ML053420528

Commitment Management Audit Letter

ML053420528
Person / Time
Site:	Dresden
Issue date:	12/13/2005
From:	Banerjee M Plant Licensing Branch III-2
To:	Crane C Exelon Generation Co
Banerjee M, NRR/ADPT, 415-2277
References
TAC MC4177, TAC MC4178
Download: ML053420528 (8)

Text

December 13, 2005 Mr. Christopher M. Crane, President and Chief Executive Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, Illinois 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - AUDIT OF LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC4177 AND MC4178)

Dear Mr. Crane:

Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC, is the NRC procedure for handling regulatory commitments made by licensees of commercial nuclear reactors to the NRC staff. LIC-105, Revision 1, dated September 7, 2004, is publically available electronically from the Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Room on the Internet at the NRC web site (ADAMS Accession No. ML042320463). The guidance provided by LIC-105 is consistent with industry guidance prepared by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes.

LIC-105 specifies that the NRR staff will conduct an audit of the licensees commitment management program once every three years. Accordingly, I conducted an audit at the Dresden Nuclear Power Station, Units 2 and 3, between January 24 through 28, 2005, and August 15 through 18, 2005. I selected items from Exelons commitment tracking system printouts provided by the Exelon staff and certain commitments from Exelons letters to the NRC. Based on the results of the audit, I conclude that Exelon has implemented a generally effective program for managing NRC commitment changes. Concerns regarding traceability between commitments and plant procedures along with thresholds for identifying regulatory commitments and including them in the commitment tracking system were discussed with your staff and are included in the enclosed audit report.

Sincerely,

/RA/

Maitri Banerjee, Sr. Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosure:

As stated cc w/encl: See next page

ML042320463). The guidance provided by LIC-105 is consistent with industry guidance prepared by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes.

LIC-105 specifies that the NRR staff will conduct an audit of the licensees commitment management program once every three years. Accordingly, I conducted an audit at the Dresden Nuclear Power Station, Units 2 and 3, between January 24 through 28, 2005, and August 15 through 18, 2005. I selected items from Exelons commitment tracking system printouts provided by the Exelon staff and certain commitments from Exelons letters to the NRC. Based on the results of the audit, I conclude that Exelon has implemented a generally effective program for managing NRC commitment changes. Concerns regarding traceability between commitments and plant procedures along with thresholds for identifying regulatory commitments and including them in the commitment tracking system were discussed with your staff and are included in the enclosed audit report.

Sincerely,

/RA/

Maitri Banerjee, Sr. Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC LPLIII-2 r/f RidsRgn3MailCenter (MRing)

RidsNrrDorlLPLf RidsNRRPMGDick RidsNrrLAPCoates ADAMS ACCESSION NUMBER:ML053420528 OFFICE NRR/LPL3-2/PM NRR/LPL3-2/LA NRR/LPL3-2/BC (A)

NAME MBanerjee PCoates MSLandau DATE 12/13/05 12/12/05 12/13/05 Dresden Nuclear Power Units 2 and 3 cc:

Site Vice President - Dresden Nuclear Power Station Senior Vice President of Operations Exelon Generation Company, LLC Exelon Generation Company, LLC 6500 N. Dresden Road 4300 Winfield Road Morris, IL 60450-9765 Warrenville, IL 60555 Dresden Nuclear Power Station Plant Manager Vice President - Licensing and Regulatory Exelon Generation Company, LLC Affairs 6500 N. Dresden Road Exelon Generation Company, LLC Morris, IL 60450-9765 4300 Winfield Road Warrenville, IL 60555 Regulatory Assurance Manager - Dresden Exelon Generation Company, LLC Director - Licensing and Regulatory Affairs 6500 N. Dresden Road Exelon Generation Company, LLC Morris, IL 60450-9765 4300 Winfield Road Warrenville, IL 60555 U.S. Nuclear Regulatory Commission Dresden Resident Inspectors Office Assistant General Counsel 6500 N. Dresden Road Exelon Generation Company, LLC Morris, IL 60450-9766 200 Exelon Way Kennett Square, PA 19348 Chairman Grundy County Board Manager Licensing - Dresden, Administration Building Quad Cities and Clinton 1320 Union Street Exelon Generation Company, LLC Morris, IL 60450 4300 Winfield Road Warrenville, IL 60555 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, IL 60532-4351 Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 110 East Adams Street Springfield, IL 62701-1109 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO NUCLEAR REGULATORY COMMISSION DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249

1.0 INTRODUCTION

Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC, provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by licensees of commercial nuclear reactors to the NRC staff. LIC-105, Revision 1, dated September 7, 2004, is publically available electronically from the Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Room on the Internet at the NRC web site (ADAMS Accession No. ML042320463). The guidance provided by LIC-105 is consistent with industry guidance prepared by the Nuclear Energy Institute (NEI) in NEI 99-04, Guidance for Managing NRC Commitment Changes.

