ML24302A297

Regulatory Audit Report in Support of Review of the License Amendment Request to Revise TS 1.1 and Add New TSs 5.5.21 and 5.5.17

ML24302A297
Person / Time
Site:	Hatch, Farley   (NPF-002, NPF-008, DPR-057, NPF-005)
Issue date:	11/15/2024
From:	Bryant J Plant Licensing Branch II
To:	Coleman J Southern Nuclear Operating Co
Turner, Zachary
Shared Package
ML24302A304	List: ML24302A297
References
EPID L-2024-LLA-0058
Download: ML24302A297 (1)

Text

November 15, 2024 Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway, N 274 EC Birmingham, AL 35243

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, AND EDWIN I.

HATCH NUCLEAR PLANT - REGULATORY AUDIT REPORT IN SUPPORT OF REVIEW OF THE LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 1.1, DEFINITIONS, AND ADD NEW TECHNICAL SPECIFICATIONS 5.5.21 AND 5.5.17, ONLINE MONITORING PROGRAM, FOR FARLEY AND HATCH, RESPECTIVELY (EPID L-2024-LLA-0058)

Dear Jamie Coleman:

By letter dated May 3, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24124A133), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, and Edwin I. Hatch Nuclear Plant, Units 1 and 2. The proposed LAR would revise Technical Specification (TS) 1.1, Definitions, and add new TS 5.5.21 and TS 5.5.17, entitled, Online Monitoring Program, for Farley and Hatch, respectively.

SNC proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed LAR is based on the U.S. Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Corporation (AMS) topical report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (ML21235A493).

The NRC staff conducted a virtual regulatory audit between July 1 and October 31, 2024, to examine the SNCs non-docketed information on the proposed Farley and Hatch OLM programs. This audit was conducted in accordance with the audit plan dated June 4, 2024 (ML24149A049). The purpose of this audit was to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.

The purpose of this letter is to provide the results of the regulatory audit. Documented in the enclosed report are the observations the NRC staff identified during the audit.

Sincerely,

/RA/

Jack H. Minzer Bryant, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321,50-366, 50-348, and 50-364

Enclosure:

Audit Report cc: Listserv

Enclosure REGULATORY AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST TO REVISE TS 1.1 AND ADD NEW TS 5.5.21 FOR FARLEY AND 5.5.17 FOR HATCH SOUTHERN NUCLEAR OPERATING COMPANY JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-321, 50-366, 50-348, AND 50-364 DATE: July 1 to October 31, 2024 LOCATION: Remote AUDIT TEAM MEMBERS:

Gilberto Blas, Audit Team Member, Office of Nuclear Reactor Regulation (NRR)/

Division of Engineering and External Hazards (DEX)/Instrumentation and Controls Branch (EICB),

Joseph Ashcraft, Audit Team Member, NRR/DEX/EICB, Ravi Grover, Audit Team Member, NRR/Division of Safety Systems (DSS)/Technical Specification Branch (STSB),

John Lamb, Audit Team Member, NRR/ Division of Operating Reactor Licensing (DORL)/Plant Licensing Branch 2-1 (LPLII-I), and Jack Minzer Bryant, Audit Team Member, NRR/DORL/LPLII-I.

BACKGROUND:

By letter dated May 3, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24124A133), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, and Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2. The proposed LAR would revise Technical Specification (TS) 1.1, Definitions, and add new TS 5.5.21 and 5.5.17, Online Monitoring Program, for Farley and Hatch, respectively.

The licensee proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed LAR is based on the U.S. Nuclear Regulatory Commission (NRC) approved Analysis and Measurement Services Corporation (AMS) topical report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (ML21235A493).

The NRC staff from NRR has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures, Revision 6, dated July 2020 (ML19248C539).

REGULATORY AUDIT BASES:

A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. The purpose of this audit was to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision. This audit was conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ML19226A274), with exceptions noted within the audit plan.

The NRC staff performed this audit to support its evaluation of whether the SNC LAR can be approved per Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of license, construction permit, or early site permit. The NRC staffs review was informed by NUREG-0800, Standard Review Plan. The results of this audit are being used to enhance the NRC staffs understanding of the licensees proposed OLM LAR.

AUDIT SCOPE:

This audit focused on reviewing the OLM procedures and Farley and Hatch specific OLM reports to confirm that the Farley and Hatch OLM programs are being implemented in a manner that is consistent with the NRC approved AMS OLM topical report. A secondary purpose of this audit was to enable the NRC staff to develop a better understanding of the information being used to support the implementation of the Farley and Hatch OLM programs.

