NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal

Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal

ML23223A139
Person / Time
Site:	Hatch, Vogtle, Farley, 07200042, 07200036, 07201039, 07100333, 07100521, 07100726
Issue date:	08/11/2023
From:	Joyce R Southern Nuclear Operating Co
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-23-0658
Download: ML23223A139 (1)

Text

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5000 tel August 11, 2023 Docket Nos.: 50-321 50-348 50-424 NL-23-0658 50-366 50-364 50-425 71-521 71-333 71-726 72-036 72-042 72-1039 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Joseph M. Farley Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Response to Request for Additional Information Regarding Southern Nuclear Operating Companys Quality Assurance Topical Report Submittal Ladies and Gentlemen:

By letter dated June 15, 2023, Southern Nuclear Operating Company (SNC) submitted Version 26.0 of the SNC Quality Assurance Topical Report (QATR) for the Edwin I. Hatch Nuclear Plant, the Joseph M. Farley Nuclear Plant, and the Vogtle Electric Generating Plant (Enclosure 1) to the NRC. By email dated July 17, 2023 [ML23198A155], the NRC staff transmitted a request for additional information (RAI) regarding SNCs QATR submittal. The Enclosure to this letter repeats the RAI and provides SNCs response to the RAI.

This letter contains no regulatory commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.

Respectfully submitted, Ryan M. Joyce Licensing Manager RMJ/agq/cbg

Enclosure:

SNC Response to Request for Additional Information

U. S. Nuclear Regulatory Commission NL-23-0658 Page 2 cc: Regional Administrator, Region ll NRR Project Manager - Farley, Hatch, Vogtle 1 & 2 Senior Resident Inspector - Farley, Hatch, Vogtle 1 & 2 RType: CGA02.001

Edwin I. Hatch Nuclear Plant - Units 1 and 2 Joseph M. Farley Nuclear Plant - Units 1 and 2 Vogtle Electric Generating Plant - Units 1 and 2 Response to Request for Additional Information Regarding Southern Nuclear Operating Companys Quality Assurance Topical Report Submittal Enclosure to NL-23-0658 SNC Response to Request for Additional Information

Enclosure to NL-23-0658 SNC Response to Request for Additional Information NRC 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.

Page 1 of 4

Enclosure to NL-23-0658 SNC Response to Request for Additional Information 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.

Page 2 of 4

Enclosure to NL-23-0658 SNC Response to Request for Additional Information SNC RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION (RAI)

The QATR was revised from version 23 to version 24 when adopting the extended audit frequencies described in the NRC safety evaluation report (SER) to Exelon dated November 5, 2020 (ML20287A130). The evaluation of the change to adopt the extended audit frequencies credited §50.54(a)(3)(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 licensee's facility;.

The bases cited by the NRC in the Exelon SER are as follows:

10 CFR 50.34(b)(6)(ii) - equivalent bases apply to SNC 10 CFR 50.54(a) - equivalent bases apply to SNC 10 CFR 50 Appendix B, Criterion XVII Audits - equivalent bases apply to SNC 10 CFR 72 Subpart G Quality Assurance - equivalent bases apply to SNC NQA-1-1994 Quality Assurance Program for Nuclear Facilities - equivalent bases apply to SNC Exelon committed to performing an annual evaluation of each audit area that is being extended beyond a 24-month audit frequency; a similar process was integrated into the NOS implementing procedure for audit planning and scheduling.

All of the bases cited in the Exelon SER apply to SNC. Per 50.54(a)(3)(ii), this change did not represent a reduction in commitment.

SNCs QATR (current version 26) contains a discussion in Section 18.1 as to what conditions would cause an audit schedule change:

Audit schedule changes reflecting more frequent audits are required by one or more of the following conditions:

When significant changes are made in functional areas of the QAP, such as significant reorganization or procedure revisions.

When there is evidence that the performance or reliability of safety-related items is in jeopardy due to deficiencies or nonconformances in the QAP.

When a systematic, independent assessment of QAP effectiveness is necessary.

When it is necessary to verify implementation of required corrective actions.

These requirements have been present in the SNC QATR since version 1 following initial NRC approval, including in version 24 when SNC adopted Exelons SER for extended frequencies of some audit areas. Section 18.1 of the QATR meets the intent of NQA-1-1994 Supplement 18S-1 Supplementary Requirements for Audits, Section 2, Scheduling:

The audit schedule shall be reviewed periodically and revised as necessary to assure that coverage is maintained current. Regularly scheduled audits shall be supplemented by additional audits of specific subjects when necessary to provide adequate coverage.

The requirements above from Section 18.1 of the QATR are implemented in the NOS procedure for audit planning and scheduling. This implementing procedure was updated as part of the Page 3 of 4

Enclosure to NL-23-0658 SNC Response to Request for Additional Information adoption of Exelons extended audit frequencies. The procedure requirements include (in addition to the requirements of QATR Section 18.1 cited above):

NOS Management will ensure periodic (e.g., annually, anniversary reviews) evaluations are performed to determine the need for more frequent audit intervals:

For all audit areas with 24- and 36-month audit frequencies, a 12-month Anniversary Audit Evaluation SHALL be conducted.

The independent spent fuel storage installation audit frequency was also revised to 36 months in QATR version 25 and the NOS implementing procedure for audit planning and scheduling following a similar application of the Exelon SER as described above.

Note that SNC had a pre-existing audit area annual review process prior to the adoption of the Exelon extended audit frequencies explicitly following a process described in the NOS implementing procedure for audit planning and scheduling, utilizing criteria specified in the QATR. As discussed above, SNC revised the previous annual audit review process using the Exelon procedure as a model, while making some changes to better fit the SNC QA program established in the QATR; one aspect of this change was performing a comprehensive evaluation every 12 months rather than the Exelon model that performed different evaluations of varying complexity at 12 and 24 months. SNC titled the revised annual evaluation Anniversary reviews in order to distinguish from the previous effort, and to reflect that these were to be performed 12 months after the last audit, and 12 months after the last anniversary review, until the next audit is performed (assuming a 36-month audit frequency).

In conclusion, since its initial issuance, the SNC QATR has listed criteria to be considered for more frequent audits which has been present since the initial SNC QATR, and the NOS implementing procedure for audit planning and scheduling has described an annual audit review process. The NOS implementing procedure for audit planning and scheduling establishes the details and requirements of the anniversary audits, which are as stringent or more stringent than those described in the Exelon SER. Thus, SNCs change to a 36-month audit frequency for certain audit topics did not represent a reduction in commitment.

Page 4 of 4