ML051570075
| ML051570075 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/09/2005 |
| From: | Sean Peters NRC/NRR/DLPM/LPD2 |
| To: | Stinson L Southern Nuclear Operating Co |
| Peters S, NRR/DLPM, 415-1842 | |
| References | |
| TAC MC3949, TAC MC3950 | |
| Download: ML051570075 (10) | |
Text
June 9, 2005 Mr. L. M. Stinson Vice President - Farley Project Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 RE: AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC3949 AND MC3950)
Dear Mr. Stinson:
On May 27, 2003, the Nuclear Regulatory Commission (NRC) staff published the Office of Nuclear Reactor Regulation 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 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 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 Joseph M. Farley Nuclear Plant (FNP) commitment management program was performed on August 16th and 17th 2004. The NRC staff concludes that, based on the audit (1) FNP had implemented NRC commitments on a timely basis; and (2) FNP had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the Enclosed audit report.
Sincerely,
/RA/
Sean E. Peters, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
As stated cc w/encl: See next page
June 9, 2005 Mr. L. M. Stinson Vice President - Farley Project Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 RE: AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC3949 AND MC3950)
Dear Mr. Stinson:
On May 27, 2003, the Nuclear Regulatory Commission (NRC) staff published the Office of Nuclear Reactor Regulation 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 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 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 Joseph M. Farley Nuclear Plant (FNP) commitment management program was performed on August 16th and 17th 2004. The NRC staff concludes that, based on the audit (1) FNP had implemented NRC commitments on a timely basis; and (2) FNP had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the Enclosed audit report.
Sincerely,
/RA/
Sean E. Peters, Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-348 and 50-364
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION: PUBLIC PDII-2 r/f RidsRgn2MailCenter RidsNrrDlpmLpdii RidsNrrDlpmLpdii2 RidsNrrLACHawes RidsNrrPMSPeters RidsOgcRp RidsAcrsAcnwMailCenter Amendment Number: ML051570075 NRR-106 OFFICE PDII-1/PM PDII-1/LA PDII-1/SC NAME SPeters CHawes EMarinos DATE 06/09/05 06/09/05 06/09/05 OFFICIAL RECORD COPY
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
JOSEPH M. FARLEY NUCLEAR PLANT (FNP), UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364
1.0 INTRODUCTION
On May 27, 2003, the NRC staff published NRR 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 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 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 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 the FNP on August 16th and 17th 2004.
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 ADAMS for the licensees licensing action and licensing activity submittals dated in the last 3 years. Some of these submittals contain regulatory commitments, but the NRC staff found that commitments meeting the definition in LIC-105 are few in number. Table 1 lists most, if not all, of the licensees commitments.
The FNP Commitment Tracking System (CTS) is the system used for handling NRC correspondence and tracking NRC commitments and CTS action items. This tracking system is described in FNP Engineering Support Procedure FNP-0-SYP-21.0, NRC Commitment Management. The FNP procedure FNP-0-AP-98, Appendix 1, Methods for Changing NRC Commitments, provides a method for changing NRC commitments and provides documentation of the basis for the changes. During the audit, the NRC staff reviewed reports generated by the tracking program 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 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 CTS for the commitments listed in Table 1 to evaluate the status of completion. The NRC staff found that the licensees commitment tracking programs had captured all the regulatory commitments that were identified by the NRC staff before the audit.
The NRC staff also reviewed plant procedures that had been revised as a result of commitments made by the licensee to NRC. These procedures are identified in the right-hand column of Table 1. The NRC staff noted that some of the revised procedures have annotations Enclosure
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 NRC staff also noted that some revised procedures had not been annotated.
Table 1 summarizes what the NRC staff observed as the current status of licensee commitments.
2.2 Verification of the Licensees Program for Managing NRC Commitment Changes FNP procedure entitled FNP-0-SYP-21.0, NRC Commitment Management, implements the information system that manages NRC commitments, including the identification, tracking, reporting, closure, recordkeeping, and change controls of the commitments. FNP-0-AP-98, Appendix 1, Methods for Changing NRC Commitments, on the other hand, provides a method for changing commitments and provides for documentation of the basis for the change. The NRC staff reviewed these procedures against NEI 99-04, in particular, with regards to managing a change or deviation from a previously completed commitment. These procedures follow the guidance of NEI-99-04 by setting forth the need for identifying, tracking and reporting commitments and by providing a mechanism for commitment changes.
