ML23198A155

NRR E-mail Capture - for Your Action - Request for Additional Information (RAI) - Hatch, Farley, and Vogtle, Units 1 and 2 Quality Assurance Topical Report (QATR) Submittal Dated June 15, 2023

ML23198A155
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	07/17/2023
From:	John Lamb NRC/NRR/DORL/LPL2-1
To:	Quarles A Southern Nuclear Operating Co
References
Download: ML23198A155 (4)

Text

From: John Lamb Sent: Monday, July 17, 2023 11:17 AM To: Quarles, Adam Graham Cc: Joyce, Ryan M.; Chamberlain, Amy Christine; Lowery, Ken G.; Pournaras, DeLisa S.; Sparkman, Wesley A.

Subject:

For Your Action - Request for Additional Information (RAI) - Hatch, Farley, and Vogtle, Units 1 and 2 QATR Submittal Dated June 15, 2023 Importance: High

Adam, By letter dated June 15, 2023 (Agencywide Documents and Access Management System Accession No. ML23166A104), Southern Nuclear Operating Company (SNC, the licensee) submitted Version 26 of SNC Quality Assurance Topical Report (QATR) for the Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, and the Vogtle Electric Generating Plant (Vogtle), Units 1 and 2.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the changes and finds that additional information is needed to provide assurance that the changes meet the no reduction in commitment of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a)(3)(ii),

i.e., (ii) The use of a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility.

On July 27, 2023, the NRC staff provided draft RAI questions to SNC to make sure that the RAI is understandable, the regulatory basis is clear, to ensure there is no proprietary information, and to determine if the information was previously docketed. On July 13, 2023, a clarifying call was held between the NRC staff and SNC. On July 17, 2023, SNC stated that it would provide the RAI response within 30 days from the date of this email.

By regulation, changes to the QATR may be regarded as accepted by the Commission 60 days after submittal to the Commission; however, in this case, the NRC staff is reviewing the QATR, and will notify SNC by letter when the review is completed.

If you have any questions, you can contact me at 301-415-3100.

Sincerely, John REQUEST FOR ADDITIONAL INFORMATION (RAI)

By letter dated June 15, 2023 (Agencywide Documents and Access Management System Accession No. ML23166A104), Southern Nuclear Operating Company (SNC, the licensee) submitted Version 26 of SNC Quality Assurance Topical Report (QATR) for the Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, the Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, and the Vogtle Electric Generating Plant (Vogtle), Units 1 and 2.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the changes and finds that additional information is needed to provide assurance that the changes meet the no reduction in commitment of Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a)(3)(ii),

i.e., (ii) The use of a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility.

Regulatory Basis The regulation 10 CFR 50.54(a)(3) states:

Each licensee described in paragraph (a)(1) of this section may make a change to a previously accepted quality assurance program description included or referenced in the Safety Analysis Report without prior NRC approval, provided the change does not reduce the commitments in the program description as accepted by the NRC. Changes to the quality assurance program description that do not reduce the commitments must be submitted to the NRC in accordance with the requirements of Sec. 50.71(e). In addition to quality assurance program changes involving administrative improvements and clarifications, spelling corrections, punctuation, or editorial items, the following changes are not considered to be reductions in commitment:

(i) The use of a QA standard approved by the NRC which is more recent than the QA standard in the licensees current QA program at the time of the change; (ii) The use of a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility; (iii) The use of generic organizational position titles that clearly denote the position function, supplemented as necessary by descriptive text, rather than specific titles; (iv) The use of generic organizational charts to indicate functional relationships, authorities, and responsibilities, or, alternately, the use of descriptive text; (v) The elimination of quality assurance program information that duplicates language in quality assurance regulatory guides and quality assurance standards to which the licensee is committed; and (vi) Organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations.

Request for Additional Information

The NRC staff identified one area where a request for additional information (RAI) is needed. In , SNC QATR Versions 24.0, 25.0, and 26.0, Summary of Changes, of the SNC letter dated June 15, 2023, Item 6 references an Exelon Safety Evaluation (SE) documented under ADAMS Accession No. ML20287A130, dated November 5, 2020. The Exelon SE addresses the following activities related to annual evaluation and an analysis:

Exelons request includes a revision to the QATR to require an evaluation once per calendar year to determine the need for additional audit activities. Exelon will assess the results of this evaluation, and, when necessary, a review of the identified areas of performance weakness will be planned at the earliest possible opportunity. Exelon also stated that: Each functional audit area will receive an additional performance analysis (evaluation) within 2 years of the last performed audit based on internal and external data; functional area changes in responsibility, resources, or management; and consideration of the impacts, as applicable, to determine if additional audit activities are necessary prior to the 36-month scheduled performance. The NRC staff determined that the additional evaluation requirement will ensure that for Exelons facilities the extension of internal audit intervals beyond 2 years will be based on the results of an annual evaluation of the applicable functional area and objective evidence that the functional area activities are being satisfactorily accomplished.

The summary of changes in the SNC letter dated June 15, 2023, is silent on how SNC meets the conditions described in the Exelon submittal dated December 5, 2019 (ML19339E544), as supplemented by letter dated February 24, 2020 (ML20055G249), and the NRC staff SE dated November 5, 2020. Please discuss how SNC has / or will incorporate the activities above to meet the intent of the Exelon SE.

Hearing Identifier: NRR_DRMA Email Number: 2169 Mail Envelope Properties (MN2PR09MB5084B408D97C800924D816CBFA3BA)

Subject:

For Your Action - Request for Additional Information (RAI) - Hatch, Farley, and Vogtle, Units 1 and 2 QATR Submittal Dated June 15, 2023 Sent Date: 7/17/2023 11:17:24 AM Received Date: 7/17/2023 11:17:00 AM From: John Lamb Created By: John.Lamb@nrc.gov Recipients:

"Joyce, Ryan M." <RMJOYCE@southernco.com>

Tracking Status: None "Chamberlain, Amy Christine" <ACCHAMBE@southernco.com>

Tracking Status: None "Lowery, Ken G." <KGLOWERY@southernco.com>

Tracking Status: None "Pournaras, DeLisa S." <DSPOURNA@SOUTHERNCO.COM>

Tracking Status: None "Sparkman, Wesley A." <WASPARKM@southernco.com>

Tracking Status: None "Quarles, Adam Graham" <AGQUARLE@southernco.com>

Tracking Status: None Post Office: MN2PR09MB5084.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6625 7/17/2023 11:17:00 AM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: