ML16096A217

Joseph M. Farley, Units 1 and 2; Edwin I. Hatch, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 - Request for Additional Information (CAC Nos. MF6670, MF6671, MF6672, MF6673, MF6674, MF6675, and RP9516)

ML16096A217
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	04/14/2016
From:	Williams S A Plant Licensing Branch II
To:	Pierce C R Southern Nuclear Operating Co
Williams S, NRR/DORL/LPL2-1
References
CAC MF6670, CAC MF6671, CAC MF6672, CAC MF6673, CAC MF6674, CAC MF6675, CAC RP9516
Download: ML16096A217 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 14, 2016 Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc. P.O. Box 1295, Bin 038 Birmingham, AL 35201-1295 SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2; EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2; AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 -REQUEST FOR ADDITIONAL INFORMATION (CAC NOS. MF6670, MF6671, MF6672, MF6673, MF6674, MF6675, AND RP9516) Dear Mr. Pierce: By letter dated August 31, 2015, Southern Nuclear Operating Company, Inc. (SNC) submitted a license amendment request for the Joseph M. Farley Nuclear Plant, Units 1 and 2; Edwin I. Hatch Nuclear Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4. The amendment requests U.S. Nuclear Regulatory Commission (NRC) approval of a standard emergency plan for all SNC sites and site-specific annexes. The NRC staff has determined that additional information is needed as listed in the enclosure. We request that SNC respond within 60 days of the date of this letter. Please note that the NRC staff's review is continuing, and further RAls may be developed. If you have any questions, please contact me at (301) 415-1009 or Shawn.Williams@nrc.gov. Docket Nos. 50-348, 50-364, 50-321, 50-366, 50-424, 50-425,52-025, and 52-026 Enclosure: Request for Additional Information cc w/enclosure: Distribution via Listserv Sincerely, Shawn A. Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST RELATED TO FLEET STANDARD EMERGENCY PLAN JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 EDWIN I. HATCH NUCLEAR PLANT. UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING STATION. UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING STATION, UNITS 3 AND 4 DOCKET NOS. 50-348, 50-364. 50-321 I 50-366. 50-424, 50-425, 52-25, AND 52-26 By letter dated August 31, 2015, Southern Nuclear Operating Company (SNC) requested approval for a fleet standard emergency plan (SEP) and site-specific annexes for the Joseph M. Farley Nuclear Plant (FNP}, Units 1 and 2; Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2; and Vogtle Electric Generating Plant (VEGP), Units 1, 2, 3, and 4 (Agencywide Documents Access and Management System Package Accession No. ML 15246A045). In addition, SNC is requesting an amendment to the Combined Licenses (COLs) for VEGP, Units 3 and 4, to address conforming changes to emergency planning inspections, tests, analyses, and acceptance criteria (IT AAC) resulting from the proposed changes. The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the requested license amendment against the standards of Title 10 of the Code of Federal Regulations (1 O CFR) Section 50.47, "Emergency plans," and the requirements of Appendix E to 10 CFR Part 50, "Emergency Planning and Preparedness for Production and Utilization Facilities," using the guidance contained in:

• NUREG-0654/FEMA-REP-1 [NUREG-0654), Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980; and

• NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants." The following requests for additional information (RAls) are needed to support the NRC staff's continued technical review. For ease of reference, the RAls are divided by the specific document. Universal RAls that Apply to all Plants (GEN) RAl-GEN-1 Please confirm that no current emergency plan commitments from the approved emergency plans for HNP, Units 1 and 2; FNP, Units 1 and 2; and VEGP, Units 1, 2, 3, and 4, have been deleted. Enclosure

