorities and needed response. changes. This function is performed by the on-shift ED until relieved.

Chemistry/ Dose Assessments/

Radio-chemistry Projections Per the guidance of Perform dose SNC has an on-shift Chemist fully dedicated to dose assessment with SNCs proposed 90-NUREG-0654, Table B-1, assessments/projections no collateral assignments for 90 minutes. Per the RIS and SNC's minute augmentation there should be one and provide input to PBPAs, there are no sampling or analysis tasks performed by responders are listed in augmented Rad/Chem applicable PAR decision- Chemistry that cannot be delayed until augmentation. Table 1 of the revised Technician at 60 minutes. maker, until relieved. SNC Standard To adequately support an SNCs dose assessment program has been improved to provide an Emergency Plan in the extension of this responder On-shift: One chemist automatic method that reduces the effort to run a dose projection. LAR. SNC augments a beyond 60 minutes, the (other personnel may be With minimal data entry, the program will perform the assessment minimum of 50 total licensee should assigned this function if no and provide the recommended protective action recommendations. responders. SNCs demonstrate that no collateral duties are This reduces the amount of time for the on-shift personnel to perform proposed augmentation chemistry-related task is assigned that are beyond these functions. staff for this function required to be performed that individuals capability.) meets the NRC guidance within 90 minutes of an The interim period from 60-90 minutes that the on-shift teams are in the Revised Table B-1.

emergency declaration (i.e., Within 60 minutes of an without the augmented dose assessment capability does not a task that is necessary for Alert or Greater, augment adversely impact either the ability to determine entry criteria for EALs implementation of one Dose Assessor to the or prevent actions to mitigate/stop a declared emergency. Because SNC uses All-emergency operating TSC. Call/All-Respond from an procedures or operation of Alert, SNC can augment safety-related equipment), Within 60 minutes of a Site this function with more or that all such tasks can Area Emergency or personnel, as needed.

be performed by the on- Greater, augment 1 Dose shift chemistry technician Assessor to the EOF. Within 90-minutes, after with no collateral duty relieved of dose concerns. assessment duties by the EOF, the on-shift chemist E2-7 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) reports to the TSC to perform radiochemistry duties.

Technical Support Engineering Per the guidance of Provide engineering The Operations STA, supported by the other SROs and ROs, SNCs proposed 90-NUREG-0654, Table B-1, coverage related to the provides sufficient technical support until relieved within 90 minutes. minute augmentation Electrical and specific discipline of the The STA and other SROs comprise a competent technical staff responders are listed in Mechanical expertise assigned engineer, until because of the limited technical support needed within 90 minutes, Table 1 of the revised should be relieved plus advancements in procedures, training and technology. SNC Standard provided by two 60-minute Emergency Plan in the responders under the On-shift: 1 Core/Thermal The STA function has been improved over the past several years. LAR. SNC augments a Technical Support major Hydraulics Engineer to Technology upgrades have enhanced data information displays in the minimum of 50 total task. To adequately justify evaluate reactor conditions. control room. The use of multiple monitors around the control room responders. SNCs an extension of these (other personnel may be allow for critical parameters to be displayed, trended, and monitored proposed augmentation responders, the licensee assigned this function if no by all members of the shift crew. Establishing critical parameters and staff for this function should show that on-shift collateral duties are then displaying them with precise trending capability allows for early meets the NRC guidance positions are capable of assigned that are beyond indication of potential emergency escalations or other issues like an in the Revised Table B-1.

filling these roles during the that individuals capability.) interruption of core cooling (e.g. indications that natural circulation 90-minute period after an has been interrupted). These parameters are discussed during crew emergency Within 60 minutes of an briefings to raise awareness. Monitoring of these parameters are Because SNC uses All-declaration. This will require Alert or Greater, augment assigned to specific individuals (i.e. reactor operators or the STA). Call/All-Respond from an a review of site procedures one Electrical/I&C, one Even when a specific individual is assigned the task of monitoring a Alert, SNC can augment to identify the technical Mechanical, and one specific parameter, the fact that so many parameters can be this function with more support tasks Core/Thermal Hydraulic displayed allows the whole crew to assist in identifying if a parameter personnel, as needed.