The licensee and AMS supported the audit by providing remote access to requested reports and by making appropriate staff with detailed knowledge of AMS-TR-0720R2-A available for discussions with the NRC staff.

REGULATORY AUDIT ACTIVITIES:

Audit Call, August 29, 2024 The NRC staff requested the following audit discussion points during the August 29th teleconference:

1. Since initial data collected by the sensors was collected during startup, operation, and shutdown, going forward describe when data is collected/analyzed and determine which if any sensors are to be calibrated?

2. How does Instrument Performance Analysis Software System (IPASS) calculate backstops?

3. Using Farley Main Steam Pressure Loops A, B, & C as an example. It appears that all sensors, but PT-486, would support a 32-year backstop.

a. Does that mean PT-486 will be the one calibrated every 1.5 years?

b. Assuming PT-486 is the one calibrated, what is the estimate of the backstop increasing for Channel B from each calibration?

c. With refuel every 30 months, are all sensors with back stops less than 30 months getting calibrated? Are they all accessible while the Reactor is operating?

4. Is there a TS to check all three channels (A, B, & C). How might this impact OLM?

The licensee explained:

1. Data is collected and analyzed, and sensors are calibrated, in accordance with the OLM program for both Farley and Hatch.

2. IPASS calculates backstops per chapter 13 of the TR AMS-TR-0720R2-A.

3. OLM methodology using PT-486 as an example.

4. There are TSs that require channel checking for all three channels, and it is incorporated into the OLM program because the OLM program would flag the channel for calibration when the assessment is done.

Audit Call, September 26, 2024 The NRC staff requested the following audit discussion points during the September 26th teleconference:

1. Clarify where these transmitters are called out in the LAR, and where the corresponding locations are in the OLM Amenable Transmitters Reports.

a. For Farley, Remote Shutdown System or Reactor Trip System, which is called out in the LAR (ML24124A133 (pg. 5, section 2.2), is not found in Tables 2.3 or 3.3, for the OLM Amenable Transmitters Report, for Farley Units 1 and 2 (FNP2301).

b. For Hatch, Remote Shutdown System, which is called out in the LAR (pg. 5 for Hatch 1, pg. 6 for Hatch 2), is not found in Table 2.3, nor Table 3.3 of the OLM Amenable Transmitters Report for Hatch Units 1 and 2 respectively (HAT2301).

2. Looking at Tables 2.3 and 3.3 for both documents (FNP2301 and HAT2301), it appears that the Pages referenced by the column titled TS Function Page Ref Table Items, is not pointing to the correct page referring to the TS document. For example, for Farley 1, Table 2.2, (pg. 15 of FNP 2301) is looking at Main Steam Pressure A, it states pg. Ref.

109 of the TS, however, when looking at the Farley, Units 1 and 2, TSs (ML052780033),

that function is found in pg. 120.

3. The licensee is proposing several changes to the Definitions section 1.1 in Hatch Unit 1 (ML052930172) and 2 (ML052930177) TSs. Two of the proposed changes for the Hatch Unit 2 TSs pertain to a revision to the definitions for Emergency Core Cooling System (ECCS) Response Time, and Isolation System Response Time, (TS pg. 1.1-4). The NRC staff noticed that Hatch Unit 1 TSs do not specify a definition for the ECCS Response Time or the Isolation System Response Time, and therefore, it seems that the changes similar to those for Unit 2 TS have not been proposed by the licensee in the amendment. Clarify the variation between the Hatch Unit 1 and 2 TSs.

The licensee explained:

1. Regarding where the transmitters are called out in the LAR and the transmitters corresponding locations in the Amenable Transmitters Report.

a. At Farley, for sensors that support the term Remote Shutdown System, or Reactor Trip System, as called out in the LAR, are shown in FNP2301 under RPS, which is what is referenced in the Amenable Transmitters report.

b. At Hatch Unit 2, for sensors that support the term Remote Shutdown System, as called out in the LAR, are shown in HAT2301 under RPS, which is what is referenced in the Amenable Transmitters report.

2. The pages referencing the TSs in Tables 2.3 and 3.3 of FNP2301 and HAT2301 refer to the pdf pages of the TSs and not the pdf pages of the authority file of the TSs that have the plants licensing pages ahead of the TSs.

3. The changes to the definitions contained in the LAR for Hatch Unit 2 for ECCS Response Time, and Isolation System Response Time do not exist for Hatch Unit 1 because Hatch Unit 1 does not have those definitions in their TSs.

