ML050540459
| ML050540459 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/16/2005 |
| From: | Stephen Monarque NRC/NRR/DLPM/LPD2 |
| To: | Christian D Virginia Electric & Power Co (VEPCO) |
| Monarque, S R, NRR/DLPM, 415-1544 | |
| References | |
| TAC MC3323, TAC MC3324 | |
| Download: ML050540459 (9) | |
Text
February 16, 2005 Mr. David A. Christian Sr. Vice President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, Virginia 23060-6711
SUBJECT:
NORTH ANNA POWER STATION, UNITS 1 AND 2 - AUDIT OF VIRGINIA ELECTRIC AND POWER COMPANYS MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC3323 AND MC3324)
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 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institutes (NEIs) 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.
On June 23, 2004, the NRC staff performed an audit of Virginia Electric and Power Companys (VEPCOs) commitment management program at North Anna Power Station, Units 1 and 2.
The NRC staff concludes that based on the audit (1) VEPCO had implemented NRC commitments on a timely basis, and (2) VEPCO had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
Stephen Monarque, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-338 and 50-339
Enclosure:
Audit Report cc w/encl: See next page
ML050540459 OFFICE PDII-1/PM PDII-2/LA PDII-1/SC NAME SMonarque EDunnington JANakoski DATE 2/15/05 2/15/05 2/16/05
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-338 AND 50-339
1.0 INTRODUCTION
On May 27, 2003, the 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 Institutes (NEIs) NEI 99-04, Guidance for Managing NRC Commitment Changes.
According to LIC-105 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 at North Anna Power Station on June 23, 2004.
The primary focus of the audit was to confirm that Virginia Electric and Power Company (VEPCO) 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 ascertained that they had been captured in an effective program for future implementation.
2.1 Audit Scope Before the audit, the NRC staff searched ADAMS for VEPCOs licensing action and licensing activity submittals dated in the last 3 years. These commitments are shown on Table 1.
Enclosure VEPCOs commitments are tracked by the Corrective Action System. The Corrective Action System is a computer database that is used to assign and track commitments to an effective completion. Commitments that are entered into the Corrective Action System are either tracked as a Plant Issue Resolution or on a Commitment Data form. Most of VEPCOs commitments that are shown on Table 1 were tracked as a Plant Issue Resolution. During the June 23, 2004 audit, the NRC staff reviewed the Plant Issue Resolution reports, VEPCOs submittals, and other documents related to the commitments.
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 VEPCOs LER process, which is imposed by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.73.
(2)
Commitments made on VEPCOs own initiative among internal organizational components and not reported to the NRC staff.
(3)
Commitments integrated into the Updated Final Safety Analysis Reports, Quality Assurance Program, Site Security Plan, Emergency Plan, or other documents governed by a change control mechanism contained in regulations such as 10 CFR 50.59 or 50.54.
2.2 Audit Results The NRC staff reviewed reports generated by the Corrective Action System for the commitments listed in Table 1 in order to evaluate the status of completion. The NRC staff found that VEPCOs commitment tracking program had captured all of the pending regulatory commitments that were identified by the NRC staff. The NRC staff also reviewed plant issue resolutions that had been revised as a result of commitments made by VEPCO to NRC. These procedures are identified in the right-hand column of Table 1.
The NRC staff reviewed several of VEPCOs commitments that had been impacted by the replacement of the reactor pressure vessel (RPV) heads. VEPCO had committed to several inspections of the RPV upper heads; however, these inspections were no longer being performed because these heads had been replaced. For instance, the NRC staff reviewed VEPCOs commitment to perform bare-metal visual inspections of the RPV upper heads during future refueling outages (RFOs) at North Anna until these heads were replaced. Because VEPCO replaced the RPV upper heads in a subsequent RFO, this negated the need to continue to perform these inspections. Therefore, the NRC staff considers this commitment to have been completed.
By letter dated November 5, 2001, VEPCO committed to inspect Penetration Nos. 3, 11, 31, 33, 52, 57, 60, and 66 at North Anna, Unit 1 during subsequent RFOs. While performing an RPV upper head examination during the fall 2001 RFO, VEPCO had discovered relevant indications on these eight penetrations. As a result, VEPCO made a commitment to inspect these eight penetrations. Additionally, as part of its response to Bulletin 2002-02, Reactor Pressure Vessel Head and Vessel Head Penetration Nozzle Inspection Programs, dated September 12, 2002, VEPCO made another commitment to perform a bare-metal visual and best effort non-visual inspection of the RPV upper head at North Anna during the next RFO for each unit.
During the spring 2003 and fall 2002 RFOs, VEPCO replaced the RPV upper heads for North Anna, Units 1 and 2, respectively. This action nullified the need to inspect the replaced RPV upper heads and their penetrations. Furthermore, NRC Order EA-03-009, Issuance of First Revised NRC Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors, dated February 20, 2004, provides the inspection requirements for the replacement RPV upper heads. As such, the NRC staff considers these commitments involving the inspection of the replaced RPV upper heads to be completed.
