ML24290A155
| ML24290A155 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 10/16/2024 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Pournaras D, Quarles A, Sparkman W Southern Nuclear Operating Co |
| References | |
| Download: ML24290A155 (5) | |
Text
From:
John Lamb Sent:
Wednesday, October 16, 2024 2:27 PM To:
Quarles, Adam Graham; Sparkman, Wesley A.; Pournaras, DeLisa S.
Cc:
Joyce, Ryan M.
Subject:
For Your Action - RAI - Farley, Hatch, and Vogtle 1 and 2 - Proposed Alternative Request for Code Case N-572 Wes, Adam, and DeLisa, By letter dated June 27, 2024 (ML24179A334), Southern Nuclear Operating Company (SNC, the licensee) submitted a proposed alternative request 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 and 2. SNC submitted a proposed alternative request to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. SNC submitted the proposed alternative request to use Code Case N-752, Risk Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, for determining the risk-informed categorization and for implementing alternative treatment for repair/replacement activities on moderate and high energy Class 2 and 3 items in lieu of certain ASME Boiler and Pressure Vessel Code,Section XI, IWA-1000, IWA-4000, and IWA-6000 requirements.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required for the staff to complete its review. The NRC staff sent the draft requestion for additional information (RAI) on October 10, 2024, to determine if SNC needed a clarifying call. On October 16, 2024, SNC said that a clarifying call was not needed. Please respond to the below RAI within 30 days of the date of this email.
If you have any questions, contact me.
John G. Lamb Senior Project Manager NRC/NRR/DORL/LPLII-1 (301) 415-3100 REQUEST FOR ADDITIONAL INFORMATION (RAI)
By letter dated June 27, 2024 (ML24179A334), Southern Nuclear Operating Company (SNC, the licensee) submitted a proposed alternative request 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 and 2. SNC submitted a proposed alternative request to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. SNC submitted the proposed alternative request to use Code Case N-752, Risk Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, for determining the risk-informed categorization and for implementing alternative treatment for repair/replacement activities on moderate and high energy Class 2 and 3 items in lieu of certain ASME Boiler and Pressure Vessel Code,Section XI, IWA-1000, IWA-4000, and IWA-6000 requirements.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required for the staff to complete its review.
Regulatory Evaluation The NRC regulations in 10 CFR 50.55a(z), Alternatives to codes and standards requirements, state:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Requests for Additional Information (RAIs)
RAI-1
Section 5.1, Overview of Code Case N-752, the licensee states the following:
The categorization and treatment requirements of Code Case N-752 are consistent with those in 10 CFR 50.69.
The NRC regulations in 10 CFR 50.69 specifies requirements regarding the categorization and treatment of SSCs. For example, 10 CFR 50.69 includes the following:
10 CFR 50.69(c), SSC Categorization Process.
(1) SSCs must be categorized as RISC-1, RISC-2, RISC-3, or RISC-4 SSCs using a categorization process that determines if an SSC performs one or more safety significant functions and identifies those functions. The process must:
(v) Be performed for entire systems and structures, not for selected components within a system or structure.
10 CFR 50.69(d), Alternative treatment requirements.
(2) RISC-3 SSCs. The licensee or applicant shall ensure, with reasonable confidence, that RISC-3 SSCs remain capable of performing their safety related functions under design basis conditions, including seismic conditions and environmental conditions and effects throughout their service life. The treatment of RISC-3 SSCs must be consistent with the categorization process. Inspection and testing, and corrective action shall be provided for RISC-3 SSCs.
(i) Inspection and testing. Periodic inspection and testing activities must be conducted to determine that RISC-3 SSCs will remain capable of performing their safety-related functions under design basis conditions; and (ii) Corrective action. Conditions that would prevent a RISC-3 SSC from performing its safety-related functions under design basis conditions must be corrected in a timely manner. For significant conditions adverse to quality, measures must be taken to provide reasonable confidence that the cause of the condition is determined and corrective action taken to preclude repetition.
The licensee is requested to describe the following:
- a. the provisions of the SNC Fleet categorization process that are consistent with 10 CFR 50.69(c)(1)(v) recognizing that industry guidance cannot modify NRC regulations without rulemaking.
