ML072780003

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Audit Report of Licensee Regulatory Commitment Management Program for Audit Performed August 20-21, 2007
ML072780003
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 10/31/2007
From: Donohew J
NRC/NRR/ADRO/DORL/LPLIV
To: Muench R
Wolf Creek
Donohew J N, NRR/DORL/LP4, 415-1307
References
TAC MD6619
Download: ML072780003 (16)
v • d • e


Text

October 31, 2007 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - AUDIT OF LICENSEE REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NO. MD6619)

Dear Mr. Muench:

An audit of the Wolf Creek Nuclear Operating Corporation (WCNOC) regulatory commitment management program was performed at the Wolf Creek Generating Station on August 20-21, 2007. Based on this audit, the NRC staff concludes that WCNOC has an adequate program to implement and manage regulatory commitments. Details of the audit are provided in the enclosed audit report, including our observations and recommendations.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosure:

Audit Report cc w/encl: See next page

ML072780003 OFFICE NRR/SNPB NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME AHoffman JDonohew JBurkhardt THiltz DATE 10/22/07 10/24/07 10/11/07 10/31/07 Wolf Creek Generating Station cc:

Jay Silberg, Esq. Chief, Radiation and Asbestos Control Pillsbury Winthrop Shaw Pittman LLP Section 2300 N Street, NW Kansas Department of Health Washington, D.C. 20037 and Environment Bureau of Air and Radiation Regional Administrator, Region IV 1000 SW Jackson, Suite 310 U.S. Nuclear Regulatory Commission Topeka, KS 66612-1366 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corporation Senior Resident Inspector P.O. Box 411 U.S. Nuclear Regulatory Commission Burlington, KS 66839 P.O. Box 311 Burlington, KS 66839 Supervisor Licensing Wolf Creek Nuclear Operating Corporation Chief Engineer, Utilities Division P.O. Box 411 Kansas Corporation Commission Burlington, KS 66839 1500 SW Arrowhead Road Topeka, KS 66604-4027 U.S. Nuclear Regulatory Commission Resident Inspectors Office/Callaway Plant Office of the Governor 8201 NRC Road State of Kansas Steedman, MO 65077-1032 Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839 February 2006

AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482

1.0 INTRODUCTION AND BACKGROUND

In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing NRC Commitments, the U.S. Nuclear Regulatory Commission (NRC, the Commission) staff informed the Commission that it found that industry guidance document NEI 99-04 contains acceptable guidance for controlling regulatory commitments made by commercial reactor licensees to the NRC and the Commission endorsed NEI 99-04. The guidance in NEI 99-04 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments, which are defined as explicit statement[s] to take a specific action agreed to, or volunteered by, a licensee and submitted in writing on the docket to the NRC.

The NRC staff has agreed that NEI 99-04 provides acceptable guidance to licensees for the control of regulatory commitments made to the NRC staff. See Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000. The commitments will be controlled in accordance with the licensee's Commitment Management Program (CMP) in accordance with NEI 99-04. Any change to the regulatory commitments is subject to licensee management approval and subject to the procedural controls established at the plant for commitment management in accordance with NEI 99-04, which include appropriate notification of the NRC.

The NRC's Office of Nuclear Reactor Regulation (NRR) performs audits of regulatory commitments made by commercial reactor licensees. An NRR project manager audits the licensees CMP by assessing the adequacy of the licensees implementation of a sample of commitments made to the NRC in past licensing actions (e.g., amendments, relief requests, exemptions) and activities (e.g., bulletins, generic letters). An audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Wolf Creek Nuclear Operating Corporations (WCNOC's, the licensee's) program for managing regulatory commitments at the Wolf Creek Generating Station, the Commitment Management System (CMS), was performed at the plant site on August 20-21, 2007. Since no such audit was performed prior to this date, the NRC staff defined the period of this audit to encompass approximately 6 years prior to the date of the audit, twice the normal period of 3 years.

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 activities, satisfying both the action committed to and the overall intent of the commitment.

The NRC staff selected a sample of individual and unrelated regulatory commitments that were approved by the NRC to justify a licensing action or resolve a licensing activity. This sample emphasized regulatory commitments encompassing a variety of systems, a variety of engineering disciplines, and a variety of licensing actions.

