ML21060B432
| ML21060B432 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 05/19/2021 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Gayheart C Southern Nuclear Operating Co |
| Lamb J | |
| References | |
| EPID L-2020-LLA-0150, EPID L-2020-LLA-0151 | |
| Download: ML21060B432 (30) | |
Text
May 19, 2021 Ms. Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2; EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2; AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 - AUDIT
SUMMARY
REPORT FOR REVISION TO EMERGENCY PLAN TO CHANGE STAFFING AND EXTEND STAFF AUGMENTATION TIMES FOR EMERGENCY RESPONSE ORGANIZATION POSITIONS (EPID L-2020-LLA-0150 AND L-2020-LLA-0151)
Dear Ms. Gayheart:
By letter dated June 30, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20192A140), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for the Joseph M. Farley Nuclear Plant, Units 1 and 2; Edwin I. Hatch Nuclear Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 (SNC fleet). The proposed LAR would revise the SNC Standard Emergency Plan (SEP), including the site annexes, to change the emergency response organization (ERO) staffing composition and extend staff augmentation time from 75 to 90 minutes.
By letter dated July 23, 2020 (ADAMS Accession No. ML20202A017), the U.S. Nuclear Regulatory Commission (NRC) staff concluded that SNCs LAR did not provide technical information in sufficient detail to enable the NRC staff to complete its detailed review and make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements for the protection of public health and safety and the environment. The NRC staff requested SNC to supplement the application to address the identified insufficiencies.
On July 30, 2020, a Category 1 public meeting was held between the NRC and representatives of SNC, (NRC Public Meeting Summary, ADAMS Accession No. ML20217L369). The purpose of the meeting was to clarify the NRC letter dated July 23, 2020, regarding the SNC fleet ERO staffing LAR.
By letter dated August 11, 2020 (ADAMS Accession No. ML20224A464), SNC provided a supplement to its LAR.
By e-mail dated September 1, 2020 (ADAMS Accession No. ML20245E284), the NRC staff accepted the LAR for review.
By e-mail dated October 14, 2020 (ADAMS Accession No. ML20293A075), the NRC staff provided a request for additional information (RAI).
On November 12, 2020, a Category 1 public meeting was held between the NRC staff and representatives of SNC, (NRC Public Meeting Summary, ADAMS Accession No. ML20318A075), to clarify any questions from SNC.
By letter dated November 20, 2020 (ADAMS Accession No. ML20325A219), SNC provided responses to the RAI.
After careful review, the NRC staff has determined that an audit was needed to review the proposed LAR justification supporting revision to the SNC SEP and to determine additional information that may need to be docketed for the NRC to complete its review. This includes the site annexes, to change the ERO staffing composition and extend staff augmentation time from 75 to 90 minutes.
By letter dated February 24, 2021 (ADAMS Accession No. ML20342A018), the NRC staff issued the Audit Plan.
On March 15, April 1, 12, 19, and 29, 2021, the NRC staff conducted an audit in accordance with the Audit Plan.
Attached is the Audit Summary Report.
If you have any questions, please contact me at 301-415-3100.
Sincerely,
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321, 50-366, 50-348, 50-364, 50-424, 50-425,52-025, and 52-026
Enclosure:
Audit Report cc: Listserv
Enclosure AUDIT
SUMMARY
REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR REVISION TO EMERGENCY PLAN TO CHANGE STAFFING AND EXTEND STAFF AUGMENTATION TIMES FOR EMERGENCY RESPONSE ORGANIZATION POSITIONS JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 DOCKET NOS. 50-348, 50-364, 50-321, 50-366, 50-424, 50-425,52-025, AND 52-026
1.0 BACKGROUND
By letter dated June 30, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20192A140), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for the Joseph M. Farley Nuclear Plant, Units 1 and 2; Edwin I. Hatch Nuclear Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 (SNC fleet). The proposed LAR would revise the SNC Standard Emergency Plan (SEP), including the site annexes, to change the emergency response organization (ERO) staffing composition and extend staff augmentation time from 75 to 90 minutes.
By letter dated July 23, 2020 (ADAMS Accession No. ML20202A017), the U.S. Nuclear Regulatory Commission (NRC) staff concluded that SNCs LAR did not provide technical information in sufficient detail to enable the NRC staff to complete its detailed review and make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements for the protection of public health and safety and the environment. The NRC staff requested SNC to supplement the application to address the identified insufficiencies.
On July 30, 2020, a Category 1 public meeting was held between the NRC and representatives of SNC, (NRC Public Meeting Summary, ADAMS Accession No. ML20217L369). The purpose of the meeting was to clarify the NRC letter dated July 23, 2020, regarding the SNC fleet ERO staffing LAR.
By letter dated August 11, 2020 (ADAMS Accession No. ML20224A464), SNC provided a supplement to its LAR.
By e-mail dated September 1, 2020 (ADAMS Accession No. ML20245E284), the NRC staff accepted the LAR for review.
By e-mail dated October 14, 2020 (ADAMS Accession No. ML20293A075), the NRC staff provided a request for additional information (RAI).
On November 12, 2020, a Category 1 public meeting was held between the NRC staff and representatives of SNC (NRC Public Meeting Summary, ADAMS Accession No. ML20318A075), to clarify any questions from SNC.
By letter dated November 20, 2020 (ADAMS Accession No. ML20325A219), SNC provided responses to the RAI.
After careful review, the NRC staff has determined that an audit was needed to review the proposed LAR justification supporting revision to the SNC SEP and to determine additional information that may need to be docketed for the NRC to complete its review. This includes the site annexes, to change the ERO staffing composition and extend staff augmentation time from 75 to 90 minutes.
2.0 SCOPE AND PURPOSE By letter dated February 24, 2021 (ADAMS Accession No. ML20342A018), the NRC staff issued the audit plan to review the proposed LAR to revise the SNC SEP, including the site annexes, to change the ERO staffing composition and extend staff augmentation times from 75 to 90 minutes. On March 15, April 1, 12, 19, and 29, 2021, the NRC staff conducted the audit in accordance with the Audit Plan.
