ML18226A094

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Edwin I. Hatch, Units 1 and 2; and Vogtle, Units 1 and 2 - License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables
ML18226A094
Person / Time
Site: Hatch, Vogtle, Farley  Southern Nuclear icon.png
Issue date: 08/09/2018
From: Gayheart C A
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-1089
Download: ML18226A094 (28)
v • d • e


Text

Southern Nuclear August 9, 2018 Docket Nos.: 50-321 50-348 50-424 50-366 50-364 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Chery l A. G ayheart Reg u latory Affairs Director 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 3535 Colonnade Parkway Birmingham , AL 35243 205 992 5316 tel 205 992 7601 fax cagayhea@sou th ernco.com NL-17-1089 License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Ladies and Gentlemen: Pursuant to the provisions of Section 50.90 of Title 1 O of the Code of Federal Regulations (10 CFR), Southern Nuclear Operating Company (SNC) hereby requests an amendment to the Technical Specifications (TS) for the following SNC facilities and includes the results of the no significant hazards determination:

Joseph M. Farley Nuclear Plant (FNP) Unit 1 Renewed Facility Operating License NPF-2 and Un i t 2 Renewed Fac i lity Operat ing License NPF-8; Edw in I. Hatch Nuclear Plant (HNP) Unit 1 Renewed Facility Operating License DPR-57 and Unit 2 Renewed Facility Operating License NPF-5; and Vogtle Electr i c Generating Plant (VEGP) Unit 1 Renewed Facility Operating License NPF-68 and Unit 2 Renewed Facility Operating License NPF-81. Additionally, SNC requests approval of the revision to the minimum on-shift staffing tables in the HNP and FNP annexes associated with the SNC standard emergency plan (SEP) and an accompanying editorial change in the SEP. This change reduces the total number of required on-shift personnel which is considered a reduction in the effectiveness of the HNP and FNP emergency plans (EPs) requiring NRC approval pursuant to 10 CFR 50.54(q)(4).

The proposed TS change aligns Specification 5.2.2.g of each plant's TS with equivalent wording, comparable to TS 5.2.2.e in the standard technical specifications

{STS). The proposed amendments are based , in part, on Technical Specification Task Force traveler TSTF-258, "Changes to Section 5.0, Administrative Controls," Revision 4. This change eliminates a dedicated shift technical advisor {STA) position at FNP and HNP by allowing the STA functions to be combined with one or more of the required senior licensed operator positions. The VEGP Units 1 and 2 TS change aligns the facilities with equivalent wording. This proposed change also incorporates wording related to the modes of operation during which the individual meeting J bl) { the requirements in TS 5.2.2.g is required and provides guidance that the same individual may /t Ax t/5 /ffc U. S. Nuclear Regulatory Commission NL-17-1089 Page 2 provide advisory technical support for both units. On approval, TS 5.2.2.g for each applicable SNC nuclear plant will be equivalent.

SNC requests approval of the proposed license amendments and change to the applicable SNC SEP annexes by April 30, 2019. The proposed amendments will be implemented within 90 days of issuance.

The enclosure provides the basis for the proposed change , the supporting technical analysis , and the no significant hazards consideration determination analysis. Attachment 1 contains marked-up pages from each plant's TS and Attachment 2 contains the associated revised TS pages. Attachment 3 contains marked-up pages of the SNC SEP and applicable annexes. Attachments 4 and 5 provide the revised HNP and FNP EP on-shift staffing analyses , respectively , performed to support the revision to the applicable SEP annexes. This letter contains no NRC commitments. In accordance with 10 CFR 50.91, SNC is notifying the State of Alabama and the State of Georgia of this license amendment request by transmitting a copy of this letter and enclosure and attachments to the designated State Official.

If you have any questions , please contact Jamie Coleman at 205.992.6611. I declare under penalty of perjury that the foregoing is true and correct. Executed on the day of August 2 018. Respectfully submitted , Chery yheart Regulatory Affairs Director Southern Nuclear Operating Company CAG/RMJ

Enclosure:

Basis for Proposed Change Attachments

1. Southern Nuclear Company Nuclear Facilities Technical Specification Marked-up Pages 2. Southern Nuclear Company Nuclear Facilities Revised Technical Specification Pages 3. Southern Nuclear Operating Company Standard Emergency Plan and Applicable Annexes -Marked-up Pages 4. Hatch Nuclear Plant Revised Emergency Plan On-shift Staffing Analysis 5. Farley Nuclear Plant Revised Emergency Plan On-shift Staffing Analysis U. S. Nuclear Regulatory Commission NL-17-1089 Page 3 cc: Regional Administrator , Region II NRR Project Manager -Farley , Hatch , Vogtle 1 & 2 Senior Resident Inspector

-Farley , Hatch , Vogtle 1 & 2 Director , Alabama Office of Radiation Control Director, Environmental Protection Division -State of Georgia RType: Farley -CFA04.054; Hatch -CHA02.004; Vogtle -CVC?OOO

