ML25265A043
| ML25265A043 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/25/2025 |
| From: | John Lamb Office of Nuclear Reactor Regulation |
| To: | Southern Nuclear Operating Co |
| References | |
| EPID L-2025-LRM-0094 | |
| Download: ML25265A043 (1) | |
Text
September 25, 2025 LICENSEE:
Southern Nuclear Operating Company, Inc.
FACILITY:
Vogtle Electric Generating Plant, Units 3 and 4
SUBJECT:
SUMMARY
OF SEPTEMBER 17, 2025, OBSERVATION PRE-SUBMITTAL MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY, INC.,
REGARDING PROPOSED LICENSE AMENDMENT REQUESTS FOR (1) RISK-INFORMED COMPLETION TIME PROGRAM, (2) 10 CFR 50.69, AND (3) SURVEILLANCE FREQUENCY CONTROL PROGRAM FOR VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 (EPID L-2025-LRM-0094)
On September 17, 2025, the U.S. Nuclear Regulatory Commission (NRC) held an Observation pre-submittal meeting with representatives from Southern Nuclear Operating Company, Inc.
(SNC, the licensee) regarding Vogtle Electric Generating Plant (Vogtle), Units 3 and 4. The purpose of the meeting was for SNC to outline its plan to submit three license amendment requests (LARs) for Vogtle, Units 3 and 4.
SNC intends to propose the following LARs:
- 1. Risk-Informed Completion Time (RICT) Program - Based on Technical Specification Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b (ML18183A493) and TSTF-591, Revise Risk-Informed Completion Time (RICT) Program (ML22081A224).
- 2. Adoption of Title 10 of the Code of Federal Regulations (10 CFR),
Section 50.69 - Risk-informed categorization and treatment of structures, systems, and components for nuclear power reactors.
- 3. Surveillance Frequency Control Program (SFCP) - Based on TSTF-425, Revision 3, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b (ADAMS Package ML090850642), TSTF-563, Revise Instrument Testing Definitions to Incorporate the SFCP (ADAMS Package ML18333A152), and TSTF-596, Revision 2, Expand the Applicability of the SFCP (ML24282B020).
The meeting was publicly announced on August 19, 2025, via the NRCs public website (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25231A077). A list of attendees is provided in the Enclosure.
The NRC staff opened the meeting with introductory remarks and a roll call. SNC representatives then presented slides (ML25247A004) and discussed the three proposed LAR topics: (1) RICT Program, (2) 10 CFR 50.69, and (3) SFCP.
Proposed RICT LAR For the proposed RICT LAR, SNC presented the following:
Description of the request Technical evaluation Regulatory evaluation Probabilistic Risk Assessment (PRA) adequacy Proposed schedule SNC stated that the proposed RICT LAR for Vogtle, Units 3 and 4, is generally consistent with TSTF-505, Revision 2, with some variations, including adoption of associated Traveler TSTF-591, Revision 0, Revise Risk-Informed Completion Time (RICT) Program, (ML22081A224). The LAR would modify Technical Specification (TS) Completion Times (CTs) for Required Actions to allow the use of calculated, risk-informed extended CTs. Additionally, SNC plans to introduce a new program, the Risk-Informed Completion Time Program, and a new reporting requirement, the RICT Program Update Report, under TS Section 5, Administrative Controls.
SNC clarified that RICTs would be applicable only in MODE 1 and MODE 2.
The proposed LAR is scheduled for submittal in the first quarter of 2026 (January-March), with a request for NRC staff to complete its safety review by the fourth quarter of 2026 (October-December). SNC noted that the amendment is not required to support an outage.