-2 -RAl-GEN-2 The proposed SNC SEP removed significant details contained in currently approved emergency plans for the respective sites. As such, please address the following: a. Please describe where the level of detail removed from the approved emergency plans for the respective sites, and necessary to implement the proposed SNC SEP and site-specific annexes, will be specifically addressed (i.e., emergency plan implementing procedures) and process to be used to maintain in order to ensure the continued effective implementation of the SNC SEP and site-specific annexes. b. Consistent with the guidance in Section 11.P.7 of NUREG-0654, please provide an appendix for each respective site that lists, by title, "procedures required to implement the plan. The listing shall include the section(s) of the plan to be implemented by each procedure." c. Consistent with the guidance in Section 11.P.8 of NUREG-0654, please provide a cross-reference to the evaluation criteria in Section II to NUREG-0654 for each respective site. Fleet Emergency Plan RAls RAl-FLEET-1 Section A.1.1 describes the NRC responsibilities during an emergency, stating, "The NRC acts as the lead federal agency for technical matters during a nuclear incident. .. " The statement is inconsistent with the language in the National Response Framework/Nuclear-Radiological Annex, where it states, "The NRC is the coordinating agency for incidents at or caused by a facility or an activity that is licensed by the NRC or an Agreement State." Please revise the language to reflect the designated role of the NRC in the above-referenced documents or provide further basis for retaining the proposed statement. (Note: Also on page E12-47 of the VEGP, Units 1 and 2, Justification Matrix.) RAl-FLEET-2 Section A.2.1 contains the following statements: The Alabama Emergency Management Agency coordinates the Radiological Emergency Plans and offsite operations of affected state agencies and local governments including notification of state and local agencies of a nuclear incident at a nuclear power plant impacting the State of Alabama .... The Alabama Office of Radiation Control has primary responsibility and authority for handling the off site aspects of an emergency in Alabama with primary focus on the welfare and safety of the general public.

-3 -In addition, in Section A.2.1, it also states that the Georgia Emergency Management Agency has "responsibilities for coordinating the state of Georgia response to emergencies at nuclear power plants," while the Department of Natural Resources Environmental Protection Division has "primary responsibility for implementation and administration of the state radiological emergency response function." These statements appear to be contradictory or at least confusing. Please revise, as necessary, to clarify the roles. RAl-FLEET-3 Section E.1.1 appears to have an inadvertent error in the following bolded wording: "NRC-will be notified by the Headquarters Operations Officer immediately following state and local notifications, but within an hour of an emergency classification." Please revise, as necessary, to clarify. RAl-FLEET -4 In Section E.2.5.2, it states (bolding added), "State and local emergency management will detail the Prompt Notification System (PNS) activation." It is unclear what the word "detail" refers to, and there is no additional perspective on the meaning of PNS versus generic alert and notification system (ANS) terminology, as there is no additional reference in the plan. Please revise as necessary to clarify. RAl-FLEET-5 Section F.1.4 incorrectly references the acronym "FTS" as the Federal Telephone System rather than the correct terminology --Federal Telecommunications System. Please revise as appropriate. Additionally, please confirm that a quarterly check of phone numbers is still required in the SNC SEP or site-specific annex (Section 11.P.10 of NUREG-0654). RAl-FLEET-6 Section H.2.1 states, "Staffing and activation of the EOF is mandatory upon declaration of an Alert or higher classification." Please explain why there is no timing criteria associated with this section, similar to Section H.1, or modify the section to address as appropriate. RAl-FLEET-7 Section H.8 states, "Emergency facilities and equipment are inspected and inventoried using appropriate administrative or department procedures." Please confirm that provisions to inspect, inventory, and operationally check emergency equipment/instruments at least once each calendar quarter and after each use is still required in the SNC SEP or site-specific annex (Section 11.H.10 of NUREG-0654). RAl-FLEET-8 In Section N.1, it states (bolding added), "Remedial exercises will be required if the emergency plan is not satisfactorily tested during the Biennial Exercise, and it is determined that reasonable assurance that adequate protective measures are not taken in the event of a radiological

-4 -emergency." In the context of exercises, please clarify whether the bolded wording should read "cannot be taken" and revise accordingly. RAl-FLEET-9 In Section N.1.3, "Ingestion Exposure Pathway Exercise," two unrelated subject areas are combined, resulting in the intent being confusing/unclear. Specifically, it states: States within an ingestion exposure pathway EPZ are expected to exercise plans and preparedness related to ingestion exposure pathway measures at least once every 8 years. Opportunities are provided to any state or local government located within the plume exposure pathway EPZ to participate in annual drills and biennial exercises when requested by that state or local government. Please provide further clarification on the language or revise appropriately to clarify respective areas. RAl-FLEET-10 Section N.2.2 addresses Hostile Action Based (HAS) drills rather than an exercise, noting it will occur at least once every 8 years, per the NRG/Federal Emergency Management Agency (FEMA) guidance. Please provide additional information regarding an HAS exercise versus drill or revise accordingly to reflect the guidance in NSIR/DPR-ISG-01. RAl-FLEET-11 NUREG-0654, Section 11.1.9, states (bolding added): Each organization shall have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 uCi/cc (microcuries per cubic centimeter) under field conditions. Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity. Section 1.9 of the SNC Standard Emergency Plan states, "Field monitoring equipment has the capability to detect and measure airborne radioiodine in the presence of noble gases." This information was identified in the applicable Justification Matrixes for VEGP, Units 1 and 2 (E12-126), and VEGP, Units 3 and 4 (E15-106), as being relocated to the SNC Standard Emergency Plan. It was identified for FNP (E6-16) as being maintained in the applicable procedures. However, the SNC Standard Emergency Plan lacks the specific detail of the NUREG-0654 evaluation criteria. Please explain how this evaluation criteria of NUREG-0654 is being addressed.

