NL-03-1792, Plants - Emergency Operations Facility Relocation Request for Prior Approval

Plants - Emergency Operations Facility Relocation Request for Prior Approval

ML032950056
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	10/16/2003
From:	Sumner H Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-03-1792
Download: ML032950056 (27)

Text

H.L Sumner, Jr. Southern Nuclear Vice President Operating Company, Inc.

Hatch Project Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.7279 SOUTHERNhha October 16, 2003 COMPANY Energy to Serve Your World w Docket Nos.: 50-32 1 50-348 50-424 NL 1792 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-000 1 Edwin I. Hlatch Nuclear Plant Joseph M. Parley Nuclear Plant Vogtle Electric Generating Plant Emergency Operations Facility Relocation Request for Prior Approval Ladies and Gentlemen:

In accordance with 10 CFR 50.54(q) and 10 CER 50.4(b)(5), Southern Nuclear Operating Company (SNC) hereby submits revisions to the Emergency Plans for the Edwin 1.Hatch Nuclear Plant (l-INP), the Joseph M. Farley Nuclear Plant (FNP) and the Vogule Electric Generating Plant (VEGP). SNC has performed a review of the proposed changes and determined that they continue to meet the standards of 10 CFR 50.47(b) and the requirements of 10 CFR 50, Appendix E.

NUREG-0696, "Functional Criteria for Emergency Response Facilities" indicates that the location of an Emergency Operations Facility (EOF) beyond 20 miles from the Technical Support Center (TSC) must be approved by the NRC prior to implementation. The revisions to these Emergency Plans provide for a consolidation of the existing Corporate Emergency Operations Center (CEOC), the on-site EOF, and the near-site backup EOF for the three sites into a single EOF located in Birmingham, Alabama at the SNC Corporate Headquarters. Accordingly, SNC is submitting these revisions for NRC approval prior to implementation.

The proposed EOF has already been constructed and tested. Emergency response drills and exercises have been conducted in the new facility and have proven to be successful.

The revisions to the referenced plans incorporate the description of the common facility and the assignment of functions based on the emergency plans for the three specific sites. The functions and description of the common EOF have been consolidated into a single appendix which is common to each site-specific emergency plan. This approach facilitates an enhancement in emergency planning process effectiveness while maintaining the site specific attributes inherent to the onsite facilities. The common EOF will function with no change in communication arrangements with the state and local governments. Additional commonalities for the onsite facilities have also been achieved through these revisions. i..,t 5

U. S. Nuclear Regulatory Commission NL 1792 Page 2 The NRC has approved similar EOF consolidations over the last several years, including TVA's common EOF in Chattanooga and Exelon's common EOF in Chicago. References to these successfully implemented common EOFs are provided as precedence for SNC's EOF in Birmingham.

The proposed revisions are one of the final steps in unifying the emergency response system for the SNC sites. This proposal will permit a wider availability of resources for the TSC at the sites because the EOF will no longer be staffed with personnel from the sites.

Additionally, the consolidation of the near-site facilities into a single facility in Birmingham results in improved response to security-based events due to the distant location of the proposed facility.

Approval of the common EOF is requested by April 15, 2004 to allow time for accurate planning and implementation of training programs and emergency response drills.

Justification for the proposed change is contained in Enclosure 1. The state and risk county concurrence letters can be found in Enclosure 2. Enclosures 3 through 5 provide detailed justification for the Emergency Plan changed pages located in Enclosure 6 through 8.

Mr. H. L. Sumner, Jr. states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY H. L. Sumner, Jr.

Sworn to and subscribedbefore me tlis / ( days of Oci b r 2003.

VoLe t2. lOtu~

7<-~, Notary Public

'M v DMnjlission expires: -2 - 7

- JILSI)JMI/LLO

Enclosure 1 Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant Emergency Operations Facility Relocation Justification

Southern Nuclear Operating Company Emergency Operations Facility Relocation Justification Summary And Impact Of The Proposed Change This proposed change requests the relocation of the Emergency Operations Facility (EOF) for the Edwin I. Hatch Nuclear Plant (HNP), the Joseph M. Farley Nuclear Plant (FNP), and the Vogtle Electric Generating Plant (VEGP) to a common EOF to be located at the Southern Nuclear Operating Company (SNC) Corporate Headquarters. HNP's on-site EOF is currently located at 11028 Hatch Parkway, Baxley GA. FNP's on-site EOF is currently located at 7388 North State Hwy 95, Columbia, AL. VEGP's on-site EOF is currently located at 7821 River Road, Waynesboro, GA.. The new EOF location will be 40 Inverness Parkway, Birmingham, Alabama. This facility will serve as the common location for coordinating response activities between on-site and off-site groups, for organizing radiological and environmental evaluations and dose projection calculations in order to make protective action recommendations to the affected states, and for interface with the state and federal agencies.

