NL-15-1392, Enclosure 16 - Evaluation of Proposed Changes Through Enclosure 19 - Off-site Response Organizations Letters of Consultation and Concurrence

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Enclosure 16 - Evaluation of Proposed Changes Through Enclosure 19 - Off-site Response Organizations Letters of Consultation and Concurrence
ML15246A060
Person / Time
Site: Hatch, Vogtle, Farley  Southern Nuclear icon.png
Issue date: 08/31/2015
From:
Southern Nuclear Operating Co
To:
Office of New Reactors, Office of Nuclear Reactor Regulation
Shared Package
ML15246A045 List:
References
NL-15-1392
Download: ML15246A060 (70)
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Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I. Hatch Nuclear Plant Units 1 and 2; Vogtle Electric Generating Plant Units 1 and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 16 Evaluation of Proposed Changes This enclosure contains 13 pages.

6 to NL-1 5-1 392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan 1TAAAC Evaluation of Proposed Changes Table of Contents

1. Summary Description
2. Detailed Description and Technical Evaluation
3. Regulatory Evaluation 3.1 Applicable Regulatory Requirements/Criteria 3.2 Precedent 3.3 No Significant Hazards Consideration Determination 3.4 Conclusion
4. Environmental Assessment El16-1 6 to NL-1 5-.1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC
1. Summary Description Pursuant to *10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests an amendment to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.

The requested amendment will revise the VEGP 3 and 4 Emergency Plan Inspections Tests and Analysis Criteria (ITAAAC) to conform to changes to the VEGP 3 and 4 Emergency Plan as proposed in Enclosures 2 and 14.

2. Detailed Description and Technical Evaluation 2.1 Changqes to Emergqency Planningq (EP) ITAAC VEGP Units 3 and 4 EP ITAAC E.3.9.01.01.01 The inspections, tests, and analyses column for EP ITAAC E.3.9.01.01.01 requires an inspection of the control room, technical support center (TSC), and emergency operations facility (EOF) be performed to verify that the displays for retrieving system and effluent parameters specified in Table V2 0.2-1, Hot Initiating Condition Matrix, Modes 1, 2, 3, and 4 and Table V2 0.2-2, Cold Initiating Condition matrix, Modes 5, 6, and De-fueled are installed and perform their intended functions, and that emergency implementing procedures (EIPs) have been completed. The information contained in Tables V2 0.2-1 and V2 D.2-2 would provide the bases for the emergency classification and emergency action level (EAL) scheme. Additional technical bases information would be included in EIPs.

The proposed change to the VEGP 3&4 Emergency Plan, to be included in the Southern Nuclear Operating Company Standard Emergency Plan (SEP) with a VEGP Units 3 and 4 Annex, would relocate the information that would otherwise be shown in Tables V2 0.2-1 and V2 0.2-2 to SEP VEGP Units 3 and 4 Annex, Appendix B, Emergency Action Level (EAL) Scheme. In addition, SNC intends to no longer place EAL technical bases information in EIPS. As a result, all EAL technical bases information will reside in SEP VEGP 3 and 4 Annex, Appendix B. No technical changes to the information contained in Tables V2 0.2-1 and V2 0.2-2, or EIPs that contain EAL technical bases information, will occur as result of the proposed relocation of EAL technical bases information.

  • Therefore, it is proposed that references to Tables V2 0.2-1 and V2 0.2-2 be replaced by a reference to the SEP VEGP Units 3 and 4 Annex, Appendix B. In addition, it is proposed to delete the reference to completion of EIPs. The proposed changes to EP ITAAC 3.9.01.01.01 are shown in Enclosures 17 and 18 for Unit 3 EP ITAAC and Unit 4 EP ITAAC, respectively.

Proposed changes to the Acceptance Criteria column entry for EP ITAAC E.3.3.01 .01.01 are addressed in SNC LAR-15-014.

Technical Evaluation - EP ITAAC E.3.9.01.01.01 10 CFR 52.97(a)(2) requires that the Commission identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. Regulatory guidance for the content of EP ITAAC is in NUREG-0800, Subsection 14.3.10, "Emergency Planning - Inspections, Tests, E16-2 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC Analyses, and Acceptance Criteria." Generic EP ITAAC is presented in NUREG-0800, Table 14.3.10-1. Item 4.0, "Emergency Classification System," contains the generic EP ITAAC from which the plant-specific EP ITAAC E.3.9.01.01.01 was developed. The generic inspections, tests, and analysis column states, "An inspection of the control room, TSC, and EOF will be performed to verify that they have displays for retrieving facility system and effluent parameters specified in the emergency classification and EAL scheme." Therefore, because the proposed change to replace the reference to Tables V2 D.2-1 and V2 0.2-1 with a reference to SEP VEGP Units 3 and 4 Annex, Appendix B and the deletion of the reference to EIPs does not involve a change in technical information, and because the revised reference is consistent with the proposed Emergency Plan revision, EP ITAAC E.3.9.01 .01.01 continues to satisfy the requirement to identify inspection, test, or analysis information for the verification of the EAL scheme.

VEGP Units 3 and 4 EP ITAAC E.3.9.06.00.01 The acceptance criteria for EP ITAAC E.3.9.06.00.01 requires in part (6.1.B.3) that during an emergency plan drill, the ability to assemble and deploy field monitoring teams within 60 minutes of the decision to deploy field teams is demonstrated. The 60 minute criterion is based on goals established in the exercise objectives and supporting criteria EIPs. However, neither the VEGP 3&4 Emergency Plan nor the proposed SEP with a VEGP Units 3 and 4 Annex contains a commitment to deploy field monitoring teams within 60 minutes. Therefore, it is proposed that the 60 minute criterion for deployment of field monitoring teams be deleted. The proposed changes to EP ITAAC 3.9.06.00.01 are shown in Enclosures 17 and 18 for Unit 3 EP ITAAC and Unit 4 EP ITAAC, respectively.

Technical Evaluation - EP ITAAC E.3.9.06.00.01 10 CFR 52.97(a)(2) requires that the Commission identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. Regulatory guidance for the content of EP ITAAC is contained in NUREG-0800, Subsection 14.3.10, "Emergency Planning - Inspections, Tests, Analyses, and Acceptance Criteria." Generic EP ITAAC is presented in NUREG-0800, Table 14.3.10-1. Item 9.0, "Accident Assessment," contains the generic EP ITAAC from which the plant-specific EP ITAAC E.3.9.06.00.01 was developed. The generic acceptance criteria states, "The means exists to provide initial and continuing radiological assessment throughout the course of an accident. [The COL applicant will identify specific capabilities.]" The drill objectives and associated acceptance criteria listed in EP ITAAC E.3.9.06.00.01 are based on approved objectives and supporting criteria used to evaluate emergency plan drills. Deleting the specific requirement to demonstrate deployment of the field monitoring teams within 60 minutes does not alter the ability of the supporting criteria to verify the related objective of "Accident Assessment and Classification" is met, because the proposed SEP with a VEGP Units 3 and 4 Annex does not contain a commitment to deploy field teams within 60 minutes.

Furthermore, NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

Revision 1, Section 11.1.7, which requires that each organization describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone, does not specify a time in which field monitoring teams are to be deployed. Therefore, E16-3 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC deleting the requirement to verify field monitoring teams are to be deployed within 60 minutes is acceptable.

VEGP Unit 3 EP ITAAC E.3.9.08.01.01.

The exercise objectives and associated acceptance criteria listed in EP ITAAC E.3.9.08.01 .01 are based on approved objectives and supporting criteria used to evaluate NRC graded exercises. Because the SEP with a VEGP Units 3 and 4 Annex will affect the exercise evaluation objectives and supporting criteria, it is proposed to revise the exercise objectives and supporting criteria as described below.

