ML041890282
| ML041890282 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 08/09/2004 |
| From: | David Beaulieu NRC/NRR/DLPM/LPD3 |
| To: | Peifer M Nuclear Management Co |
| anm1 | |
| References | |
| TAC MC3650 | |
| Download: ML041890282 (12) | |
Text
August 9, 2004 Mark A. Peifer Site Vice President Duane Arnold Energy Center Nuclear Management Company, LLC 3277 DAEC Road Palo, IA 52324-0351
SUBJECT:
DUANE ARNOLD ENERGY CENTER - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC3650)
Dear Mr. Peifer:
On May 27, 2003, the U.S. Nuclear Regulatory Commission (NRC) Office of Nuclear Reactor Regulation published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. Office Instruction LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML022750041), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by licensees for commercial nuclear reactors to the NRC staff. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI), NEI 99-04, Guidance for Managing NRC Commitment Changes.
Office Instruction LIC-105 specifies that the NRC staff will audit the licensees commitment management program once every 3 years.
An audit of Duane Arnold Energy Center's (DAEC's) commitment management program was performed on site on June 21 through 25, 2004. Based on the results of this audit, the NRC staff concluded that (1) DAEC properly tracked and implemented regulatory commitments, and (2) DAEC implemented an effective program to manage regulatory commitment changes.
Details of the audit are provided in the enclosed audit report.
Sincerely,
/RA/
David P. Beaulieu, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-331
Enclosure:
Audit Report
cc w/encl: See next page
ML041890282 OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/SC NAME DBeaulieu THarris LRaghavan DATE 08/09/04 07/09/04 08/09/04 Duane Arnold Energy Center cc:
Mr. John Paul Cowan Daniel McGhee Executive Vice President & Utilities Division Chief Nuclear Officer Iowa Department of Commerce Nuclear Management Company, LLC Lucas Office Buildings, 5th floor 700 First Street Des Moines, IA 50319 Hudson, MI 54016 Chairman, Linn County John Bjorseth Board of Supervisors Plant Manager 930 1st Street SW Duane Arnold Energy Center Cedar Rapids, IA 52404 3277 DAEC Road Palo, IA 52324 Craig G. Anderson Senior Vice President, Group Operations Steven R. Catron 700 First Street Manager, Regulatory Affairs Hudson, WI 54016 Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U. S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1 Palo, IA 52324 Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Jonathan Rogoff Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Bruce Lacy Nuclear Asset Manager Alliant Energy/Interstate Power and Light Company 3277 DAEC Road Palo, IA 52324
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION DUANE ARNOLD ENERGY CENTER DOCKET NO. 50-331
1.0 INTRODUCTION AND BACKGROUND
On May 27, 2003, the U.S. Nuclear Regulatory Commission (NRC) Office of Nuclear Reactor Regulation published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. Office Instruction LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML022750041), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by licensees for commercial nuclear reactors to the NRC staff. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI), NEI 99-04, Guidance for Managing NRC Commitment Changes.
Office Instruction LIC-105 defines regulatory commitment as an explicit statement to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC. Office Instruction LIC-105 further directs the Nuclear Reactor Regulation Project Manager to audit the licensees commitment management program by assessing the adequacy of the licensees implementation of a sample of commitments made to the NRC in past licensing actions (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters, etc.). The audit is to be performed every 3 years.
2.0 AUDIT PROCEDURE AND RESULTS An audit of Duane Arnold Energy Center's (DAEC's) commitment management program was performed on site on June 21 through 25, 2004. This audit consisted of two major parts: (1) verification of the licensees implementation of NRC commitments, and (2) verification of the licensees programs for managing NRC commitment changes.