The combined facility will be staffed with an experienced workforce from the SNC corporate office. SNC is the licensed operator for HNP, FNP and VEGP. The engineering support organization, nuclear licensing and environmental services organizations, as well as the nuclear line executive management of the company, are located in the corporate office. The corporate staff will be sufficiently trained to perform their emergency response functions for all emergencies.

Multiple federal, state, and local officials have toured the new EOF (including representatives from NRC-NRR and NRC-Region II in February 2003). The tour included a demonstration of the facility's state-of-the-art technology and innovative design. SNC has also received written acceptance from the states and affected counties of Alabama, Georgia, Florida and South Carolina which can be found in Enclosure 2.

The emergency planning requirements for each of the three sites dealing with location, size, and layout of the new facility will continue to be met. Periodic drills will be used to verify staff response capabilities.

These changes do not impact or alter arrangements for requesting and effectively using support resources to accommodate state and local staff or other organizations capable of augmenting the planned response.

Justification Of The Proposed Change Since the proposed change represents a revised location for the near-site EOFs, the adequacy of the facility was evaluated against the criteria in NUREG-0696, "Functional Criteria for Emergency Response Facilities," Section 4 entitled "Emergency Operations Facility" using the methodology in NUREG-0814, "Methodology for Evaluation of Emergency Response Facilities."

Functions The consolidation of the three EOFs does not alter the basic functions required of the EOF facilities as described in Section 4.1 of NUREG-0696. The facilities, equipment and staffing of the EOF are adequate to ensure the continued effective and timely performance of the following functions:

El-l

Southern Nuclear Operating Company Emergency Operations Facility Relocation Justification

- Management of licensee emergency response,

- Coordination of radiological and environmental assessment,

- Determination of recommended public protective actions, and

- Coordination of emergency response activities with federal, state and local agencies.

When activated, the EOF will be staffed with emergency personnel designated by the emergency plans as well as liaisons from federal and state entities. Senior company personnel will manage activities in the EOF and will be augmented, as needed, with an experienced organization of SNC personnel.

The HNP, FNP, and VEGP data acquisitions and displays will be provided for the evaluation of radiological, meteorological, and plant system data needed to determine off-site protective action recommendations and off-site dose projections. Upon relocation of the EOF to Birmingham, the current Emergency Response functions for communication of information to the public via the news media by designated spokespersons will remain as described in the respective sites plans.

SNC has taken precautions to ensure that the EOF can be quickly accessed and made operational within about an hour of the initial notification and yet is safe-guarded against unauthorized personnel. The common EOF is located in a secure building. The building itself has posted security guards and video surveillance cameras. Any outside doors that do not have security guards are accessible only by SNC ID badges. Additionally, the EOF facility door is accessible only to people with ID badges that have been pre-approved for access.

Therefore, the function of the proposed EOF provides for the same or improved support to plant operations personnel and communication capability during emergency conditions as the existing near-site EOFs and meets the guidance of NUREG-0696.

Location. Structure. And Habitability The location, size and layout of the common EOF will continue to meet the staffing and equipment requirements of the emergency plans to carry out strategic direction for off-site and support operations, determination of public protective actions to be recommended to off-site officials, and coordination with federal, state, and local organizations. Periodic emergency response augmentation drills will be used to verify staff response capabilities.

The Birmingham facility represents a dedicated facility that is better able to support the staff addressed in the proposed revised plan. It has a more sophisticated communication system due to an upgrade in information technology. The relocation of the facility is an enhancement to current response capabilities.

Staffin2 And Training The EOF staff will be trained in the emergency response for all three plants. Key decision makers will attend the trainings as required based on their prior experience and qualifications. Therefore, proper response to any emergency will be within the capabilities of the EOF staff. Transferring EOF functions to the corporate staff will allow the plants to better focus station resources on site accident management.

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Southern Nuclear Operating Company Emergency Operations Facility Relocation Justification The EOF is staffed to provide the overall management of resources and the continuous evaluation and coordination of activities during and after an accident, which meets the guidance of NUREG-0696. Upon EOF mobilization to achieve minimum staffing to perform required assigned major tasks, designated personnel shall report directly to the common EOF to achieve functional operation. Personnel with that specific plant operational expertise will report to the EOF to support the EOF function. The EOF staff includes personnel needed to manage the on-site and off-site radiological monitoring, to perform radiological evaluations, and to interface with off-site officials for all emergency classes. Operating procedures, staff training in the use of data systems and instrumentation is part of continuous training and activation drills to maintain proficiency in accordance with the respective emergency plans. Enhanced performance training will be conducted prior to implementation of the common EOF.

Size The size of the EOF work area provides for the same or improved capability when compared to the existing EOF configurations and meets the guidance of NUREG-0696.

Radiological Monitoring The Birmingham EOF is beyond the 10-mile distance from the station as discussed in Table 2 of NUREG-0696 and therefore, does not require radiological monitoring equipment.