3.0 AUDIT TEAM The audit team consisted of Mr. John Lamb, Senior Project Manager for Hatch, Units 1 and 2; and Vogtle, Units 1 and 2, in the Office of Nuclear Reactor Regulation; Mr. Mike Norris, Senior Emergency Plan (EP) Specialist in the Office of Nuclear Security and Incident Response (NSIR); and Mr. Ray Hoffman, EP Specialist in NSIR.
4.0 AUDIT REPORT During the audit, the licensee presented information on the audit items listed in Section 4.0 of the audit plan (ADAMS Accession No. ML20342A018). The licensee also established an online portal and placed supporting information in the portal on each audit item. Section 5.0 of this audit report lists the documents and files the NRC staff reviewed. The NRC staff discussed with the licensee each audit item and made relevant observations contained in Attachments 1 through 3.
The emergency preparedness functions discussed during the audit were (1) command and control, (2) communications, (3) maintenance, (4) engineering, (5) radiation protection (RP), and (6) dose assessment.
Item 1 - Command and Control Function The NRC asked SNC to provide the following:
Provide information that supports the capability to provide timely augmentation to the Command and Control function.
Provide the qualification and training requirements for SNCs Shift Managers/Emergency Directors (ED) to implement SNC event response procedures. This information would include both the capabilities/responsibilities of a Shift Manager and of a ED. This information should provide justification for the proposed changes to Shift Manager/ED ERO augmentation timing.
Provide information related to drills and/or exercises that were supported by only the Shift Manager for 75 minutes from the declaration of an Alert or greater emergency classification level (ECL) and for similar drills and/or exercises where an Emergency Director/Manager arrived before 75 minutes so that a direct comparison of emergency response can be made.
Item 2 - Communications Function The NRC asked SNC to provide the following:
Provide information to show how SNC licensed operators could concurrently meet the requirements of a licensed operator pursuant to 10 CFR 50.54(m)(2) and the Communications function as required by 10 CFR 50.47(b)(2).
Provide information related to drills and/or exercises that were supported by only licensed operators as on-shift communicators for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where augmenting communicators arrived before 75 minutes so that a direct comparison of emergency response can be made.
Provide licensed operator initial and requalification evaluated scenarios where either the licensed or senior licensed operator performed their licensed operator responsibilities concurrently with performing the ERO communication function.
Item 3 - Maintenance Function The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine how SNC licensed operators could concurrently implement event response procedures which would include emergency operating procedures, the emergency plan and related implementing procedures, and communication responsibilities while providing electrical and mechanical support for emergency core cooling system equipment, event mitigation, and equipment repair. Note: This information should address both maintenance technicians and maintenance supervisor capabilities.
Procedures and related qualifications for SNCs version of Fix-It-Now (FIN) maintenance and its troubleshooting procedures.
Evaluated scenarios where the SNC crew demonstrated the capabilities to perform troubleshooting, as provided in the SNC maintenance procedures, without assistance from the maintenance or engineering organizations.
Item 4 - Engineering Function The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Engineering. Note: This information should include addressing the unique SNC shift technical advisor (STA) method of providing on-shift STA expertise and not an individual dedicated to performing the STA function.
Provide information related to drills and/or exercises that were supported by only licensed operators as on-shift engineering staff for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where engineering staff arrived before 75 minutes so that a direct comparison of emergency response can be made.
Item 5 - Radiation Protection Function The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Radiation Protection (RP). Note: SNC includes field monitoring, supervision of radiation protection, and radiation protection actions in one Major Functional Area.
Provide information related to drills and/or exercises that were supported by only the three Radiation Protection Technicians for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where radiation protection support arrived before 75 minutes so that a direct comparison of emergency response can be made.
Item 6 - Dose Assessment Function The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Dose Assessment. Specifically, explain how the on-shift chemistry technician, or other trained individual, can provide equivalent dose assessment information as the augmenting ERO for an additional 15 minutes.
Note: The augmenting ERO includes a RP Supervisor at the Technical Support Center (TSC) and two Dose Assessment Supervisor & Analysts at the Emergency Operations Facility (EOF) which appear to have additional dose assessment capability.
5.0 DOCUMENTS AND FILES REVIEWED In addition to the discussions of each audit item, the NRC staff reviewed the following documents and files:
No.
Document/File Document Title/File Description Revision/Date Need on Docket?
1 pdf Farley [Site Emergency Plan Validation]
3/22/2017 No 2
pdf Farley [Drill/Exercise]
12/14/2017 No No.
Document/File Document Title/File Description Revision/Date Need on Docket?
3 pdf Hatch [Drill/Exercise]
4/24/2018 No 4
pdf Farley [Drill/Exercise]
6/19/2018 No 5
pdf Hatch [Drill/Exercise]
6/19/2018 No 6
pdf Farley [Drill/Exercise]
8/14/2018 No 7
pdf Hatch [Drill/Exercise]
9/18/2018 No 8
pdf Farley [Drill/Exercise]
10/30/2018 No 9
pdf Farley [Drill/Exercise]
12/12/2018 No 10 pdf Vogtle [Drill/Exercise]
2/26/2019 No 11 pdf Vogtle [Drill/Exercise]
5/21/2019 No 12 pdf Farley [Drill/Exercise]
6/15/2019 No 13 pdf Hatch [Drill/Exercise]
9/17/2019 No 14 pdf Hatch [Drill/Exercise]
10/22/2019 No 15 pdf Farley [Drill/Exercise]
11/5/2019 No 16 pdf Vogtle [Drill/Exercise]
11/4/2020 No 17 pdf ERO Staffing License Amendment Request (LAR)
Analytical Data - Vogtle 1-2
[VEGP 1&2 ERO Staffing LAR Analysis]
N/A No 18 pdf ERO Staffing LAR Analytical Data - Farley 1-2 [FNP 1&2 ERO Staffing LAR Analysis]
N/A No 19 pdf ERO Staffing LAR Analytical Data - Hatch 1-2 [HNP 1&2 ERO Staffing LAR Analysis]
N/A No 20 N/A Farley 20-05 as found
[Operations Training Simulator Exam Scenario]
N/A No No.