The effectiveness of a procedure can be indicated by the products that are produced by the procedure. 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 review of the licensees information, as well as information from other sources, 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.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit, (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 W. Marlar Principal Contributor: Sean E. Peters Date: June 9, 2005
TABLE 1 (page 1 of 2)
AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION (2001 THROUGH 2004)
FNP NRC NRC Issuance Licensees Tracking Number and Licensee Submittal TAC Summary of Commitment Implementation No. Status 1/24/02, MB4089 Amend. Nos. 156 to CMT # 10587 Complete*
NEL-02-0022 MB4090 NPF-2 and 148 to NPF-8, 5/22/02 Develop contingency plans for obtaining Procedures and analyzing highly radioactive samples of FNP-0-EIP-30.0 reactor coolant, containment sump, and FNP-0-CCP-1300 containment atmosphere. Place into plant procedures.
1/24/02, MB4089 Amend. Nos. 156 to CMT # 10588 Complete*
NEL-02-0022 MB4090 NPF-2 and 148 to NPF-8, 5/22/02 Establish the capability to classify fuel Procedure damage events at the Alert Level threshold. FNP-0-EIP-9.0 Place into plant procedures.
1/24/02, MB4089 Amend. Nos. 156 to CMT # 10589 Complete*
NEL-02-0022 MB4090 NPF-2 and 148 to NPF-8, 5/22/02 Establish and maintain the capability to Procedure monitor radioactive iodines that have been FNP-0-EIP-9.0 released to offsite environs.
1/17/03, NRC Bulletin CMT # 10609 Complete NL-03-0088 2002-01 Perform a semi-annual sample and analysis Procedure of containment atmosphere for iron FNP-0-CCP-201 concentration to detect low level RCS leakage.
8/31/03 MA9495 Amend. Nos. 150 to CMT # 10529 Complete NEL-01-0206 MA9496 NPF-2 and 142 to NPF-8 Add description to FSAR of methodology FSAR Sections 3.3 and used to determine which systems and 3.5 components require protection from tornado missiles by 12/31/04.
7/16/03, MB6406 Amend. Nos. 161 to CMT # 10595 Complete NL-03-1511 MB6407 NPF-2 and 154 to MB9092 NPF-8 When penetration room filtration (PRF), FNP-0-SOP-0.0 MB9093 spent fuel pool room, or control room pressure boundary is opened for other than normal entry, with a breach of size to make boundary inoperable, station adedicated person area with continuous control room communication. Implement Admin controls for rapid restoration of pressure boundary/filter system if needed. Also ensure physical security.
TABLE 1 (page 2 of 2)
FNP NRC NRC Issuance Licensees Tracking Number and Licensee Submittal TAC Summary of Commitment Implementation No. Status 7/16/03, MB6406 Amend. Nos. 161 to CMT # 10596 Complete NL-03-1511 MB6407 NPF-2 and 154 to MB9092 NPF-8 When control room pressure boundary is FNP-0-SOP-0.0 MB9093 inoperable, consider providing temporary closure. Prohibit core alterations and movement of irradiated fuel and loads over irradiated fuel. Implement compensatory measures to require both control room emergency filtration system trains to be operable and make self-contained breathing apparatus or iodine filters for the operators available 7/16/03, MB6406 Amend. Nos. 161 to CMT # 10597 Complete NL-03-1511 MB6407 NPF-2 and 154 to MB9092 NPF-8 Prohibit movement of irradiated fuel when FNP-0-SOP-0.0 MB9093 spent fuel pool room pressure boundary is inoperable. Also, prevent movement of loads over the irradiated fuel. Give consideration to provide a temporary closure barrier should an accident occur.
7/16/03, MB6406 Amend. Nos. 161 to CMT # 10598 Complete NL-03-1511 MB6407 NPF-2 and 154 to MB9092 NPF-8 When the PRF boundary is inoperable, give FNP-0-SOP-0.0 MB9093 consideration to provide a temporary closure barrier. Additionally, implement compensatory measures to require both PRF trains to be operable and require availability of self-contained breathing apparatus or iodine filters for the control room operators.
11/07/01 MB3817 Amend. Nos. 158 to CMT # 10584 Complete NEL-01-0137 MB3818 NPF-2 and 149 to NPF-8 Update FSAR with commitment for special FSAR Section lift devices to comply with ANSI N14.6, as 9.1.4.2.2.5 clarified by NUREG-0612 without exception.
- Except that the cited procedures will need to be annotated (i.e., marked with commitment number) such that future procedure writers would not inadvertently delete or alter items covered by commitments without going thru the commitment change process.
Joseph M. Farley Nuclear Plant, Units 1 & 2 cc:
Mr. J. R. Johnson General Manager Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312 Mr. B. D. McKinney, Licensing Manager Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm P.O. Box 306 1710 Sixth Avenue North Birmingham, AL 35201 Mr. J. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 State Health Officer Alabama Department of Public Health 434 Monroe St.
Montgomery, AL 36130-1701 Chairman Houston County Commission P.O. Box 6406 Dothan, AL 36302 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312