,----------

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 License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Enclosure Basis for Proposed Change Enclosure to NL-17-1089 Basis for Proposed Change 1.0 Summary Description Southern Nuclear Operating Company (SNC) proposes to revise the Technical Specifications (TS) for the Joseph M. Farley Nuclear Plant (FNP) -Units 1 and 2 , the Edwin I. Hatch Nuclear Plant (HNP) -Units 1 and 2 , and the Vogtle Electric Generating Plant (VEGP) -Units 1 and 2. The proposed change aligns Specification 5.2.2.g of each plant's TS with equivalent wording , comparable to TS 5.2.2.e in the standard technical specifications (STS). The proposed amendments are based , in part , on Technical Specification Task Force traveler TSTF-258 , Revision 4 (Reference 1 ). This change eliminates a dedicated shift technical advisor (ST A) position at FNP and HNP by allowing the STA functions to be combined with one or more of the required senior reactor operator (SRO) positions. The VEGP Units 1 and 2 TS change aligns the facilities with equivalent wording. This proposed change also incorporates wording related to the modes of operation during which the individual meeting the requirements in TS 5.2.2.g is required and provides guidance that the same individual may provide advisory technical support for both units. On approval , TS 5.2.2.g for each applicable SNC nuclear plant will be equivalent.

Additionally , SNC proposes a revision to the on-shift staffing tables in the HNP and FNP annexes associated with the SNC standard emergency plan (SEP) to reduce the total number of required on-shift personnel from 25 to 24 and includes an accompanying editorial change to the SEP. 2.0 Detailed Description

2.1 Current

Technical Specification Requirements TS 5.2.2.g of the current HNP and FNP TS states: The Shift Techn i cal Advisor (STA) shall provide advisory technica l support to the [responsible SR0]1 in the areas of thermal hydraulics , reactor eng i neering , and plant analysis with regard to the safe operation of the unit. In addi t ion , the STA shall meet the qualifications specified by the Commission Pol i cy Statement on Eng i neering Expertise on Shift. [The same individual may fill this position for both un i ts.]2 1 The HNP TS states " shift supervisor" instead of " responsible SRO". 2 The HNP TS does not contain this final statement.

TS 5.2.2.g of the cu r rent VEGP TS states: An individual shall be assigned who provides technical support in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. This individual shall be available for duty when the plant is in modes 1-4. At other times , this individual is not required. In addition , th i s individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This position may also be filled by the shift supervisor or the individual with an SRO license provided that person meets the qual i fications specified by the Commission Policy Statement on Engineering Expertise on Shift. E-1 Enclosure to NL-17-1089 Basis for Proposed Change 2.2 Current Emergency Plan Requirements The minimum on-shift staffing tables in the HNP and FNP annexes of the SNC SEP require one Shift Support Supervisor/Shift Technical Advisor (SRO/STA) to provide technical support in the major functional area of plant system engineering , repair , and corrective action. The total shift personnel in these table is specified as 25. Section B of the SEP describes the emergency response organization (ERO) and includes the on-site ERO responsibilities.

Paragraph B.2.1.8 states , in part, regarding the technical support center reactor engineer: " The Reactor Engineer relieves the Shift Technical Advisor (STA) of Core Thermal Analysis responsibilities

." 2.3 Reason for the Proposed Change The proposed change tci TS 5.2.2.g is needed for HNP Units 1 and 2 and FNP Units 1 and 2 , to provide flexibility to the on-shift staffing by emending the STA role from a dedicated position to a function. The proposed TS change is also needed to explicitly state the modes of operation during which the individual meet i ng the requirements in TS 5.2.2.g is required and , for the app l icable plants , explicitly allow the same individual to provide advisory technical support for both units. The proposed change to the minimum on-shift staffing tables in the HNP and FNP annexes of the SNC SEP and accompanying editorial change in the SEP are needed because the STA role is being emended as a function in lieu of a position , thereby , eliminating the dedicated position from the respective staffing tables. The SEP annex revision constitutes a reduction in the effectiveness of the HNP and FNP emergency plans (EPs) requiring NRC approval pursuant to 10 CFR 50.54(q)(4). 2.4 Description of the Proposed Change SNC proposes to revise TS 5.2.2.g for HNP Units 1 and 2 , FNP Units 1 and 2 , and VEGP Units 1 and 2 to state: An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. In addition , SNC proposes to add Mode specific requirements and also state that the same individual may provide advisory support for both units. The proposed addition to be appended at the end of TS 5.2.2.g states: This individual shall be available for duty when an operating unit is in [MODE 1 , 2 , 3 , or 4]3. This same individual may provide advisory technical support for both units. 3 MODE 1 , 2 , or 3 for HNP. SNC also proposes to change the position " Shift Support Supervisor/Shift Technical Advisor (SRO/STA)" to " Shift Support Supervisor or other trained individual" in the minimum on-shift staffing tables in the HNP and FNP annexes of the SNC SEP and replace the number for the position with Note 2 , which states: " May be provided by shift personnel assigned other E-2 Enclosure to NL-17-1089 Basis for Proposed Change functions." As a result , the proposed total on-shift personnel in these tables is revised from 25 to 24. In addition , Paragraph B.2.1.8 of the SNC SEP is revised , in part , regarding the technical support center reactor engineer to state: " The Reactor Engineer relieves the Shift Manager or Supervisor of the Core Thermal Analysis responsibilities

