Charles R. Pierce Southern NuclearRegulatory Affairs Director Operating Company, Inc.4

40 Inverness Center Parkway SOUTH ERN .

Post Office Box 1295Birmingham, AL 35242 NUCLEARTel 205.992.7872Fax 205.992.7601 A SOUTHERN COMPANY'•,,

NL-16-0169FEBl 1 2016 10 CER 50.90

Docket Nos.: 50-32 1 50-348 50-424 52-02550-366 50-364 50-425 52-026

U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D. C. 20555-0001

Southern Nuclear Operating CompanyJoseph 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

Resp~onse to First Request for Additional Information RegardingqStandard Emergqency Plan

Ladies and Gentlemen:

By letter dated August 31, 2015 (NL-1 5-1392), Southern Nuclear Operating Company(SNC) requested license amendments (LARs) for approval of a fleet standardemergency plan for Edwin I. Hatch Nuclear Plant Units 1 and 2, Joseph M. FarleyNuclear Plant Units 1 and 2, and Vogtle Electric Generating Plant Units 1, 2, 3 and 4(Agencywide Documents Access and Management System (ADAMS) AccessionNumber ML15246A045). By letter dated December 2, 2015, the U.S. NuclearRegulatory Commission (NRC) requested additional information (ADAMS AccessionNumber ML 15334A009).

Specifically, SNC proposed to change the current Joint Information Centers (JICs)described in the respective site emergency plans to incorporate an SNC fleet standardapproach for a JIC/Joint Information System (JIS). The NRC's request for additionalinformation (RAI), in regards to the SNC LAR Enclosure 3, "Corporate Joint InformationCenter Description and Technical Evaluation," was issued to support the NRC staff'sContinued technical review of the proposed change.

The NRC RAI and the SNC response is provided below. Additional information,including revisions to SNO documents submitted on August 31, 2015 that support theSNC response to the RAI, is attached in the enclosures.

SNC is notifying the states of Georgia and Alabama of this response to the NRC RAI bytransmitting a copy of this letter and enclosures to the designated state official.

This letter contains no new regulatory commitments. If you have any questions, pleasecontact Ken McElroy at (205) 992-7369. ,-"/.• --

U. S. Nuclear Regulatory CommissionNL-1 6-0169Page 2

This letter contains no new regulatory commitments. If you have any questions,please contact Ken McElroy at (205) 992-7369.

Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern NuclearOperating Company, is authorized to execute this oath on behalf of SouthernNuclear Operating Company and, to the best of his knowledge and belief, thefacts set forth in this letter are true.

Respectfully sub :itted,

C. R. Pierce '

Regulatory Affairs Director '

CRP/EFB/lac

Sworn to and subscribed before me this JZiday of• • , 2016.

v /NtaryPublic

My commission expires: V - 2 "'o("

Attachment 1 - NRC RAI and SNC Response

Enclosures:

1. Evaluation of the Proposed Changes - LAR for the Adoption of a StandardEmergency Plan for the SNO Fleet (Marked-up pages)

2. SNC Standard Emergency Plan. (Marked-up pages)3. Corporate Joint Information Center Staffing - Detailed Description and

Technical Evaluation. (Deleted)4. Farley Staffing - Detailed Description and Technical Evaluation. (Marked-

up pages)5. Farley Standard Emergency Plan Annex. (Marked-up pages)6. Farley Justification Matrix (Marked-up pages)7. Hatch Staffing - Detailed Description and Technical Evaluation. (Marked-

up pages)8. Hatch Standard Emergency Plan Annex (Marked-up pages)9. Hatch Justification Matrix. (Marked-up pages)10. Vogtle (Units 1 and 2) Staffing - Detailed Description and Technical

Evaluation. (Marked-up pages)11. .Vogtle (Units 1 and 2) Standard Emergency Plan Annex. (Marked-up

pages)12. Vogtle (Units 1 and 2) Justification Matrix. (Marked-up pages)

U. S. Nuclear Regulatory CommissionNL-16-0169Page 3

13. Vogtle (Units 3 and 4) Staffing - Detailed Description and Technical Evaluation.(Marked-up pages)

14. Vogtle (Units 3 and 4) Standard Emergency Plan Annex. (Marked-up pages)15. Vogtle (Units 3 and 4) Justification Matrix. (Marked-up pages)16. Evaluation of Proposed Changes - LAR for the Revision to Vogtle 3 and 4