2.1 Verification of Licensees Implementation of NRC Commitments 2.1.1 Audit Scope The NRC staff reviewed sample of the licensee's commitments that were approved by the NRC to justify a licensing action (amendment, exemption, etc.) or resolve a licensing activity (bulletin, generic letter, etc.) to evaluate whether the commitments were implemented in a manner that satisfied both the action committed to and the overall intent of the commitment. For commitments that had not yet been implemented, the NRC staff evaluated whether these commitments were being effectively tracked for future implementation by the committed schedule. The NRC staff searched ADAMS for past licensing actions/activities and evaluated
whether the licensee entered associated commitments into their tracking database. The NRC staff evaluated the licensee's implementation of specific regulatory commitments by reviewing licensee commitment management records, work orders, revised procedures, design documents, surveillance histories, and other documentation that could demonstrate that the specific actions were completed in accordance with the stated commitment and schedule. In addition, the NRC staff interviewed cognizant licensee engineering and licensing personnel as necessary to confirm implementation. Each commitment was also evaluated to determine whether the commitment was captured, as appropriate, in an update to the Updated Final Safety Analysis Report.
2.1.2 Audit Results The specific commitments that were audited are as follows:
Docketed Regulatory Commitments as Stated in Licensee Audit Results -
Correspondence Submittal Verification of Implementation Status DAEC Submittal 1. Nuclear Management Company (NMC) has verified Commitments are January 30, 2004 that a hydrogen monitoring system capable of being appropriately ML040420424 diagnosing beyond design-basis accidents is installed tracked (CAP032070)
at each facility and is making a regulatory commitment for completion by the NRC Issuance to maintain that capability. The hydrogen monitors will committed date of Amendment 254 be included in the Technical Requirements Manual. October 15, 2004.
June 10, 2004 This regulatory commitment will be implemented by the ML041480049 implementation date.
- 2. NMC has verified that an oxygen monitoring system capable of verifying the status of the inerted containment is installed and is making a regulatory commitment to maintain that capability. The oxygen monitors will be included in the Technical Requirements Manual. This regulatory commitment will be implemented by the implementation date.
DAEC Submittal 1. As part of implementation of this license Complete March 23, 2004 amendment, NMC will revise the guidelines for the ML010870296 assessment of systems removed from service during Outage Risk
handling of irradiated fuel assemblies or Core Management NRC Issuance Alterations at DAEC to implement the provisions of Guideline OMG-7 Amendment 240 Section 11.3.6.5 of NUMARC 93-01, Rev. 3. changed as specified.
July 31, 2001 2. The design calculations using the Brockman-Bixler ML011660142 pipe deposition model will be updated to only credit Design calculation horizontal runs of piping in the next revision of these performed as calculations used to support a DAEC licensing action. specified.
Docketed Regulatory Commitments as Stated in Licensee Audit Results -
Correspondence Submittal Verification of Implementation Status DAEC Submittal If there is an unplanned shutdown with a drywell entry Complete March 12, 2004 before the next refueling outage (currently scheduled to ML040850127 begin in March 2005), another inspection of this Item added as a
mechanical joint will be performed to look for any Startup issue to the NRC Issuance evidence of leakage. pre-RFO 19 schedule.
Relief Authorization April 13, 2004 ML040930429 DAEC Submittal 1. NMC will develop contingency plans for obtaining Complete May 30, 2003 and analyzing highly radioactive samples from the ML031611045 reactor coolant system, the suppression pool, and the Post Accident containment atmosphere. The contingency plans will Sampling and Analysis
be contained in the plant technical procedures and Procedures, as well NRC Issuance implementation will be completed within the 180-day as, the Emergency Amendment 252 implementation period for the Amendment when Plan and implementing August 8, 2003 approved. Establishment and maintenance of procedures, were ML031750871 contingency plans are considered a regulatory revised.
commitment.
- 2. The capability for classifying fuel damage events at See further the Alert level threshold will be established for DAEC at discussion of the radioactivity levels of 300 µCi/gm dose equivalent item below.
iodine. This capability will be described in the emergency plan implementing procedures and implementation will be completed within the 180-day implementation period for the Amendment when approved. The capability for classifying fuel damage events is considered a regulatory commitment.
- 3. The NMC has developed an I-131 site survey detection capability, including an ability to assess radioactive iodines released to offsite environs by using effluent monitoring systems or portable sampling equipment. The capability for monitoring iodines is maintained within the emergency plan implementing procedures. The capability to monitor radioactive iodines is considered a regulatory commitment.
