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EPID:L-2023-LLA-0050, Summary of December 8, 2022, Public Meeting with Southern Nuclear Operating Company (Open) |
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Category:Meeting Summary
MONTHYEARML24025A1372024-01-31031 January 2024 Summary of Observation Pre-Submittal Meeting Held with Snc., Regarding a Proposed Alternative Request - Explosively Actuated Valves for Vogtle Electric Generating Plant, Units 3 and 4 ML24019A1932024-01-30030 January 2024 Summary of January 8, 2024, Observation Pre-Submittal Meeting Held with Southern Nuclear Operating Company Regarding a Proposed LAR for Vogtle Electric Generating Plant, Units 1, 2, 3, & 4; Hatch, Units 1 & 2; Farley, Units 1 & 2 ML23356A0282023-12-27027 December 2023 December 11, 2023, Pre-Application Meeting with SNC Regarding a Proposed Fleet LAR to Revise TS 5.3.1 to Relocate Training Qualification Requirements from TS to Their Qatr/Ndqam ML23311A1302023-11-17017 November 2023 Summary of Nov. 6, 2023, - Closed Meeting Held with Southern Nuclear Operating Company, Inc., Regarding Physical Barriers Exemptions for Hatch Units 1 & 2, Farley Units 1 & 2 and Vogtle Units 1, 2, 3 & 4 (EPID L-2023-LLE-0018 & L-2023-LLE-0 ML23313A0952023-11-16016 November 2023 Summary of November 7, 2023, Observation Pre-Submittal Meeting Held with Southern Nuclear Operating Company, Inc., Regarding a Proposed License Amendment Request for Vogtle Electric Generating Plant, Units 1 and 2 ML23303A2032023-11-0101 November 2023 October 24, 2023, Summary of Comment Gathering Public Meeting on Lessons Learned from the ITAAC Hearing Process for Vogtle Units 3 and 4 ML23275A0882023-10-12012 October 2023 Summary of Meeting with Southern Nuclear Operating Company ML23272A1822023-10-11011 October 2023 Summary of September 28, 2023, Observation Pre Submittal Meeting Held with Southern Nuclear Operating Company, Inc., Regarding a Proposed License Amendment Request for Vogtle Electric Generating Plant, Units 3 and 4 ML23230A0212023-08-30030 August 2023 LAR-22-002 Technical Specification 3.8.3 Summary of 08-17-23 Public Meeting ML23187A5742023-08-22022 August 2023 Summary of June 29, 2023, Meeting with Southern Nuclear Operating Company ML23146A1542023-06-0505 June 2023 Summary of May 25, 2023, Meeting with Southern Nuclear Operating Company ML23132A0412023-05-18018 May 2023 Summary of May 11, 2023, Meeting with Southern Nuclear Operating Company ML23121A1692023-05-12012 May 2023 Summary of Meeting with Southern Nuclear Operating Company Vogtle LAR-23-006 U/3&4 More Restrictive Action for TS 3.1.9 Cvs Isolation Valves ML23115A3282023-05-10010 May 2023 Summary of Public Meeting with Southern Nuclear Operating Company to Have a Pre-Submittal Discussion of Draft License Amendment Request (LAR) for Vogtle Electric Generating Plant (VEGP) Unit 3 ML23115A0662023-05-0101 May 2023 Summary of Public Meeting with Southern Nuclear Operating Company to Have Presubmittal Meeting for Vogtle Electric Generating Plant, Unit 4 IR 05000424/20040252023-04-28028 April 2023 Public Meeting Summary - Vogtle Electric Generating Plant, Units 1, 2, 3, & 4 Docket No. 5000424, 5000425, 5200025, 5200026, Meeting Number 20230375 ML23090A1422023-04-0303 April 2023 Summary of Conference Call Regarding the Spring 2022 Steam Generator Tube Inspections ML23065A0732023-03-17017 March 2023 March 2, 2023, Summary of Meeting with Southern Nuclear Operating Company - Vogtle Electric Generating Plant, Unit 4 ML23055A0902023-03-14014 March 2023 February 16, 2023, Summary of Meeting with Southern Nuclear Operating Company ML23048A0682023-03-0101 March 2023 Summary of February 13, 2023, Observation Pre-Submittal Meeting Held with Southern Nuclear Operating Company, Inc. 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Farley Nuclear Plant ML21238A1622021-09-10010 September 2021 Summary of Public Meeting with Southern Nuclear Operating Company, Inc., Regarding a Proposed License Amendment Request to Change the Technical Specification Related to Main Steam Isolation Valves for Vogtle Electric Generating Plant ML21225A5532021-08-31031 August 2021 August 13,2021, Public Meeting Summary with Southern Nuclear Operating Regarding Proposed LAR to Revise Technical Specifications Related to Reactor Trip System & Engineered Safety Feature Actuation System Instrumentation for Vogtle 1&2 (L-2 ML21230A0102021-08-24024 August 2021 Summary of Public Meeting with Southern Nuclear Operating Company on August 12, 2021 ML21154A2772021-07-20020 July 2021 Summary of a Public Meeting with Southern Nuclear Operating Company on May 27, 2021 ML21194A0402021-07-20020 July 2021 Summary of June 24, 2021 Public Meeting with SNC ML21190A0622021-07-16016 July 2021 Summary of July 8 2021 Public Meeting to Discuss Late-Filed Allegation Process for Vogtle Electric Generating Plant Units 3 and 4 2024-01-31
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January 3, 2023 LICENSEE: SOUTHERN NUCLEAR OPERATING COMPANY FACILITY: VOGTLE ELECTRIC GENERATING PLANT, UNIT 3
SUBJECT:
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