ML25346A274
| ML25346A274 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 12/30/2025 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Coleman J Southern Nuclear Operating Co |
| Lamb J | |
| References | |
| EPID L-2025-LLA-0157 | |
| Download: ML25346A274 (0) | |
Text
December 30, 2025 Ms. Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2; EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2; AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE: LICENSE AMENDMENT REQUEST FOR CHANGES TO EMERGENCY ACTION LEVEL SCHEMES TO ADOPT NEI 99-01, REVISION 7 (EPID L-2025-LLA-0157)
Dear Ms. Coleman:
By letter dated September 30, 2025 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML25273A375), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for the Joseph M. Farley Nuclear Plant, Units 1 and 2; Edwin I. Hatch Nuclear Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1, 2, 3, and 4 (SNC Fleet). The proposed LAR would change its emergency action level (EAL) schemes to adopt Nuclear Energy Institute (NEI) 99-01, Revision 7, September 2024 Development of Emergency Action Levels for Non-Passive Reactors, (ML24274A312) to replace the EAL schemes for the facilities above that are currently based on NEI 99-01, Revision 6. For Vogtle, Units 3 and 4, SNC proposes a unique EAL scheme that combines NEI 99-01, Revision 7 with additional EALs that accommodate the passive features of the AP-1000 design.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this LAR. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an application for an amendment to a license (including the technical specifications) or construction permit must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
As such, based on our review of your application, the NRC staff has concluded that it did not provide technical information in sufficient detail to enable the NRC staff to complete its detailed review and make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements for the protection of public health and safety and the environment. The information needed by the NRC staff was conveyed to you during a call on December 17, 2025, and is followed by this letter.
The NRC staff identified that the following information was insufficient for its technical review:
The LAR does not conspicuously identify variances from NEI 99-01, Revision 7 or provide sufficient technical justification for each difference/deviation. In particular, the proposed license amendment does not provide a complete and accurate mapping to the EAL revision 7 scheme, explanations for the changes to the as built/as modified plant, changes to instruments and values, or substantial additions or deletions of text in the EAL bases.
The LAR appears to lack sufficient documentation to confirm that all the applicable calculations supporting adoption of NEI 99-01, Revision 7, are the same as those approved for Revision 6, or to provide the applicable revised calculations.
The LAR provides a mark-up of proposed changes but does not include a clean and complete proposed version of the EAL schemes including the front matter for each of the sites.
During a pre-submittal meeting on June 5, 2025 (ML25161A094), the NRC staff discussed the above and information needs for the NRC staff to conduct its detailed review. In particular, the NRC emphasized the need to be able to follow the mapping and traceability of changes and associated justifications.
During the pre-submittal meeting, SNCs presentation indicated that the changes would align with each site. The NRC notes that the SNC submittal contains information on the EAL schemes that is formatted in a manner that does not support an efficient review of the entirety of changes for each site. The NRC has concerns that the complexity of the submittal and organization of the proposed changes to adopt NEI 99-01, Revision 7, substantially increase the schedule and review hours in discovery before a detailed review can begin.
In order to make the application complete, the NRC staff requests that SNC supplement the application to address the information requested above within 13 working days of the date of this letter. This will enable the NRC staff to begin its detailed technical review. The NRC staff is considering this review to be complex and may require additional time to complete the review. If the information responsive to the NRC staffs request is not received within 13 working days of the date of this letter, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its activities associated with the application under EPID No. L-2025-LLA-0157. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.
If you have any questions, please contact me at (301) 415-3100 or via email at John.Lamb@nrc.gov.
Sincerely,
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321, 50-366, 50-348, 50-364, 50-424, 50-425,52-025, and 52-026 cc: Listserv
ML25346A274 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NSIR/DPR/RLB/BC NSIR/DPR/D NAME JLamb KZeleznock JQuichocho (JHerrera for) MWaters DATE 12/12/2025 12/15/2025 12/17/2025 12/18/2025 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/D(A)
NRR/DORL/LPL2-1/PM NAME MMarkley ARivera-Varona JLamb DATE 12/18/2025 12/18/2025 12/30/2025