2.3 Verification of VEPCOs Program for Managing NRC Commitment Changes The NRC staff reviewed VEPCOs procedure entitled Commitment Management, VPAP-2801, Revision 3, against NEI 99-04. Attachments 3 and 4 of VPAP-2801, Revision 3 provide details on the commitment management process that closely follows the guidance of NEI-99-04. In general, VPAP-2801, Revision 3 follows 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 NRC staff found that VEPCO had properly addressed each regulatory commitment selected for this audit. As a result of reviewing VEPCOs information, as well as information from other sources, the NRC staff found no reason to differ from VEPCOs reported status of the audited commitments. Thus, the NRC staff concludes that the procedure used by VEPCO to manage commitments is appropriate and effective.
3.0 CONCLUSION
The NRC staff concludes that based on the above audit: (1) VEPCO had implemented, or is tracking for future implementation, regulatory commitments; and (2) VEPCO had implemented an effective program to manage regulatory commitment changes.
4.0 VEPCO PERSONNEL CONTACTED FOR THIS AUDIT M. Whalen J. Leberstein Principal Contributor: S. Monarque Date: February 16, 2005
TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION VEPCOS Submittal NRC TAC NO.
VEPCO Issuance Summary of Commitment VEPCOs Implementation Status 11/5/2001 Ser 01-490A MB2641 Response to Bulletin 2001-01 for North Anna, Unit 1 The 11/05/2001 letter provided the following commitment on the inspection of the reactor vessel upper head.
(1) Periodic inspection of the indications associated with these eight penetrations (i.e., Penetration Nos. 3, 11, 31, 33, 52, 57, 60, 66) will be performed during subsequent RFO, as required by ASME Section XI, to minimize the probability of a rapidly propagating fracture of the pressure boundary.
Completed.
The Unit 1 reactor vessel head was replaced during the subsequent (spring 2003) RFO. NRC Order EA-03-009 established the inspection requirements for the replacement head.
01/11/2002 Ser 01-490E MB2642 Response to Bulletin 2001-01 for North Anna, Unit 2 The 01/11/2002 letter provided the following commitment regarding the inspection of the Unit 2 reactor vessel head. Submit a copy of the final metallurgical analysis report, when received from Westinghouse.
Completed.
The Unit 2 analysis was received on March 22, 2002.
04/01/2002 Ser 02-168 MB4557 and MB4558 Bulletin 2002-01 for North Anna, Units 1 and 2 The 04/01/2002 letter provided the following commitment. A qualified bare metal visual inspection of the reactor vessel head inside the ventilation shroud will be performed during each scheduled RFO for North Anna, until each units reactor vessel head is replaced.
Completed.
The Unit 2 RPV head was replaced during the subsequent (fall 2002) RFO. Likewise, the Unit 1 RPV head was replaced during the spring 2003 RFO.
09/12/2002 Ser 02-491 MB5903 and MB5904 Bulletin 2002-02 for North Anna, Units 1 and 2 The 09/12/2002 letter provided a commitment to perform a bare metal visual and best effort non-visual inspection of the RPV head and upper head penetrations for the North Anna units during the next scheduled RFO for each unit.
Completed.
By letter dated 01/23/2003, the Unit 2 RPV head was replaced during the fall 2002 RFO, and the Unit 1 RPV head was replaced during the spring 2003 RFO.
TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION VEPCOS Submittal NRC TAC NO.
VEPCO Issuance Summary of Commitment VEPCOs Implementation Status 02/14/2003 Ser 02-633 N/A Commitment change for steam generator power operated relief valves (SG PORVs) for North Anna, Unit 2 Revise existing commitment associated with the operation of the SG PORVs.
Pending. Plant Issue.
Resolution N-2004-409, VEPCO intends to submit a basis change that incorporates this revised commitment.
05/21/2003 Ser 03-350 N/A 10 CFR 50. 46 Annual Report of ECCS model changes Complete re-analysis of the large-break loss-of-coolant accident for North Anna by June 30, 2004 Completed.
The re-analysis was submitted on 6/18/2004.
2/12/2004 Ser 03-494A MB6957 and MB6958 Request for amendment to extend inverter allowed outage time The 2/12/2004 letter provided the following commitments. (1) entry into extended inverter completion time will not be planned concurrent with emergency diesel generator maintenance, and (2) entry into extended completion time will be planned concurrent with planned maintenance on another RPS/ESFAS channel.
Completed.
