ML26026A123
| ML26026A123 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 01/26/2026 |
| From: | Southern Nuclear Company |
| To: | John Lamb Office of Nuclear Reactor Regulation |
| Lamb J | |
| References | |
| EPID L-2026-LLA-0157 | |
| Download: ML26026A123 (0) | |
Text
January 26, 2026 Public Meeting regarding the SNC Fleet License Amendment Request for Changes to Emergency Action Level Schemes to Adopt NEI 99-01 Rev. 7 (L-2025-LLA-0157)
NRC Non-Acceptance 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.
Background
2
- Establish a clear, shared understanding of what SNC intends to submit in the LAR supplement
- Review the high-level contents and structure of the LAR supplement
- Walk through examples from the draft supplement to illustrate format and rationale
- Obtain NRC feedback on the proposed approach and any additional information needs
- Align on the information to be included so the LAR can be accepted for further technical review Meeting Objectives 3
Cover letter with 9 attachments:
1.
Farley EAL Comparison Table 2.
Draft NMP-EP-141-001 Farley Emergency Action Levels and Basis (NEI 99-01 Rev 7) 3.
Vogtle 1-2 EAL Comparison Table 4.
Draft NMP-EP-141-003 Vogtle 1-2 Emergency Action Levels and Basis (NEI 99-01 Rev 7) 5.
Hatch EAL Comparison Table 6.
Draft NMP-EP-141-002 Hatch Emergency Action Levels and Basis (NEI 99-01 Rev 7) 7.
Vogtle 3-4 EAL Comparison Table 8.
Draft NMP-EP-141-004 Vogtle 3-4 Emergency Action Levels and Basis (NEI 99-01 Rev 7) 9.
Global Differences Table Proposed Supplement Contents 4
Format of SNCs Comparison Tables (Farley HU5) 5 Verbatim Rev. 7 wording for the ECL, IC, Mode, Notes, & EALs. Relevant text is provided to identify substantial additions or deletions of text in the EAL Bases.
Differences identified Justifications See Global Differences Table.
Global Differences Table - HU5 Example 6
From Mapping Table
Farley RA2 7
Approved in Rev. 6 - Farley RA2 (see ML16314A505 PDF Page 35 of 476).
Current EALs (in EAL implementing procedure)
Proposed RA2 in Rev. 7 LAR (Page A1-7 and A1-8)
Farley RA2 Example (continued) - EAL Basis Information 8
Approved in Rev. 6 Farley RA2 (see ML16314A512 PDF Page 23 of 717).
Current EAL basis information (in EAL implementing procedure)
Proposed RA2 in Rev. 7 LAR adds similar info about SFP HVAC operation (e.g., shutdown when operating PRF aligned to the SFP Room).
Farley RA2 (continued) 9 There are several reasons why SFP ventilation may be removed from service, including:
operating the PRF system aligned to the SFP room fuel sipping activities maintenance on SFP HVAC or RE-25A/B Because SFP HVAC and RE-25A/B can be out of service for multiple operational or maintenance reasons, this issue does not lend itself to a MODE dependency in the EAL.
Vogtle 3&4 CA2 10 See ML17031A445 PDF Page 90/673 and ML19284C122 PDF Page 49/133 for where this information was previously docketed to the NRC.
11 Vogtle 3&4 CA2 (continued)
Basis Information
Vogtle 3&4 CA4 12 See ML17031A445 PDF Page 99/673 and ML19284C122 PDF Page 52/133 for where this information was previously docketed to the NRC.
From NRCs SER in ML17079A292 PDF Page 10/24
Example - HU1 13 The justification provides a summary of the difference & whether it was approved in the Rev.
6 scheme or is new information. A relevant RAI is referenced.
SNC will reference previous Rev. 6 correspondence (ML16314A505, ML16314A512, etc.) to assist NRC review of the supplement.
From Mapping Table
Example - Farley RA1 (Difference Involving Calculations) 14 This is an example where updates made after the Rev. 6 scheme was approved are directly tied to plant changes.
SNC calculations support these updates, and those calculations are available for NRC audit.
This Global Difference addresses several changes related to radiation monitors.
Farley Clean Draft Versions 15
- Establish a clear, shared understanding of what SNC intends to submit in the LAR supplement
- Review the high-level contents and structure of the LAR supplement
- Walk through examples from the draft supplement to illustrate format and rationale
- Obtain NRC feedback on the proposed approach and any additional information needs
- Align on the information to be included so the LAR can be accepted for further technical review Meeting Objectives - Closing Summary 16