NL-24-0097, Exemption Request: Final Safety Analysis Report Update Schedule
| ML24085A711 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/22/2024 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-24-0097 | |
| Download: ML24085A711 (1) | |
Text
A Southern Nuclear March 22, 2024 Docket Nos.52-025 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Southern Nuclear Operating Company Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.5000 NL-24-0097 10 CFR 52.7 Vogtle Electric Generating Plant Units 3 and 4 Exemption Request: Final Safety Analysis Report Update Schedule In accordance with 10 CFR 52.7, Southern Nuclear Operating Company (SNC) requests an exemption for the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 (License Numbers NPF-91 and NPF-92, respectively) from the specific regulations of 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, and 10 CFR 50.71(e)(4), for submission of revisions and updates to the Final Safety Analysis Report (FSAR) including the plant-specific Design Control Document for the VEGP Units 3 and 4.
SNC requests that the due date for submittal of the VEGP Units 3 and 4 combined FSAR be June 30 of every odd-numbered year. This change will result in a submittal that does not exceed 24 months between successive updates, as required by 10 CFR50.71(e)(4).
The Enclosure to this letter provides the background and supporting basis for the requested exemption.
SNC requests NRC staff review and approval of this exemption request no later than March 31, 2025, to allow for implementation prior to six months after the scheduled refueling outage for Unit 3. SNC expects to implement this exemption upon issuance.
This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.
U. S. Nuclear Regulatory Commission NL-24-0097 Page 2 If you have any questions, please contact Mr. Ryan Joyce at (205) 992-6468.
Respectfully submitted, Jamie M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Company
Enclosure:
NRC Regional Administrator, Region II NRR Project Manager - Vogtle 3&4 Senior Resident Inspector - Vogtle 3&4 Document Services RTYPE: VND.LI.L00 File AR.01.02.06
Southern Nuclear Operating Company NL-24-0097 ENCLOSURE Vogtle Electric Generating Plant Units 3 and 4 Exemption Request:
Final Safety Analysis Report Update Schedule 1.0 SPECIFIC EXEMPTION REQUEST 2.0 BASIS FOR EXEMPTION REQUEST 3.0 JUSTIFICATION FOR THE EXEMPTION 4.0 ENVIRONMENTAL ASSESSMENT 5.0 PRECEDENT
6.0 CONCLUSION
(This enclosure consists of 10 pages, including this cover page.)
Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule 1.0 SPECIFIC EXEMPTION REQUEST In accordance with 10 CFR 52.63, 52.7, and 50.12, Southern Nuclear Operating Company (SNC) is requesting U.S. Nuclear Regulatory Commission (NRC) approval of a permanent schedular exemption from the requirements of 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, and 10 CFR 50.71 (e)(4) for submission of revisions and updates to the combined Final Safety Analysis Report (FSAR) for Vogtle Electric Generating Plant (VEGP), Units 3 and 4.
Specifically, SNC requests that the submittal of revisions and updates for VEGP Units 3 and 4 combined FSAR be due by June 30 of every odd-numbered year. This change will result in a submittal that does not exceed 24 months between successive updates, as required by 10 CFR 50.71(e)(4).
This request for exemption provides the technical and regulatory basis to demonstrate that 10 CFR 52.63, 52.7, and 50.12 requirements are met.
SNC requests NRC staff review and approval of this exemption request no later than March 31, 2025, to allow for implementation prior to six months after the scheduled refueling outage for Unit 3. Delayed approval of this exemption subjects the plant personnel and the NRC Staff to additional regulatory burden and associated additional costs. SNC expects to implement this exemption upon issuance.