Communications The emergency communications systems at the Birmingham EOF are designed to ensure the reliable, timely flow of information between all parties having an emergency response role. The use of a dedicated phone switch, backup radio links, and commercial telephone lines results in flexible communications plans capable of responding to local and wide-area service outages. On-site and off-site communication capability is either maintained or improved as a result of the relocation of the EOF. The single facility results in commonality in communications and interface with off-site officials and representatives.

The Emergency Notification Network (ENN) continues to be the primary means of communicating changes in event classification and PARs to state and risk county authorities. These voice communications circuits meet the following primary functions as outlined in Section 4.6 of NUREG-0696:

• EOF Management communications with the designated senior manager in charge of the TSC,

• Communications to manage licensee emergency response resources,

• Communications to coordinate radiological monitoring,

• Communications to coordinate off-site emergency response activities, and

• Communications to disseminate information and recommended protective actions to responsible government agencies.

Existing commercial telephone service via trunked lines to the local telephone central office and designated company tie lines from the Birmingham facility will serve as the designated backup means of communication in the event of an ENN loss. Therefore, E1-3

Southern Nuclear Operating Company Emergency Operations Facility Relocation Justification reliable primary and backup means of voice communications from and to the EOF are available.

Access to telephone lines will be provided to the respective federal and state representatives in their respective office areas. This includes access to the NRC Emergency Notification System (ENS) and Health Physics Network (HPN) circuits from the designated NRC office and respective EOF ENS and HPN communicator workstations. Fax machines are available in the EOF to support the hard copy transmission of information between facilities and with the NRC and local authorities.

Therefore, the EOF communications capability provides for the same or improved communications capability when compared to the existing individual configuration and meets the guidance of NUREG-0696.

Instrumentation, Data Svstem Equipment, And Power Supplies - Technical Data And Data System Primary and alternate routes have been developed for the transmission of Plant Process Computer (PPC) data from the three stations to the Birmingham facility. The primary method is provided to the Birmingham facility via a PPC-LAN Ethernet connection. A redundant link involves the transmission of PPC data via the company LAN to a token-ring LAN at the SNC office complex. PPC data is then accessed by the Birmingham facility via LAN connection to this token-ring. Meteorological data is available on the PPC for use in dose assessment models.

A subset of designated emergency plan data from the PPC can be displayed on projection screens in the main room of the common EOF and allows for the trending of designated parameters. In addition to the PPC subset of designated backup emergency plan data screens, static displays (Facility Status Boards) are provided in the event the computer data display is unavailable. One or more PCs in the Dose Assessment area are capable of running the dose projection computer program and accessing the PPC subset of designated EP data screens required to perform a dose projection.

The power supplies for the common EOF do not, and need not, meet safety grade or Class IE criteria; however; they do include commercial electrical power, a battery backup, and a backup diesel generator. Accordingly, the technical data capabilities and data systems are sufficient for use at the proposed EOF.

Records Availability And Management The EOF is located adjacent to SNC's Document Services and will therefore have an up-to-date repository of selected plant records and procedures at the disposal of EOF personnel to aid in their technical analysis and evaluation of emergency conditions. The records will be controlled to ensure they are current and complete. Hardcopies of key reference materials will be maintained for use within the common EOF.

In addition, station design documentation, plant drawings, updated FSARs, and procedures are available via LAN connections. Therefore, the records availability and management meets the guidance of NUREG-0696.

E14

Southern Nuclear Operating Company Emergency Operations Facility Relocation Justification Conclusion The common EOF in Birmingham has been tested and has proven to be an effective facility for implementation of the integrated emergency plans for multiple stations. This EOF meets the guidance specified in NUREG-0696 for the requirements of an acceptable EOF. Approval of the new location of the HNP, FNP and VEGP common EOF extends the philosophy of a single emergency response concept at all SNC nuclear stations located within the given region. This single philosophy will allow the state, regulatory and utility emergency responders to function in consistent roles when responding to any SNC nuclear plant emergency, which is advantageous to the overall response effort.

The states of Alabama, Florida, Georgia and South Carolina have provided concurrence with this proposed change. The risk counties for all three nuclear power plants have indicated concurrence or no objection to our desire to move the EOFs to Birmingham assuming NRC approval. The current schedule anticipates consolidation of the three EOFs in June 2004.

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Enclosure 2 Edwin I. Hatch Nuclear Plant Joseph M. Farley Nuclear Plant Vogtle Electric Generating Plant State and Risk County Concurrence Letters

OFFICE OF THE GOVERNOR Georgia Emergency Management Agency II c OFFICE BOX 18055

,POST

X'fi.'- t ~AATLANTA, GEORGiA 30316-0055 J

_______ CTELEPHONE: (404) 635-7000 INGEORGA 1-800-TRY GEMA FAX: (404) 635-7205 ROY E. BARNES GARYW. MCCONNELL GOVERNOR DIRECTOR MYF X May 31, 2002 Mr. Jack Woodard, Executive Vice President Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35201

Dear Mr. Woodard:

Reference your letter of March 15, 2002, in which you have requested written concurrence from this agency on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for Plant Farley, Plant Hatch and Plant Vogtle into a common EOF located at the Southern Nuclear corporate office in Birmingham.

