ML061280623
| ML061280623 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 08/23/2006 |
| From: | Tam P Plant Licensing Branch III-2 |
| To: | Conway J Nuclear Management Co |
| References | |
| TAC MD1361 | |
| Download: ML061280623 (9) | |
Text
August 23, 2006 Mr. John T. Conway Site Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 SUBJECT MONTICELLO NUCLEAR GENERATING PLANT - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD1361)
Dear Mr. Conway:
On September 7, 2004, the Office of Nuclear Reactor Regulation published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission], Revision 1. LIC-105, Rev. 1, 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 No. ML042320463),
provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by commercial nuclear reactor licensees 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 licensees commitment management program.
An audit of Monticellos commitment management program was performed on site on July 18, 2006. Based on the audit, the NRC staff concludes that (1) the licensee had implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee had implemented an effective program to manage regulatory commitment changes.
Sincerely,
/RA/
Peter S. Tam, Senior Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-263
Enclosure:
As stated cc w/encl: See next page
ML061280623 OFFICE LPL3-1\\PM LPL3-1/LA LPL3-1/(A)BC NAME PTam THarris LRaghavan for MMurphy DATE 08/23/06 08/3/06 08/23/06
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
MONTICELLO NUCLEAR GENERATING PLANT (MNGP)
DOCKET NO. 50-263
1.0 INTRODUCTION AND BACKGROUND
On September 7, 2004, the Office of Nuclear Reactor Regulation Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC, Revision 1, was published. LIC-105, Rev. 1, 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 No. 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.
According to LIC-105, Rev. 1, 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, Rev 1, 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 PROCEDURE AND RESULTS Since no such audit was performed before the date of the subject audit, 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 onsite at MNGP on July 18, 2006.
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 had not yet been implemented, the NRC staff aimed to ascertain that they have been captured in an effective program for future implementation.
ENCLOSURE 2.1.1 Audit Scope Before the audit, the NRC staff searched ADAMS for the licensees licensing action and licensing activity submittals dated in the last 3 years. Some of these submittals contain regulatory commitments, but the NRC staff found that commitments meeting the definition in LIC-105, Rev. 1, are few in number. Table 1 lists most, if not all, of the licensees commitments.
MNGP commitments are tracked by multiple programs, e.g., Passport, and Team Action. The proliferation of tracking programs has to do principally with the change of ownership. The NRC staff, thus, aimed to ascertain that commitments had not fallen thru the crack because of multiple tracking programs. During the audit, the NRC staff reviewed reports generated by various tracking programs, and other documents related to the commitments.
LIC-105, Rev. 1, 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 conveyed by Licensee Event Reports (LER)s - These commitments are controlled by the licensees LER process, which is imposed by Title 10 of the Code of Federal Regulations (10 CFR) Section 50.73.
(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 one or more of the licensees tracking programs for the commitments listed in Table 1 to evaluate the status of completion. 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. Table 1 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 The NRC staff reviewed (1) the licensees company-wide procedure FG-R-CM-01, "Regulatory Commitment Management," Revision 0, dated May 8, 2006; and (2) Monticello's procedure 4 AWI-02.09.01, "NRC Commitments," Revision 12. Both these procedures make extensive references to NEI 99-04. In particular, Section 4.6 of the latter procedure specifically addresses the process to modify or retract existing NRC commit, citing Figure 5.1 of NEI 99-04 for details of the process. The associated form "NMC Commitment Change Evaluation" instructs the initiator of a commitment to provide needed information and an evaluation of the impacts of a proposed commitment change. The NRC staff concludes that the licensee's procedures follow closely the guidance of NEI-99-04 in that they set forth the need for identifying, tracking, and reporting commitments, and they provide 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 Section 2.1.1 and Table 1 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 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 surmises that the procedure used by the licensee to manage commitments is appropriate and effective.
3.0 CONCLUSION
Based on the above audit, the NRC staff concludes that (1) the licensee had implemented or is tracking future implementation of regulatory commitments made to the NRC; and (2) the licensee had implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Gerald Holthaus Rick Loeffler Duwayne Wacha Principal Contributor: P. S. Tam Date: August 23, 2006
TABLE 1 (page 1 of 3)
MONTICELLO NUCLEAR GENERATING PLANT AUDIT OF WRITTEN LICENSEE COMMITMENTS 2003 THROUGH 2006 MNGP Submittal NRC TAC No.
NRC Issuance Summary of Commitment Licensee Implementation Status 3/19/03 L-MT-03-017 ML030920428 MB8063 Amend. No. 136, 6/17/03 Within 180 days after implementation of the amendment, the licensee will develop contingency plans for obtaining and analyzing highly radioactive samples from the reactor coolant system, the suppression pool, and the containment atmosphere.
The contingency plans will be in the plant technical procedures.
Completed on 10/20/03.
Commitment No.
M03003A.
3/19/03 L-MT-03-017 ML030920428 MB8063 Amend. No. 136, 6/17/03 Within 180 days after implementation of the amendment, the licensee will establish capability for classifying fuel damage events at the Alert level threshold at radioactivity levels of 300 µCi/gm dose equivalent iodine. This capability will be described in the emergency plan implementing procedures.