2.0 BASIS FOR EXEMPTION REQUEST As noted in 45 FR 30614, the 10 CFR 50.71(e)(4) regulation requiring periodic FSAR revisions and updates to the NRC was made to "provide an updated reference document to be used in recurring safety analyses performed by the licensee, the Commission, and other interested parties." This requested exemption extends the reporting period and does not allow SNC to exceed the maximum time period (i.e., 24 months) between successive revisions and updates as established by 10 CFR 50.71 (e)(4). It is noted that the VEGP Units 3 and 4 FSAR contains the plant-specific Design Control Document (DCD);
therefore, this exemption will also affect the interval as defined in 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c that reference 10 CFR 50.71 (e). Thus, the FSAR, including the plant-specific DCD, would continue to be periodically updated.
10 CFR 52, Appendix D, Section X.B.2, requires that, in regard to FSAR updates, a licensee "... shall submit updates to its DCD, which reflect the generic changes to and plant-specific departures from the generic DCD made under Section VIII of this appendix.
These updates must be filed under the filing requirements applicable to final safety analysis report updates in 10 CFR 52.3 and 50.71(e)."
10 CFR 52, Appendix D, Section X.B.3.c, requires that, "After the Commission makes the finding required by 10 CFR 52.103(g), the reports and updates to the plant-specific DCD must be submitted, along with updates to the site-specific portion of the final safety analysis report for the facility, at the intervals required by 10 CFR 50.59(d)(2) and 50.71 (e)(4), respectively, or at shorter intervals as specified in the license."
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Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule 10 CFR 50.71(e)(4) requires that, in regard to FSAR updates, "Subsequent revisions must be filed annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months."
10 CFR 52.7 indicates that exemptions from the regulations in Part 52 will be governed by 10 CFR 50.12. 10 CFR 50.12(a)(1) stipulates that the NRC may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.
SNC is the holder of Combined Licenses Nos. NPF-91 and NPF-92, which authorizes construction and operation of two Westinghouse Electric Company AP1000 nuclear plants named VEGP Units 3 and 4, respectively.
The proposed exemption would change the current FSAR update submittal schedule for VEGP Units 3 and 4 to a calendar-based schedule that would not exceed the maximum of 24 months between successive updates as required by 10 CFR 50.71(e)(4). The VEGP Units 3 and 4 FSAR updates will continue to reflect changes to the FSAR up to a maximum of six months prior to the date of filing, as required by 10 CFR 50.71 (e)(4).
VEGP Units 3 and 4 refueling outages are generally staggered to avoid simultaneously removing both units from power production. With staggered refueling outages, under the regulation, two FSAR updates would be required for each cycle; i.e., an update within six months after the refueling outage for each unit.
VEGP Units 3 and 4 are two SNC units of the AP1000 design with planned refueling cycles of no more than 18 months and sharing the VEGP site with VEGP Units 1 and 2.
The VEGP Units 3 and 4 share a combined FSAR last submitted on June 13, 2023
[ML23165A215]. If this exemption request is approved within one year of submittal, the subsequent submittal would occur by June 30, 2025.
The proposed schedule change would allow a continued single submittal of the updates to the VEGP Units 3 and 4 FSAR within the 24 months between submittals required by 10 CFR 50.71 (e)(4). For practical or business reasons, the submittal would occur any time in the month of June on an odd-numbered year.
VEGP Units 1 and 2 are two SNC units of a previous Westinghouse design with 18 month refueling cycles. VEGP Units 1 and 2 share a combined FSAR. On August 4, 2021
[ML21179A204], the NRC granted VEGP Units 1 and 2 an exemption to allow a single submittal of the periodic updates of the VEGP Units 1 and 2 FSAR by October 31 of every even-numbered year, not to exceed 24 months between successive updates.
Farley Nuclear Plant (FNP) Unit 1 and Unit 2 are two SNC units on another site also with 18 month refueling cycles. The August 4, 2021 [ML21179A204] NRC approval also granted FNP Units 1 and 2 an exemption to allow a single submittal of the periodic updates of the FNP Units 1 and 2 FSAR by October 31 of every odd-numbered year, not to exceed 24 months between successive updates.