Please accept this letter as this agency's concurrence with the Southern Nuclear proposal to establish the common EOF for Plants Farley, Hatch and Vogtle.

If I can be of additional assistance, please contact me.

Sincerely, PATRICK COCHRAN Manager Radiological Programs E2-1

IWGH = Georgia Department of Natural Resources IJOW = 4244 International Parkway, Suite 114, Atlanta, Georgia 30354

=ifJA _ Lonice C. Barrett, Commissioner Environmental Protection Division Harold F. Reheis, Director April 11, 2002 Mr. Jack Woodard, Executive Vice President Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35201 Deaa,"6 rg This letter is in response to your letter of March 15, 2002, in which you requested written concurrence from this office on Southern Nuclear's proposal to consolidate the Plant Farley, Plant Hatch and Plant Vogtle Emergency Operations Facilities (EOFs) into a common EOF to be located at the Southem Nuclear corporate office in Birmingham, Alabama.

It is our understanding that this facility will be located in the area now occupied by the Corporate Emergency Operations Facility (CEOC).

As you know, Southern Nuclear emergency preparedness staff met with staff from this office and the Georgia Emergency Management Agency (GEMA) in the summer of 2001 to discuss this proposal in some detail. At that time, we provided Southern Nuclear staff with a verbal indication of support for the proposal. Since that time, we have had the opportunity to observe the activation of Southern Nuclear corporate facilities, most recently during the'Plant Hatch Alert of April 2, 2002, and, as expected, we are pleased with your ability to rapidly staff and activate corporate facilities.

At the previous meeting with your staff on this subject, we indicated that we wished to retain the option, should it be deemed necessary, to send state staff to the affected unit to work side-by-side with Southern Nuclear staff in areas such as field monitoring and/or consequence assessment. Although at this time, we cannot spell out a specific scenario in which we might wish to take such action, we still wish to retain this option, and with your concurrence, will investigate with your staff how this can be accomplished with minimal impact.

We concur with your assessment of the benefits of a corporate EOF, as spelled out in your letter of March 15. One additional 'intangible" benefit is the close working relationship that we have established with your corporate emergency preparedness staff over the years. We know each of your staff well, and likewise, they know us well. They are familiar with our operating procedures, and are well acquainted with our need for timely, accurate plant status data and other information related to incidents at Southern Nuclear facilities. Our relationship with your corporate emergency preparedness staff has served us well in many instances in the past, and I'm certain that, should the need arise, it will continue to serve us well in the future.

Please consider this letter as a written indication of my concurrence with the Southern Nuclear proposal to establish a common EOF to serve Plant Farley, Plant Hatch and Plant Vogtle. If I can be of additional assistance, please contact me by letter, by telephone at (404) 362-2675 or by electronic mail at Jim Hardeman(&mail.dnr.state.Qa.us Sincere James C. Hardeman, Jr., Manager Aft As "lZb

% / Environmental Radiation Program E2-2

STATE OF ALABAMA DEPARTMENT Of PUBLIC HEALTH Donald E. Williamson, MD State Health Officer April 10,2002 Mr. Dave Morey, Vice President Farley Project Southern Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alabama 35201

Dear Mr. Morey:

This is in response to your letter dated March 15, 2002, in which you requested written concurrence from our agency regarding the consolidation of the Plant Farley, Plant Hatch and Plant Vogtle Emergency Operations Facilities (EOFs) into a common EOF at the Southern Nuclear facility located in Birmingham, Alabama.

We concur that the common facility that would serve the EOF needs of Plant Farley in Alabama and Plants Hatch and Vogtle in Georgia should result in an overall improvement in the response capabilities of Southern Nuclear Operating Company personnel.

In addition, we have the following comments:

• For many years, TVA has successfully used a common Central Emergency Operations Center (CEOC) located in Chattanooga, Tennessee, for its three nuclear power plants including Browns Ferry in Alabama. We would expect the same successful outcome in this case.

• For exercises and emergencies relating to Plant Farley, we still plan to relocate our operations to the basement of the Houston County Court House in Dothan.

• We trust that this move to a common EOF in Birmingham will result in improved personal communications between our office and your staff. We do not need to rely too heavily on paper documentation for initial communications although we certainly need it for followup documentation.

• As long as we get the information that we need to respond to an emergency at Plant Farley, it does not matter to us where you are when you send it to us.

We look forward to continued and improved success in future activities involving the Office of Radiation Control and the Plant Farley Emergency Preparedness personnel.