-5 -FNP Annex RAl-FNP-1 In Sections 1.2.1 and 1. 7 .1, it is noted that Henry County is referenced in the two plan statements, but additional narrative is not included in the plan, as was done for all states (including Florida, an Ingestion Pathway Zone state) and other counties (Houston, Alabama, and Early, Georgia). In Section 4.11, Henry County is also absent from the agencies to be notified by FNP. Specifically, Section 4.2 states: Siren system activation, test, and monitoring panels are provided for Houston County and Henry County in Alabama, Early County in Georgia, and the state of Georgia. . . . Capability to activate the calling system is provided by Houston County and Henry County, Alabama, and Early County, Georgia. Please provide further perspective on Henry County's involvement in the radiological emergency preparedness program for FNP and revise the annex accordingly to address this. RAl-FNP-2 Section 1.4 states that the Alabama Department of Public Health, Office of Radiation Control (ADPH-ORC) is responsible for initiating the Alabama Radiological Response Plan for Nuclear Power Plants in support of an emergency at FNP. The Alabama Emergency Management Agency (AEMA) is not referenced here, yet on page E5-5, AEMA is categorized as one of the "primary offsite authorities." ADPH is not referenced on page E5-5, nor anywhere else in the annex, including receiving notifications from the plant. Please provide further perspective on the roles of these respective agencies and revise accordingly to ensure that information is fully documented in the FNP Annex, where appropriate. RAl-FNP-3 Section 5.3.1 states, "The primary means of communication between FNP, the state of Alabama, state of Georgia, Houston County, and Early County is the Emergency Notification Network (ENN)." See earlier comment in RAl-FNP-1 regarding the lack of reference to Henry County notification from FNP. Please clarify or revise accordingly to address. FNP Staffing -Detailed Description and Technical Evaluation RAl-FNP-4 Regarding the Emergency Operations Facility (EOF) Emergency Director (ED) on page E4-5, it states:

-6-Under this proposal, within 75 minutes of classification, the Shift Manager/ED is relieved in the TSC [Technical Support Center] by the ED, who then assumes overall control of the response efforts. The EOF ED arrives and relieves the TSC ED of overall emergency management and off-site responsibilities including PARs, dose assessment, and emergency notifications. This appears to contradict the table on page E4-3 where notification is shown as transferring directly from the CR ED to the EOF ED. Please provide additional clarification regarding the turnover of notifications from the Shift Manager/ED and revise accordingly. FNP Justification Matrix RAl-FNP-5 The EP Introduction to the SNC Emergency Plan (reference page E6-5 of the Justification Matrix) states, "There are supporting and complementing emergency plans, including those of federal agencies, the states of Alabama, Georgia, South Carolina, and individual counties." Realizing that Florida is an Ingestion Only state, it is referenced in other parts of the plan. Please clarify why the State of Florida should not be included as part of this introductory statement or revise accordingly. RAl-FNP-6 On page E6-11, Section EP B.2.1.1, TSC Emergency Director (ED) states, "Once Command and Control has been completed, the TSC ED assumes the non-delegable duties .... " This would also apply to plan sections referenced on pages E6-8/9. Please clarify this statement intended to address the transition of command and control and revise accordingly. RAl-FNP-7 On page E6-20, the current Emergency Plan states that Field Monitoring Teams, "will provide radiation protection support at the Southeast Alabama Medical Center, during transport of potentially irradiated and/or contaminated casualties. The Emergency Plan Equivalent Description no longer includes such a commitment.. .. " Please provide additional details around the radiation protection support that will continue to be provided to the Southeast Alabama Medical Center, including interface with offsite authorities, and revise as appropriate to address. RAl-FNP-8 On page E6-22, it references the current FNP Emergency Plan, which contains a section on Additional Plant Staff Assignments. Specifically, it states the senior individual at each of the Assembly Areas will become the supervisor at that location. The revised SNC Emergency Plan Equivalent Description makes no reference to such a position. Please provide clarification as to the supervision status at Assembly Areas and revise as appropriate to address.