Hatch Nuclear Plant (HNP) Units 1 and 2 are two SNC units on a third site with 24 month refueling cycles. On January 30, 2020 [ML19364A018], the NRC granted HNP Units 1 E-3
Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule and 2 an exemption to allow a single submittal of the periodic updates of the HNP Units 1 and 2 inter-related FSARs by August 31 of every even-numbered year, not to exceed 24 months between successive updates.
Upon approval of this requested exemption, SNC would be providing FSAR updates for the SNC fleet of nuclear-powered facilities on the following schedule:
Hatch Units 1 and 2 FSAR updates by August 31 of even-numbered years Vogtle Units 1 and 2 FSAR updates by October 31 of even-numbered years Vogtle Units 3 and 4 FSAR updates by June 30 of odd-numbered years Farley Units 1 and 2 FSAR updates by October 31 of odd-numbered years Periodic updates maintain the FSAR to accurately reflect the plant design and operation.
SNC internally updates the VEGP Units 3 and 4 FSAR on a more frequent basis following SNC business process guidance and posts the updated documents for convenient access by SNC personnel.
Routine submittals as required by 10 CFR 50.71(e)(4) are proposed to be made on a 24-month calendar schedule. The VEGP Units 3 and 4 FSAR submittals will continue to reflect changes to the FSAR up to a maximum of six months prior to the date of filing, as required by 10 CFR 50.71 (e)(4). The use of a 24-month submittal schedule would be similar to the FSAR submittal schedule currently used by stations on a 24-month refueling cycle.
Consequently, the proposed 24-month submittal schedule does not impair the ability of the NRC to review station information in a timely manner.
1 O CFR 50.12(a) states, in part:
(a) The Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part, which are-(1) Authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security.
(2) The Commission will not consider granting an exemption unless special circumstances are present. Special circumstances are present whenever-(ii) Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule;or (iii) Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated;...
The intent of the regulation can be achieved by continuing to remain within the required maximum time limit of 24 months between successive updates. Allowing the requested exemption for VEGP Units 3 and 4 would result in continuing to provide FSAR revision and update submittals on a routine schedule, while maintaining compliance with the maximum 24 months between successive submittals. This change would achieve the underlying E-4
Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule purpose to provide an updated reference document; i.e., an FSAR that is up-to-date and accurately reflects the plant design and operation. Therefore, this exemption meets the requirements of 10 CFR 50.12(a)(2)(ii).
The proposed schedule change in this exemption request, to submit the updated VEGP Units 3 and 4 FSAR by June 30 of every odd-numbered year, would allow more efficient scheduling and allocation of SNC resources to prepare and submit FSAR revisions and updates for the SNC fleet while remaining within the maximum allowed 24 months between successive submittals of the VEGP Units 3 and 4 FSAR.
In summary, this exemption request proposes a revised FSAR update schedule for VEGP Units 3 and 4. SNC would submit the updated VEGP Units 3 and 4 FSAR by June 30 of every odd-numbered year. This schedule would allow more efficient scheduling and allocation of SNC resources to prepare and submit FSAR revisions and updates for the SNC fleet while remaining with the maximum allowed 24 months between successive submittals as required by 10 CFR 50.71 (e)(4). The proposed due date for VEGP would allow, for practical or business reasons, the submittal to be made any time during the month due. The VEGP Units 3 and 4 FSAR revisions updates will continue to reflect changes to the FSAR up to a maximum of six months prior to the date of filing, as required by 10 CFR 50.71 (e)(4 ). The proposed schedule will continue to meet the underlying purpose of the rule.
With consideration of the above information, SNC is requesting a permanent schedular exemption from the provisions of 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, and 10 CFR 50.71 (e)(4) to set the due date for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 FSAR revisions and updates to be June 30 of odd-numbered years.