1. The acceptance criteria for EP ITAAC E.3.9.08.01.01 require in part that the graded exercise activities used to verify "Notifications" be performed in accordance with a designated checklist. The affected criteria are 8.1.1.B.1.a, 8.1.1 .B.2.a, 8.1.1 .B.2.b, 8.1.1 .B.2.c, and 8.1.1 .B.3.a. Because the objectives and supporting criteria for drills and graded exercises will be revised to be more flexible as to how actions are to be performed, it is proposed to delete the phrase, "using the designated checklist," from the affected criteria.
2. Criterion 8.1.1.8.2 requires the ability to notify responsible state and local government agencies within 15 minutes and to notify the NRC within 60 minutes of declaration of an emergency. Criterion 8.1.1 .B.2.c requires that information be transmitted to the NRC with 60 minutes of event classification. Because 10 CFR 50.72(a)(3) requires that the NRC be notified immediately after the completion of the notification to the state or local authorities and no later than one hour from event classification, it is proposed that Criteria 8.1.1.8.2 and 8.1.1.B.2.c be revised to require that the NRC be notified immediately after the completion of the notification to state and local authorities and no later than 60 minutes after declaration of an event.
3. Criterion 8.1.1.C.1.a requires that command and control be demonstrated in the control room in the early phases of the emergency and that command and control be demonstrated in the technical support center (TSC) within 60 minutes from activation. The SEP changes two commitments related to command and control: 1) Elements of command and control related to accident assessment will also be performed in the emergency offsite facility (EOF), and 2) the time for demonstrating command and control will be revised from 60 minutes from activation to 75 minutes from declaration of an Alert or higher classification. As a result, it is proposed to change criterion 8.1.1.C.1.a to read, "Command and control is demonstrated by the control room in the early phase of the emergency and by the technical support center (TSC) and the emergency offsite facility (EOF) within 75 minutes following the declaration of an Alert or higher classification."
  • 4. Criterion 8.1.1.C.2 requires that the ability to transfer emergency direction from the control room (simulator) to the TSC be demonstrated within 30 minutes from activation. Because the SEP will revise the commitment related to command and control to include the EOF, and exercise evaluation objectives no longer identify a 30 minute time frame to demonstrate the transfer, it is proposed to change criterion 8.1.1.C.2 to read, "Demonstrate the ability to transfer emergency direction from the control room (simulator) to the TSC and EOF."
5. Criterion 8.1.1.C.2.a requires that briefings occur before turnover of responsibility and that the transfer of duties be documented. The exercise evaluation El16-4 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC objectives and supporting criteria no longer require the transfer of duties to be documented. Consequently, it is proposed to change criterion 8.1.1.C.2.a to read, "Briefings were conducted prior to turnover responsibility."
6. Criterion 8.1.1.0.4 requires the ability to perform assembly and accountability for all onsite personnel within 30 minutes of an emergency requiring protected area assembly and accountability. Because the SEP clarifies that accountability is
  • performed for personnel located within the protected area, it is proposed to change criterion 8.1.1.C.4 to read, "Demonstrate the ability to perform assembly and accountability for all individuals located within the protected area within 30 minutes of an emergency requiring protected area assembly and accountability."

The SEP also changes the commitment for when accountability is required, from an Alert or higher classification to a Site Area Emergency or higher classification.

As a result, it is proposed to change criterion 8.1.1.C.4.a to read, "Protected area personnel assembly and accountability completed within 30 minutes of the Site Area Emergency or higher emergency declaration via public address announcement."

7. Criterion 8.1.1.0.1 requires that the activation of the operational support center (OSC) and full function operation of the TSC and EOF occur within 60 minutes of activation. The SEP changes this commitment to 75 minutes from declaration of an Alert or higher classification. As a result, it is proposed to change criterion 8.1.1.D.1 to read, "Demonstrate activation of the operational support center (OSC), and full functional operation of the TSC and EOF within 75 minutes following declaration of an Alert or higher classification."
8. Criterion 8.1.1.D.2 requires that the adequacy of equipment, security, provisions, and habitability precautions for the TSC, OSC, EOF, and emergency news center (ENC) be demonstrated as appropriate. Because the SEP changes the title of the ENC to the joint information center (JIC), it is proposed to change criterion 8.1.1.0.2 to read, "Demonstrate the adequacy of equipment, security provisions, and habitability precautions for the TSC, OSC, FOF, and joint information center (JIC), as appropriate."
9. Criterion 8.1.1.D.2.c requires verification that the Health Physics Supervisor (TSC) implements the designated checklist if an onsite or offsite release has occurred. Because the SEP changes the title of-the Health Physics Supervisor to Radiation Protection Supervisor, it is proposed to change criterion 8.1.1.D.2.c to read, "The Radiation Protection Supervisor (TSC) implements the designated checklist if an onsite or offsite release has occurred."
10. Criterion 8.1.1.E.1.a requires that HP Technicians demonstrate the ability to obtain appropriate instruments and take surveys. Because the SEP changes the title of HP Technicians to RP Technicians, it is proposed to change criterion 8.1.1 .E.l.a to read, "RP Technicians demonstrate the ability to obtain appropriate instruments (range and type) and take surveys."
11. Criterion 8.1.1 .E.3 requires the ability to assemble and deploy field monitoring teams within 60 minutes from the decision to do so. Because the SEP does not contain a commitment to deploy field monitoring teams within 60 minutes, it is proposed to change criterion 8.1.1.E.3 to read, "Demonstrate the ability to assemble and deploy field monitoring teams."

E16-5 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC

12. Criterion 8.1.1.E.3.a requires that one field monitoring team be ready to be deployed within 60 minutes of being requested from the OSC, and no later than 90 minutes from the declaration of an Alert or higher emergency. Because the SEP does not contain a commitment related to the timing of field team deployment, but does contain commitments related to the definition of readiness for field team deployment, it is proposed to change criterion 8.1.1 .E.3.a to read, "Field monitoring teams are briefed, obtain equipment, and are dispatched in accordance with EIPs."
13. Criterion 8.1.1.E.5.a requires that the HP/Chemistry Shared Foreman or the Does Assessment Supervisor perform timely and accurate dose projections in accordance with emergency implementing procedures (EIPs). Because the SEP has changed the titles and commitment for personnel performing dose projections, it is proposed to change criterion 8.1.1 .E.5.a to read, "Personnel with dose assessment expertise on-shift and in the EOF perform timely and accurate dose projections, in accordance with emergency implementing procedures (EIPs)."
14. Criterion 8.1.1.F.1.a requires that media information is made available within 60 minutes of notification of the on-call media representative. Because the SEP changes the level of detail regarding communication information and transfers goals for performance to the Emergency Communications Plan (ECP), it is proposed to change criterion 8.1.1.F.1.a to read, "Media information (e.g., press releases, press briefings, electronic media) concerning events, conditions, and actions is made available."
15. Criterion 8.1.1.F.1.b requires that follow-up information be provided, at a minimum, within 60 minutes of an emergency classification or PAR change.

Because the SEP changes the level of detail regarding communication information and transfers goals for performance to the Emergency Communications Plan (ECP), it is proposed to delete criterion 8.1.1 .F.1 .b.

16. Criterion 8.1.1.F.2.a requires that calls be answered in a timely manner with the correct information in accordance with EIPs. Because the SEP changes the level of detail regarding .communication information and transfers tasks related to public information to the Emergency Communications Plan (ECP), which is not considered an emergency implementing procedure (EIP), it is proposed to change criterion 8.1.1 .F.2.a to read, "Calls are answered in a timely manner with the correct information."

The proposed changes to Unit 3 EP ITAAC 3.9.08.01.01 are shown in Enclosure 17.

Technical Evaluation - Unit 3 EP ITAAC E.3.9.08.01 .01 10 CFR 52.97(a)(2) requires that the Commission identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. Regulatory guidance for the content of EP ITAAC is found in NUREG-0800, Subsection 14.3.10, "Emergency Planning - Inspections, Tests, Analyses, and Acceptance Criteria." Generic EP ITAAC is presented in NUREG-0800, Table 14.3.10-1. Item 14.0, "Exercises and Drills," contains the generic EP ITAAC from which EP ITAAC E.3.9.08.01.01 was developed. The generic acceptance criteria E16-6 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC states, "The exercise is completed within the specified time periods of Appendix E to 10 CFR Part 50, onsite exercise objectives have been met, and there are no uncorrected onsite exercise deficiencies. [The COL applicant will identify exercise objectives and associated acceptance criteria.]" The exercise objectives and associated acceptance criteria listed in EP ITAAC E.3.9.08.01.01 are based on existing emergency plan commitments and approved objectives and supporting criteria used to evaluate NRC graded exercises. The revised E.3.9.08.01 .01 criteria continue to be based on commitments in the SEP with a VEGP Units 3 and 4 Annex. Therefore, changing the supporting criterion as described above is acceptable.

Unit 4 EP ITAAC E.3.9.08.01 .01 The exercise objectives and associated acceptance criteria listed in EP ITAAC E.3.9.08.01 .01 are based on approved objectives and supporting criteria used to evaluate NRC graded exercises. Because the SEP with a VEGP Units 3 and 4 Annex will affect the exercise evaluation objectives and supporting criteria, it is proposed to revise the exercise objectives and supporting criteria as described below.