requiring electrical and engineer to the TSC. is trending towards or exceeds a threshold. Critical safety function mechanical expertise that status indications are examples of such parameters. These In the TSC, within 90 must be performed within advancements allow the STA to perform other duties. Many SROs minutes, SNC augments the first 90 minutes of an are also qualified as STA. For example, if the Shift Support with an Engineering emergency. The licensee Supervisor Fire Brigade Leader is STA-qualified, under non-fire Supervisor, Reactor should then show that there scenarios, they would be available and could be dispatched to the Engineer, and two are on-shift positions with field to provide engineering expertise. discipline engineers.

the necessary expertise to E2-8 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) perform the identified Engineering expertise can be provided by the STA during the In the EOF, within 90 technical support functions, proposed, extended augmentation time, which is of limited duration. minutes, SNC augments and that such performance The qualification program for an STA encompasses many areas with a technical will not prevent the timely including electrical fundamentals and mechanical equipment supervisor.

performance of their other operating principles. For example, the electrical fundamentals assigned functions, as include, but are not limited to, principle of operation and basic specified in the emergency construction of fuses, magnetic overloads, circuit breakers, thermal plan. The justification overloads, etc. This also includes the ability to provide technical should identify procedure, advice to the operating crew regarding the function of electrical training and information equipment using systems, component, and circuit data. Likewise, the technology advances made curriculum also provides similar training in mechanical equipment since the implementation of operating fundamentals. While the STA may not be able to leave the NUREG-0654 that facilitate control room during an emergency event, it is possible to use technical support photographs from the field, which can be sent real-time electronically assessments by on-shift (e.g. via a text message) to the SROs in the control room. The sites personnel or obviate the have Wi-Fi capabilities in areas of the plant and the coverage need for such assessments continues to expand. Once the STA uses their expertise to diagnose within 90 minutes of an an equipment issue (whether mechanical, electrical, or other), it is emergency declaration. likely that the equipment deficiency would be more than minor and Additionally, the change corrective action would require equipment clearance and tagging, justification should address work order preparation, spare parts, special tooling, lubricants, the ability of on-shift meters, etc. These activities would most likely not be accomplished positions to perform within 90 minutes. The more likely occurrence is that a clearance troubleshooting activities and/or work sequence would be required and the shift crew would be without interfering with their either developing or hanging clearances in the field as the primary emergency augmentation teams travel to the station (opening or racking out response duties (e.g., on- circuit breakers, closing isolation valves, opening drains/vents, shift electrical or hanging danger tags on components, etc.). As a result, mechanical augmentation of Engineers within 60 vs 90 minutes is not necessary maintenance personnel and not consistent with the kinds of immediate technical support with supervisory personnel required. Further, a broad spectrum of Engineering support is to provide oversight). available by mobile technology from the beginning of initiating conditions.

E2-9 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018)

These improvements, along with the training expertise of the STA, allows the on-shift staff to achieve success in the Technical Support function for the augmentation time extension. The PBPA approach, reviewing procedure-driven steps for EOPs/AOPs supplemental to the staffing studies meets the guidance in the RIS that states review of site procedures to identify the technical support tasks requiring electrical and mechanical expertise that must be performed within the first 90 minutes of an emergency. The PBPA review stacked probable emergency response actions on to the procedure driven actions. SNCs PBPA demonstrated that the proposed on-shift staffing has the necessary expertise to perform the identified technical support functions, and that such performance will not prevent the timely performance of their other assigned functions, as specified in the emergency plan.

Key improvements in communications and quick access to engineering and vendor information provide much greater capabilities for the on-shift staff prior to augmentation. On-shift personnel and offsite Engineers have access to information remotely. The ED can use a bridge line to communicate with and obtain assistance prior to the augmented staff arriving at the station. Advancements in mobile communications allow rapid technical support response from SNC Engineering and contractor engineers prior to 90 minutes.

SNC has concluded that the proposed Operations staff for this function is effective and that augmenting this position for the period from 60-90 minutes is not necessary.