Implementation of this commitment is complete.
Docketed Regulatory Commitments as Stated in Licensee Audit Results -
Correspondence Submittal Verification of Implementation Status DAEC Submittal For the duration of this temporary TS allowance, NMC Complete April 15, 2003 commits to not moving irradiated fuel assemblies (or ML031150414 portions thereof) within the secondary containment Plant Manager issued
except as part of performing/supporting Core Special Order 03-01 NRC Issuance Alterations in Mode 5 (Refuel). directing plant Amendment 250 personnel as stated in April 16, 2003 commitment.
ML031070087 DAEC Submittal Single-Failure Proof Reactor Building Crane - Complete March 11, 2003 Commitment to comply with NUREG-0612.
Commitment reflected NRC Issuance in Updated Safety Amendment 243 Analysis Report, Section 9.1.4.4.3, and procedure ACP 1408.09, Control of Heavy Loads.
DAEC Submittal Perform generator load reject and main steam isolation A subsequent DAEC June 6, 2001 valve closure transient tests required by the Extended submittal dated Oct.
Power Uprate Topical Report. 17, 2001, incorporated commitment as a license condition.
DAEC Submittal DAEC will use Code Case N-S 16-1 in its entirety with Complete May 1, 2001 the following added limitation:
ML011280096 When welding is to be performed on high neutron DAEC Third Interval
fluence Class 1 material, then a mockup, using material Inservice Inspection NRC Issuance with similar fluence levels, should be welded to verily Plan modified to Relief that adequate crack prevention measures were used. reflect commitment.
Authorization May 7, 2001 ML011280097
Docketed Regulatory Commitments as Stated in Licensee Audit Results -
Correspondence Submittal Verification of Implementation Status DAEC Submittal Written procedures will be available describing Complete April 26, 2000 compensatory measures to be taken in the event of an ML003710814 intentional or unintentional entry into Technical Surveillance test
Specification 3.7.4 Condition B. As part of this procedure NRC Issuance commitment, the following compensatory measures are appropriately revised.
Amendment 233 being added to procedures:
August 11, 2000 a. Verify self-contained breathing apparatus equipment ML0037411440 is available for the operating crew to use if determined necessary by the Operations Shift Supervisor in the unlikely event a hazardous environment arises.
- b. Notify Security Department of any impairment affecting security access control.
- c. If an impairment exists that precludes maintaining acceptable temperature and humidity in the control room, verify that Technical Specification Condition 3.7.5.D has been entered for inoperable Control Building chillers.
- d. If an impairment exists that affects fire protection features, verify that applicable requirements of the Fire Plan have been implemented.
DAEC Submittal The Corrective Action Program is capable of trending Complete April 12, 1999 excess flow check valves (EFCV) test failures and ML003672739 determining whether additional testing is warranted. Maintenance Rule
Additionally, we have revised our 10 CFR 50.65 Performance Criteria NRC Issuance Maintenance Rule Performance Criteria to ensure changed as stated.
Amendment 230 EFCV performance remains consistent with the EFCV failures December 29, extended test interval. The new performance criterion appropriately identified 1999 is less than or equal to 1 failure per year on a 3 year and trended.
ML003672720 rolling average.
NRC Issuance DAEC commitment to establish a Flow Accelerated Verified Licensee NRC Generic Corrosion Program. established a Flow Letter 89-08, Accelerated Program.
Erosion/ Licensee corrective Corrosion actions for three Inducted Pipe though-wall leaks were Wall Thinning reviewed and found acceptable.
The NRC staff found that all the above commitments were captured in the licensees database and that each commitment was implemented as specified or was being appropriately tracked for completion by committed schedule. In addition, the NRC staff found that revised procedures were properly annotated as necessary to refer to commitments.