." 3.0 Technical Evaluation NRC Generic Letter 86-04 (Reference

2) promulgated the policy statement regarding engineering expertise on shift and establ i shed the requirements for eliminating the separate STA position. The NRC policy statement offers the licensees two options for meeting the NUREG-0737 (Reference 3), Enclosure 3 , Item I.A.1.1 requirement regarding engineering expertise on shift and meeting licensed operator staffing requirements pursuant to 10 CFR 50.54(m)(2). Option 1 provides for elimination of the separate STA position by allowing licensees to combine one of the required SRO positions with the STA position into a dual-role (SRO/STA) position. Option 2 allows a licensee to continue use of an NRC-approved STA program while meeting licensed operator staffing requirements. Per the policy statement , the Commission encourages licensees to move toward the dual-role (SRO/STA) position , with the eventual goal of the shift supervisor serving in the dual role. TS 5.2.2.g is revised to eliminate the title of "Shift Technical Advisor (STA)," because the STA function may be fulfilled by one or more of the other on-shift individuals. Therefore , TS 5.2.2.g is revised so that it does not imply that the STA and the shift supervisor must be different individuals. Option 1 of the NRC policy statement is satisfied by assigning an individual with specified educational qualifications to each operating crew as one of the SR Os required by 10 CFR 50.54(m)(2)(i) to provide the technical expertise on shift. However , the TS 5.2.2.g wording of , "the Shift Technical Advisor (STA) shall provide ... support to the shift supervisor

[ or responsible SRO] ... " , is considered to be misinterpreted to require separate individuals. The r efore , SNC is electing to implement Option 1 of the NRC policy statement at FNP and HNP such that technical expertise may be provided by either an ST A qualified individual who also fulfills another role in the shift command structure or a separate individual.

VEGP Units 1 and 2 TS 5.2.2.g is currently worded such that Option 1 of the NRC policy statement may be used. The proposed change is consistent with the applicable portion of NRC-approved traveler TSTF-258 (Reference 1). The proposed mode specific requirements to be included in FNP and HNP TS 5.2.2.g are currently specified in the VEGP Units 1 and 2 TS 5.2.2.g and reflect the clarification in NUREG-0737 , Enclosure 3 , Item I.A.1.1 that states , in part: " ... an STA be available for duty on each operating shift when a plant is being operated in Modes 1-4 for a PWR and Modes 1-3 for a BWR. At other times , an STA is not required to be on duty." The proposed statement to be included in HNP and VEGP Units 1 and 2 TS 5.2.2.g that the same individual may provide advisory technical support for both units is currently allowed by FNP Units 1 and 2 TS 5.2.2.g and reflect the NUREG-0737 , Enclosure 3 , Item I.A.1.1 position statement:

" The shift technical advisor (ST A) may serve more than one unit at a multiunit site if qualified to perform the advisor function for the various units." E-3 Enclosure to NL-17-1089 Basis for Proposed Change The STA training programs at HNP , FNP , and VEGP Units 1 and 2 provide for dual unit STA qualification and include dissimilarity training between the units. Therefore , an i ndividual provid i ng advisory technical support is qualified to perform the advisor function for both units. Detailed staffing studies were performed in 2012 for HNP and FNP to ensure on-shift staffing was adequate to perform critical functions unt i l relieved by the augmented ERO as required by 10 CFR 50 , Append i x E. The minimum staff identified was determined to be adequate to respond to the scenarios identified in the regulations until relieved by the augmented ERO 75 minutes after declaration and that no conflicts in responsibilities existed. These studies were performed in accordance with NEI 10-05 (Reference