1. The acceptance criteria for EP ITAAC E.3.9.08.01.01 require in part that the graded exercise activities used to verify "Notifications" be performed in accordance with a designated checklist. The affected criteria are 8.1.1 .B.2.a, 8.1.1.B.2.b, 8.1.1.B.2.c, and 8.1.1.B.3.a. Because the objectives and supporting criteria for drills and graded exercises will be revised to be more flexible as to how actions are to be performed, it is proposed to delete the phrase, "using the designated checklist," from the affected criteria.
2. Criterion 8.1.1 .B.2 requires the ability to notify responsible state and local government agencies within 15 minutes and to notify the NRC within 60 minutes of declaration of an emergency. Criterion 8.1.1 .B.2.c requires that information be transmitted to the NRC with 60 minutes of event classification. Because 10 CFR 50.72(a)(3) requires that the NRC be notified immediately after the completion of the notification to the state or local authorities and no later than one hour of event classification, it is proposed that Criteria 8.1.1.8.2 and 8.1.1.B.2.c be revised to require that the NRC be notified immediately after the completion of the notification to state and local authorities and no later than 60 minutes after declaration of an event.
3. Criterion 8.1.1.C.1.a requires that command and control be demonstrated in the control room in the early phases of the emergency and that command and control be demonstrated in the technical support center (TSC) within 60 minutes from activation. The SEP changes two commitments related to command and control: 1) Elements of command and control related to accident assessment will also be performed in the emergency offsite facility (EOF), and 2) the time for demonstrating command and control will be revised from 60 minutes from activation to 75 minutes from declaration of an Alert or higher classification. As a result, it is proposed to change criterion 8.1.1.C.1.a to read, "Command and control is demonstrated by the control room in the early phase of the emergency and by the technical support center (TSC) and the emergency offsite facility (EOF) within 75 minutes following the declaration of an Alert or higher classification."
4. Criterion 8.1.1.C.2 requires that the ability to transfer emergency direction from the control room (simulator) to the TSC be demonstrated within 30 minutes from activation. Because the SEP will revise the commitment related to command and E16-7

Enclosure Ev'aluation 16 of to NL-15-1392 Proposed Changes, VEGP 3 & 4 EmergencY Plan ITAAAC control to include the EOF, and exercise evaluation objectives no longer identify a 30 minute time frame to demonstrate the transfer, it is proposed to change criterion 8.1.1.C.2 to read, "Demonstrate the ability to transfer emergency direction from the control room (simulator) to the TSC and EOF."

5. Criterion 8.1.1.C.2.a requires that briefings occur before turnover of responsibility and that the transfer of duties be documented. The exercise evaluation objectives and supporting criteria no longer require the transfer of duties to be documented. Consequently, it is proposed to change criterion 8.1.1 .C.2.a to read, 'Briefings were conducted prior to turnover responsibility."
6. Criterion 8.1.1.C.4 requires the ability to perform assembly and accountability for all onsite personnel within 30 minutes of an emergency requiring protected area assembly and accountability. Because the SEP clarifies that accountability is performed for personnel located within the protected area, it is proposed to change criterion 8.1.1 .C.4 to read, "Demonstrate the ability to perform assembly and accountability for all individuals located within the protected area within 30 minutes of an emergency requiring protected area assembly and accountability."

The SEP also changes the commitment for when accountability is required, from an Alert or higher classification to a Site Area Emergency or higher classification.

As a result, it is proposed to change criterion 8.1.1 .C.4.a to read, "Protected area personnel assembly and accountability ,completed within 30 minutes of the Site Area Emergency or higher emergency declaration via public address

  • announcement."
7. Criterion 8.1.1.D.1 requires that the activation of the operational support center (OSC) and full function operation of the TSC and EOF occur within 60 minutes of activation. The SEP changes this commitment to 75 minutes from declaration of an Alert or higher classification. As a result, it is proposed to change criterion' 8.1.1 .D.1 to read, "Demonstrate activation of the operational support center (OSC), and full functional operation of the TSC and EOF within 75 minutes following declaration of an Alert or higher classification."
8. Criterion 8.1.1.D.2.c requires verification that the Health Physics Supervisor (TSC) implements the designated checklist if an, onsite release has occurred.

Because the SEP changes the title of the Health Physics Supervisor to Radiation Protection Supervisor, it is proposed to change criterion 8.1.1 .D.2.c to read, "The Radiation Protection Supervisor (TSC) implements the designated checklist if an onsite or offsite release has occurred."

9. Criterion 8.1.1.E.1.a requires that HP Technicians demonstrate the ability to obtain appropriate instruments and take surveys. Because the SEP changes the title of HP Technicians to RP Technicians, it is proposed to change criterion 8.1.1 .E. 1 .a to read, "RP Technicians demonstrate the ability to obtain appropriate instruments (range and type) and take surveys."
10. Criterion 8.1.1.E.3 requires the ability to assemble and deploy field monitoring teams within 60 minutes from the decision to do so. Because the SEP does not contain a commitment to deploy field monitoring teams within 60 minutes, it is proposed to change criterion 8.1.1.E.3 to read, "Demonstrate the ability to assemble and deploy field monitoring teams."
11. Criterion 8.1.1.E.3.a requires that one field monitoring team be ready to be deployed within 60 minutes of being requested from the OSC and no later than E16-8 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC 90 minutes from the declaration of an Alert or higher emergency. Because the SEP does not contain a commitment related to the timing of field team deployment, but does contain commitments related to the definition of readiness for field team deployment, it is proposed to change criterion 8.1.1 .E.3.a to read, "Field monitoring teams are briefed, obtain equipment, and are dispatched in accordance with EIPs."
12. Criterion 8.1.1.E.5.a requires that the HP/Chemistry Shared Foreman or the Does Assessment Supervisor perform timely and accurate dose projections in accordance with emergency implementing procedures (EIPs). Because the SEP has changed the titles and commitment for personnel performing dose projections, it is proposed to change criterion 8.1.1 .E.5.a to read, "Personnel with dose assessment expertise on-shift and in the EOF perform timely and accurate dose projections, in accordance with emergency implementing procedures (EIPs)."

The proposed changes to Unit 4 EP ITAAC 3.9.08.01.01 are shown in Enclosure 18.

Technical Evaluation - Unit 4 EP ITAAC E.3.9.08.01 .01 10 CFR 52.97(a)(2) requires that the Commission identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. Regulatory guidance for the content of EP ITAAC is found in NUREG-0800, Subsection 14.3.10, "Emergency Planning - Inspections, Tests, Analyses, and Acceptance Criteria." Generic EP ITAAC is presented in NUREG-0800, Table 14.3.10-1. Item 14.0, "Exercises and Drills," contains the generic EP ITAAC from which EP ITAAC E.3.9.08.01.01 was developed. The generic acceptance criteria states, "The exercise is completed within the specified time periods of Appendix E to 10 CFR Part 50, onsite exercise objectives have been met, and there are no uncorrected onsite exercise deficiencies. [The COL applicant will identify exercise objectives and associated acceptance criteria.]" The exercise objectives and associated acceptance criteria listed in EP ITAAC E.3.9.08.01 .01 are based on existing emergency plan commitments and approved objectives and supporting criteria used to evaluate NRC graded exercises. The revised E.3.9.08.01.01 criteria continue to be based on commitments in the SEP with a VEGP Units 3 and 4 Annex. Therefore, changing the supporting criterion as described above is acceptable.

Summary:

The proposed changes to the VEGP 3 and 4 EP ITAAC are in compliance with applicable emergency preparedness and ITAAC regulations, and meet the requirements of supporting regulatory guidance. The proposed changes do not affect the design of a system, structure, or component (SSC) used to meet the design bases of the nuclear plant. Nor do the changes affect the construction or operation of the nuclear plant. Therefore, based on the technical evaluation above and the regulatory analysis provided in Section 4.1 below, the proposed changes to the VEGP 3 and 4 Emergency Plan and EP ITAAC are acceptable.

E16-9 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC

3. Regulatory Evaluation 3.1 Applicable Regulatory Requirements/Criteria 10 CFR 52.97(a)(2) requires that the Commission shall identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. Based on the technical evaluations provided in Section 2 above, the proposed changes to the EP ITAAC continue to meet the requirements of 10 CFR 52.97(a)(2).

10 CFR 52.98(f) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL. This activity involves change to COL Appendix C, Inspections, Tests, Analyses, and Acceptance Criteria information; therefore, this activity requires a proposed amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this license amendment request.

3.2 Precedent No precedent is identified.

3.3 No Significant Hazards Consideration Determination The requested amendment will revise the plant-specific emergency planning inspections, tests, analyses, and acceptance criteria (ITAAC) in Appendix C of the VEGP Units 3 and 4 COLs to be consistent with proposed changes to the Vogtle Electric Generating Plant (VEGP) 3 and 4 Emergency Plan. There is no physical change to the plant itself.

An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

3.3.1 Does. the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The VEGP 3 and 4 emergency planning inspections, tests, analyses, and acceptance criteria (ITAAC) provide assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. The proposed changes do not affect the design of a system, structure, or component (SSC) used to meet the design bases of the nuclear plant. Nor do the changes affect the construction or operation of the nuclear plant itself, so there is no change to the probability or consequences of an accident previously evaluated. Changing the VEGP 3 and 4 emergency planning ITAAC does not affect prevention and mitigation of abnormal events (e.g., accidents, anticipated operational occurrences, earthquakes, floods, or turbine missiles) or their safety or design analyses. No safety-related structure, system, component (SSC) or function is adversely affected. The changes neither involve nor interface with any SSC accident initiator or initiating sequence of events, so the probabilities of the accidents evaluated in the Updated Final Safety Analysis Report (UFSAR) are not affected.

