ML21314A583
| ML21314A583 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/10/2021 |
| From: | NRC |
| To: | NRC/NRR/DNRL |
| References | |
| Download: ML21314A583 (23) | |
Text
From: Santos, Cayetano Sent: Wednesday, November 10, 2021 5:28 PM To: Vogtle PEmails Cc: Gleaves, Billy
Subject:
NRC staff presentation for 11-10-21 public meeting with SNC Attachments: Presentation on requested exemption language.pptx
Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 627 Mail Envelope Properties (MN2PR09MB524486128D129C1F10A6CC69E5939)
Subject:
NRC staff presentation for 11-10-21 public meeting with SNC Sent Date: 11/10/2021 5:28:15 PM Received Date: 11/10/2021 5:28:16 PM From: Santos, Cayetano Created By: Cayetano.Santos@nrc.gov Recipients:
"Gleaves, Billy" <Bill.Gleaves@nrc.gov>
Tracking Status: None "Vogtle PEmails" <Vogtle.PEmails@usnrc.onmicrosoft.com>
Tracking Status: None Post Office: MN2PR09MB5244.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3 11/10/2021 5:28:16 PM Presentation on requested exemption language.pptx 1785522 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Discussion of proposed rule language changes discussed in the exemption request
Proposed language change discussed in the NRCs January 2021 regulatory basis document
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall implement the FFD program before the receipt of special nuclear material in the form of fuel assemblies.
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall implement the FFD program before the before receipt initial fuelof special nuclear load.
material in the form of fuel assemblies.
Proposed language change discussed in the licensees exemption request submittal
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall implement the FFD program before the receipt of special nuclear material in the form of fuel assemblies.
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after after the Commission initial loadinghas ofmade the the fuel into finding under reactor 10 CFR 52.103(g) shall vessel comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part after 52 after the initial loading Commission hasof fuel the made intofinding the reactor undervessel 10 CFR 52.103(g) shall implement the FFD program before the receipt of special nuclear material in the form of fuel assemblies.
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after after the Commission initial loadinghas ofmade the the fuel into finding under reactor 10 CFR 52.103(g) shall vessel comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part after 52 after the initial loading Commission hasof fuel the made intofinding the reactor undervessel 10 CFR 52.103(g) shall implement the FFD program before the receipt of special nuclear material in the form of fuel assemblies.
NRC considerations Consideration 1:
The timing of when exactly SNC intends to transition the Vogtle 3&4 Fitness for Duty programs out of Part 26, Appendix K (i.e. construction-phase requirements)
Consideration 2:
Which instance of the text, specifically, in Part 26.4(a)
SNC intends to change
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part 52 after the Commission has made the finding under 10 CFR 52.103(g) shall implement the FFD program before the receipt of special nuclear material in the form of fuel assemblies.
Consideration 3:
Potential gap created by the proposed language change
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after after the Commission initial loadinghas ofmade the the fuel into finding under reactor 10 CFR 52.103(g) shall vessel comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part after 52 after the initial loading Commission hasof fuel the made intofinding the reactor undervessel 10 CFR 52.103(g) shall implement the FFD program before the receipt of special nuclear material in the form of fuel assemblies.
§ 26.3 Scope.
(a) Licensees who are authorized to operate a nuclear power reactor under 10 CFR 50.57, and holders of a combined license under 10 CFR Part 52 after after the Commission initial loadinghas ofmade the the fuel into finding under reactor 10 CFR 52.103(g) shall vessel comply with the requirements of this part, except for subpart K of this part. Licensees who receive their authorization to operate a nuclear power reactor under 10 CFR 50.57 after the date of publication of this final rule in the Federal Register and holders of a combined license under 10 CFR Part after 52 after the initial loading Commission hasof fuel the made intofinding the reactor undervessel 10 CFR 52.103(g) shall implement the FFD program before the receipt of special nuclear material in the form of fuel assemblies.
Consideration 4:
Justification as to why this exemption is in the public interest - specifically, why site-specific information on reduced burden and the technical justification for the exemption (beyond the generic discussion in the NRCs regulatory basis document) is not included in the submittal
From SNCs submittal