ML061600058
| ML061600058 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 06/13/2006 |
| From: | Kansler M Entergy Nuclear Operations |
| To: | Boska J Plant Licensing Branch III-2 |
| Boska J, NRR, 301-415-2901 | |
| References | |
| TAC MD1195 | |
| Download: ML061600058 (10) | |
Text
June 13, 2006 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - AUDIT OF ENTERGY'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD1195)
Dear Mr. Kansler:
The Nuclear Regulatory Commission (NRC) staff performed an audit of the James A.
FitzPatrick Nuclear Power Plant (JAFNPP) commitment management program at JAFNPP, which is located near Oswego, New York, on May 31 and June 1, 2006. The Entergy commitment management system is described in the Entergy corporate procedure EN-LI-110, "Commitment Management Program," Rev. 0, dated September 27, 2005. EN-LI-110 is based on and implements the recommendations of Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," Rev. 0. NRC Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made By Power Reactor Licensees to the NRC Staff,"
describes NEI 99-04 as an acceptable way for licensees to control regulatory commitments.
The Office of Nuclear Reactor Regulation's Office Instruction LIC-105, Revision 1, Managing Regulatory Commitments Made by Licensees to the NRC, provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments. LIC-105 specifies that once every 3 years, the NRC staff shall audit a licensees commitment management program.
The NRC staff concludes that, based on the audit (1) Entergy has implemented NRC commitments for JAFNPP on a timely basis; and (2) Entergy has implemented an effective program for managing NRC commitment changes at JAFNPP. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
John P. Boska, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333
Enclosure:
As stated cc w/encl: See next page
ML06 OFFICE LPL1-1/PM LPL1-1/LA LPL1-1/BC NAME JBoska SLittle RLaufer DATE 6/12/06 6/12/06 6/13/06 FitzPatrick Nuclear Power Plant cc:
Mr. Gary J. Taylor Resident Inspector's Office Chief Executive Officer James A. FitzPatrick Nuclear Power Plant Entergy Operations, Inc. U. S. Nuclear Regulatory Commission 1340 Echelon Parkway P.O. Box 136 Jackson, MS 39213 Lycoming, NY 13093 Mr. John T. Herron Ms. Charlene D. Faison Sr. VP and Chief Operating Officer Manager, Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Peter T. Dietrich Mr. Michael J. Colomb Site Vice President Director of Oversight Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant 440 Hamilton Avenue P.O. Box 110 White Plains, NY 10601 Lycoming, NY 13093 Mr. David Wallace Mr. Kevin J. Mulligan Director, Nuclear Safety Assurance General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant James A. FitzPatrick Nuclear Power Plant P.O. Box 110 P.O. Box 110 Lycoming, NY 13093 Lycoming, NY 13093 Mr. James Costedio Mr. Oscar Limpias Manager, Regulatory Compliance Vice President Engineering Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. James A. FitzPatrick Nuclear Power Plant 440 Hamilton Avenue P.O. Box 110 White Plains, NY 10601 Lycoming, NY 13093 Mr. Christopher Schwarz Assistant General Counsel Vice President, Operations Support Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Charles Donaldson, Esquire Mr. John F. McCann Assistant Attorney General Director, Licensing New York Department of Law Entergy Nuclear Operations, Inc. 120 Broadway 440 Hamilton Avenue New York, NY 10271 White Plains, NY 10601
FitzPatrick Nuclear Power Plant cc:
Regional Administrator, Region I Mr. Garrett D. Edwards U.S. Nuclear Regulatory Commission 814 Waverly Road 475 Allendale Road Kennett Square, PA 19348 King of Prussia, PA 19406 Oswego County Administrator Mr. Steven Lyman 46 East Bridge Street Oswego, NY 13126 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. James H. Sniezek BWR SRC Consultant 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster BWR SRC Consultant 5931 Barclay Lane Naples, FL 34110-7306
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333
1.0 INTRODUCTION AND BACKGROUND
The Nuclear Regulatory Commission (NRC) staff performed an audit of the James A.