Notwithstanding, the NRC staff noted one instance in which although the licensee satisfied the specific wording of the commitment (and therefore no violation or deviation from NRC requirements occurred), the NRC staff discussed with the licensee whether the intent of the commitment was fully satisfied. Specifically, as described above, the licensee's letter dated May 30, 2003, includes a commitment that "NMC will develop contingency plans for obtaining and analyzing highly radioactive samples from the reactor coolant system, the suppression pool, and the containment atmosphere." The NRC staff evaluated the licensee's implementation of this commitment and noted that, DAEC Post Accident Sampling Procedure 2.7, "Contingency Reactor Coolant Sampling," Paragraph 2.1 (3), states, "Warning: exposure rates may be 200 Rem/hour or higher in sample sink vicinity during certain post-accident conditions." Similarly, DAEC Post-Accident Sampling Procedure 2.8, "Contingency Torus Water Sampling," Paragraph 2.2 (2) states "Warning: exposure rates may prohibit entry during certain post accident conditions." The NRC Safety Evaluation for this amendment stated, "the NRC staff has found that licensees could satisfy this function by developing contingency plans to describe existing sampling capabilities and what actions (e.g., assembling temporary shielding) may be necessary to obtain and analyze highly radioactive samples from the reactor coolant system, suppression pool, and containment atmosphere." The NRC staff noted that while DAEC's contingency plans reflect exposure rates that would too high to make sampling feasible, they had not evaluated whether the exposure rates would also be too high to allow temporary shielding to be installed. The NRC discussed this concern with the licensee who entered the issue into their corrective action program as Action Request OTH001686.
2.2 Verification of the Licensees Program for Managing NRC Commitment Changes 2.2.1 Audit Scope The NRC staff evaluated whether the licensee appropriately established and implemented controls for modifying or deleting commitments made to the NRC by reviewing the following:
" Change Control Procedure Verification --The NRC staff reviewed the licensee's commitment change control procedure to identify and evaluate any differences between the licensee's process and NEI 99-04, "Guidelines for Managing NRC Commitment Changes," which the NRC has reviewed and found acceptable. In particular, the NRC staff evaluated whether the licensee's procedure provided guidance for evaluating proposed commitment changes in terms of safety and regulatory significance and whether criteria were specified for determining when it would be appropriate to notify the NRC of the change.
" Procedure Implementation Assessment -- Licensee implementation of their commitment change process was assessed by selecting a sample of commitment changes to verify the changes were evaluated in accordance with their established procedure, that the licensees technical evaluations adequately justified the change, and that the NRC was informed of commitment changes which had safety or regulatory significance. The NRC
staff also evaluated the licensee's administrative controls for maintaining commitment "traceability" (e.g., markings or notations within procedures) to ensure that licensee personnel are able to recognize that future changes to the affected design features or operating practices require evaluation of the proposed change in accordance with the commitment change control process.
The NRC staff also evaluated the licensee's administrative controls for maintaining commitment "traceability" (e.g., markings or notations within procedures) to ensure that licensee personnel are able to recognize that future changes to the affected design features or operating practices require evaluation of the proposed change in accordance with the commitment change control process.
2.2.2 Audit Results The NRC staff evaluated DAEC Administrative Control Procedure (ACP) 102.2, "Procedure for Evaluation of NRC Commitment Changes," Revision 7, against NEI 99-04, "Guidelines for Managing NRC Commitment Changes," which the NRC has reviewed and found acceptable.
The NRC staff noted that DAEC procedure ACP 102.2, specifies that when the need for a commitment change arises, an Action Request is written to initiate the preparation of an NRC Commitment Change Evaluation Form which provides a series of questions to justify the change. The NRC staff noted that series of questions listed in DAEC's form align with the series of questions provided in NEI 99-04. After the NRC Commitment Change Evaluation Form is reviewed and approved by the Responsible Manager, Licensing Engineer, and Licensing Manager, the completed form is retained by Licensing for incorporation, as needed, into the periodic 10 CFR 50.59 report to the NRC. DAEC procedure ACP 102.2 specifies that these forms be maintained as a lifetime quality assurance record.