-7 -RAl-FNP-9 On page E6-73, the description of the Radiation Monitoring System (RMS) provides that there are three types of monitors, area airborne, and air particulate monitors. Please provide further perspective as to why the two bullets discuss additional details for the area and airborne monitors but do not discuss air particulate monitors or revise accordingly. RAl-FNP-10 On page E6-80, the current FNP Emergency Plan states, "Results of dose estimates and projections are provided to off-site agencies responsible for initiating protective actions .... " This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies or revise accordingly to address. RAl-FNP-11 On page E6-98, the current FNP Emergency Plan, states: The Dose Assessment Supervisor will work with the state/local agency representatives to determine the Total Effective Dose Equivalent (TEDE) exposure (resulting from external exposure and inhalation of the plume and external exposure from deposition) and thyroid Committed Dose Equivalent (CDE) exposure (resulting from the inhalation of radio-iodines). This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. RAl-FNP-12 On page E6-98, the current FNP Emergency Plan, states: If a site evacuation is warranted, personnel will be advised as to which routes should be used. The normal routes are State Highway 95 North or South and County Road 42 West (Figures 17 and 19). All personnel being evacuated from the site will be monitored before being released. Personnel leaving the site would then proceed, in their own vehicles, on one of these major routes, to their residences. Transportation for persons without vehicles will be arranged. This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or revise accordingly to address.

-8 -RAl-FNP-13 On page E6-107, the current FNP Emergency Plan states: Accountability within the Controlled Area will be determined by the senior individual at each assembly area coordinating with the Security Response Center (SRC) Staff and then will be reported to the Emergency Director by the senior individual in the SRC. This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or revise accordingly to address. RAl-FNP-14 On page E6-122, the current FNP Emergency Plan states (bolding added): The authority for initiation or relaxation of protective action recommendations is vested solely with the Emergency Director and may not be delegated to any other member of the emergency organization. This language has apparently been deleted in the SNC SEP and is not in the Farley Annex. Please explain why the referenced language was removed or where the information is located, or revise accordingly. RAl-FNP-15 On pages E6-136 through E6-139, significant detail describing the primary and backup ANS was removed. The ANS design report is reviewed and approved by FEMA, not the NRC. As such, an adequate description of the primary and backup ANS needs to be included in the FNP Annex. RAl-FNP-16 On page E6-154, the current FNP Emergency Plan, states, " ... a formal critique will be performed for all exercises, drills, and training that provide performance opportunities to develop, maintain, or demonstrate key skills in order to identify weak or deficient areas that need correction." This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or revise accordingly to address. RAl-FNP-18 On page E6-188, the current FNP Emergency Plan states, "If both units are in concurrent classifications, the highest classification would be used for the notification and the other unit classification noted on the notification form." This language has apparently been deleted in the SNC SEP and is not in the FNP Annex. Please explain why the referenced language was removed or where the information was relocated, or revise accordingly to address.

-9 -HNP Justification Matrix RAl-HNP-1 On page E9-93, the current HNP Emergency Plan, states: Any proposed change in the method of dissemination of emergency information to the public must be coordinated and discussed with, and agreed upon by appropriate State and local offsite emergency officials prior to implementation of the change. This language has apparently been deleted in the SNC SEP and is not in the HNP Annex. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. RAl-HNP-2 On page E9-132, the current HNP Emergency Plan states, "Initially at least two persons can be dispatched from on-shift personnel for offsite surveys. The on-shift HP/Chem department foreman will provide for field monitoring coordination until the TSC is activated." This language has apparently been deleted in the SNC SEP and is not in the HNP Annex. Please explain why the referenced language was removed or where the information is located, or revise accordingly. RAl-HNP-3 On pages E9-225 through E9-231, significant detail describing the primary and backup ANS was removed. The ANS design report is reviewed and approved by FEMA, not the NRC. As such, an adequate description of the primary and backup ANS needs to be included in the HNP Annex. VEGP. Units 1 and 2. Justification Matrix RAl-VEGP1 &2-1 On page E12-149, the proposed VEGP, Units 1 and 2, Annex, Section 2.3.2, states (bolding added): Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency, to provide assistance for injured personnel, including cases involving radioactive contamination. On page E12-155, the proposed VEGP, Units 1and2, Annex, Section 5.8.1, states, "Agreements are in place with the Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination." Please explain why reference to the UAB Hospital was