Completed on 1/30/04.
Commitment No.
M03004A.
3/19/03 L-MT-03-017 ML030920428 MB8063 Amend. No. 136, 6/17/03 The licensee will develop an I-131 site survey detection capability, including an ability to assess radioactive iodine species released to offsite environs by using effluent monitoring systems of portable sampling equipment. This capability is maintained in the emergency implementing procedures.
Completed on 7/14/03.
Commitment No.
M03002A.
1/30/04 ML040330467 MC1902 Amend. No. 138 A hydrogen monitoring system capable of diagnosing beyond-design-basis accidents is installed. It will be included in the Commitment Tracking Program by the implementation date of the proposed amendment (i.e., 120 days).
Completed 5/28/04.
Commitment No.
M04001A.
1/30/04 ML040330467 MC1902 Amend. No. 138 An oxygen monitoring system capable of verifying the status of the inerted containment is installed. It will be included in the Commitment Tracking Program. By the implementation date of the proposed amendment (i.e., 120 days)
Completed 5/28/04.
Commitment No.
M04002A.
NRC Issuance Summary of Commitment Licensee Implementation Status 10/5/04 ML042880508 MC4622 Amend. No 142 Using an industry database, the licensee will provide the NRC the operating data (for each calendar month) that is described in GL 97-02, Revised Contents of the Monthly Operating Report, by the last day of the month following the end of each calendar quarter. The commitment will be based on the use of an industry database (e.g., the industrys Consolidated Data Entry (CDE) program, currently being developed by the Institute of Nuclear Power Operations).
This regulatory commitment will be implemented to prevent any gaps in the monthly statistics and shutdown experience provided to the NRC (i.e., data for all months will be provided using one or both systems (monthly operating reports and CDE).
Completed on 4/18/05.
Commitment No.
M04007A.
6/30/04 L-MT-04-036 ML042040166 MC3692 Amend. No. 143, 144 The licensee will implement a trending program to address setpoints for TS calibration intervals extended to 24 months.
Setpoint found to exceed the expected drift for the instruments would require an additional evaluation to ensure the instrument's performance is still enveloped by the assumptions in the drift or setpoint analysis. The trending program will also plot setpoint or transmitter As-Found/As-Left values to verify that the performance of the instruments is within expected boundaries and that adverse trends are detected and evaluated.
Completed on 12/22/05.
Commitment No.
M04005A.
4/29/04 L-MT-04023 ML041450022 MC7596 Amend. No. 145 The licensee will revise guidelines for assessing systems removed from service during handling of irradiated fuel assemblies or core alterations to implement the provisions of Section 11.3.6.5 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"
Revision 3.
Pending, under GAR00870521.
Commitment No.
M04003A.
4/29/04 L-MT-04023 ML041450022 MC7596 Amend. No. 145 The licensee will revise refueling procedure(s) to require a minimum of 23 feet of water above stored fuel in the Spent Fuel Pool during irradiated fuel movement.
This commitment had been superseded by a change to the proposed TS (licensee's letter of 4/12/05). The corresponding requirement has been implemented by Amend. No. 145.
NRC Issuance Summary of Commitment Licensee Implementation Status 11/25/03 ML033300162 MB9824 (pending, regarding control room habitability)
By 8/04, the licensee will perform the ASTM E741 testing and provide the requested response to GL 2003-01 Item 1(a).
Completed per letter of 11/18/04.
Commitment No.
M03008A.
11/25/03 ML033300162 MB9824 (pending, regarding control room habitability)
By 2/23/04, the licensee will perform smoke assessment (GL 2003-01 Item 1(b) Part 2)
Completed per letter of 2/23/04.
Commitment No.
M03010A.
11/18/04 L-MT-04-049 ML043240240 MB9824 (pending, regarding control room habitability)
The licensee will restore full compliance with GDC 19 (e.g., removing reliance on manual actions and ensuring control room envelope inleakage assumptions are met) following the adoption of an alternative source term methodology.
Pending.
Commitment No.
M04008A.
4/13/06 L-MT-06-028 ML061310408 MC8971 (pending)
As part of Improved Technical Specification implementation, the licensee will relocate the control room radiation surveillances from the TS to the Technical Requirements Manual.
Completed on 1/5/06.
Commitment No.
M06030A.
Monticello Nuclear Generating Plant cc:
Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 U.S. Nuclear Regulatory Commission Resident Inspector's Office 2807 W. County Road 75 Monticello, MN 55362 Manager, Nuclear Safety Assessment Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Robert Nelson, President Minnesota Environmental Control Citizens Association (MECCA) 1051 South McKnight Road St. Paul, MN 55119 Commissioner Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155-4194 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Commissioner Minnesota Department of Health 717 Delaware Street, S. E.
Minneapolis, MN 55440 Douglas M. Gruber, Auditor/Treasurer Wright County Government Center 10 NW Second Street Buffalo, MN 55313 Commissioner Minnesota Department of Commerce 85 7th Place East, Suite 500 St. Paul, MN 55101-2198 Manager - Environmental Protection Division Minnesota Attorney Generals Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 Michael B. Sellman President and Chief Executive Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 Nuclear Asset Manager Xcel Energy, Inc.
414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401 November 2005