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Category:General FR Notice Comment Letter type:NL
MONTHYEARNL-19-1221, Comment (91) of Michael D. Meier on ROP Enhancement Initiative Phase 12019-10-0707 October 2019
Comment (91) of Michael D. Meier on ROP Enhancement Initiative Phase 1
NL-18-0171, Comment (10) of Justin T. Wheat, on Behalf of Southern Nuclear Operating Co., on Draft Project Plan to Prepare the U.S Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel2018-02-0606 February 2018
Comment (10) of Justin T. Wheat, on Behalf of Southern Nuclear Operating Co., on Draft Project Plan to Prepare the U.S Nuclear Regulatory Commission to License and Regulate Accident Tolerant Fuel
NL-12-2113, Comment (6) of Mark J. Ajluni of Joseph M. Farley, Units 1 & 2, Edwin I. Hatch, Units 1 & 2, Vogtle, Units 1 & 2 on Draft Regulatory Issues Summary 2012 - Xx Clarification of Submission of Requests for Relief or Alternatives Under 10 CFR2012-10-22022 October 2012
Comment (6) of Mark J. Ajluni of Joseph M. Farley, Units 1 & 2, Edwin I. Hatch, Units 1 & 2, Vogtle, Units 1 & 2 on Draft Regulatory Issues Summary 2012 - Xx Clarification of Submission of Requests for Relief or Alternatives Under 10 CFR 50
NL-12-0079, Comment (14) of M. J. Ajluni on Behalf of Southern Nuclear Operating Company, Inc., on Draft NUREG-1022, Rev. 32012-01-18018 January 2012
Comment (14) of M. J. Ajluni on Behalf of Southern Nuclear Operating Company, Inc., on Draft NUREG-1022, Rev. 3
NL-11-0298, Comment (4) of M. J. Ajuni on Behalf of Southern Nuclear Operating Co. Draft NRC Regulatory Issue Summary (RIS) 2011-XX, Adequacy of Station Electric Distribution System Voltages2011-02-17017 February 2011
Comment (4) of M. J. Ajuni on Behalf of Southern Nuclear Operating Co. Draft NRC Regulatory Issue Summary (RIS) 2011-XX, Adequacy of Station Electric Distribution System Voltages
NL-10-0053, Comment (2) of M. J. Ajluni, on Behalf of Southern Nuclear Operating Company, on Proposed Generic Communications; Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers), Docket Id NRC-2009-05112010-02-0909 February 2010
Comment (2) of M. J. Ajluni, on Behalf of Southern Nuclear Operating Company, on Proposed Generic Communications; Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers), Docket Id NRC-2009-0511
NL-09-2000, Comment (1) of Mark J. Ajluni on Draft License Renewal Interim Staff Guidance LR-ISG-2009-01: Staff Guidance Regarding Plant-Specific Aging Management Review and Aging Management Program for Neutron-Absorbing Material in Spent Fuel Pools2009-12-17017 December 2009
Comment (1) of Mark J. Ajluni on Draft License Renewal Interim Staff Guidance LR-ISG-2009-01: Staff Guidance Regarding Plant-Specific Aging Management Review and Aging Management Program for Neutron-Absorbing Material in Spent Fuel Pools
NL-08-1038, Comment (6) of T. E. Tynan on Behalf of Southern Nuclear Operating Company, Inc., on Draft Generic Environmental Impact Statement for License Renewal of Vogtle, Units 1 & 2, Supplement 342008-07-14014 July 2008
Comment (6) of T. E. Tynan on Behalf of Southern Nuclear Operating Company, Inc., on Draft Generic Environmental Impact Statement for License Renewal of Vogtle, Units 1 & 2, Supplement 34
NL-07-1861, Comment (2) of L. M. Stinson on Behalf of Southern Nuclear Operating Co. Inc., Supporting the Comments Submitted by the Nuclear Energy Institute by the Ltr Dated 09/25/2007 Re Draft Regulatory Guide 1021 on Managing the Safety/Security In2007-09-24024 September 2007
Comment (2) of L. M. Stinson on Behalf of Southern Nuclear Operating Co. Inc., Supporting the Comments Submitted by the Nuclear Energy Institute by the Ltr Dated 09/25/2007 Re Draft Regulatory Guide 1021 on Managing the Safety/Security Inte
NL-07-1734, Comment (6) of L. M. Stinson on Behalf of Southern Nuclear Operating Company Supporting Nei'S Comments on Draft Regulatory Guide DG-5019, Reporting of Safeguards Events (72FR37058 Dated July 6, 2007)2007-09-0707 September 2007
Comment (6) of L. M. Stinson on Behalf of Southern Nuclear Operating Company Supporting Nei'S Comments on Draft Regulatory Guide DG-5019, Reporting of Safeguards Events (72FR37058 Dated July 6, 2007)
NL-04-2241, Comment (8) of Jeffrey T. Gasser on Proposed Generic Communication; Establishing and Maintaining a Safety Conscious Work Environment2004-11-15015 November 2004
Comment (8) of Jeffrey T. Gasser on Proposed Generic Communication; Establishing and Maintaining a Safety Conscious Work Environment
NL-04-1908, Comment (5) of Jeffrey T. Gasser on Draft Revision to NRC Inspection Manual Chapter 99002004-10-0101 October 2004
Comment (5) of Jeffrey T. Gasser on Draft Revision to NRC Inspection Manual Chapter 9900
NL-03-2232, Comment (1) of L. B. Long Re Draft Construction Inspection Program for Reactors Built Under 10 CFR Part 52, Reopening of Comment Period2003-10-30030 October 2003
