ML061230220
| ML061230220 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/12/2006 |
| From: | Richard Guzman NRC/NRR/ADRO/DORL/LPLA |
| To: | Crane C Exelon Generation Co, Exelon Nuclear |
| Guzman R, NRR/DLPM 415-1030 | |
| References | |
| TAC MD0222, TAC MD0223 | |
| Download: ML061230220 (9) | |
Text
May 12, 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:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - AUDIT OF EXELON GENERATION COMPANY, LLCS MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD0222 AND MD0223)
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 to the NRC staff for commercial nuclear reactors. 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 Limerick Generating Station (LGS) was performed at the Exelon Generation Company, LLC office in Kennett Square, Pennsylvania, on April 20, 2006. Based on the audit, the NRC staff concludes that: (1) LGS had implemented NRC commitments on a timely basis; and (2) LGS 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. 50-352 and 50-353
Enclosure:
As stated cc w/encl: See next page
ML061230220 OFFICE LPL1-2/PE LPL1-1/PM LPL1-2/LA LPL1-2/BC NAME TValentine RGuzman CRaynor DRoberts DATE 5/12/06 5/12/06 5/12/06 5/12/06
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY EXELON GENERATION COMPANY, LLC TO THE NUCLEAR REGULATORY COMMISSION FOR LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
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 to the NRC staff for commercial nuclear reactors. 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 Limerick Generating Station, Units 1 and 2 (LGS) 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 April 20, 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 procedures follow 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 the 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 to be 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 four commitments, were selected for review, as listed in Table 1. The NRC staff also reviewed recent responses to Generic Letter (GL) 2003-01, Control Room Habitability;Bulletin 2005-01, Material Control and Accounting at Reactors and Wet Spent Fuel Storage Facilities; and Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events. The commitments for GL 2003-01 are listed in Table 1. Commitments related to Bulletins 2005-01 and 2005-02 are provided in non-public security-related correspondence and will not be documented in this audit report.
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).
(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 1 Amendments were issued January 29, 2003 (ADAMS Accession Number ML030290755). The original application was dated May 31, 2002 (ADAMS Accession Number ML021610477).
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 PIMS system included tracking items for all three of the selected license amendments.
Additionally, the NRC staff confirmed that the commitments from the selected generic communication responses, including those not provided in Table 1 for security reasons, were captured in another tracking program.
The NRC staff found that the licensees commitment tracking programs had appropriately captured all but one of the regulatory commitments that were identified by the NRC staff before the audit. The tracking item for Amendment No. 164 to Facility Operating License (FOL) No.
NPF-39 and Amendment No. 126 to FOL No. NPF-85 for LGS Units 1 and 2, respectively,1 did not mention the commitment specifically called out in the licensees application and the NRCs Safety Evaluation. The NRC staff called the licensees attention to this omission, and the licensee immediately added an entry to the tracking system to reflect the commitment. The original intent of the commitment had already been fulfilled by updating the Technical Specifications Bases for LGS after issuance of the amendments. Therefore, the NRC staff considered the resolution appropriate, given that this commitment will continue to be tracked in the future.
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 Annual Commitment Change Summary Reports submitted by Exelon for LGS on December 20, 2005 (ADAMS Accession Number ML053540164), November 23, 2004 (ADAMS Accession Number ML043280337), and October 16, 2003 (ADAMS Accession Number ML033040395).
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, in general, properly addressed the regulatory commitments 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 procedures used by the licensee to manage commitments are 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 R. Gropp G. Stewart Principal Contributor: T. Valentine Date: May 12, 2006
TABLE 1 WRITTEN COMMITMENTS AND RELATED INFORMATION (2003 THROUGH 2006)
NRC Issuance Summary of Commitment and Licensees Tracking Number(s)
Licensee Implementation Status 5/31/2002 MB5257 and MB5258 Amendment Nos. 164 and 126, 1/29/2003 (1) Revise commitments to Institute of Electrical and Electronics Engineers Standard 450 to reflect commitment to the 1995 edition.
A1405924 (1) Complete - changes to Technical Specifications Bases Section 3/4.8 made after issuance of amendment.
Commitment was not initially tracked, but is now included in licensees tracking system.
12/9/2003 MB9818 and MB9819 GL 2003-01, 6/12/2003 (1) Perform integrated control room envelope testing utilizing the American Society for Testing and Materials E741 methodology.
(2) Revise Technical Specifications to include an administrative program requirement for control room habitability.
A1457108 00189765 (1) Complete - testing performed in September 2004, as documented by letter to the NRC dated December 10, 2004.
(2) In progress - license amendments submitted for Exelon fleet on November 29, 2004, and withdrawn on July 11, 2005. The licensee committed to resubmit 90 days after NRC approval of Technical Specification Task Force-448.
This commitment is being tracked as well.
4/13/2004 MC2741 and MC2742 Amendment Nos. 171 and 133, 4/20/2004 (1) Maintain hydrogen monitors within emergency and operating procedures and the maintenance program.
(2) Maintain oxygen monitors within emergency and operating procedures and the maintenance program.
A1512502 Complete - changes to Updated Final Safety Analysis Report (UFSAR) Section 6.2.5 identify commitment. The changes to the UFSAR will be included in the 2006 revision.
10/21/04 MC4944 and MC4945 Amendment Nos. 175 and 137, 4/29/2005 (1) Provide operating data (described in GL 1997-02) quarterly using industry database.
A1518396 Complete - changes to procedure LS-AA-2003.
TABLE 2 CHANGED COMMITMENTS (2003 THROUGH 2006)
Tracking Number Source Justification for Change/Deletion NRC Notification?
T00878 NRC Inspection Report 90-17/16 Commitment restates an existing regulatory requirement. Deleted.
Yes T02392 LER 1-86-054 and NRC Inspection Report 86-03 Procedures revised for human performance. Deleted.
No T02665 LGS Safety Evaluation Report, NUREG-0991, Section 17.3 Commitment superceded by NRC approval of current Exelon Quality Assurance Topical Report. Deleted.
Yes T02779 LGS Response to 1987 NRC Systematic Assessment of Licensee Performance Report Performance of laboratory check standards included in procedure CY-AA-130-200. Deleted.
No T02835 LER 1-93-003 Modification to toxic gas analyzer system made commitment unnecessary.
Deleted.
No T03881 Letter from Philadelphia Electric Co. to NRC related to Unit 1 Amendment No. 72, 8/19/1996 Unit 1 spent fuel pool modification was completed and UFSAR was revised.
Deleted.
No T04085 LGS Response to Notice of Violation, 8/5/1998 Exelon corrective action program meets industry standards and operations interface is included. No longer annotated as an LGS-specific commitment.
Yes T04437 LER 1-02-003 Turbine thrust bearing wear detector replaced with a new system with additional redundancy. Deleted.
No
Limerick Generating Station, Unit Nos. 1 and 2 cc:
Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Senior Vice President - Nuclear Services 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 Vice President Licensing and Regulatory Affairs 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 Manager Licensing Limerick Generating Station Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation Protection Pennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803