4) as endorsed by the NRC in i nter i m staff guidance NSIR/DPR-ISG-01 (Reference 5). To facilitate the STA role being emended as a function in lieu of a position , the EP minimum staffing studies were re-evaluated and updated to ensure oh-shift staffing continues to be adequate to perform critical functions until relieved by the augmented ERO as required by 10 CFR 50 , Appendix E. Per the guidance prov i ded in NRC Regulatory Issue Summary 2016-1 O (Reference 6), the HNP and FNP on-shift staffing analysis reviewed events addressed in NSIR/DPR-ISG-01 as well as those described in NEI 10-05. Events that required STA actions were evaluated for impact as a result of the proposed change. The HNP and FNP EP staffing studies are provided in Attachments 4 and 5 , respectively. For HNP , the events evaluated include:
  • design basis threat (DBT),
  • large break loss of coolant accident (LB LOCA),
  • aircraft probable threat (APT),
  • station blackout (SBO),
  • control room fire leading to evacuation to remote shutdown panel (RSDP), and
  • radiological fast breaker event 4. 4 Rap i dly progress i ng event tha t results in rad i oactive r elease greater than Env i ronmen t al P r o t ection Agency (EPA) p r otect i ve act i o n guidel i nes (PAGs) at the s ite boundary. The HNP EP notification and plant system engineering functions currently performed by the ST A during these events include:
  • performance of NRC notifications ,
  • plant announcements , and
  • LB LOCA resulting in rad i olog i cal fast breaker event 5 ,
  • control room fire leading to evacuation to RSDP , and
  • SBO. E-4 Enclosure to NL-17-1089 Basis for Proposed Change 5 Rapidly progressing event t hat results in radioactive release greater than EPA PAGs at the site boundary. The FNP EP plant engineering functions currently performed by the STA during these events include:
  • monitoring critical safety functions status trees ,
  • verification of safety injection actuation and plant response ,
  • oversight of reactor shut down and trip response actions. Analysis of the proposed change identified that these EP functions can be completed by other on-shift Operations personnel , and does not result in assignment of conflicting duties for on-shift personnel.

The HNP analysis demonstrates that the plant system engineering and notification functions are not adversely impacted , and that no degradation or loss of function occurs as a result of the proposed change. The FNP analysis demonstrates that the plant system engineering functions are not adversely impacted , and that no degradation or loss of function occurs as a result of the proposed change. Therefo r e , the proposed change to the minimum on-shift staffing tables i n the HNP and FNP annexes of the SNC SEP and accompanying editorial change in the SEP continue to ensure the on-sh i ft staffing is adequate to perform critical functions until relieved by the augmen t ed ERO as required by 10 CFR 50.47(b)(2) and 10 CFR 50 , Appendix E , Paragraph IV.A.9. 4.0 Regulatory Evaluation

4.1 Applicable

Regulatory Requirements/Criteria 10 CFR 50.36(b)(4), Administrative controls TS r equirements associated w it h the unit staff satisfy , in part , provis i ons related to organization and management , procedures , recordkeeping , review and audit , and reporting necessary to assure operation of the facility in a safe manner. The proposed amendments emend the wording associated with the individual that provides technical advisory support to change the STA role from a position to function. This proposed change does not adversely impact the abil i ty of the facility staff to operate in a safe manner. 10 CFR 50.54 , Condition of licenses The proposed TS change confo r ms to existing NRC policy guidance regarding engineering expert i se on shift and SNC continues to maintain minimum licensed operator staffing requirements pursuant to 10 CFR 50.54(m)(2)(i). 10 CFR 50.47 , Emergency plans 10 CFR 50.47(b) requires emergency respons i bilities of various supporting organizations be specifically established and principal response organization has staff to respond and to augment its initial response on a continuous basis. §50.47(b) also requires adequate staffing to provide initial facility accident response in key functional areas to be maintained at all times including E-5 Enclosure to NL-17-1089 Basis for Proposed Change timely augmentation of response capabilities available. The proposed amendments reduce the minimum on-shift staff from 25 to 24 in the HNP and FNP annexes to the SNC SEP and includes an accompanying editorial change in the SEP. This change does not adversely impact emergency responsibilities of various supporting organizations and the principal response organization continues to contain staff necessary to respond and to augment its initial response on a continuous basis. 10 CFR 50, Appendix E Section IV.A provides requirements on the emergency organization including a description of the ERO with detailed discussion of , in part , plant staff emergency assignments. The HNP and FNP EP minimum staffing studies were re-evaluated and updated to ensure on-shift staffing continues to be adequate to perform critical functions until relieved by the augmented ERO. Therefore , the proposed change to the HNP and FNP annexes of the SNC SEP continue to meet the applicable 10 CFR 50 , Appendix E requirements.

NUREG-0737 Enclosure 3 Item I.A.1.1 position requires each licensee to provide an on-shift technical advisor to the shift supervisor.

The STA may serve more than one unit at a multiunit site if qualified to perform the advisor function for the various units. The position also describes the educational and training qualifications required for the STA function.

The proposed amendments emend the wording associated with the individual that provides technical advisory support to change the STA role from a position to function.