3.0 JUSTIFICATION FOR THE EXEMPTION 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, and 10 CFR 50.71(e)(4) govern the schedule for submittal of FSAR updates. Since SNC is requesting an alternative submittal schedule, an exemption from the submittal schedule identified in 10 CFR Part 52, Appendix D, and in 10 CFR 50.71(e)(4), is needed.
10 CFR 50.12, 52.7, and 52.63 provide for the NRC to grant exemptions from the requirements of the regulations provided six conditions are met: 1) the exemption is authorized by law[§ 50.12(a)(1 )]; 2) the exemption will not present an undue risk to the health and safety of the public[§ 50.12(a)(1 )]; 3) the exemption is consistent with the common defense and security [§ 50.12(a)(1 )]; 4) special circumstances are present
[§ 50.12(a)(2)]; 5) the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption[§ 52.63(b)(1 )]; and
- 6) the changes do not result in a significant decrease in the level of safety [Part 52, App.
D, VIII.A.4].
The requested exemption satisfies the criteria for granting specific exemptions, as described below.
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Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule
- 1. This exemption is authorized by law The NRC has authority under 10 CFR 52.63, 52. 7, and 50.12 to grant exemptions from the requirements of NRC regulations. Specifically, 10 CFR 50.12 and 52.7 state that the NRC may grant exemptions from the requirements of 10 CFR Parts 50 and 52, respectively, upon a proper showing. No law exists that would preclude the changes covered by this exemption request. Additionally, granting of the requested exemption does not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations.
Accordingly, this requested exemption is "authorized by law," as required by 10 CFR 50.12(a)(1 ).
- 2. This exemption will not present an undue risk to the health and safety of the public The requested exemption from the requirements of 10 CFR 50.71(e)(4) and 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, would allow the periodic update submittals required by 10 CFR 50.71(e)(4) to be made on a 24-month calendar schedule. The VEGP Units 3 and 4 FSAR submittals will continue to reflect changes to the FSAR up to a maximum of six months prior to the date of filing, as required by 10 CFR 50.71 (e)(4). The use of a 24-month submittal schedule would be similar to the FSAR submittal schedule currently used by stations on a 24-month refueling cycle and the rest of the SNC fleet. Consequently, the proposed 24-month submittal schedule does not impair the ability of the NRC to review station information in a timely manner.
The proposed exemption will not alter the manner in which changes to the FSAR are evaluated in that changes to the FSAR will continue to be reviewed through the existing applicable administrative and programmatic control processes.
Therefore, the requested exemption would not present an undue risk to the health and safety of the public.
- 3. The exemption is consistent with the common defense and security The requested exemption from the requirements of 10 CFR 50.71(e)(4) and 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, would allow the periodic submittals required by 10 CFR 50.71 (e)(4) to be made on a 24-month calendar schedule. The requested exemption does not alter the design, function, or operation of any structures or plant equipment that is necessary to maintain a safe and secure status of the plant.
The requested exemption has no impact on plant security or safeguards procedures.
Therefore, the requested exemption is consistent with the common defense and security.
- 4. Special circumstances are present 10 CFR 50.12(a)(2) lists six "special circumstances" for which an exemption may be granted. Pursuant to the regulation, it is necessary for one of these special circumstances to be present in order for the NRC to consider granting an exemption E-6
Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule request. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii) and 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, which reference the FSAR update intervals of 10 CFR 50.71 (e). That subsection defines special circumstances as when "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." The requested exemption also meets the special circumstances of 10 CFR 50.12(a)(2)(iii). That subsection defines special circumstances as when "Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated."
