ML042290018
| ML042290018 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 08/13/2004 |
| From: | Macon W NRC/NRR/DLPM/LPD4 |
| To: | Parrish J Energy Northwest |
| Macon W, NRR/DLPM,415-3965 | |
| References | |
| NEI 99-04, TAC MC3456 | |
| Download: ML042290018 (11) | |
Text
August 13, 2004 Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968 SUBJECT COLUMBIA GENERATING STATION (CGS) - AUDIT OF THE MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC3456)
Dear Mr. Parrish:
On May 27, 2003, the Office of Nuclear Reactor Regulation Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]," was published. 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 No. 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." LIC-105 specifies that once every 3 years, the NRC staff will audit a licensees commitment management program.
An audit of Energy Northwest's commitment management program was performed on site on June 17, 2004. The NRC staff concludes that: (1) the licensee had implemented or is tracking for future implementation regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
William A. Macon, Jr., Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-397
Enclosure:
Audit Report cc w/encl: See next page
August 13, 2004 Mr. J. V. Parrish Chief Executive Officer Energy Northwest P.O. Box 968 (Mail Drop 1023)
Richland, WA 99352-0968 SUBJECT COLUMBIA GENERATING STATION (CGS) - AUDIT OF THE MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC3456)
Dear Mr. Parrish:
On May 27, 2003, the Office of Nuclear Reactor Regulation Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]," was published. 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 No. 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." LIC-105 specifies that once every 3 years, the NRC staff will audit a licensees commitment management program.
An audit of Energy Northwest's commitment management program was performed on site on June 17, 2004. The NRC staff concludes that: (1) the licensee had implemented or is tracking for future implementation regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
William A. Macon, Jr., Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-397 DISTRIBUTION:
PUBLIC
Enclosure:
Audit Report PDIV-2 Reading RidsNrrDlpmPdiv (HBerkow) cc w/encl: See next page RidsNrrPMWAMacon RidsNrrLAEPeyton RidsOGCRp RidsAcrsAcnwMailCenter ACCESSION NO.: ML042290018 Nrr-106 OFFICE PDIV-2/PM PDIV-2/LA PDIV-2/SC NAME WMacon EPeyton SDembek DATE 8/13/04 8/13/04 8/13/04 DOCUMENT NAME: C:\ORPCheckout\FileNET\ML042290018.wpd OFFICIAL RECORD COPY
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY ENERGY NORTHWEST TO THE NUCLEAR REGULATORY COMMISSION COLUMBIA GENERATING STATION DOCKET NO. 50-397
1.0 INTRODUCTION AND BACKGROUND
On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC," was published. 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 No. 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."
According to LIC-105, which cites the definition from NEI-99-04, a "regulatory commitment" is 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. LIC-105 further directs the NRR 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 three years.
2.0 AUDIT PROCEDURE AND RESULTS An audit of the Columbia Generating Station (CGS) commitment management program was performed on site on June 17, 2004. Copies of plant records were subsequently reviewed at NRC Headquarters to complete the audit. The audit consisted of two major parts: (1) verification of the licensees implementation of NRC commitments, and (2) verification of the licensees program for managing NRC commitment changes.
2.1 Verification of Energy Northwest's Implementation of NRC Commitments 2.1.1 Audit Scope The primary focus of this part of the audit is to confirm that the licensee has implemented those commitments made to the NRC as part of past licensing actions/activities. The audit should, therefore, ensure that the sample of completed commitments was implemented in a manner that satisfied both the action committed to and the overall intent of the commitment.
The NRC staff reviewed samples of Energy Northwests 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 licensees implementation of specific regulatory commitments by reviewing licensee commitment management records and other documentation that could demonstrate that the specific actions were completed in accordance with the stated commitment and schedule. Each commitment was also evaluated to determine whether the commitment was captured, as appropriate, in an update to the CGS Updated Final Safety Analysis Report (UFSAR).