Emergency Planning ITAAC. (No changes)17. Vogtle (Units 3 and 4) Revision to Unit 3 COL Appendix C - Proposed Changes

- Markups. (No changes)18. Vogtle (Units 3 and 4) Revision to Unit 4 COL Appendix C - Proposed Changes

- Markups. (No changes)19. Off-site Response Organizations - Letters of Consultation and Concurrence

(New Letters Replacing Originals)20. SNC Standard Emergency Plan LAR (Updated clean version of Enclosures 1-

19)

cc: Nuclear Reciulatory CommissionMs. C. Haney, Regional AdministratorMs. J. Uhle, Director, Office of New ReactorsMr. M. Delligatti, Deputy Division Director, DNRLMr. L. Burkhart, Branch Chief, LB4, DNRLMr. M. E. Ernstes, Branch Chief, DRP, RIIMr. J. McKirgan, Branch ChiefMr. W. C. GleavesMr. T. E. ChandlerMs. P. Braxton, Resident Inspector - Vogtle 3 & 4Mr. R. E. Martin, NRR Senior Project Manager - Vogtle 1 & 2Mr. S. A. Williams, NRR Project Manager - FarleyMr. M. D. Orenak, NRR Project Manager - HatchMr. C. Patel, NRO Project Manager - Vogtle 3 & 4Mr. P. Kallan, Senior Project Manager - Vogtle 3 & 4Mr. B. M. Bavol, Project Manager - Vogtle 3 & 4Ms. R. Reyes, Project Manager - Vogtle 3 & 4Ms. M. A. Sutton, Project Manager - Vogtle 3 & 4Mr. D. H. Hardage, Senior Resident Inspector - HatchMr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2Mr. P. K. Niebaum, Senior Resident Inspector- FarleyMr. J. D. Fuller, Senior Resident Inspector, Vogtle 3 & 4Mr. C. B. Abbott, Resident Inspector - Vogtle 3 & 4Ms. S. Temple, Resident Inspector - Vogtle 3 & 4

Alabama Department of Public HealthDr. T. M. Miller, State Health Officer

State of GeorgiaMr. J. H. Turner, Director- Environmental Protection Division

U. S. Nuclear Regulatory CommissionNL-1 6-01 69Page 4

Blind Copyv List (without enclosures unless noted):

Southern Nuclear Operating CompanyMr. S. E. Kuczynski, Chairman, President & CEOMr. D. G. Bost, Executive Vice President & Chief Nuclear OfficerMr. J. T. Gasser, Executive V.P. Operational Readiness - Vogtle 1-4Mr. D. L. McKinney, Vice President, Nuclear Development. - Vogtle 3-4Mr. M. D. Rauckhorst, Vice President, Construction - Vogtle 3-4Mr. D. H. Jones, Vice President Technical Compliance - Vogtle 3-4Ms. K. D. Fili - Vice President - Operational ReadinessMs. C. A. Gayheart, Vice President - FarleyMr. D. R. Vineyard, Vice President - HatchMr. B. K. Taber, Vice President - Vogtle 1-2Mr. D. R. Madison, Vice President - Fleet OperationsMr. M. D. Meier, Vice President - Regulatory AffairsMr. B. J. Adams, Vice President - EngineeringMr. C. R. Pierce, Regulatory Affairs Director - FleetMr. B. H. Whitley, Regulatory Affairs Director - Nuclear DevelopmentMr. M. J. Yox, Regulatory Affairs Director - Vogtle 3-4Ms. B. L. Taylor, Regulatory Affairs Manager - FarleyMr. G. L. Johnson, Regulatory Affairs Manager - HatchMr. G. W. Gunn, Regulatory Affairs Manager - Vogtle 1-2Mr. W. A. Sparkman, Licensing Manager - Nuclear DevelopmentMr. T. W. Yelverton - Commercial Director - Vogtle 3-4Mr. J. C. Hasweli, Regulatory Manager - Vogtle 3-4Ms. K. A. Roberts, Licensing Supervisor - Vogtle 3-4Mr. D. L. Fulton - Nuclear Development Environmental ManagerMr. T. R. Takats - Engineering SupervisorMr. J. P. Redd - Licensing SupervisorRTYPEs: CFA04.054; CHA02.004; CVC7000; VND.LI.L00 (w/enclosures)File AR.01 .02.06 (w/enclosures)

