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 NRC VEPCO Summary of Commitment VEPCOs Submittal TAC Issuance Implementation NO. Status 11/5/2001 MB2641 Response to The 11/05/2001 letter provided the Completed.
Ser 01-490A Bulletin 2001-01 following commitment on the inspection The Unit 1 reactor for North Anna, of the reactor vessel upper head. vessel head was Unit 1 (1) Periodic inspection of the indications replaced during the associated with these eight penetrations subsequent (spring (i.e., Penetration Nos. 3, 11, 31, 33, 52, 2003) RFO. NRC Order 57, 60, 66) will be performed during EA-03-009 established subsequent RFO, as required by ASME the inspection Section XI, to minimize the probability of requirements for the a rapidly propagating fracture of the replacement head.
pressure boundary.
01/11/2002 MB2642 Response to The 01/11/2002 letter provided the Completed.
Ser 01-490E Bulletin 2001-01 following commitment regarding the The Unit 2 analysis was for North Anna, inspection of the Unit 2 reactor vessel received on March 22, Unit 2 head. Submit a copy of the final 2002.
metallurgical analysis report, when received from Westinghouse.
04/01/2002 MB4557 Bulletin 2002-01 The 04/01/2002 letter provided the Completed.
Ser 02-168 and for North Anna, following commitment. A qualified bare The Unit 2 RPV head MB4558 Units 1 and 2 metal visual inspection of the reactor was replaced during vessel head inside the ventilation shroud the subsequent (fall will be performed during each scheduled 2002) RFO. Likewise, RFO for North Anna, until each units the Unit 1 RPV head reactor vessel head is replaced. was replaced during the spring 2003 RFO.
09/12/2002 MB5903 Bulletin 2002-02 The 09/12/2002 letter provided a Completed.
Ser 02-491 and for North Anna, commitment to perform a bare metal By letter dated MB5904 Units 1 and 2 visual and best effort non-visual 01/23/2003, the Unit 2 inspection of the RPV head and upper RPV head was head penetrations for the North Anna replaced during the fall units during the next scheduled RFO for 2002 RFO, and the Unit each unit. 1 RPV head was replaced during the spring 2003 RFO.
TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION NRC VEPCO Summary of Commitment VEPCOs VEPCOS TAC Issuance Implementation Submittal NO. Status 02/14/2003 N/A Commitment Revise existing commitment associated Pending. Plant Issue.
Ser 02-633 change for steam with the operation of the SG PORVs. Resolution N-2004-409, generator power VEPCO intends to operated relief submit a basis change valves (SG that incorporates this PORVs) for North revised commitment.
Anna, Unit 2 05/21/2003 N/A 10 CFR 50. 46 Complete re-analysis of the large-break Completed.
Ser 03-350 Annual Report of loss-of-coolant accident for North Anna The re-analysis was ECCS model by June 30, 2004 submitted on changes 6/18/2004.
2/12/2004 MB6957 Request for The 2/12/2004 letter provided the Completed.
Ser 03-494A and amendment to following commitments. (1) entry into Staff issued the MB6958 extend inverter extended inverter completion time will amendments on allowed outage not be planned concurrent with 5/12/2004. VEPCO time emergency diesel generator has completed bases maintenance, and (2) entry into and UFSAR changes extended completion time will be that implement planned concurrent with planned commitments. Refer to maintenance on another RPS/ESFAS Plant Issue Resolution channel. N-2002-3519-R1, N-2002-3519-R7, N-2002-3519-R3 11/17/2003 MC0548 Response to (1) Perform a bare metal visual Completed.
Ser 03-459A and Bulletin 2003-02 examination on the 50 bottom mounted For Units 1 and 2, Plant MC0549 instrumentation penetration nozzles Issue Resolution during the Unit 2 spring 2004 RFO and N-2004-0035-R1 and the Unit 1 Fall 2002 RFO, and (2) N-2004-0035-R2. For perform a bare metal visual examination future outages, of the bottom mounted instrumentation augmented Inspection penetration nozzles during subsequent Manual Attachment 44 RFOs. This schedule may be adjusted in will govern future the future should ongoing research and inspections at both inspection results justify a less frequent units.
inspection schedule.
