ML25139A345
| ML25139A345 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/22/2025 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | |
| Shared Package | |
| ML25139A350 | List: |
| References | |
| EPID L-2025-LRM-0042 | |
| Download: ML25139A345 (6) | |
Text
May 22, 2025 LICENSEE:
Southern Nuclear Operating Company, Inc.
FACILITY:
Vogtle Electric Generating Plant, Units 3 and 4
SUBJECT:
SUMMARY
OF MAY 14, 2025, OBSERVATION PRE-SUBMITTAL MEETING HELD WITH SOUTHERN NUCLEAR OPERATING COMPANY, INC.,
REGARDING A PROPOSED EXEMPTION REQUEST FROM 10 CFR 50.71(h)(2) AND 10 CFR 50.71(h)(3) FOR VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 (EPID L-2025-LRM-0042)
On May 14, 2025, an Observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC, the Commission) and representatives of Southern Nuclear Operating Company, Inc. (SNC, the licensee). The purpose of the meeting was for SNC to describe its plan to submit an exemption request for Vogtle Electric Generating Plant (Vogtle), Units 3 and 4.
SNC is proposing an exemption from Title 10 of the Code of Federal Regulations (10 CFR),
Sections 50.71(h)(2) and 50.71(h)(3) requiring upgrade of the probabilistic risk assessment (PRA) to include low-power and shutdown (LPSD) modes of operation for Vogtle, Units 3 and 4.
On April 16, 2025 (Agencywide Documents and Access Management System (ADAMS)
Accession No. ML25107A167), the meeting was noticed on the NRC public webpage.
The NRC staff opened the meeting with introductory remarks and a roll call of the attendees.
The SNC representative presented slides contained in ML25128A019.
SNC discussed the following topics: background, request, justification, and schedule.
=
Background===
The regulation 10 CFR 50.71(h) states the following:
(h)(1) No later than the scheduled date for initial loading of fuel, each holder of a combined license under subpart C of 10 CFR part 52 shall develop a level 1 and a level 2 probabilistic risk assessment (PRA). The PRA must cover those initiating events and modes for which NRC-endorsed consensus standards on PRA exist one year prior to the scheduled date for initial loading of fuel.
(2) Each holder of a combined license shall maintain and upgrade the PRA required by paragraph (h)(1) of this section. The upgraded PRA must cover initiating events and modes of operation contained in NRC-endorsed consensus standards on PRA in effect one year prior to each required upgrade. The PRA must be upgraded every four years until the permanent cessation of operations under § 52.110(a) of this chapter.
(3) Each holder of a combined license shall, no later than the date on which the licensee submits an application for a renewed license, upgrade the PRA required by paragraph (h)(1) of this section to cover all modes and all initiating events.
SNC stated that 10 CFR 50.71(h)(2) and 10 CFR 50.71(h)(3) were added in 2007 via a final rule published in the Federal Register on August 28, 2007 (72 FR 49352).
SNC said that the provisions apply only to Combined Licenses (COLs) under 10 CFR Part 52.
SNC stated that the final rule discussion did not address the need for the upgrades.
SNC said that it remains unclear why a new scope of the PRA is necessary for COLs when currently operating plants are sufficiently safe using the currently existing low-power shutdown risk tools.
SNC stated that Chapter 19 of the Updated Final Safety Analysis Report presents an overview of the PRA performed for Vogtle, Units 3 and 4.
Request SNC said that the proposed exemption request is to allow SNC to NOT upgrade the PRA to include low-power and shutdown (LPSD) modes of operation. SNC said that it would update the full power PRA.
SNC stated that the exemption request (1) includes the current requirement to upgrade the PRA to include LPSD modes if an NRC-endorsed LPSD PRA standard exists at one year prior to the required upgrade (every four years) and (2) includes the current requirement to upgrade the PRA to include LPSD modes of operation before submittal of an application for a renewed license.
SNC Justification SNC stated that the exemption request (1) is authorized by law, (2) will not present an undue risk to the health and safety of the public, (3) is consistent with the common defense and security, and (4) special circumstances are present.
Schedule SNC said that it plans to submit the proposed exemption request by May 21, 2025.
SNC stated that it plans to request that the NRC staff complete its review by December 21, 2025 (acceptance plus 6 months).
Discussion The NRC staff asked the following questions:
Does SNC have an LPSD PRA for Vogtle, Units 3 and 4?
Is SNC going to ask for a permanent exemption to 10 CFR 50.71(h)(2) and 10 CFR 50.71(h)(3) for LPSD PRA?
What about defense in depth for LPSD?
What are the special circumstances for the exemption request?
Did SNC consider a scheduler exemption?
Why is SNC requesting that the NRC staff complete the exemption request by December 21, 2025?
Closing Remarks There were two members of the public in attendance, and each asked questions of the NRC staff.
The NRC staff did not make any regulatory decisions during the meeting. Once received, the NRC staff will perform a thorough review of the proposed exemption request. The NRC staff will make any regulatory decisions in writing in a timely manner. Public Meeting Feedback forms were available, but no comments were received.
The meeting adjourned at 3:57 pm Eastern Time (ET).
Please direct any inquiries to me at John.Lamb@nrc.gov or 301-415-3100.
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch, II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.52-025 and 52-026
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES MAY 14, 2025, PRE-SUBMITTAL MEETING WITH SOUTHERN NUCLEAR COMPANY REGARDING A PROPOSED EXEMPTION REQUEST TO 10 CFR 50.71(h)(2) and 10 CFR 50.71(h)(3)
VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 ATTENDEE REPRESENTING John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Mike Markley NRC Zach Turner NRC Steven Alferink NRC Keith Tetter NRC Michael Swim NRC Jigar Patel NRC Jeffery Wood NRC Ken Lowery Southern Nuclear Operating Company (SNC)
Ryan Joyce SNC Jeremiah Gilbreath SNC Vish Patel SNC Jordan Rice SNC Brad Dolan SNC Eddie Grant SNC Sari Alkhatib SNC Ryan Henderson SNC Victoria Anderson SNC Doug Hance SNC Susan Sterrett Public Jeff Julius Public - Jensen Hughes
Package: ML25139A350 Meeting Notice: ML25107A167 SNC Slides: ML25128A019 Meeting Summary: ML25139A345 OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA DRA/APLC/BC DORL/LPL2-1/BC DORL/LPL2-1/PM NAME JLamb KZeleznock SAlferink MMarkley JLamb DATE 05/14/2025 05/21/2025 05/22/2025 05/22/2025 05/22/2025