ML051110489
| ML051110489 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/20/2005 |
| From: | Stephen Monarque NRC/NRR/DLPM/LPD2 |
| To: | Christian D Virginia Electric & Power Co (VEPCO) |
| Monarque, S R, NRR/DLPM, 415-1544 | |
| References | |
| TAC MC3325, TAC MC3326 | |
| Download: ML051110489 (13) | |
Text
April 20, 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:
SURRY POWER STATION, UNITS 1 AND 2 - AUDIT OF VIRGINIA ELECTRIC AND POWER COMPANYS MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC3325 AND MC3326)
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 July 22, 2004, the NRC staff performed an audit of Virginia Electric and Power Companys (VEPCOs) commitment management program at Surry 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. 50-280 and 50-281
Enclosure:
Audit Report cc w/encl: See next page
ML051110489 NRR-106 OFFICE PDII-1/PM PDII-2/LA PDII-1/SC NAME SMonarque EDunnington JNakoski DATE 04/19 /2005 04/ 19 /2005 04/20 /2005 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-280 AND 50-281
1.0 INTRODUCTION
On May 27, 2003, 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 Surry Power Station on July 22, 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. All of VEPCOs commitments that are shown on Table 1 were tracked as a Plant Issue Resolution. During the July 22, 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.
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 follow 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 B. Garber P. Kershner Principal Contributor: S. Monarque Date: April 20, 2005
TABLE 1 - LISTING OF REGULATORY COMMITMENTS FOR SURRY VEPCOS TAC VEPCO Summary of Commitment Implementation Submittal NO. Issuance Status April 22, MB9861 Response to This letter provided the following Pending.
2004 and Generic Letter commitment. Submit an The NRC staff has not Ser 03- MB9862 2003 amendment request to incorporate a issued TSTF-448. Plant 373C Control Room control room habitability program Issue Resolutions S-Habitability into the Technical Specifications 2004-1673-R1 and R2 Control Room within six months following either are tracking this action Testing and the approval of TSTF-448 or TSTF- item.
Technical 448 being made available for Information adoption in the Consolidated Line Submittal - for Item Improvement Process (CLIIP)
Surry, Units 1 by the NRC, whichever is later.
and 2.
January 5, MB4583 Response to This letter provided the following Pending 2004 and Bulletin 2002- commitments. (1) The Surry RCS Plant Issue Resolution Ser 02- MB4584 01, Reactor resistance temperature detector S-2003-5130-R4 689A Pressure (RTD) Alloy 600 thermowells will be The Surry procedures Vessel Head incorporated into the boric acid need to be revised to Degradation corrosion control program. (2) Bare include these commitment and Reactor metal visual inspections of the actions. Personnel at Coolant reactor coolant system RTD Alloy Surry Power Station are Pressure 600 thermowells will be performed requesting an extension Boundary during future refueling outages at of the commitment date.
Integrity for Surry.
Surry, Units 1 and 2.
VEPCOS TAC VEPCO Summary of Commitment Implementation Submittal NO. Issuance Status Sep. 22, MC0569 Response to This letter provided the following Plant Issue Resolution 2003 and Bulletin 2003- commitments. (1) A bare-metal S-2003-4245-R1 is Ser 03-459 MC0570 02, Leakage visual examination of the 50 bottom complete as it addressed from Reactor mounted instrumentation the Surry, Unit 2 Pressure penetration nozzles will be inspection during the fall Vessel Lower performed during the Surry, Unit 2 2003 refueling outage.
head fall 2003 refueling outage as Plant Issue Resolution penetrations described in Attachment 1. (2) A S-2003-4245-R2 is and Reactor bare-metal visual examination of the complete, as the Surry, Coolant 50 bottom mounted instrumentation Unit 1 reactor vessel Pressure penetration nozzles will be lower head penetration Boundary performed during the Surry, Unit 1 exam was done during Integrity for fall 2004 refueling outage as the fall 2004 refueling Surry, Units 1 described in Attachment 2. (3) A outage.
and 2 bare-metal visual examination of the Plant Issue Resolutions 50 bottom mounted instrumentation S-2003-4245-R3 and R4 penetration nozzles will be are pending as they performed during subsequent address the inspection at refueling outages for Surry, Units 1 Surry Units 1 and 2 during and 2. This schedule may be subsequent outages, adjusted in the future should beyond the fall 2003 and ongoing research and inspection fall 2004 outages. Surry results justify a less frequent procedures need to be performance based sample revised.
inspection schedule. Plant Issue Resolution S-2003-4245-R6 has been completed. 60-day response to Bulletin 2003-02 was submitted for Surry, Unit 2.
Nov. 14, MB2667 Response to This letter provided the following Plant Issue Resolution 2001 and Bulletin 2001- commitment. Commence a qualified S-2001-2536-R14 has Ser 01- MB2668 01, bare-metal visual inspection of the been completed. The 490B Circumferential reactor vessel head penetrations for inspections did not Cracking of Surry, Unit 2 prior to December 31, identify any penetrations Reactor Vessel 2001. that required additional Head inspection.