-10 -removed in the proposed VEGP, Units 1 and 2, Annex, Section 5.8.1, or revise accordingly to address. RAl-VEGP1 &2-2 On page E12-172, the current VEGP, Units 1and2, Section M.4, states: VEGP will provide radiological information including estimated quantity of radioactivity released, isotopic composition of released material, and meteorological data to assist the governmental authorities in their determinations. Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. RAl-VEGP1 &2-3 On pages E12-193 through E12-197, there are numerous references relating to tone alert radios. Understanding the proposed language and justification reference the FEMA-approved design report, and also that, "The combination of Sirens and Tone Alert Radios is conducted in accordance with the FEMA approved Design Report." Additionally, there are specific commitments identified:

• SNC, in conjunction with Georgia Power Company, provides National Oceanic and Atmospheric Administration (NOAA) radio receivers for all known establishments (residence, businesses, schools, etc.) within the plume exposure pathway EPZ that choose to accept them.

• During the distribution to those accepting the radios, a brochure is handed out.

• That brochure will be redistributed on an annual basis to NOAA recipients.

• Public information will be distributed on an annual basis to the NOAA radio recipients.

• SNC will replace any defective radios upon request or discovery that the radios are defective.

• SNC will annually distribute replacement batteries to all recipients of tone alert radios.

• SNC will maintain a register of all radio recipients.

• The Emergency Preparedness staff distributes tone alert radios to any new residents and updates the register of radio recipients periodically.

• The Emergency Preparedness staff also determines whether there are any permanent Burke County EPZ residents with electricity. A list of these residents is maintained. The ANS design report is reviewed and approved by FEMA, not the NRC. As such, an adequate description of the primary and backup ANS needs to be included in the VEGP, Units 1

-11 -and 2, Annex. Also, please explain why the commitments listed above, which are currently contain in the VEGP, Units 1 and 2, Emergency Plan Appendix 3, are not being maintained in the site-specific annex. RAl-VEGP1 &2-4 On page E12-199, the current plan language states, "The periodic test program will consist of a weekly silent test, from the county activation points, and an annual full scale activation of the system," while proposed wording reads, "Annually the system will be activated in the normal mode." Please explain why the referenced language regarding the weekly silent test was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. VEGP, Units 3, and 4, Annex RAl-VEGP3&4-1 On page E14-13, the proposed VEGP, Units 3 and 4, Annex, Section 2.3.2, states (balding added): Agreements are in place with the University of Alabama at Birmingham (UAB) Hospital, Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency, to provide assistance for injured personnel, including cases involving radioactive contamination. On page E14-26, the proposed VEGP, Units 3 and 4, Annex, Section 5.8.1, states, "Agreements are in place with the Burke Medical Center, Doctors Hospital, and Burke County Emergency Management Agency to provide assistance for injured personnel, including cases involving radioactive contamination." Please explain why reference to the UAB Hospital was removed in the proposed VEGP, Units 3 and 4, Annex, Section 5.8.1, or revise accordingly to address. VEGP. Units 3 and 4, Annex Justification Matrix RAl-VEGP3&4-2 On page E15-156, the current VEGP, Units 3 and 4, Section M.4, states, "VEGP will provide radiological information including estimated quantity of radioactivity released, isotopic composition of released material, and meteorological data to assist the governmental authorities in their determinations." Please explain why the referenced language was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. RAl-VEGP3&4-3 On pages E15-183 through E15-186, there are numerous references relating to tone alert radios. Understanding the proposed language and justification reference the FEMA-approved design report, and also that, "The combination of Sirens and Tone Alert Radios is conducted in

-12 -accordance with the FEMA approved Design Report." Additionally, there are specific commitments identified:

• SNC, in conjunction with Georgia Power Company, provides NOAA radio receivers for all known establishments (residence, businesses, schools, etc.) within the plume exposure pathway EPZ that choose to accept them.

• During the distribution to those accepting the radios, a brochure is handed out.

• That brochure will be redistributed on an annual basis to NOAA recipients.

• Public information will be distributed on an annual basis to the NOAA radio recipients.

• SNC will replace any defective radios upon request or discovery that the radios are defective.

• SNC will annually distribute replacement batteries to all recipients of tone alert radios.

• SNC will maintain a register of all radio recipients.

• The Emergency Preparedness staff distributes tone alert radios to any new residents and updates the register of radio recipients periodically.