Because the changes do not involve any safety-related SSC or function used to El16-10 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC mitigate an accident, the consequences of the accidents evaluated in the UFSAR are not affected.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

3.3.2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The VEGP 3 and 4 emergency planning ITAAC provide assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. The changes do not affect the design of an SSC used to meet the design bases of the nuclear plant. Nor do the changes affect the construction or operation of the nuclear plant. Consequently, there is no new or different kind of accident from any accident previously evaluated. The changes do not affect safety-related equipment, nor do they affect equipment that, if it failed, could initiate an accident or a failure of a fission product barrier. In addition, the changes do not result in a new failure mode, malfunction, or sequence of events that could affect safety or safety-related equipment.

No analysis is adversely affected. No system or design function or equipment qualification is adversely affected by the changes. This activity will not allow for a new fission product release path, nor will it result in a new fission product barrier failure mode, nor create a new sequence of events that would result in significant fuel cladding failures.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The VEGP 3 and 4 emergency planning ITAAC provide assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. The changes do not affect the assessments or the plant itself. The changes do not adversely affect safety-related equipment or fission product barriers. No safety analysis or design basis acceptance limit or criterion is challenged or exceeded by the proposed change.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

3.4 Conclusion In conclusion, based on the considerations discussed above, 1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the propo~sed manner, 2) activities will be conducted in compliance with the Commission's regulations, and 3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Pursuant to 10 CFR 50.92, the requested change does not involve a Significant Hazards Consideration.

E16-11 6 to NL-15-1392 Evaluation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC

4. Environmental Assessment The requested license amendment provides proposed changes to the Vogtle Electric Generating Plant (VEGP) 3 and 4 emergency planning ITAAC. In accordance with 10 CFR 51, the following information is provided in support of a finding that the proposed changes have no significant effect on the quality of the human environment.

The VEGP 3 and 4 emergency planning ITAAC provide assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commission's rules and regulations. There is no physical change to the plant itself; and there is no effect on how a system, structure, or component (SSC) is used to meet the design bases of the nuclear plant. Nor is there an effect on the construction or operation of the nuclear plant.

SNC has determined that the proposed changes do not involve a significant hazards consideration.

(i) There is no significant hazards consideration.

As documented in Section 4.3, Significant Hazards Consideration Determination, of this license amendment request, an evaluation was completed to determine whether or not a significant hazards consideration is involved. The evaluation focused on the three standards set forth in 10 CER 50.92, "Issuance of amendment." As noted above, the proposed change will not affect how an SSC is used to meet the design bases of the nuclear plant. Nor is there an effect on the construction or operation of the nuclear plant.

The Significant Hazards Consideration determined that 1) the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated, 2) the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated, and 3) the proposed amendment does not involve a significant reduction in a margin of safety.

Therefore, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The requested amendment proposes changes to the VEGP 3 and 4 emergency planning ITAAC in Appendix C of the VEGP 3 and 4 COLs. As noted above, the proposed change will not affect how an SSC is used to meet the design bases of the nuclear plant.

Nor is there an effect on the construction or operation of the nuclear plant, as the changes to the VEGP 3 and 4 emergency planning ITAAC are needed to maintain consistency with proposed changes to the VEGP 3 and 4 Emergency Plan. The VEGP 3 and 4 emergency planning ITAAC are unrelated to any aspects of plant construction or operation that would introduce any changes to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, or other effluents) or affect any plant radiological or non-radiological effluent release quantities. Furthermore, these changes do not diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, the proposed amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

E16-12 6 to NL-15-1392 Evaiuation of Proposed Changes, VEGP 3 & 4 Emergency Plan ITAAAC (iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes to the VEGP 3 and 4 emergency planning ITAAC reflect conforming changes to the VEGP 3 and 4 Emergency Plan. As noted above, the proposed change will not affect how an SSC is used to meet the design bases of the nuclear plant. Nor is there an effect on the construction or operation of the nuclear plant.

Consequently, the changes to the VEGP 3 and 4 emergency planning ITAAC have no effect on individual or cumulative occupational radiation exposure during plant operation.

Therefore, the proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above review of the proposed amendment, it has been determined that anticipated construction and operational effects of the proposed amendment do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Consequently, the proposed amendment will not have a significant effect on the quality of the human environment.

El16-13

Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I, Hatch Nuclear Plant Units 1 and 2; Vogtle Electric Generating Plant Units I and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 17 Revision to Vogtle Unit 3 COL Appendix C Proposed Changes - Markups This enclosure contains 9 pages.

7 to NL-15-1 392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups Revision to Unit 3 COL Appendix C, Page C-457 and C-458 EP ITAAC E.3.9.01.01.01 (845)

Table E.3.9-1 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment Inspections, Tests, Analyses Acceptance Criteria 845 E.3.9.01.01.01 1.1 An emergency classification 1.1.1 An inspection of the control 1.1.1 The parameters specified and emergency action level (EAL) room, technical support center in UFSAR Table 7.5-1, Post-scheme must be established by the (TSC), and emergency operations Accident MonitoringSystem, licensee. The specific instruments, facility (EOF) will be performed are retrievable in the control parameters, or equipment status to verify' that the displays for room, TSC, and EOF. The shall be shown for establishing retrieving system ranges of values of these parameters that Table E.3.9-1 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment Inspections, Tests, Analyses Acceptance Criteria each emergency class, in the in- and effluent parameters specified can be displayed encompass plant emergency procedures. The in Table \'2 D.2 I, ot!..Ini~tiatig the values specified in the plan shall identify the parameter C-.onditio

,.v..,, 'latrix*,**,,

,.odcA .', -. 3,* emergency classification and values and equipment status for ,,'adI,; wTable, Y2*, D.,2 2*,' Coldt EAL scheme.

each emergency class. [D. 1] !ni:,iatin r-'onditio, Matrix, Mods 5,*5, anzd Do filddthe Southern Nuclear Operatine Company Standard Emereency Plan VEGP Units 3 and 4 Annex.

Appendix B. Emergency Action Level (EAL) Scheme, are installed and perform their intended functions; and that emergceny 846 Not Used El17-1 7 to NL-15-1 392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups Revision to Unit 3 COL Appendix C, Page C-460 and C-461 EP ITAAC E.3.9.06.00.01 (859 )

Table E.3.9-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment j Inspections, Tests, Acceptance Criteria 859 E.3.9.06.00.01 6.1 The means exists to provide 6.1 A test of the emergency plan 6.1 Using selected monitoring initial and continuing radiological will be conducted by performing parameters listed in UFSAR assessment throughout the course a drill to verify the capability to Table 7.5-1, Post-Accident Monitoring System, simulated

____________________________________________degraded

_________ plant Table E.3.9-6 Inspections, Tests, Analyses, and Acceptance Criteria

~o. I No. . I AAP Cr oN r a m C mmit m nt IAAC PrgramCommiment of an accident. [1.2]

] I n p e ctA lys es t s na InsectinsyTests perform accident assessment.

c e t n eCi ei cetneCiei conditions are assessed and protective actions are initiated in accordance with the following criteria:

A. Accident Assessment and Classijfication

1. Demonstrate the ability to identify initiating conditions, determine emergency action level (EAL) parameters, and correctly classify the emergency throughout the drill.

B. RadiologicalAssessment and Control

1. Demonstrate the ability to obtain onsite radiological surveys and samples.
2. Demonstrate the ability to continuously monitor and control radiation exposure to emergency workers.
3. Demonstrate the ability to assemble and deploy field monitoring teams-with*i 60 minutcz frcm thedaccbizn to 4eso.

El17-2 7 to NL-15-1 392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups Revision to Unit 3 COL Appendix C, Page3 C-466-469 EP ITAAC E.3.9.08.01.01 (870)

Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. IITAAC No. I Program Commitment Inspections, Tests, fAcceptance Criteria

_ _ II _ __ __ _ _ _ _ _ _ jAnalysesI _ _ _ _

events and their impact on the current conditions, within 15 minutes from the time the initiating condition(s) or EAL is identified.

B. Noti(fications

1. Demonstrate the ability to alert, notify, and mobilize site emergency response personnel.

Standard Criteria:

a. Complete the designated checklist-and pPerform the announcement within 10 minutes of the initial event classification for an Alert or higher.
b. Activate the emergency recall system within 10 minutes of the initial event classification for an Alert or higher.
2. Demonstrate the ability to notify responsible State and local government agencies within 15 minutes and notify_

the NRC immediately after the completion of the notification to the State and local authorities and no later than w4it60 minutes after declaring an emergency.

Standard Criteria:

a. Transmit information ttsing-accordance with approved emergency implementing procedures (EIPs), within 15 minutes of event classification.

E17-3 7 to NL-15-1392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups r V V

b. Transmit information *s~g accordance with approved EIPs, within 60 minutes of last transmittal for a follow-up notification to State and local authorities.
c. Transmit information u.sing~-

immediately after the completion of the notification to the State and local authorities and no later than wilii60 minutes of event Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment Inspections, Tests, Acceptance Criteria Analyses classification for an initial notification of the NRC.

