ML060680502
| ML060680502 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  (NPF-014, NPF-022) |
| Issue date: | 11/18/2004 |
| From: | Richard Guzman NRC/NRR/DLPM/LPD1 |
| To: | Shriver B Susquehanna |
| References | |
| TAC MC3961, TAC MC3962 | |
| Download: ML060680502 (9) | |
Text
s0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 18, 2004 Bryce L. Shriver President-PPL Generation and Chief Nuclear Officer PPL Susquehanna, LLC Two North Ninth Street Allentown, PA 18101
SUBJECT:
SUSQUEHANNA STEAM ELECTRIC STATION UNIT NOS. 1 AND 2 (SSES 1 AND 2) - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MC3961 AND MC3962)
Dear Mr. Shriver:
On May 27, 2003, the Office of Nuclear Reactor Regulation Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]," was published. 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 licensee's commitment management program.
An audit of the commitment management program for PPL Susquehanna, LLC (PPL, the licensee) was performed onsite and in the NRC office. The NRC staff concludes that, based on the audit (1) PPL had implemented NRC commitments on a timely basis; and (2) PPL's program for managing NRC commitment changes is effective. Details of the audit are set forth in the enclosed audit report.
Sincerely, Richard V. Guzman, Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388
Enclosure:
As stated cc w/encl: See next page
`9to UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
SUSQUEHANNA STEAM ELECTRIC STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-387 AND 50-388
1.0 INTRODUCTION AND BACKGROUND
On May 27, 2003, the 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 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, a "regulatory commitment" as defined in NEI 99-04 and also for the NRC staff, 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 licensee's commitment management program by assessing the adequacy of the licensee's 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, as described above, was performed for PPL Susquehanna, LLC (PPL, the licensee) 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 Susquehanna Steam Electric Station, Units 1 and 2 (SSES 1 and 2) on August 19, 2004; in-office work was performed before and after the audit.
In support of the audit, the NRC staff reviewed several of PPL's procedures related to commitment management:
"Regulatory Open Items/Commitments," NDAP-QA-0750, Revision 5; "NRC Correspondence," NDAP-QA-0729, Revision 5; "Condition Report," NDAP-QA-0702.
Specifically, NDAP-QA-0750, Revision 5, was compared to the guidance in NEI 99-04. In general, the licensee's 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 licensee's 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 Licensee's 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 PPL's commitments are computerized under the title, "Nuclear Information Management System (NIMS)." There are two NIMS search screens where commitments can be found; for purpose of the audit, the WMAMMAIN screen search tool was used. The NRC staff reviewed a computer-generated report listing 37 PPL, Nuclear Regulatory Affairs (NRA) Commitments. In addition, before the audit, the NRC staff reviewed license amendments issued in the last 3 years. Some of the licensee's submittals for these amendments contain regulatory commitments, but the NRC staff found that commitments meeting the definition in LIC-1 05 are few in number. Two license amendments and one licensing activity were selected for review, as listed in Table 1.
LIC-1 05 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 licensee's documents to their procedures, but review of these commitments will not be documented.
(2)
Commitments made on the licensee's 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 licensee's commitment tracking program, NIMS, to evaluate the status of the commitments listed in Table 1. The licensee's NIMS produces a report on each commitment. Each report is identified by a commitment number.
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. In general, each commitment comprises multiple components, such as revising appropriate plant procedures, revising appropriate sections of the UFSAR, revising training manuals, and training personnel.
The NRC staff reviewed the information associated with each commitment to determine the status of completion. The NRC staff found that the licensee's NIMS captured all the regulatory commitments that were identified by the NRC staff before the audit.
The NRC staff also reviewed other sources of information, in particular licensee submittals, to verify implementation of commitments. The review results are shown in the last column on the right of Table 1, where appropriate.
Table 1 summarizes what the NRC staff observed as the current status of licensee commitments. The NRC staff has no basis to dispute the implementation status of these regulatory commitments.
2.2 Verification of the Licensee's Program for Managing NRC Commitment Changes Regarding changes to commitments, Section 6.3 of NDAP-QA-0750, Revision 5, specifically refers to the guidance of NEI-99-04. Attachments A, B, and C of NDAP-QA-0750, Revision 5, provide details of the Regulatory Commitment Change Evaluation process.
Before changing a commitment, the licensee answers various questions related to the commitment's 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 letter, "10 CFR 50.59 Summary Report and Changes to Regulatory Commitments," submitted by PPL for SSES 1 and 2 on October 8, 2004 (ML042940283).
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 licensee's NIMS information, as well as information from other sources, the NRC staff found no reason to differ from the licensee's 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 NRC commitments on a timely basis; and (2) the licensee's program for managing NRC commitment changes is effective.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT M. Crowthers D. Filchner B. O'Rourke Principal Contributor: R. Guzman Date:
TABLE 1 WRITTEN COMMITMENTS AND RELATED INFORMATION (2001 THROUGH 2004)
PPL NRC NRC Summary of Commitment Licensee Implementation Submittal TAC Issuance and Licensee's Tracking Status No.
