ML042590357
| ML042590357 | |
| Person / Time | |
|---|---|
| Site: | Waterford  (NPF-038) |
| Issue date: | 09/15/2004 |
| From: | Kalyanam N NRC/NRR/DLPM/LPD4 |
| To: | Venable J Entergy Operations |
| Kalyanam N,NRR/DLPM,415-1480 | |
| References | |
| TAC MC3790 | |
| Download: ML042590357 (12) | |
Text
September 15, 2004 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 SUBJECT WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3)
- AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC3790)
Dear Mr. Venable:
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 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. LIC-105 specifies that once every 3 years, the NRC staff will audit a licensees commitment management program.
An audit of Waterford 3's commitment management program was performed at Entergy's office at the plant site in Louisiana on July 20, 21, and 22, 2004. The NRC staff concludes that, based on the audit (1) Waterford 3 had implemented NRC commitments on a timely basis; and (2) Waterford 3 had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
N. Kalyanam, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated cc w/encl: See next page
ML042590357 OFFICE PDIV-1\\PM PDIV-1\\LA PDIV-1\\SC NAME NKalyanam DBaxley DJaffe DATE 9/10/04 9/10/04 9/14/04
Enclosure AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
WATERFORD STEAM ELECTRIC STATION, UNIT 3 (WATERFORD 3)
DOCKET NO. 50-382
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 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.
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 once every 3 years.
2.0 AUDIT PROCEDURE AND RESULTS Since no such audit was performed before issuance of LIC-105, the NRC staff defined the period covered by this audit to go back approximately 3 years from the date of the audit. The audit was performed at Entergy offices at the plant site in Louisiana on July 20, 21, and 22, 2004.
2.1 Verification of Licensees Implementation of NRC Commitments 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. For commitments that had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
2.1.1 Audit Scope Waterford 3 commitments are tracked by a program titled Commitment Management Program. There are approximately 27,500 commitments listed in the data base, which includes all the commitments made from 1984. The NRC staff picked out at random, about 20 commitments dated in approximately the last 3 years from the licensees program.
2.1.2 Audit Results The NRC staff reviewed reports generated by the tracking program for the commitments listed in Table 1 to evaluate the status of completion. The NRC staff found that the licensees commitment tracking programs had captured all the regulatory commitments that were made to the NRC staff in its licensing actions/activities, generic letters, bulletins, etc.
Table 1 summarizes what the NRC staff observed as the current status of licensee commitments.
2.2 Verification of the Licensees Program for Managing NRC Commitment Changes The NRC staff reviewed the licensees procedure entitled Commitment Management Program, LI-110, Revision 0, against NEI 99-04. In general, LI-110, Revision 0, follows closely the guidance of NEI 99-04 and it sets forth the need for identifying, initiating, tracking, and reporting commitments, managing a change or deviation from a previously completed commitment.
The effectiveness of a procedure can be indicated by the products that are produced by the procedure. As set forth in Section 2.1 above, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of review of the licensees information, as well as information from other sources, the NRC staff found no reason to differ from the licensees reported status of the audited commitments. Thus, the NRC staff surmises that the procedure used by the licensee to manage commitments is appropriate and effective.
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 R. Murillo G. Scott Principal Contributor: N. Kalyanam Date: September 15, 2004
TABLE 1 AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION (2000 THROUGH 2003)
Waterford 3 Commitment Tracking No.
& Status Commitment Basis (TSAmendment/ IEB/
LER/ Peer review/
etc.)
Summary of Commitment Licensee Implementation Status A-26485 CLOSED(I)
TS Amendment No.
185, dated 3/27/03, Regarding Reactivity/Boron Concentration Changes Implement Amendment within 60 days Implemented via ER-WF3-2003-0131, DRN 03-347-performed the TS Changes and DRN 03-375 performed the associated Bases changes.
P-26562 CLOSED(I)
NRC Bulletin 2003-01 Potential impact of debris blockage on emergency sump recirculation at PWRs Entergy will train licensed operators on indications of and responses to ECCS sump clogging. The training will include identification of indications, possible responses, Emergency Operating Procedure (EOP) and Severe Accident Management Guideline (SAMG) Instructions for responding to ECCS sump clogging. This training will be completed by March 31, 2004.
Training was provided to approximately 50 (from operation/training/ planning & Scheduling (Outage) on sump clogging issues, via course no. WLP-OPS-SI on 2/28/04.
A-26563 CLOSED(I)
As a compensatory measure, Entergy will enhance the ability to ensure that alternative water sources are available to refill the RWSP or to otherwise provide inventory to inject into the reactor core and/or spray Into the containment by adding appropriate guidance to emergency plan implementing procedures and/or the SAMGs.
The commitment was met by 1) expanding the information provided in SAMG Implementation Strategies, BD/CC-CHLA-1 and BD/CC-CHLA-8 to provide more details concerning water resources.
