IR 05000348/2024010
| ML24101A203 | |
| Person / Time | |
|---|---|
| Site: |  |
| Issue date: | 04/16/2024 |
| From: | Daniel Bacon NRC/RGN-II/DRS/EB2 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| IR 2024010 | |
| Download: ML24101A203 (9) | |
Text
SUBJECT:
JOSEPH M. FARLEY - NRC INSPECTION REPORT 05000348/2024010 AND 05000364/2024010
Dear Jamie M. Coleman:
On March 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley. On March 20, 2024, the NRC inspectors discussed the results of this inspection with Gene Surber and other members of your staff. The results of this inspection are documented in the enclosed report.
No findings or violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Daniel M. Bacon, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000348 and 05000364 License Nos. NPF-2 and NPF-8
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000348 and 05000364
License Numbers: NPF-2 and NPF-8
Report Numbers: 05000348/2024010 and 05000364/2024010
Enterprise Identifier: I-2024-010-0022
Licensee: Southern Nuclear Operating Company, Inc.
Facility: Joseph M. Farley
Location: Columbia, AL
Inspection Dates: January 22, 2024 to February 09, 2024
Inspectors: P. Braaten, Senior Reactor Inspector P. Meier, Senior Resident Inspector J. Montgomery, Senior Reactor Inspector A. Rosebrook, Senior Reactor Analyst
Approved By: Daniel M. Bacon, Chief Engineering Branch 2 Division of Reactor Safety
Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC inspection at Joseph M. Farley, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
Type Issue Number Title Report Section Status URI 05000348,05000364/20 Multiple Components 37060 Open 24010-01 Associated With HSS Systems Re-Categorized to LSS based on Defense-In-Depth or Manual Actions
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
37060 - 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection
The inspectors reviewed the licensees program and implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, in accordance with the following procedure sections. Section 02.04 was not completed during this inspection because the feedback and process adjustment required by 10 CFR 50.69(e) was not implemented by the licensee. As of the date of this inspection, two refueling outages have not occurred since system categorization was completed on at least three systems.
Review of the Licensees Programs and Procedures (IP Section 02.01) (1 Partial)
(1) (Partial)
The team reviewed the licensees programs and procedures to ensure that the procedures fully described the categorization and treatment process for SSCs as described in its UFSAR and as required by 10 CFR 50.69.
Review of the Licensees 10 CFR 50.69 Program Implementation (IP Section 02.02) (1 Partial)
(1) (Partial)
The team reviewed the licensee's 10 CFR 50.69 categorization process and alternate treatment requirements completed on the following systems:
- Chemical Volume & Control/Safety Injection
- Main Feedwater
Problem Identification and Resolution (IP Section 02.03) (1 Partial)
(1) (Partial)
For the systems listed above, the inspectors reviewed the licensees corrective action program to verify that conditions that would prevent RISC-3 SSCs from performing their safety-related function have been corrected. Additionally, the inspector verified that, as appropriate, the licensee performed common cause reviews for RISC-3 SSC deficiencies to ensure that the licensees SSC categorization process remains valid.
INSPECTION RESULTS
Unresolved Item Multiple Components Associated With HSS Systems Re- 37060 (Open) Categorized to LSS based on Defense-In-Depth or Manual Actions URI 05000348,05000364/2024010-01
Description:
On June 30, 2021, the NRC approved Farley Nuclear Plant (FNP) License Amendments 233 and 230 (ML21137A247) which allows the implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors. In its license amendment request, FNP stated that they will implement the risk categorization process in accordance with NEI 00-04, Revision 0, as endorsed by Regulatory Guide (RG) 1.201, "Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to their Safety Significance".
The categorization of structures, systems, and components (SSCs) is governed by fleet procedure NMP-ES-065-003, 10 CFR 50.69 Risk Informed Categorization for Structures, Systems, and Components.
The NEI 00-04 categorization process yields components that are preliminarily screened as high-safety-significant (HSS) or low-safety-significant (LSS). Some preliminary HSS components can be downgraded via Detailed Categorization. This process is described in Section 10.2 of NEI 00-04. This part of the process is optional and is implemented based on the anticipated benefit of performing additional analyses to support downgrading a component.
The licensees categorization of the Chemical Volume and Control (CVCS) system was approved on July 26, 2023. The licensee's categorization of the Emergency Diesel Generators (EDGs) was approved on September 19, 2022. The results of these categorization processes yielded multiple components that were identified as preliminary HSS, and these components were subsequently re-categorized to LSS based on defense-in-depth and/or the ability to take manual actions to ensure the components are placed in their credited states to support the function.
Section 10.2 of NEI 00-04 states that the criterion for categorizing as LSS a component that supports an HSS function is that its failure would not preclude the fulfillment of the safety-significant function. Section 10.2 goes on to provide examples of considerations for meeting the aforementioned criterion:
- There is no credible failure mode for the SSC that would prevent a safety-significant function from being fulfilled (e.g., a locked open or locked closed valve, a manually controlled valve, etc.),
- A failure for the SSC would not prevent a safety-significant function from being fulfilled (e.g., a vent or drain line that is not a significant flow diversion path, SSCs downstream of the first isolation valve from the active pathway of the function, etc.),
and
- Instrumentation that would not prevent a safety-significant function from being fulfilled (e.g., radiation monitors that do not have a direct diagnosis function, etc.)
