ML042590357
| ML042590357 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| 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 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.
Enclosure
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 Basis Summary of Commitment Licensee Implementation Status Commitment (TSAmendment/ IEB/
Tracking No. LER/ Peer review/
& Status etc.)
A-26485 TS Amendment No. Implement Amendment within 60 days Implemented via ER-WF3-2003-0131, DRN 03-185, dated 3/27/03, 347-performed the TS Changes and DRN 03-375 CLOSED(I) Regarding performed the associated Bases changes.
Reactivity/Boron Concentration Changes P-26562 NRC Bulletin 2003-01 Entergy will train licensed operators on indications of and Training was provided to approximately 50 (from Potential impact of responses to ECCS sump clogging. The training will include operation/training/ planning & Scheduling (Outage)
CLOSED(I) debris blockage on identification of indications, possible responses, Emergency on sump clogging issues, via course no. WLP-emergency sump Operating Procedure (EOP) and Severe Accident Management OPS-SI on 2/28/04.
recirculation at PWRs Guideline (SAMG) Instructions for responding to ECCS sump clogging. This training will be completed by March 31, 2004.
A-26563 As a compensatory measure, Entergy will enhance the ability to The commitment was met by 1) expanding the ensure that alternative water sources are available to refill the information provided in SAMG Implementation CLOSED(I) RWSP or to otherwise provide inventory to inject into the reactor Strategies, BD/CC-CHLA-1 and BD/CC-CHLA-8 to core and/or spray Into the containment by adding appropriate provide more details concerning water resources.
guidance to emergency plan implementing procedures and/or the SAMGs.
P-26564 The design of Waterford 3 containment building allows the An inspection was made at the transition to majority of the water to freely flow down to the ECCS sump by Mode 4 on the way back up from RFO 12.
SATISFIED bypassing grating on each of the elevations. Drainage paths (O) exist In the refueling cavity where water must pass valves in This is an ongoing activity and upon completion of order to reach the ECCS sump. These valves are verified by this activity, the commitment is updated to reflect a operations at the end of the refueling outage to be locked open new due date of the next RFO.
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
A-26591 TS Amendment No. Implement the Amendment by revising TS, TS Bases, and Amendment implemented in all three via ER-W3-189, dated 9/22/2003 TRM 2003-0610.
CLOSED(I) Re. relocation &
modification of TS 4.0.5 and 3/4.4.9 and extension of RCP flywheel volumetric exam. interval.
A-26622 License Amendment Implement measures as necessary to prevent potential Commitment to be tracked when amendment is Request NPF-38-249, condenser tube vibration under power uprate conditions. issued.
OPEN Extended Power Uprate P-23872 License Amendment Original Commitment description: Design Engineering Revised Commitment description: Code programs Request NPF-38-146, Programs will ensure that procedural commitments stated in Engineering will ensure that procedural CLOSED(C) NOCEP-252, steam generator eddy current inservice testing commitments stated in steam generator eddy specific to tube plugging will also be invoked for the tube current inservice testing procedures specific to sleeving process (... utilizing site QA/QC personnel). 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 License Amendment Higher heat loads will increase the temperature of the CCWS Commitment to be tracked when amendment is Request NPF-38-249, return flow in some of the CCWS piping sections. The impact issued/implemented (end of RF 13).
OPEN Extended Power of these higher temperatures on the CCWS piping, supports, Uprate and components will be evaluated. Also, the impact of these higher temperatures on the shutdown cooling heat exchanger room coolers will be evaluated.
A-26595 License Amendment Implement TRM changes associated with TS Amendment 190, Implemented TRM changes per Amendment 81 on Request NPF-38-246, Main Steam Isolation Valves 11/21/03 via document ER-WR-2002-0321-001.
CLOSED(I) Main Steam Isolation Valves A-26594 Implement TS Bases changes associated with TS Amendment Implemented TS Bases changes associated with (TAC No. MB6963) 190, Main Steam Isolation Valves TS Amendment 190, per change 31, on 11/12/03 CLOSED(I) via document ER-WR-2002-0321-001.
A-26593 Implement TS Amendment 190, Main Steam Isolation Valves TS Amendment 190 implemented on 11/12/03, via prior to Mode 4 for RF12 startup. document ER-WR-2002-0321-001.
CLOSED(I)
P-25499 As a part of Corrective Action of performing work on the wrong Since Waterford 3 implements a comprehensive component, Waterford 3 committed to revise Maintenance Human Performance Program designed to lessen CLOSED(D) Directive #7 Pre Job/Post Job Briefing form checklist to include the potential for human error and the pre-job brief a step to verify components that are scheduled to be worked. 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 LER 97-012.01 Programmatic breakdown of overtime program - QA to perform Th commitment was initiated in 1997. The audit of audits of working hour policy implementation. the implementation of the working hour policy ia CLOSED(D) 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 NRC Inspection report Revise site directive W2.501, corrective action, which will This commitment was primarily an enhancement 50-382/97-16 NOV, contain detailed operability assessment guidance. to the existing operability determination process.
