ML26050A181

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Changes to the Quality Assurance Program and Transition Nuclear Development Quality Assurance Manual to the Quality Assurance Topical Report
ML26050A181
Person / Time
Site: Hatch, Vogtle, Farley  
(DPR-057, NPF-005, NPF-002, NPF-008, NPF-058, NPF-081)
Issue date: 02/25/2026
From: Markley M
Plant Licensing Branch II
To: Coleman J
Southern Nuclear Operating Co
Lamb J
References
EPID L-2025-LLQ-0002
Download: ML26050A181 (0)


Text

February 25, 2026 Ms. Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2; EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2; AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 - CHANGES TO THE QUALITY ASSURANCE PROGRAM AND TRANSITION NUCLEAR DEVELOPMENT QUALITY ASSURANCE MANUAL TO THE QUALITY ASSURANCE TOPICAL REPORT (EPID L-2025-LLQ-0002)

Dear Ms. Coleman:

By letter dated June 30, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25181A815), as supplemented by letter dated February 12, 2026 (ML26043A417), Southern Nuclear Operating Company (SNC) requested approval of proposed changes to the SNC Quality Assurance Topical Report (QATR) and transition the Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, Nuclear Development Quality Assurance Manual (NDQAM) to the QATR for Joseph M. Farley Nuclear Plant, Units 1 and 2, Edwin I. Hatch Nuclear Plant, Units 1 and 2, and Vogtle, Units 1, 2, 3, and 4. These proposed changes include a reduction in commitment requiring U.S. Nuclear Regulatory Commission (NRC) approval prior to implementation.

The NRC staff reviewed SNCs changes to its QATR, and as documented in the enclosed safety evaluation, finds that SNC will continue to comply with the criteria of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50. Therefore, the NRC staff concluded that the changes to the SNC QATR are acceptable.

J. Coleman If you have any questions, please contact John G. Lamb at (301) 415-3100 or by email at John.Lamb@nrc.gov.

Sincerely, Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321, 50-366, 50-348, 50-364 50-424, 50-425,52-025, and 52-026.

Enclosure:

Safety Evaluation cc: Listserv MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2026.02.25 12:07:19 -05'00'

ML26050A181 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DRO/IQVB/BC NAME JLamb KZeleznock DBollock DATE 02/18/2026 02/23/2026 02/23/2026 OFFICE NRR/DORL/LPL2-1/BC NAME MMarkley DATE 02/25/2026

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION QUALITY ASSURANCE TOPICAL REPORT AND NUCLEAR DEVELOPMENT QUALITY ASSURANCE MANUAL JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

DOCKET NOS. 50-348, 50-364, 50-321, 50-366, 50-424 50-425,52-025, AND 52-026

1.0 INTRODUCTION

By letter dated June 30, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25181A815), as supplemented by letter dated February 12, 2026 (ML26043A417), Southern Nuclear Operating Company (SNC, the licensee) requested approval of proposed changes to the SNC Quality Assurance Topical Report (QATR) and transition the Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, Nuclear Development Quality Assurance Manual (NDQAM) to the QATR for Joseph M. Farley Nuclear Plant (Farley), Units 1 and 2, Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2, and Vogtle, Units 1, 2, 3, and 4.

These proposed changes include 21 reductions in commitment (RIC) requiring U.S. Nuclear Regulatory Commission (NRC, the Commission) approval prior to implementation.

2.0 REGULATORY EVALUATION

The Commissions regulatory requirements related to Quality Assurance (QA) programs are set forth in the following regulations:

Appendix B to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, which establishes QA requirements for the design, manufacture, construction, and operation of structures, systems, and components (SSCs) that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The pertinent requirements of this appendix apply to all activities affecting the safety-related functions of those SSCs; these activities include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying for nuclear power plants and fuel reprocessing plants.

Regulation 10 CFR 50.34(b)(6)(ii) requires the final safety analysis report for a nuclear power plant to include information on the managerial and administrative controls that would ensure safe operation. The information on the controls shall also include a discussion on how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.