- b. the provisions of the SNC Fleet treatment process that are consistent with 10 CFR 50.69(d) with respect to inspection, testing, and corrective action for safety-related SSCs categorized as low safety significant (LSS) to provide a technically defensible method for the treatment of LSS safety-related SSCs as indicated by the Commission guidance in the Federal Register notice (69 FR 68008) describing acceptable implementation of 10 CFR 50.69 programs.
RAI-2
The alternative request includes statements regarding treatment requirements established by the Owner such as the following:
treatment requirements established by the Owner Owner to define alternative treatment requirements SNC will develop and/or revise existing procedures and documents to define treatment requirements Owners Requirements shall be met requirements shall be established by the Owner SNC will define alternative treatment requirements Owner-defined administrative requirements on LSS items Further, Item 14 of Paragraph E, Treatment Requirements for LSS Items, of the alternative request states the following:
For SNC nuclear sites having received NRC authorization to use the alternative repair/replacement categorization and treatment requirements of ASME Code Case N-752 in lieu of the corresponding sections of ASME Section XI, as referenced in 10 CFR 50.55a Codes and Standards, treatment of safety-related structures, systems, and components identified as low safety significant (LSS) Class 2 and 3 SSCs in accordance with ASME Code Case N-752 is not required to meet the requirements of this manual [SNC Quality Assurance Topical Report
(QATR)]. Instead, treatment of these LSS SSCs is performed in accordance with existing QA Program procedures and processes which include supplemental controls to ensure the capability and reliability of the SSCs design basis function.
The licensee is requested to clarify these statements because QA and treatment activities for LSS safety-related SSCs remain within the scope of 10 CFR Part 50, Appendix B, when implementing Code Case N-752, with risk-informed relaxation of specific activities allowed by the NRC when authorizing N-752 requests, with the design, licensing basis, and regulatory enforcement remaining subject to 10 CFR Part 50, Appendix B, regardless of the change to the SNC QATR.
RAI-3
An alternative request under 10 CFR 50.55a(z) cannot grant an exemption to 10 CFR Part 50, Appendix B, requirements. The NRC staff approved the Arkansas Nuclear One (ANO) precedent, referenced in the SNC Fleet request, on the basis that the QA Manual changes were acceptable for meeting 10 CFR Part 50, Appendix B, for LSS safety-related SSCs when implementing Code Case N-752. In its evaluation of the ANO request, the NRC staff determined that the relaxed requirements did not constitute a reduction in the effectiveness for the LSS items and continue to meet 10 CFR Part 50, Appendix B.
The SNC Fleet alternative request includes statements regarding exemptions such as the following:
LSS components are exempt from ASME Section XI repair/replacement requirements In light of these statements and the above discussion, the licensee is requested to clarify the statements in the SNC Fleet alternative request regarding:
(1) the applicability of 10 CFR Part 50, Appendix B, during the use of Code Case N-752, (2) the submittals reference to the use of Code Case N-752 without exception although Appendix B will continue to apply, (3) meeting reasonable confidence vs. reasonable assurance to confirm that Appendix B will continue to be met, and (4) updates to the QATR regarding Class 2 and 3 LSS items in that these items are not exempt from Appendix B.
Also, please discuss whether these clarifications will result in changes to the SNC plans for updating the QATR under 10 CFR 50.54.
Hearing Identifier:
NRR_DRMA Email Number:
2622 Mail Envelope Properties (MN2PR09MB5084DEFFC983373892890174FA462)
Subject:
For Your Action - RAI - Farley, Hatch, and Vogtle 1 and 2 - Proposed Alternative Request for Code Case N-572 Sent Date:
10/16/2024 2:27:20 PM Received Date:
10/16/2024 2:27:00 PM From:
John Lamb Created By:
John.Lamb@nrc.gov Recipients:
"Joyce, Ryan M." <RMJOYCE@southernco.com>
Tracking Status: None "Quarles, Adam Graham" <AGQUARLE@southernco.com>
Tracking Status: None "Sparkman, Wesley A." <WASPARKM@southernco.com>
Tracking Status: None "Pournaras, DeLisa S." <DSPOURNA@SOUTHERNCO.COM>
Tracking Status: None Post Office:
MN2PR09MB5084.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 9762 10/16/2024 2:27:00 PM Options Priority:
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