2.1.2 Audit Results CGS procedure number SWP-LIC-01, "Regulatory Commitment Management," describes the licensees regulatory commitment management process. This procedure defines how written commitments to regulatory agencies are to be made only by those individuals with signature authority for correspondence addressed to regulatory agencies. Specifically:
Prior to placing a commitment in an outgoing letter, the responsible managers are expected to obtain support from the managers of the implementing organizations. A Regulatory Commitment Identification Form should be attached to all outgoing regulatory correspondence that contains commitments during the concurrence and approval process.
Once commitments are identified, Plant Tracking Log (PTL) codes are properly assigned on the Regulatory Commitment Identification Form for each proposed commitment and the commitments entered into the PTL. For commitments that are ongoing and are implemented in plant procedures, items are created in the Requirement Tracking System (RTS) to facilitate future identification and tracking.
The NRC staff reviewed reports generated by the RTS for the commitments listed below and evaluated the status of their completion. The NRC staff found that the licensees commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before and during the audit.
The specific regulatory commitments that were audited are as follows (as described in CGS plant records):
Docketed Regulatory Commitment as Stated in Licensee Audit Results -
Correspondence Submittal and Licensees Tracking Number Verification of Implementation NRC Issuance Modify HPCS system injection valve HPCS-V-4 to Complete. HPCS-V-4 GL 95-07 preclude pressure locking during the R-15 refueling was modified on August 17, 1995 outage. PTL #160195 6/22/01 under PMR
99-0108-0.
CGS Submittal June 30, 1999 GO2-99-121 NRC Issuance Modify RCIC system valve RCIC-V-31 to preclude Complete. RCIC-V-31 GL 95-07 pressure locking during the R-15 refueling outage. PTL was modified on August 17, 1995 #160202 6/1/01 under PMR
99-0107-0.
CGS Submittal June 30, 1999 GO2-99-121 CGS Submittal Perform a causal analysis for the degraded DG-1 Complete. Root cause February 19, 2003 bearing(s) after removal. PTL #197339 analysis on DG1 ML030590246 bearings completed
4/7/03.
NRC Issuance NOED 03-4-001 February 21, 2003 ML030520647 CGS Submittal Maintain contingency plans for obtaining and analyzing Complete. Procedure October 22, 2002 highly radioactive samples of reactor coolant. PTL PPM 12.10.12, Rev. 2, ML023050386 #197991 effective 4/15/04,
incorporates this NRC Issuance commitment.
Amendment 184 January 27, 2003 ML030280681 CGS Submittal Maintain the capability for classifying fuel damage Complete. RTS October 22, 2002 events at the alert level threshold. PTL #197992 commitments entered ML023050386 into procedure EPIP
13.1.1A and EPIP NRC Issuance 13.8.1 where Amendment 184 appropriate.
January 27, 2003 ML030280681
Docketed Regulatory Commitment as Stated in Licensee Audit Results -
Correspondence Submittal and Licensees Tracking Number Verification of Implementation CGS Submittal Maintain I-131 site survey detection capability, including Complete. RTS October 22, 2002 the ability to assess radioactive iodines released to commitments entered ML023050386 offsite environs. PTL #197993 into procedure EPIP
13.1.1A and EPIP NRC Issuance 13.8.1 where Amendment 184 appropriate.
January 27, 2003 ML030280681 NRC Issuance Reperform ASTM E741 tracer gas test to support GL Complete. Testing GL 2003-01 2003-01 response and resubmittal of alternate source was completed on June 12, 2003 term license amendment. PTL #205294 11/4/03 under WO ML031620248 01062664.
CGS Submittal August 11, 2003 ML032260330 NRC Issuance Determine the value for the most limiting unfiltered Open. Evaluation in GL 2003-01 inleakage into the CRE during a hazardous chemical progress.
June 12, 2003 event. PTL #205296 ML031620248 CGS Submittal August 11, 2003 ML032260330 NRC Issuance Following the guidance in Reg Guide 1.196, perform an Open. Evaluation in GL 2003-01 analysis to confirm reactor control capability is progress.