Document/File Document Title/File Description Revision/Date Need on Docket?
21 pdf Farley Non-Licensed Operator (NLO) OPS-40401.2
- Rover Qual Card [J. M.
Farley NPO (Nuclear Plant Operator) System Operator (SO) Initial Training Program, Rover Qual Card OPS-40401.2 10/28/2009 No 22 pdf Farley NLO OPS-40401.4 DB
[Diesel Building] Qual Card.]
[J. M. Farley NPO SO Initial Training Program, Diesel Building Qual Card OPS-40401.4]
10/23/2009 No 23 pdf Farley NLO Miscellaneous items qual - OPS-40401.7 Miscellaneous QCM [J. M.
Farley NPO SO Initial Training Program, Miscellaneous Qual Card OPS-40401.7 10/23/2009 No 24 pdf JFG CR ED S-EP-JF-101 v4
[Job Familiarization Guide for the Control Room Emergency Director, Version 4.0 N/A No 25 NMP-AD-002-F04 Troubleshooting or troubleshooting log 6/26/2020 No 26 NMP-AD-002 Troubleshooting or troubleshooting log 6/30/2020 No 27 NMP-EP-003 WebEOC Set Up and Use, version 12.0 6/20/2019 No 28 NMP-EP-141 Event Classification Procedure, version 2.1 8/23/2019 No 29 NMP-EP-145 Termination and Recovery Procedure, version 2.0 8/12/2019 No 30 NMP-EP-146 Emergency Response Organization (ERO),
version 4.0 2/10/2021 No No.
Document/File Document Title/File Description Revision/Date Need on Docket?
31 NMP-EP-146-F01 Control Room (CR)
Emergency Director, version 4.2 12/16/2020 No 32 NMP-EP-146-F03 CR Emergency Notification System (ENS) Communicator Checklist, version 1.0 3/4/2021 No 33 NMP-EP-146-F06 Emergency Operations Facility (EOF) Dose Analyst checklist, Version 4.0 3/4/2021 No 34 NMP-EP-146-F07 EOF Dose Assessment Supervisor checklist, Version 5.0 3/4/2021 No 35 NMP-EP-146-F43 Technical Support Center (TSC) RP Supervisor Checklist, Version 4.0 3/4/2021 No 36 NMP-EP-147 Offsite Dose Assessment Automated MIDAS Procedure, version 4.0 1/27/2020 No 37 NMP-EP-313 Emergency Preparedness Policies and Interpretations, version 4.0 5/19/2020 No 38 NMP-MA-012-GL03 Maintenance Fundamentals N/A No 39 NMP-MA-052 Repair/Replacement Program Procedure, version 4.0 10/13/2020 No 40 NMP-MA-055 Conduct of Fix-It-Now (FIN)
Procedure, version 2.1 4/7/2020 No 41 NMP-TR-420 Shift Manager and Shift Supervisor Qualification Program, Version 11 1/7/2021 No 42 NMP-TR-421 Shift Technical Advisor (STA)
Qualification Program N/A No 43 NMP-TR-421-FO1 STA Qualification Checklist N/A No 44 NMP-TR-421-FO3 Vogtle STA Qualification Checklist, Version 3.1 6/25/202 No No.
Document/File Document Title/File Description Revision/Date Need on Docket?
45 NMP-TR-421-FO3 Hatch STA Qualification Checklist, Version 1.2 N/A No 46 NMP-TR-421-FO2 Farley STA Qualification Checklist, Version 1.1 N/A No 47 S-EP-PP-10101 Classification-Emergency Action Levels (EALs) Version 2, Emergency Classification PowerPoint Training Slides 5/16/2019 No 48 S-EP-PP-10201 Protective Action Recommendations, Version 2, Emergency Classification PowerPoint Training Slides 5/16/2019 No 49 S-EP-PP-10301 Facility Activation Approved Emergency Response Facility (ERF) Overview PowerPoint Training Slides 4/19/2019 No 50 S-EP-PP-10501-2.0 Emergency Exposure PowerPoint Training Slides N/A No 51 S-EP-PP-10601 Emergency Notification Lesson Plan, version 2.0 4/18/2019 No 52 NMP-TR-421 Shift Technical Advisor (STA)
Qualification Program N/A No 53 NMP-TR-421-FO1 Shift Technical Advisor (STA)
Qualification Checklist N/A No 54 S-EP-PP-11301 Offsite Organization Overview, SNC Lesson Plan 4/2019 No 55 S-EP-PP-11401 Emergency Preparedness Overview, Version 3, SNC Lesson Plan 5/9/2019 and 5/16/2019 No 56 NMP-EP-313, Version 4 Emergency Preparedness Policies and Interpretations 5/19/2020 No 57 SGTR OSA Steam Generator Tube Rupture (SGTR) OSA provided N/A No No.
Document/File Document Title/File Description Revision/Date Need on Docket?
58 NMP-TR-420, Version 11 Shift Manager and Shift Supervisor Qualification Program 1/7/2021 No 59 S-EP-PP-10101, Version 2 Classification-EALS Emergency Classification PowerPoint Training Slides 5/16/2019 No 60 Vogtle 1_2 V-SO-JP-51010-006, Revision 2.2 Locate fuses in a Termination Cabinet Vogtle Non-License Operator (NLO) Job Performance Measure (JPM) 1/31/2013 No 61 Vogtle 1_2 V-SO-JP-13145-004 Locally Emergency Start the Diesel Generator, Vogtle Non-Licensed Operator (NLO)
Job Performance Measure (JPM), Revision 7.2 1/31/2013 No 62 Vogtle 1_2 V-SO-JP-51010-006 Locate fuses in a Termination Cabinet, Vogtle Non-Licensed Operator (NLO) Job Performance Measure (JPM),
Revision 2.2 1/31/2013 No 63 Vogtle 3_4 AP-NL-Q Vogtle 3-4 Qualification Card for Basic SO Skills, Version 1.3 N/A No 64 NMP-EP-143 Main Procedure, Facility Activation, Version 1.0 6/28/2017 No 65 NMP-EP-143-F08 Team Tracking briefing sheet, In-Plant Team Tracking Form, Version 4.0 9/16/2020 No 66 NMP-EP-143-F09 Priorities, Task Priority Chart, Version 2.0 9/24/2019 No 67 NMP-EP-143-F14 Deviations from Normal Processes, Deviation from Normal Work Processes, Version 2.0 9/14/2019 No No.
