ML26008A232
| ML26008A232 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 01/15/2026 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Southern Nuclear Operating Co |
| Lamb J | |
| Shared Package | |
| ML26008A249 | List: |
| References | |
| EPID L-2025-LLA-0157 | |
| Download: ML26008A232 (0) | |
Text
January 15, 2026 LICENSEE:
Southern Nuclear Operating Company, Inc.
FACILITY:
Edwin I. Hatch Nuclear Plant, Units 1 and 2 Joseph M. Farley Nuclear Plant, Units 1 and 2 Vogtle Electric Generating Plant, Units 1, 2, 3, and 4
SUBJECT:
SUMMARY
OF JANUARY 7, 2026, OBSERVATION MEETING HELD WITH SOUTHERN NUCLEAR OPERATING COMPANY, INC., REGARDING THE CHANGE TO THE EMERGENCY ACTION LEVEL SCHEME FROM NEI 99-01 REVISION 6 TO REVISION 7 (EPID L-2025-LLA-0157)
On January 7, 2026, an Observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Southern Nuclear Operating Company, Inc. (SNC, the licensee). The purpose of the meeting was for SNC to discuss its proposed change to the emergency action level (EAL) scheme from Nuclear Energy Institute (NEI) 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 (Agencywide Documents and Access Management System Accession No. ML12326A805) to NEI 99-01, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, Revision 7, dated September 30, 2024 (ML24274A313) for Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, and Vogtle Electric Generating Plant (Vogtle), Units 1, 2, 3 and 4 (SNC Fleet). By letter dated September 30, 2025 (ML25273A375),
SNC submitted the license amendment request (LAR). By letter dated December 30, 2025 (ML25346A274), the NRC issued a letter to SNC for supplemental information.
A list of attendees is provided as an Enclosure.
On December 19, 2025 (ML25353A552), the meeting was noticed on the NRC public web page, and the NRC slides are located at ML25364A338.
The NRC staff slides are located in ADAMS Accession No. ML26007A032, and the SNC slides are located in ADAMS Accession No. ML26007A033.
The NRC Senior Executive Service managers from Office of Nuclear Reactor Regulation, Division of Operating Reactor Licensing, and from the Office of Nuclear Safety and Incident Response, Division of Preparedness and Response, provided introductory remarks.
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Background===
On June 4, 2025 (ML25149A206), 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.
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.
Regulatory Requirements/Guidance The regulation Title 10 of the Code of Federal Regulations (10 CFR), Part 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.
The regulation 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.
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 its application and provides elements that should also be included in the application.
Results of Acceptance Review The LAR 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 markup 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.
The LAR 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.
Examples Farley, Hatch, and Vogtle - EAL HU5 All differences and deviations (variances) should be identified and justification provided. The intent of EAL HU5 is to declare this EAL based upon the effects that natural or technological hazard events may have on the facility. The NRC staff provided this example to show that the LAR submittal did not identify that an EAL for Sustained hurricane force winds greater than 74 mph forecast to be at the plant site in the next four hours was removed from HU5.
Vogtle 3 and 4 - EAL CA4 All differences and deviations (variances) should be identified and justification provided. The intent of this EAL CU4 and CA4 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. The NRC staff provided this example to show that the LAR submittal did not identify that a paragraph is being added to the basis related to the classification under this IC.
Farley - EAL RA2 Sufficient technical justification was not provided. The intent of this EAL RU2, RA2, RS2, and RG2 set is to ensure that an EAL is declared upon indications of potential or actual damage to an irradiated fuel assembly or multiple assemblies. The NRC staff provided this example to show that while the LAR provided a statement that information was added consistent with the Revision 7 developer notes, the information added is related to decision-making criteria associated with the EAL while the Spent Fuel Pool Ventilation system is being operated in an alternate configuration and no additional justification was provided for the reviewer to understand how the Alert will be declared without this information in the top portion of the EAL.
Farley, Hatch, Vogtle EAL - CU5, SU4 All deviations should be identified and justification provided. The intent of EAL CU5 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 offsite response organizations (OROs), including NRC, are lost. The NRC staff provided this example of where the LAR justification was incomplete. The justification does not address how the changes would impact the Unusual event declaration and what means or method would the site utilize to notify the offsite response organizations and the NRC upon the loss of mobile/cellular or satellite devices. The information added is connected to the decision-making criteria for what constitutes a loss of commercial phones.
Vogtle 3 and 4 - EAL CA2 The LAR does not provide a complete and accurate mapping to the EAL Revision 7 scheme.
The intent of EAL CA2 is that this EAL be declared upon a loss of available alternating current power to power electrical buses. The NRC staff provided this example to illustrate that the LAR provides a redline and strikeout version as a comparison between the NEI 99-01 Revision 7 guidance document and the proposed EAL, however, the justification does not provide sufficient detail to understand the differences between the information that is being retained from the currently approved EAL scheme, information that may have been added to the EAL via the 50.54q process and information that is being added to the EAL via this LAR. The NRC staff requested that a complete mapping of the differences and deviations be provided along with justifications for ALL of the changes.