3. Demonstrate the ability to warn or advise onsite individuals of emergency conditions.

Standard Criteria:

a. Initiate notification of onsite individuals (via plant page or telephone), usi,*g he-designated checklist within 15 minutes of notification.
4. Demonstrate the capability of the Prompt Notification System (PNS), for the public, to operate properly when required.

Standard Criteria:

a. 90% of the sirens operate properly, as indicated by the Whelen feedback system.
b. A National Oceanic and Atmospheric Administration (NOAA) tone alert radio is activated.

C. Emergency Response

1. Demonstrate the capability to direct and control

____ ____________emergency operations.

El17-4 7 to NL-15-1 392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups Standard Criteria:

a. Command and control is demonstrated by the control room in the early phase of the emergency and the technical support center (TSC) and the emergency offsite facility (EF)within 75_60 minutes 4ieftl-followinu declaration of an Alert or higher classification.TSC act*'vatkcn.
2. Demonstrate the ability to transfer emergency direction from the control room (simulator) to the TSC and EOF. wit!*hin 30 minu*tes from Standard Criteria:
a. Briefings were conducted prior to turnover responsibility. Personn~eb
3. Demonstrate the ability to prepare for around-the-clock staffing requirements.

Standard Criteria:

a. Complete 24-hour staff assignments.
4. Demonstrate the ability to perform assembly and accountability for all eonsi*e individuals located within the protected area within 30 minutes of an emergency requiring protected area assembly and accountability.

Standard Criteria:

a. Protected area personnel assembly and accountability completed within 30 minutes of the Ale Site Area Emergtency~ or higher emergency declaration via public address announcement.

D. Emergency Response Facilities

1. Demonstrate activation of the operational support center (OSC), and full functional operation of the TSC and EOF within 60 75 minutes El17-5 7 to NL-15-1 392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups followingt declaration of an Alert or higher classification.

Standard Criteria:

a. The TSC, OSC, and EOF are activated within e-ine:iqiationi75 minutes of an Alert or hig~her declaration.
2. Demonstrate the adequacy of equipment, security provisions, and habitability precautions for the TSC, OSC, EOF, and ioint information center (JIC), emergency news

...... ef..... as appropriae.

Standard Criteria:

a. Demonstrate the adequacy of the emergency equipment in the emergency response facilities, including availability and general consistency with emergency implementing procedures (EIPs).
b. The Security Shift Captain implements and follows applicable EIPs.
c. The Radiation Protection H~ealth-Phys.ie* Supervisor (TSC) implements the designated checklist if an onsite or offsite release has occurred.
d. Demonstrate the capability of TSC and EOF equipment and data displays to clearly identify and reflect the affected unit.
3. Demonstrate the adequacy of communications for all emergency support resources.

Standard Criteria:

a. Emergency response communications listed in emergency implementing procedures (EIPs) are available and operational.
b. Communications systems are tested in accordance with TSC, OSC, and EOF El17-6 7 to NL-15-1392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups activation checklists.
c. Emergency response facility personnel are able to operate all specified communication systems.
d. Clear primary and backup communications links are established and maintained for the duration of the exercise.

E. RadiologicalAssessment and Control

1. Demonstrate the ability to obtain onsite radiological surveys and samples.

Standard Criteria:

a. RP l=i,-Technicians demonstrate the ability to obtain appropriate instruments (range and type) and take surveys.
b. Airborne samples are taken when the conditions indicate the need for the information.
2. Demonstrate the ability to continuously monitor and control radiation exposure to emergency workers.

Standard Criteria:

a. Emergency workers are issued self-reading dosimeters when radiation levels require, and exposures are controlled to 10 CFR Part 20 limits (unless the Emergency Director authorizes emergency limits).
b. Exposure records are available, either from the ALARA computer or a hard copy dose report.
c. Emergency workers include Security and personnel within all emergency facilities.
3. Demonstrate the ability to assemble and deploy field monitoring teams-wtit 60 r,,mintcz from the decision, Standard Criteria:

E17-7 7 to NL-15-1392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups than 90 minutez from the higher emergency. Field monitorine teams are briefed.

obtain equipment, and are dispatched in accordance with EIPs.

4. Demonstrate the ability to satisfactorily collect and disseminate field team data.

Standard Criteria:

a. Field team data to be collected is dose rate or counts per minute (cpm) from the plume, both open and closed window, and air sample (gross/net cpm) for particulate and iodine, if applicable.
b. Satisfactory data dissemination is from the field team to the Dose Assessment Supervisor, via the field team communicator and field team coordinator.
5. Demonstrate the ability to develop dose projections.

Standard Criteria:

a. The-etn-shift Personnel with dose assessment expertise on-shift and in the OEO c*ape....4sef°* performs timely and accurate dose projections, in accordance with emergency implementing procedures (EIPs).
6. Demonstrate the ability to make the decision whether to issue radioprotective drugs (KI) to emergency workers.

Standard Criteria:

a. KI is taken (simulated) if the estimated dose to the i thyroid will exceed 25 rem

~committed dose equivalent (CDE).

____________________________ ___________7.__Demonstrat7eDemnstraeathlabiltytt E17-8 7 to NL-15-1392 Revision to VEGP Unit 3 COL Appendix C - Proposed Changes - Markups develop appropriate protective action recommendations (PARs) and notify appropriate authorities within 15 minutes of development.

Standard Criteria:

a. Total effective dose equivalent (TEDE) and CDE dose projections from the dose assessment computer code are compared to emergency implementing procedures (EIPs).

F. Public Information

1. Demonstrate the capability to develop and disseminate clear, accurate, and timely information to the news media, in accordance with EIPs.

Standard Criteria:

a. Media information (e.g.,

press releases, press briefings, electronic media) conceniin*

events, conditions, and actions is made available ...........

m*n utc3 of notification of thc

! tpr....e...at a minimum,

2. Demonstrate the capability to establish and effectively operate rumor control in a coordinated fashion.

Standard Criteria:

a. Calls are answered in a timely manner with the correct information, in acco~rdance E17-9

Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I. Hatch Nuclear Plant Units I and 2; Vogtle Electric Generating Plant Units I and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 18 Revision to Vogtle Unit 4 COL Appendix C Proposed Changes - Markups This enclosure contains 9 pages.

8 to NL-15-1392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Revision to Unit 4 COL Appendix C, Page C-457 and C-458 EP ITAAC E.3.9.01.01.01 (845)

Table E.3.9-1 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment Inspections, Tests, Analyses Acceptance Criteria 845 E.3.9.01.01.01 1.1 An emergency classification 1.1.1 An inspection of the control 1.1.1 The parameters specified and emergency action level (EAL) room will be performed to verify in UFSAR Table 7.5-1, Post-scheme must be established by the that the displays for retrieving Accident Monitoring System, licensee. The specific instruments, system and effluent parameters are retrievable in the control parameters, or equipment status specified in Table 'V2 D.2 1, !'nt room. The ranges of values of shall be shown for establishing .,niti,,t-ing,;-

C..anditi.,,,n, these parameters that can be Table E.3.9-1 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment Inspections, Tests, Analyses Acceptance Criteria each emergency class, in the in- ,

M.atrix*,, ,M.des1.., 2,*3,*and'!; displayed encompass the plant emergency procedures. The Table*,w'/2 D.2r 2 , Col Ini*tia,.,,.-,,ting";

values specified in the plan shall identify the parameter ('onddit: n A!utrix, Mfodes .5. 6, and~emergency classification and values and equipment status for rDe- ]l.ekd-*the Southern Nuclear EAL scheme.

each emergency class. [D. I] Operating Company Standard Emergency Plan VEGP Units 3 and 4 Annex, Appendix B, Emergency A4ction Level (IEl L)

Schemue are installed and perform their intended functions;-and 4at-846 Not used E18-1 8 to NL-t5-1392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Revision to Unit 4 COL Appendix C, Page C-463 EP ITAAC E.3.9.06.00.01 (859)

Table E.3.9-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment Inspections, Tests, Acceptance Criteria 859 E.3.9.06.00.01 6.1 The means exists to provide 6.1 A test of the emergency plan 6.1 Using selected monitoring initial and continuing radiological will be conducted by performing parameters listed in UFSAR assessment throughout the course a drill to verify the capability to Table 7.5-1, Post-Accident of an accident. [1.2] perform accident assessment. Monitoring System, simulated degraded plant conditions are assessed and protective actions are initiated in accordance with the following criteria:

A. Accident Assessment and Classification

1. Demonstrate the ability to identify initiating conditions, determine emergency action level (EAL) parameters, and correctly classify the emergency throughout the drill.

B. RadiologicalAssessment and Control 1, Demonstrate the ability to obtain onsite radiological surveys and samples.

2. Demonstrate the ability to continuously monitor and control radiation exposure to emergency workers.
3. Demonstrate the ability to assemble and deploy field monitoring teams w~i~

60mi-ts fz he.ezint El18-2 8 to NL-15-1392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Revision to Unit 4 COL Appendix C, Pages 0-468-473 EP ITAAC E.3.9.08.01.01 (870)

Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria IITAAC No. I Inspections, Tests, IAcceptance Criteria No.