01/28/04 MC1917 Commitment Eliminates the leak detection system Pending.
Ser 03-348 and change on leak used for monitoring the main steam and Refer to Plant Issue MC1918 detection system main feedwater system piping. Adds a Resolution 2004-0331, used to monitor commitment to modify daily operators daily operator logs high energy piping logs to document no piping or weld 1-LOG-6C and outside of leakage from MS and FW lines in the 2-LOG-6C containment mechanical equipment room.
TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION VEPCOS NRC VEPCO Summary of Commitment VEPCOs Submittal TAC Issuance Implementation NO. Status 11/10/2003 MB4714 License VEPCOs letters dated November 10, Completed.
Ser 03-313G and amendment 2003, January 6, 2004, and June 16, Plant Issue Resolution MB4715 request to replace 2004, provided the following N-2002-0751-R38.
01/06/2004 Westinghouse fuel commitments: (1) Add a 64 degree Ser 03-313J with Framatome penalty to the peak cladding fuel at North Anna, temperature, calculated by disabling the Pending 06/16/2004 Units 1 and 2 Forslund Rohsenow correlation for rod Plant Issue Resolution Ser 03-407A to droplet heat transfer (on the hot rod) N-2002-0751-R39.
when Twall > Tmin. This departure from the methodology in the approved Pending RLBLOCA topical, EMF-2103(P)(A), will Plant Issue Resolution be documented in the UFSAR, N-2002-0751-R40.
(2) the first report of LBLOCA PCT effects made per the provisions of 10 Pending CFR 50.46(a)(3)(ii) following operation Plant Issue Resolution with Framatome fuel will include an N-2002-0751-R43.
additional 8 degree on the reported 95/95 PCT result, and (3) in future North Completed.
Anna RLBLOCA analyses, the assumed Plant Issue Resolution treatment of RWST temperature in the N-2004-0075-R1 containment pressure analyses will be either a biased lower bound or sampled Completed.
range that encompasses the allowable Plant Issue Resolution TS values. This modeling change will be N-2004-0054-R1 incorporated into the first RLBLOCA reanalysis following operation with Pending.
Framatome fuel.
Plant Issue Resolution N-2004-0054-R2 06/18/2004 MB4714 License VEPCOs letter dated June 18, 2004 Completed.
Ser 03-407B amendment provided the following commitment: Plant Issue Resolution request to replace provide confirmation of the adequacy of N-2002-0751-R41, and Westinghouse fuel previous responses to requests for VEPCOs letter dated with Framatome additional information and any June 18, 2004.
fuel at Unit 1 necessary clarifications, resulting from the revised Unit 1 realistic large break LOCA analyses.
06/18/2004 MB4714 License VEPCOs letter dated June 18, 2004, Completed.
Ser 03-313N and amendment provided the following commitment: Plant Issue Resolution MB4715 request to replace VEPCO will conduct a review of N-2002-0751-R42 Westinghouse fuel Framatome ANPs design control with Framatome processes and documentation related to fuel at North Anna, the RLBLOCA analysis for North Anna Units 1 and 2. Units 1 and 2. This review is expected to be completed by July 30, 2004.
Mr. David A. Christian North Anna Power Station Virginia Electric and Power Company Units 1 and 2 cc:
Mr. C. Lee Lintecum Mr. Jack M. Davis County Administrator Site Vice President Louisa County North Anna Power Station Post Office Box 160 Virginia Electric and Power Company Louisa, Virginia 23093 Post Office Box 402 Mineral, Virginia 23117-0402 Ms. Lillian M. Cuoco, Esq.
Senior Counsel Dr. Robert B. Stroube, MD, MPH Dominion Resources Services, Inc. State Health Commissioner Building 475, 5 th floor Office of the Commissioner Rope Ferry Road Virginia Department of Health Waterford, Connecticut 06385 Post Office Box 2448 Richmond, Virginia 23218 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