Audit Call, October 10, 2024 Based on the audit call on September 26, 2024, the NRC staff requested additional discussion on why the changes to the definitions contained in the LAR for Hatch Unit 2 for ECCS Response Time, and Isolation System Response Time do not exist for Hatch Unit 1.

The licensee clarified that the definitions contained in the Hatch Unit 2 TSs for ECCS Response Time, and Isolation System Response Time do not exist in Hatch Unit 1. Therefore, the changes to the definitions of ECCS Response Time and Isolation System Response Time, for Hatch Unit 2 TSs are not applicable to the Hatch Unit 1 TSs and are not included in the LAR. The licensee used the docketed information in Safety Evaluation supporting amends 195 & 135 to license DPR-57 and NPF-5, respectively, March 3, 1995 (ML20081C068) pg. 14 to clarify that these two definitions are not included in the improved TS for Hatch Unit 1 because response time test requirements are not currently contained in the Unit 1 CTS.

During the final Audit Call conducted on October 10th, 2024, the audit was closed with the licensee. There were no open items from audit discussions and no deviations from the audit plan.

DOCUMENTS AVAILABLE ON CERTEC PORTAL:

The licensee supported the audit by making appropriate staff and contractor supporting personnel available for discussions who have detailed knowledge of AMS-TR-0720R2-A, and the principles and bases for the OLM processes discussed in AMS-TR-0720R2-A. The following documents were made available for the NRC staffs review on a web-based portal throughout the duration of the audit period.

Item #

Audit Item 1

AMS Report FNP2301R0, OLM Amenable Transmitters Report for Farley Units 1 & 2 2

AMS Report HAT2301R0, OLM Amenable Transmitters Report for Hatch Units 1 & 2 3

AMS Report FNP2302R0, OLM Analysis Methods and Limits Report for Farley Units 1 & 2 4

AMS Report HAT2302R0, OLM Analysis Methods and Limits Report for Hatch Units 1 & 2 5

AMS Report FNP2303R0, OLM Drift Monitoring Program Report for Farley Units 1 & 2 6

AMS Report HAT2303R0, OLM Drift Monitoring Program Report for Hatch Units 1 & 2 7

AMS Procedure OLM2201, Procedure for Online Monitoring Data Retrieval, November 2022 Item #

Audit Item 8

AMS Procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis, November 2022 9

AMS Report FNP2304R0, OLM Noise Analysis Program Report for Farley Units 1 & 2 10 AMS Report HAT2304R0, OLM Noise Analysis Program Report for Hatch Units 1 & 2 11 AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors, March 2015 12 AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, November 2022 Review notes for each of the audited AMS reports and procedures are provided below.

FNP2301R0: OLM AMENABLE TRANSMITTERS REPORT FOR FARLEY UNITS 1 AND 2 This report documents the steps to initiate the online OLM implementation process for extending pressure, level, and flow transmitter calibration intervals at Farley Units 1 and 2 in accordance with Section 11.1.1 of TR AMS-TR 0720R2-A. More specifically, this report addresses Steps 1 through 6 of Section 11.1.1 of the TR AMS-TR-0720R2-A, for the transmitters in Farley Units 1 and 2 that are included in the OLM program.

HAT2301R0: OLM AMENABLE TRANSMITTERS REPORT FOR HATCH UNITS 1 AND 2 This report documents the steps to initiate the online OLM implementation process for extending pressure, level, and flow transmitter calibration intervals at Hatch Units 1 and 2 in accordance with Section 11.1.1 of TR AMS-TR 0720R2-A. More specifically, this report addresses Steps 1 through 6 of Section 11.1.1 of the TR AMS-TR-0720R2-A, for the transmitters in Hatch Units 1 and 2 that are included in the OLM program.

FNP2302R0: OLM ANALYSIS METHODS AND LIMITS REPORT FOR FARLEY UNITS 1 AND 2 This report addresses Steps 7 through 8 of Section 11.1.1 of the TR AMS-TR-0720R2-A for the transmitters in Farley Units 1 and 2 that are included in the OLM program.

HAT2302R0: OLM ANALYSIS METHODS AND LIMITS REPORT FOR HATCH UNITS 1 AND 2

This report addresses Steps 7 through 8 of Section 11.1.1 of the TR for the transmitters in Hatch Units 1 and 2 that are included in the OLM program.