Oglethorpe Power CorporationMr. M. W. PriceMr. Ms. K. T. HaynesMs. A Whaley

Municipal Electric Authority of GeorgiaMr. J. E. FullerMr. S. M. Jackson

Dalton UtilitiesMr. T. Bundros

U. S. Nuclear Regulatory CommissionNL-16-0 169Page 5

Westinqhouse Electric Company. LLCMr. R. EasterlingMr. J. W. CrenshawMr. C. D. ChurchmanMr. L. WoodcockMr. P. A. RussMr. G. F. CoutureMr. M. Y. ShaqqoMs. K. StonerMr. C. A.Castell

OtherMr. J. E. Hesler, Bechtel Power CorporationMs. L. A. Matis, Tetra Tech NUS, Inc.Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.Mr. S. Roetger, Georgia Public Service CommissionMs. S. W. Kernizan, Georgia Public Service CommissionMr. K. C. Greene, Troutman SandersMr. S. Blanton, Balch BinghamMr. R Grumbir, APOGMr. J. R. Bouknight, South Carolina Electric & Gas CompanyMr. D. Kersey, South Carolina Electric & Gas CompanyMr. B. Kitchen, Duke EnergyMr. S. Franzone, Florida Power & LightMs. A. Rice, South Carolina Electric & Gas Company

ATTACHMENT 1To NL-16-0169

SNC Response to NRC RAI-1Fleet Standard Emergency Plan

NRC RAI-1

The letters provided in Enclosure 19, "Off-site Response Organizations Letters ofConsultation and Concurrence," provides the following "boilerplate language"describing the level of changes discussed with applicable State and localgovernmental authorities:

This discussion included but was not limited to layout and formatof the Southern Nuclear emergency plan base document and sitespecific annexes, reduction in level of detail of the overall contentof the plan consistent with a planning level document, proposedchanges to on-shift and augmented emergency responsepersonnel staffing, proposed changes to emergency responsepersonnel augmentation time, standardization of Southern NuclearFleet position titles and duties, proposed changes to disseminationof public information, etc.

Please provide documentation that the offsite response organizations havereviewed and concur on the proposed changes with respect to the relocation ofthe JICs and its potential impact on their respective radiological emergencypreparedness (REP) plans. Additionally, please identify whether other proposedchanges to the respective site emergency plans were evaluated for their impactthe State and local response organizations ability to effectively implement theirFEMA-approved REP plans, specifically in regards to licensee interface andcoordination with State and local response organizations. If so, please provideevaluation performed and documentation regarding discussions with affectedState and local response organizations used in making this determination.[NOTE: Per 10 CFR 50/54 (s) (3), any change to the licensee's emergency planthat impacts or has the potential to impact State and local REP plans will beprovided to FEMA for review to verify that continued reasonable assurance existsthat State and local emergency plans can be implemented. As such, anadequate evaluation and documentation of coordination with offsite responseorganization needs to be provided as part of licensee's submittal.]

SNC Response

SNC performed a detailed review of the relevant off-site response organization(ORO) emergency plans to identify potential impacts resulting from the proposedSNC fleet standard emergency plan. Only minor editorial changes related to theSNC emergency plan document titles were identified. Nonetheless, SNC heldadditional discussions with the OROs to provide further clarification and answerany questions. Specifically, in addition to covering the specific changes thatwould be needed to the ORO emergency plans, SNC and the OROs discusseddetails of the personnel interfaces and coordination necessary to effectivelyimplement the plans during an emergency. The OROs concur there are noadverse impacts to their respective emergency plans from the proposed SNC

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ATTACHMENT 1To NL-16-0169

SNC Response to NRC RAI-1Fleet Standard Emergency Plan

fleet standard emergency plan and have responded via letters to this effect.These letters of concurrence are provided in Enclosure 19 and replace the OROconcurrence letters originally submitted. Savannah River Site (SRS) has electednot to provide a follow-up response to their initial acknowledgement letter inkeeping with SRS's position that, as a Department of Energy facility, a simple"acknowledgement" letter is appropriate rather than a "concurrence" letter.