In accordance with 10 CFR 50.12(a)(2)(ii), special circumstances exist when compliance is not necessary to achieve the underlying purpose of the rule. The underlying purpose of 10 CFR 50. 71 ( e )(4) is for the licensee to provide periodic revisions and updates of the FSAR. 10 CFR 50.71(e)(4) currently specifies a maximum time of 24 months between successive updates and the requirement to reflect changes to the FSAR up to a maximum of six months prior to the date of filing. The processing and submittal of more frequent revisions to the FSAR, including the documents incorporated by reference, is not necessary to achieve the underlying purpose of the rule. SNC maintains the VEGP Units 3 and 4 FSAR as a living document that is posted to the SNC intranet when updated. These documents are available to plant staff. The VEGP Units 3 and 4 revisions and update FSAR submittals will not exceed the maximum 24 months between submission and the submittals will continue to contain timely updates as required by 10 CFR 50.71(e)(4).
Therefore, special circumstances exist such that application of the regulations is not necessary to achieve the underlying purpose of the rules.
- 5. The special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.
Since the proposed schedule for periodic revisions and updates would continue to provide updated information consistent with the maximum interval of 24 months between successive updates identified in the regulations, there is no significant benefit to be achieved by the added burden of more frequent updates. It is expected that similar changes would be requested by other dual-unit AP1000 stations that share a combined FSAR once their§ 52.103(g) finding is complete. Additionally, the requested frequency would standardize the SNC fleet update schedules.
Therefore, the special circumstances associated with the requested exemption outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.
- 6. The design change will not result in a significant decrease in the level of safety.
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Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule There are no design changes associated with this request. The proposed schedule for periodic updates would continue to provide updated information consistent with the maximum interval of 24 months between successive revisions and updates identified in the regulations. Thus, there is no significant decrease in the level of safety that would be achieved by the added burden of more frequent updates.
4.0 ENVIRONMENTAL ASSESSMENT An exemption is requested from the requirements of 10 CFR 50.71(e)(4) and 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, to allow the periodic submittals required by 10 CFR 50.71 (e)(4) to be made on a 24-month calendar schedule. The requested exemption does not alter the design, function, or operation of any structures or plant equipment that would have a significant effect on the human environment.
SNC has determined that the proposed departure would require a permanent exemption from the referenced requirements and require NRC review and approval prior to implementation.
SNC has determined that the requested exemption meets the categorical exclusion provision in 10 CFR 51.22(c)(25). 10 CFR 51.22(c)(25) allows the exemption to be granted provided that the requirements of 10 CFR 51.22(c)(25)(i) through (vi) are met.
SNC has determined that all of the criteria for this categorical exclusion are met as follows:
(i) There is no significant hazards consideration.
The criteria for determining whether an action involves a significant hazards consideration are contained in 10 CFR 50.92. The proposed action is an administrative activity that involves a change in schedule for routine submission of the VEGP Units 3 and 4 FSAR revisions and updates. The change does not affect plant equipment, operation, or procedures. There are no significant hazards consideration associated with granting the exemption as this change does not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
The proposed action involves a schedule change for routine submittal of revisions and updates to the VEGP Units 3 and 4 FSAR. This activity is administrative in nature and does not involve any change in the types or significant increase in the amounts of any effluents that may be released offsite.
(iii) There is no significant increase in individual or cumulative public or occupational radiation exposure.
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Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule The proposed action involves a schedule change for routine submittal of revisions and updates to the VEGP Units 3 and 4 FSAR. This activity is administrative in nature and does not result in a significant increase in occupational or public radiation exposure.
(iv) There is no significant construction impact.
The proposed action involves a schedule change for routine submittal of revisions and updates to the VEGP Units 3 and 4 FSAR. This activity is administrative in nature and does not involve any construction impact.
(v) There is no significant increase in the potential for or consequences from radiological accidents.
The proposed action involves a schedule change for routine submittal of revisions and updates to the VEGP Units 3 and 4 FSAR. This activity is administrative in nature and does not result in a significant increase in the potential for or consequences from radiological accidents.