As described in LIC-105, NRR project managers are expected to audit the licensees commitment management program once every three years by assessing the adequacy of the licensees implementation of a sample of commitments made to the NRC in past licensing actions (amendments, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.). The audit basically consists of two major parts: (1) verification of the licensees implementation of NRC commitments that have been completed and (2) verification of the licensees programs for managing NRC commitment changes.

2.0 BACKGROUND

Two procedures govern the commitment management process at the Dresden Nuclear Power Station. The first document is Procedure LS-AA-110, Commitment Management. This procedure provides guidance for: (1) identification of regulatory commitments and their attributes, (2) defining how commitments are tracked and traceability maintained, (3) defining what is required to ensure appropriate commitment closure, and (4) describing how to extend, change and/or eliminate regulatory commitments.

The second document is Training and Reference Material (T&RM) LS-AA-110-1001, Commitment Tracking Program T&RM for Use with Passport. This T&RM describes the Exelon Commitment Tracking Program (CTP) and establishes the responsibilities, authorities, processes, and organizational interfaces for tracking and assuring compliance with Exelon Regulatory Commitments. It also describes the processing and tracking of Exelon Non-Regulatory Commitments made to external organizations. Passport is the action tracking system used at Dresden.

3.0 AUDIT RESULTS

3.1 Verification of Licensees Implementation of NRC Commitments Many letters from Exelon to the NRC responding to resolution of plant specific or generic safety issues proposed actions by the licensee that were referenced in staff safety evaluations. These actions could include operator actions, procedure revisions, specialized training, pre-briefings, or bringing in specific backup equipment to handle potential contingencies. The audit confirmed that these actions were being tracked within the Passport system. However, some difficulty appears to exist in determining the threshold between intended or planned actions and regulatory commitments. An inconsistency in identification of regulatory commitments in the Passport system was noted in that corrective actions identified in LERs were included as regulatory commitments contrary to Exelon procedure LS-AA-110, however, a commitment made in a licensing action request from Exelon to the NRC was not included in the system.

Actions and commitments were traced to applicable plant procedures. However, in the sample of procedures reviewed to verify regulatory commitment implementation, it was noted that procedure changes were not annotated to indicate why they had been revised. Thus, a procedure writer may not necessarily know why specific changes were made and may propose future changes that may defeat the original commitment.

3.2 Verification of the Licensees Program for Managing NRC Commitment Changes In SECY-00-0045, the staff informed the Commission that the industry document NEI 99-04, Guidelines for Managing NRC Commitments, had been reviewed and found to contain acceptable guidance for controlling regulatory commitments made by power reactor licensees to the NRC staff. The staff reviewed the licensees procedure LS-AA-110, Revision 2, Commitment Management, and found it to be consistent with the guidance found acceptable in NEI 99-04. In particular, the staff focused on Section 4.5, Changing Regulatory Commitments, of LS-AA-110 which included the commitment change process. Therefore, the staff concludes that the licensee has appropriate guidance documents for managing commitment changes.

As part of the audit, the staff examined a number of commitment changes made by the licensee.

3.3 Discussion of Findings Exelon letters to the NRC included in the audit and specific findings are as follows:

• Exelon Letter to the NRC RS-03-174, dated September 19, 2003, Notification of Intent to Perform Analyses Using Vendor Safety Analysis Codes, included the following regulatory commitments:

- Software QA program will be revised to require the licensee to notify vendors of errors discovered in vendor supplied computer codes.

Exelon procedure IT-AA-101, Rev 3, Digital Technology Systems QA Procedure, section 4.5.1, item 3, includes a vendor notification requirement. However,

commitment reference is not stated nor annotated per Exelon procedure LS-AA-110-1001, Rev 0, Commitment Tracking Program T&RM, Step 4.4.3, and LS-AA-110, Rev 2, Commitment Management, Step 4.3.1.

- Revisions to procedures including the instructions and restrictions on the use of CASMO-4/MICROBURN-B2 for tasks related to reactivity anomaly and cold shutdown evaluations will be completed.

It was noted that NF-AB-110-3005, Rev. 1, CASMO-4 Lattice Physics Calculations, and NF-AB-110-3050, Rev.3, Design Cold Shutdown Margin, provide such instructions but the regulatory commitment reference is not stated or annotated in these procedures.

• Exelon letter RS-03-127, dated June 27, 2003, Commitment for Resolution of Steam Dryer Degradation Issue, included the following regulatory commitment:

- EGC will submit a voluntary LER by August 22, 2003, describing event, failure mechanism, root cause, corrective action, and safety significance.

Exelon submitted LER 265/03-004, Reactor Shutdown due to Degraded Reactor Steam Dryer as a result of Increased Steam Velocities from Extended Power Uprate, dated August 22, 2003

• Exelon letter RS-03-088, dated April 30, 2003, modified a commitment in RS-02-187, dated October 25, 2002, with the following regulatory commitment:

- Exelon will examine Dresden Unit 2 Control Rod Drive tube-to-tube welds required by ASME Section XI at the next outage in which reactor is in cold shutdown for at least 4 days.

Dresden Work Order 00462569 indicates completion of the NDE examinations.