Comment (1) of L. B. Long Re Draft Construction Inspection Program for Reactors Built Under 10 CFR Part 52, Reopening of Comment Period
NL-03-1394, Comment (3) of J. B. Beasley Re Requirements for Steam Generator Tube Inspections2003-07-0808 July 2003
Comment (3) of J. B. Beasley Re Requirements for Steam Generator Tube Inspections
2019-10-07
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.. Michael D. Meier 3535 Colonnade Parkway Vice President, Regulatory Affairs Birmingham, AL 35243 205 992 7615 tel mdmeier@southernco.com October 7, 2019 Docket Nos.: 50-348 50-321 50-424 52-025 NL-19-1221 50-364 50-366 50-425 52-026 SUNSI Review Complete Template = ADM-013 U. S. Nuclear Regulatory Commission E-RIDS=ADM-03 ADD: Daniel Merzke, Russell Gibbs, ATTN: Document Control Desk Manuel Crespo Washington, D. C. 20555-0001 COMMENT (91)
SNC Response to NRC Solicitation for Comments PUBLICATION DATE: 8/7/2019 on Potential Improvements to the Reactor Oversight ProcessCITATION 84 FR 38675 Ladies and Gentlemen:
In Federal Register Notice (FRN) 2019-16876, the NRC summarized its approach in developing targeted, near-term recommendations (ROP Enhancement Initiative Phase 1) for consideration by the Commission in revising the NRCs Reactor Oversight Process (ROP).1 Additionally, the NRC announced solicitation of stakeholder feedback on potential long-term improvements (ROP Enhancement Initiative Phase 2) to the NRCs ROP in the areas of: (1) problem identification and resolution; (2) the cross-cutting issues program; (3) radiation protection inspection procedures; (4) the inspection program for Independent Spent Fuel Storage Installation; and (5) the Significance Determination Process, particularly for the emergency preparedness cornerstone. The FRN also welcomed comments on any other areas of the ROP that the staff should consider under this initiative. Southern Nuclear Operating Company (SNC) is pleased to provide this response to the FRN.
Over the past twelve months, SNC has participated as a member of the NEI Reactor Oversight Process Task Force (ROPTF), including participating in fifteen public meetings with the NRC staff to develop proposed enhancements to the twenty-year-old ROP. As discussed in SECY-19-0067, the NRC staff considered twenty years of operating experience and inspection trend data, as well as the recommendations of the ROPTF and suggestions by other NRC internal and external stakeholders to develop the staffs Phase 1 recommendations for enhancing the ROP.
SNC supports the incremental improvements suggested in the SECY, as well as the improvements discussed in the NEI letter of May 20, 2019.2 In particular, SNC supports the recommendation in the NEI letter regarding the staffs proposal for changing the treatment of white performance indicators.
SNC commends the NRC for its ROP Enhancement Phase 2 Initiative and endorses the Nuclear Energy Institutes (NEI) comments regarding ROP Enhancement Phase 2 as discussed in its October 7, 2019 response to the FRN. By almost any measure, the safety performance of U.S. commercial nuclear reactors has improved dramatically over the 1 See SECY-19-0067, Recommendations for Enhancing the Reactor Oversight Process, dated June 28, 2019.
2 ADAMS ML19141A143
NL-19-1221 Page 2 twenty years the ROP has been in existence.3 Many of the foundational elements of the ROP continue to evolve through innovation, technology development, and improved understanding of plant risk and operations. SNC supports an approach that treats the ROP as a living program that must continue to keep pace with these advancements in the regulation of the nations nuclear power plants.
With respect to other areas the staff should consider under this initiative, SNC is in the unique position to provide feedback on the construction ROP (cROP). SNC recommends expanding the ROP enhancement initiative to include a parallel effort to enhance the cROP. SNC would welcome the opportunity to work with the NRC staff and other external stakeholders in a public forum similar to the ROPTF to enhance the cROP and its application for Vogtle 3 and 4 and future new reactor construction projects.
This letter contains no NRC commitments.
If you have any questions, please contact Terrence Reis at 205.992.7331.
Respectfully submitted, Michael D. Meier Vice President, Regulatory Affairs Southern Nuclear Operating Company MDM/tr/cg cc: Regional Administrator, Region ll NRR Project Manager - Farley Nuclear Plant Senior Resident Inspector - Farley Nuclear Plant NRR Project Manager - Hatch Nuclear Plant Senior Resident Inspector - Hatch Nuclear Plant NRR Project Manager - Vogtle Electric Generating Plant Senior Resident Inspector - Vogtle Electric Generating Plant RTYPE: CGA02.001 3
As explained in referenced NEI letter Uhle to Nieh of May 20, 2019