Repair and Corrective Repair Team Activities Actions To adequately support the On Shift: Not applicable SNC NLOs are trained and capable of providing electrical and SNCs proposed 90-elimination or extension of mechanical support for ECCS and other equipment repair. A primary minute augmentation the mechanical, electrical, Within 60 minutes of an point is that most likely, any equipment degradation that goes beyond responders are listed in and I/C technicians, the Alert or Greater, augment 1 the capability of an NLO couldnt be performed within 90 minutes Table 1 of the revised E2-10 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) licensee should show that electrician and 1 mechanic even if maintenance technicians were available. This is due to SNC Standard on-shift positions are to the OSC. actions that need to take place to allow effective maintenance to Emergency Plan in the identified as capable of occur safely (work order preparation, tagging, obtaining parts, etc.). LAR. SNC augments a filling these roles. The Within 90 minutes of an Work order planning is usually necessary to provide a basic work minimum of 50 total justification should Alert or Greater, augment 1 sequence, identify and obtain parts, etc. If parts from the warehouse responders. SNCs establish that the scope of I&C tech, and additional are needed, this would necessitate the assistance of supply chain proposed augmentation repair and corrective electricians and mechanics personnel, which would be called upon by the Shift Manager or by staff for this function actions performed by on- as needed to the OSC. the TSC after augmentation. meets the NRC guidance shift personnel would in the Revised Table B-1.

typically be limited to In direct response to the RIS guidance for this function, SNC actions that promptly reviewed all EOPs, AOPs, and supporting procedures to identify site-restore a non-functioning specific tasks that personnel need to perform in addition to their EP Because SNC uses All-component or system to duties to ensure expected execution of EOPs and support ECCS Call/All-Respond from an functional status (e.g. equipment. SNCs PBPA approach concluded that the 60-90 minute Alert, SNC can augment resetting a relay or logic responders were not necessary. this function with more manipulation) or place a personnel, as needed.

component or system in a On-shift operations personnel are focused on either preventing or desired configuration such mitigating accidents including trouble-shooting and performing limited Within 90 minutes, SNC as opening a valve or repairs and corrective actions that promptly restore a non-functional closing a breaker. NRC component or system to functional status (e.g., resetting a relay, augments a mechanic, staff will consider whether opening a valve or closing a breaker.) The priority is on stopping or and electrician, and an the licensee has identified limiting radioactive releases and maintaining or restoring equipment I/C technician to the TSC any site-specific tasks that needed for core cooling. who report to augmented these personnel need to Group Leads.

perform to ensure expected The minor repair/corrective actions intended in both the Revised execution of EOPs and Table B-1 and the RIS are performed by the NLOs consistent with support of ECCS EPIPs. Drills have shown that the on-shift maintenance staff is limited equipment. in what they are able to perform because most corrective maintenance necessitates a planned work order and a tagged Additionally, as part of the clearance boundary. The SNC analysis confirmed that the NLOs justification for an extension perform the essential first response duties of locating equipment, request, the licensee initial electrical/mechanical equipment diagnosis, such as opening should show that a cabinets, restoring power, restoring flow, etc. While on-shift radiological waste operator personnel would not be expected to perform a major repair of an E2-11 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) is not needed for the period ECCS pump in the first 90-minutes, they would be expected to of time to 90 minutes. promptly perform damage control efforts (e.g. stopping an air leak in a control line, resetting breakers remotely, taking manual control of a component locally, etc.) or promptly restore equipment function.

In conclusion, under the proposed staffing, which removes Maintenance personnel from on-shift, the SNC emergency response for this function is effective. Further, augmenting this position for the period from 60-90 minutes is not necessary.

Radiation Protection Radiation Protection Radiation protection On-Shift: Two RP In alignment with Revised Table B-1 guidance, SNC has proposed As part of this LAR personnel perform multiple Technicians two on-shift RP Technicians that perform the EP functions. supplement, SNC is roles during normal and 1) Provide qualified RP Additionally, SNC has determined that adequate coverage is proposing to add two emergency plant coverage for responders provided for the first 90-minutes. responders to the 48 operations. These roles accessing potentially proposed in the original include access control, unknown radiological 1) RP technicians are trained and qualified to provide coverage for LAR application. These personnel monitoring, and environments during troubleshooting/repair team actions where personnel may be two additional resources dosimetry, in addition to HP emergency conditions. accessing potentially unknown radiological environments. The will be RP Technicians.

