IR 05000348/2024010

NRC Inspection Report 05000348/2024010 and 05000364/2024010

ML24101A203
Person / Time
Site:	Farley
Issue date:	04/16/2024
From:	Daniel Bacon NRC/RGN-II/DRS/EB2
To:	Coleman J Southern Nuclear Operating Co
References
IR 2024010
Download: ML24101A203 (9)

Text

SUBJECT:

JOSEPH M. FARLEY - NRC INSPECTION REPORT 05000348/2024010 AND 05000364/2024010

Dear Jamie M. Coleman:

On March 21, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Joseph M. Farley. On March 20, 2024, the NRC inspectors discussed the results of this inspection with Gene Surber and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Daniel M. Bacon, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 05000348 and 05000364 License Nos. NPF-2 and NPF-8

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000348 and 05000364 License Numbers:

NPF-2 and NPF-8 Report Numbers:

05000348/2024010 and 05000364/2024010 Enterprise Identifier:

I-2024-010-0022 Licensee:

Southern Nuclear Operating Company, Inc.

Facility:

Joseph M. Farley Location:

Columbia, AL Inspection Dates:

January 22, 2024 to February 09, 2024 Inspectors:

P. Braaten, Senior Reactor Inspector P. Meier, Senior Resident Inspector J. Montgomery, Senior Reactor Inspector A. Rosebrook, Senior Reactor Analyst Approved By:

Daniel M. Bacon, Chief Engineering Branch 2 Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC inspection at Joseph M. Farley, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000348,05000364/20 24010-01 Multiple Components Associated With HSS Systems Re-Categorized to LSS based on Defense-In-Depth or Manual Actions 37060 Open

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 37060 - 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components Inspection The inspectors reviewed the licensees program and implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors, in accordance with the following procedure sections. Section 02.04 was not completed during this inspection because the feedback and process adjustment required by 10 CFR 50.69(e) was not implemented by the licensee. As of the date of this inspection, two refueling outages have not occurred since system categorization was completed on at least three systems.

Review of the Licensees Programs and Procedures (IP Section 02.01) (1 Partial)

(1)

(Partial)

The team reviewed the licensees programs and procedures to ensure that the procedures fully described the categorization and treatment process for SSCs as described in its UFSAR and as required by 10 CFR 50.69.

Review of the Licensees 10 CFR 50.69 Program Implementation (IP Section 02.02) (1 Partial)

(1)

(Partial)

The team reviewed the licensee's 10 CFR 50.69 categorization process and alternate treatment requirements completed on the following systems:

• Chemical Volume & Control/Safety Injection

• Emergency Diesel Generators

• Main Feedwater

• Main Steam

• Containment Spray Problem Identification and Resolution (IP Section 02.03) (1 Partial)

(1)

(Partial)

For the systems listed above, the inspectors reviewed the licensees corrective action program to verify that conditions that would prevent RISC-3 SSCs from performing their safety-related function have been corrected. Additionally, the inspector verified that, as appropriate, the licensee performed common cause reviews for RISC-3 SSC deficiencies to ensure that the licensees SSC categorization process remains valid.

INSPECTION RESULTS

Unresolved Item (Open)

Multiple Components Associated With HSS Systems Re-Categorized to LSS based on Defense-In-Depth or Manual Actions URI 05000348,05000364/2024010-01 37060

Description:

On June 30, 2021, the NRC approved Farley Nuclear Plant (FNP) License Amendments 233 and 230 (ML21137A247) which allows the implementation of 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors. In its license amendment request, FNP stated that they will implement the risk categorization process in accordance with NEI 00-04, Revision 0, as endorsed by Regulatory Guide (RG) 1.201, "Guidelines for Categorizing Structures, Systems, and Components in Nuclear Power Plants According to their Safety Significance".

The categorization of structures, systems, and components (SSCs) is governed by fleet procedure NMP-ES-065-003, 10 CFR 50.69 Risk Informed Categorization for Structures, Systems, and Components.

The NEI 00-04 categorization process yields components that are preliminarily screened as high-safety-significant (HSS) or low-safety-significant (LSS). Some preliminary HSS components can be downgraded via Detailed Categorization. This process is described in Section 10.2 of NEI 00-04. This part of the process is optional and is implemented based on the anticipated benefit of performing additional analyses to support downgrading a component.

The licensees categorization of the Chemical Volume and Control (CVCS) system was approved on July 26, 2023. The licensee's categorization of the Emergency Diesel Generators (EDGs) was approved on September 19, 2022. The results of these categorization processes yielded multiple components that were identified as preliminary HSS, and these components were subsequently re-categorized to LSS based on defense-in-depth and/or the ability to take manual actions to ensure the components are placed in their credited states to support the function.

Section 10.2 of NEI 00-04 states that the criterion for categorizing as LSS a component that supports an HSS function is that its failure would not preclude the fulfillment of the safety-significant function. Section 10.2 goes on to provide examples of considerations for meeting the aforementioned criterion:

• There is no credible failure mode for the SSC that would prevent a safety-significant function from being fulfilled (e.g., a locked open or locked closed valve, a manually controlled valve, etc.),

• A failure for the SSC would not prevent a safety-significant function from being fulfilled (e.g., a vent or drain line that is not a significant flow diversion path, SSCs downstream of the first isolation valve from the active pathway of the function, etc.),

and

• Instrumentation that would not prevent a safety-significant function from being fulfilled (e.g., radiation monitors that do not have a direct diagnosis function, etc.)