Sincerely, AP002 Kirksey E. Whatley, Director GOP Office of Radiation Control The RSA Tower

• 201 Monri;feet

• Montgomery, AL 36104 P.O. Box 303017

• Montgomery, AL 36130-3017

STATE OF ALABAMA EMERGENCY MANAGEMENT AGENCY 5898 COUNTY ROAD 41

• P.O. DRAWER 2160

• CLANTON, ALABAMA 35046-2160 (205) 280-2200 FAX # (205) 280-2495 J

i I DNM I /,&. If IMJAA DON SIEGELMAN GOVERNOR iI " to PDHI I I'e D M I GM LEE HEIMS April 4, 2002 ACTING DIRECrOR

• 3 - ____ ____ _ _____

Mr. Dave Morey Vice President, Farley Project Southern Nuclear Operating Company.

P.O. Box 1295 Birmingham, Alabama 35201

Dear Mr. Morey:

We agree and support the concept of the consolidation of Emergency Operations Facilities (EOFs) for the Southern Nuclear facilities. We believe that this will enhance the communications capabilities between us, should an event ever happen.

Please contact Mr. Sam Guerrera at (205) 280-2474 if you have any questions.

Sincerely, /7 Lee He s Acting Director Farley 4Ik Id 2'2 OR Vicr.-e  !,-~. dce kra e~

E2-4

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BQM IE F WGHI

\AM S 1DOC STATE OF FLORIDA

.DEPARTMENT OF COMMUNITY A FFAIRS

'Ded i cated to making Florida a better place to call home' JEB BUSH STEVEN M. SEIBERT Governor Secretary April l , 2002 Mr. Dave Morey Southern Nuclear Operating Company, Inc.

Post Office Box 1295 Birmingham, Alabama 35201

Dear Mr. Morey:

I am in receipt of your letter dated March 15, 2002 relative the consolidation of the multiple plant Emergency Operations Facilities (EOF's) into a single facility in Birmingham, Alabama. In the letter you seek concurrence on this consolidation and provided numerous facts in support.

The State of Florida concurs with the concept of a consolidated EOF, believing it will improve overall response and operational capabilities on behalf of Plant Farley, and ultimately on behalf of the citizens of Florida.

Thanic you for the opportunity to comment on this important issue. Should you have any questions pertaining to this letter, or on the State of Florida Radiological Emergency Preparedness Program, please do not hesitate to contact me at (850) 413-9953 or mike.mcdonald(idca.state.fl.us.

Sincerely, Michael J. McDonald, Manager Radiological Emergency Preparedness cc: Walt Lee, Southern Nuclear Operating Company Scott Nelson, Florida Division of Emergency Management Don A. "Sonny" O'Bryan, Calhoun County Emergency Management Rodney Andreasen, Jackson County Emergency Management Ed Spooner, Gadsden County Emergency Management Roger Hagan, Washington County Emergency Management Robert J. Majka, Jr., Bay County Emergency Management c Wanda Stafford, Holmes County Emergency Management Sammy Hanna, Liberty County Emergency Management 2 55 S SHUMARD OAK BOULEVARD

• TALLAHASSEE, FLORIDA 32399-2100 Phone: (850) 488-466/Suncom 278-8466 FAX: (850) 921-078lSuncom 291-0781 Internet address: fi5www.dca.state.f1.us CRFTICAL SlAII CONCERN FIE)D OFFICE COMMUNITY PLANNING EMERGENCY MANAGEMEN7 HOUSING a COMMUNITY DEVEROPMENT 2796 Overseas Highway. Suite 212 2555 Shurnard Oak Boulevard 2555 Shumard Oak Boulevard 2555 Shurnard Oak Boulevard tMaratho FL33050-2227 7Talahassee. FL 32399-2100 Tallahassee, FL 32399-2100 Tallahassee, FL 32399-2100 qs gficfna.,.cg

FLSORIDA Dr{~ i Jeb Bush John 0. Agwunobi, M.D., M.BA.

Governor Secretary*.

April 17, 2002 Mr. Dave Morey Vice President Farley Project Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201

Dear Mr. Morey:

Thank you for your March 15th letter. We concur with your proposal to consolidate the Plant Farley, Plant Hatch and Plant Vogtle Emergency Operations Facilities (EOFs) into a common facility located in Birmingham, AL. We feel that the safety and protection of our citizens in the event of a radiological incident is of the utmost importance.

The new EOF appears to be an improvement in meeting those goals. Your continued support of our response to such an event is critical to our program. If we can be of any help to you in this or any other matter in which our cooperation is required in response to, or decision making, with regard to a radiological incident, please let us know.