coverage for repair and 2) Provide in-plant surveys approach was to look at procedure steps using the staffing studies corrective actions, search 3) Control dosimetry and and the PBPAs. This provides a baseline of actions and time for SNCs proposed 90-and rescue, first aid, and RCA access. each. What was identified is that for the first 90 minutes, RP work is minute augmentation firefighting during responders are listed in at the direction of the ED based on priorities. Both positions are emergency response Within 60 minutes of an Table 1 of the revised available to perform functions such as support for operations. Per the Alert or Greater, augment 3 SNC Standard guidance in Table B-1 of RP technicians in addition troubleshooting/repair teams, and radiological surveys (both inside Emergency Plan in the NUREG-0654, there should to personnel on shift to the the plant and within the Protected Area). Drills demonstrate that two LAR. SNC augments a be two augmented OSC. RP technicians can be successful in implementing the EDs priorities, minimum of 50 total responders at 60 minutes including various duties that could arise, such as, supporting responders. SNCs for the major task of Within 90 minutes of an movement of security personnel due to radioactive release via 10 proposed augmentation Radiation Protection. To Alert or Greater, augment 3 CFR 50.54(x) and (y). staff for this function adequately support an more RP technicians to the meets the NRC guidance extension in response OSC. (6 augmented RP in the Revised Table B-1.

E2-12 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) timing of the two radiation responders plus the 2 on- 2) RP technicians are trained and qualified to perform in-plant Because SNC uses All-protection 60-minute shift for a total of 8) surveys in support of tasks established by the ED based on the Call/All-Respond from an responders to 90 minutes, emergency. RP takes surveys during their support of Alert, SNC can augment the licensee should show troubleshooting/repair teams. The data is compiled when the teams this function with more that the on-shift HP staffing return. Using the staffing studies and PBPAs, the first 30 minutes or personnel, as needed.

includes as a minimum, so of an event is focused on the classification, notification and if four HP technicians in total needed PAR determination. The ED then evaluates the plant systems for the site. The extra HP and establishes priorities for the team. RP support of those priorities Within 90 minutes, SNC technicians are needed for is unchanged. Surveys will be performed to support either dose augments with 6 RP in-plant protective actions assessment (for unmonitored releases), troubleshooting/repair team technicians added to the for the other personnel support or to evaluate on-site protective actions due to radioactive 2 on-shift RP technicians added to the on-shift plume effects on station staff. The current practice of dispatching for a total of 8.

staffing to compensate for FMT 1 to the site boundary has indicated that even with a rapidly the extension in progressing event either the release is just starting or the augmented augmentation time, and to staff has arrived in 90 minutes. The RP tasks needed to support the assess any off-site releases event has typically been to support troubleshooting activities and of radioactive materials. inform the ED of survey results to assist with establishing repair Additionally, the licensee priorities.

request should demonstrate that on-shift 3) The 2 RP technicians on-shift are trained and qualified to issue HP technicians will be dosimetry, establish RWP requirements, develop dose extension relieved of the need to documents for ED approval, brief individuals on KI and provide perform access control, documentation to the ED for its issuance. None of these functions are personnel monitoring, and adversely impacted by shifting an on-shift RP to the expanded dosimetry-related tasks, augmented staffing. As stated previously, currently 2 RPs provide thereby freeing these these functions with no adverse impact on emergency response.

personnel to cover vital response activities (e.g., SNCs analysis shows that the 2 on-shift RP technicians will follow HP coverage for repair and the priorities set by the ED and can perform their functions effectively corrective actions, search for the first 90 minutes, and SNC has determined that the three 60-and rescue, first aid, and minute responders are not necessary during the interim time from 60-firefighting). NRC staff will 90 minutes.

consider whether the basis for the justification includes E2-13 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) the availability of installed area, process, airborne and effluent radiation monitors, automated systems and information technology solutions, and enhanced work processes. The licensee should include supporting tools and processes that will be considered such as portal monitors, self-alarming dosimeters, and automated access control systems for the RCA that maintain Supervision of Radiation active radiation work Protection permits that are readily On-Shift: The Operations In alignment with Revised Table B-1 guidance, SNC has proposed SNCs proposed 90-available if an emergency is Shift Manager supervises on-shift RP supervision by the Operations Shift Manager who minute augmentation declared (e.g., the system RP as follows: performs the EP functions. SNC has also determined that the SM responders are listed in verifies qualifications, dose 1) Evaluate and assess can effectively direct qualified RP technicians provide for the first 90- Table 1 of the revised margins, and access plant and offsite radiological minutes, until relieved. SNC Standard requirement). See guidance data in the development of Emergency Plan in the provided above under onsite protective actions 1) Onsite protective measures have not changed in the LAR. They LAR. SNC augments a Considerations of the and offsite PARs, until are based on RP input to the Emergency Director who evaluates the minimum of 50 total Review Process for relieved. need for protective action recommended by RP. Procedure driven responders. SNCs Proposed Extensions of 2) Recommend onsite and actions for EOPs and AOPs are accounted for in the PBPA which proposed augmentation NUREG-0654, Table B offsite PARs to the supplements the staffing studies so both procedurally driven actions staff for this function 30-Minute ERO applicable decision-maker, and emergency preparedness actions are performed concurrently. meets the NRC guidance Augmentation Times to 60 until relieved. PARs are one of the Risk Significant Planning Standards and are in the Revised Table B-1.