The August 31, 2015 SNC submittal contained provisions for designating theAlabama Power Company and Georgia Power Company Corporate MediaCenters (CMCs) located in Birmingham, Alabama and Atlanta, Georgiarespectively as the official Joint Information Center (JiC) until such time as thenear site JIC could be established. This proposal included prescribing a minimumactivation time for this facility of 75 minutes. Moving the JIC to the CMC locationswas intended to facilitate meeting the 75 minute minimum staff augmentationtime.

The SNC proposal to add a minimum staff augmentation time was predicated onproposed changes to NUREG-0654, Criteria for Preparation and Evaluation ofRadiological Emergency Response Plans and Preparedness in Support ofNuclear Power Plants. However, based on recent input from NRC staff, thecurrent version of NUREG-0654 (Revision 1), which does not require a minimumstaff augmentation time, will continue to be an acceptable means of meeting therequirements of 10 CFR 50.47 even after issuance of the proposed changes toNUREG-0654 (Revision 2).

Consequently, SNC has decided not to propose these changes to the JIC asoriginally described to the NRC in Enclosure 3 of the SNC submittal on August31, 2015. SNC's practice for coordination and dissemination of information to thepublic as provided in the current SNC emergency plans and the State and Countyemergency plans via the near site JICs will remain unchanged in the SNC fleetstandard emergency plan. Accordingly, SNC has enclosed the correspondingchanges, including marked-up pages, to the original enclosures and hasenclosed a clean revised copy of the entire submittal in Enclosure 20 forconvenience. A few minor editorial and typographical corrections are alsoincluded. These revisions reflect the deletion of the 75 minute JIC augmentationcommitment, the re-assignment of the SNC Spokesperson and TechnicalAssistant from the EOF to the JIC as described in the current emergency plans,and the description of the JIC and CMC as separate facilities.

A1-2

Southern Nuclear Operating CompanyJoseph 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 1Evaluation of the Proposed Changes

(Marked -up pages)

Evaluation of Proposed Changes

Table of Contents

1. SUMMARY DESCRIPTION

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION

3. REGULATORY EVALUATION

3.1 Applicable Regulatory Requirements3.2 Precedent3.3 No Significant Hazards Consideration Determination

4. STATE CONSULTATION

5. ENVIRONMENTAL ASSESSMENT

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FEnclosure 1 to NL-16-0169Evaluation of the Proposed Changes

1. SUMMARY DESCRIPTION

Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests amendmentsto the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear PlantUnits 1 and 2, Vogtle Electric Generating Plant Units 1 and 2, and Vogtle Electric GeneratingPlant Units 3 and 4.

Specifically, the proposed changes would revise each plant's license in order to adopt a fleetSNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishesan updated licensing basis for the SNO operating plants that complies with current NRCregulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.

By standardizing emergency plans, SNC will make improvements to the fleet by increasingconsistency of organizations, duties and responsibilities, procedures, and training. SNC also willalign the plants using consistent standards and definitions.

Among the more notable proposed changes are a) the adoption of a standard staffaugmentation time period of 75 minutes from time of declaration of an Alert or higherEmergency Classification, b) changes in staffing numbers, and c) changes in staffing duties.•and, d) .... ncol÷d"io of tho oint,,, Informatio Contor.•-*' Although SNC has implementedsignificant improvements in overall staffing, procedures, training, and technology since theNRC's initial approval of the plant emergency plans, SNC has conservatively evaluated theproposed changes as reductions in effectiveness requiring NRC approval.

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION

The SNC SEP is attached as Enclosure 2. A-The detailed description and technical evaluationof the Corporate Joint Information Center s,,afi•g-"i,, sformerly documented in Enclosure 3 hasbeen deleted because SNC has determined that no changes are necessary.

Detailed descriptions and technical evaluations of the site emergency plan staffing changes aredocumented in Enclosures 4 (Farley), 7 (Hatch), 10 (Vogtle 1-2), and 13 (Vogtle 3-4).

The SNC Standard Emergency Plan is supplemented by plant-specific annexes documented inEnclosures 5 (Farley), 8 (Hatch), 11 (Vogtle 1-2), and 14 (Vogtle 3-4).

A Justification Matrix for each plant identifies the wording in the current plant emergency plansections, the revised wording and location in the Standard Emergency Plan or Annex, and thereasoning behind or justification for the change. The matrices are documented in Enclosures 6(Farley), 9 (Hatch), 12 (Vogtle 1-2), and 15 (Vogtle 3-4).