Regulation 10 CFR 50.54(a) requires each nuclear power plant licensee subject to the requirements of Appendix B to implement a QA program. Regulation 10 CFR 50.54(a)(4) sets forth the NRCs regulatory requirements regarding changes to a QA program description that are considered reduction in commitment. Changes to a QA program description that reduces the licensees commitments must be submitted to the NRC and receive approval prior to implementation. This includes changes made to the QA program description as presented in the safety analysis report or in a topical report that must be submitted as specified in 10 CFR 50.4.

Regulation 10 CFR 50.120 requires each nuclear power plant licensee to establish, implement, and maintain a training and qualification program that is derived from a systems approach to training as defined in 10 CFR 55.4, and must provide for the training and qualification of various categories of nuclear power plant personnel.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the information provided in the Quality Assurance Program Description (QAPD) against the QA requirements of Appendix B to 10 CFR Part 50, and in accordance with the review guidance in Standard Review Plan (SRP) Section 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, Revision 1.

In evaluating the adequacy of the SNC QAPD, Revision 28, the NRC staff utilized the guidance contained in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light water reactor] Edition, Standard Review Plan (SRP) 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, Revision 1 dated August 2015. SRP 17.5 provides guidance to the NRC staff for the review of a QAPD for Design Certification (DC), Early Site Permit, Combined License (COL), Construction Permit, and Operating License applications. SRP 17.5 is based on Appendix B to 10 CFR Part 50 and describes regulatory and industry guidance determined to be acceptable methods for meeting the requirements of Appendix B to 10 CFR Part 50.

In addition, the American Society of Mechanical Engineers (ASME) standard NQA-1-1994, Quality Assurance Requirements for Nuclear Facility Applications, upon which the SNC QAPD is based, is incorporated in 10 CFR Part 50.55a, Codes and Standards.

3.1 Elimination of Positions In RIC 1 and RIC 2, a list of positions is removed in Part II, Quality Assurance Program Details, Section 1, Organization, of the QATR, including senior manager positions for Operations, Maintenance, Radiation protection, Environmental and chemistry, Industrial safety,

Training, Engineering, Organizational effectiveness, Nuclear fuel, Central design engineering, Plant support engineering, Regulatory affairs director, Regulatory compliance, Licensing, Environmental, Security, and Emergency preparedness.

In addition, the Vice President - Site position is also eliminated in Subsection 1.2.1.1.1.1.1 of the QATR.

The NRC staff issued Request for Additional Information (RAI) Question 1 by email dated January 13, 2026 (ML26015A161), requesting SNC to clarify how the functions of these positions will still be accomplished after elimination of these positions. By letter dated February 12, 2026, SNC clarified that these positions will remain in the organization structure in its response to RAI Question 1. The description of their roles and responsibilities will be removed from the QATR and will be described in each departments Conduct of Operation procedure.

In addition, this proposed change will allow SNC to update roles and responsibilities of these positions via procedure revision versus revision of the licensing document for minor changes.

The responsibilities of the Vice President - Site, previously detailed under the Corporate Organization Section, are now provided in Section 1.3.1.2, Vice President - Site, under the Standard Plant Organization. The position itself remains in the QATR.

The NRC staff finds this acceptable on the basis that these positions will remain in organization structure and the responsibilities of the Vice President - Site remains in the QATR. In addition, the SNC QATR is committed to ASME, NQA-1-1994 and is one way of meeting the requirements of Appendix B to 10 CFR Part 50.

3.2 Nonconforming Materials In RIC 3 and RIC 4, a sentence in Part II, Section 15, Nonconforming Materials, Parts, or Components, of the QATR that states Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reports provided to the Vice President - site.

Significant trends are reported to the Vice President - site in accordance with SNC procedures, regulatory requirements, and industry standards. is deleted.

The NRC staff finds this acceptable on the basis that significant conditions adverse to quality and significant adverse trends are documented and reported to responsible management, as stated in Part II, Section 16, Corrective Action, Subsection 16.1.4 of the QATR. In addition, the SNC QATR is committed to ASME, NQA-1-1994 and is one way of meeting the requirements of Appendix B to 10 CFR Part 50.

3.3 Plant Review Board In RIC 6, RIC 7, RIC 8, RIC 9, RIC 11.a, and RIC 11.b, Appendix A, Plant Review Board of the QATR is deleted.

