ML25161A094

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Summary of June 5, 2025, Observation Pre-Submittal 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
ML25161A094
Person / Time
Site: Hatch, Vogtle, Farley  Southern Nuclear icon.png
Issue date: 06/23/2025
From: John Lamb
Plant Licensing Branch II
To:
Southern Nuclear Operating Co
Lamb J
Shared Package
ML25161A097 List:
References
EPID L-2025-LRM-0056
Download: ML25161A094 (5)


Text

June 23, 2025 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 JUNE 5, 2025, OBSERVATION PRE-SUBMITTAL 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-LRM-0056)

On June 5, 2025, 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, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, (Agencywide Documents and Access Management System Accession No. ML12326A805) to NEI 99-01, Revision 7, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, September 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).

A list of attendees is provided as an Enclosure.

On May 8, 2025 (ML25138A001), the meeting was noticed on the NRC public web page, and the SNC slides are located at ML25143A077.

The NRC staff opened the meeting with introductory remarks and a rollcall of the attendees.

SNC representatives discussed the following topics: (1) background, (2) submittal contents, technical evaluation, format, and validation of EALs, (3) proposed EAL scheme for Vogtle, Units 3 and 4, and (4) schedule.

=

Background===

SNC contributed to the development of NEI 99-01, Revision 7.

By letter dated April 10, 2025 (ML24352A163), the NRC staff informed NEI that the NRC staff has completed its technical review of NEI 99-01, Revision 7.

SNC stated that its proposed EAL scheme was developed based on NEI 99-01, Revision 7.

SNC representatives stated that its currently approved EAL schemes are based on NEI 99-01, Revision 6, and include unique initiating conditions (ICs) for the Vogtle, Units 3 and 4, AP-1000 design.

SNC stated that the proposed EAL scheme incorporates NEI 99-01 Revision 7, across the SNC Fleet. SNC said that in adopting the guidance in NEI 99-01, Revision 7, SNC has incorporated site-specific information, operating experience, and for Vogtle, Units 3 and 4, and differences associated with the AP-1000 design. SNC stated that its proposed EAL schemes aligns closely with NEI 99-01 Revision 7, with only minor differences and no deviations for Farley, Units 1 and 2, Hatch, Units 1 and 2, and Vogtle, Units 1 and 2. SNC said that the Vogtle, Units 3 and 4, EALs align with NEI 99-01, Revision 7; however, the proposed EAL scheme contains site-specific initiating conditions (ICs)/EALs that accommodate the AP-1000 design.

Submittal Contents and Format SNC stated that submittal contents will contain the following: (1) cover letter, (2) enclosure, (3) attachment - EALs, and (4) attachment - definitions. SNC said that the enclosure will contain the normal amendment components including: (a) summary of the change, (b) detailed description, (c) technical evaluation, (d) regulatory evaluation, (e) state consultation, and (f) environmental consideration.

SNC said that the technical evaluation will be organized by recognition category and grouped into EAL sets in alignment with previous NRC Safety Evaluations. SNC stated that the technical evaluation: (1) describes when the EALs were not changed by NEI 99-01 Revision 7 and the proposed EAL remains unchanged since last approved by the NRC, (2) describes when the EALs were downgraded to a lower emergency classification in the NEI 99-01 Revision 7 scheme but are otherwise unchanged since last approved by the NRC, (3) describes when certain indications or values were deleted in the NEI 99-01 Revision 7 scheme but are otherwise unchanged since last approved by the NRC, and (4) describes the EALs with changes to the indications or values as outlined in NEI 99-01 Revision 7.

Proposed EAL Scheme for Vogtle, Units 3 and 4 SNC presented the proposed EAL scheme for Vogtle, Units 3 and 4, in slides 11 through 18.

Schedule SNC stated that it plans to submit the SNC Fleet LAR in August 2025. SNC said that it expects NRC staff to perform an audit in the fourth quarter of 2025. SNC stated that it plans to request the NRC staff complete its technical review of the proposed LAR within one year of the acceptance review. SNC said that it would implement the LAR within one year after the LAR is issued.

Discussion The NRC staff asked the following questions:

Will SNC provide a roadmap of the changes between Revision 6 and Revision 7?

Will SNC have deviations from NRC-approved Revision 7?

Will SNC provide redline-strikeout information reflecting the Revision 7 Change Summary?

Did SNC consider the latest seismic information (e.g., Fukushima 10 CFR 50.54(f) response, Generic Safety Issue 199 and NRC Process for the Ongoing Assessment of Natural Hazards Information (POANHI))?

How complex will the Vogtle, Units 3 and 4, submittal be?

Will the submittal contain sufficient information for NRC staffs detailed review and to what extent will the review be dependent on regulatory a regulatory audit?

During the SNC presentation, the NRC staff asked whether there would be additional EAL changes proposed in the LAR that are not part of NEI 99-01 Revision 7? SNC responded yes and suggested that the additional EAL changes would propose to add new EALs and revise certain current EALs. The NRC staff suggested to SNC that the other technical disciplines may be required to review these additional changes and noted that the custom review would likely require additional review resources. The NRC staff noted that if additional EAL changes are provided in the proposed LAR that are outside the scope of those described in NEI 99-01 Revision 7, the proposed LAR would likely be considered a complex review.

Closing Remarks There were two 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 LAR 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 11:57 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, 50-354, 50-424, 50-425,52-025, and 52-026

Enclosure:

List of Attendees cc: Listserv

Enclosure LIST OF ATTENDEES FOR THE JUNE 5, 2025, PRE-SUBMITTAL MEETING 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 John G. Lamb*

U.S. Nuclear Regulatory Commission (NRC)

Mike Markley*

NRC Zach Turner*

NRC Dawnmathews Kalathiveettil*

NRC Jeff Herrera*

NRC Jessie Quichocho*

NRC Keith Miller NRC Ed Miller NRC Eric Schrader NRC Miguel Hernandez NRC Don Johnson NRC Michael Mahoney NRC Jack Minzer Bryant NRC Jamole Skeeter NRC Ernest Bates*

Southern Nuclear Operating Company (SNC)

Ryan Joyce SNC Ricky Collings*

SNC Justin Wheat SNC Dave Simmons SNC Shannon Smelley SNC Monica Ray SNC Keith Brown SNC Ted Amundson SNC Nicholas Krebser SNC Scott Odom SNC Ben Rothschadl SNC Ulrich Perleberg SNC Susan Sterrett Public Taha Abdelnaeem Public

  • Attending in-person

Package - ML25161A097 Meeting Notice - ML25138A001 Meeting Slides - ML25143A077 Meeting Summary - ML25161A094 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 JLamb DATE 06/05/2025 06/13/2025 06/17/2025 06/23/2025 06/23/2025