The NRC staff found that, DAEC procedure ACP 102.2, closely follows the guidance of procedure NEI 99-04 in that it establishes the need for identifying, tracking and reporting commitments, and it provides an acceptable mechanism for changing commitments.
Additionally, the effectiveness of a procedure can be indicated by the products that are produced by the procedure. As described in Section 2.1 above, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit and that commitment "traceability" was properly maintained.
The specific commitment changes that were audited are as follows:
- DAEC Commitment Original Revised Reason for Change NRC Submittal Date Commitment Commitment Informed?
- Commitment Description Description Change No.
- Commitment Tracking System No.
- DAEC Submittal Perform PT (dye- Delete commitment Not required by Yes Nov. 21, 1986 penetrant) exam of NUREG 0619, "BWR DAEC Letter
the control rod drive Feedwater Nozzle May 15, 1997
- C96-010 return nozzle once and Control Rod Drive every 4 cycles. Return Line Nozzle Cracking."
- DAEC Submittal Per NUREG 0619, UT Inspect 2 1/2 feet of Clarification of Yes Nov. 21, 1986 & control rod drive stainless steel control commitment DAEC Letter Dec. 16, 1986 piping every refueling rod drive return line Nov. 19, 1998
outage. (containing stagnant
- AR 971798.00 water) in accordance New 9217 with NUREG 0313,
rev.1, "Technical
- 86121601 & Report on Material 86112103 Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping."
- DAEC Submittal Provide 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of Provide a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> minimum is Yes Aug. 25, 1992 simulator training per 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of simulator per INPO 86-025, and DAEC Letter
year for licensed training per year for will allow for better Oct. 20, 2003
- AR 28099 operator licensed operator quality training.
requalification requalification
- 9008250102
- DAEC Submittal All shift technical All STAs must Allow STA candidate Yes May 14, 1986 advisors (STAs) must complete an STA to concentrate on DAEC Letter
complete a 42 week training course. integrated plant Oct. 20, 2003
- AR 28100 hot license training knowledge rather than
course. operator skills (panel
- 8605140101 skills).
- DAEC Commitment Original Revised Reason for Change NRC Submittal Date Commitment Commitment Informed?
- Commitment Description Description Change No.
- Commitment Tracking System No.
- DAEC Submittal Accelerated testing Delete provision for NRC Generic Letter Yes June 15, 1992 provision for station accelerated testing. 94-01, "Removal of DAEC Letter
blackout diesel Accelerated Testing Nov. 19, 1998
- AR 972471.00 generators. and Special Reporting New 9940 Requirements for
Emergency Diesel
- 9206150105 Generators," allows deletion due to Maintenance Rule.
- DAEC Submittal Inspect condensate Eliminate the required The inspections No NRC July 27, 1976 storage tank (CST) inspection performed over the notification
level element probes last 15 years have required.
- OTH025760 every 4 years. found no indication of
algae growing on the
- 7607270201 probes. Also the surveillance test procedure performed quarterly to functionally check the CST level (low) instrumentation will indicate problems with the probes from algae or cable degradation.
- DAEC Commitment Original Revised Reason for Change NRC Submittal Date Commitment Commitment Informed?
- Commitment Description Description Change No.
- Commitment Tracking System No.
- DAEC Submittal Require the Require comparisons A favorable No NRC June 29, 1990 preparation of of current reference comparison, notification
comparisons of values to original performed by the required.
- AR 14671 current reference pump curves for inservice test
values to original ASME program engineer indicates the
- 199006290508 pump curves for pumps before pump is in good ASME program accepting the condition and pumps and require a reference value. reasonably conforms yearly comparison of to the manufacturers current pump design and test data.
performance to the This is a good original pump curves practice activity and for ASME program has no ASME nor pumps. code compliance aspect. Yearly trending by the System Engineer is not necessary.
3.0 CONCLUSION
The NRC staff concluded that based on the above audit (1) the licensee properly tracked and implemented regulatory commitments, and (2) the licensee implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT S. Catron C. Rushworth T. Browning D. Barta Principal Contributor: D. P. Beaulieu