Number 8/11/2003 MB9863 NRC Generic (1) PPL to perform design Complete - PLA-571 1, PPL letter and Letter 2003-01:
review to confirm that dated 2/3/2004 MB9864 Control Room applicable design and Habitability regulatory requirements are (CRH) met for postulated radiological and hazardous chemical release events.
(2) PPL to provide basis for determination of the necessity for unfiltered rate testing and schedule for any further action (3) PPL to validate that no compensatory measures have been taken that were required to demonstrate compliance to CRH requirement 2/3/2004 MB9863 Under Review (1) PPL to provide a dose (1) Ongoing commitment and consequence submittal to the
(#554989)
MB9864 NRC, using the methodology described in RG 1.183 by (2), (3) Ongoing commitment 6/30/2005
(#554977).
(2) PPL to notify NRC if release of an inventory of hazardous chemicals, transported by railroad, is not imminent - OR - if inventory received by July 30, 2004, PPL will complete the hazardous chemical control room habitability assessment.
(3) PPL to comply with RG 1.78, Rev.1 and will be incorportated into the FSAR.
9/18/2003 MB9008 Amendment Submit TS Amendment request Complete - PLA-5686 submitted No. 215 for for Oscillation Power Range on 12/22/2003 Unit 1, Monitor (OPRM) by 12/30/2003 10/29/2003 9/18/2003 MB9009 Amendment Submit TS Amendment request Complete - PLA-5686 submitted No. 190 for for Oscillation Power Range on 12/22/2003 Unit 2, Monitor by 12/30/2003 10/29/2003 9/28/2004 MC1659 Amendment Implement new Oscillation Complete - NRC approved No. 217 for Power Range Monitor Trip OPRM for SSES 1 Unit 1, Setpoints utilizing revised implementation on 11/9/2004.
11/9/2005 methodology by 9/30/2004.
(#539044) 9/28/2004 MC1 660 Amendment Implement new Oscillation Complete - NRC approved No. 192 for Power Range Monitor Trip OPRM for SSES 2 Unit 2, Setpoints utilizing revised implementation on 1119/2004.
11/9/2005 methodology by 9/30/2004.
(#539044)
TABLE 2 CHANGED COMMITMENTS (2001 THROUGH 2004)
Tracking Source DescriptionlJustification for Change/Deletion Number LDCN NRC Inspection Report 50-Eliminated the need to perform states links 3358 387/86-09 and 50-388/86-09, inspections during each refueling outage to identify 6/12/1986.
links that are not in their normally closed position or are administratively closed.
LDCN PPL Letter dated 514/1998 (PLA-Review of the Process Control Program by the Plant 3376 4893)
Operations Review Committee. Deleted.
LDCN PPL Letter to Bulletin 80-14 (PLA-Report Scram Discharge Volume valve failures in 3487 751) accordance with 10 CFR 50.72 and 50.73 reporting requirements in lieu of 24-hour reporting commitment.
LDCN Licensee Event Report 387/00-Revise applicable surveillance procedures that 3594 009-00 implement SR 3.6.1.3.2 to clarify the appropriate action statement to be entered in the event that the subject valves fail to meet the surveillance requirement.
LDCN PPL letter dated 10/4/2000 (PLA-Frequency of inspection of Unit 2 core shroud welds 3613 5234) changed from Spring 2003 to Spring 2005 refueling outage.
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:
Britt T. McKinney Vice President - Nuclear Site Operations PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Richard L. Anderson Vice President - Nuclear Operations PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Aloysius J. Wrape, IlIl General Manager - Nuclear Assurance PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Terry L. Harpster General Manager - Plant Support PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Robert A. Saccone General Manager - Nuclear Engineering PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467 Rocco R. Sgarro Manager - Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Walter E. Morrissey Supervising Engineer Nuclear Regulatory Affairs PPL Susquehanna, LLC 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Michael H. Crowthers Supervising Engineer Nuclear Regulatory Affairs PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Dale F. Roth Manager - Quality Assurance PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Luis A. Ramos Special Office of the President PPL Susquehanna, LLC 634 Salem Blvd., SSO Berwick, PA 18603-0467 Bryan A. Snapp, Esq Assoc. General Counsel PPL Services Corporation Two North Ninth Street, GENTW3 Allentown, PA 18101-1179 Supervisor - Document Control Services PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Richard W. Osborne Allegheny Electric Cooperative, Inc.
212 Locust Street P.O. Box 1266 Harrisburg, PA 17108-1266 Director - Bureau of Radiation Protection Pennsylvania Department of Environmental Protection P.O. Box 8469 Harrisburg, PA 17105-8469 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 35, NUCSA4 Berwick, PA 18603-0035
Susquehanna Steam Electric Station, Unit Nos. 1 and 2 cc:
Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803