However, although this commitment in the subject letters appear to meet the definition of a regulatory commitment per Exelon procedure LS-AA-110, it was not included in the regulatory commitment tracking list provided to the auditor.

• Exelon letter RHLTR #03-0072, dated November 6, 2003, Delay in Completion of USI A-46 Commitment for Dresden Unit 3, included the following regulatory commitment:

- ADS auto blowdown relay replacement will be done by D3R18, fall 2004 (SQUG modification).

Exelon letter SVPLTR #04-0088, dated December 29, 2004, reported completion of this commitment during refueling outage D3R18. The auditor verified that this work, EC 8264, Unit 3 Reactor Building Panel 2203-32-HFA Relay Replacement, was completed under work order WO 522226 on January 28, 2004.

• Exelon letter, RS-02-023, dated February 11, 2002, Evaluation of Radiation Protection Department Work Environment (Response to NRC Chilling Effect Letter), included the following commitment:

- (Performance of) Pre-outage meetings with key work groups prior to (maintenance outage) D3M09 to reiterate corporate and station expectations regarding RP departments stop work authority.

A note from Asst. Radiation Protection (RP) Manager, M. Phalan, included in the computerized assignment tracking system (Action Request (AR) No. 00096141),

recorded completion of the commitment. This record indicated that RP management met with both day and night shift GE and Reactor Services personnel assigned to the refuel floor for the outage and also with Venture personnel. A random population of RP technicians and supervisors attended these meetings to perform observations and feedback to RP management.

• Exelon letter RHLTR #03-0027, 2002 Regulatory Commitment Change Summary Report, dated April 30, 2003, revised a commitment to perform enhanced monitoring and trending of certain Rosemount transmitters by deleting the requirement for transmitters installed in systems with operating pressure less than 500 psig. The inspector noted that Exelon met the requirement in LS-AA-110 for NRC notification via this summary report.

• The following corrective action from LER 2002-003, dated July 8, 2002, Manual Valve Failure Prevents Cooling Water Flow to Control Room Refrigeration Condensing Unit (RCU), was included in the regulatory commitment tracking system:

- During a monthly surveillance, on May 9, 2002, for the control room heating, ventilating and air-conditioning system, the RCU tripped. Disk of a manual isolation valve, found separated, blocked flow to RCU. Frequent exercising in corrosion environment of service water was root cause. Extent of condition review identified similar valves in other systems, and one of the corrective actions was to disassemble and inspect diesel generator cooling water valves that are in similar condition.

A sample checking of the extent of condition review was performed. Dresden work order system indicates diesel generator cooling pump discharge valves 2 (3, 2/3) -3930-500 were opened, inspected and cleaned.

• The following corrective actions from Dresden Unit 2 LER 2002-001-00, Isolation Condenser Time Delay Relays Over Technical Specification Limit of 15 sec on January 18, 2002, dated March 19, 2002, were included in the regulatory commitment tracking system:

- Change set point with adequate margin to the limit,

- Use of chart recorders (prevent use of stopwatches).

Exelon procedures NED-I-EIC-0098, Sustained High Reactor Pressure (Isolation Condenser Initiation) Setpoint error Analysis, and DIS 1300-08, Sustained High Reactor Pressure Time Delay Relay Calibration, implement setpoints with margin, specify use of chart recorders and thus prevent use of a stopwatch.

• The following corrective actions from Dresden Unit 2 LER 2002-004-00, dated July 30, 2002, Control Room Envelope was Breached During Replacement of a Temperature Transmitter (TT), were included in the regulatory commitment tracking system:

- Place a sign in the area to alert individuals about risk to the CR HVAC. This CA was later revised to require no additional signs as existing signs were considered adequate.

A walkdown of the area containing TT2/3-5731-7A revealed multiple signs to contact control room before any work in the area. However, a handwritten note, marking the location of the TT, was found on the duct insulation. The licensee initiated an AR to replace the markings with a permanent sign.

- In addition to a corrective action to train the maintenance work planners on use of barrier control procedure, an assignment for annual training was also included in AR no. 00110467.

Training request forms indicate maintenance work planners were trained on use of CC-AA-201, Plant Barrier Control Program, on December 2002 and January 2003. Annual training was completed in 2003, but missed in 2004 and was not yet scheduled for 2005 when NRC asked the question. Exelon placed the missed 2004 training assignment into the corrective action program via AR 00295192 which resulted in addition of plant barrier integrity training in the Work Planning Annual Training Schedule and the 5 year Work Planing Training Long Range Training Plan.

4.0 CONCLUSION

S The NRC staff concludes that, based upon the above audit: (1) Exelon has implemented NRC commitments on a timely basis, and (2) using procedures based upon the industry guidance found in NEI 99-04, Exelon has implemented an overall effective program for managing NRC commitment changes. Inconsistencies were identified regarding traceability between commitments and plant procedures. In addition, it was not clear how guidance documents differentiated between regulatory commitments and proposed corrective actions.

5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT P. Salas J. Griffin K. Nicely Principal Contributor: M. Banerjee Date: December 13, 2005