Minutes. 3) Direct all radiation addressed in the staffing studies. However, should classification at protection activities, the General Emergency level be required during the period of the including field team proposed, additional augmentation time (60 to 90 minutes), the ED Because SNC uses All-direction, until relieved. will perform the actions as they would on initial classifications. The Call/All-Respond from an

4) Provide relevant initial General Emergency declaration would use a plant-based PAR Alert, SNC can augment E2-14 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) information to applicable using wind speed and direction. If a release is in progress, a follow- this function with more communicators who are up PAR would be evaluated and promptly communicated to the personnel, as needed.

communicating offsite OROs per the EPIPs.

protective actions to offsite 2) The ED determines the on-site protective actions as well as the In the TSC, within 90 agencies, until relieved. off-site PARs based on input, as appropriate, from on-shift RP minutes, SNC augments technicians and the dose analyst rather than an SRPC from 60-90 with an RP Supervisor.

Within 60 minutes of an minutes.

Alert or Greater, augment 1 3) The need for on-site out-of-plant surveys are determined and In the OSC, within 90 Site RP Coordinator to the prioritized by the ED based on the nature of the event. One of the two minutes, SNC augments TSC. RPs on-shift will use existing vehicles and/or equipment to perform with an RP/Chemistry tasks in support of either on-site protective action determinations or Group Lead.

Within 60 minutes of a Site for direct radiation readings to support dose assessment during an Area Emergency or unmonitored release as determined by the dedicated Chemistry dose In the EOF, within 90 Greater, augment 1 RP assessor. minutes, SNC augments Manager to the EOF. 4) The ED is and continues to be the focal point for the flow of with a Dose Assessment information between the site and various offsite organizations via Supervisor, Dose Analyst, defined bridge lines. The communication of PARs and providing FMT Coordinator and an information to OROs including the NRC remains the same process as FMT Communicator.

currently described in the Emergency Plan. The individuals that perform those actions remain the same in both number and training/qualification.

SNCs analysis shows that the on-shift ED can supervise the qualified RP technicians effectively for the first 90 minutes, and SNC has determined that an augmented SRPC and RP Manager is not necessary during the interim time from 60-90 minutes.

Off-site Surveys / On-site Field Monitoring Teams (out-of-plant) / In-Plant (FMTs)

Surveys Per the guidance of On-Shift: Not Applicable SNC has evaluated the Field Monitoring Team function described in SNCs proposed 90-NUREG-0654, Table B-1, the Revised Table B-1 and has proposed a slightly different alternate minute augmentation there should be four Within 60 minutes of an strategy. responders are listed in augmented responders at Alert or Greater, augment 1 First, augmentation of on-shift personnel with two Field Monitoring Table 1 of the revised 60 minutestwo for off-site Teams will be at 90 minutes rather than one at 60 and the other at 90 SNC Standard E2-15 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) surveys, one for on-site RP Tech for Onsite FMT minutes. Second, a dedicated on-site out-of-plant FMT will not be Emergency Plan in the surveys, and one for in- and 1 driver. used, but rather SNC will use one of the two on-shift RP Technicians LAR. SNC augments a plant surveys. To for this function as directed by the ED based on priorities for the 60- minimum of 50 total adequately support an Within 60 minutes of an 90 minute interim time period. responders. SNCs extension of these Alert or Greater, augment 1 proposed augmentation responders to 90 minutes, qualified individual for Under the proposed SNC strategy, at 90 minutes, two FMTs will be staff for this function the licensee should show Offsite FMT Team A and 1 available. Each FMT has one qualified individual to perform surveys differs slightly from the that the on-shift HP staffing driver. and an assistant (driver). The FMT Coordinator, with assistance by NRC guidance in the includes a minimum of four an FMT Communicator, in the EOF deploys the FMTs such that one Revised Table B-1.