FitzPatrick Nuclear Power Plant (JAFNPP) commitment management program at JAFNPP, which is located near Oswego, New York, on May 31 and June 1, 2006. Entergy Nuclear Operations, Inc. (Entergy or the licensee) is the licensee for JAFNPP. The Entergy commitment management system is described in the Entergy corporate procedure EN-LI-110, "Commitment Management Program, " Rev. 0, dated September 27, 2005. EN-LI-110 is based on and implements the recommendations of Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," Rev. 0. NRC Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made By Power Reactor Licensees to the NRC Staff," describes NEI 99-04 as an acceptable way for licensees to control regulatory commitments. The Office of Nuclear Reactor Regulation's (NRR's) Office Instruction LIC-105, Revision 1, Managing Regulatory Commitments Made by Licensees to the NRC, provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments.
LIC-105 specifies that once every 3 years, the NRC staff shall audit a licensees commitment management program. LIC-105 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 www.nrc.gov (Accession Number ML042320463).
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.).
2.0 AUDIT PROCEDURE AND RESULTS The audit was performed at JAFNPP, which is located near Oswego, New York, on May 31 and June 1, 2006, and reviewed commitments made by Entergy in the past 3 years.
Enclosure
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 in accordance with the NRC guidance and approved plant procedures. 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.
2.1.1 Audit Scope Before the audit, the NRC staff searched ADAMS for a sampling of the licensees licensing actions dated within the past 3 years. NRC staff identified documents containing regulatory commitments meeting the criteria specified by LIC-105. Table 1 lists the licensees commitments which were audited.
The list of the selected regulatory commitments for JAFNPP was provided to the site licensing group with a request to provide plant documentation used to track each individual commitment.
Also, the site personnel were requested to provide status and a copy of the revised documents (plant procedures, Updated Final Safety Analysis Report, Technical Specifications (TSs), etc.)
for verification, if the required actions had already been completed. The regulatory commitments were reviewed against the plant documents to verify if the commitment had been implemented satisfactorily in accordance with the approved plant procedures.
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 excludes the following types of commitments:
(1) Commitments as a result of 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 or 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 or activity was completed.
(4) Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, TSs, 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 the commitments listed in Table 1 to ensure that the selected commitments are included in the plant database used to track the commitments and evaluate the status of completion of each commitment. The NRC staff found that the licensees commitment tracking program had captured the regulatory commitments that were identified by the NRC staff before the audit.
The NRC staff also reviewed plant procedures and other design bases documents that had been revised as a result of commitments made by the licensee to NRC. These procedures and documents are identified in the right-hand column of Table 1. The NRC staff review indicated that:
- 1. All the regulatory commitments selected for the audit were being tracked.
- 2. Review of the plant documents for the completed commitments indicated that the commitments selected for the review were implemented as committed.
Table 1 summarizes what the NRC staff observed as the current status of licensee commitments reviewed during the audit.
2.2 Verification of the Licensees Program for Managing NRC Commitment Changes The NRC staff reviewed the licensees procedure EN-LI-110, Commitment Management Program, Revision 0, against NEI 99-04 guidelines. In particular, in regards to managing a change or deviation from a previously completed commitment, Section 1.0 specifically states that the procedure is based on and implements the recommendations of NEI 99-04. Section 5.5 of EN-LI-110 defines the process for making changes to a commitment. In general, EN-LI-110 follows closely the guidance of NEI-99-04: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments.
The NRC staff reviewed the submittals from the licensee to the NRC during 2003 to 2006 which reported revisions to the docketed commitments as permitted per NEI-99-04. These submittals included Entergy letters JAFP-03-0065, dated May 12, 2003, JAFP-05-0069, dated May 5, 2005, and JAFP-06-0068, dated April 26, 2006. The NRC staff has no comments on these revisions, but may inspect them in more detail at a later time.
As set forth in Section 2.1 above, the NRC staff found that the licensee had properly addressed all 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 the licensees reported status of the audited commitments to be acceptable. Thus, the NRC staff judges 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 its regulatory commitments; and (2) the licensee had implemented an effective program to manage changes to regulatory commitment.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT G. Brownell R. Plasse J. Costedio Principal Contributor: J. Boska Date: June 13, 2006
TABLE 1 (Page 1 of 2)
AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION (2002 THROUGH 2006)
Entergy NRC NRC Summary of Commitment, and Licensees Tracking Licensee Implementation Status Submittal TAC No. Issuance Number 6/7/02 MB5328 Amend. ENO will revise the FitzPatrick guidelines for assessing Complete. Guidelines are in JPN No. 276, systems removed from service during the handling of procedure AP-10.09, rev. 19, Outage 016 09/12/02 irradiated fuel assemblies or core alterations to Risk Assessment, section 7.2.4.