Penetrations, Plant Issue Resolution for Surry, Units S-2001-2536-R20 states 1 and 2 that VEPCO will provide the results of the above inspection to the NRC staff. This was completed on January 2, 2002.
VEPCOS TAC VEPCO Summary of Commitment Implementation Submittal NO. Issuance Status August 31, MB2667 Response to This letter provided the following Plant Issue Resolution 2001 and Bulletin 2001- commitments. (1) It is our intention S-2001-2536-R1 has Ser 01-490 MB2668 01, to perform an effective visual been completed for Circumferential inspection of the reactor vessel commitment (1).
Cracking of heads under the insulation for Surry, Plant Issue Resolution Reactor Vessel Unit 1 to inspect for signs of leakage S-2001-2536-R3 has Head around each of the control rod drive been completed for Penetrations, housings and the reactor head vent commitment (2).
for Surry, Units where they penetrate the head Ultrasonic inspections and 1 and 2 during the fall 2001 refueling liquid penetrant testing outages. (2) It is our intention to was performed instead of perform additional inspections from eddy current testing since under the head of North Anna, Unit these tests are more able 1 or Surry, Unit 1 with an eddy to locate cracks.
current procedure capable of Plant Issue Resolutions detecting small surface connected S-2001-2536-R9 and flaws on the inner diameter of the S-2001-2536-R10 have housings, on the outer diameter of been completed for the housings below the inside commitment (3).
surface of the head, and on the J- Circumferential and axial groove attachment welds. The indications were identified inspections are contingent upon the and six penetrations were availability and acceptable repaired on Surry, Unit 1.
performance of the necessary Plant Issue Resolutions equipment and personnel to S-2001-2536-R16 and accomplish the inspections. (3) The S-2001-2536-R17 have NRC staff will be contacted prior to been completed for the evaluation or repair of any commitment (3) for Surry, identified circumferential flaws. Unit 2. No circumferential (4) It is our intention to perform an flaws were found.
effective visual inspection of the Plant Issue Resolution reactor vessel heads under the S-2001-2536-R5 has insulation for Surry, Unit 2 during been completed for the spring 2002 refueling outage. commitment (4). The Surry, Unit 2 inspection was completed in November 2001.
VEPCOS TAC VEPCO Summary of Commitment Implementation Submittal NO. Issuance Status August 31, MB2667 Response to (5) If any of the visual inspections Plant Issue Resolution 2001 and Bulletin 2001- discover evidence of leakage at the S-2001-2536-R12 has Ser 01-490 MB2668 01, junction of the CRDM housings or been completed for Circumferential head vent and the vessel head, it is commitment (5). The Cracking of our intention to perform inspection of the Surry, Reactor Vessel supplemental inspections from Unit 2 reactor head was Head under the vessel head using eddy clean. Additionally, Plant Penetrations, current and ultrasonic inspection Issue Resolution S-2001-for Surry, Units procedures, as appropriate, to 2536-R12 has been 1 and 2 locate the source of the leakage and completed for to characterize any flaws. It is our commitment (5). The intention to perform eddy current inspections of the Surry, and/or ultrasonic inspection Unit 1 reactor vessel head procedures, as appropriate, of an identified potential leaking additional number of housings penetrations. Ultrasonic based on statistical determination of testing and liquid a relevant sample size. The penetrant testing were inspections are contingent upon the performed instead of eddy availability and acceptable current inspection since performance of the necessary they are more able to equipment and personnel to locate cracks in the tube accomplish the inspections. (6) Any or J-groove weld. A total axial indications discovered and of 16 penetrations were sized by the combination of eddy inspected with ultrasonic current and ultrasonic inspection will testing and /or liquid be evaluated in accordance with penetrant testing and requirements consistent with ASME there were six Section XI and as delineated in the penetrations that required ASME paper entitled, Inspection repairs.
and Evaluation of the Reactor Plant Issue Resolutions Vessel Head Penetrations at DC S-2001-2536-R2 and R13 Cook, Unit 2, by WH Bamford, et have been completed for al., 1994. (7) We anticipate that the commitment (6) for Surry, statistical analysis for determining Units 1 and 2. There appropriate scope and schedule for were no axial indications future inspection activities for Surry, discovered at either site.
Unit 2 will be completed and For commitment (7), Plant communicated to the NRC by mid- Issue Resolutions S-November of this year, along with 2001-2536-R11 and R6 the inspection results from under were completed at Surry, the head inspections of North Anna, Units 1 and 2. The Unit 1 or Surry, Unit 1. licensee determined that statistical analysis was not needed to delay the schedule of the reactor vessel head inspections.
These heads were inspected in 2001.
VEPCOS TAC VEPCO Summary of Commitment Implementation Submittal NO. Issuance Status May 21, N/A Annual Report This letter provided a commitment Plant Issue Resolution 2003 and 30-Day to complete the re-analysis of the S-2003-2304-R1 is not Ser 03-350 Report of large-break loss-of-coolant accident expected to be completed Emergency for Surry Power Station by March until March 31, 2006.