At the end of each Justification Matrix are two additional tables for the Site On-Shift and SiteAugmented Emergency Response Organization that compare the number of personsperforming major tasks in each major functional area with the guidance in NUREG 0654, theemergency plan first approved by the NRC, the current emergency plan, and the proposed SNCStandard Emergency Plan.

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Enclosure i to NL-1 6-01 69Evaluation of the Proposed Changes

3. REGULATORY EVALUATION

3.1 Applicable Regulatory Requirements

The SNC Standard Emergency Plan establishes an updated licensing basis for the SNC plantsthat complies with current NRC regulations in 10 CFR 50.47(b) and 10 CFR 50, Appendix E. Inaddition, the SNC plan complies with NRC-generated guidance in NUREG-0654/FEMA-REP-1Revision 1.

3.2 Precedent

The SNC SEP was modeled generally after the Exelon Standardized Radiological EmergencyPlan. (See ML1 3200A1 24.) The NRC has previously approved increases in staff augmentationtimes. (See, e.g., ML112450464.)

3.3 No Significant Hazards Consideration Determination

Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests amendmentsto the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. Hatch Nuclear PlantUnits 1 and 2, Vogtle Electric Generating Plant Units 1 and 2, and Vogtle Electric GeneratingPlant Units 3 and 4.

Specifically, the proposed changes would revise each plant's license in order to adopt a fleetSNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishesan updated licensing basis for the SNC operating plants that complies with current NRCregulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.

By standardizing emergency plans, SNC will make improvements to the fleet by increasingconsistency of organizations, duties and responsibilities, procedures, and training. SNC also willalign the plants using consistent standards and definitions. Put simply, the changes will makeSNC's emergency plan easier to follow and understand.

Among the more notable changes are a) the adoption of a standard staff augmentation timeperiod of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b)changes in staffing numbers, and c) changes in staffing duties, and d) consolidation of tho JointInformation Contor. Although SNC has implemented significant improvements in overallstaffing, procedures, training, and technology since the NRC's initial approval of the plantemergency plans, SNC has conservatively evaluated these changes as reductions ineffectiveness requiring NRC approval per 10 CER 50.54(q).

SNC has evaluated whether or not a significant hazards consideration is involvedwith the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92,"Issuance of amendment," as discussed below:

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Enclosure i to NL-16-0169Evaluation of the Proposed Changes

1) Does the proposed amendment involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response: No.

The proposed changes have no effect on normal plant operation or on any accident initiator orprecursors, and do not impact the function of plant structures, systems, or components (SSCs).The proposed changes do not alter or prevent the ability of the emergency responseorganization to perform its intended functions to mitigate the consequences of an accident orevent. The ability of the emergency response organization to respond adequately to radiologicalemergencies has been demonstrated as acceptable through a staffing analysis as required by10 CFR 50 Appendix E.IV.A.9.

Therefore, the proposed changes do not involve a significant increase in theprobability or consequences of an accident previously evaluated.

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

Response: No.

The proposed changes will not change the design function or operation of SSCs. The changesdo not impact the accident analysis. The changes do not involve a physical alteration of theplant, a change in the method of plant operation, or new operator actions. The proposedchanges do not introduce failure modes that could result in a new accident, and the changes donot alter assumptions made in the safety analysis. As demonstrated by the SNC staffinganalysis performed in accordance with 10 CFR 50 Appendix E.IV.A.9, the proposed changes donot alter or prevent the ability of the emergency response organization to perform its intendedfunctions to mitigate the consequences of an accident or event.

Therefore, the proposed changes do not create the possibility of a new or different kind ofaccident from any accident previously evaluated.

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

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e.,fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit thelevel of radiation dose to the public. The proposed changes are associated with the EmergencyPlan and do not impact operation of the plant or its response to transients or accidents. Thechanges do not affect the Technical Specifications. The changes do not involve a change in themethod of plant operation, and no accident analyses will be affected by the proposed changes.Safety analysis acceptance criteria are not affected. The Standard Emergency Plan willcontinue to provide the necessary response staff for emergencies as demonstrated by staffingand functional analyses including the necessary timeliness of performing major tasks for thefunctional areas of the Emergency Plan. The proposed changes do not adversely affect SNC'sability to meet the requirements of 10 CFR 50 Appendix E and the emergency planningstandards of 10 CFR 50.47.

