ML22349A214

Summary of December 8, 2022, Public Meeting with Southern Nuclear Operating Company

ML22349A214
Person / Time
Site:	Vogtle
Issue date:	01/03/2023
From:	Cayetano Santos NRC/NRR/VPOB
To:
References
Download: ML22349A214 (4)

Text

January 3, 2023 LICENSEE: SOUTHERN NUCLEAR OPERATING COMPANY FACILITY: VOGTLE ELECTRIC GENERATING PLANT, UNIT 3

SUMMARY

OF DECEMBER 8, 2022, MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY On December 8, 2022, the U.S. Nuclear Regulatory Commission (NRC) held a virtual public meeting with representatives of Southern Nuclear Operating Company (SNC or the licensee).

The purpose of the meeting was to have a pre-submittal discussion of a draft license amendment request (LAR) and exemption request (draft LAR 23-001) for Vogtle Unit 3. This LAR proposes to remove Appendix C (inspections, tests, analyses, and acceptance criteria or ITAAC) from the Unit 3 Combined License (COL). The exemption requests removal of Tier 1 and Tier 2* requirements in Appendix D to Part 52 of Title 10 of the Code of Federal Regulations (10 CFR), which includes requirements for NRC approval of changes to Tier 1 and Tier 2* information.

The meeting notice and agenda are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML22336A052. A list of attendees is enclosed.

SNC representatives described their technical and regulatory evaluations justifying the proposed license amendment and exemption requests. Draft LAR 23-001 is available in ADAMS (ML22332A537).

Below is a summary of the general comments and discussions regarding the request to remove Appendix C:

The NRC staff noted that some references in Enclosure 1 of draft LAR 23-001 to Appendix D,Section IX.A.3 may actually refer to Appendix D,Section IX.B.3.

If Appendix C were removed from the COL, the NRC staff has not yet determined whether subsequent changes to Tier 1 information would require only an exemption or both an exemption and a license amendment.

Below is a summary of the general comments and discussions regarding the exemption request:

The NRC staff noted that one of the major objectives of the 10 CFR Part 52 rule was to provide a process for the standardization of nuclear power plants, and the change control processes defined in the design certifications were chosen to prevent the loss of standardization while still allowing for the flexibility needed by licensees. This position

was consistently applied in the 10 CFR Part 52 rulemaking, the design certification rulemakings, and the proposed rule to apply lessons learned from new reactor licensing.

SNC representatives stated that since construction is complete and the 10 CFR 52.103(g) finding has been made for Vogtle Unit 3, significant design changes are not likely to be needed in the future so standardization would be maintained. In addition, the 10 CFR 50.59 change process would be sufficient to maintain safety because safety-significant changes would continue to be submitted to the NRC for review and approval.

The NRC staff noted that the 10 CFR Part 52 and design certification rulemakings clearly state that changes to Tier 1 information require an exemption whereas changes to Tier 2 information are to be evaluated using the 10 CFR 50.59 process. SNC representatives commented that the Commission also intended that the design certification rule would encompass roughly the same information that the 10 CFR 50.59 process would prohibit changing without NRC approval but that has not always been the case. During construction of Vogtle Unit 3, NRC approval was required for changes that had no impact to public health and safety because the change involved Tier 1 information that went beyond the Commissions intended level of detail necessary for Tier 1 information. The NRC staff responded that since there were situations in which exemptions were needed for changes with minimal safety significance, improvements to Tier 1 design certification content are needed as described in SECY-19-0034, Improving Design Certification Content, (ML19080A032). SNC representatives noted that the recommendations in SECY-19-0034 would not apply to Vogtle Units 3 and 4.

The NRC staff commented that since one of the underlying purposes of the 10 CFR Part 52 rule is to maintain standardization, the special circumstances described in the exemption request may not be present.

The NRC staff noted that the Tier 1 design descriptions are requirements for the lifetime of the facility. SNC representatives noted that since Tier 1 information is derived from Tier 2 information, the Tier 1 design descriptions will be maintained for the life of the facility. In addition, if major design changes are needed that would impact Tier 1 information, SNCs current process for evaluating changes to the Final Safety Analysis Report would require that such changes be submitted to NRC for review and approval prior to implementation.

The NRC staff agreed to send SNC additional references describing the regulatory history of 10 CFR Part 52 and design certifications.

The NRC staff noted that draft LAR 23-001 did not address the revised Tier 2*

evaluation process approved in LAR-17-037 approved in September 2018 (ML18235A029).

Members of the public were in attendance. There were no comments or questions from the public. The staff did not receive any Public Meeting Feedback forms.

Please direct any inquiries to me at 301-415-7270 or Cayetano.Santos@nrc.gov .

Sincerely, Signed by Santos, Cayetano on 01/03/23 Cayetano Santos Jr., Senior Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation Docket No.52-025

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES DECEMBER 8, 2022, MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY Name Organization Cayetano (Tanny) Santos Billy Gleaves Christopher Welch Victor Hall Phil OBryan James Gaslevic NRC/Office of Nuclear Reactor Regulation Garry Armstrong Joseph Colaccino Michael Dudek Nanette Valliere Ryan Nolan NRC/Advisory Committee on Reactor Michael Snodderly Safeguards Michael Spencer NRC/Office of the General Counsel Keith Dorsey Amy Chamberlain Eddie Grant Nathan Chapman Southern Nuclear Operating Company Neil Haggerty Wesley Sparkman Dan Williamson Jana Bergman Members of the Public Enclosure

ML22349A214 OFFICE NRR/VPO/VPOB NRR/VPO/VPOB NRR/VPO/VPOB NAME CSantos CS RButler RB CSantos CS DATE Dec 16, 2022 Dec 30, 2022 Jan 3, 2023