P-26564 SATISFIED (O)
The design of Waterford 3 containment building allows the majority of the water to freely flow down to the ECCS sump by bypassing grating on each of the elevations. Drainage paths exist In the refueling cavity where water must pass valves in order to reach the ECCS sump. These valves are verified by operations at the end of the refueling outage to be locked open in order to ensure drainage from the refueling cavity. Entergy will inspect these lines and other drain lines that could affect drainage paths during future outages to ensure that these are unobstructed An inspection was made at the transition to Mode 4 on the way back up from RFO 12.
This is an ongoing activity and upon completion of this activity, the commitment is updated to reflect a new due date of the next RFO.
A-26591 CLOSED(I)
TS Amendment No.
189, dated 9/22/2003 Re. relocation &
modification of TS 4.0.5 and 3/4.4.9 and extension of RCP flywheel volumetric exam. interval.
Implement the Amendment by revising TS, TS Bases, and TRM Amendment implemented in all three via ER-W3-2003-0610.
A-26622 OPEN License Amendment Request NPF-38-249, Extended Power Uprate Implement measures as necessary to prevent potential condenser tube vibration under power uprate conditions.
Commitment to be tracked when amendment is issued.
P-23872 CLOSED(C)
License Amendment Request NPF-38-146, Original Commitment description: Design Engineering Programs will ensure that procedural commitments stated in NOCEP-252, steam generator eddy current inservice testing specific to tube plugging will also be invoked for the tube sleeving process (... utilizing site QA/QC personnel).
Revised Commitment description: Code programs Engineering will ensure that procedural commitments stated in steam generator eddy current inservice testing procedures specific to tube plugging will also be invoked for the tube sleeving process (... utilizing site or vendor QA/QC personnel).
Commitment Change Evaluation Form (CCEF) for source document WF195-0080 to cover vendor personnel.
A-26618 OPEN License Amendment Request NPF-38-249, Extended Power Uprate Higher heat loads will increase the temperature of the CCWS return flow in some of the CCWS piping sections. The impact of these higher temperatures on the CCWS piping, supports, and components will be evaluated. Also, the impact of these higher temperatures on the shutdown cooling heat exchanger room coolers will be evaluated.
Commitment to be tracked when amendment is issued/implemented (end of RF 13).
A-26595 CLOSED(I)
License Amendment Request NPF-38-246, Main Steam Isolation Valves (TAC No. MB6963)
Implement TRM changes associated with TS Amendment 190, Main Steam Isolation Valves Implemented TRM changes per Amendment 81 on 11/21/03 via document ER-WR-2002-0321-001.
A-26594 CLOSED(I)
Implement TS Bases changes associated with TS Amendment 190, Main Steam Isolation Valves Implemented TS Bases changes associated with TS Amendment 190, per change 31, on 11/12/03 via document ER-WR-2002-0321-001.
A-26593 CLOSED(I)
Implement TS Amendment 190, Main Steam Isolation Valves prior to Mode 4 for RF12 startup.
TS Amendment 190 implemented on 11/12/03, via document ER-WR-2002-0321-001.
P-25499 CLOSED(D)
As a part of Corrective Action of performing work on the wrong component, Waterford 3 committed to revise Maintenance Directive #7 Pre Job/Post Job Briefing form checklist to include a step to verify components that are scheduled to be worked.
Since Waterford 3 implements a comprehensive Human Performance Program designed to lessen the potential for human error and the pre-job brief is an important part of reducing the probability of human error, neither a commitment is necessary to insure that appropriate pre-job briefs are performed nor is tracking of this commitment necessary to prevent reoccurrence of the condition adverse to quality.
P-25038 CLOSED(D)
LER 97-012.01 Programmatic breakdown of overtime program - QA to perform audits of working hour policy implementation.
Th commitment was initiated in 1997. The audit of the implementation of the working hour policy ia an after-the-fact review and therefore would not prevent recurrence of the original condition. The commitment is historical, adds no value and should be deleted.
CCEF plant licensing track number 2003-0010 was generated to delete and close this commitment.
P-25722 CLOSED(D)
NRC Inspection report 50-382/97-16 NOV, Self-assessment and peer group review Revise site directive W2.501, corrective action, which will contain detailed operability assessment guidance.
This commitment was primarily an enhancement to the existing operability determination process.
A review of this commitment finds that it is no longer necessary due to changes made in the Waterford 3 corrective action program.
CCEF plant licensing track number 2003-0006 was generated to delete and close this commitment.
A-26690 A-26691 A-26692 OPEN Supplement to the Request for Exemption to the Cladding Material Specified in 10 CFR 50.46 & App. K to Allow Use of Optimized ZIRLO Lead Test Assemblies (LTA)
A-26690 - Visual inspections of the LTAa will be performed in the spent fuel pit during the outage (at the end of cycles 14, 15, and 16).
A-26691 - Non-destructive post-irradiation examinations (PIE) will be performed on the LTAs at the end of cycles 15 and 16.