3.4 Surveillance In RIC 5 and 14, a sentence in Part II, Section 18, Audits of that QATR that states: In addition to audits, SNC commits to perform surveillances as described in Appendix C of this QATR. A sentence that states In addition in audits, SNC may also provide oversight with surveillances.

In addition, Appendix C, Quality Assurance Surveillances of the QATR is deleted.

The NRC staff finds this acceptable on the basis that SNC still performs audits in accordance with Part II, Section 18 of the QATR. In addition, the SNC QATR is committed to ASME, NQA 1994, which is incorporated in 10 CFR Part 50.55(a) Codes and Standards, and is one way of meeting the requirements of Appendix B to 10 CFR Part 50.

3.5 Commitment to American National Standards Institute (ANSI)/American Nuclear Society (ANS)-3.1-1993, Selection, Qualification, and Training of Personnel for Nuclear Power Plants, for PRB Members In RIC 12, the QATR removes the commitment to ANSI/ANS-3.1-1993 for Vogtle, Units 3 and 4, as it relates to technical knowledge and experience of PRB members.

The NRC staff finds this acceptable on the basis that the PRB chairman and members of the PRB possess technical knowledge and experience in the areas of nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, instrumentation and control, radiological safety, mechanical and electrical engineering, administrative controls and QA practices as stated in Part II, Section 2, Quality Assurance Program, Subsection 2.5.2.1 of the QATR. In addition, the proposed change is consistent with NEI 06-14A, which is endorsed in an NRC safety evaluation and ASME, NQA-1-1994.

3.6 Independent Review In RIC 13, Appendix B, Independent Review of the QATR is deleted.

The NRC staff finds this acceptable on the basis that independent reviews are still being conducted, as stated in Part II,Section II, Subsection 2.5.3 of the QATR. In addition, similar information deleted in Appendix B of the QATR, such as safe operation of the facility, resolving issues potentially affecting safe plant operation, and identification of performance trends, are still in Part II,Section II, Subsection 2.5.3 of the QATR.

3.7 Definition In RIC 15, Appendix D, Definition of the QATR is deleted.

The NRC staff considers the deletion of definitions to be an administrative change and is, therefore, acceptable.

3.8 Procedure In RIC 16, Appendix E, Procedures of the QATR is deleted. As stated in Part III, Regulatory Commitments, of the QATR, SNC commits to using Appendix A of RG 1.33, Quality Assurance Program Requirements (Operation), Revision 2, as a guidance to establish procedures.

The NRC staff finds this acceptable on the basis that SNC establishes procedures in accordance with Appendix A of RG 1.33, Revision 2.

3.9 Commitment to ANSI N18.7-1976/ANS-3.2, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, and RG 1.33, Revision 2 In RIC 17, Subsection 1.5.1 of Part III of the QATR states that SNC considers that the collective QA requirements of this QATR and the QA requirements of ASME NQA-1-1994 are equivalent to ANSI N18.7-1976/ANS-3.2 and RG 1.33, Revision 2. Consequently, SNC does not commit to ANSI N18.7-1976, or to RG1.33, except that Appendix A of Regulatory Guide 1.33 shall be used as guidance for establishing the procedures required for plant operational phase activities. This approach was approved in an NRC safety evaluation (ML071510506) dated June 21, 2007.

The NRC staff finds this acceptable on the basis that not committing to ANSI N 187.7-1976/ANS-3.2 and RG 1.33 Revision 2, was approved previously by the NRC.

In addition, the SNC QATR is committed to ASME, NQA-1-1994.

3.10 RIC 18 In RIC 18, upon implementation of the proposed change, the Vogtle, Units 3 and 4, the Quality Assurance Program (QAP) will still be audited consistently with the process used at Farley, Hatch, and Vogtle, Units 1 and 2, which utilizes the Nuclear Industry Evaluation Program (NIEP) to audit the QAPs for each utility every 36 months. See Part 11, Subsection 18.2.2 of the proposed QATR. Based on the above, the NRC staff finds this acceptable.