Document/File Document Title/File Description Revision/Date Need on Docket?
68 NMP-OS-019-121 FNP FLEX RCS inventory, Farley Unit 2 FSG-1, Long Term RCS Inventory Control, Version 2.0 2/13/2019 No 69 NMP-OS-019-263 HNP FLEX Rx vessel inventory, Hatch Unit 1 SIG-3, Core Cooling, Version 3.0 5/30/2019 No 70 NMP-OS-019-321 VEGP 1-2 FLEX Reactor Core System (RCS) inventory, Vogtle Unit 2 FSG-1, Long Term RCS Inventory Control, Version 1.0 11/19/2015 No 71 S-EP-JF-106 V4 EOF Dose Analyst, Job Familiarization Guide (JFG) for the Emergency Operations Facility Dose Analyst, Version 4.0 N/A No 72 S-EP-JF-132 V3 On-Shift Dose Analyst, JFG for the On-Shift Dose Analyst, Version 3.0 N/A No 73 S-EP-PP-10701 Dose Assessment, Dose Assessment Lesson Plan, Version 2.0 5/31/2019 No 74 S-EP-PP-10702 Enhanced Dose Assessment
- Automated MIDAS, Dose Assessment/MIDAS Lesson Plan, Version 2.0 5/31/2019 No
6.0 CONCLUSION
As a result of the audit, the NRC staff has gained a better understanding of the following functions: (1) command and control, (2) communications, (3) maintenance, (4) engineering, (5) radiation protection (RP), and (6) dose assessment.
SNC supplemented the application by letter dated April 27, 2021 (ADAMS Accession No. ML21117A351).
In accordance with LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ADAMS Accession No. ML19226A274), it states:
The regulatory audit summary report should be placed on the docket and in ADAMS within 90 days of the completion of the audit or before the regulatory action that the audit supports is completed, whichever is shorter.
The audit was closed out on April 29, 2021, and the 90-day deadline for the audit summary report is July 28, 2021.
ATTACHMENT 1 AUDIT DAY 1 - MONDAY, MARCH 15, 2021 Attendees NAME ORGANIZATION John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Michael Norris NRC Raymond Hoffman NRC Michael Markley NRC Caroline Carusone NRC Joseph Anderson NRC Jessie Quichocho NRC Ernest Bates Southern Nuclear Operating Company (SNC)
Justin Wheat SNC Shannon Smelley SNC Jamie Coleman SNC Cheryl Gayheart SNC Ken Lowery SNC Liz Williford SNC Marvin Warren SNC Rick Collins SNC Summary The audit commenced with the above attendees. The U. S. Nuclear Regulatory Commission (NRC) staff provided background information related to how the review came to an audit, after Southern Nuclear Operating Companys (SNCs) response to the request for additional information (RAI), dated November 20, 2020. The SNC RAI response did not sufficiently address the identified regulatory gaps that the NRC staff needed to complete its review; therefore, the NRC staff determined that an audit was needed to review the proposed license amendment request (LAR) justification supporting revision to the SNC Standard Emergency Plan (SEP) and to determine additional information that may need to be docketed for the NRC to complete its review. This includes the site annexes, to change the emergency response organization (ERO) staffing composition and extend staff augmentation time from 75 to 90 minutes.
For the duration of the audit, SNC and the NRC used Microsoft Teams and the video/audio communications of choice.
On March 5, 2021, SNC provided a link to a Certrex portal for the NRC staff to review SNC documents. SNC made approximately 85 documents available for NRC staff review. There was no discussion or roadmap provided that summarized how the 85 documents addressed the questions posed to SNC in the Audit Plan. The NRC staff reviewed approximately half of the SNC documents before the start of the audit, but gaps remain as described in Section 4 of the Audit Plan.
The NRC staff referred to Section 4 of the Audit Plan. The functions of Section 4 of the Audit Plan are (1) command and control, (2) communications, (3) maintenance, (4) engineering, (5) radiation protection, and (6) dose assessment.
Command and Control Function The first topic discussed was the Command and Control Function.
The NRC asked SNC to provide the following:
Provide information that supports the capability to provide timely augmentation to the Command and Control function.
Provide the qualification and training requirements for SNCs Shift Managers/Emergency Directors (ED) to implement SNC event response procedures. This information would include both the capabilities/responsibilities of a Shift Manager and of a ED. This information should provide justification for the proposed changes to Shift Manager/ED ERO augmentation timing.
Provide information related to drills and/or exercises that were supported by only the Shift Manager for 75 minutes from the declaration of an Alert or greater emergency classification level (ECL) and for similar drills and/or exercises where an Emergency Director/Manager arrived before 75 minutes so that a direct comparison of emergency response can be made.
The following is a summary of the NRC staff discussion with SNC relating to the Command and Control function.
The NRC staff stated that clarification, as to who will be relieving the Shift Manager (SM)/Emergency Director (ED) of either the SM or ED responsibilities within 60 minutes of an Alert or greater classification, was needed in support of the SNC LAR.
The NRC staff stated that the current 75-minute ERO augmentation included consideration of support that could be provided by an on-shift maintenance supervisor to provide supervision for repair and troubleshooting activities, and a third radiation protection technician who could assist in the coordination of radiation protection activities.
The NRC staff stated that, based on a review of SNC qualification requirements for EDs, SNC did provide sufficient information to clarify that SNC had an appropriate qualification program for EDs. However, it was not apparent that the SNC Standard Emergency Plan (SEP) would ensure that an individual would be available to relieve the Shift Manager SM/ED of either the SM or ED responsibilities within 60 minutes of an Alert or greater classification.
SNC indicated that all on-shift senior reactor operators (SROs) complete initial ED qualifications and that each shift includes two fully qualified EDs. SNC further described that either the unaffected unit supervisor or an additional on-shift SRO, who was responsible to respond to fires, could provide augmentation for the SM/ED.
