ML20045D769
| ML20045D769 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/2020 |
| From: | Jennivine Rankin NRC/NRR/VPOB |
| To: | Victor Hall Office of Nuclear Reactor Regulation |
| Jennivine Rankin EX. 1530 | |
| References | |
| Download: ML20045D769 (9) | |
Text
March 2, 2020 MEMORANDUM TO:
Victor E. Hall, Chief Vogtle Project Office Office of Nuclear Reactor Regulation FROM:
Jennivine Rankin, Project Manager /RA/
Vogtle Project Office Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF A PUBLIC MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ON FEBRUARY 13, 2020 The U.S. Nuclear Regulatory Commission (NRC) staff held a Category 1 public meeting with Southern Nuclear Operating Company (SNC) on February 13, 2020. The purpose of the meeting was to discuss SNCs proposed license amendment request (LAR) to change Combined License (COL) license condition (LC) 2.D.(1) and to discuss non-material issues related to completion of inspections, tests, analyses, and acceptance criteria (ITAAC).
The meeting notice can be found in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML20043C588. The meeting notice is also posted on the NRC public website. Enclosures 1 and 2 are the meeting agenda and attendance list for the meeting, respectively. The other documents referenced during the discussion can be found at the ADAMS Accession Nos. given below:
SNC Slides for COL Condition 2.D.(1) and non-material issues related to ITAAC ML20038A102 Draft Sample LAR to support non-material issues related to ITAAC discussion ML20041E075 NRC presentation Slides to support non-material issues related to ITAAC discussion ML20042E344 CONTACT: Jennivine Rankin, NRR/VPO (301) 415-1530
V. Hall Summary of Meeting:
Technical Discussion: Proposed LAR to change COL License Condition 2.D.(1)
On February 13, 2020, staff from the NRC conducted a public meeting with representatives from SNC to discuss a potential LAR to change COL License Condition 2.D.(1) by replacing the Changes during Construction (CdC) process addressed in COL-ISG-025, Interim Staff Guidance on Changes During Construction Under 10 CFR Part 52, with a site-specific at-risk CdC process. SNC staff reviewed the background of COL-ISG-025, the administrative burden of the preliminary amendment request (PAR) process and the need for a change to allow additional flexibility during construction by allowing construction/testing to lead licensing basis changes prior to commencement of power ascension testing. SNC emphasized that the proposal of replacing the PAR process in LC 2.D.(1) with an allowance to proceed at-risk with construction/testing activities in advance of a regulatory evaluation would require that the CdC be incorporated, or the plant restored to the current licensing basis prior to the applicable requirement being needed (e.g., ITAAC closure notification (ICN) submittal, technical specifications mode applicability). In addition, SNC maintains the risk of returning the plant to the CLB if the change is not approved. The NRC and SNC discussion are highlighted below:
The NRC staff expressed concern that SNCs proposed revision to LC 2.D.(1) language does not identify a timeframe for when LARs should be formally submitted to the NRC.
SNC stated that formal completion of a straightforward Title 10 of the Code of Federal Regulations (10 CFR) 50.59 evaluation takes a minimum of several days. SNCs proposal would rely on the corrective action program to document the engineering analysis and decision. The regulatory decision via the 10 CFR 50.59 or LAR would be complete prior to the needed date.
The NRC staff noted that SNC should look to see if other processes or regulations are affected. Examples include the ICN process, changes to Tier 1 information, exemptions to other portions of 10 CFR, ITAAC hearing process, and the proposed no significant hazards considerations under 10 CFR 50.91.
The NRC staff noted that originally COL-ISG-025 was based on the interpretation that 10 CFR 50.10 does not allow construction to proceed until the licensing basis is changed. The current proposal is a change in the interpretation of 10 CFR 50.10 to only apply to the licensee receiving the appropriate license (e.g., Combined License) prior to commencing construction.
The NRC staff is currently working on draft regulatory guide (DG) 1321 to allow more flexibility during construction. The staff expects to have the DG out for public comment around March 2020. This may inform SNCs future LAR submittal.
SNC indicated they will evaluate the NRC staffs feedback and schedule a pre-submittal meeting with the NRC staff at a future date.
At the conclusion of the presentation, there was an opportunity for the public to provide comments and ask questions. There were several public comments questioning the need for a modification of the LC and SNCs interpretation of 10 CFR 50.10(c). In addition, there was a question regarding the applicability of SNCs proposal on advanced reactors. The NRC responded that the results of the DG would inform its applicability throughout the industry.
V. Hall Technical Discussion: Non-Material Issues Related to Completion of ITAAC On February 13, 2020, staff from the NRC conducted a public meeting with representatives from SNC to discuss non-material issues related to completion of ITAAC. The SNC and NRC discussion are highlighted below:
SNC described a streamlined LAR to address instances where requirements in an ITAAC were not necessary to show the design commitment was met. SNC also provided an example with testing of the accumulator that limited the SNCs flexibility during construction.
The NRC staff provided a timeline of how the NRC could streamline its review to approximately 35 days depending on the complexity and safety significance of the issue.
SNC and the NRC staff agreed communication between licensing organizations would be important in establishing expectations.
SNC indicated that in the 2015 timeframe, SNC performed a global review of the ITAAC and submitted LARs to correct many of the ITAAC affecting the design. Currently, the anticipated LARs would be associated with the installation and testing components of the ITAAC.
The NRC staff proposed crafting the LAR to reflect how NRC conducts its review. This may save the staff time during the review.
The NRC staff emphasized that this is not a departure from agency processes and the reviews will be conducted commensurate with the safety significance of the requested change in accordance with our principles of good regulation.