____I

__ I___

Program Commitment

___ ___ ____ ___ ___ ___ _ jAnalyses_ _ _ _ _ _ _ _ _ _ _ _

870 E.3.9.08.01 .01 8.1 The licensee conducts a limited 8.1 A limited participation 8.1.1 The exercise is participation exercise to evaluate exercise (test) will be conducted completed within the specified portions of emergency response within the specified time periods time periods of Appendix E to capabilities, which includes of 10 CFR Part 50, Appendix E. 10 CFR Part 50, onsite participation by each State and local exercise objectives listed agency within the plume exposure EPZ below have been met and that have not been tested in a previous there are no uncorrected onsite exercise. [N.I] exercise deficiencies.

A. Accident Assessment and Classification

1. Demonstrate the ability to identify initiating conditions, determine emergency action level (EAL) parameters, and correctly classify the emergency throughout the exercise Standard Criteria:
a. Determine the correct highest emergency classification level based on events which were in progress, considering past events and their impact on the current conditions, within 15 minutes from the time the initiating condition(s) or EAL is identified.

B. Noti~fications

1. Demonstrate the ability to alert, notify, and mobilize site emergency response personnel.

Standard Criteria:

a. Ccmpletc the designated eheeklizt and pPerform the announcement within 10 minutes of the initial event classification for an Alert or higher.
b. Activate the emergency E18-3

Enclosure 18 to NL-15-1392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria

[No.1 ITAAC No. Program Commitment Inspections, Tests, Acceptance Criteria L Ij LI_ __

_Analyses_ _ _

~~recall system withinintaevt classification for an Alert or Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. IITAAC No. [ Program Commitment Inspections, Tests, [Acceptance Criteria

_ _ _ _ _ _ _ _ _Analyses___

higher.

2. Demonstrate the ability to notify' responsible State and local government agencies within 15 minutes and notify the NRC immediately after the completion of the notification to the State and local authorities and no later than wi4160 minutes after declaring an emergency.

Standard Criteria:

a. Transmit information is*g the dczign.ated checkzlizt, in accordance with approved emergency implementing procedures (EIPs), within 15 minutes of event classification.
b. Transmit information ,isiaig-the dezign*ated checkib*t, in accordance with approved EIPs, within 60 minutes of last transmittal for a follow-up notification to State and local authorities.
c. Transmit information i~fg tthi deigntzdlll cheli~tll immediately after the completion of the notification to the State and local authorities and no later than whii60 minutes of event classification for an initial notification of the NRC.
3. Demonstrate the ability to warn or advise onsite I. ___________________________________ L L El18-4 8 to NL-1 5-1 392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. IITAAC No. I Program Commitment 1 Inspections, Tests, 1Acceptance Criteria

_ _ II _ _ __ _ _ _ _ _ _ _ jAnalyses _ _ _ _

individuals of emergency conditions.

Standard Criteria:

a. Initiate notification of onsite individuals (via plant page or telephone), "t°:ii,,,g h,,-

dez:gnated c.heckiz within 15 minutes of notification.

C. Emergency Response

1. Demonstrate the capability to direct and control emergency operations.

Standard Criteria:

a. Command and control is demonstrated by the control room in the early phase of the emergency and by the technical support center (TSC) and the enmergency offsite facility (EOF) within 6075 minutes following the declaration of an Alert or higher classification. 4rm
2. Demonstrate the ability to transfer emergency direction from the control room (simulator) to the TSC and EOF. within 30 min'utc* from Standard Criteria:
a. Briefings were conducted prior to turnover responsibility7 -Perserniel-
3. Demonstrate the ability to prepare for around-the-clock staffing requirements.

Standard Criteria:

a. Complete 24-hour staff assignments.
4. Demonstrate the ability to perform assembly and accountability for all ensit-e individuals located within the E18-5 8 to NL-15-1392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment I Inspections, Tests, Acceptance Criteria

__ _ _ _I Analyses I_

protected area within 30 minutes of an emergency requiring protected area assembly and accountability.

Standard Criteria:

a. Protected area personnel assembly and accountability completed within 30 minutes of the Alee4 Site Area Emergency or higher emergency declaration via public address announcement.

D. Emergency Response Facilities I. Demonstrate timely activation of the operational support center (OSC).

Standard Criteria:

a. The OSC is activated within about 60-7_5_5minutes following declaration of an Alert or higher classification. ef-ht-
2. Demonstrate the adequacy of equipment, security provisions, and habitability precautions for the OSC, as appropriate.

Standard Criteria:

a. Demonstrate the adequacy of the emergency equipment in the emergency response facilities, including availability and general consistency with emergency implementing procedures (Elas).
b. The Security Shift Captain implements and follows applicable EIPs.
c. The Radiation Protection H=ea4th Phy~ies-Supervisor (TSC) implements the designated checklist if an onsite or offsite release has occurred.

I I J El18-6 8 to NL-15-1 392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No.

IJ _ _ _ __

Program Commitment IjAnalyses Inspections, Tests, IAcceptance I Criteria

3. Demonstrate the adequacy of communications for all emergency support resources.

Standard Criteria:

a. Emergency response communications listed in emergency implementing procedures (EIPs) are available and operational.
b. Communications systems are tested in accordance with OSC activation checklist.
c. Emergency response facility personnel are able to operate all specified communication systems.
d. Clear primary and backup communications links are established and maintained for the duration of the exercise.

E. RadiologicalAssessment and Control

1. Demonstrate the ability to obtain onsite radiological surveys and samples.

Standard Criteria:

a.RP_-44ta Technicians demonstrate the ability to obtain appropriate instruments (range and type) and take surveys.

b. Airborne samples are taken when the conditions indicate the need for the information.
2. Demonstrate the ability to continuously monitor and control radiation exposure to emergency workers.

Standard Criteria:

a. Emergency workers are issued self-reading dosimeters when radiation levels require, and exposures are controlled to 10 CFR Part 20 limits (unless the Emergency Director authorizes emergency

.1. 1 ___________________________________ £ A -

E18-7 8 to NL-1 5-1 392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. IITAAC No. I Program Commitment I Inspections, Tests, JAcceptance Criteria

_ II _ _ _ _ _ _ _ _ _ _ IAnalyses_ _ _ _

limits).

b. Exposure records are available, either from the ALARA computer or a hard copy dose report.
c. Emergency workers include Security and personnel within all emergency facilities.
3. Demonstrate the ability to assemble and deploy field monitoring team*-wj4**~n 60 minute: from the dee!izin Standard Criteria:
a. One field monitoring team 60 minute: zfheine" reauested hi, he

......... ...n ._Field monitoring teams are briefed, obtain equipment. and are dispatched in accordance with ElIPs

4. Demonstrate the ability to satisfactorily collect and disseminate field team data.

Standard Criteria:

a. Field team data to be collected is dose rate or counts per minute (cpm) from the plume, both open and closed window, and air sample (gross/net cpm) for particulate and iodine, if applicable.
b. Satisfactory data dissemination is from the field team to the Dose Assessment Supervisor, via the field team communicator and field team coordinator.
5. Demonstrate the ability to develop dose projections.

Standard Criteria:

a. The-efn-.514f Personnel I __________ I __________________________ L _____________________ I E18-8 8 to NL-15-1 392 Revision to VEGP Unit 4 COL Appendix C - Proposed Changes - Markups Table E.3.9-8 Inspections, Tests, Analyses, and Acceptance Criteria No. IITAAC No. I Program Commitment I Inspections, Tests, Acceptance Criteria

_ II J ~ Analyses_ _ _ _

with dose assessment expertise on-shift and in the EOF HP/Chemiztry Shared Foreman or Doze Azzezzmenzt Stlpef,'4ser performs timely and accurate dose projections, in accordance with emergency implementing procedures (EIPs).

6. Demonstrate the ability to develop appropriate protective action recommendations (PARs) and notify' appropriate authorities within 15 minutes of development.

Standard Criteria:

a. Total effective dose equivalent (TEDE) and CDE dose projections from the dose assessment computer code are compared to emergency implementing procedures (EIPs).
b. PARs are developed within 15 minutes of data availability.
c. PARs are transmitted to responsible State and local government agencies via voice or fax within 15 minutes of PAR development.

E18-9

Southern Nuclear Operating Company Joseph M. Farley Nuclear Plant Units 1 and 2; Edwin I. Hatch Nuclear Plant Units 1 and 2; Vogtle Electric Generating Plant Units 1 and 2; Vogtle Electric Generating Plant Units 3 and 4 Enclosure 19 Off-site Response Organizations Letters of Consultation and Concurrence This enclosure contains 35 pages.

STAT E OF ALAB-AMA DEPXRT_'MENTOF PUDBL iC H EfAL T Stat~e H-ealth,.Oficer'q*"

August 11, 2015 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Mansfield This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with Alabama Department of Public Health/Office of Radiation Control staff members in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

R .O.IB,*tx 2 i 7

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Alabama Department of Public Health/Office of Radiation Control concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Alabama.