Following implementation of the proposed amendments , an on-shift individual will continue to be available to provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit and will meet the qualifications specified by the Commission policy statement on engineering expertise , including those necessary to perform the technical advisory function for both units. Item 1.A.1.1 further provides clarification for eliminating the STA position and until such time , an ST A be available for duty on each operating shift when a plant is being operated in Modes 1-4 for a PWR and Modes 1-3 for a BWR. At other times, an STA is not required to be on duty. Following implementation of the proposed amendments , advisory technical support (i.e., STA functions) will continue to be provided by senior licensed operators while the VEGP Units 1 and 2 and FNP units are operating in Modes 1-4 and HNP units are operating in Modes 1-3. Regulatory Guide 1.101 and NUREG-0654 NUREG-0654/FEMA-REP-1 (Reference 7), which is considered acceptable by the NRC staff as indicated in Regulatory Guide 1.101 (Reference 8), describes the onsite emergency ass i gnments and functions in Table B-1 entitled "Minimum Staffing Requirements for Nuclear Power Plant Emergencies

." The proposed change to reduce the minimum on-shift staff from 25 to 24 in the HNP and FNP annexes to the SNC SEP continue to meet the minimum on-shift staffing as indicated in NUREG-0654, Table B-1. 4.2 Precedent Eliminating a dedicated STA position allowing advisory technical support to be provided by sen i or reactor operators has been approved for multiple licensees including; E-6 Enclosure to NL-17-1089 Basis for Proposed Change

  • Amendment 220 to Oyster Creek Nuclear Generating Station operat i ng license (NRC ADAMS Accession No. ML010310230) allowing one of the required on-shift SRO positions to be combined with the required STA position so as to serve in a dual SRO/STA position.
  • Amendments 173 and 113 to St. Lucie Plant , Units 1 and 2 operating licenses , respectively (NRC ADAMS Accession No. ML010810277) permitting , as an alternative to the current ded i cated STA , a single , qualified individual to simultaneously serve as an STA and an SRO.
  • Amendments 266 and 257 to Sequoyah Nuclear Plant Units 1 and 2 operating licenses , r espect i vely (NRC ADAMS Accession No. ML010520368), which revised Section 6.2.4 , " Shift Technical Advisor ," to align with the latest revision of the Westinghouse STS , NUREG-1431. This change assigned the role of STA to a qualified individual in the operating crew , as specified in the STS.
  • Amendments 132 and 111 to VEGP Un i ts 1 and 2 operating licenses (NRC ADAMS Accession No. ML041810596) revising TS 5.2.2.g to limit the requirements of the STA f unct i ons to Modes 1-4 in accordance with NUREG-0737 , Enclosure 3 , Item I.A.1.1. 4.3 No Significant Hazards Cons i deration Determination Analysis Southern Nuclear Operating Company (SNC) proposes to revise the Technical Specifications (TS) for the Joseph M. Farley Nuclear Plant (FNP) -Units 1 and 2 , the Edwin I. Hatch Nuclear Plant (HNP) -Units 1 and 2 , and the Vogtle Electric Generating Plant (VEGP) -Units 1 and 2. The proposed change will align Section 5.2.2.g of each plant's TS with equivalent wording , comparable to TS 5.2.2.e in the standard techn i cal specifications. This change eliminates a dedicated shift techn i cal advisor (STA) personnel position at FNP and HNP by allowing the STA functions to be combined with one or more of the required senior reactor operator positions. The VEGP Units 1 and 2 TS change aligns the facilities with equivalent wording. This proposed change also incorporates word i ng related to the modes of operation during which the individual meeting the requirements in TS 5.2.2.g is required and provides guidance that the same individual may provide advisory technical support for both units. On approval , TS 5.2.2.g for each applicable SNC nuclear plant will be equivalent.

