ML052710421
| ML052710421 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 10/25/2005 |
| From: | Martin R NRC/NRR/DLPM/LPD2 |
| To: | Archie J South Carolina Electric & Gas Co |
| Martin R, DLPM, 301-415-1493 | |
| References | |
| TAC MC4249 | |
| Download: ML052710421 (7) | |
Text
October 25, 2005 Mr. Jeffery B. Archie Vice President, Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsville, South Carolina 29065
SUBJECT:
VIRGIL C. SUMMER NUCLEAR STATION - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC4249)
Dear Mr. Archie:
On May 27, 2003, the Nuclear Regulatory Commission (NRC) staff issued Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. LIC-105, provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments for commercial nuclear reactors made by licensees to the NRC staff. LIC-105 provides that the NRC staff will periodically audit the licensees commitment management program.
An audit of the Virgil C. Summer Nuclear Station commitment management program was performed on site, on September 27 and 28, 2004, by Ms. Karen Cotton. The NRC staff conclusions are provided in the enclosed audit report.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager, Section 1 Project Directorate II-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-395
Enclosure:
As stated cc w/encl: See next page
ML052710421 NRR-106 OFFICE PDII-1\\PM PDII-1\\PM PDII-2\\LA PDII-1\\SC NAME KCotton RMartin BClayton E. Marinos DATE 10/19/05 10/19/05 10/19/05 10/25/05
Enclosure AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
DOCKET NO. 50-395
1.0 INTRODUCTION AND BACKGROUND
On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC, (Reference 1) was published. LIC-105 provides the Nuclear Regulatory Commission (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, (Reference 2).
LIC-105 defines a regulatory commitment as 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 also provides for an audit of the licensees commitment management program by the NRC staff.
2.0 AUDIT PROCEDURE AND RESULTS The NRC staff defined the period covered by this audit to be the 3 years prior to the date of the audit. The audit was performed at the Virgil C. Summer Nuclear Station (VCSNS) on September 27 through 28, 2004, by Ms. Karen Cotton. Licensee personnel contacted included R. Clary, R. Sweet and D. Railey.
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 or activities. For commitments that had not yet been implemented, the NRC staff attempted to determine that they have been captured in an effective program for future implementation.
2.1.1 Audit Scope Before the audit, the NRC staff searched ADAMS for the licensees licensing action and licensing activity submittals that were dated within the 3 years prior to the audit. Some of these submittals contain regulatory commitments, but the NRC staff found that there were a small number of commitments meeting the definition in LIC-105. Table 1 lists some of the licensees commitments.
VCSNS commitments are tracked by its Procedure/Commitment Accountability, Corrective Action, and Regulatory Commitment Reduction Programs. The NRC staff attempted to determine, notwithstanding multiple programs, that commitments are continuing to be monitored and the appropriate action taken. During the audit, the NRC staff reviewed reports generated by all three tracking programs, and did not identify concerns related to this issue.
LIC-105 defines the scope of the audit of commitments to those made in writing to the NRC as a result of past licensing actions (amendments, reliefs, exemptions) or generic letter responses, bulletin responses or other docketed correspondence. The audit excluded changes to the Updated Final Safety Analysis Report, Quality Assurance Program, Site Security Plan, Emergency Plan, or other documents governed by a change control mechanism that is embodied in the NRCs regulations.
2.1.2 Audit Results The NRC staff reviewed reports generated by one or more of the three tracking programs for the commitments listed in Table 1 to evaluate the status of completion. The NRC staff found that the licensees commitment tracking programs had appropriately captured these commitments. 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 The NRC staff reviewed the licensees procedure entitled Regulatory Commitment Reduction, NL-121, Revision 3, against NEI 99-04. In particular, in regards to managing a change or deviation from a previously completed commitment, Section 6 specifically uses NEI-99-04 as guidance. Enclosure 8.1 of the licensees procedure provides guidance for safety significance assessments and Enclosure 8.2 provides guidance for NRC Notification requirements. These procedures are part of VCSNSs mechanism for managing commitments in accordance with NEI-99-04.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit, (1) that the commitments listed in Table 1 had been appropriately implemented, and, therefore, the licensees implementation of its commitment management procedures had been effective for these commitments, and (2) the licensees program to manage regulatory commitment changes reflected the use of the NEI guidance.
4.0 REFERENCES
1.
NRR Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC. Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Accession Number ML022750041, dated May 27, 2003.
2.
NEI 99-04, Guidance for Managing NRC Commitment Changes. (Accession Number ML003680088)
Attachment:
Commitment Status Table Principal Contributor: K. R. Cotton Date: October 25, 2005
Attachment TABLE AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION VCSNSs Submittals/
NRC TAC No.
NRC Issuance Summary of Commitment, and Licensees Tracking Number Licensee Implementation Status 12/29/00 MB0251 12/29/2000 SCE&G will perform noble gas sampling & analysis to provide additional verification of RCS Integrity testing with Argon-41, Xenon-133 & Xenon-135. C-00-1392 Complete 02/02/2001 MB0251 12/29/2000 SCE&G revised noble gas sampling & analysis to provide verification of RCS Integrity testing with only Xenon-133 &
Xenon-135. C-00-1392 Complete 07/23/2003 MC0239 7/21/2004 Amendment No. 169 1.a Only PHOENIX/ANC calculation methods are used for the individual plant analyses relevant to determinations for the EOL MTC plant methodology, and 1.b The predictive correction is reexamined if changes in core fuel design or continued MTC calculation/measurement data show significant effect on the predictive correction.
- 2. All of the core performance benchmark criteria, from routine HFP boron concentration measurements, and from flux map surveillances performed during the cycle, must be met before the revised Predicted MTC can be calculated per the prescribed algorithm. C-02-3626 Complete 09/14/2000 MB0066 7/30/2001 Amendment No. 151
- 1) The corrective action program is used by all groups as a process for identifying, classifying, trending, reporting, and correcting situations requiring further review, evaluation and/or action for resolution.
- 2) Quality systems organization performs independent oversight activities during refueling outages, startup activities, and normal and off-normal operational activities.
- 3) Quality Systems performs surveillance activities to verify conformance with specified requirements and industry good practices, and to evaluate their adequacy and effectiveness.
- 4) Plant Support Engineering has primary responsibility for implementing the Maintenance Rule Program.
- 5) Probabilistic Safety Assessment Group monitors plant performance and operating characteristics in the VCSNS.
Complete
Mr. Jeffrey B. Archie VIRGIL C. SUMMER NUCLEAR STATION South Carolina Electric & Gas Company cc:
Mr. R. J. White Nuclear Coordinator S.C. Public Service Authority c/o Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 802 Jenkinsville, South Carolina 29065 Resident Inspector/Summer NPS c/o U.S. Nuclear Regulatory Commission 576 Stairway Road Jenkinsville, South Carolina 29065 Chairman, Fairfield County Council Drawer 60 Winnsboro, South Carolina 29180 Mr. Henry Porter, Assistant Director Division of Waste Management Bureau of Land & Waste Management Dept. of Health & Environmental Control 2600 Bull Street Columbia, South Carolina 29201 Mr. Thomas D. Gatlin, General Manager Nuclear Plant Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 300 Jenkinsville, South Carolina 29065 Mr. Ronald B. Clary, Manager Nuclear Licensing South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88, Mail Code 830 Jenkinsville, South Carolina 29065 Ms. Kathryn M. Sutton Morgan, Lewis & Bockius LLP 111 Pennsylvania Avenue, NW.
Washington, DC 20004