Planned Closure Actions: More information is needed to determine whether the licensee is allowed to credit defense-in-depth as a sole basis to say that failure of a component would not preclude the fulfillment of a safety-significant function, to address the optional detailed categorization portion of the NEI 00-04 classification process. Additionally, if defense-in-depth can be credited in this way, more information is needed to verify that the licensee completed all necessary sensitivity studies and subsequent defense-in-depth reviews associated with the re-classified components.

Corrective Action References: The licensee entered this issue of concern into their corrective action program as

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On March 20, 2024, the inspectors presented the NRC inspection results to Gene Surber and other members of the licensee staff.

• On February 8, 2024, the inspectors presented the initial exit inspection results to Edwin D. Dean III (Sonny) and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

F-RIE-FIREPRA-

U00-014

Fire Probabilistic Risk Assessment Quantification and

Summary Report

Version 5.0

Calculations

F-RIE-OEE-U00

Evaluation of Other External Hazards

Version 1

PMCR 104132

Per NMP-ES-065, UFSAR Chapter 13.8 and 10 CFR50.69,

RISC-3 SSCs of Categorized Systems can be exempted

from the IST program. This PMCR approves the removal of

these RISC-3 SSCs from IST required PMs and defines the

Alternative Treatment (AT) for the associated Tests and/or

Inspections

11/12/2022

PMCR 104133

Per NMP-ES-065, UFSAR Chapter 13.8 and 10 CFR50.69,

RISC-3 SSCs of Categorized Systems can be exempted

from the 50.49 (EQ) program. This PMCR approves the

removal of these RISC-3 SSCs from EQ required PMs and

defines the Alternative Treatment (AT) for the associated

Tests and/or Inspections.

11/11/2022

PMCR 106768

Updates Alternative Treatment in PMCR 104179

01/16/2024

RBD-FNP-5069-

E13

CFR 50.69 System Categorization - Containment Spray

Revision 3

RBD-FNP-5069-

E21

CFR 50.69 System Categorization - Chemical & Volume

Control/Safety Injection

Revision 1

RBD-FNP-5069-

N11

CFR 50.69 System Categorization - Main Steam

Revision 1

RBD-FNP-5069-

N21

CFR 50.69 System Categorization - Main Feedwater

Revision 2

Engineering

Evaluations

RBD-FNP-5069-

R43, Y52, and

P21

CFR 50.69 System Categorization - Emergency Diesel

Generators

Revision 1

Joseph M. Farley Nuclear Plant - Units 1 and 2 - Application

to Adopt 10 CFR 50.69, "Risk-informed categorization and

treatment of structures, systems and components for nuclear

power reactors"

06/18/2020

37060

Miscellaneous

JOSEPH

M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2,

06/30/2021

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

ISSUANCE OF AMENDMENT NO

S. 233 AND 230, TO

ADOPT 10 CFR 50.69, RISK-INFORMED

CATEGORIZATION AND TREATMENT OF STRUCTURES,

SYSTEMS AND COMPONENTS FOR NUCLEAR POWER

REACTORS

EPRI

3002017583

Alternative Approaches for Addressing Seismic Risk in 10 CFR 50.69 Risk-Informed Categorization

February

20

NEI 00-04

CFR 50.69 SSC Categorization Guideline

Revision 0

NEI 16-09

Risk-Informed Engineering Programs (10 CFR 50.69)

Implementation Guidance

Revision 1

NEI 17-05

RISK INFORMED ENGINEERING PROGRAMS (10 CFR 50.69): RISC-3 ALTERNATIVE TREATMENTS

Revision 0

PWROG-19014-

NP

CFR 50.69: NEI 00-04 Sole Means Categorization

Interpretations

Revision 0

RG 1.201

GUIDELINES FOR CATEGORIZING STRUCTURES,

SYSTEMS, AND COMPONENTS IN NUCLEAR POWER

PLANTS ACCORDING TO THEIR SAFETY SIGNIFICANCE

Revision 1

TP18-2-392

50.69 Working Group Committee - Categorization Focus

Group - Detailed Structures Systems and Components

(SSCs) Categorization for 10CFR50.69

Revision 0

NMP-ES-065

CFR 50.69 Program

Version 6.0

NMP-ES-065-001

CFR 50.69 PRA Component Risk Significance Insights

Version 7.0

NMP-ES-065-002

CFR 50.69 Passive Component Categorization

Version 5.0

NMP-ES-065-003

CFR 50.69 Risk Informed Categorization for Structures,

Systems, and Components

Version 9.0

NMP-ES-065-004

CFR 50.69 Treatment Requirements

Version 7.0

Procedures

NMP-ES-065-005

Integrated Decision-Making Panel for Risk Informed SSC

Categorization Duties and Responsibilities

Version 5.0