Additionally , SNC proposes a revision to the minimum on-shift staffing tables in the HNP and FNP annexes to the SNC standard emergency plan (EP) that reduces the total number of required on-shift personnel from 25 to 24 and includes an accompanying editorial change to the SNC standard EP. SNC has evaluated whether a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92 , " Issuance of amendment ," as discussed below: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The advisory technical support function and on-shift staffing requirements are not associated w i th an initiator of any acc i dent previously evaluated , so the probability of accidents prev i ously evaluated is unaffected by the proposed change. In addition , the E-7 Enclosure to NL-17-1089 Basis for Proposed Change proposed change does not alter the design or safety function of any safety related system. The proposed change emends the STA role as a function in lieu of a position and reduces the minimum required on-shift EP staffing for HNP and FNP by one. Minimum staffing studies were re-performed and confirmed on-shift staffing continues to be adequate to perform critical functions until relieved by the augmented emergency response organization (ERO) as required by 10 CFR 50.47(b)(2) and 10 CFR 50, Appendix E , Paragraph IV.A.9. As a result, manual operator action necessary to mitigate previously evaluated accidents continue to be persevered. Thus , the consequences of any accident are not affected by the proposed change. Therefore , the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed change emends the STA role as a function in lieu of a position and reduces the minimum required on-shift EP staffing for HNP and FNP by one. The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation , or new operator actions. The proposed change does not introduce failure modes that could result in a new accident , and the change does not alter assumptions made in the safety analysis. As a result , there are no new accident scenarios , failure mechanisms , including no new single failures , introduced as a result of the proposed change. Therefore , the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated. 3. Does the proposed amendment involve a significant reduction in a margin of safety? Response: No Safety margins are applied to the design and licensing basis functions and to the controlling values of parameters to account for various uncertainties and to avoid exceeding regulatory or licensing limits. The proposed change emends the STA role as a function in lieu of a position and reduces the minimum required on-shift EP staffing for HNP and FNP by one. The change does not impact any specific values that define margin established in each plant's licensing basis and , as a result, does not result in exceeding or altering a design basis or safety limit (i.e., the controlling numerical value for a parameter established in the UFSAR or the licenses). On-shift staffing continues to be adequate to perform critical functions until relieved by the augmented ERO as required by 10 CFR 50.47(b)(2) and 10 CFR 50 , Appendix E , Paragraph IV.A.9. Therefore , the proposed change does not involve a significant reduction in a margin of safety. E-8 Enclosure to NL-17-1089 Basis for Proposed Change 4.4 Conclus i on In conclusion , based on the considerations discussed here i n , (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner , (2) such 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. 5.0 Environmental Consideration The proposed amendments modify the technical specification administrative controls to emend the shift technical advisory role as a function in lieu of a position and eliminates a dedicated pos i tion from the Hatch Nuclear P l ant and Farley Nuclear Plant annexes to the Southern Nuclear Operating Company standard emergency plan , allowing the functions to be combined with one or more of other personnel positions.

The proposed amendments are confined to personnel actions and changes to administrative requirements. Accordingly , the proposed amendments meet the eligibility criterion for categorical exclusion set forth in categor i es (7) and (10) of 10 CFR 51.22(c). Therefore , pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared i n connect i on with the proposed amendments. 6.0 References

1. TSTF-258 , Revision 4 , " Changes to Section 5.0 , Administrative Controls ," June 29 , 1999. (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML040620 1 02) 2. NRC Generic Letter 86-04 , " Policy Statement on Engineering Expertise on Shift ," February 13 , 1986. (NRC ADAMS Accession No. ML031150270) 3. NUREG-0737 , " Clarificat i on of TMI Act i on Plan Requirements

," November 1980. (NRC ADAMS Accession No. ML051400209)

4. NEI 10-05 , " Assessment of On-Shift Emergency Response Organization Staffing and Capabilities

," Revision 0 , June 2011. (NRC ADAMS Accession No. ML 111751698)

5. NSIR/DPR-ISG-01 , " Inter i m Staff Guidance , Emergency Planning for Nuclear Power Plants ," Rev i sion 0 , November , 2011. (NRC ADAMS Accession No. ML 14106A057)
6. NRC Regulato r y Issue Summary 2016-10 , " License Amendment Requests fo r Changes to Emergency Response Organization Staffing and Augmentation

," August , 5 , 2016. (NRC ADAMS Access i on No. ML 16124A002)

7. NUREG-0654 FEMA-REP-1 , " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants ," Revision 1 , November 1990. ((NRC ADAMS Accession No. ML040420012)
8. Regulatory Guide 1.101 , " Emergency Planning and Preparedness for Nuclear Power Reactors ," Revision 5 , June 2005. (NRC ADAMS Accession No. ML050730286)

E-9 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 License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Attachment 1 Southern Nuclear Company Nuclear Facilities Technical Specification Marked-up Pages Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The operations manager or at least one assistant operations manager shall hold an SRO license. g. The Shift Technical Advisor (STA) An indiv i dua l shall provide advisory technical support to the shift supervisor unit operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. In addition , the STA This individua l shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. Th i s individual shall be available for duty when an operat i ng un i t is in MODE 1, 2 or 3. This same individua l may provide advisory technical support for both units. HATCH UNIT 1 5.0-4 Amendment No. 282 Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)
f. The operations manager or assistant operations manager shall hold an SRO license. g. The Shift Technical Advisor (STA)An individual shall provide advisory technical support to the shift supervisor unit operations shift crew in the areas of thermal hydraulics, reactor engineering , and plant analysis with regard to the safe operation of the unit. In addition, the STA This i ndividual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This individual shall be available for duty when an operating unit is in MODE 1, 2 or 3. This same individual may provide advisory technical support for both units. HATCH UNIT 2 5.0-4 Amendment No. 227 Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)
f. The operations manager or at least one assistant operations manager shall hold an SRO license. g. The Shift Technical Advisor (STJ\)An i nd i vidual shall provide advisory technical support to the responsible SRO unit operat i ons shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. In addition , the STA T h is ind i vidual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This individual shall be available for duty when an operating unit is in MODE 1, 2 , 3 , or 4. +Re-Th i s same individual may fill this position prov i de adv i sory technical support for both units. Farley Units 1 and 2 5.2-3 Amendment No. 207 (Unit 1) Amendment No. 203 (Unit 2)

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The operations manager or at least one assistant operations manager shall hold an SRO license. g. An individual shall be assigned who pro 1 1ides provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analys i s with regard to the safe operation of the unit. This individual shall be available for duty when the plant is in modes 1 4. At other times , this individual is not required.