The NRC staff noted that plant events, such as a response to a fire or security event, could require the time of the extra SRO. The NRC staff further noted that the unaffected unit supervisor would be required by 10 CFR 50.54(m) for each operating unit. Because a unit supervisor would be responsible for the unaffected unit would retain the responsibility to provide oversight for that unit during normal and abnormal operations, such as the security event described in the SNC on-shift staffing analysis, the NRC suggested that the unit supervisor may not be available to relieve the SM/ED of either the SM or ED functions.
SNC indicated it reached out to other facilities to gain insights on addressing NRC staff requests. SNC confirmed that it understood what information the NRC needed and that SNC would provide a supplement to address the Command and Control function gap.
Although not directly related to the Command and Control information request, SNC did indicate a desire to discuss the performance-based procedure analysis (PBPA) that was submitted by SNC. The NRC staff explained that the PBPA only included tasks that would be reasonably expected to be performed by the SNC staff on-shift. Although the PBPA does provide a comprehensive assessment of the capability for the SNC on-shift staff to respond to a range of emergency conditions, the PBPA does not indicate that the augmenting response organizations perform any tasks when responding to an Alert or greater classification. Because the PBPA does not include an assessment of the tasks performed by the augmenting organization, the PBPA does not provide information that could be used to justify changes to the emergency response organization and augmentation times. The NRC staff explained that the PBPA did not include an assessment of the tasks performed by the maintenance technicians that indicated SNC will change some emergency procedures to support the proposed removal on-shift maintenance technicians.
Although the PBPA and related systematic approach to training process (SAT) discussions occurred during the Command and Control portion, specific details related to this discussion will be included in the most appropriate audit discussion.
Communications Function The next topic discussed was the Communications Function.
The NRC asked SNC to provide the following:
Provide information to show how SNC licensed operators could concurrently meet the requirements of a licensed operator pursuant to 10 CFR 50.54(m)(2) and the Communications function as required by 10 CFR 50.47(b)(2).
Provide information related to drills and/or exercises that were supported by only licensed operators as on-shift communicators for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where augmenting communicators arrived before 75 minutes so that a direct comparison of emergency response can be made.
Provide licensed operator initial and requalification evaluated scenarios where either the licensed or senior licensed operator performed their licensed operator responsibilities concurrently with performing the ERO communication function.
The following is a summary of the NRC staff discussion with SNC relating to the Communication function.
The NRC staff explained that there was no concern regarding the utilization of one on-shift reactor operator, who is in addition to the three reactor operators required by 10 CFR 50.54(m),
to perform the communication function. The NRC staff questioned using one control room operator to perform communications with offsite response organizations (State and local) concurrently with the emergency notification communication function, which will require continuous communications with the NRC. The NRC staff noted that this concern is for communications that are 60 minutes after an Alert or greater classification.
SNC noted that a Hatch drill that took 87 minutes to turn over Command and Control to the Technical Support Center (TSC) and Emergency Operations Facility (EOF) and a Farley drill, that took 69 minutes to turn over the Command and Control function, as justification for increasing augmentation time for the communicator to 90 minutes. The NRC staff indicated that since the Hatch TSC was activated within 18 minutes of the Alert declaration, it would be reasonable that the TSC would have provided support to the on-shift staff. SNC indicated that neither the TSC nor the EOF assume any functions until Command and Control is transferred.
The NRC staff reiterated its concern and explained that communications during actual events would be expected to provide an increasing burden on ERO communicators as time after the event increases. Considering that one communicator would be required to maintain communications with the NRC, the second communicator would be responsible for communications with various State and local agencies until relieved of that responsibility.
Note: Subsequent to the first audit, the NRC staff performed a review of the April 24, 2018 Drill Event Timeline, and determined that the TSC Emergency Notification System (ENS)
Communicator was on the line with simulated NRC once the TSC was activated (18 minutes after Alert declaration). The NRC staff could not determine when, or if, communication between Farley and the NRC was established.
Based on the above, SNC indicated they did understand what information the NRC staff needed and would provide supplemental information.
Maintenance Function The next topic discussed was the Maintenance Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine how SNC licensed operators could concurrently implement event response procedures which would include emergency operating procedures, the emergency plan and related implementing procedures, and communication responsibilities while providing electrical and mechanical support for emergency core cooling system equipment, event mitigation, and equipment repair. Note: This information should address both maintenance technicians and maintenance supervisor capabilities.
Procedures and related qualifications for SNCs version of Fix-It-Now (FIN) maintenance and its troubleshooting procedures.
Evaluated scenarios where the SNC crew demonstrated the capabilities to perform troubleshooting, as provided in the SNC maintenance procedures, without assistance from the maintenance or engineering organizations.
The NRC staff and SNC discussed the capabilities of non-licensed operators and maintenance technicians. Part of this discussion was during the PBPA discussion and the remainder of this discussion occurred during the Maintenance function discussion.
Prior to this Audit, the NRC staff reviewed various operator qualification guides and maintenance procedures provided by SNC. This review indicated that SNC non-licensed operators are trained appropriately to implement normal and off-normal operating procedures.
Operations procedures provide operators with direction to take manual control of failed components, align systems for maintenance, and take local control of certain components.
Considering that operations procedures are used for plant operation and not the performance of maintenance, the NRC staff questioned the assertion that SNC operators provide the same or comparable capability as maintenance technicians.
Additional discussion regarding fix-it-now and an expedited process for maintenance during Site Area Emergency or greater was conducted. This information provided clarity that SNC had the capability to perform expedited maintenance.
The NRC staff explained that current Diverse and Flexible Coping Strategies (FLEX) capabilities could provide the on-shift staff with the capability to mitigate the consequences of a radiological event. The NRC staff stated that SNC needs more information to be submitted on the docket to confirm that SNC had the equipment, procedures, and on-shift staffing to implement the FLEX strategy.
SNC stated that it would provide the NRC staff with a supplement that provides information on the SNC FLEX strategy.
Engineering Function The next topic discussed was the Engineering Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Engineering. Note: This information should include addressing the unique SNC shift technical advisor (STA) method of providing on-shift STA expertise and not an individual dedicated to performing the STA function.
