ML050940119

Handout Used in Meeting Held on March 30, 2005 Between the U.S. Nuclear Regulatory Commission Staff and the Constellation Energy Group, Inc. Representatives

ML050940119
Person / Time
Site:	Nine Mile Point
Issue date:	03/30/2005
From:	Le N NRC/NRR/DRIP/RLEP
To:	Constellation Energy Group
Le N. B., NRR/DRIP/RLEP, 415-1458
References
Download: ML050940119 (23)

Text

Nine Mile Point Units 1 and 2 LRA Status Update Am ,P~

____,;ietta f-, r 3/30/2005

Agenda

+/-

m Introductions Flaherty m Objectives Flaherty

• Opening Remarks Spina/Hosmer w Recovery Plan Overview Flaherty

- Focus Areas Dellario

. Schedule Flaherty

. Summary Flaherty

. Action Items Flaherty 2

Constellation Attendees I

NAME TITLE John Hosmer VP - Technical Services Jim Spina Site VP - NMP Mark Flaherty Mgr Fleet Licensing David Dellario License Renewal Project Mgr Jeff Jeffries Sr. Licensing Consultant Keith Cunningham Director - Generation Communications 3

Objectives

• Explain causes of the quality issues

• Outline the recovery plan

• Establish communications protocol with the NRC mIdentify schedule and actions items going forward 4

Opening Remarks

• Constellation management views

- Acknowledge quality issues

- In response:

• Direct engagement of senior management in the project

• Assigned significantly more resources

• Established checks and balances

• Clearly delineate roles and responsibilities

• Establishing Site Champions (active site engagement) 5

Opening Remarks How did we get here?

Cause Corrective Action Culture of minimal compliance Reorganized under Fleet Licensing; benchmarking; outside experts Lack of questioning attitude and over Same reliance on CCNPP LR experience Project roles, responsibilities, and Reorganized under Fleet Licensing; accountability not clearly established clear roles and responsibilities; written expectations; direct senior management involvement Poor internal and external Use of communications plan communications

Recovery Plan Overview

• Methodology

• Resources

• Project Controls

• Communication Plan

• Focus Areas

- NSR Scoping

- Licensing

- Programs 7

Recovery Plan Overview Methodology

+

• Completed

- Identified gaps m Benchmarking (will include review of Beaver Valley issues)

- Developed a plan

• Going Forward

- Capture plan in project procedures

- Conduct work per procedures including use of pilots

- Extensive use of Challenge Boards

• Critical and independent review of product

• Members include affected site organizations, SMEs, licensing I etc

- Strong constructive interface with the NRC

- Utilize project controls to ensure quality goals are met

- Continue to identify gaps through benchmarking, industry forums, etc. 8

Recovery Plan Overview Reso urces

• Project relocated under Fleet Licensing

• Project resources significantly increased rv 30 personnel now working on project

- Senior Licensing Consultant added

- Hired outside LR experience (DC Cook and Brunswick)

- Site Champions (Operations, Maintenance, Work Control, Training, Engineering, and Chemistry)

• Relocated project personnel to NMP

• Independent project advisor assigned to CNO

• Accountability clearly established for project personnel 9

Recovery Plan Overview Resou rces e _________________________

What is Different?

• Direct senior mgmt involvement eClear accountability

-Use established Licensing tools 10

Recovery Plan Overview Resources 11

Recovery Plan Overview Project Controls v Developing Key Performance Indicators (KPIs) to communicate progress

- Schedule compliance

- Quality

• Continuous quality assessments

- External

• CNO Technical Advisor

• NRC feedback

- Internal

• Weekly internal self-assessments mQPA assessments a Senior Licensing Consultant 12

Recovery Plan Overview Communication Plan

• Proposed NRC interaction

- Frequent calls to NRC LR PM from NMP PM

- Bi-weekly meetings with NRC LR Program Director

• Constellation VP or Manager attends

• Internal communications

- Daily project call with corporate and site management

- Weekly status calls with:

• CNO

• NMP Site VP

- Weekly updates at NMP "Plan of Day" meeting

• Make available lessons learned to industry via NEI 13

Recovery Plan Overview Focus Areas

.+.

m Benchmarking identified 3 recovery focus areas

- (a)(2) Scoping - (NSR)

- Licensing/RAI

- Programs m Detailed recovery plans created for each focus area

• Similar themes for each focus area

- Benchmarking

- Challenge and confirm results

- Strong constructive interface with the NRC 14

Recovery Plan Overview Focus Areas - NSR Scoping Re-performing NSR Scoping evaluation

- Will use most current standards and expectations in new. evaluation e Benchmarked most recent applications e Will use NUREG-1800, Draft 1 and NEI 95-10, Rev 5 as basis documents

- Represent the latest standards

- Will not use the'exclusion' provisions in NEI 95-10

- Result to be reflected in LRA 15

Recovery Plan Overview Focus Areas - NSR Scoping

• LRA update includes:

- Methodology section to be expanded to provide details of evaluation

- Description of NSR portions in-scope will be clarified

- NSR component types to be included with SR component types

- Component functions will be the same as those defined in NUREG-1800, Draft 1, Table 2.1-4(a) & (b)

- AMR tables will be revised to reflect the component types and functions

- Assigned AMPs will be consistently applied for the appropriate material/environment combination 16

Recovery Plan Overview Focus Areas Licensing/RAIs e RAI response effort is composed of 4 tasks:

- Review and update previously answered RAIs and Audit / Inspection questions

- Ensure extent of condition is appropriate for previously identified changes to the LRA

- Review RAI responses by 6 most recent LRAs to self-identify and resolve potential NRC questions

- Generate responses for existing unanswered RAIs 17

Recovery Plan Overview Focus Areas - Licensing/RAIs c All RAIs will:

- Be reviewed against industry data base for RAI responses and NRC acceptance

- Require a Challenge Board to review all responses

- LR Team meeting with NRC to discuss draft responses

• Revision and control of the LRA:

- Changes to be controlled by LRA Owner and lone editor n Markups to be used similar to TS change process

- Ensure extent of condition is addressed 18

Recovery Plan Overview Focus Areas - Programs Program Basis Documents (PBDs) upgrade

- Benchmarked most recent LRAs to identify gaps:

• More consistent and detailed documentation to support GALL assessments

• Identification of specific implementing site documents

• Improved document basis capture

• Address both known and anticipated NRC concerns related to AMPs

• Create "audit trail" from the AMR to implementing activity

- Will create new PBD template and pilot

- Incorporate lessons learned, train team, and fully implement 19

Recovery Plan Overview Focus Areas - Programs mImplementation will include:

Review and update !site implementing documents for 21 off38 LR programs

- Completely finish 4-5 programs and implement new programs

• Demonstrates an established process for updating and establishing new plant procedures and programs 20

Schedule C Quality product is highest priority

• Plan to update LRA by mid-July 2005

• Technical work has begun, remainder will begin by 4/4/05

• Anticipate/desire interaction with NRC prior to update submittal, e.g.,

- Discuss proposed RAI responses

- Discuss changes to NSR Scoping 21

Summary

• What is different?

- Direct engagement of senior management

- Clear focus on quality

- New organization

• Clear roles and responsibilities

• Accountable to Fleet Licensing Manager

• Relocated to NMP site

• More resources added, including use of Site Champions

- Use aggressive independent oversight

- Use established licensing tools and processes 22

Action Items mSchedule next meeting

- Review sample products

• Method of marking up LRA

• RAI resolution

- Review schedule 23