In addition, this This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This individual shall be available for duty when an operatiing unit is in MODE 1, 2, 3, or 4. This same individual may provide advisory technical support for both units. ::i::J::Hs position may also be filled by the shift supervisor or the individual with an SRO license provided that person meets the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. Vogtle Units 1 and 2 5.2-3 Amendment No. 183 (Unit 1) Amendment No. 166 (Unit 2)

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 License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Attachment 2 Southern Nuclear Company Nuclear Facilities Revised Technical Specification Pages Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The operations manager or at least one assistant operations manager shall hold an SRO license. g. An individual shall prov i de advisory technical support to the unit operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the
  • Commission Policy Statement on Engineering Expertise on Shift. This individual shall be available for duty when an operating unit is in MODE 1 , 2 or 3. This same indiv i dual may provide advisory technical support for both units. HATCH UNIT 1 5.0-4 Amendment No.

O r ganization 5.2 5.2 Organization 5.2.2 Unit Staff (cont i nued) f. The operations manager or assistant operations manager shall hold an SRO license. g. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This. i ndividual shall be available for duty when an operating unit is in MODE 1 , 2 or 3. This same individual may provide advisory technical support for both units. HATCH UNIT 2 5.0-4 Amendment No.

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The operations manager or at least one assistant operations manager shall hold an SRO license. g. An individual shall provide advisory technical support to the un i t operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This individual shall be available for duty when an operating unit is in MODE 1 , 2 , 3 , or 4. This same individual may provide advisory technical support for both units. Farley Units 1 and 2 5.2-3 Amendment No. Amendment No. (Unit 1) (Unit 2)

Organization 5.2 5.2 Organization 5.2.2 Unit Staff (continued)

f. The operations manager or at least one assistant operations manager shall hold an SRO license. g. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics , reactor engineering , and plant analysis with regard to the safe operation of the unit. This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift. This individual shall be available for duty when an operating unit is in MODE 1 , 2 , 3 , or 4. This same individual may provide advisory technical support for both units. Vogtle Units 1 and 2 5.2-3 Amendment No. (Unit 1) Amendment No. (Unit 2)

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 License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Attachment 3 Southern Nuclear Operating Company Standard Emergency Plan and Applicable Annexes -Marked-up Pages SNC Standard Emergency Plan Version 3.0 2 B.2. I .3 TSC Operations Supervisor The Operations Supervisor reports to the TSC Manager. Major position functions include evaluating plant conditions and initiating mitigation actions , coordinating TSC efforts in determining the nature and extent of plant conditions affecting plant equipment, actions to limit or contain the emergency , invoking the provisions of I 0 CFR 50.54(x) (including completion of NRC notification), and assisting the OSC Mana ge r in determining the priority assigned to OSC activities.

B.2.1.4 TSC Maintenance Supervisor The Maintenance Supervisor reports to the TSC Manager and is responsible for planning and coordination of repair , damage control , and plant modification activities. The Maintenance Supervisor works closely with the Engineering Supervisor in planning for plant modifications and repairs. B.2.1.5 TSC Radiation Protection (RP) Supervisor The RP Supervisor reports to the TSC Manager and supervises the activities of the radiation protection staff and Health Physics Network (HPN) Communicator.

The RP Supervisor assists the Radiation Protection

/Chemistry Group Lead in the OSC in determining the extent and nature of radiological or hazardous conditions , and assists in the establishment of offsite dose assessment activities prior to EOF activation. B.2. I .6 On-shift Dose Analyst The On-shift Dose Analyst normally responds to the TSC and reports to the Shift Manager. The On-shift Dose Analyst operates the dose assessment model to provide estimates of environmental dose in the event of a radiological release attributable to the event until this duty is transferred to the EOF. B.2.1.7 TSC Engineering Supervisor The E ngineering Supervisor reports to the TSC Manager. The TSC Engineering Supervisor is responsible for the overall direction of Engineering Group activities and assessment.

The Engineering Supervisor also directs the analysis of plant problems and core damage , and provides recommendations for plant modifications to mitigate the effects of the accident.

B.2.1.8 TSC Reactor Engineer The Reactor Engineer reports to the Engineering Supervisor in the TSC. The Reactor Engineer is responsible for monitoring core conditions and providing recommendations to maintain the viability of the core. The Reactor Engineer relieves the Shift Technical Ad,*isor {STA) Manager or Supervisor of the Core Thermal Analysis responsibilities.

B.2.1 .9 TSC Engineering Support The TSC Engineering Support reports to the Engineering Supervisor in the TSC. The TSC Engineering Support is responsible for monitoring the plant systems and planning corrective actions as appropriate.