Provide information related to drills and/or exercises that were supported by only licensed operators as on-shift engineering staff for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where engineering staff arrived before 75 minutes so that a direct comparison of emergency response can be made.
Although the audit information provided by SNC did not appear to address the Engineering function, the SNC RAI response dated November 20, 2020, provided information to address the Engineering gap. Specifically, SNC stated that improved technology could allow engineering support to be provided remotely. The NRC staff explained that the primary concern is that the proposed SNC SEP, dated June 30, 2020, did not include any capability to provide engineering support prior to 90 minutes. The NRC staff stated that further support at 60 minutes was particularly important for reactor engineering. SNC indicated that it understood the NRC staff concerns and would provide a supplement addressing those concerns.
Radiation Protection Function The next topic discussed was the Radiation Protection (RP) Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Radiation Protection. Note: SNC includes field monitoring, supervision of radiation protection, and radiation protection actions in one Major Functional Area.
Provide information related to drills and/or exercises that were supported by only the three Radiation Protection Technicians for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where radiation protection support arrived before 75 minutes so that a direct comparison of emergency response can be made.
The NRC staff noted that current FLEX capabilities could provide the on-shift staff with the capability to mitigate the consequences of a radiological event. The NRC staff stated that FLEX strategies would use prescribed equipment locations and procedures that may require fewer RP resources. The NRC staff suggested a site-specific assessment may be needed to demonstrate the sufficiency of potential RP needs to implement FLEX strategies. SNC indicated that it understood the constraint and that SNC would provide additional information on the docket indicating that SNC has the equipment, procedures, and on-shift staffing to implement the FLEX strategy.
The NRC staff discussed the importance of having the capability to perform offsite/near site radiological monitoring to determine magnitude and extent of radioactive releases at 60 minutes after an Alert or greater classification.
SNC is proposing to extend the response time of maintenance and engineering support personnel who do not perform dose assessment. SNC proposes to provide sufficient RP coverage to implement the SNC FLEX strategy. SNC is not proposing to change its dose assessment capability or timing. At 90 minutes, SNC is proposing to add 5 more RP technicians (which is 2 more than their current plan). SNC proposes to add an additional 60-minute RP technician who could support offsite/near site radiological monitoring. If offsite/near site radiological monitoring is not needed, this additional RP technician could perform other RP functions if needed.
Dose Assessment Function The next topic discussed was the Dose Assessment Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Dose Assessment. Specifically, explain how the on-shift chemistry technician, or other trained individual, can provide equivalent dose assessment information as the augmenting ERO for an additional 15 minutes. Note:
The augmenting ERO includes a RP Supervisor at the TSC and two Dose Assessment Supervisor & Analysts at the Emergency Operations Facility (EOF) which appear to have additional dose assessment capability.
The NRC staff and SNC discussed on-shift dose assessment capability. Based on the information provided by SNC, it was not apparent that on-shift and augmenting dose assessment provided the same dose assessment capability. SNC explained that the proposed SNC dose assessment would be performed by a dedicated dose assessor who would be using the same procedures and processes as the augmenting dose assessor.
Follow-Up SNC agreed to put additional information into 6 folders in Certrex by March 20, 2021. The NRC staff would review the information in Certrex from March 20 to March 31, 2021. Day 2 of the Audit would continue April 1, 2021. SNC offered to submit a supplement no later than April 12, 2021. Day 3 of the Audit was planned to be held on April 12, 2021.
ATTACHMENT 2 AUDIT DAY 2 - THURSDAY, APRIL 1, 2021 Attendees NAME ORGANIZATION John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Raymond Hoffman NRC Michael Markley NRC Caroline Carusone NRC Jessie Quichocho NRC Billy Gleaves NRC Ernest Bates Southern Nuclear Operating Company (SNC)
Justin Wheat SNC Shannon Smelley SNC Liz Williford SNC Marvin Warren SNC Rick Collins SNC Summary The audit commenced with the above attendees. On March 19, 2021, SNC placed additional documents discussed during from the Day 1 of the Audit into Certrex for NRC staff review.
The NRC staff referred to Section 4 of the Audit Plan. The functions of Section 4 of the Audit Plan are (1) command and control, (2) communications, (3) maintenance, (4) engineering, (5) radiation protection (RP), and (6) dose assessment.
Dose Assessment Function The first topic discussed was the Dose Assessment Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC emergency response organization (ERO) augmenting response time would not impact emergency preparedness key function of Dose Assessment.
Specifically, explain how the on-shift chemistry technician, or other trained individual, can provide equivalent dose assessment information as the augmenting ERO for an additional 15 minutes. Note: The augmenting ERO includes a RP Supervisor at the Technical Support Center (TSC) and two Dose Assessment Supervisor & Analysts at the Emergency Operations Facility (EOF) which appear to have additional dose assessment capability.
The NRC staff questioned the audit information provided by SNC that appeared to indicate the training for the on-shift and ERO Dose Assessors were similar; however, lesson plans for dose assessment were different in that the on-shift dose assessor performs a Quick dose assessment and the EOF performs a more comprehensive dose assessment [Enhanced Dose Projection]. Enhanced Dose Projection was identified as the preferred method of dose assessment for the EOF Dose Assessor. The NRC staff questioned this potential difference between the on-shift Dose Assessor and the EOF Dose Assessor.
SNC stated that the distinction was related to the timing of the dose assessment and not the qualifications of the on-shift and ERO Dose Assessors. SNC stated that the on-shift and ERO Dose Assessors have the same qualifications.
The NRC staff suggested that a supplement may be needed to confirm the same qualifications for the on-shift and ERO Dose Assessors as described. SNC agreed to provide additional information regarding this matter.
Maintenance Function The next topic discussed was the Maintenance Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine how SNC licensed operators could concurrently implement event response procedures which would include emergency operating procedures, the emergency plan and related implementing procedures, and communication responsibilities while providing electrical and mechanical support for emergency core cooling system equipment, event mitigation, and equipment repair. Note: This information should address both maintenance technicians and maintenance supervisor capabilities.