Core Cooling 31, 2006.
System Evaluation Model Changes for Surry Power Station, Units 1 and 2
May 14, MB5114 Proposed This letter provided a commitment Plant Issue Resolution 2002 and Technical to modify the Post Maintenance S-2002-1729-R1 has Ser 02-306 MB5115 Specification Testing (PMT) program to address been completed. The Change on the need for a specific evaluation to licensee made several Containment determine if a spray nozzle procedural changes to Spray and inspection or test is necessary to revise the frequency to Recirculation ensure the nozzles remain require testing to be Spray Nozzles unobstructed after maintenance on performed following Surveillance the spray ring headers and other maintenance that could Frequency for appropriate portions of the systems. cause nozzle blockage.
Surry Power Plant Issue Resolution Station, Units 1 S-2002-1729-R2 has and 2 been completed. Training class was conducted.
Plant Issue Resolution S-2002-1729-R3 has been completed. On January 8, 2003, the PMT Program was revised to address this license amendment.
Plant Issue Resolution S-2002-1729-R4 has been completed. The spray nozzle periodic tests have been removed from the periodic test scheduling system as the PMT program will determine when the periodic tests are performed.
Plant Issue Resolution S-2002-1729-R5 has been completed. The Updated Final Safety Analysis Report, Rev. 34 incorporated this amendment.
VEPCOS TAC VEPCO Summary of Commitment Implementation Submittal NO. Issuance Status
April 16, MB6291 Proposed This letter provided the following Plant Issue Resolution 2003 and Technical commitments. (1) The licensee will S-2002-2814-R1 was Ser 03-150 MB6292 Specifications ensure that provisions to obtain fuel completed for Change Buried from Gravel Neck using the station commitment 1.
Fuel Oil Storage tanker truck are verified prior to a Procedures were Tank Inspection buried fuel oil tank being removed developed to remove from and Related from service. (2) In addition to the service and return to Repair Request actions required by the proposed TS service the underground for Additional regarding fuel oil availability, the fuel oil tanks.
Information for licensees planning and scheduling Plant Issue Resolution Surry Power activities to remove a buried fuel oil S-2002-2814-R2 was Station, Units 1 tank from service will specifically completed for and 2 identify restrictions / contingency commitment 2.
measures. (3) Transfer pump Procedures were operability will be verified prior to developed to support the removing a buried fuel oil storage cleaning and inspection of tank from service. the fuel oil tanks.
Plant Issue Resolution S-2002-2814-R2 was completed for these commitments. The provisions for Emergency Diesel Generator Fuel Oil Storage Repair was incorporated into the Updated Final Safety Analysis Report.
Plant Issue Resolution S-2002-2814-R9 was completed for these commitments. The licensee has revised its procedure for obtaining fuel oil from Gravel Neck, if needed. The licensee closed this Plant Issue Resolution because this issue was tracked by Plant Issue Resolution S-2002-2814-R2.
Plant Issue Resolution S-2002-2814-R8 was completed for these commitments. Several procedures were reviewed and were found to be adequate to address fuel oil quality based on tank cleaning.
VEPCOS TAC VEPCO Summary of Commitment Implementation Submittal NO. Issuance Status June 9, MB6291 Proposed This letter provided the following Plant Issue Resolution 2003 and Technical commitments. (1) The S-2002-2814-R3 was Ser 03- MB6292 Specifications implementing procedures for buried completed for these 150A Change Buried fuel oil tank inspection activities will commitments. The Fuel Oil Storage specify that arrival of the first tanker licensee determined the Tank Inspection truck will be within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> specific procedures to and Related following identification of the need needed to obtain oil from Repair Request for the offsite replacement fuel oil. offsite location.
for Additional (2) The implementing procedures Plant Issue Resolution Information for for buried fuel oil tank inspection S-2002-2814-R4 was Surry Power activities will specify that the out of completed for these Station, Units 1 service tank will be returned to an commitments. Operators and 2 available status in an expeditious were trained by manner, if a hurricane or severe September 5, 2003.
thunderstorm / tornado condition is Plant Issue Resolution impending or in the event that S-2002-2814-R5 was emergency diesel generator completed for these operation is required while a buried commitments.
tank is out of service. Plant Issue Resolution S-2002-2814-R4 tracked the employee training.
Plant Issue Resolution S-2002-2814-R6 was completed for these commitments.
Surry Power Station, Units 1 & 2 cc:
Ms. Lillian M. Cuoco, Esq. Office of the Attorney General Senior Counsel Commonwealth of Virginia Dominion Resources Services, Inc. 900 East Main Street Building 475, 5th Floor Richmond, Virginia 23219 Rope Ferry Road Waterford, Connecticut 06385 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Mr. Donald E. Jernigan Dominion Resources Services, Inc.
Site Vice President Innsbrook Technical Center Surry Power Station 5000 Dominion Blvd.
Virginia Electric and Power Company Glen Allen, Virginia 23060-6711 5570 Hog Island Road Surry, Virginia 23883-0315 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 Dr. Robert B. Stroube, MD, MPH State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218