FNP2303R0: OLM DRIFT MONITORING PROGRAM REPORT FOR FARLEY UNITS 1 AND 2 This document provides the steps that must be followed to implement OLM for transmitter drift monitoring in accordance with TR AMS-TR-0720R2-A at Farley Units 1 and 2. The steps described in the document are intended to be repeated at each operating cycle to identify the transmitters that should be scheduled for a calibration check.

Following the steps in this document will ensure that OLM data is properly acquired, qualified, analyzed, interpreted, reported, and documented.

HAT2303R0: OLM DRIFT MONITORING PROGRAM REPORT FOR HATCH UNITS 1 AND 2 This document provides the steps that must be followed to implement OLM for transmitter drift monitoring in accordance with TR AMS-TR-0720R2-A at Hatch Units 1 and 2. The steps described in the document are intended to be repeated at each operating cycle to identify the transmitters that should be scheduled for a calibration check.

Following the steps in this document will ensure that OLM data is properly acquired, qualified, analyzed, interpreted, reported, and documented.

OLM2201: PROCEDURE FOR PERFORMING ONLINE MONITORING DATA RETRIEVAL This is a test procedure for retrieving OLM data from the plant historian using the AMS Bridge software. It is not a Farley or Hatch specific document, so it does not describe any of the Farley or Hatch data archival systems. It provides general steps that are followed when retrieving OLM data.

OLM 2202: PROCEDURE FOR PERFORMING ONLINE MONITORING DATA QUALIFICATION AND ANALYSIS This document outlines the general steps that are followed when performing OLM data analysis.

It is not a Farley or Hatch specific document, so it does not describe any of the Farley or Hatch data archival systems or provide any actual analysis of Farley or Hatch specific data.

FNP2304R0: OLM NOISE ANALYSIS PROGRAM REPORT FOR FARLEY UNITS 1 AND 2 This document provides the steps that must be followed to implement noise analysis for assessment of transmitter dynamic failure modes. The steps described are to be repeated at each operating cycle at Farley Units 1 and 2 for a minimum of one transmitter on a staggered basis in each redundant group which has a response time requirements as outlined to identify its dynamic failure modes.

The steps outlined in this document ensure that proper noise analysis equipment is used, and data is properly acquired, qualified, analyzed, interpreted, reported, and documented.

HAT2304R0: OLM NOISE ANALYSIS PROGRAM REPORT FOR HATCH UNITS 1 AND 2 This document provides the steps that must be followed to implement noise analysis for assessment of transmitter dynamic failure modes. The steps described are to be repeated at each operating cycle at Hatch Units 1 and 2 for a minimum of one transmitter on a staggered basis in each redundant group which has a response time requirements as outlined to identify its dynamic failure modes.

The steps outlined in this document ensure that proper noise analysis equipment is used, and data is properly acquired, qualified, analyzed, interpreted, reported, and documented.

NPS1501: PROCEDURE FOR NOISE DATA COLLECTION FROM PLANT SENSORS This procedure provides guidelines for the collection of noise data to determine the dynamic performance characteristics of sensors and systems in nuclear power plants and other processes. This procedure is used for on-line data acquisition from a wide variety of sensors and systems while the plant is operating at any mode that provides adequate signal amplitudes for analysis. Since the noise tests are passive and do not normally create any disturbance to plant operation, the data acquisition is normally performed with the plant at steady state, gradual coast down, or during startup conditions. In addition, some sensors that are not normally subject to adequate signal amplitudes during normal plant operation may also be tested, if they can be removed from service and stimulated with adequate process signals.

NAR2201: PROCEDURE FOR PERFORMING DYNAMIC FAILURE MODE ASSESSMENT USING NOISE ANALYSIS This procedure provides general guidelines for performing dynamic failure mode assessment using the noise analysis method. It is not a Farley or Hatch specific document, so it does not provide any actual Farley or Hatch noise data or analyses results.

Package: ML24302A304 Audit Plan: ML24149A049 Audit Summary: ML24302A297 OFFICE NRR/DORL/LPLII-1/PM NRR/DORL/LPLII-1/LA NRR/DEX/EICB/BC NRR/DSS/STSB/BC NAME JMinzer Bryant KGoldstein FSacko SMehta DATE 10/28/2024 10/29/2024 11/12/2024 11/4/2024 OFFICE NRR/DORL/LPLII-1/(A)BC NRR/DORL/LPLII-1/PM NAME MMarkley (JKlos for)

JMinzer Bryant DATE 11/15/2024 11/15/2024