Procedures and related qualifications for SNCs version of Fix-It-Now (FIN) maintenance and its troubleshooting procedures.
Evaluated scenarios where the SNC crew demonstrated the capabilities to perform troubleshooting, as provided in the SNC maintenance procedures, without assistance from the maintenance or engineering organizations.
The NRC staff discussed the FLEX strategy procedures provided by SNC. Although not explicitly stated, NRC staff noted that FLEX procedures appear to be performed by the on-shift operators. SNC explained that FLEX procedures would be performed by on-shift non-licensed operators (NLOs). This capability was evaluated by a team that developed the SNC FLEX strategy and was also demonstrated during recent drills/exercises, provided in Certrex and listed in Section 5.0 above. The NRC staff informed SNC that a docketed statement indicating that on-shift NLOs would be capable of implementing FLEX strategies is needed by the NRC staff. The NRC suggested SNC provide its docketed information or provide a supplement indicating when FLEX strategies were demonstrated during recent drills/exercises.
Communications Function The next topic discussed was the Communications Function.
The NRC asked SNC to provide the following:
Provide information to show how SNC licensed operators could concurrently meet the requirements of a licensed operator pursuant to 10 CFR 50.54(m)(2) and the Communications function as required by 10 CFR 50.47(b)(2).
Provide information related to drills and/or exercises that were supported by only licensed operators as on-shift communicators for 75 minutes from the declaration of an Alert or greater emergency classification level (ECL) and for similar drills and/or exercises where augmenting communicators arrived before 75 minutes so that a direct comparison of emergency response can be made.
Provide licensed operator initial and requalification evaluated scenarios where either the licensed or senior licensed operator performed their licensed operator responsibilities concurrently with performing the ERO communication function.
SNC is proposing to staff an Emergency Notification System (ENS) communicator within 75 minutes of [an Alert] declaration. The NRC staff noted that this would not provide a relief of the on-shift communicator who is also the licensed reactor operator responsible for the least affected unit or provide the capability to maintain continuous communications with the NRC.
The NRC staff further stated that the current 75-minute ERO augmentation time is based on certain assumptions and those assumptions must be considered when extending all but one ERO position from 75 minutes to 90 minutes. SNC stated that Command and Control enhancements would help address the communicator function.
SNC stated that the SNC communicators are primarily phone talkers and the SM/ED is the actual communicator. The NRC staff noted that the Command and Control and Communication functions are two separate functions as identified in NUREG-0654, Revision 2, and that both functions need an individual to perform that function. The Command and Control discussion did not provide sufficient information for the NRC staffs detailed review.
Command and Control Function The next topic discussed was the Command and Control Function.
The NRC asked SNC to provide the following:
Provide information that supports the capability to provide timely augmentation to the Command and Control function.
Provide the qualification and training requirements for SNCs Shift Managers/Emergency Directors (ED) to implement SNC event response procedures. This information would include both the capabilities/responsibilities of a Shift Manager and of a ED. This information should provide justification for the proposed changes to Shift Manager/ED ERO augmentation timing.
Provide information related to drills and/or exercises that were supported by only the Shift Manager for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where an Emergency Director/Manager arrived before 75 minutes so that a direct comparison of emergency response can be made.
SNC proposed that an operations-centric person, an ENS Communicator responding within 75 minutes of an Alert or greater declaration, and a RP Technician responding within 60 minutes of an Alert or greater declaration would provide the resources needed to support the extension of ERO response time for the Command and Control function from 75 minutes to 90 minutes.
Although the NRC staff emphasized the need to relieve the SM/ED of either the SM or ED functions within 60 minutes of an Alert classification, SNC indicated they were planning on providing an operations-centric person within 75 minutes.
The NRC staff reiterated its discussion of March 15, 2021, regarding prompt relief for the SM/ED of either the SM or ED functions. The NRC staff did agree that having an additional operation-centric individual could add value to the on-shift staff. However, this position would not provide expected augmentation and relief for the SM/ED.
The NRC staff informed stated that the SNC response was insufficient in addressing concerns for either the Command and Control or Communications functions.
After taking a break to discuss the NRCs concerns with Emergency Plan (EP) management, SNC stated that they were considering retaining the EOF staffing within 75 minutes of an Alert or greater declaration. SNC noted a concern with having the SM/ED retain classification responsibility. The NRC staff informed SNC that having the SM/ED of retain classification responsibility until relieved by the TSC ED at 90 minutes would require more discussion but may not be unacceptable, if justified.
Engineering Function The next topic discussed was the Engineering Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Engineering. Note: This information should include addressing the unique SNC shift technical advisor (STA) method of providing on-shift STA expertise and not an individual dedicated to performing the STA function.
Provide information related to drills and/or exercises that were supported by only licensed operators as on-shift engineering staff for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where engineering staff arrived before 75 minutes so that a direct comparison of emergency response can be made.
The above discussion for retaining EOF staffing at 75 minutes, would include engineering personnel who continue to provide engineering support needed for dose assessment and other engineering support that may be needed by the on-shift staff.
Radiation Protection Function The next topic discussed was the Radiation Protection Function.
The NRC asked SNC to provide the following:
Provide information that could be used by the NRC staff to determine that the proposed increase in SNC ERO augmenting response time would not impact emergency preparedness key function of Radiation Protection. Note: SNC includes field monitoring, supervision of radiation protection, and radiation protection actions in one Major Functional Area.
Provide information related to drills and/or exercises that were supported by only the three Radiation Protection Technicians for 75 minutes from the declaration of an Alert or greater ECL and for similar drills and/or exercises where radiation protection support arrived before 75 minutes so that a direct comparison of emergency response can be made.
SNC stated that they planned to have an additional RP technician respond within 60 minutes to perform field monitoring, if needed. SNC further explained that they will clarify their emergency plan to indicated that, if field monitoring is not needed, the augmenting RP technician could provide RP support as needed.
Follow-Up SNC agreed to put additional information into Certrex as soon as possible. The NRC staff would review the information in Certrex as soon as practical. Day 3 of the Audit was held on August 12, 2021. Day 4 of the Audit was planned to be held on April 19, 2021.