A-26692 - PIE measurements will be compared to the model predictions. Significant deviations from these predictions will be addressed and reconciled in the fuel performance models Four LTAs are scheduled to be inserted into the core during RF13 and at the end of each operating cycle must be inspected. A-26690 is intially scheduled for RF14 and rescheduled for RF 15 and RF 16.
Commitment A-26691 and A-26692 are required following the completion of cycles 15 and 16 and therefore the commitment will be intially scheduled for RF15 and rescheduled for RF16.
P-21439 CLOSED(C)
NRC Inspection Report 50-382/94-19???
- 1) The function of the Condition Review Group (CRG) will be to (A)... ; and (B) designate a Corrective Action Review Board (CARB) Chairman. The CARB will review and approve root cause analyses and root cause determination (RCD) for significant condition reports when so designated by the CRG.
- 2)... At the sites, the group is chaired by the stations GMPO or if unavailable, a designee. The CRG chairman ensures that adequate representation is in attendance at meetings.
- 1) The function of the Condition Review Group (CRG) will be to (A)... ; and (B) designate a Corrective Action Review Board (CARB)
Chairman. The CARB will review and approve root cause analyses and for for significant condition reports when so designated by the CRG
- 2. The 2nd commitment is expanded to say... is in attendance at meetings, to support QA independence, W 3 may procedurally authorize the Director Oversight to override the CRG on categorization for CRS documenting QA identified issues. The procedure authorization will only allow the director oversight to increase the categorization level.
CCEF plant licensing track number 2004-0002 provides the summary of justification for change and was generated to revise and close this commitment.
A-26596 CLOSED License Amendment Request NPF-38-245, Use of CEN-372-P-A.
TS Amendment 191 Issuance of Amendment, Addition of Topical Report entitled Fuel Rod Maximum Allowable Gas Pressure, CEN-372-P-A, to the list of analytical methods in TS 6.9.1.11.1 to determine the Core Operatiming Limits.
Implement TS Amendment within 60 days of Issuance.
TS implemented on November 4, 2003. via ER-W3-2003-0678-000.
In addition, FSAR Section 4.2.1.2.1.f was changed to reflect the provisions of the Amendment.
A-26448 A-26449 A-26450 A-26451 CLOSED License Amendment Request NPF-38-239, Revision of Letdown Line Break Dose Consequences TS Amendment 184 Issuance of the Amendment, Letdown Line Break Dose Consequences Revision required the licensee to implement the Amendment within 60 days of issuance (January 8, 2003).
The licensee identified that changes to TS, TS Bases, FSAR, and supporting procedures will be necessary.
The 4 commitments tracked the implementation of the changes to the TS, Operations Deficiency Database, FSAR, and other supporting procedures.
Waterford 3 Engineering Review document ER-W3-2003-0059-000 Revision 0, was generated as per the procedures to close out these commitments.
P-24733 CLOSED LER-97-12-01 determined that a programmatic breakdown occurred in the administration of the TS working hour limits.
Plant Procedure UNT-005-005 will be revised to include 1) an enhancement to Attachment 6.1, authorization of working hours policy deviations, to indicate, in addition to the reasons for the deviation, the number of hours to be worked,
- 2) clarification on the requirements for approval of working hour deviations prior to the commencement of the work activity, 3) clarification of the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exception for the late watch relief, and 4) clarification on who the working hour policy applies to.
A new procedure OM-123, in which all the identified clarifications were made, was developed to cover the working hour limits requirements for all Entergy Nuclear South plants.OM-123 replaces UNT-005-005. CCEF 2003-0003 was generated to close the commitment list.
P-26609 P-26684 CLOSED License Amendment Request NPF-38-249 Extended Power Uprate (EPU)
As per the Application for the EPU dated November 13, 2003, the licensee made a commitment to replace the existing Atmospheric Dump Valves (ADV) analog controllers with more accurate digital controllers. This was reflected in P-26609.
Later, with the emergent issues regarding the EPU SBLOCA analysis, the licensee stated in its supplement dated July 14, 2004, that there will be no need to install digital ADV controllers. This position was reflected in P-26684.
With the status quo, P-26684 was closed.
The licensee was in the process of closing Commitment A-26609 NOTE:
The letter within the parentheses in first column in the table refers to the current status of the commitment.
I - Commitment has been Implemented and closed O - Commitment is open C - The original commitment has been changed/revised D - The original commitment has been deleted
Waterford Steam Electric Station, Unit 3 cc:
Mr. Michael E. Henry, State Liaison Officer Department of Environmental Quality Permits Division P.O. Box 4313 Baton Rouge, Louisiana 70821-4313 Vice President Operations Support Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Director Nuclear Safety Assurance Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.
17265 River Road Killona, LA 70066-0751 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Parish President Council St. Charles Parish P. O. Box 302 Hahnville, LA 70057 Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Chairman Louisiana Public Services Commission P. O. Box 91154 Baton Rouge, LA 70825-1697