CLOSED(D) Self-assessment and A review of this commitment finds that it is no peer group review 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 Supplement to the A-26690 - Visual inspections of the LTAa will be performed in Four LTAs are scheduled to be inserted into the A-26691 Request for the spent fuel pit during the outage (at the end of cycles 14, core during RF13 and at the end of each operating A-26692 Exemption to the 15, and 16). cycle must be inspected. A-26690 is intially Cladding Material A-26691 - Non-destructive post-irradiation examinations (PIE) scheduled for RF14 and rescheduled for RF 15 OPEN Specified in 10 CFR will be performed on the LTAs at the end of cycles 15 and 16. and RF 16.
50.46 & App. K to A-26692 - PIE measurements will be compared to the model Commitment A-26691 and A-26692 are required Allow Use of predictions. Significant deviations from these predictions will following the completion of cycles 15 and 16 and Optimized ZIRLO be addressed and reconciled in the fuel performance models therefore the commitment will be intially scheduled Lead Test Assemblies for RF15 and rescheduled for RF16.
(LTA)
P-21439 NRC Inspection 1) The function of the Condition Review Group (CRG) will be 1) The function of the Condition Review Group Report 50-382/94- to (A) ... ; and (B) designate a Corrective Action Review Board (CRG) will be to (A) ... ; and (B) designate a CLOSED(C) 19??? (CARB) Chairman. The CARB will review and approve root Corrective Action Review Board (CARB) cause analyses and root cause determination (RCD) for Chairman. The CARB will review and approve significant condition reports when so designated by the CRG. root cause analyses and for for significant
- 2) ... At the sites, the group is chaired by the stations GMPO condition reports when so designated by the CRG or if unavailable, a designee. The CRG chairman ensures that 2. The 2nd commitment is expanded to say ... is adequate representation is in attendance at meetings. 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 License Amendment Issuance of Amendment, Addition of Topical Report entitled TS implemented on November 4, 2003. via ER-Request NPF-38-245, Fuel Rod Maximum Allowable Gas Pressure, CEN-372-P-A, W3-2003-0678-000.
CLOSED Use of CEN-372-P-A. to the list of analytical methods in TS 6.9.1.11.1 to determine In addition, FSAR Section 4.2.1.2.1.f was changed TS Amendment 191 the Core Operatiming Limits. to reflect the provisions of the Amendment.
Implement TS Amendment within 60 days of Issuance.
A-26448 License Amendment Issuance of the Amendment, Letdown Line Break Dose The 4 commitments tracked the implementation of A-26449 Request NPF-38-239, Consequences Revision required the licensee to implement the changes to the TS, Operations Deficiency A-26450 Revision of Letdown the Amendment within 60 days of issuance (January 8, 2003). Database, FSAR, and other supporting A-26451 Line Break Dose procedures.
Consequences The licensee identified that changes to TS, TS Bases, FSAR, Waterford 3 Engineering Review document ER-CLOSED TS Amendment 184 and supporting procedures will be necessary. W3-2003-0059-000 Revision 0, was generated as per the procedures to close out these commitments.
P-24733 LER-97-12-01 Plant Procedure UNT-005-005 will be revised to include 1) an A new procedure OM-123, in which all the determined that a enhancement to Attachment 6.1, authorization of working identified clarifications were made, was developed CLOSED programmatic hours policy deviations, to indicate, in addition to the reasons to cover the working hour limits requirements for breakdown occurred for the deviation, the number of hours to be worked, all Entergy Nuclear South plants.OM-123 replaces in the administration of 2) clarification on the requirements for approval of working UNT-005-005. CCEF 2003-0003 was generated the TS working hour hour deviations prior to the commencement of the work to close the commitment list.
limits. 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.
P-26609 License Amendment As per the Application for the EPU dated November 13, 2003, With the status quo, P-26684 was closed.
P-26684 Request NPF-38-249 the licensee made a commitment to replace the existing Extended Power Atmospheric Dump Valves (ADV) analog controllers with more The licensee was in the process of closing CLOSED Uprate (EPU) accurate digital controllers. This was reflected in P-26609. Commitment A-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.
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 Regional Administrator, Region IV Department of Environmental Quality U.S. Nuclear Regulatory Commission Permits Division 611 Ryan Plaza Drive, Suite 400 P.O. Box 4313 Arlington, TX 76011 Baton Rouge, Louisiana 70821-4313 Parish President Council Vice President Operations Support St. Charles Parish Entergy Operations, Inc. P. O. Box 302 P. O. Box 31995 Hahnville, LA 70057 Jackson, MS 39286-1995 Executive Vice President Director & Chief Operating Officer Nuclear Safety Assurance Entergy Operations, Inc.
Entergy Operations, Inc. P. O. Box 31995 17265 River Road Jackson, MS 39286-1995 Killona, LA 70066-0751 Chairman Wise, Carter, Child & Caraway Louisiana Public Services Commission P. O. Box 651 P. O. Box 91154 Jackson, MS 39205 Baton Rouge, LA 70825-1697 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