17 SNC Standard Eme r gency Plan Annex for FNP Units 1 and 2 Version J3 Table 2.2.A -Farley Nuclear Plant On-Shift Staffing Major Functional Area Major Tasks Position On-Shift Emergency Direction Sh i ft Manager (SM)/ 1 and Control Emergency Director (ED) Plant Operations and Shift Supervisor (SRO) 2 Assessment of Reactor Operator (RO) 4 Operational Aspects Shift Support 1 Supervisor/Fire Brigade Leader (SRO/FBL) Note 1 System Operato r (SO) Not e 1 7 . Plant System Technical Support Sh i ft Support Superv i sor o r 4-Engineer i ng , Repair othe r tra i ned i nd i v i duals.Mt Note 2 and Corrective Actions Support Superv i sor/Shift

+eGhAiGa l Aei.i i so r ~SRQ/S+A) Notificat i on/ Notify licensee , state , local , and Licensed Operator (RO or Note 2 Communication federal personnel and ma i ntain SRO) communication Radiolog i cal Accident Offsite Dose Assessment Chemistry Techn i cian or 1 Assessment and other trained personnel Support of Operationa l In-plant surveys RP Technician or other 1 Accident Assessment trained personnel Offsite Surveys , Onsite (out-of-RP Technician or other 1 plant) trained personnel Protective Actions Radiation Protection

RP Technician 1 a. Access Control b. RP Coverage for repair , corrective actions , search and rescue , first-aid , and firefighting
c. Personnel monitoring
d. Dosimetry Chemistry/Radio

-chem i stry Chemistry Technician 1 Plant System Repair and Corrective Actions Maintenance Supervisor 1 Engineering , Repair Electrical Maintenance 1 and Corrective Actions Mechanical Maintenance 1 l&C Maintenance 1 Total: 2 54 Fire Fight i ng Fire Brigade Note 1 5 Rescue Operations and Rescue Operations/First 2 First Aid Aid Note 2 Site Access Control Security Security and Personnel Plan Accountability Note 1 -Fire Brigade made up of FB Leader (SSS) and 4 System Operators not assigned safe shutdown responsibilities. Note 2 -May be provided by shift personnel assigned other functions 12 SNC Standard Emergency Plan Annex for HNP Un i ts 1 and 2 Version 2 J Table 2.2.A -Hatch Nuclear Plant On-Shift Staffing Major Functional Area Major Tasks Position On-Shift Emergency Direction Shift Manager (SM)/ 1 and Control Emerqencv D i rector (ED) Plant Operations and Shift Supervisor (SRO) 2 Assessment of Operat i onal Aspects Reactor Operator (RO) 4 Sh i ft Support 1 Supervisor/F i re Brigade Leader (SRO/FBL)Not e 1 System Operator (SO) Not e 1 7 P l ant System Technical Support Shift Su1212ort Su12ervisor or 4'Note2 Engineering , Repair other tra i ned ind i vidual~ and Cor r ective Actions S1:113J3eFt a1:1J3er:viseF t Sl:!ift +eGAAiGal .A.Eli.*iseF

/<'r.r\/CT/\\

---'I Notificat i on/ Notify licensee , State local and Licensed Ope r ator (RO or Note 2 Commun i cation Federal personnel

& ma i ntain SRO) commun i cation Radiological Acciden t Offsite Dose Assessment Chemistry Technician or 1 Assessment and othe r trained personnel Support of Operational In-plant surveys RP Technician or other 1 Accident Assessment trained personnel Offsite Surveys Onsite (out-of-RP Technician or other 1 plant) trained personnel Protect i ve Actions Radiation P r otection: RP Technician 1 a. Access Control b. RP Cove r age for repa i r , correct i ve actions , sea r ch and rescue fi r st-a i d & firefighting

c. Personnel monitor i ng d. Dosime t rv Chemistry/Rad i o-chem i stry Chemistry Techn i cian 1 Plant System Repa i r and Corrective Act i ons Maintenance Supervisor 1 Enginee r ing Repair and Corrective Actions Electrical Maintenance 1 Mechanical Ma i ntenance 1 l&C Maintenance 1 Total: 2~ Fire Fighting F i re Brigade Not e 1 5 Rescue Operations and Rescue Operat i ons/First 2 First Aid A i d Note 2 Site Access Control a nd Security Security Personnel Plan Accountability Note 1 -F i re Brigade made up of FB Leader (SSS) and 4 System Operators not assigned safe shutdown responsibilities. Note 2 -May be provided by shift personnel assigned other functions. 10

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---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 License Amendment Request to Revise Technical Specification 5.2.2.g and Update Emergency Plan Minimum On-shift Staff Tables Attachment 4 Hatch Nuclear Plant Revised Emergency Plan On-shift Staffing Analysis

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