ML071910070
| ML071910070 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/20/2007 |
| From: | James Kim NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Balduzzi M Entergy Nuclear Operations |
| kim J, NRR/ADRO/DORL, 415-4125 | |
| References | |
| TAC MD3486 | |
| Download: ML071910070 (8) | |
Text
July 20, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD3486)
Dear Mr. Balduzzi:
An audit of the Entergy Nuclear Operations, Inc. (Entergy) commitment management program was performed at the Pilgrim Nuclear Power Station (Pilgrim) site on January 15 and January 16, 2007. The Nuclear Regulatory Commission (NRC) staff concludes that, based on the audit: (1) Pilgrim has an established commitment management program, (2) Pilgrim has implemented NRC commitments on a timely basis, with some minor inconsistencies, which were discussed with the licensee during the exit meeting on January 16, 2007, and (3) as a result of a new Entergy fleet procedure, Pilgrim has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-4125.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosures:
- 1. Audit Report
- 2. List of Commitments Reviewed cc w/encls: See next page
July 20, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
PILGRIM NUCLEAR POWER STATION - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD3486)
Dear Mr. Balduzzi:
An audit of the Entergy Nuclear Operations, Inc. (Entergy) commitment management program was performed at the Pilgrim Nuclear Power Station (Pilgrim) site on January 15 and January 16, 2007. The Nuclear Regulatory Commission (NRC) staff concludes that, based on the audit: (1) Pilgrim has an established commitment management program, (2) Pilgrim has implemented NRC commitments on a timely basis, with some minor inconsistencies, which were discussed with the licensee during the exit meeting on January 16, 2007, and (3) as a result of a new Entergy fleet procedure, Pilgrim has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff for performing the audit. If you have any questions, I may be reached at (301) 415-4125.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosures:
- 1. Audit Report
- 2. List of Commitments Reviewed cc w/encls: See next page DISTRIBUTION:
PUBLIC RidsOgcRp JShea LPL1-1 R/F RidsAcrsAcnwMailCenter RidsNrrDorlLpl1-1 RidsRgn1MailCenter RidsNrrLASLittle RidsNrrDorlDPR RidsNrrPMJKim Accession No.: ML071910070 OFFICE LPL 1-2/PM LPL1-1/PM LPL1-1/LA LPL1-1/BC NAME JShea JKim SLittle MKowal DATE 7/05/07 7/18/07 7/18/07 7/20/07 OFFICIAL RECORD COPY
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
OF REGULATORY COMMITMENTS MADE BY ENTERGY NUCLEAR OPERATIONS, INC.
PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION AND BACKGROUND
On September 7, 2004, NRR Office Instruction LIC-105, Revision 1, 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 website (Accession No. ML042320463), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by licensees of 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 3 years.
2.0 AUDIT SCOPE AND RESULTS 2.1 Audit Scope The audit was performed at the Entergy Nuclear Operations, Inc. (Entergy or licensee) Pilgrim Nuclear Power Station (Pilgrim) site on January 15 and January 16, 2007. The focus of this audit was to capture the state of the licensee commitment program since the issuance of LIC-105. The NRC staff defined the period covered by this audit to encompass approximately 3 to 4 years prior to the date of the audit.
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.). Prior to the audit, in order to generate a list of items for the audit, the NRC staff performed a Public, Web-Based ADAMS search for commitments listed in licensing action and licensing activity submittals dated in the last 3 to 4 years. From this list (Enclosure 2), the NRC staff selected a representative sample of regulatory commitments to audit. The selection of the sample list covered a variety of systems, disciplines and licensing actions important to NRC staffs decision-making process.
Enclosure 1
2.2 Verification of Licensees Implementation of NRC Commitments The primary focus of this audit was to confirm that the licensee has implemented those commitments made to the NRC as part of past licensing actions/activities.
The licensees Commitment Management Program is described in the Entergy corporate procedure Commitment Management Program, EN-LI-110, Revision 0, dated September 27, 2005. This procedure established a fleet procedure applicable to all the licensee nuclear power plants including Pilgrim. This procedure incorporated an existing guidance document referred to as the Pilgrim licensing Work Instruction No. 3.03-03, Revision 6, "NRC Commitment Tracking." The licensee enters commitments made to the NRC into a database called the Integrated Action Database (IADB). The IADB database is used to track a number of licensee action items including regulatory commitments. However, this tracking system only tracked the implementation of commitments and did not have a mechanism for determining if a commitment was changed or was closed by licensee actions. Pilgrim will be utilizing the fleet Commitment Management System (CMS), which is a database process that is used to track the status of commitments in the Entergy fleet. The licensee recognized the deficiencies in the current tracking system for NRC commitments at Pilgrim and the new tracking system will better implement the NEI guidance.
The NRC staff reviewed documentation generated by the licensee related to the sample items listed in Enclosure 2. For the commitments selected, the NRC staff found that the licensees commitment tracking program had captured all of the regulatory commitments. However, the NRC staff noted that implementation of the program had some inconsistencies in regards to accurate database tracking of some of the items reviewed. For these items, the licensee submitted corrective actions to correct these minor discrepancies.
2.3 Verification of the Licensees Program for Managing NRC Commitment Changes 2.3.1 Change Control Procedure Verification The NRC staff reviewed the licensees procedure EN-LI-110, against NEI 99-04, Revision 0.
This corporate fleet procedure follows the NEI guidance and incorporates a database, "Commitment Management System (CMS)" at Pilgrim to utilize a new computer-based tracking system called the Licensing Research System (LRS) that will better track the history of specific commitment changes and deletions if applicable. Regulatory commitment changes are processed and tracked by the Pilgrim Plant Licensing Personnel (Site Licensing) and are approved by the Site Management. A Commitment Change Evaluation Form is used to document the evaluation of the commitment change or deletion. This procedure also includes a mechanism for notifying the NRC on a periodic basis regarding commitment changes.