June 12, 2003 maintained in the event of smoke. PTL #205298 ML031620248 CGS Submittal August 11, 2003 ML032260330 As described in Section 2.1.1 above, the NRC staff found that all of the above commitments were adequately captured in the licensees database and that each commitment was implemented as specified or was being appropriately tracked for completion.
2.2 Verification of Energy Northwests Program for Managing NRC Commitment Changes 2.2.1 Audit Scope The primary focus of this part of the audit is the licensees performance related to implementing controls for modifying or deleting commitments made to the NRC. The audit should ensure that changes to commitments (modifications or deletions) are evaluated in accordance with the licensees programs and procedures, that the licensees technical evaluations adequately justify the change, and that the NRC is informed of commitment changes that have safety or regulatory significance.
The NRC staff reviewed the licensees commitment change process to: (1) evaluate the licensees methodology for proposed changes to regulatory commitments with particular consideration given to the intent of the original commitment and the safety and regulatory significance of the proposed change; and, (2) evaluate the licensees method of communicating commitment changes to the NRC when reports are warranted due to either safety or regulatory considerations. The NRC staff also evaluated the licensees 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 CGS procedure number SWP-LIC-01 includes a consistent process to change NRC regulatory commitments of low safety significance without adversely affecting the level of safety at CGS.
This process is based on the guidance of NEI 99-04 and provides a logical method for evaluating commitments for possible revision or deletion. Appropriate NRC notification in response to regulatory commitment changes is also defined.
CGS procedure number SWP-LIC-02, "Licensing Basis Impact Determinations," is used to perform an applicability determination for any proposed commitment revision or deletion. The results of this review will determine if the proposed commitment change is covered by another codified process (e.g., 10 CFR 50.59, 10 CFR 72.48, or 10 CFR 50.54). CGS procedure number SWP-LIC-03, "Licensing Document Change Process," is used to evaluate individual changes to regulatory commitments embodied in the plants UFSAR or to justify reductions in scope of the UFSAR.
Once commitment changes are identified, a Regulatory Commitment Change Form is completed and reviewed. NRC notification is provided as necessary, as determined by the commitment change evaluation process defined in SWP-LIC-01. PTL and RTS items tracking the commitment are updated as appropriate to document the regulatory commitment change.
In addition, an annual report is provided to the NRC summarizing regulatory commitment changes that require NRC notification but did not require prior NRC notification.
The NRC staff determined that CGS procedure number SWP-LIC-01 closely follows the guidance of NEI 99-04 in that it sets forth the need for identifying, tracking, and reporting commitments, and it provides an acceptable mechanism for changing commitments.
Additionally, the effectiveness of the procedure, as well as SWP-LIC-02 and SWP-LIC-03, is demonstrated by the products that are produced and maintained.
The specific commitment changes that were audited are as follows (as described in CGS plant records):
Docketed Original Regulatory Commitment and Licensees Audit Results -
Correspondence Tracking Number Verification of Change CGS Submittal Revise procedures associated with power oscillation Revised 8/18/00.
2000 Annual monitoring to require that the ANNA system be operable Eliminated Operating Report and in service from greater than 25% reactor power and requirement for February 23, 2001 less than 50% core flow. PTL #62133 continuous ANNA ML010650173 watch while in the AIA at steady state due to installation of OPRM which provides an audible alarm.
CGS Submittal Letter G02-93-055 committed to an enhanced Deleted 10/5/99. All 1999 Annual monitoring program for Rosemount dp transmitters. actions have been Operating Report PTL #104285 completed and the February 29, 2000 commitment is no ML003694647 longer needed.
CGS Submittal Plant QA procedure PQA-03 will be revised to provide Deleted 10/13/99. QA 1999 Annual direction to evaluate surveillance deficiency findings surveillance findings Operating Report against plant reporting requirements. PTL #108284 are reviewed for February 29, 2000 reportability under the ML003694647 corrective action program.
CGS Submittal Revise pre-fire plans to include shutdown of ventilation Deleted 7/6/00. This 2000 Annual systems as a fire brigade leader action. PTL #110598 action is now directed Operating Report from the control room February 23, 2001 by approved plant ML010650173 procedures.
