ML060480001
| ML060480001 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/08/2006 |
| From: | Richard Guzman NRC/NRR/ADRO/DORL/LPLA |
| To: | Crane C Exelon Nuclear |
| Guzman R, NRR/DLPM 415-1030 | |
| References | |
| TAC MC9712, TAC MC9713 | |
| Download: ML060480001 (9) | |
Text
March 8, 2006 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - AUDIT OF EXELON GENERATION COMPANY, LLCS MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC9712 AND MC9713)
Dear Mr. Crane:
On May 27, 2003, the Office of Nuclear Reactor Regulation published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]. 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 three years, the NRC staff will audit a licensees commitment management program.
An audit of the commitment management program for Peach Bottom Atomic Power Station (PBAPS) was performed at the Exelon Generation Company, LLC office in Kennett Square, Pennsylvania, on February 13, 2006. Based on the audit, the NRC staff concludes that: (1)
PBAPS had implemented NRC commitments on a timely basis; and (2) PBAPS had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
Richard V. Guzman, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosure:
As stated cc w/encl: See next page
ML060480001 OFFICE LPL1-2/PE LPL1-1/PM LPL1-2/LA LPL1-2/BC NAME TValentine RGuzman CRaynor DRoberts DATE 3/06/06 3/08/06 3/02/06 3/08/06
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY EXELON GENERATION COMPANY, LLC TO THE NUCLEAR REGULATORY COMMISSION FOR PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278
1.0 INTRODUCTION AND BACKGROUND
On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR) published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]. 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 three years.
2.0 AUDIT PROCEDURE AND RESULTS Since no audit, as described above, was performed for Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS) before the issuance of LIC-105, the NRC staff defined the period covered by this audit to go back approximately three years from the date of the audit. The audit was performed at the Exelon Generation Company, LLC (Exelon or the licensee) office in Kennett Square, Pennsylvania, on February 13, 2006.
In support of the audit, the NRC staff reviewed several of the licensees procedures related to commitment management:
Commitment Management, LS-AA-110, Revision 3; Commitment Tracking Program For Use With PIMS [Plant Information Management System], LS-AA-110-1002, Revision 2; Written Communications, LS-AA-117, Revision 4; and Typical Format of Correspondence (as Submitted in Accordance with [Title 10 of the Code of Federal Regulations] 10 CFR 50.4), LS-AA-117-1003, Revision 3.
Specifically, LS-AA-110, Revision 3, was compared to the guidance in NEI 99-04. In general, the licensees procedure follows the guidance closely: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments.
The NRC staff concluded that the licensees procedures appropriately implemented NEI guidance for commitment management. The remainder of the audit evaluated the effectiveness of the procedures by exploring the products produced by the procedures.
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 have yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
2.1.1 Audit Scope Before the audit, the NRC staff reviewed license amendments issued in the last three years.
Some of the licensees submittals for these amendments contain regulatory commitments, but the NRC staff found that commitments meeting the definition in LIC-105 are few in number.
Three license amendments, with a total of seven commitments, were selected for review, as listed in Table 1.
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). Several commitments related to LERs were reviewed to provide a larger sample and better compare the licensees documents to their procedures, but review of these commitments will not be documented.
(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 licensees commitment tracking program, PIMS Commitment Tracking, to evaluate the status of the commitments listed in Table 1. 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 several plant procedures that had been revised as a result of commitments made by the licensee to the NRC. Relevant procedures are identified in the right-hand column of Table 1. Table 1 also 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 Regarding changes to commitments, Subsection 4.5.1 of LS-AA-110, Revision 3, specifically refers to the guidance of NEI-99-04. Attachments 1 and 2 of LS-AA-110, Revision 3, provide details regarding making changes to a commitment. Several changed commitments, as listed in Table 2, were reviewed to confirm that the steps in LS-AA-110, Revision 3, were being followed.