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Enclosure i to NL-16-0169Evaluation of the Proposed Changes

Therefore, the proposed change does not involve a significant reduction in themargin of safety.

Based on the above evaluation, SNC has determined that operation of the subject facilities inaccordance with the proposed changes does not involve a significant hazards consideration asdefined in 10 CFR 50.92(c), in that it does not: 1) involve a significant increase in the probabilityor consequences of an accident previously evaluated; 2) create the possibility of a new ordifferent kind of accident from any accident previously evaluated; or 3) involve a significantreduction in a margin of safety.

4. STATE CONSULTATION

SNC has consulted with the appropriate state and county officials from Alabama, Georgia, and

South Carolina and has received their support for the SEP.

5. ENVIRONMENTAL ASSESSMENT

In accordance with 10 CFR 51, the following information is provided in support of a finding thatthe adoption of the SNC Standard Emergency Plan has no significant effect on the quality of thehuman environment.

Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) has requestedamendments to the licenses for Joseph M. Farley Nuclear Plant Units 1 and 2, Edwin I. HatchNuclear Plant Units 1 and 2, Vogtle Electric Generating Plant Units 1 and 2. and Vogtle ElectricGenerating Plant Units 3 and 4.

Specifically, the proposed changes would revise each plant's license in order to adopt a fleetSNC Standard Emergency Plan (SEP) that includes site-specific Annexes. The SEP establishesan updated licensing basis for the SNC operating plants that complies with current NRCregulations in 10 CFR 50.47, 10 CFR 50 Appendix E, and NRC-generated guidance in NUREG-0654/FEMA-REP-1 Revision 1.

By standardizing emergency plans, SNC will make improvements to the fleet by increasingconsistency of organizations, duties and responsibilities, procedures, and training. SNC also willalign the plants using consistent standards and definitions. Put simply, the changes will makeSNC's emergency plan easier to follow and understand.

Among the more notable changes are a) the adoption of a standard staff augmentation timeperiod of 75 minutes from time of declaration of an Alert or higher Emergency Classification, b)changes in staffing numbers, and c) changes in staffing duties, an"d d) con~clidation of the JointInformation Center. Although SNC has implemented significant improvements in overallstaffing, procedures, training, and technology since the NRC's initial approval of the plantemergency plans, SNC has conservatively evaluated the proposed changes as reductions ineffectiveness requiring NRC approval per 10 CFR 50.54(q).

SNC has determined that the proposed changes do not individually or cumulatively have asignificant effect on the human environment. The proposed amendment updates the licensing

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Enclosure i to NL-16-0169Evaluation of the Proposed Changes

basis for the plants and creates a standardized emergency plan. The associated changes tothe organization, staffing, and augmentation times will not affect the quality of the humanenvironment.

As described above, SNC has determined that operation of the subject facilities in accordancewith the proposed changes does not involve a significant hazards consideration, in that it doesnot: 1) involve a significant increase in the probability or consequences of an accidentpreviously evaluated; 2) create the possibility of a new or different kind of accident from anyaccident previously evaluated; or 3) involve a significant reduction in a margin of safety.

SNC has determined that operation of the subject facilities in accordance with the proposedchanges does not authorize a significant change in the types or a significant increase in theamounts of any effluent that may be released offsite. The proposed changes are unrelated toany aspects of plant construction or operation that would introduce any changes to effluenttypes (e.g., effluents containing chemicals or biocides, sanitary system effluents, or othereffluents) or affect any plant radiological or non-radiological effluent release quantities.Furthermore, these changes do not diminish the functionality of any design or operationalfeatures that are credited with controlling the release of effluents during plant operation.

SNC has determined that operation of the subject facilities in accordance with the proposedchanges does not result in a significant increase in individual or cumulative occupationalradiation exposure. The proposed changes will not affect how a structure, system, orcomponent will be used to meet the design bases of the nuclear plant. The proposed changeswill have no effect on the construction or operation of the nuclear plants, and therefore wouldnot introduce any changes to the amount of occupational radiation exposure.

In conclusion, SNC has determined that anticipated construction and operational effects of theproposed amendment do not involve 1) a significant hazards consideration, 2) a significantchange in the types of or significant increase in the amounts of any effluents that may bereleased offsite, or 3) a significant increase in the individual or cumulative occupational radiationexposure. Consequently, the proposed amendment will not have a significant effect on thequality of the human environment.

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