Proposed 10 CFR 50.69 LAR For the proposed 10 CFR 50.69 LAR, SNC presented the following:
Meeting purpose Background information Licensing approach LAR scope LAR overview Approach for addressing seismic risks Schedule Regulation 10 CFR 50.69(b) states, in part:
Applicability and scope of risk-informed treatment of SSCs and submittal/approval process. (1) A holder of a license to operate a light water reactor (LWR) nuclear power plant under this part; a holder of a renewed LWR license under part 54 of this chapter; an applicant for a construction permit or operating license under this part; or an applicant for a design approval, a combined license, or manufacturing license under part 52 of this chapter; may voluntarily comply with the requirements in this section as an alternative to compliance with the following requirements for RISC-3 and RISC-4 [structures, systems and components] SSCs:
SNC said that it has three licensing approaches.
Option 1 would be to pursue completion of rulemaking activities to amend 10 CFR 50.69 to include Part 52 holders in paragraph 10 CFR 50.69(b)(1).
Option 2 would be to develop a program that includes requirements similar to those in 10 CFR 50.69 and seek NRC approval for the program under 10 CFR 50.90.
Option 3 would be to pursue an exemption request to expand the scope of the rules applicability to include Part 52 combined license (COL) holders. SNC said that its preferred approach is Option 3 to seek an exemption from 10 CFR 50.69(b)(1).
The NRC staff mentioned that it is considering performing an NRC-initiated exemption and suggested this be discussed in a follow-up meeting.
The proposed 10 CFR 50.69 LAR would add a condition to the Vogtle, Units 3 and 4, license to document the NRCs approval for the use of 10 CFR 50.69.
SNC said that the categorization process will follow NEI 00-04, except for the seismic risk evaluation. SNC stated that the Electric Power Research Institute (EPRI) alternative seismic approach will be used for addressing seismic risk.
SNC stated that it plans to submit the proposed Vogtle, Units 3 and 4, 10 CFR 50.69 LAR in the first quarter of 2026. SNC said that it plans to request that the NRC staff complete its safety review by the fourth quarter of 2026, and it is not needed to support an outage.
Proposed SFCP LAR For the proposed SFCP LAR, SNC presented the following:
Description Technical evaluation Regulatory evaluation Schedule.
SNC stated that the proposed Vogtle, Units 3 and 4, SFCP LAR is based on and generally consistent with TSTF-425, TSTF-563, and TSTF-596.
SNC said that the proposed SFCP LAR relocates periodic surveillance frequencies from TS and places frequencies in the SFCP. SNC stated that it would have some variations from the TSTFs.
SNC stated that it plans to submit the proposed Vogtle, Units 3 and 4, SFCP LAR in the first quarter of 2026 and would request that the NRC staff complete its safety review by the fourth quarter of 2026, and it is not needed to support an outage.
Discussion The NRC staff asked the following questions:
- 1. What is the rationale for applying RICT to Required Actions [p]lace inoperable channel in bypass or trip? In TSTF-505, Revision 2, exclusion criterion 8 states, [t]he traveler will not modify Required Actions that specify placing an instrument channel in bypass.
The background for removal of RICTs associated with channel bypass actions is discussed in the NRC staffs request for additional information #1 and the TSTFs response for TSTF-505, Revision 0 (ML111260628).
- 2. What type of risk management actions (RMAs) (RMAs for bypass or RMAs for trip) will be implemented during the RICT and which state (bypass or trip) will be modeled in the PRA if RICT is applied to the action of [p]lace inoperable channel in bypass or trip?
- 4. Will there be PRA updates?
- 5. Will modeling be addressed in detail?
- 6. Will SNC discuss the resolution of open findings and observations (F&Os)?
- 7. Why is SNC taking a seismic penalty instead of using their Seismic PRA (SPRA)? How did SNC come up with their seismic penalty?
- 9. How are inservice testing (IST) Program references being revised or retained, and what criteria determine whether a reference is replaced or preserved?