Harlan Keaton Environmental Administrator Environmental Radiation Control cc: Walt H. Lee Ill - Farley Project William Passetti, Chief Bureau of Radiation Control BUREAU OF RADIATION CONTROL

• P.O. BOX 68006E-C)RLANDO, FL 32868-0069

• TEL: (407) 297-2095

CJW hrh2 uff f L5nuflb (Turuinn OFFICE OF THE ADJUTANT GENERAL STANHOPE S. SPEARS MAJOR GENERAL THE ADJUTANT GENERAL May 29,2002 Mr. J. B. Beasley, Jr., P. E.

Vice President, Vogtle Project Southern Niclear Operating Company. Inc.

40 Inverness Center Parkway P. 0. Box 1295 11 Birmingham, AL 35201

Dear Mr. Beasley:

This is in reference to your March 15, 2002, letter regarding the consolidation of the Plant Farley, Plant Hatch and Plant Vogtle Emergency Operations Facilities (EOFs).

I met with Mr. Chris Boone of Southern Company on May 2, 2002, who provided a more detailed concept of your proposal. Mr. Boone assured me that in the event of an emergency at Plant Vogtue that would necessitate the activation of your EOF, Southern Company would immediately dispatch a corporate aircraft to Columbia to transport our state Liaison Officer (LNO) to Birmingham. He also assured me that the consolidated EOF would be equipped with sophisticated primary and backup communications systems that would ensure continuous contact with Plant Vogtle and Southern Company officials and our state LNO.

Based on the above assurances, I have no objection to the common EOF concept.

Thank you for providing the opportunity to comment on your proposal.

Sincerely, 7 6 Ronald C. Osborne Director 14 .

RCO/RWD cc: Mr. Chris Boone P, I,  ;

Emergency Management Division 1100 Fish HRit7ry Road West Columbia, South Carolina 29172 (803) 737-8500

• Fax: (803)-737-8570

• ~~~~~~~~~applius Cffuig

• ~ fnirrBntg~trng rmrnt< ge -;ti I Post OfMc= Box 747 DANEBRUCE . BAXLEYGEORGIA31515 CORITTHARRIS Director Telephone (912) 367-8170 Deputy Dirmtor October 09, 2003 Mr. H. L. Sumncr Jr.

Vice President - Hatch Project Southern Nuclear Operating Company P. O. Box 1295, lin 045 42 Inverness Center Parkway Birmingham, Alabama 35201-1295 Dear Mr. Sumner.

This letter is in response to your letter dated March 15, 2002, requesting written concurrence on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for the three Soutbern Nuclear sites into a common facility to be located in Birmingham, Alabama. The Appling County Emergency Management Agency has reviewed the proposal with a member of your staff and is convinced that the consolidated facility will continue to meet the needs of both the State of Georgia, Appling County and its citizens.

Please consider this letter as my written concurrence for the concept of a consolidated EOF for Southern Nuclear. I would like to thank you for the opportunity to comment on this important issue. If I can be of further assistance,.

please contact me by telephone at 912-367-8170. Thanking you in advance for your continued support and cooperation.

Dane cc, Director Appling County Emergency Management Agency E2-8

JEFF DAVIS COUNTY EMERGENCY MANAGEMENTAGENCY a 10 PUBLIC SAFETY DRIVE HAZLEHURST. GEORGIA 31539 JAMESE.DUNN .... m ,THY W. LOAD:

DIRECTOR CLERK Lewis Sumner PHONE (912) 3756628 P. O. Box 1295 Birmingham, AL 35201-1295

Dear Mr. Sumner:

l!

This letter is in response to your letter requesting written concurrence on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for the three Southern Nuclear sites into a common facility to be located in Birmingham, Alabama. JeffDavis County EMA has reviewed the proposal with a member of your staff and is convinced that the consolidated facility will continue to meet the needs of both Jeff Davis County and its citizens.

Pleas consider represents my concurrence for the concept of a consolidated EOF for Southern Nuclear. I would like to thank you for the opportunity to comment on this important issue. If I can be of further assistance, please contact me by telephone at (912)

Sincerely Jeff Davis County EMA - Director E2-9

October 07, 2003 Mr. H. L. Sumner Jr.

Vice President - Hatch Project Southern Nuclear Operating Company P. 0. Box 1295, Bin 02 42 Inverness Center Parkway Birmingham, Alabama 35201-1295

Dear Mr. Sumner:

This letter is in response to your letter dated March 15, 2002, requesting written concurrence on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for the three Southern Nuclear sites into a common facility to be located in Birmingham, Alabama. Tattnall County Emergency Management has reviewed the proposal with a member of your staff and is convinced that the consolidated facility will continue to meet the needs of both Tattnall County and its citizens.

Please consider this letter as my written concurrence for the concept of a consolidated EOF for Southern Nuclear. I would like to thank you for the opportunity to comment on-this important issue. If I can be of farther assistance, please contact me by telephone atr (912) 557-6820.