Before changing a commitment, the licensee answers various questions related to the commitments importance to continued safety. Commitments meeting the procedure requirements can be changed with or without notifying the NRC, depending on the circumstances. The NRC staff found that commitments were changed in accordance with licensee procedures and that the NRC was notified appropriately, as in the Biennial Commitment Revision Report submitted by Exelon for PBAPS on January 31, 2005 (ML050350272).
The effectiveness of a procedure can be indicated by the products that are produced by the procedure. As set forth in Section 2.1 and this section, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of the 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 found 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 D. Helker T. Loomis R. Gropp Principal Contributor: T. Valentine Date: March 8, 2006
TABLE 1 WRITTEN COMMITMENTS AND RELATED INFORMATION (2003 THROUGH 2006)
NRC Issuance Summary of Commitment and Licensees Tracking Number Licensee Implementation Status 11/27/2002 MB6921 and MB6922 Amendment Nos. 248 and 251, 5/22/2003 (1) Maintain or develop contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, suppression pool, and containment atmosphere.
(2) Establish capability for classifying fuel damage events at the Alert threshold.
(3) Maintain an I-131 site survey detection capability A1419340 (1) Final safety analysis report changes complete. Chemistry procedure changes for the post accident sampling system are pending.
(2) Complete - classification included in emergency action levels and commitment noted in emergency plan annex, EP-AA-1007, Revision 9.
(3) Complete - field survey teams covered in emergency plan, EP-AA-1000, under 10 CFR 50.54(Q).
10/21/2004 MC4947 and MC4948 Amendment Nos. 254 and 257, 6/14/2005 (1) Provide operating data (described in Generic Letter 97-02) quarterly using industry database.
(2) Provide information annually to support apportionment of station doses to each type of reactor and to differentiate between operating and shutdown units.
A1520265 (1) Complete - changes to procedures LS-AA-2190, LS-AA-2010, and LS-AA-2030.
(2) Complete - changes to procedure ST-H-099-840-2.
9/15/2004 MC4456 and MC4457 Amendment Nos. 256 and 259, 8/11/2005 (1) Maintain hydrogen monitors within Technical Requirements Manual (TRM).
(2) Maintain oxygen monitors within TRM.
A1527599 Complete - TRM Section 3.6, functions 10 and 11.
TABLE 2 CHANGED COMMITMENTS (2003 THROUGH 2006)
Tracking Number Source Justification for Change/Deletion NRC Notification?
T01849 NRC request for additional information, 8/12/1977 Procedures revised for compressed gas cylinder storage and use. Deleted.
No T03067 NRC Inspection Report 81-10/11 Corrective actions taken and radiation protection management procedures improved. No longer tracked.
Yes T03136 NRC Inspection Report 82-24/23 Procedures revised for work areas around open flames. Deleted.
No T03147 NRC Inspection Report 82-19/18 Corrective actions taken and radioactive waste management procedures improved. No longer tracked.
Yes T03507 Licensee Event Report 2-94-07 Procedures revised for fire watch communication. Deleted.
No T04197 NRC Generic Letter 89-13 Routine silt monitoring and intake canal dredging performed. Frequency changed from yearly to every 1490 days.
Yes
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Site Vice President Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Plant Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Regulatory Assurance Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.O. Box 399 Delta, PA 17314 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Roland Fletcher Department of Environment Radiological Health Program 2400 Broening Highway Baltimore, MD 21224 Correspondence Control Desk Exelon Generation Company, LLC P. O. Box 160 Kennett Square, PA 19348 Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Board of Supervisors Peach Bottom Township 545 Broad Street Ext.
Delta, PA 17314-9203 Mr. Richard McLean Power Plant and Environmental Review Division Department of Natural Resources B-3, Tawes State Office Building Annapolis, MD 21401 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236 Manager Licensing-Peach Bottom Atomic Power Station Exelon Generation Company, LLC 200 Exelon Way, KSA -3E Kennett Square, PA 19348
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President-Operations Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director-Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348