Other feedback the NRC staff provided:
A. If the licensee would like to use the phrase OR in accordance with the RICT Program instead of OR in accordance with the Risk Informed Completion Time Program with the selected completion times, it would be a variation to TSTF-505 and should be discussed in the LAR. For reference, the Diablo Canyon TSTF-505 amendment uses similar wording (ML24099A219). It is specifically discussed in Audit Question STSB-02 in the supplement to the LAR (ML24016A299).
B. During the discussion of an administrative variation to split a TS condition so that a RICT can be applied, the example, TS 3.5.2, Core Makeup Tanks (CMTs) - Operating, appears to have an excluded condition. Specifically, in TSTF-505, Revision 2, exclusion criterion 10 states [t]he traveler will not modify Required Actions in Conditions in which variables are not within limit unless a modeled system could be used as a surrogate in calculating a RICT (e.g., using the modeled pressurizer as a surrogate for pressurizer level.) If considering this, the licensee should either provide justification in the LAR or not apply RICT to Conditions that meet criterion 10.
C. In many of the past RICT LARs, licensees have provided a cross-reference table between TSTF-505 and the plant specific TS. The table facilitates the NRC staff review with information such as technical variations, justification for RICT inclusion (or the location if elsewhere in the LAR), similarities to RICTs in TSTF-505, or administrative differences (e.g., different system name or numbering). It is understood that there are no direct TSTF-505 NUREG-2194 markups for the Vogtle, Units 3 and 4, design. If feasible, the NRC staff would appreciate the licensee clarifying the LAR in a fashion similar to a cross-reference table. Two reference LARs to consider are McGuire (ML23047A465) and Diablo Canyon (ML24099A219). See Attachment 4 in each.
D. To make for a more efficient LAR, SNC should add a figure that compares its Safe Shutdown Earthquake and Ground Motion Response Spectra showing that Vogtle, Units 3 and 4, are, in fact, a Tier 1 plant and show that seismic risk is small compared to total plant risk.
Closing Remarks There were five members of the public in attendance. One public member asked about the Nuclear Energy Institute (NEI) petition for a rule change to extend the applicability of 10 CFR 50.69 to Part 52 COL holders (ML15037A481).
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 three LARs. 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 11:33 am 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 SEPTEMBER 17, 2025, PRE-SUBMITTAL MEETING WITH SOUTHERN NUCLEAR COMPANY REGARDING THREE PROPOSED LICENSE AMENDMENT REQUESTS VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 ATTENDEE REPRESENTING John G. Lamb*
U.S. Nuclear Regulatory Commission (NRC)
Mike Markley*
NRC Rob Elliott*
NRC Andrea Russell NRC Khadijah West*
NRC Jay Collins NRC Keith Tetter*
NRC Malcolm Patterson*
NRC Todd Hilsmeier*
NRC Daniel Ju*
NRC Reinaldo Rodriguez NRC Sunwoo Park NRC Ed Miller*
NRC Zach Turner*
NRC Ching Ni NRC Norbert Carte NRC Ming Li*
NRC Bob Pascarelli NRC SMetha*
NRC Charles Moulton NRC Ken Lowery*
Southern Nuclear Operating Company (SNC)
Adam Quarles SNC Neil Haggerty*
SNC Eddie Grant*
SNC Tom Byrne*
SNC Adam Coker*
SNC Carrie Gilbreath*
SNC Jordan Rice SNC Jamie Coleman SNC Vish Patel SNC Jonathan Register SNC Beny Ratnagaran SNC Victoria Anderson*
Nuclear Energy Institute (NEI)
Kelli Voelsing NEI Susan Sterrett Public Paul Ouellette Public Mitchell Sepe Public
- Attendance in-person
PKG ML25265A039 Meeting Notice ML25231A077 SNC Slides ML25247A004 Meeting Summary ML25265A043 OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA DSS/STSB/BC DORL/LPL2-1/BC DORL/LPL2-1/PM NAME JLamb KZeleznock SMehta MMarkley JLamb DATE 09/17/2025 09/23/2025 09/25/2025 09/25/2025 09/25/2025