Please consider this letter as a written indication of Alabama Department of Public Health/Office of Radiation Control concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

SincerelyW ,

Tonya Appleyard, Director Emergency Planning Branch Office of Radiation Control Alabama Department of Public Health The. RSA Tower° 201 Monroe Streer . Montgomery,, Al 36101 P.O. Box 303017" Montgomnery, Al 36130-3017

AIKEN COUNTYEM Department or Emergency Services GN a Emergency Management Division F 1930oU,,iversityP.rkway, Suite 1100 MANAGEMENT 1.,~l*/

Aiken, South Carolina, 29801 AIKEN COUNTY Telephone: (893) 642-1623 FAX: (803) 642.25*56 August 11, 2015 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.

P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtfe Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with Aiken County, South Carolina Emergency Management in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency.

Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear

Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency pran would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained arnd prepared to transition to the new emergency plan.

Aiken County Emergency Management concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a furl review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Aiken County.

Please consider this letter as a written indication of Aiken County Emergency Management's concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Sincerely,_

Paul Matthews Interim Emergency Management Coordinator Aiken County Emergency Management Division 2

EMERGENCY MANAGEMENT AGENCY

~STATE 5898 COUNTY OF ALABAMA ROAD 41

  • P.O. DRAWER 2160
  • CLANTON, ALABAMA 35046-2160 Wtk Op(205") 280-2200 FAX # (205) 280-2495; ROBERT BENTLEY ART FAULKNER GOVERN*OR DIRECTOR Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.

P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 August 21, 2015

Dear Mr. Meier:

This letter is in response to the request from Southern Nuclear Operating Company, hereafter" referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met With Alabama Emergency Management Agency (AEMA) in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency resPonse personnel augmentation time, standardization of Southern Nuclear Fleet pOsition titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to *better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with cur~rent regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents Such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

AEMA concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of the State of Alabama.

Please consider this letter as a Written indication of AEMA's concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtte Units 3 and 4.

Sind~rely1 t2 .- /

Director of Response Operations (205) 280-2262 Office (205) 746-511I3 Cell tim.payne~erna.alabama~gov

Gidget L. Stanley-Banks, Director William Robinson Jr'., Asst. Director 911-B Main Street North Allen dale, South Carolina 29810 A 803-584-4081 - Phone 803-584-3807 - Fax

-S August 7, 2015 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.

P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with Allendale County Emergency Management in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans, and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-

site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Allendale County Emergency Management concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Allendale County.

Please consider this letter as a written indication of Allendale County Emergency Management concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Thanks, Gidget L. Stanley-Banks 0 Page 2

Post Orfice Box 747 DANE BRUCE B3AXLEY, GEORGIA 31515 DARRELL HOLCOMB Director Telephone (91!2) 367-8170 Deput, Director a~cema@bellsouth.net Mr. ike eierAugust 20, 2015 Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham,-AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant VogUe Units 1 and 2 and Plant VogUe Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with our (Appling County Emergency Management Agency) in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

(Appling County Emergency Management Agency) concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of (Appling County Emergency Management Agency.)

Please consider this letter as a written indication of (Appling County Emergency Management Agency) concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units R *ine 4

Appling County Emergency Management Agency

i1 August, 201 5 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway lBirmingham, AL 35201

Dear Mr. Meier,

This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with Barnwel! County Emergency Management in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Barnwell County Emergency Management concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans.

We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Barnwell County.

Please consider this letter as a written indication of Rarnwell County Emergency Managements concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Sincerely,

'~.Roger Riey Drctor Barnwell County Emergency Management 57 Wall Street Barnwell, SC 29812 Office 1 -803-259-7013 Fax - 803-259-1759 Cell - 803-541-2013

(Bur&County cErergency §AManagement Agency Fire 277 Highway 24 South EA'S

~Waynesboro, Georgia 30830

~Tel. (706) 554-665 I Fax (706) 554-4660 E-Mail: rsanders~burkecounty-ga.go\'

Dedicated To The Protection Of Lifre And Property Rusty Sanders - chief August 21, 2015 Mr. Mike Meier, Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc Post Office Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier; This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 & 2 and Plant Vogtle Units 3 & 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with our Burke County Emergency Management Agency in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southemn Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

8.21.2015 Letter from Burke County EMA Page 2 of 2 Burke County Emergency Management Agency concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Burke County, Georgia.

Please consider this letter as a written indication of Burke County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 & 2, and Plant Vogtle Units 3 & 4.

Sincerely, RustSanersDirector Burke County Emergency Management Agency

Bnurk County

§Emergency ]IanagementAgency Fire 277 Highway 24 South EMS

~Waynesboro, Georgia 30830 Tel. (706) 554-6651 Fax (706.) 554-4660 E-Mail: rsanders@burkecounty-ga.gov Dedicated To The Protection Of Lift, And Property Rusty Sanders - Chief August 21, 2015 Mr. Mike Meier, Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc Post Office Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier; This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 & 2 and Plant Vogtle Units 3 & 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with our Burke County Emergency Management Agency in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new~emergency plan.

8.21.2015 Letter from Burke County EMA Page 2 of 2 Burke County Emergency Management Agency concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Burke County, Georgia.

Please consider this letter as a written indication of Burke County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 & 2, and Plant Vogtle Units 3 & 4.

Sincerely, Rusty *anders, Director Burke County Emergency Management Agency

Blakely-Early County Emergency Management Ray Jarrett, CEM.

P.O. Box 726 - i861o East South Blvd.

Blakely, Ga. 39823 Phone: 229-723-3029 / Fax: 229-723-5908 E-Mail- becema@windstream.rnet Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201

Dear Mr. Meier,

This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with our Early County Emergency Management in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change In the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Early County Emergency Management concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Early County.

Please consider this letter as a written indication of Early County Emergency Management's concurrence with the Southern Nuclear proposal to establish a common emergency plan for Piant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

E ty EMADirector

Georgia Department of Natural Resources Environmental Protection Division, Air Protection Branch 4244 International Parkway, Suite 120, Atlanta, Georgia 30354 404-363-7000 Judson H. Turner, Director August 20, 2015 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc.

P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201

Dear Mr. Meier,

This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with staff from the Georgia Department of Natural Resources, Environmental Protection Division, Environmental Radiation Program in the summer of 2,015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan.

This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission.

Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

The Georgia Department of Natural Resources, Environmental Protection Division, Environmental Radiation Program concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of the State of Georgia.

Please consider this letter as a written indication of the Georgia Department of Natural Resources, Environmental Protection Division, Environmental Radiation Program's concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Sincerely, Sidney B. Simonton Environmental Compliance Specialist Environmental Radiation Program

GEORGIA EMERGENCY MANAGEMENT AGENCY GEORGIA OFFICE OF HOMELAND SECURITY NATHAN DEAL JIM BUTTERWORTH GovERNOR DIRECTOR August 25, 2015 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201

Dear Mr. Meier:

This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with Georgia Emergency Management Agency/Homeland Security (GEMA/HS) Radiological Preparedness Program (REP) staff in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to the layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergencY plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Post Office Box 18055

  • Atlanta, GA 30316-0055 (404) 635-7000 ° Toll Free in Georgia 1-800-TRY-GEMA
  • www.gema.ga.gov

Mr. Mike Meier Page Two August 25, 2015 GEMA/HS concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Georgia.

Please consider this letter as a written indication of GEMAiI-S's concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Sincerely, Stephen Car Program Director Radiological Emergency Preparedness

/sc

Henry county EMA P.O. Box 636 Abbeville, Al 36310 334-585-6702 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with our Henry County EMA in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Henry County EMA concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to

requestbyathe plans full Nuclear review and approval Commission Regulatory of the proposed changes to ensure thetoSouthern the Southern Nuclear emergency Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Henry County Alabama.

Please consider this letter as a written indication of Henry County EMA's concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Ronakd Dollar Director

August 11, 2015 Mr. Mike Meier Dothan/Houston County Vice President Regulatory Affairs Emergency Management Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Steve Carlisle Director

Dear Mr. Meier:

This fetter is in response to the request from Southern Nuclear Leigh Adams Operating Company, hereafter referred to as Southern Nuclear, for Deputy Director written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtue Units 1 and 2 and Plant Vogtle Units 3 Charles Finney and 4 emergency plans into a single common emergency plan with P1lannin2/Communications site specific annexes to address emergency plan elements unique to the specific sites.

Kris Ware Support/PLO A member of the Southern Nuclear Emergency Preparedness staff met with Dothan/Houston County EMA in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

P.O. Drawer 6406 Southern Nuclear discussed with our staff how the proposed Dothan, Alabama 36302 consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern (Phone) 334.794.9720 Nuclear's emergency response efforts to better leverage Southern (Fax) 334.793.3550 Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission.