ATTACHMENT 3 AUDIT DAY 3 - MONDAY, APRIL 12, 2021 Attendees NAME ORGANIZATION John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Raymond Hoffman NRC Michael Norris NRC Michael Markley NRC Caroline Carusone NRC Jessie Quichocho NRC Billy Gleaves NRC Ernest Bates Southern Nuclear Operating Company (SNC)
Justin Wheat SNC Shannon Smelley SNC Rick Collins SNC Summary The audit commenced with the above attendees. On April 8, 2021, SNC sent an email to the NRC staff notifying the staff that the information discussed on April 1, 2021, was placed into Certrex for review.
The NRC staff referred to Section 4 of the Audit Plan. The functions of Section 4 of the Audit Plan are (1) command and control, (2) communications, (3) maintenance, (4) engineering, (5) radiation protection (RP), and (6) dose assessment.
Discussion The following discussion elements are a continuation of the April 1, 2021 audit discussion. For consistency, the summary for the April 12, 2021, discussion follows the same sequence as the April 1 discussion.
Dose Assessment Function SNC proposed to retain staffing of the Emergency Operations Facility (EOF) within 75 minutes of an Alert or declaration. Considering that the staffing of the EOF within 75 minutes would provide SNC with the same dose assessment augmentation capability as the currently approved SNC emergency plan, the NRC staff finds the information provided by SNC appears to provide sufficient information for the NRC staff to complete its review. SNC stated that it will provide a supplement regarding confirming the same qualifications for the on-shift and emergency response organization (ERO) augmenting Dose Assessors.
Maintenance Function SNC acknowledged the need for a supplement regarding the SNC capability to implement FLEX strategy without impacting the SNC security plan or the SNC emergency plan.
Communications Function SNC proposed to retain staffing of the EOF within 75 minutes of an Alert or greater declaration.
Considering that the staffing of the EOF within 75 minutes would provide SNC with the same communication capability as the currently approved SNC emergency plan, the NRC staff acknowledged that SNC proposal would provide timely augmentation for the communication function. SNC stated that they would have an emergency notification network (ENN) and an emergency notification system (ENS) communicator respond within 75 minutes of an Alert declaration.
Command and Control Function SNC proposed retaining staffing of the EOF within 75 minutes of an Alert or greater declaration.
This would provide an emergency director (ED) that would relieve the shift manager (SM)/ED of ERO duties, with the exception of event classification. The NRC staff acknowledged that the SM would continue to monitor for classification upgrade criteria even after the responsibility for classification is transferred to the Technical Support Center (TSC) ED. As such, the NRC staff acknowledged that staffing the EOF would provide the SM with timely relief and augmentation.
Engineering Function SNC proposed to retain staffing of the EOF within 75 minutes of an Alert or greater declaration.
SNC stated that the EOF is staffed with an engineering technical supervisor with the training and capability to provide engineering support. This engineering support included monitoring of critical fault trees and core damage evaluation for dose assessment.
Radiation Protection Function SNC and the NRC staff confirmed that the information provided during the April 1, 2021, audit call was sufficient to address the NRC requested information.
Closing of Day 3 The above discussions provided the NRC staff, conceptually, with the information needed to support the SNC Fleet Emergency Plan (EP) LAR.
Follow-Up SNC agreed to put additional information into Certrex as soon as possible. The NRC staff would review the information in Certrex as soon as practical. SNC stated that it would provide a supplement by April 28, 2021. Day 4 of the Audit was planned to be held on April 29, 2021.
ATTACHMENT 4 AUDIT DAY 4 - MONDAY, APRIL 19, 2021 Attendees NAME ORGANIZATION John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Raymond Hoffman NRC Michael Norris NRC Michael Markley NRC Caroline Carusone NRC Ernest Bates Southern Nuclear Operating Company (SNC)
Justin Wheat SNC Shannon Smelley SNC Rick Collins SNC Summary The audit commenced with the above attendees. On April 14, 2021, SNC sent an email to the NRC staff notifying the staff that the information discussed on April 12, 2021, was placed into Certrex for review.
The NRC staff referred to Section 4 of the Audit Plan. The functions of Section 4 of the Audit Plan are (1) command and control, (2) communications, (3) maintenance, (4) engineering, (5) radiation protection, and (6) dose assessment.
Discussion Due to the scope of the previous audit discussions, the Day 4 Audit focused primarily on ensuring that SNC and the NRC were aligned on what supplemental information was needed by the NRC. SNC provided a summary of the draft information that would be included in the proposed supplement. The NRC staff and SNC also discussed acceptable methods to ensure that required training for the on-shift operators would be completed prior to removing maintenance personnel from on-shift emergency response organization (ERO) staffing.
Follow-Up SNC agreed to provide a supplement by April 28, 2021. Day 5 of the Audit was planned to be held on April 29, 2021, to close out the Audit.
ATTACHMENT 5 AUDIT DAY 5 (AUDIT CLOSEOUT) - THURSDAY, APRIL 29, 2021 Attendees NAME ORGANIZATION John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Raymond Hoffman NRC Caroline Carusone NRC Jessie Quichocho NRC Ernest Bates Southern Nuclear Operating Company (SNC)
Jamie Colemen SNC Liz Williford SNC Rick Collins SNC Closeout The audit commenced with the above attendees. SNC submitted a supplement to the application dated April 27, 2021 (ADAMS Accession No. ML21117A351). After brief remarks, the NRC staff closed out the audit. The NRC staff made no regulatory decisions during the audit. The NRC staff will perform a thorough review of the SNC supplement dated April 27, 2021, and the NRC staff will make any regulatory decisions in writing in a timely manner.
In accordance with LIC-111, it states:
The regulatory audit summary report should be placed on the docket and in ADAMS within 90 days of the completion of the audit or before the regulatory action that the audit supports is completed, whichever is shorter.
The 90-day deadline for the audit summary report is July 28, 2021.
ML21060B432 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NSIR/DPR/BC NAME JLamb KGoldstein JQuichocho DATE 04/29/2021 05/06/2021 05/10/2021 OFFICE NRR/DORL/ LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley JLamb DATE 05/18/2021 05/19/2021