Walt Rogers, Director Tattnall County-ENIA P.O. Box 905 ' ReG14fc, GA 30453 Office: (912) 557-6820

• Fax: (912) 557-6937

. TOOMBS COUNTY EMERGENCY MANAGEMENT AGENCY EMERGENC BOX 487 MANANP. C.

LYONS, GEORGIA 30436 PHONE QONALO E. WIOENER 912

• 5264021 01rector Lewis Sumner P. 0. Box 1295 Birmingham, AL 35201-1295

Dear Mr. Sumner:

This letter is in response to your letter requesting written concurrence on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOF;) for the three Southern Nuclear sites into a common facility to be located in Birmingham, Alabama. Toombs County EMA has reviewed the proposal with a member of your staff and is convinced that the consolidated facility will continue to meet the needs of both Toombs County and its citizens.

Please consider this letter as it represents my concurrence for the concept of a consolidated EOF for Southern Nuclear. I would like to thank you for the opportunity to comment on this important issue. If I can be of further assistance, please contact me by telephone at (912) 526-6424.

Sincerely, Ronald E. Widener Toombs County EMA - Director E2-11 Protection Of Life And Property Thru Action

DOTHAN / HOUSTON COUNTY EMERGENCY MANAGEMENT P.O. Drawer 6406

• Dothan, Alabama 36302 (334) 677-4834 (334) 794-9720 Fax (334) 793-3550.

Shelby G. Womack Director I DNM ~MJA WS _ ~PDH _

Brenda T. Dunning Deputy Director April 8, 2002 LPH DEG Mr. Dave Morey Southern Nuclear Operating Company P.O. Box 1295 Birmingham, AL 35201

Dear Mr. Morey:

The combining of the Emergency Operating Facilities for Southern Nuclear into one unit located in Birmingham would help the information flow between your facility and ours. In case of an actual incident, information flow should be as fast and dependable as possible, and the proposed concept would accomplish this goal.

This concept is a very positive step in Emergency Preparedness. This office heartily concurs with it. Please call on us if we can be of any assistance.

50 .

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BLAKELY - EARLY COUNTY EMERGENCY MANAGEMENT RAY JARRErr. CEM J E.MA. DIRECTOR IL I "'.

May 3,2002 Mr. Dave Morey, Vice President Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, Alabama 35201

Dear Mr. Morey:

The consolidation of the Plant Hatch, Plant Farley and Plant Vogtle's Emergency Operation's Center into one is the most efficient use of the facility as well as personnel. This concept has been discussed with Walt Lee and considerable thought put into it. Blakely-Early County Emergency Management is in total agreement with this concept.

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.;CI11 E2-13 P.O. BOX 726

• 402 SOUTH BLVD.

• BLAKELY, GA 31723

• PHONE (912) 723-3029 / 3577

• FAX (912) 723-5908

imernemr ncf gement 277 Highway 24 South Nrnq Waynesboro, Georgia 30830 TEL: (706) 554-6651 ANGIE OUICK J.E. SANDERS SECRETARY

- ASST. CHIEF FAX: (706) 554-4660 KAREN DELAIGLE KERRY MALLARD E-Mail: burkeema~burke.net SECRETARY BATTALION CHIEF EARL PORTERFIELD JAYNE BRINSON WILLIE JORDAN SECRETARY

• BATTALION CHIEF CHIEF May 23, 2002 J. B. Beasley P. 0. Box 1295 42 Inverness Center Parkway Birmingham, Alabama 35201-1295

Dear Mr. Beasley:

This letter is in response to your letter requesting written concurrence on Southem Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for the three Southern Nuclear sites into a common facility to be located in Birmingham, Alabama. Burke County Emergency Management Agency has reviewed the proposal with a member of your staff and is convinced that the consolidated facility will continue to meet the needs of both Burke County and its citizens.

Please consider this letter as my written concurrence for the concept of a consolidated EOF for Southern Nuclear. I would like to thank you for the opportunity to comment on this important issue. If I can be of further assistance, please contact me by telephone at (706) 554-6651.

Sincerely, Earl Porterlield ChiefYDirector Burke County EMA E2-14

Department of Energy Savannah River Operations Office P.O. Box A Aiken, South Carolina 29802 JUN 1 2 2002 J. Barnie Beasley, Jr., P.E.

Vice President, -Vogtle Project Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway P.O. Box 1295 Birmingham, AL 35201

SUBJECT:

Common Emergency Operations Facility (EOF) II Pursuant to your letter of March 15, 2002, and Mr. Boone's briefing in May, Department of Energy (DOE) Savannah River Operations Office (SR) has reviewed the Southern Nuclear Operating Company's (SNC) plan to consolidate the Plant Farley, Plant Hatch, and Plant Vogtle EOFs into a common facility located in Birmingham. We are in agreement that the common EOF concept will improve the overall SNC response capability, and we have no concerns regarding adverse impacts to communications and coordination between the Savannah River Site and Plant Vogtle during an event.

