ML052800067
| ML052800067 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/21/2005 |
| From: | Michelle Honcharik NRC/NRR/DLPM/LPD4 |
| To: | Edington R Nebraska Public Power District (NPPD) |
| Honcharik M, NRR/DLPM, 301-415-1774 | |
| References | |
| TAC MC5086 | |
| Download: ML052800067 (8) | |
Text
October 21, 2005 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - RE: AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC5086)
Dear Mr. Edington:
An audit of the Nebraska Public Power Districts (NPPD's) commitment management program was performed at the Cooper Nuclear Station on November 16 - 18, 2004. The Nuclear Regulatory Commission (NRC) staff concludes that, based on the audit (1) NPPD has implemented NRC commitments on a timely basis; and (2) NPPD has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff during the audit. If you have any questions, please have your staff contact us.
Sincerely,
/RA/
Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Audit Report cc w/encl: See next page
October 21, 2005 Mr. Randall K. Edington Vice President-Nuclear and CNO Nebraska Public Power District P. O. Box 98 Brownville, NE 68321
SUBJECT:
COOPER NUCLEAR STATION - RE: AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MC5086)
Dear Mr. Edington:
An audit of the Nebraska Public Power Districts (NPPD's) commitment management program was performed at the Cooper Nuclear Station on November 16 - 18, 2004. The Nuclear Regulatory Commission (NRC) staff concludes that, based on the audit (1) NPPD has implemented NRC commitments on a timely basis; and (2) NPPD has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff during the audit. If you have any questions, please have your staff contact us.
Sincerely,
/RA/
Michelle C. Honcharik, Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-298
Enclosure:
Audit Report cc w/encl: See next page DISTRIBUTION:
RidsNrrDlpmLpdiv1 (DTerao)
RidsNrrPMMHoncharik PUBLIC RidsNrrPMBVaidya RidsNrrLADJohnson PDIV-1 r/f RidsAcrsAcnwMailCenter RidsRgn4MailCenter (WWalker)
RidsOgcRp Accession No.:ML052800067 Nrr-106 OFFICE PDIV-1/PM PDIV-1/LA PDIV-1/SC NAME MHoncharik DJohnson DTerao DATE 10/20/05 10/19/05 10/21/05 OFFICIAL RECORD COPY
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION COOPER NUCLEAR STATION DOCKET NO. 50-298
1.0 INTRODUCTION AND BACKGROUND
On September 7, 2004, the Office of Nuclear Reactor Regulation (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 System (ADAMS) Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML042320463), 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, July 1999.
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 SCOPE AND RESULTS 2.1 Audit Scope The audit was performed at Cooper Nuclear Station on November 16 - 18, 2004; in-office work was performed before and after the audit. 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, concentrating on the last 2 years. The primary focus of this part of the audit was to confirm that the licensee had implemented those commitments made to the NRC as part of past licensing actions/activities.
Nebraska Public Power District (NPPD) commitments are computerized in the Regulatory Commitment Tracking System (RCTS). The RCTS can be searched and sorted to produce a variety of reports. The RCTS is an Intranet-based software program that documents regulatory commitments, type, implementation methods, and status. The database also serves as the licensees correspondence tracking system. However, 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 overwhelming majority of the commitments listed in NPPDs RCTS do not qualify as commitments as defined in LIC-105, and were, thus, not audited for one or more of the following reasons:
(1)
Commitments made as a result of Licensee Event Reports, (2)
Commitments made on the licensees own initiative among internal organizational components, (3)
Commitments made as a result of NRC Inspections Reports, and (4)
Commitments as a result of the Confirmatory Action Letter.
In order to generate a list of items for the audit, the NRC staff searched ADAMS for the licensees licensing action and licensing activity submittals dated in the last 3 years.
Additionally, the NRC staff reviewed a computer-generated report listing an estimate of thousands of commitments made over the last several years and selected a number of items to be audited. Then from these lists, the NRC staff selected a representative sample of submittals to audit. Table 1 lists the regulatory commitments (as defined by LIC-105) which the NRC staff audited.
2.2 Audit Results The licenseess RCTS can produce a report on each commitment. Each report is identified by a document ID. If more than one commitment was made in a given document, then a commitment number is assigned in addition to the document ID. The NRC staff reviewed the reports for each of the commitments listed in Table 1 to evaluate the status of completion of various components of each commitment. The NRC staff reviewed the information associated with each commitment to determine the status of completion. The NRC staff found that the licensee<s RCTS captured all the regulatory commitments that were identified by the NRC staff.
The NRC staff also reviewed other sources of information, licensee submittals in particular, to verify implementation of commitments.
Table 1 summarizes what the NRC staff observed as the current status of licensee regulatory commitments in November of 2004. The NRC staff has no basis to dispute the implementation status of these regulatory commitments.
