ML26007A032
| ML26007A032 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 01/07/2026 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | |
| References | |
| EPID L-2025-LLA-0157 | |
| Download: ML26007A032 (16) | |
Text
SNC Fleet License Amendment Request for Changes to Emergency Action Level Scheme January 7, 2026
Agenda
- Introduction
- Opening Remarks
- Staff Discussion
- Summary of Technical Inadequacies for Acceptance
- Examples of Technical Inadequacies from application
- Questions
- Closing Remarks
- Public Comment to NRC 2
=
Background===
- By letter dated September 30, 2025 (ML25273A375), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for the SNC Fleet.
- The proposed LAR would change the emergency action level (EAL) schemes for the SNC fleet. For Vogtle Units 3 and 4, SNC proposes a unique EAL scheme in addition to those in NEI 99-01, Rev. 7, that accommodate the passive features of the AP-1000 design.
3
Background - Continued
- On June 4, 2025, a public meeting was held to discuss licensing review of NEI 99-01, Revision 7, where NRC staff discussed the submittal contents, technical evaluation and format of applications (ML25149A206).
- A pre-submittal meeting was held with Southern Nuclear Operating Company on June 5, 2025 (ML25161A094),
where NRC staff discussed the submittal contents, technical evaluation, format and validation of EALs.
- By letter dated December 30, 2025 (ML25346A274), the NRC notified SNC that supplemental information was needed for the NRC review.
- On December 19, 2025 (ML25353A552), this public meeting was noticed.
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Regulatory Requirements/Guidance
- 10 CFR 50, Appendix E.IV.B.2 states in part, A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change.
- 10 CFR 50.90 states in part, application for an amendment must be filed with the Commission, as specified in §§ 50.4 or 52.3 of this chapter, as applicable, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
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Regulatory Requirements/Guidance
- On April 19, 2011, the NRC issued Regulatory Issue Summary 2005-02, Revision 1, Clarifying the process for making emergency plan changes (ML100340545).
- Enclosure 2 provides guidance to licensees in the development of their application and provides elements that should also be included in the application.
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Results of Acceptance Review
- The application appears to lack sufficient documentation to confirm that all the applicable calculations supporting adoption of NEI 99-01, Revision 7, were either previously approved in Revision 6, or new and revised.
- The application 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.
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Results of Acceptance Review Cont
- The application does not fully describe the changes desired.
1.
The variances are not conspicuously identified from NEI 99-01, Revision 7.
2.
For each difference or deviation, there was insufficient or no technical justification.
3.
The application does not provide a complete and accurate mapping to the EAL revision 7 scheme that should include explanations for:
a.
changes to the as-built/as-modified plant, b.
changes to instruments and values, or c.
substantial additions or deletions of text in the EAL bases.
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Examples 9
Farley, Hatch, Vogtle EAL - HU5 All differences and deviations (variances) should be identified and justification provided EAL HU5 - The intent is to declare this EAL based upon the effects that natural or technological hazard events may have on the facility. These hazard events are considered to be precursors to a more significant event or condition or have potential impacts that warrant emergency notification to local, state, and federal authorities. EAL #1 and EAL #3 from Rev. 6 (HU3) were deleted in Rev. 7 and the EALs were renumbered accordingly.
Examples 10 Vogtle 3 and 4 EAL - CA4 All differences and deviations (variances) should be identified and justification provided EAL CU4 and CA4 - The intent of this EAL set is to ensure that an EAL is declared when there is a loss of vital direct current (DC) power, or a loss of the capability to charge the applicable DC power sources.
CA4 is a site-specific IC/EAL that is not included in Rev. 7. The EAL results in an Alert declaration upon loss of all required Class 1E DC power or Class 1E UPS bus power for 15 minutes or longer. This IC/EAL was approved as part of licensing Vogtle 3&4's current scheme.
Examples 11 Farley 1 and 2 EAL - RA2 Sufficient technical justification was not provided EAL set RU2, RA2, RS2, and RG2 - The intent of this EAL set is to ensure that an EAL is declared upon indications of potential or actual damage to an irradiated fuel assembly or multiple assemblies. Rev. 7 made no changes to the ICs or EALs in this set. The location of the spent fuel pool instrumentation is added to the Basis of RA2, RS2, and RG2.
In RG2, the wording in the last sentence of the Basis is modified from Rev. 7 as its likely that another GE IC would be met prior to RG2 (consistent with the Rev. 6 scheme). Site-specific information is added to the Basis of RA2 EAL #2 regarding the operation of the ventilation systems, consistent with the Rev. 7 Developer Notes.
Examples 12 Farley, Hatch, Vogtle EAL - CU5, SU4 All deviations should be identified and justification provided EAL CU5 - The intent is to highlight the importance of emergency communications by ensuring that an EAL is declared if normal communications methods for onsite and offsite personnel, or with OROs, including NRC, are lost.
There is no change to the CU5 IC or EALs. Personal electronic devices (e.g., cell phones) are routinely used from within the Control Room as part of conducting daily work activities. Therefore, limiting their use could result in unnecessary declarations since contact with the NRC and OROs would be maintained without extraordinary effort.
Therefore, the Basis is updated to reflect use of this practice. Note that "use of non-plant, privately owned equipment" is removed from the parenthetical in the second paragraph of the Basis regarding what constitutes "extraordinary means."
Examples 13 Vogtle 3 and 4 EAL CA2 The application does not provide a complete and accurate mapping to the EAL revision 7 scheme EAL CA2 - The intent is that this EAL be declared upon a loss of available alternating current (AC) power to power electrical buses.
CU2 was deleted in its entirety in Rev. 7.
In Rev. 7, CA2 IC/EAL remains unchanged, but information was added as a Note and in the Basis for crediting non-safety-related power sources. However, this is not relevant for Vogtle 3&4 and is not being adopted as part of the proposed scheme.
The proposed scheme removes the operating mode applicability when the plant is defueled. When defueled, forced cooling of the RCS is not required and if the normal spent fuel pool cooling system is unavailable, cooling is provided by the heat capacity of the spent fuel pool inventory and the available makeup sources. This information is provided in the Basis Section. The proposed change represents a deviation from Rev. 7 but is acceptable based on the plant's licensing and design basis.
Examples 14 Farley EAL set RA1, RS1, RG1 Vogtle 1 and 2 EAL RA1 Vogtle 3 and 4 RS1 The application does not provide justification for changes to instruments or values EAL set RA1, RS1, and RG1 - The intent of this EAL set is to ensure that an EAL is declared upon indications of a release of radioactivity. RU1 was deleted in its entirety in Rev. 7. A note was added to RA1, RS1, and RG1 to clarify that radiation monitor readings in EAL #1 should not be used for emergency classification assessments if dose assessment results are available. This is clarified in the Basis. Other wording enhancements were made to the EAL notes, but with no change of intent. For RA1, Rev.
6 EAL #3 was deleted in Rev. 7; EAL #4 was renumbered to EAL #3.
Summary Revise the application to:
- Identify all changes (e.g., references to changes since revision 6, not included in revision 6 or 7, etc.)
- Provide justifications for ALL changes
- Document decision making criteria in the EAL -
versus the EAL bases
- Provide the information in a format that maps the changes and the associated justification (e.g.,
as was provided for revision 6) 15
Questions ??
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