ML25008A037
| ML25008A037 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley, 05000026, 05000025 |
| Issue date: | 01/15/2025 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | Coleman J Southern Nuclear Operating Co |
| Turner, Zachary | |
| References | |
| EPID L-2023-LLE-0018, EPID L-2023-LLE-0021 | |
| Download: ML25008A037 (1) | |
Text
January 15, 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 - AUDIT
SUMMARY
REPORT FOR THE EXEMPTION REQUESTS REGARDING PHYSICAL BARRIERS (EPID L-023-LLE-0018 AND EPID L-2023-LLE-0021)
Dear Jamie Coleman:
By letter dated July 7, 2023, (Agencywide Documents and Access Management System(ADAMS) Accession No. ML23188A163), as supplemented by letters dated February 5 and 12, and April 4, 2024 (ML24036A292, ML24043A186, and ML24095A348), and September 5, 2024 (non-publicly available), Southern Nuclear Operating Company (SNC, the licensee) submitted a request for exemptions from specific requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 73, Section 73.2, Definitions for portions of the physical barriers at 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. The regulation at 10 CFR 73.2 requires, in part, that Physical barrier means: (1) Fences constructed of No. 11 American wire gauge, or heavier wire fabric, topped by three strands or more of barbed wire or similar material on brackets angled inward or outward between 30° and 45° from the vertical, with an overall height of not less than eight feet, including the barbed topping;.
By letter dated November 15, 2024, the NRC staff issued the Audit Plan with a cover letter (ML24320A134) available to the public and an enclosure that was not available to the public, because it contained security-related information.
On November 20, 2024, the NRC staff conducted an audit meeting in accordance with the Audit Plan. At this meeting, the NRC staff provided background information on the reasons for the audit and clarified information required from SNC.
By letter dated January 15, 2025 (ML25010A122), SNC withdrew the SNC physical barrier exemptions.
Attached is the Audit Summary Report.
J. Coleman If you have any questions, please contact me at 301-415-3100.
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
Enclosure:
Audit Report cc: Listserv
Enclosure AUDIT
SUMMARY
REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR THE EXEMPTION REQUESTS TO PHYSICAL BARRIERS JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-321, 50-366, 50-348, 50-364, 50-424, 50-425,52-025, AND 52-026
1.0 BACKGROUND
By letter dated July 7, 2023, (Agencywide Documents and Access Management System(ADAMS) Accession No. ML23188A163), as supplemented by letters dated February 5 and 12, and April 4, 2024 (ML24036A292, ML24043A186, and ML24095A348), and September 5, 2024 (non-publicly available), Southern Nuclear Operating Company (SNC, the licensee) submitted a request for exemptions from specific requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 73, Section 73.2, Definitions for portions of the protected area boundary fencing at 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.
The regulation at 10 CFR 73.2 requires, in part, that Physical barrier means: (1) Fences constructed of No. 11 American wire gauge, or heavier wire fabric, topped by three strands or more of barbed wire or similar material on brackets angled inward or outward between 30° and 45° from the vertical, with an overall height of not less than eight feet, including the barbed topping;.
The Nuclear Regulatory Commission (NRC) staff identified the need for a regulatory audit to examine the SNCs non-docketed information with the intent to gain understanding, to verify information, or to identify information that would require docketing to support the basis of the licensing or regulatory decision.
2.0 SCOPE AND PURPOSE By letter dated November 15, 2024, the NRC staff issued the Audit Plan with a cover letter (ML24320A134) available to the public and an enclosure that was not available to the public, because it contained security-related information.
On November 20, 2024, the NRC staff conducted an audit meeting in accordance with the Audit Plan. At this meeting, the NRC staff provided SNC background information on the reasons for the audit and clarified information required from SNC.
3.0 AUDIT TEAM The audit team consisted of the following:
John G. Lamb, Office of Nuclear Reactor Regulation, Division of Operating Reactor Licensing (DORL)/Plant Licensing Branch 2-1 (LPL2-1),
Lou Cubellis, Office of Nuclear Security and Incident Response (NSIR), Division of Physical and Cybersecurity Policy (DPCP)/Reactor Physical Protection Branch (RPPB)
Steven Sarver, NSIR/DPCP/RPPB
Tony Bowers, Deputy Director, NSIR/DPCP or Mandy Marshall, Chief, NSIR/DPCP/RPPB
Jeff Bream or Jeremiah Rey, NSIR, Division of Security Operations/Security Oversight and Support Branch 4.0 AUDIT REPORT SNC also established an online portal. Attachment 1 contains the summary where the NRC staff explained the issues involved, questions, and requested information for the audit.
5.0 CONCLUSION
The SNC staff decided to withdraw the physical barrier exemptions by letter dated January 15, 2025 (ML25010A122).
The audit was closed out on January 15, 2025.
ATTACHMENT 1 AUDIT DAY 1 - NOVEMBER 20, 2024 Attendees NAME ORGANIZATION John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Michael Markley NRC Lou Cubellis NRC Steve Sarver NRC Jeremiah Rey NRC Amanda Marshall NRC Anthony Bowers NRC Jeff Bream NRC Desiree Davis NRC Sarah Temple NRC Dawnmathews Kalathiveettil NRC Richard Easter NRC Ryan Henderson Southern Nuclear Operating Company (SNC)
Ryan Joyce SNC Gerald Durham SNC Jeanne Johnston SNC The audit commenced with the above attendees. The U. S. Nuclear Regulatory Commission (NRC) staff provided background information related to how the review came to an audit.
The NRC staff clearly explained the following:
Description, characteristics, and installation location for each physical barrier on the protected grounds at each site.
Equipment, general arrangement, or other scaled civil engineering drawings that depict the interiors of all protected area structures (including vital areas) that house target set elements; the drawings should identify the requested information.
Descriptions or drawings of staging areas and response position locations, including potential redirect locations, for members of the armed response team (i.e., ARs and ASOs) at each site.
The three quantitative times, one for each site, that the licensee used for intrusion alarm acknowledgement, assessment, and communication (AAC) in its supplement, dated September 5, 2024 (non-publicly available - safeguards information). The information is needed for NRC staffs independent validation. The NRC staff needs to understand the interdiction points.
The quantitative data that the licensee used to determine the response timelines for ARs and ASOs at each site.
The NRC staff is looking for qualitative and quantitative information.
The NRC staff needs drawings available for efficiency.
SNC wants Audit to occur visit at SNC Headquarters in Birmingham, Alabama only. The NRC staff will consider it. The NRC staff will consider visiting Vogtle and Hatch another week.
Summary The NRC staff explained the issues and clarified the non-safeguards questions.
ML25008A037 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NSIR/DPCP/RPPB/BC NAME JLamb KZeleznock AMarshall DATE 01/08/2025 01/10/2025 01/10/2025 OFFICE NRR/DORL/ LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley JLamb DATE 01/13/2025 01/15/2025