The NRC staff found that the licensee's procedure for handling the commitment change, in general, is consistent with the guidance in NEI 99-04.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit: (1) Pilgrim has an established commitment management program, (2) Pilgrim has implemented NRC commitments on a
timely basis, with some minor inconsistencies, which were discussed with the licensee during the exit meeting on January 16, 2007, and (3) as a result of a new Entergy fleet procedure along with the LRS database, Pilgrim has implemented an effective program for managing NRC commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Principal Contributors: Doug Ellis, Walter Lobo, Ed Sanchez, Brian Ford, and J. Shea (NRC)
Date: July 20, 2007
LIST OF REVIEWED COMMITMENTS FOR PILGRIM ITEM ENTERGY LETTER NO. DATE SUBJECT 1 JPN-02-004 3/18/02 Order for Interim Safeguards and Security Compensatory Measures 2 2.02.084 10/10/02 Request for Tech Spec change concerning change of trip level settings, calibration frequencies, and editorial changes 3 JPN-03-002 1/27/03 Order for compensatory measures related to access authorization 4 2.03.011 3/19/03 Eliminate the requirements of PASS using CLII process 5 2.03.099 12/8/03 Changes to the reactor vessel material surveillance program, TS Surveillance 4.6.A.2 6 2.04.046 6/2/04 Fourth 10 Year IST Relief Request 7 2.04.074 9/2/04 Tech Spec changes for single recirculation loop operation 8 2.04.106 10/25/04 Supplemental response to April 29, 2003, Orders to Pilgrim 9 2.04.115 12/15/04 Limited scope application for AST for FHA 10 2.05.038 5/26/05 Response to NRC guidance regarding mitigation strategies Enclosure 2
Pilgrim Nuclear Power Station cc:
Regional Administrator, Region I Secretary of Public Safety U. S. Nuclear Regulatory Commission Executive Office of Public Safety 475 Allendale Road One Ashburton Place King of Prussia, PA 19406-1415 Boston, MA 02108 Senior Resident Inspector Director, Massachusetts Emergency U. S. Nuclear Regulatory Commission Management Agency Pilgrim Nuclear Power Station Attn: James Muckerheide Post Office Box 867 400 Worcester Road Plymouth, MA 02360 Framingham, MA 01702-5399 Chairman, Board of Selectmen Mr. William D. Meinert 11 Lincoln Street Nuclear Engineer Plymouth, MA 02360 Massachusetts Municipal Wholesale Electric Company Chairman P.O. Box 426 Nuclear Matters Committee Ludlow, MA 01056-0426 Town Hall 11 Lincoln Street Mr. Kevin H. Bronson Plymouth, MA 02360 Site Vice President Entergy Nuclear Operations Chairman, Duxbury Board of Selectmen Pilgrim Nuclear Power Station Town Hall 600 Rocky Hill Road 878 Tremont Street Plymouth, MA 02360-5508 Duxbury, MA 02332 Mr. Robert G. Smith Office of the Commissioner General Manager, Plant Operations Massachusetts Department of Entergy Nuclear Operations Environmental Protection Pilgrim Nuclear Power Station One Winter Street 600 Rocky Hill Road Boston, MA 02108 Plymouth, MA 02360-5508 Office of the Attorney General Mr. Stephen J. Bethay One Ashburton Place Director, Nuclear Safety Assurance 20th Floor Entergy Nuclear Operations Boston, MA 02108 Pilgrim Nuclear Power Station 600 Rocky Hill Road MA Department of Public Health Plymouth, MA 02360-5508 Radiation Control Program Schrafft Center, Suite 1M2A Mr. Bryan S. Ford 529 Main Street Manager, Licensing Charlestown, MA 02129 Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
Pilgrim Nuclear Power Station cc:
Mr. John T. Herron Sr. Vice President Ms. Charlene D. Faison Entergy Nuclear Operations Manager, Licensing 1340 Echelon Parkway Entergy Nuclear Operations Jackson, MS 39213 440 Hamilton Avenue White Plains, NY 10601 Mr. Oscar Limpias Vice President, Engineering Mr. Ernest J. Harkness Entergy Nuclear Operations Director, Oversight 440 Hamilton Avenue Entergy Nuclear Operations, Inc.
White Plains, NY 10601 1340 Echelon Parkway Jackson, MS 39213 Mr. John A. Ventosa GM, Engineering Mr. William C. Dennis Entergy Nuclear Operations Assistant General Counsel 440 Hamilton Avenue Entergy Nuclear Operations White Plains, NY 10601 440 Hamilton Avenue White Plains, NY 10601 Mr. Joseph P. DeRoy VP, Operations Support Ms. Stacey Lousteau Entergy Operations, Inc. Treasury Department 1340 Echelon parkway Entergy Services, Inc.
Jackson, MS 39213 639 Loyola Avenue New Orleans, LA 70113 Mr. Michael Kansler President & CEO/CNO Mr. James Sniezek Entergy Nuclear Operations 5486 Nithsdale Drive 1340 Echelon Parkway Salisbury, MD 21801-2490 Jackson, MS 39213 Mr. Michael D. Lyster Mr. John F. McCann 5931 Barclay Lane Director, Nuclear Safety & Licensing Naples, FL 34110-7306 Entergy Nuclear Operations 440 Hamilton Avenue Mr. Garrett D. Edwards White Plains, NY 10601 814 Waverly Road Kennett Square, PA 19348 Mr. John Doering P.O. Box 189 Parker Ford, PA 19457