3.11 RIC 19 In RIC 19, upon implementation of the proposed change, the Vogtle, Units 3 and 4, the QAP will be audited consistently with the process used at Farley, Hatch, and Vogtle, Units 1 and 2, which utilizes the NIEP to audit the QAPs for each utility every 36 months.

The NRC staff finds this acceptable on the basis that the proposed change is approved in an NRC safety evaluation (ML071510506) dated June 21, 2007. Therefore, the proposed change is acceptable and satisfies the requirements of Appendix B to 10 CFR Part 50.

3.12 RIC 20 In RIC 20, the proposed QATR addresses nonconforming materials, parts, or components. This is similar to RIC No. 3 and 4 for Farley, Hatch, and Vogtle, Units 1 and 2.

The NRC staff finds this acceptable on the basis that Section 15, the proposed change of the QATR meets the standards in ANSI N18.7-1976/ANS-3.2 and ASME NOA-1-1994 related to dispositioning nonconformances for materials, parts, or components.

3.13 Reporting Program In RIC 21, Section 2.0 Reporting Program of Part II, Section 15, Nonconforming Materials, Parts, or Components is not included in the SNC QATR. This Section states:

SNC has appropriate interfaces between the NDQAP [Nuclear Development Quality Assurance Program] for identification and control of nonconforming materials, parts, or components and the non-QA Reporting Program to satisfy the requirements of 10 CFR 52, 10 CFR 50.55(e) and/or 10 CFR 21 during COL and construction and 10 CFR 21 during operations.

Subsection 4.1.2 of Part II, Section 4, Procurement Document Control, of the QATR retains similar reporting requirements.

The NRC staff finds this acceptable on the basis that similar reporting requirements are still in the QATR, and that the QATR is committed to ASME, NQA-1-1994.

3.14 QA Manager In the QATR, Part II, Quality Assurance Program Details, Section 1, Organization, there is not a position of a QA Manager. Subsection 1.3.1.1.3.1.1, Senior Manager Responsible for Nuclear Oversight, states that The senior manager responsible for nuclear oversight is responsible for SNC nuclear oversight activities using staffs located at corporate headquarters and at each of the operating plants. This includes ensuring implementation of the QA program in accordance with regulatory commitments.

The NRC staff issued RAI Question 3 in email dated January 13, 2026, requesting SNC to clarify if this position of Senior Manager Responsible for Nuclear Oversight is responsible for the implementation of the QAP.

By letter dated February 12, 2026, SNC stated that the Senior Manager responsible for nuclear oversight is accountable for implementing the QAP in its response to RAI Question 3. To minimize changes to the QATR as a licensing document, SNC uses the generic title Senior Manager to present the position at the top of a given organization. Section 1.3.1.1.3.1.1, Senior manager responsible for nuclear oversight describes the position responsible for SNC nuclear oversight activities using staffs located at corporate headquarters and at each of the operating plants. This includes ensuring implementation of the QA program in accordance with regulatory commitments. It further states, the senior manager responsible for nuclear oversight will have the authority and organizational freedom, including sufficient independence from cost and schedule to escalate matters directly to the Chief Nuclear Officer/Executive Vice President (CNO/EVP) if needed to ensure the quality concerns and/or nuclear safety considerations are addressed. While the title QA Manager is not used, the responsibilities are described and remain consistent with Appendix B requirements.

The NRC staff finds this acceptable on the basis that the proposed change is consistent with NEI 06-14A, Revision 7.

4.0 CONCLUSION

The SNC QATR delineates the policies, processes, and controls for QA requirements established by SNC. The SNC QATR provides for control of activities that affect the quality of safety-related SSCs and includes all planned and systematic activities necessary to provide adequate confidence that such SSCs will perform satisfactorily inservice.

The NRC staff used the acceptance criteria set forth in SRP Section 17.5 as the basis for evaluating the compliance of the SNC QATR, with the provisions of Appendix B to 10 CFR Part 50 and concludes that the SNC QATR satisfies the acceptance criteria in SRP Section 17.5. The NRC staff concludes the SNC QATR meets the requirements in Appendix B to 10 CFR Part 50 and is, therefore, acceptable.

Principal Contributor: Y. Law, NRR Date of Issuance: February 25, 2026