Page 2 Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Dothan/Houston County EMA concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Dothan and Houston County.

Please consider this letter as a written indication of Dothan/Houston County EMA's concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Sincerely,

/ A.*

Steve F. Carlisle Director

~~JEFFT -AVIS-COUNTY- , 34=

EMERGENCY MANAGEMENT AGENCY iF.l 10 PUBLIC SAFETY DRIVE I t HAZLEHURST, GEORGIA 31539 CHARLES WAS DIN KATHY W. LORD DIRECTOR CLERK PHONE (912) 375-6628 August 18, 2015 Mr. Mike Meier Vice-President Regulatory Affairs Southern Nuclear Operating Company, Inc.

P. O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201

Dear Mr. Meier:

This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2, and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with Jeff Davis County Emergency Management Agency in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included, but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that that the proposed changes are consistent with current regulatory requirements and applicable guidance; however, they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the

Nuclear Regulatory implementation Commission.

of the Southern Nuclear also informed our staff that new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Jeff Davis County Emergency Management Agency concurs with Southern Nuclear's assessment of the benefits of the proposed changed to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Jeff Davis County.

Please consider this letter as a written indication of Jeff Davis County Emergency Management Agency concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2, and Plant Vogtle Units 3 and 4.

Charles Wasdin, Director Emergency Management Agency Jeff Davis County

P ROM OTE P ROTE.CT P ROSPE R W. Mairshali Taylor Jr., Acting Director J~romatingand'protecting the health of*the public anti the environlment Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201

Dear Mr. Meier:

This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan; with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with the South Carolina Department of Health and Environmental Control (SCDHEC) in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included, but was not limited to, layout and format of the Southern Nuclear emergency plan base document and site specific annexes; reduction in level of detail of the overall content of the plan consistent with a planning level document; proposed changes to on-shift and augmented emergency response personnel staffing; proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties; and proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

SCDHIEC concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans.

We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of South Carolina.

Please consider this letter as a written indication of the SCDHEC concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units I and 2 and Plant Vogtle Units 3 and 4.

Chris Staton, Director SCDHEC Division of Emergency Response SOU'TH- CAROLINA DEPARTMENT OF ttEALTFH AND ENVIRONMENTAL CONTROL 2600 Bull Strcet

  • Columbia. SCO9,201 Phxone:(803) 898-"3432 *www.scdhcc.gov

OFFICE OF THE ADJUTANT GENERAL ROBE*RTE. LIVINGSTON..Jr.- -

MAJOR GENERAL August 25, 2015 THE ADJUTANT GENERAL Mr. Mike Meier Vice.President Regul!atory ,,ithirs South*erm Nuclear:Operating Company, [tic P.O. Box 1295 42 linverness C.'enter Parkway Birmrninlten, AL. 35201

Dear Mr. Meie'r:

"Vhis letter is inl response to the recluesi from Southern Nuclear Op~erating. C'ompany, hereafter referred to as Southern Nuclear. for written concurrence on the proposal to consolidate die Plhnt Farley, Plant Hatch.

Plant Vog~tle Units 1 and 2 and Plant Vogtle Units 3 .and 4 emergency plans into, a single common emnergency plan with site speciftic annexes to address-emergency plan elements unique to the specific sites.

Scott (:dora, a member of the Southern Nuclear Emergency Preparedness staff miet with the Fixed Nuclear IFacility Section of the South Carolinia EmergencyM'nliagement Divis ioiu (SCEMD) August 4, 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emer~gency plan.

SCEMD concurs 'with Southern Nuclear .assessment of the: benefits of the proposed chan~ges to their emerg~ency plans.. We also agree tlat it is appropriate and prude.nt to requcvt ai fufl revie,.V and appr~ova~l of" the,proposed chlanges to t~e. Southern Nuclearemnergency plans by the N.uclear; Regulatory C'ommission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ,ability to protect the safety and. health of the citizenis of South Ca~rolina.

Please consider this letter as a written indication 'of.SCEMD concurrence with the Southern Nuclear proposal tO estahilish a cotmfun emergency plan for Plan~t Farley. Plant Hatch, Plant Vogtle Unils I :and 2 and Plant Vogtle Units 3 and 4..

Sincerely, Kim Stenson Director KS/jlt Emergency Management Division 2779 Fish Hatc~hesy Road West Columbia, South Carolina 29172 (803) 737-8500 * (803) 737-8570

~~NT Op~

~- ~*\ ~ Department of Energy Q Savannah River Operations Office C~1 P.O. Box A Aiken, South Carolina 29802

~'1TES O~ ~'

AUG 2 52015 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201

Dear Mr. Meier:

SUBJECT:

Department of Energy-Savannah River Operations (DOE-SR) Acknowledgement of Changes to Southern Nuclear Operating Company's Emergency Plan The Department of Energy-Savannah River Operations (DOE-SR) has received the Draft Standard Emergency Plan, Rev 0 for Southern Nuclear Operating Company and the accompanying Annexes for Vogtle Electric Generating Plant Units 1-4. The changes to the Plan were briefed at the August 13, 2015 SRS/Plant Vogtle Quarterly Issues Meeting.

After reviewing the Plan and Annexes, DOE-SR acknowledges there are no changes that will impact the operations or emergency preparedness at the Savannah River Site.

If you have any questions, please contact Ms. Clarissa Waller of my staff at (803) 952-8531.

Sincerely, Office of Safeguards, Security anid OSSES-1 5-049 Emergency Services cc: E. Szymanski, SR, 730-2B M. Delmore, SR, 730-2B C. Edwards, NNSA, 730-4B M. Lepard, SRNS, 703-45A D. Foutch, SRNS, 703-45A

Tattnall County EMA Walt D. Rogers, Director POB 905 194 John 0. Parker Drive Office: (912) 557-6820 Reidsville, GA. 30453 Fax: (912) 557-6937 tattnaliema~dwindstrean~net August 14, 2015 Mr. Mike Meier Vice President Regulatory Affairs Southern Nuclear Operating Company, Inc P.O. Box 1295 42 Inverness Center Parkway Birmingham, AL 35201 Dear Mr. Meier This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with Tattnall County Emergency Management Agency in the summer of 2015 and discussed this proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with a planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination of public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable Page 1

guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff .that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Tattnall County EMA concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by the Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Tattnall County.

Please consider this letter as a written indication of Tattnall County concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Units 1 and 2 and Plant Vogtle Units 3 and 4.

Sincerely, eA&*

Walt D. Rogers, Director Tattnall County EMA Page 2

Toombs County Emergency Management Agency P.O Box 487 Lyons, Georgia 30436 Dear Mr. Meier This letter is in response to the request from Southern Nuclear Operating Company, hereafter referred to as Southern Nuclear, for written concurrence on the proposal to consolidate the Plant Farley, Plant Hatch, Plant Vogtle Unit 1 and 2 and Plant Vogtle Unit 3 and 4 emergency plans into a single common emergency plan with site specific annexes to address emergency plan elements unique to the specific sites.

A member of the Southern Nuclear Emergency Preparedness staff met with our Toombs County EMA in the summer of 2015 and discussed the proposal in detail and allowed us to provide feedback on the proposed fleet standard emergency plan. This discussion included but was not limited to layout and format of the Southern Nuclear emergency plan base document and site specific annexes, reduction in level of detail of the overall content of the plan consistent with planning level document, proposed changes to on-shift and augmented emergency response personnel staffing, proposed changes to emergency response personnel augmentation time, standardization of Southern Nuclear Fleet position titles and duties, proposed changes to dissemination to public information, etc.

Southern Nuclear discussed with our staff how the proposed consolidation of the Southern Nuclear emergency plans and the changes contained therein will serve to standardize Southern Nuclear's emergency response efforts to better leverage Southern Nuclear resources to respond in the unlikely event of a radiological emergency. Southern Nuclear also informed our staff that the proposed changes are consistent with current regulatory requirements and applicable guidance however they constitute a significant change in the Southern Nuclear emergency plan documents such that they will submit the new emergency plan for full review and approval by the Nuclear Regulatory Commission. Southern Nuclear also informed our staff that implementation of the new Southern Nuclear fleet standard emergency plan would not occur until final approval was received from the Nuclear Regulatory Commission and on-site and off-site stakeholders were properly trained and prepared to transition to the new emergency plan.

Toombs County EMA concurs with Southern Nuclear's assessment of the benefits of the proposed changes to their emergency plans. We also agree that it is appropriate and prudent to request a full review and approval of the proposed changes to the Southern Nuclear emergency plans by Nuclear Regulatory Commission to ensure the Southern Nuclear emergency plan continues to provide reasonable assurance of their ability to protect the safety and health of the citizens of Toombs County.

Please consider this letter as written indication of Toombs County EMA concurrence with the Southern Nuclear proposal to establish a common emergency plan for Plant Farley, Plant Hatch, Plant Vogtle Unit 1 and 2 and Plant Vogtle Unit 3 and 4.

Lynn Moore, Director / Toombs County EMA

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