NL-14-2060, 50.54(q) Evaluation Performed on a New Revision of the Emergency Plan On-Shift Staffing Analysis Supplement Report

50.54(q) Evaluation Performed on a New Revision of the Emergency Plan On-Shift Staffing Analysis Supplement Report

ML14356A623
Person / Time
Site:	Hatch
Issue date:	12/22/2014
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-2060
Download: ML14356A623 (3)

Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 A

Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY December 22,2014 Docket Nos.: 50-321 NL-14-2060 50-366 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant 50.54(q) Evaluation Performed on a New Revision of the Emergency Plan On-Shift Staffing Analysis Supplement Report

References:

1. Southern Nuclear Operating Company letter to the NRC, Edwin I. Hatch Nuclear Plant On-Shift Staffing Analysis, dated January 18, 2013 (NL 0065)

2. Southern Nuclear Operating Company letter to the NRC, Edwin I. Hatch Nuclear Plant On-Shift Staffing Analysis Supplement, dated February 5, 2013 (NL-13-0187)

3. Southern Nuclear Operating Company letter to the NRC, Edwin I. Hatch Nuclear Plant- Units 1 and 2 Emergency Preparedness Information Requested by NRC Letter, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Daiichi Accident,"dated April30, 2013 (NL-13-0764)

4. Southern Nuclear Operating Company letter to the NRC, Edwin I. Hatch Nuclear Plant On-Shift Staffing Analysis Supplement, dated October 07, 2014 (NL-14-1185)

5. NEI 10-05, Assessment of On-Shift ERO Staffing and Capabilities, Revision 0, June 2011

6. NEI 12-01, Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities, Revision 0, May 2012 Ladies and Gentlemen:

Southern Nuclear Operating Company (SNC) submitted information pursuant to Title 10 of the Code of Federal Regulations (1 0 CFR) 50.54(q)(5) via Reference 1 to the Nuclear Regulatory Commission (NRC) regarding the on-shift staffing

US Nuclear Regulatory Commission NL-14-2060 Page 2 analysis performed for Edwin I. Hatch Nuclear Plant (HNP) per Reference 5.

Subsequently, SNC submitted supplemental information to Reference 1 via Reference 2 regarding the assignment of compensatory measures required as a result of the staffing analysis. Reference 1 stated that the 10 CFR 50.54(q) evaluation performed for the HNP NEI 10-05 On-Shift Staffing Analysis Report (hereafter referred to as "1 0-05 report) concluded the minimum staff identified in Table B-1 of the HNP Emergency Plan is adequate to respond to the scenarios identified in the regulations until relieved by the augmented Emergency Response Organization, with the exception of NRC Event Notifications made by the Shift Manager for the Aircraft Probability Threat and Control Room Fire events.

While reviewing the 10-05 report for a future license amendment request, a third-party vendor notified SNC of a possible discrepancy between the 10-05 report and the HNP Emergency Plan. After further research, the discrepancy was confirmed, and it was determined that the minimum staffing level identified in Table B-1 of the HNP Emergency Plan differs from the minimum staffing level identified in the 10-05 report. Therefore, the conclusion submitted in Reference 1 should have stated that the most limiting event in the study requires 16 Operations personnel, that the minimum staffing identified in the HNP Emergency Plan is not consistent with this number of Operations personnel, and that a compensatory measure is required. This error was captured in the SNC Corrective Action Program. A compensatory measure was put in place on Thursday, July 17, 2014 to assure the minimum Operations staffing is not below the number identified in the 10-05 report on any given shift.

In Reference 4, the Southern Nuclear Operating Company letter to the NRC, Edwin I. Hatch Nuclear Plant On-Shift Staffing Analysis Supplement, dated October 07, 2014 (NL-14-1185), a more detailed explanation of how SNC should address the items in Reference 5 and 6 is discussed as well as the need to evaluate a future revision change to the HNP Emergency Plan.

Subsequently a new On-Shift Staffing Analysis was conducted, using the structured approach provided in NEI 10-05: Assessment of On-Shift Emergency Response. The results have confirmed that the existing staffing provided in the current version of the HNP Emergency Plan is adequate and resolves the conflicts identified in the previous 10-05 report. As this staffing assessment provides the technical basis for the minimum shift staffing provided in the HNP Emergency Plan, the results of this assessment were evaluated pursuant to 10 CFR 50.54(q)(3) and determined not to result in a reduction of the effectiveness of the HNP Emergency Plan.

In accordance with 10 CFR 50.54(q), Southern Nuclear Operating Company (SNC) hereby submits a 30 day notification that the above stated changes have been made to the technical basis for the HNP Emergency Plan as it relates to Organization Staffing and Capability.

US Nuclear Regulatory Commission NL-14-2060 Page 3 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Respectfully submitted, C,fl-~

C. R. Pierce Regulatory Affairs Director CRP/GLS cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Vineyard, Vice President- Hatch Mr. M.D. Meier, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President- Engineering Mr. G. L. Johnson, Regulatory Affairs Manager- Hatch Mr. R. L. Mansfield, Emergency Preparedness Director RTYPE: CHA02.004 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Hatch Mr. D. H. Hardage, Senior Resident Inspector- Hatch