ML042600186
| ML042600186 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 10/21/2004 |
| From: | Clark R Division of Nuclear Materials Safety I |
| To: | Korsnick M Ginna |
| Clark R, NRR/DLPM, 415-2297 | |
| References | |
| TAC MC3752 | |
| Download: ML042600186 (9) | |
Text
October 21, 2004 Mrs. Mary G. Korsnick Vice President R.E. Ginna Nuclear Power Plant R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, NY 14519
SUBJECT:
R. E. GINNA NUCLEAR POWER PLANT- AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC3752)
Dear Mrs. Korsnick:
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 R. E. Ginna Nuclear Power Plant, LLC (Ginna) commitment management program was performed onsite on August 19, 2004. The NRC staff concludes that, based on the audit (1) Ginna has implemented NRC commitments on a timely basis; and (2) Ginna has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
Robert Clark, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
As stated cc w/encl: See next page
ML042600186 OFFICE PDI-1\PM PDI-1\LA PDI-1\SC NAME RClark SLittle RLaufer DATE 10/14/04 10/18/04 10/18/04 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
R. E. GINNA NUCLEAR POWER PLANT (GINNA)
DOCKET NO. 50-244
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 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 onsite on August 19, 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 Before the audit, the NRC staff searched ADAMS for the licensees licensing action and licensing activity submittals dated in the last 3 years. Some of these submittals contain regulatory commitments, but the NRC staff found that commitments meeting the definition in LIC-105 are few in number. Table 1 is a list of the licensees commitments which were included in the audit sample.
LIC-105 limits the audit of commitments to those made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Accordingly, the audit excluded the following types of commitments:
(1) Commitments as a result of Licensee Event Reports (LERs) - These commitments are controlled by the licensees LER process, which is imposed by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.73.
(2) Commitments made on the licensees own initiative among internal organizational components.
(3) Commitments that pertain to milestones of licensing actions/activities (e.g., respond to an NRC request for additional information by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed.
(4) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Orders, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
2.1.2 Audit Results The NRC staff reviewed reports generated by the commitment tracking program for the commitments listed in Table 1 to evaluate the status of completion. The NRC staff found that the licensees commitment tracking program had captured all the regulatory commitments that were identified by the NRC staff before the audit.
The NRC staff also reviewed plant procedure A-52-12, Inoperability of Equipment Important to Safety. The NRC staff noted that the revised procedure used superscripts to annotate commitments including those made to the NRC. The annotated commitments are referred to by the licensee as hardened steps. The annotations or hardened steps serve to prevent future procedure writers from inadvertently deleting or altering an item without having gone through the commitment change process. The NRC staff noted that guidance for implementing hardened steps for plant procedures are provided in IP-PRO-3, Procedure Control. Based on the above review, the staff concludes that the licensee has implemented an adequate program for ensuring that revised commitments continue to be traceable.
The attached 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 Regulatory Commitment Management, IP-LPC-6, Revision 2, against NEI 99-04. According to subsection 2.2.1, this document was developed in accordance with the guidance provided in NEI 99-04. This procedure defined the criteria for review and evaluation of implemented commitments and the mechanism for changing commitments. Additional guidelines for performing an NRC Commitment Change Evaluation was also provided in Attachments 1 and 2, of the procedure.
In general, IP-LPC-6, Revision 2, follows closely the guidance of NEI-99-04: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments.
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 has implemented or is tracking for future implementation all regulatory commitments; and (2) that the licensee has also implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT G. Wroble M. Rubin D. Skolnik Principal Contributor: R. Clark Date:
Attachment:
Table 1, Audited: Written Commitments and Related Information
TABLE 1 AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION Ginna, LLC NRC NRC Issuance Summary of Commitment, and Licensee Submittal TAC Licensees Tracking Number Implementation Date No. Status 07/08/04 MB9123 Under review Provide seismic and equipment Complete qualification data for control room emergency air treatment system modification.
CATS ID 11645 05/21/04 MB9123 Under review Provide summary of Appendix R Complete review for control room emergency air treatment system modification.
CATS ID 11498 07/14/04 MB9123 Under review Provide updated AST dose Complete calculations for control room emergency air treatment system modification.
CATS ID 11497 05/17/04 NA NRC letter to Provide comments on the NRC Complete RG&E dated Preliminary Accident Sequence 03/18/04 Precursor Analysis regarding the August 18, 2003 blackout and reactor trip.
CATS ID 11620 05/23/03 MB7240 NRC Safety Revise Ginna Nuclear Emergency Complete Evaluation Response Plan (NERP) to include dated 07/24/03 18 one hour responders. NERP R22 CATS ID 11274 05/23/03 MB7240 NRC Safety Revise NERP to include one 30 Complete Evaluation minute responder to address the dated 07/24/03 on shift requirements for NERP R22 Rad/Chem Technician position.
CATS ID 11275
Ginna, LLC NRC NRC Issuance Summary of Commitment, and Licensee Submittal TAC Licensees Tracking Number Implementation Date No. Status 05/23/03 MB7240 NRC Safety Add Dose Assessment Manager Complete Evaluation to the list of responders who are dated 07/24/03 activated at the declaration of an NERP R22 Unusual Event.
CATS ID 11276 05/23/03 MB7240 NRC Safety NERP responders will respond Complete Evaluation immediately upon being notified dated 07/24/03 and not wait for additional time. NERP R22 CATS ID 11277 05/23/03 MB7240 NRC Safety Completion of corrective actions Complete Evaluation associated with the unannounced dated 07/24/03 off-hours call out drill. NERP R22 CATS ID 11278 05/23/03 MB7240 NRC Safety Submit revised NERP. Complete Evaluation dated 07/24/03 CATS ID 11279 NERP R22
R.E. Ginna Nuclear Power Plant cc:
Mr. Michael J. Wallace President Daniel F. Stenger R.E. Ginna Nuclear Power Plant, LLC Ballard Spahr Andrews & Ingersoll, LLP c/o Constellation Energy 601 13th Street, N.W., Suite 1000 South 750 East Pratt Street Washington, DC 20005 Baltimore, MD 21202 Ms. Thelma Wideman, Director Mr. John M. Heffley Wayne County Emergency Management Senior Vice President and Office Chief Nuclear Officer Wayne County Emergency Operations Constellation Generation Group Center 1997 Annapolis Exchange Parkway 7336 Route 31 Suite 500 Lyons, NY 14489 Annapolis, MD 21401 Ms. Mary Louise Meisenzahl Kenneth Kolaczyk, Sr. Resident Inspector Administrator, Monroe County R.E. Ginna Nuclear Power Plant Office of Emergency Preparedness U.S. Nuclear Regulatory Commission 1190 Scottsville Road, Suite 200 1503 Lake Road Rochester, NY 14624 Ontario, NY 14519 Mr. Paul Eddy Regional Administrator, Region I New York State Department of U.S. Nuclear Regulatory Commission Public Service 475 Allendale Road 3 Empire State Plaza, 10th Floor King of Prussia, PA 19406 Albany, NY 12223 Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 James M. Petro, Jr., Esquire Counsel Constellation Energy 750 East Pratt Street, 5th Floor Baltimore, MD 21202 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271