Planned Closure Actions: More information is needed to determine whether the licensee is allowed to credit defense-in-depth as a sole basis to say that failure of a component would not preclude the fulfillment of a safety-significant function, to address the optional detailed categorization portion of the NEI 00-04 classification process. Additionally, if defense-in-depth can be credited in this way, more information is needed to verify that the licensee completed all necessary sensitivity studies and subsequent defense-in-depth reviews associated with the re-classified components.
Corrective Action References: The licensee entered this issue of concern into their corrective action program as
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On March 20, 2024, the inspectors presented the NRC inspection results to Gene Surber and other members of the licensee staff.
- On February 8, 2024, the inspectors presented the initial exit inspection results to Edwin D. Dean III (Sonny) and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
37060 Calculations F-RIE-FIREPRA- Fire Probabilistic Risk Assessment Quantification and Version 5.0
U00-014 Summary Report
F-RIE-OEE-U00 Evaluation of Other External Hazards Version 1
Engineering PMCR 104132 Per NMP-ES-065, UFSAR Chapter 13.8 and 10 CFR50.69, 11/12/2022
Evaluations RISC-3 SSCs of Categorized Systems can be exempted
from the IST program. This PMCR approves the removal of
these RISC-3 SSCs from IST required PMs and defines the
Alternative Treatment (AT) for the associated Tests and/or
Inspections
PMCR 104133 Per NMP-ES-065, UFSAR Chapter 13.8 and 10 CFR50.69, 11/11/2022
RISC-3 SSCs of Categorized Systems can be exempted
from the 50.49 (EQ) program. This PMCR approves the
removal of these RISC-3 SSCs from EQ required PMs and
defines the Alternative Treatment (AT) for the associated
Tests and/or Inspections.
PMCR 106768 Updates Alternative Treatment in PMCR 104179 01/16/2024
RBD-FNP-5069- 10 CFR 50.69 System Categorization - Containment Spray Revision 3
E13
RBD-FNP-5069- 10 CFR 50.69 System Categorization - Chemical & Volume Revision 1
E21 Control/Safety Injection
RBD-FNP-5069- 10 CFR 50.69 System Categorization - Main Steam Revision 1
N11
RBD-FNP-5069- 10 CFR 50.69 System Categorization - Main Feedwater Revision 2
N21
RBD-FNP-5069- 10 CFR 50.69 System Categorization - Emergency Diesel Revision 1
R43, Y52, and Generators
P21
Miscellaneous Joseph M. Farley Nuclear Plant - Units 1 and 2 - Application 06/18/2020
to Adopt 10 CFR 50.69, "Risk-informed categorization and
treatment of structures, systems and components for nuclear
power reactors"
JOSEPH
- M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, 06/30/2021
Inspection Type Designation Description or Title Revision or
Procedure Date
ISSUANCE OF AMENDMENT NO
- S. 233 AND 230, TO
ADOPT 10 CFR 50.69, RISK-INFORMED
CATEGORIZATION AND TREATMENT OF STRUCTURES,
SYSTEMS AND COMPONENTS FOR NUCLEAR POWER
REACTORS
EPRI Alternative Approaches for Addressing Seismic Risk in 10 February
3002017583 CFR 50.69 Risk-Informed Categorization 2020
NEI 00-04 10 CFR 50.69 SSC Categorization Guideline Revision 0
NEI 16-09 Risk-Informed Engineering Programs (10 CFR 50.69) Revision 1
Implementation Guidance
NEI 17-05 RISK INFORMED ENGINEERING PROGRAMS (10 CFR Revision 0
50.69): RISC-3 ALTERNATIVE TREATMENTS
PWROG-19014- 10 CFR 50.69: NEI 00-04 Sole Means Categorization Revision 0
NP Interpretations
RG 1.201 GUIDELINES FOR CATEGORIZING STRUCTURES, Revision 1
SYSTEMS, AND COMPONENTS IN NUCLEAR POWER
PLANTS ACCORDING TO THEIR SAFETY SIGNIFICANCE
TP18-2-392 50.69 Working Group Committee - Categorization Focus Revision 0
Group - Detailed Structures Systems and Components
(SSCs) Categorization for 10CFR50.69
Procedures NMP-ES-065 10 CFR 50.69 Program Version 6.0
NMP-ES-065-001 10 CFR 50.69 PRA Component Risk Significance Insights Version 7.0
NMP-ES-065-002 10 CFR 50.69 Passive Component Categorization Version 5.0
NMP-ES-065-003 10 CFR 50.69 Risk Informed Categorization for Structures, Version 9.0
Systems, and Components
NMP-ES-065-004 10 CFR 50.69 Treatment Requirements Version 7.0
NMP-ES-065-005 Integrated Decision-Making Panel for Risk Informed SSC Version 5.0
Categorization Duties and Responsibilities
7