ML043090370
| ML043090370 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/05/2005 |
| From: | Nerses V NRC/NRR/DLPM/LPD1 |
| To: | Christian D Dominion Nuclear Connecticut |
| Nerses V, NRR//DLPM, 415-1484 | |
| References | |
| TAC MC4473, TAC MC4474 | |
| Download: ML043090370 (9) | |
Text
May 5, 2005 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
MILLSTONE POWER STATION, UNIT NOS. 2 AND 3 - AUDIT OF DOMINION NUCLEAR CONNECTICUT, INCS MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC4473 AND MC4474)
Dear Mr. Christian:
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 to the NRC staff by licensees for commercial nuclear reactors. 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 the Dominion Nuclear Connecticut, Inc. (licensee) commitment management program was performed at the Millstone site in Waterford, Connecticut on October 7, 2004.
The NRC staff concludes that, based on the audit (1) the licensee has an adequate program to implement and manage regulatory commitments, or to track for future implementation of regulatory commitments, and (2) the licensee has an adequate program to implement and manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
Victor Nerses, Senior Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-336 and 50-423
Enclosure:
As stated cc w/encl: See next page
ML043090370 OFFICE PDI-2\\PM PDI-2\\LA PDI-2\\SC NAME VNerses CRaynor DCollins for DRoberts DATE 5/3/05 5/2 /05 5/5/05
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION MILLSTONE POWER STATION UNIT NOS. 2 AND 3 DOCKET NOS. 50-336 AND 50-423
1.0 INTRODUCTION AND BACKGROUND
On May 27, 2003, the Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regulation (NRR), published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management System (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 a 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 4 years from the date of the audit. The audit of the Dominion Nuclear Connecticut, Inc. (licensee) program was performed at the Millstone Power Station, Unit Nos. 2 and 3 (MPS) in Waterford, Connecticut on October 7, 2004. The NRC staff dealt mainly with the Regulatory Affairs Department, which has a key role in the administration of the licensees Regulatory Commitment Program.
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 the licensees licensing action and licensing activity submittals dated in the last 4 years. Some of these submittals contain regulatory commitments.
The NRC staff found a number of commitments that met the definition in LIC-105. The attached table lists the sample of the licensees commitments that were selected for this audit.
The licensees commitments are implemented through their Station Administrative Procedure, MP-03-LBM-SAP06, Regulatory Commitment Management Program Implementation.
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 (LER)s - 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, 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 licensees tracking program for the commitments listed in the attached table to evaluate the status of completion. The NRC staff found that the licensees commitment tracking program had incorporated all the regulatory commitments that were selected by the NRC staff for this audit.
The NRC staff also reviewed plant procedures that had been revised as a result of commitments made by the licensee to the NRC. The NRC staff noted that some of the revised procedures have annotations to refer to commitments. These annotations would serve to prevent future procedure writers from inadvertently deleting or altering an item without having gone through the commitment change process.
The attached table summarizes what the NRC staff observed as the current status of licensee regulatory commitments for those selected 2.2 Verification of the Licensees Program for Managing NRC Commitment Changes The licensees document entitled License Basis Management Program (MP-03-LBM-PRG, Rev. 002-01), is a manual that applies to work and operational activities that initiate, receive, implement, generate or change commitments at the MPS. The manual also applies to common station areas, common station processes, organizations and functions. In Section 4.2 of the manual, it specifically states that NEI 99-04, dated July 1999, Guidelines for Managing NRC Commitment Changes is applicable to the program, its implementing procedures and guidelines as described in Section 5 of the manual. In Section 5, commitments is specifically identified. Further, the NRC staff reviewed the licensees procedure entitled Commitment Change Request (MP-03-LBM-SAP06-001, Rev. 001) against NEI 99-04 and found that MP-03-LBM-SAP06-001 uses the NEI guidelines with regard to managing a change or deviation from a previously completed commitment. In fact, the licensees procedure appears nearly identical in format to the NEI procedure. It sets forth the need for identifying, tracking, and reporting commitments, and it provides a mechanism for changing commitments.
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 the review of the licensees information, 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.
2.3 Additional Observation The NRC staff requested information of the Regulatory Command Program regarding what self-assessments have been performed. The NRC staff learned that the licensees Oversight Group could not find any record of having performed an assessment. However, the NRC staff learned that the Regulatory Affairs Department performed a self-assessment five years ago.
However, the assessment performed five years ago was prior to the major changes made to the current program and, therefore, may not be representative.
The licensee should consider incorporating a periodic assessment of the Regulatory Command Program to assess the program effectiveness in meeting its objectives.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit findings, (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 D. Dodson, Licensing Manager, Regulatory Affairs Department W. Brown, Technical Analyst, Regulatory Affairs Department R. McIntosh, Engineer III, Regulatory Affairs Department W. Bartron, Engineer III, Regulatory Affairs Department R. Donovan, Supervisor Technical Procedures Principal Contributor: V. Nerses Date: May 5, 2005
TABLE - LICENSEES REGULATORY COMMITMENTS Dominion Nuclear Connecticut, Inc. (Licensee)
Submitted Licensee Commitment Tracking No.