• The Emergency Preparedness staff also determines whether there are any permanent Burke County EPZ residents with electricity. A list of these residents is maintained. The ANS design report is reviewed and approved by FEMA, not the NRC. As such, an adequate description of the primary and backup ANS needs to be included in the VEGP, Units 3 and 4, Annex, as well as site-specific annexes for HNP and FNP. Also, please explain why the commitments listed above, which are currently contained in the VEGP, Units 3 and 4, Emergency Plan Appendix 3 are not being maintained in the site-specific annex. RAl-VEGP3&4-4 On page E15-190, the current plan language states, "The periodic test program will consist of a weekly silent test, from the county activation points, and an annual full scale activation of the system," while proposed wording reads, "Annually the system will be activated in the normal mode." Please explain why the referenced language regarding the weekly silent test was removed and, if so, whether or not there was consultation with applicable offsite agencies, or revise accordingly to address. RAl-VEGP3&4-5 VEGP, Units 3 and 4, EP ITAAC E.3.9.08.01.01 -The language in EP ITAAC, "Acceptance Criteria 8.1.1.B.3.a (for both Units 3 and 4) currently ends with "within 15 minutes of notification." Should this be changed to "within 15 minutes of event classification," in order to be consistent with other similar ITAAC acceptance criteria?

-13 -RAl-VEGP3&4-6 VEGP, Unit 4, EP ITAAC E.3.9.08.01.01 -Description No. 1 for Unit 4 lists the affected criteria as 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. In contrast, the comparable Unit 3 description also includes affected criteria 8.1.1.B.1.a. Should 8.1.1.B.1.a be added to the Unit 4 listing of affected criteria, as it too includes the "designated checklist" reference that is being removed from the other criteria? RAl-VEGP3&4-7 VEGP, Unit 4, EP ITAAC E.3.9.08.01.01 -Description No. 7 for Unit 4 (Acceptance Criterion 8.1.1.D.1) repeats the same description that is provided for Unit 3, Description No. 7 (acceptance criterion 8.1.1.D.1 ). In Appendix C of the COLs, the Unit 3 and Unit 4 language for acceptance criterion 8.1.1.D.1 are not the same, as the Unit 4 language does not include reference to the TSC and EOF. Should the Unit 4, Description No. 7 (for Criterion 8.1.1.D.1) be deleted, as the change to Unit 3 Criterion 8.1.1. D.1 is not applicable to Unit 4?

Mr. C. R. Pierce Regulatory Affairs Director Southern Nuclear Operating Co., Inc. P.O. Box 1295, Bin 038 Birmingham, AL 35201-1295 April 14, 2016 SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2; EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2; AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4-REQUEST FOR ADDITIONAL INFORMATION (CAC NOS. MF6670, MF6671, MF6672, MF6673, MF6674, MF6675, AND RP9516) Dear Mr. Pierce: By letter dated August 31, 2015, Southern Nuclear Operating Company, Inc. (SNC) submitted a license amendment request for the Joseph M. Farley Nuclear Plant, Units 1 and 2; Edwin I. Hatch Nuclear Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4. The amendment requests U.S. Nuclear Regulatory Commission (NRC) approval of a standard emergency plan for all SNC sites and site-specific annexes. The NRC staff has determined that additional information is needed as listed in the enclosure. We request that SNC respond within 60 days of the date of this letter. Please note that the NRC staff's review is continuing, and further RAls may be developed. If you have any questions, please contact me at (301) 415-1009 or Shawn.Williams@nrc.gov. Sincerely, IRA/ Shawn A. Williams, Senior Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364, 50-321, 50-366, 50-424, 50-425,52-025, and 52-026 Enclosure: Request for Additional Information cc w/enclosure: Distribution via Listserv DISTRIBUTION: PUBLIC RidsNrrDorlDpr Resource RidsNrrLALRonewicz Resource MNorris, NRR MOrenak, NRR RidsNroDnrl LPL2-1 R/F RidsNrrDorllpl2-1 Resource RidsNrrDe Resource CPatel, NRO RMartin, NRR N RO _ON RL_LB4 ADAMS Accession No.: ML 16096A217 RidsACRS_MailCTR Resource RidsRgn2MailCenter Resource RidsNrrPMFarley Resource RidsNrrPMVogtle Resource RidsNrrPMHatch Resource JAnderson, NSIR *by e-mail OFFICE LPL2-1/PM LPL2-1/LA NSI R/DPR/ORLOB/BC* NRO/DNRL/LB4* LPL2-1/BC LPL2-1/PM NAME SWilliams LRonewicz JAnderson JMcKirgan MMarkley SWilliams DATE 4/5/2016 4/12/2016 3/25/2016 4/13/2016 4/14/2016 4/14/2016 OFFICIAL RECORD COPY