Please thank Mr. Chris Boone for personally traveling to the Savannah River Site to brief DOE SR and Westinghouse Savannah River Company staff on the SNC plan. Please feel free to contact me at (803) 952-6302 or Ms. Christina Edwards of my staff at (803) 725-1791 if we can be of any assistance during this endeavor.

Sincerely,

{-c Randall J. Clendenning, Di ctor Radiation Protection and Emergency Management Division VA-02-0028 cc: C. K. Browm C. E. Boone W. H. Lee, III D. J. Matthews, WSRC R. Steadman, WSRC E2-15

AIKEN COUNTY Department of Emergency Services Emergency Preparedness Division 828 Richland Ave. West Aiken, South Carolina, 29801 Telephone: (803) 642-1623 FAX: (803) 642-2556 June 29,2002 Mr. J. Barnie Beasley, Jr.

Vice President - Vogtle Project Southern Nuclear Operating Company P. 0. Box 1295 42 Inverness Center Parkway Birmingham, Alabama 35201-1295

Dear Mr. Beasley:

This letter is in response to your letter dated March 15, 2002, requesting written concurrence on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for the three Southern Nuclear sites into a common facility to be located in Birmingham, Alabama. I met with Chris Boone and Merrill Maddox, Southern Nuclear Operating Company, John Angil, Barnwell County Emergency Management, and Bob Duggleby, South Carolina Emergency Management Division. The excellent relationship we have with Plant Vogtle and the Southern Company has me convinced that the consolidated facility would continue to meet the needs of both Aiken County and its citizens.

Please consider this letter as my written concurrence for the concept of a consolidated EOF for Southern Nuclear. I would like to thank you for the opportunity to comment on this important issue. If ] can be of further assistance, please contact me by telephone at 803.642.1623.

S- rely, David Ruth EP Coordinator Aiken County Emergency Services E2-16

Linda S. Sanders, Director Allendale County Emergency PreparednessAgency P.O. Box 129 Allendale, South Carolina 29810 (803) 584-4081 acepa(barnwellsccom June 5, 2002 Mr. J. Barnie Beasley, Jr. f..

Vice President - Vogtle Project i e d Southern Nuclear Operating Company c P;sIeitf P. 0. Box 1295 tec 42 Inverness Center Parkway ' .

Birmingham, Alabama 35201-1295

Dear Mr. Beasley:

This letter is in response to your letter dated March 15, 2002, requesting written concurrence on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for the three Southern Nuclear sites into a common facility to be located in Birmingham, Alabama. The Allendale County Emergency Preparedness Agency has reviewed the proposal with a member of your staff and is convinced that the consolidated facility will continue to meet the needs of both Allendale County and its citizens.

Please consider this letter as my written concurrence for the concept of a consolidated EOF for Southern Nuclear. I would like to thank you for the opportunity to comment on this important issue. If I can be of further assistance, please contact me by telephone at (803) 584-4081.

Sincere a S. Sanders Allendale County Emergency Preparedness Agency Cc: Chris Boone E2-17

BARNWELL COUNTY EMERGENCY MANAGEMENT JOHN F. ANGIL, I1Director ERIC 7KE1TH' TOOLE BARNWELL COUNTY ADMIN BLDG ASST TO THE DlRECTOR 57 WALL STREET DATA-BASE MANAGER BARNWELIO SOUTH CAROLINA 29812 PHONE (803) 259-7013 /541.1001 JANICE 'JAN COX FAX (803) 259-1759 ADMINISTRATIVE ASSISTANT May 29, 2002 Mr. J. Barnie Beasley, Jr.

Vice President - Vogtle Project Southern Nuclear Operating Company P. O. Box 1295 42 Inverness Center Parkway Birmingham; Alabama 35201-1295

Dear Mr. Beasley:

This letter is in response to your letter dated March 15, 2002, requesting written concurrence on Southern Nuclear's proposal to consolidate the Emergency Operations Facilities (EOFs) for the three Southern Nuclear sites into a common facility to be located in Birmingham, Alabama. I met with Chris Boone and Merrill Maddox, Southern Nuclear Operating Company, David Ruth, Aiken County Emergency Services and Bob Duggleby, South Carolina Emergency Management Division, to discuss the plausibility of this endeavor. Several issues were discussed: the State and Local Government's needs during an emergency, duplication of facilities and efforts during an emergency and costs.

The excellent relationship we have with Plant Vogtle and the Southern Company has me convinced that the consolidated facility would continue to meet the needs of both Barnwell County and its citizens.

Please consider this letter as my written concurrence for the concept of a consolidated Emergency Operation Facilities (EOFs) for Southern Nuclear. I would like to thank you for the opportunity to comment on this important issue. If I can be of further assistance, please contact me by telephone at (803) 259-7013 or (803) 541-1155 private line.

rel Director LT Pc: C. Boone M. Maddox D. Ruth B. Duggleby E2-18