Description Licensee Implementation Status 02/01/01 RCR 42885 Establish criteria for monitoring in-leakage rate in the sump by adding a Technical Requirement to the MP3 Technical Requirements Manual Completed 02/01/01 RCR 42886 Establish a calibration schedule for the level indication and alarm instrument loops prior to entering Mode 4 of refueling outage 3R07 Completed 02/08/01 RCR 42887 Incorporate the final 10 CFR 50.59 rule into implementing procedures Completed 07/31/01 RCR 42888 Incorporate in the Chemistry Department implementing procedures contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, the containment sump, and the containment atmosphere Completed 07/31/01 RCR 42889 Incorporate in the Emergency Plan implementing procedures the capability for classifying fuel damage events at the Alert level threshold Completed 07/31/01 RCR 42890 Incorporate in the Emergency Plan implementing procedures the capability to monitor radioactive iodines that have been released to offsite environs Completed 12/04/01 RCR 42895 Perform RTCB trip torgue testing. Due: 9th refueling outage Completed 12/04/01 RCR 42896 Revise nine year RTCB overhaul procedure to specifically require the the Mobilgrease 28 be completely replaced. Due: December 31, 2001 Completed 04/02/02 RCR 42897 Millstone Unit No. 3 will perform a bare metal visual inspection under the insulation. Due:
During the 9th refueling outage Completed 04/02/02 RCR 42898 In support of the bare head visual examination, Millstone Unit No. 3 will do an analysis that demonstrates that a through-wall leak in a penetration nozzle would be detected by this visual inspection. Due: Prior to the next refueling outage.
Completed 07/03/02 RCR 42899 DNC will install a fixed fire suppression system in the CSA. Due: Prior to startup from refueling outage nine Completed
Dominion Nuclear Connecticut, Inc. (Licensee)
Submitted Licensee Commitment Tracking No.
Description Licensee Implementation Status 09/06/02 RCR 42902 DNC will be providing supplemental information for addressing the GL 96-06 Water hammer issue using the methodology included in EPRI Report TR-1135943. Due:
June 15, 2003 Completed 12/13/02 RCR 42904 Operating experience will be reviewed during the annual review required by 10 CFR 54.21 (b) to identify plant-specific concerns with regard to age-related degradation. Due:
December 31, 2005 Completed 07/01/03 RCR 42905 DNC hereby commits to submit a license amendment request to reflect two channels of control room isolation actuation instrumentation. Due: date by July 31, 2004.
Completed 08/07/03 RCR 42906 Dominion will implement the EOP revisions and training before March 31, 2004.
Completed 08/11/03 RCR 42908 Submit Genric Letter 2003-01 requested information for Millstone Units 2 and 3.
Completed 11/17/03 RCR 42909 A bare-metal visual examination of the 58 bottom-mounted instrumentation penetration nozzles will be performed during the currently scheduled Millstone Unit 3 Spring 2004 refueling outage as described in Attachment 2
[of DNC letter B19000 and Serial No. 03-459A].
Completed 11/17/03 RCR 42910 A 360-degree bare-metal visual examination of the bottom-mounted instrumetnation penetration nozzles will be performed during subsequent refueling outages for Millstone Unit 3. These schedules may be adjusted in the future should ongoing research and inspection results justify a less frequent performance-based sample inspection schedule.
Completed 06/01/04 RCR 42912 Provide the MPS 3 control room tracer gas test results and delineate plan and schedule for any proposed changes to the MPS 3 Technical Specifications to verify the integrity of the Control Room Habitability Envelope and the maximum assumed unfiltered in-leakage rates by August 31, 2004 Completed 09/23/04 RCR 42914 Permanent Code repairs for the service water system brazed joint flaws in the safety injection pump cooler 3CCA will be performed by the next cold shutdown of greater than 30 days or the 10th refueling outage,whichever comes first.
Completed
Millstone Power Station, Unit Nos. 2 and 3 cc:
Lillian M. Cuoco, Esquire Senior Counsel Dominion Resources Services, Inc.
Building 475, 5th Floor Rope Ferry Road Waterford, CT 06385 Edward L. Wilds, Jr., Ph.D.
Director, Division of Radiation Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 First Selectmen Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Charles Brinkman, Director Washington Operations Nuclear Services Westinghouse Electric Company 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Senior Resident Inspector Millstone Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Mr. John Markowicz Co-Chair Nuclear Energy Advisory Council 9 Susan Terrace Waterford, CT 06385 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terrys Plain Road Simsbury, CT 06070 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056 Mr. David W. Dodson Licensing Supervisor Dominion Nuclear Connecticut, Inc.
Building 475, 5th Floor Roper Ferry Road Waterford, CT 06385 Mr. J. Alan Price Site Vice President Dominion Nuclear Connecticut, Inc.
Building 475, 5th Floor Rope Ferry Road Waterford, CT 06385 Mr. Chris L. Funderburk Director, Nuclear Licensing and Operations Support Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711