2.3 Verification of the Licensees Program for Managing NRC Commitment Changes The NRC staff reviewed the licensees administrative procedure entitled Regulatory Commitment Tracking, Procedure 0.42.1, Revision 7, against NEI 99-04. In general, Procedure 0.42.1 follows the guidance of NEI 99-04, because it defines NRC Commitment similar to how regulatory commitment is defined in the latter; it identifies persons responsible for managing and tracking commitments; it sets forth the need for identifying, tracking and reporting commitments; and it provides a mechanism for changing commitments.
The effectiveness of a procedure can be indicated by the products that are produced by the procedure. As set forth in Sections 2.1 and 2.3 of this report, 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 RCTS information and information for other sources, the NRC staff found no inconsistencies from the licensees reported status of the audited commitments.
Therefore, 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 has implemented NRC commitments on a timely basis, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT D. Van Der Kamp, Licensing Supervisor N. Robinson, Licensing Staff Member (at time of audit)
Attachment:
Table 1, "Commitment Audit at Cooper Nuclear Station (CNS) Performed November 16 Through November 18, 2004" Principal Contributor: M. Honcharik Date: October 21, 2005
Attachment TABLE 1 COMMITMENT AUDIT AT COOPER NUCLEAR STATION (CNS)
PERFORMED NOVEMBER 16 THROUGH NOVEMBER 18, 2004 Document ID and Commitment Date Status Description/Summary of Commitment NLS20022014 2/26/02 Closed Submit finalized description of modifications needed to configure the main steamline isolation valve leakage pathway.
NLS2003028 3/19/03 Open Due 3/1/06 Following BWRVIP resolution, implement the final BWRVIP recommendations regarding the BWRVIP-25 rim holddown bolt inspection.
NLS2003117 11/10/03 Closed Submit written response to Generic Letter 2003-01.
NLS2003059 9/19/03 Closed Superceded by NLS2003120-01.
NLS2003120-01 11/25/03 Closed Conduct Inservice Testing on core spray pump B, using 0.400 inch/second as the alert limit for vibration points 1H and 5H in accordance with Relief Request RP-06.
NLS2004073 5/28/04 Closed Prior to first use of encryption software for safeguards information material, procedure shall be in place to describe proper use and controls.
NLS2004042-01 3/25/04 Closed Provide supplemental submittal with revised technical specification figures, modifying the amendment request to approve use of the pressure/temperature limit curves for one operating cycle.
NLS2004042-02 3/25/04 Open Due 6/1/05 Fluence recalculations will be performed for previously withdrawn capsules using Regulatory Guide 1.190 methodology.
NLS2002104 12/31/02 Closed Commitment changed, NRC notified appropriately. See NLS2004004.
NLS2004004 1/20/04 Closed Commitment changed, NRC notified appropriately. See NLS2004004-02.
NLS2004111 9/28/04 Closed Multiple commitments regarding one-time extension of the diesel generator allowed outage time.
NLS2000033-02 3/24/00 Closed Make potassium-iodide tablets available to the control room operators.
NLS2003105-04 12/9/03 Open Due 3/1/05 Describe the testing performed for the manual valves in the updated safety analysis report.
July 2005 Cooper Nuclear Station cc:
Mr. William J. Fehrman President and Chief Executive Officer Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. Michael T. Boyce Nuclear Assett Manager Nebraska Public Power District 1414 15th Street Columbus, NE 68601 Mr. John C. McClure Vice President and General Counsel Nebraska Public Power District P. O. Box 499 Columbus, NE 68602-0499 Mr. Paul V. Fleming Licensing Manager Nebraska Public Power District P.O. Box 98 Brownville, NE 68321 Mr. Michael J. Linder, Director Nebraska Department of Environmental Quality P. O. Box 98922 Lincoln, NE 68509-8922 Chairman Nemaha County Board of Commissioners Nemaha County Courthouse 1824 N Street Auburn, NE 68305 Ms. Cheryl K. Rogers, Program Manager Nebraska Health & Human Services System Division of Public Health Assurance Consumer Services Section 301 Centennial Mall, South P. O. Box 95007 Lincoln, NE 68509-5007 Mr. Mike Wells, Deputy Director Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65101 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 218 Brownville, NE 68321 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Director, Missouri State Emergency Management Agency P. O. Box 116 Jefferson City, MO 65102-0116 Chief, Radiation and Asbestos Control Section Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson Suite 310 Topeka, KS 66612-1366 Mr. Daniel K. McGhee Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319 Mr. Scott Clardy, Director Section for Environmental Public Health P.O. Box 570 Jefferson City, MO 65102-0570 Jerry C. Roberts, Director of Nuclear Safety Assurance Nebraska Public Power District P.O. Box 98 Brownville, NE 68321