HP technicians in total for Within 90 minutes of an team is stationed at the site boundary in the path of the radioactive However, because SNC the site. The licensee Alert or Greater, augment 1 plume based on wind direction. The second FMT is deployed uses All-Call/All-Respond should demonstrate that qualified individual for downwind from the FMT stationed at the site boundary. The location from an Alert, SNC can two HP technicians, in Offsite FMT Team B and 1 varies based on wind speed, but generally the location is 1 - 2 miles augment this function excess of the number driver. from the site boundary. This ensures conditions are identified that with more personnel, as evaluated previously for may exceed EAL thresholds (e.g. 1 Rem TEDE and/or 5 Rem CEDE needed.

extending the 30-minute at the site boundary).

responders, are available SNCs approach is based for in-plant protective For on-site surveys, an RP on-shift is sent by the ED to the Protected on two sets of FMTs (2 actions for the other Area boundary for dose readings or other on-site out-of-plant surveys qualified individuals with maintenance personnel that when required based on priorities. A driver is not needed because the assistants for a total of 4) need to be added to the on- RP technician does not take readings while driving in the Protected augmented and deployed shift staffing to compensate Area. Rather, the RP technician drives to the desired location, based as described. SNC uses for the extension in on wind direction, and then takes the readings. Thus, a 100%

an on-shift RP technician augmentation time for the dedicated on-site, out-of-plant FMT is not needed at 60 minutes.

for onsite surveys in major task of Repair and When augmentation is completed and the FMT function is turned Corrective Actions, and to over to the EOF, the on-shift RP technician is released to the OSC, accordance with the EDs perform surveys to assess when activated. This resource can then support other priorities direction and priorities as any off-site release of established by the TSC ED. described.

radioactive materials.

Licensees may consider Full augmentation of RP technicians provides adequate resources to alternative approaches for perform assessment of radiation and contamination in support of staffing this functional area troubleshooting, repair teams, in-plant and out-of-plant surveys, and by training non-HP the remainder of RP functions per the SEP. SNC has concluded that personnel to perform these providing one offsite FMT for the period from 60-90 minutes is not E2-16 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) survey tasks. See guidance necessary. The EP functions identified in Revised Table B-1 continue provided above under to be met with the proposed changes without adverse impact on the Considerations of the SEP or the general public.

Review Process for Proposed Extensions of NUREG-0654, Table B-1 30-Minute ERO Augmentation Times to 60 Minutes.

Security The Security Plans for each station are aligned with the Standard Within 90-minutes, the Emergency Plan to provide a Security Supervisor on-shift. The duties Security Supervisor On-Shift: Staff per the site- remain the same as does the interface with the on-shift Emergency reports to the TSC. The specific security plan. Director. Duties during the additional augmentation time from 60-90 Security Supervisors minutes are consistent with those starting at the beginning of a duties do not change.

Within 60 minutes of an declared event. The approach for this position remains unchanged Alert or Greater, augment 1 from the existing version of the Emergency Plan. The on-shift security liaison to the TSC Security Supervisor reports to the on-shift Emergency Director and to coordinate security- then reports to TSC to continue the duties during turnover of related activities and Command and Control to the TSC Emergency Director. The duties information to the are the same including determining security plan compliance and Emergency Coordinator. compensatory actions due to plant or barrier damage. Movement of security resources due to radiological conditions, possible dose extensions or consumption of KI are discussed with on-shift RP and the ED. Decisions are provided and subsequently implemented by on-shift RP (for completion of dose extensions or issuance of KI) with approval of the ED. Movement of security is performed either in accordance with the Security Plan or under 10 CFR 50.54(x) and (y).

The ED completes the X and Y documentation per SNC procedures and the Security Supervisor directs Security resources to the appropriate locations. Hostile Action based events remain unchanged. In a Hostile Action based event, the Augmented ERO may not be able to access the site within the required augmentation time. Many if not all the processes/tools in place for that type of event E2-17 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018)

(i.e. communication, remote on-shift staff support, access to plant information for troubleshooting, etc.) will also be available for non-Hostile Action based emergency declarations.