Staff issued the amendments on 5/12/2004. VEPCO has completed bases and UFSAR changes that implement commitments. Refer to Plant Issue Resolution N-2002-3519-R1, N-2002-3519-R7, N-2002-3519-R3 11/17/2003 Ser 03-459A MC0548 and MC0549 Response to Bulletin 2003-02 (1) Perform a bare metal visual examination on the 50 bottom mounted instrumentation penetration nozzles during the Unit 2 spring 2004 RFO and the Unit 1 Fall 2002 RFO, and (2) perform a bare metal visual examination of the bottom mounted instrumentation penetration nozzles during subsequent RFOs. This schedule may be adjusted in the future should ongoing research and inspection results justify a less frequent inspection schedule.
Completed.
For Units 1 and 2, Plant Issue Resolution N-2004-0035-R1 and N-2004-0035-R2. For future outages, augmented Inspection Manual Attachment 44 will govern future inspections at both units.
01/28/04 Ser 03-348 MC1917 and MC1918 Commitment change on leak detection system used to monitor high energy piping outside of containment Eliminates the leak detection system used for monitoring the main steam and main feedwater system piping. Adds a commitment to modify daily operators logs to document no piping or weld leakage from MS and FW lines in the mechanical equipment room.
Pending.
Refer to Plant Issue Resolution 2004-0331, daily operator logs 1-LOG-6C and 2-LOG-6C
TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION VEPCOS Submittal NRC TAC NO.
VEPCO Issuance Summary of Commitment VEPCOs Implementation Status 11/10/2003 Ser 03-313G 01/06/2004 Ser 03-313J 06/16/2004 Ser 03-407A MB4714 and MB4715 License amendment request to replace Westinghouse fuel with Framatome fuel at North Anna, Units 1 and 2 VEPCOs letters dated November 10, 2003, January 6, 2004, and June 16, 2004, provided the following commitments: (1) Add a 64 degree penalty to the peak cladding temperature, calculated by disabling the Forslund Rohsenow correlation for rod to droplet heat transfer (on the hot rod) when Twall > Tmin. This departure from the methodology in the approved RLBLOCA topical, EMF-2103(P)(A), will be documented in the UFSAR, (2) the first report of LBLOCA PCT effects made per the provisions of 10 CFR 50.46(a)(3)(ii) following operation with Framatome fuel will include an additional 8 degree on the reported 95/95 PCT result, and (3) in future North Anna RLBLOCA analyses, the assumed treatment of RWST temperature in the containment pressure analyses will be either a biased lower bound or sampled range that encompasses the allowable TS values. This modeling change will be incorporated into the first RLBLOCA reanalysis following operation with Framatome fuel.
Completed.
Plant Issue Resolution N-2002-0751-R38.
Pending Plant Issue Resolution N-2002-0751-R39.
Pending Plant Issue Resolution N-2002-0751-R40.
Pending Plant Issue Resolution N-2002-0751-R43.
Completed.
Plant Issue Resolution N-2004-0075-R1 Completed.
Plant Issue Resolution N-2004-0054-R1 Pending.
Plant Issue Resolution N-2004-0054-R2 06/18/2004 Ser 03-407B MB4714 License amendment request to replace Westinghouse fuel with Framatome fuel at Unit 1 VEPCOs letter dated June 18, 2004 provided the following commitment:
provide confirmation of the adequacy of previous responses to requests for additional information and any necessary clarifications, resulting from the revised Unit 1 realistic large break LOCA analyses.
Completed.
Plant Issue Resolution N-2002-0751-R41, and VEPCOs letter dated June 18, 2004.
06/18/2004 Ser 03-313N MB4714 and MB4715 License amendment request to replace Westinghouse fuel with Framatome fuel at North Anna, Units 1 and 2.
VEPCOs letter dated June 18, 2004, provided the following commitment:
VEPCO will conduct a review of Framatome ANPs design control processes and documentation related to the RLBLOCA analysis for North Anna Units 1 and 2. This review is expected to be completed by July 30, 2004.
Completed.
Plant Issue Resolution N-2002-0751-R42
Mr. David A. Christian North Anna Power Station Virginia Electric and Power Company Units 1 and 2 cc:
Mr. C. Lee Lintecum County Administrator Louisa County Post Office Box 160 Louisa, Virginia 23093 Ms. Lillian M. Cuoco, Esq.
Senior Counsel Dominion Resources Services, Inc.
Building 475, 5 th floor Rope Ferry Road Waterford, Connecticut 06385 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Old Dominion Electric Cooperative 4201 Dominion Blvd.
Glen Allen, Virginia 23060 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.
Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, Virginia 23060-6711 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Senior Resident Inspector North Anna Power Station U. S. Nuclear Regulatory Commission 1024 Haley Drive Mineral, Virginia 23117 Mr. Jack M. Davis Site Vice President North Anna Power Station Virginia Electric and Power Company Post Office Box 402 Mineral, Virginia 23117-0402 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218