(vi) The requirements from which an exemption is sought involve:
(A) Recordkeeping requirements; (B) Reporting requirements; (C) Inspection or surveillance requirements; (D) Equipment servicing or maintenance scheduling requirements; (E) Education, training, experience, qualification, requalification or other employment suitability requirements; (F) Safeguard plans, and materials control and accounting inventory scheduling requirements; (G) Scheduling requirements; (H) Surety, insurance or indemnity requirements; or (I) Other requirements of an administrative, managerial, or organizational nature.
The proposed action involves 10 CFR 51.22(c)(25)(vi)(G), scheduling requirements. The schedule requirements are associated with an administrative activity to provide periodic FSAR revisions and updates as prescribed in 10 CFR 50.71(e)(4). This exemption request proposes a revised FSAR update schedule for VEGP Units 3 and 4. SNC would submit the updated VEGP Units 3 and 4 FSAR by June 30 of every odd-numbered year.
This schedule will meet the underlying purpose of 10 CFR 50.71 (e)(4) to periodically submit FSAR revisions and updates, including documents incorporated by reference in the FSAR, to NRG to maintain the FSAR up-to-date and accurately reflecting the plant design and operation.
The VEGP Units 3 and 4 FSAR updates will continue to reflect changes to the FSAR up to a maximum of six months prior to the date of filing, as required by 10 CFR 50.71(e)(4). Further, the proposed exemption would not allow SNC to exceed the maximum 24 months between successive updates as required by 10 CFR 50.71 (e)(4).
The proposed due dates would allow, for practical or business reasons, the submittal to be made any time during the month in which the submittal is due.
Based on the above discussion, SNC asserts that the proposed exemption meets the eligibility criteria for the categorical exclusion set forth in 10 CFR 51.22(c)(25).
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Enclosure to NL-24-0097 Exemption Request: Final Safety Analysis Report Update Schedule Therefore, in accordance with 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with this exemption request.
5.0 PRECEDENT On August 4, 2021 [ML21179A204], the NRC granted VEGP Units 1 and 2 an exemption to allow a single submittal of the periodic updates of the VEGP Units 1 and 2 FSAR by October 31 of every even-numbered year, not to exceed 24 months between successive updates.
The August 4, 2021 [ML21179A204] NRC approval also granted Farley Nuclear Plant (FNP) Units 1 and 2 an exemption to allow a single submittal of the periodic updates of the FNP Units 1 and 2 FSAR by October 31 of every odd-numbered year, not to exceed 24 months between successive updates.
On January 30, 2020 [ML19364A018], the NRC granted Hatch Nuclear Plant (HNP)
Units 1 and 2 an exemption to allow a single submittal of the periodic updates of the HNP Units 1 and 2 FSAR by August 31 of every even-numbered year, not to exceed 24 months between successive updates.
Upon approval of this requested exemption, SNC would be providing FSAR revisions and updates for the SNC fleet of nuclear-powered facilities on the following schedule:
Hatch Units 1 and 2 FSAR updates by August 31 of even-numbered years Vogtle Units 1 and 2 FSAR updates by October 31 of even-numbered years Vogtle Units 3 and 4 FSAR updates by June 30 of odd-numbered years Farley Units 1 and 2 FSAR updates by October 31 of odd-numbered years
6.0 CONCLUSION
The requested exemption from the requirements of 10 CFR 50.71(e)(4) and 10 CFR Part 52, Appendix D, Sections X.B.2 and X.B.3.c, would allow the periodic submittals required by 10 CFR 50.71 (e)(4) to be made on a 24-month calendar schedule. The exemption request meets the requirements of 10 CFR 52.63, Finality of design certifications, 10 CFR 52.7, Specific exemptions, and 10 CFR 50.12, Specific exemptions. Specifically, the exemption request meets the criteria of 10 CFR 50.12 in that the request is authorized by law, presents no undue risk to public health and safety, and is consistent with the common defense and security. Furthermore, approval of this request does not result in a significant decrease in the level of safety, satisfies the underlying purpose of the regulations, and does not present a significant decrease in safety as a result of a reduction in standardization.
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