implement the provisions of Section 11.3.6.5 of NUMARC 93-01, Revision 3 [to avoid unmonitored releases and to have a contingency method to close secondary containment]. (JPN-02-016-01)
ENO will revise the FitzPatrick UFSAR to reflect the Complete. UFSAR has been revised, revised fuel handling analyses and alternate source see for example, section 14.8.2.3.
term. (JPN-02-016-02)
ENO will submit to the NRC updated technical Complete. Submitted on 7/17/02 in specification marked-up pages for relaxed secondary JAFP-02-0146.
containment changes. (JPN-02-016-03, ACT-02-65768) 2/27/03 MB8030 Amend. ENO will develop and maintain contingency plans for Complete. Highly radioactive JAFP No. 278, obtaining and analyzing highly radioactive samples samples and radioactive iodine 0034 05/16/03 from the reactor coolant system, suppression pool, and samples are obtained and analyzed containment atmosphere. (JAFP-03-0034-1, ACT per plant procedure PSP-17, rev. 24, 66634) PASS Operating Procedure.
ENO will establish and maintain the capability for Complete. Classifying fuel damage classifying fuel damage events at the Alert level events is in IAP-2, Rev. 26, threshold at 300 microcuries / cc dose equivalent Classification of Emergency iodine. (JAFP-03-0034-2, ACT-03-66635) Conditions, commitment 3.1.1., and p.16, section 1.1.2. and TRM 5.5.c.
ENO will develop and maintain an iodine-131 site survey detection capability, including an ability to Complete. See SP-03.09, Rev. 4, assess radioactive iodines released to offsite environs, Stack Automatic and Particulate by using effluent monitoring systems or portable Sample System, commitment 2.1.1.
sampling equipment. (JAFP-03-0034-3, ACT-03-66636) 6/22/04 MC3675 Amend. The drywell hydrogen monitoring system will maintain Complete. See OP-37, Rev. 71, JAFP No. 280, the capability of diagnosing beyond-design-basis Containment Atmosphere Dilution 0087 12/18/04 accidents (to the level of Regulatory Guide (RG) 1.97, System, and CA-01.02, Rev. 9, category 3) (JAFP-04-0087-1) Drywell and Torus Atmosphere Sampling and Analysis. See also The drywell oxygen monitoring system will maintain the TRM 3.3.C, function 11, TRS capability of verifying the status of the inerted 3.3.c.2, and the TRM Bases.
containment (to the level of RG 1.97, category 2)
(JAFP-04-0087-2)
The drywell hydrogen and oxygen monitoring capabilities will be maintained in the Technical Requirements Manual (TRM). (JAFP-04-0087-3) 9/1/04 MC4276 Amend. Provide to the NRC using an industry database the Ongoing.
JPN No. 282, operating data (for each calender month) that is 015 2/3/04 described in Generic Letter 97-02, "Revised Contents of The licensee is required to submit the Monthly Operating Report," by the last day of the reports on a regular interval and no month following the end of each calendar quarter. The further verification is needed.
regulatory commitment will be based on use of an industry database (e.g., the industrys Consolidated Data Entry (CDE) program, currently maintained by the Institute of Nuclear Power Operations)
Entergy NRC NRC Summary of Commitment, and Licensees Tracking Licensee Implementation Status Submittal TAC No. Issuance Number 9/27/04 MB9805 NRC ENO commits to create a preventive maintenance Complete. A preventive JAFP Generic surveillance procedure to annually inspect the Relay maintenance task has been created 0159 Letter Room and components located inside the CRE to as job plan 70DPI-063*002.
2003-01 ensure CRE unfiltered inleakage vulnerability is maintained as leak tight as possible. (ACT-04-67792) 12/30/04 MC5506 Amend. ENO will incorporate the revised acceptance criterion Complete. See the surveillance JAFP No. 283, value of 7.5 percent into the TS Bases. procedure for TS SR 3.1.4.2., RAP-0195 3/5/05 7.4.01, Rev. 19, Control Rod Scram Time Evaluation, steps 4.7.4 and 10.2.
7/6/05 MC7508 Relief ENO will perform coating of the repair inside the torus. Open, with a committed date of JAFP Request (ACT-05-679490 10/1/06, which corresponds to the 0102 RR-37, Fall 2006 refueling outage.
7/8/05