Media Information On-Shift: Not Applicable The SNC SEP states that after the initial notification of an emergency Within 90 minutes, SNC at the Alert classification or higher, the Public Information Director will augments a news writer Within 60 minutes, of an coordinate with the EOF Emergency Director and affected OROs and to the EOF.

Alert or Greater, staff to determine whether to staff the JIC.

address media inquiries. Because SNC uses All-SNC has improved public communication such that within minutes Call/All-Respond from an Within 60 minutes, of an after a classification, the SNC media personnel can provide Alert, SNC can augment Site Area Emergency or information to the public. SNC continues to follow the existing this function as needed.

Greater, staff to perform Standard Emergency Plan. Pre-planned and drafted media releases JIC-related tasks. support quick dissemination of information to the public. SNC currently uses a JIS approach to media and will continue to under this proposed LAR and provide media information within 60 minutes of an Alert or higher.

Therefore, SNC concludes that augmenting JIC staff during the period from 60-90 minutes is not necessary.

Information Technology If emergency plan functions SNC has IT support staff on the all-call/all-respond list. Therefore, IT Because SNC has IT rely on computer-based Support is available if problems arise with the computer equipment in personnel on its all call/all equipment, provide IT the ERFs. respond list from an Alert, support. SNC can augment this The EOF Manager and TSC Manager are responsible to maintain the function as needed.

On-Shift: Not Applicable facility equipment including computer equipment. In addition, SNCs ERO team members have the basic computer skills necessary to Within 90 minutes, SNC Within 90 minutes of an troubleshoot most problems that arise. Issues requiring additional augments an EOF Alert or Greater, augment skill are addressed through the SNC IT call-in process. Manager and TSC E2-18 to NL-20-0908 SNC Response to NRC Request for Supplemental Information SNC Supplemental Analysis Table RIS 2016-10 NUREG 0654 Revised 90-minute (Based on Table B-1 On-shift performance until Augmented augmentation NUREG 0654 Rev 1 Guidance (TSC, OSC, EOF) guidance) (June 12, 2018) with a qualified individual to Manager who are ensure IT equipment is SNC has concluded that augmenting a specific IT individual to the responsible for operable in the TSC. TSC and EOF is not necessary because SNC IT support personnel maintaining the computer have an on-call support staff that responds to critical IT needs equipment operable.

Within 60 minutes of a Site company-wide. The IT on-call team is supplemental to the SNC Area Emergency or ERO, but is available to the ERO as needed.

Greater, augment with a qualified individual to ensure IT equipment is operable in the EOF.

E2-19

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 License Amendment Request to Revise Standard Emergency Plan To Change Staffing and Extend Augmentation Times Enclosure 3 SNC Standard Emergency Plan Revised Table 1 to NL 20-0908 SNC Response to NRC Request for Supplemental Information Augmented Major Functional Responders Major Task Position Title Area 90 min Emergency Emergency Director (TSC) 1 Direction and Command and Control Control Emergency Director (EOF) 1 Emergency Communication Coordinator (EOF)

Notification/ Licensee, Local/State and ENS Communicator (EOF & TSC) 7 Communication Federal communications ENN Communicator (EOF)

ERF Communicators (OSC, TSC, & EOF)

RP Supervisor (TSC) 1 Offsite Dose Assessment Dose Assessment Supv. & Analyst (EOF) 2 HPN Communicators (EOF & TSC) 2 Radiation Protection FMT Lead and Assistant (OSC) (two each) 4 Actions and Offsite Surveys FMT Coordinator and Communicator (EOF) 2 Supervision In-plant / Onsite (out-of- RP/Chemistry Group Lead (OSC) plant) Surveys Dosimetry 8 RP Technicians (OSC) 9

/ Access Control (6 augmented and 2 from on-shift)

Engineering/Tech Supervisor (TSC & EOF) 2 Engineering Technical Support Reactor Engineer (TSC) 1 Engineering Support (TSC) 2 ERF Manager (OSC/TSC/EOF) 3 Mechanical Group Lead and Tech (OSC) 2 Electrical Group Lead and Tech (OSC) 2 Maintenance, and Repair and Corrective I & C Group Lead and Tech (OSC) 2 Other Support Actions Operations Group Lead/Supv. (OSC & TSC) 2 Security Supervisor/Coordinator (TSC & EOF) 2 Maintenance Supervisor (TSC) 1 ORO Coordinator and News Writer (EOF) 2 Total 50 Table 1 30 E3-1