At the conclusion of the presentation, there was an opportunity for the public to provide comments and ask questions. There were no comments or questions from the public.
Docket Nos.: 52-025 52-026
Enclosure:
As stated cc w/encls: See next page
- via e-mail NRC-001 OFFICE PM: NRR/VPO LA: NRR/VPO PM: NRR/VPO BC: NRR/VPO NAME JRankin* (c)
RButler*
CSantos*
VHall*
DATE 2/24/2020 2/16/2020 2/25/2020 2/28/2020 OFFICE PM: NRR/VPO NAME JRankin (s)
DATE 3/2/2020
AGENDA FOR PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION (NRC)
Thursday, February 13, 2020 Teleconference 9:30 a.m. - 12:00 p.m.
PURPOSE:
To discuss issues associated with the safety review of licensing actions for Southern Nuclear Operating Companys (SNC) Vogtle Electric Generating Plant (VEGP) Units 3 and 4.
OPEN Time Topic Led By 9:30 a.m.
Opening Remarks NRC 9:40 a.m.
Discussion of Identified Topics NRC/SNC Opportunity for Public Comment Open Portion Concludes NRC/Public CLOSED 12:00 p.m.
(If needed)
Adjourn NRC/SNC
PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION Thursday, February 13, 2020 One White Flint North, Room O-11B4 9:30 a.m. - 12:00 p.m.
List of Attendees Name Organization Representing the Nuclear Regulatory Commission Jennivine Rankin Mike King Chandu Patel Vic Hall Alina Schiller Billy Gleaves Don Habib*
Chris Welch*
Olivier Lareynie NRR/VPO Michael Spencer Bob Weisman*
Olivia Mikula*
Joe Gillespie OGC Anna Bradford Michael Dudek NRR/DNRL Denise McGovern SECY Representing Industry Amy Chamberlain Neil Haggerty Eddie Grant Steven Leighty*
Tom Petrak*
Mark Humphries*
Southern Nuclear Operating Company Public Ravi Joshi*
Public Steve Franzone*
Florida Power and Light Jana Bergman*
Curtiss-Wright Bill Freebairn*
Platts
- = participated via teleconference
Vogtle Mailing List (Revised 2/13/2020) cc:
Resident Manager Resident Inspector Oglethorpe Power Corporation Vogtle Plant Units 3 & 4 Alvin W. Vogtle Nuclear Plant 8805 River Road 7821 River Road Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Barty Simonton Office of the Attorney General Team Leader 40 Capitol Square, SW Environmental Radiation Program Atlanta, GA 30334 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company 4244 International Parkway, Suite 120 Document Control Coordinator Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 Brian H. Whitley Regulatory Affairs Director Anne F. Appleby Southern Nuclear Operating Company Olgethorpe Power Corporation 3535 Colonnade Parkway, BIN N-226-EC 2100 East Exchange Place Birmingham, AL 35243 Tucker, GA 30084 Mr. Michael Yox County Commissioner Site Regulatory Affairs Director Office of the County Commissioner Vogtle Units 3 & 4 Burke County Commission 7825 River Road, Building 302 (ESB)
Waynesboro, GA 30830 Bin 6031 Waynesboro, GA 30830 Mr. Wayne Guilfoyle Commissioner District 8 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334 Page 1 of 3
Vogtle Mailing List Email aagibson@southernco.com (Amanda Gibson) acchambe@southernco.com (Amy Chamberlian) gam@nei.org (Gia Montserrat)
Lindsay@georgiawand.org (Lindsay Harper) bhwhitley@southernco.com (Brian Whitley)
Bill.Jacobs@gdsassociates.com (Bill Jacobs) corletmm@westinghouse.com (Michael M. Corletti) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dlfulton@southernco.com (Dale Fulton) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David)
G2NDRMDC@southernco.com (SNC Document Control)
George.Taylor@opc.com (George Taylor) harperzs@westinghouse.com (Zachary S. Harper) james1.beard@ge.com (James Beard)
JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)
John.Bozga@nrc.gov (John Bozga)
Joseph_Hegner@dom.com (Joseph Hegner) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy) kroberts@southernco.com (Kelli Roberts)
KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) markus.popa@hq.doe.gov (Markus Popa) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)
Melissa.Smith@Hq.Doe.Gov (Melissa Smith) mike.price@opc.com (M.W. Price)
MKWASHIN@southernco.com (MKWashington) mphumphr@southernco.com (Mark Humphrey)
MSF@nei.org (Marvin Fertel) nirsnet@nirs.org (Michael Mariotte)
Nuclaw@mindspring.com (Robert Temple)
Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) ppsena@southernco.com (Peter Sena,III) r.joshi15@comcast.net (Ravi Joshi) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) michelle@cleanenergy.org (Michelle Powell)
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Vogtle Mailing List Email (continued) sblanton@balch.com (Stanford Blanton)
Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) sjones@psc.state.ga.us (Shemetha Jones) skauffman@mpr.com (Storm Kauffman) slieghty@southernco.com (Steve Leighty) sroetger@psc.state.ga.us (Steve Roetger) syagee@southernco.com (Stephanie Agee)
TomClements329@cs.com (Tom Clements)
Vanessa.quinn@dhs.gov (Vanessa Quinn) wayne.marquino@gmail.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver)
William.Birge@hq.doe.gov (William Birge)
X2edgran@southernco.com (Eddie R. Grant) x2gabeck@southernco.com (Gary Becker)
X2hagge@southern.com (Neil Haggerty)
X2wwill@southernco.com (Daniel Williamson)
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