NEI 99-01, SNC Slides - SNC Fleet - Pre-Submittal Meeting - LAR for EAL Scheme Change to NEI 99-01 Rev 7
| ML25143A077 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 06/05/2025 |
| From: | Southern Nuclear Company |
| To: | John Lamb NRC/NRR/DORL/LPL2-1 |
| Lamb J | |
| References | |
| NEI 99-01, Rev 7 | |
| Download: ML25143A077 (1) | |
Text
SNC Pre-Submittal Meeting with NRC Meeting to Discuss SNCs Intent to Adopt NEI 99-01, Rev. 7 June 5, 2025
Agenda Introductions & Meeting Purpose
Background
Submittal Contents & Format Proposed EAL Scheme for Vogtle 3&4 Schedule Discussion / Feedback
SNC Adoption of NEI 99-01, Rev. 7 INTRODUCTIONS Southern Nuclear Operating Company (SNC)
Nuclear Regulatory Commission (NRC)
MEETING PURPOSE SNC intends to submit an application to amend the Emergency Action Level (EAL) schemes at Farley, Hatch, Vogtle 1&2, and Vogtle 3&4, consistent with NEI 99-01, Revision 7 (Rev. 7).
The purpose of this meeting is to discuss the proposed EAL schemes, format and contents of the submittal, and timeline. A concise format is proposed for ease of review.
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SNC Adoption of NEI 99-01, Rev. 7 BACKGROUND SNC has contributed to the development of NEI 99-01, Rev. 7.
On April 10, 2025, the NRC documented the completion of its technical review of NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 7 in a letter dated Sept. 30, 2024 (ML24352A163, ML24274A312 / 313).
SNCs proposed EAL schemes have been developed based on NEI 99-01 Rev. 7 dated September 30, 2024.
The NRC Staff intends to finalize and issue an endorsement decision in Revision 7 of RG 1.101, by July 2025.
SNCs currently approved EAL schemes are based on NEI 99-01, Rev. 6, and include unique initiating conditions (ICs) for the Vogtle 3&4 AP-1000 design.
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SNC Adoption of NEI 99-01, Rev. 7 BACKGROUND - SCHEME DEVELOPMENT The proposed EAL schemes incorporate Rev. 7 across the fleet (Farley, Hatch, Vogtle 1&2, and Vogtle 3&4).
In adopting the Rev. 7 guidance, SNC has incorporated site-specific information, operations experience, and for Vogtle 3&4, differences associated with the AP-1000 design.
The Farley, Hatch, and Vogtle 1&2 proposed EAL schemes align closely with Rev. 7 guidance with only minor differences and no deviations.
The Vogtle 3&4 EALs also align with Rev. 7. However, the proposed scheme contains site-specific IC/EALs that accommodate the AP-1000 design.
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Rev 7 LAR Format and Contents SUBMITTAL CONTENTS
- Cover letter
- Enclosure
- Summary of the Change
- Detailed Description
- Technical Evaluation
- Regulatory Evaluation
- State Consultation
- Environmental Consideration
- Attachment - EALs
- Attachment - Definitions 6
Technical Evaluation This section explains how the Rev. 7 guidance has been adopted specifically to each site for all EALs and demonstrates consistency with the Rev. 7 scheme, as required by 10 CFR 50.47(b)(4). Differences and site-specific information are identified, explained and justified.
EALs This section will provide all proposed EALs. As in Rev.
7, the EALs are grouped by recognition category (R, C, F, H, S) and arranged by severity (NOUE, Alert, SAE, GE).
Rev. 7 calls for site-specific information to be inserted in some EALs. These text inserts are highlighted in the EALs provided in the LAR. Additional site-specific differences, if any, are also highlighted. Examples are provided in the following slides.
Rev 7 LAR Format and Contents TECHNICAL EVALUATION Organized by Recognition Category and grouped into EAL Sets in alignment with previous NRC Safety Evaluations. For example, for Recognition Category R - Abnormal Radiological Release / Effluent, the EAL Set that ensures declaration upon indications of a release of radioactivity includes RA1, RS1, and RG1.
Describes when the EALs were not changed by Rev. 7 and the proposed EAL remains unchanged since last approved by the NRC.
Describes when the EALs were downgraded to a lower emergency classification in the Rev.
7 scheme but are otherwise unchanged since last approved by the NRC.
Describes when certain indications or values were deleted in the Rev. 7 scheme but are otherwise unchanged since last approved by the NRC.
Describes the EALs with changes to the indications or values as outlined in Rev 7.
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Rev 7 LAR Format and Contents EXAMPLE - RU3 Red text indicates site-specific information Red, bold text indicates site-specific information as identified by the Rev. 7 template Uniquely defined terms are capitalized, and the definitions are provided in a LAR attachment If helpful, additional mark-ups can be generated and made available for Audit 8
Rev 7 LAR Format and Contents EXAMPLE - RU3 continued Technical Evaluation:
EAL RU3 - The intent is that an EAL is declared upon the occurrence of radiation levels in the plant that limit normal access. The EAL addresses elevated radiation levels in certain plant rooms and areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation or to perform a normal plant cooldown and shutdown. In Rev. 7, the IC and EALs were relocated from an Alert level (RA3) to an Unusual Event level (RU3). No changes were made to the IC or wording of the EALs.
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Rev 7 LAR Supporting Information VALIDATION of EALs CALCULATIONS Site-specific calculations have been reformatted to align with Rev 7.
Calculations are available for NRC Audit, if needed.
STATE and LOCAL CONSULTATIONS DEVIATIONS and DIFFERENCES Differences are explained in the Technical Evaluation and clearly highlighted in the EALs. There are no deviations.
CLEAN COPIES of EALs EALs provided in the LAR are a Clean Set (with highlights).
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VEGP 3&4 Proposed EAL Scheme - Recognition Category R 11
VEGP 3&4 C & E-HU1 12 CU6 - Site-specific IC that addresses an unplanned loss of monitoring and control functions.
CA4 - Site-specific IC that addresses a loss of all required Class 1E DC power or UPS bus power.
E-HU1 - Damage to loaded spent fuel cask will be included due to the ISFSI pad being inside the protected area for Vogtle Units 1 through 4.
VEGP 3&4 Proposed Scheme FPB Matrix - RCS or SG Tube Leakage 13
V3&4 FPB Matrix - Inadequate Heat Removal & RCS Activity / CTMT Radiation 14
VEGP 3&4 Proposed Scheme FPB Matrix - Containment Integrity or Bypass 15
VEGP 3&4 Proposed Scheme FPB Matrix - ED Judgement 16
VEGP 3&4 Proposed EAL Scheme - Recognition Category H 17
VEGP 3&4 Proposed Scheme
- Recognition Category S 18 SU2 - Site-specific IC that addresses an unplanned partial loss of monitoring and control functions for 30 minutes or longer.
The following are Rev. 7 ICs that are not included in the proposed scheme for VEGP 3&4, which is consistent with the currently approved scheme:
o SG1 - extended loss of AC power to emergency buses o SS6 - loss of all Vital DC power
(> 15 mins.)
o SG6 - loss of all AC and Vital DC power sources (> 15 mins.)
SNC Adoption of NEI 99-01, Rev. 7, for VEGP 3&4 SCHEDULE
- NRC issues endorsement of Rev. 7 in RG 1.101 - July 2025
- NRC Audit of the LAR - 4th quarter 2025
- NRC approval within one year of acceptance
- SNC Implementation within one year of issuance DISCUSSION & FEEDBACK 19