CGS Submittal Test backup scram valves at 18 month intervals as part Revised 4/30/02.
2002 Annual of the RPS logic functional test to verify operability. PTL Testing interval Operating Report #110953 changed to 24 months.
February 27, 2003 ML030730459
Docketed Original Regulatory Commitment and Licensees Audit Results -
Correspondence Tracking Number Verification of Change CGS Submittal Revise Procedure PPM 11.2.2.5 to require exposure Deleted 12/30/99. The 1999 Annual controls for non-routine high radiation area entries commitment failed to Operating Report expected to be greater than 50 mrem per task. PTL address the violations February 29, 2000 #116677 it was intended to ML003694647 correct.
CGS Submittal Revise internal process to enhance the effectiveness of Deleted 11/19/02.
2002 Annual industry events training by July 1, 1993. PTL #140312 Incorporation of OE Operating Report into training programs February 27, 2003 is preserved by other ML030730459 requirements.
CGS Submittal Workers are required to notify HP personnel prior to Revised 6/10/99.
1999 Annual starting work in radiological areas. PTL #144467 Change requires Operating Report workers to have a February 29, 2000 face-to-face meeting ML003694647 with HP only for those instances which are radiologically significant or have the potential to change radiological conditions.
CGS Submittal A startup plan would be developed in accordance with a Revised 6/18/99.
1999 Annual POC-approved procedure. PTL #159531 Revision 26 to the Operating Report OQAPD eliminated the February 29, 2000 need for POC to ML003694647 review plant procedures which was approved by the NRC.
CGS Submittal Doors R-6 and R-6A located between the RHR pump Deleted 9/26/00.
2000 Annual rooms will remain closed and locked and will only be Administrative means Operating Report opened during shutdown modes of the plant and in the will be used to keep February 23, 2001 unlikely event of fire in RHR room on northeast corner doors R-6 and R-6A ML010650173 of the plant (Fire Zone R-V). PTL #170082 normally closed, and to control fire fighting actions.
CGS Submittal Perform augmented RFW nozzel inspections in Revised 11/19/2002.
2002 Annual accordance with WNP-2 response to NUREG-0619. Changed to implement Operating Report PTL #185190 the latest NRC February 27, 2003 approved industry ML030730459 recommendations.
As described in Section 2.2.1 above, the NRC staff found that all of the above commitment changes were adequately identified, evaluated, and reported.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit: (1) the licensee had implemented or is tracking for future implementation, regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT A. Carlyle C. Perino
Columbia Generating Station cc:
Mr. Dale Atkinson (Mail Drop PE08) Mr. Rodney L. Webring (Mail Drop PE04)
Vice President, Technical Services Vice President, Nuclear Generation Energy Northwest Energy Northwest P.O. Box 968 P.O. Box 968 Richland, WA 99352-0968 Richland, WA 99352-0968 Mr. Albert E. Mouncer (Mail Drop PE01) Thomas C. Poindexter, Esq.
Vice President, Corporate Services/ Winston & Strawn General Counsel/CFO 1400 L Street, N.W.
Energy Northwest Washington, DC 20005-3502 P.O. Box 968 Richland, WA 99352-0968 Mr. Bob Nichols Executive Policy Division Chairman Office of the Governor Energy Facility Site Evaluation Council P.O. Box 43113 P.O. Box 43172 Olympia, WA 98504-3113 Olympia, WA 98504-3172 Ms. Lynn Albin Mr. D. W. Coleman (Mail Drop PE20) Washington State Department of Health Manager, Performance Assessment P.O. Box 7827 and Regulatory Programs Olympia, WA 98504-7827 Energy Northwest P.O. Box 968 Richland, WA 99352-0968 Ms. Christina Perino (Mail Drop PE20)
Manager, Licensing Energy Northwest P.O. Box 968 Richland, WA 99352-0968 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Chairman Benton County Board of Commissioners P.O. Box 190 Prosser, WA 99350-0190 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 69 Richland, WA 99352-0069