Farley - EAL set RA1, RS1, RG1; Vogtle 1 and 2 - EAL RA1; and Vogtle 3 and 4 - EAL RS1 The LAR does not provide justification for changes to instruments or values. The intent of this EAL set (RA1, RS1, and RG1) is to ensure that an EAL is declared upon indications of the release of radioactivity. The NRC staff provided this example to show that the LAR did not identify that one of the instruments changed and the values for both instruments changed and justification was not provided for the change being requested via this LAR. The NRC stated that changes implemented since the last approved Revision 6 EAL scheme should be identified and justification provided, if changes were implemented via a 50.54q, references to the associated 50.54q should be provided.
Summary Revise the LAR to:
Identify all changes (e.g., changes since the Revision 6 EAL scheme was last approved via license amendment, changes not included in Revision 6 or 7, etc.),
Provide justifications for ALL changes, Provide justification for information being added related to decision-making criteria and provide justification for documenting decision-making criteria in the EAL - versus the EAL bases, and Provide the information in a format that maps the changes and the associated justification.
SNC The SNC representative stated that it will provide an EAL comparison matrix which identifies differences and deviations (per RIS 2003-18) in a line-by-line comparison to the NEI 99-01 Revision 7 wording with a basis for each. SNC said that they would provide references for the changes that were made to the Revision 6 EALs since NRC approval.
SNC stated it will provide technical justifications for the values and instruments that have changed. SNC stated it will also provide technical justification for any revised calculations required for Revision 7, and will provide the calculations, if needed.
SNC stated it will provide a clean and complete proposed versions of the EAL schemes including the front matter for each of the sites.
Next Steps Thirteen working days from the NRC letter dated December 30, 2025, for SNC to provide a supplement to the LAR is January 20, 2026. SNC stated that it may need more time to provide a high-quality supplement as well as consult with the plant operators.
Closing Remarks There were 24 members of the public present at the meeting.
The NRC staff did not make any regulatory decisions during the meeting. The NRC staff will thoroughly review the supplement when it is submitted by SNC. 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 11:15 am eastern time.
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. 50-321, 50-366, 50-348, 50-364, 50-424, 50-425,52-025, and 52-026
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES FOR THE MEETING HELD ON JANUARY 7, 2025, WITH SOUTHERN NUCLEAR COMPANY REGARDING A PROPOSED LAR TO CHANGE THE EAL SCHEME FROM NEI 99-01 REVISION 6 TO REVISION 7 EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 ATTENDEE REPRESENTING Michael Waters*
U.S. Nuclear Regulatory Commission (NRC)
Aida Rivera*
NRC John G. Lamb*
NRC Mike Markley*
NRC Ken Mott*
NRC Jeff Herrera*
NRC Jessie Quichocho NRC Zach Turner NRC Don Johnson NRC Eric Schrader NRC Miguel Hernandez NRC Jon Fiske NRC Tenisha Meadows NRC Ernest Bates*
Southern Nuclear Operating Company (SNC)
Ryan Joyce*
SNC Ricky Collings*
SNC Dave Simmons*
SNC Bryce Wilkens SNC Jamie Coleman SNC Monica Ray SNC Keith Brown SNC Elizabeth Williford SNC Nicholas Krebser SNC Scott Odom SNC John Perkins SNC Monica Ray Public - Energy Compliance Consultants, LLC Marty Vonk Public - Energy Compliance Consultants, LLC Robert Harrsch Public - Energy Compliance Consultants, LLC Michael Daus Public - Ciel Consultants, Inc.
Brian Carberry Public - Xcel Energy David Young Public - Nuclear Energy Institute (NEI)
Gina Taylor Public - Entergy Eric White Public - Duke Sophia Bartels Public - Constellation Nicholas Kuchmay Public - Talen Energy Quenette Alsop Public - Constellation Greg Norris Public - Entergy Zach Smith Public-Constellation Walter Lee Public - Tennessee Valey Authority (TVA)
Sean Zalesny Public - NEI Michael Henry Public - Constellation Ed Bates Public - BWROGNEXGEN Andrew Taylor Public - TVA Justin Knowles Public - Constellation Travis Rollins Public - Duke Scott Odom Public - TVA Jeff Seiter Public - Entergy Cameron Christian Public - PGE Samanth Caldwell Public - PGE
- Attending in-person
PKG, ML26008A249 Meeting Notice, ML25353A552 Meeting Slides, ML26007A032 and ML26007A033 Meeting Summary, ML26008A232 OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA NSIR/DPR/RLB/BC DORL/LPL2-1/BC DORL/LPL2-1/PM NAME JLamb KZeleznock JQuichocho MMarkley (EMiller for) JLamb DATE 01/07/2026 01/12/2026 01/13/2026 01/15/2026 01/15/2026