The NRC staff reviewed reports generated by the licensees CMS along with other relevant documentation to evaluate the status of the completion of regulatory commitments. The results of this review are listed in the attached Table 1. The NRC staff found that the licensees CMS had adequately incorporated and implemented all of the regulatory commitments that were selected by the NRC staff for this audit.

2.2 Verification of Licensees Program for Managing NRC Commitment Changes The primary focus of this part of the audit is the licensees performance related to implementing controls for modifying or deleting regulatory commitments made to the NRC in order to ensure that changes to regulatory commitments are evaluated in accordance with the licensees programs and procedures, that the licensees technical evaluations adequately justify the change, and that the NRC is informed of regulatory commitment changes that have safety or regulatory significance in accordance with NEI 99-04.

The licensee manages regulatory commitments using procedure AI 26D-001, Commitment Management System. In accordance with this procedure, commitment changes are evaluated using procedure AI 26A-003, Evaluation of Proposed Change (Other than [Part 50, Section 59 of Title 10 of the Code of Federal Regulations]) with the aid of the flowchart in ATTACHMENT A to AI 26D-001. The NRC staff reviewed Revision 5 of these procedures and concluded that they are consistent with the guidance of NEI 99-04; that the procedures constitute adequate administrative controls for modifying and deleting regulatory commitments made to the NRC; that the programs provide guidance regarding the evaluation of proposed changes to regulatory commitments in terms of safety and regulatory significance; and that the guidance included criteria consistent with NEI 99-04 for determining when it would be appropriate to notify the NRC of a regulatory commitment change.

The NRC staff selected a sample of regulatory commitment changes that were reported to the NRC. In addition, the licensee provided examples of regulatory commitment changes that the licensee has not and does not plan to report to the NRC. The samples of reported and non-reported regulatory commitments are listed in the attached Table 2. The NRC staff found that the licensees CMS had adequately evaluated all of the regulatory commitments that were sampled and reported those changes to NRC that met the criteria in NEI 99-04.

2.3 Additional Observations and Recommendations (a) The licensee explicitly identifies regulatory commitments in outgoing correspondence to the NRC and when such correspondence does not include any commitments, the licensee will include a statement to the effect, There are no commitments associated with this submittal in the cover letter. When such commitments are included in the letter, there is an attachment to the letter that clearly states that the attachment contains regulatory commitments, what these commitments are, and when the commitments will be implemented. These explicit statements that the correspondence contain or do not contain regulatory commitments represent clear and effective communications, and is considered by the NRC staff to be a positive initiative on the part of the licensee.

(b) The licensees commitment tracking software as a part of their document management system was a powerful tool that facilitated the straightforward location of not only information pertaining to the implementation and management of the commitment but also the location of related documents (e.g.,

the source document, procedures in which the commitment was implemented, reports documenting the implementation of the procedure). The licensee staff member assigned to support this audit had very little difficulty retrieving the required documentation.

(c) Some sampled entries within the commitment tracking software had incorrect or absent information (e.g., incorrect status, no closure date). In spite of these inconsistencies and omissions, the correct information was generally available elsewhere within the document management system.

3.0 CONCLUSION

Based on the above audit, the NRC staff concludes that (1) the licensee has an adequate program to implement and manage regulatory commitments, and (2) the licensee has an adequate program to implement and manage changes to regulatory commitments.

4.0 LICENSEE PERSONNEL CONTACTED AT SITE FOR THIS AUDIT Bill Muilenberg Attachments:

1. Table 1: Implemented Regulatory Commitments
2. Table 2: Revised or Deleted Regulatory Commitments Principal Contributor: Adam Hoffman, NRR Date: October 31, 2007

AUDIT OF WOLF CREEK NUCLEAR OPERATING CORPORATION (WCNOC)

MANAGEMENT OF REGULATORY COMMITMENTS AT WOLF CREEK NUCLEAR GENERATING STATION PERFORMED AUGUST 20-21, 2007 LIST OF COMMITMENTS INCLUDED IN AUDIT Table 1. Implemented Regulatory Commitments Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 1 2001-026 11/14/2001 WCNOC will provide the requested Closed During refueling outage 12, a information (NRC Bulletin 2001-01, 5/22/2002 remote visual inspection of the Request 5) or indicate no leakage was top of the reactor vessel head found, within 30 days after plant restart was performed to support an following the next refueling outage. engineering evaluation of its condition. No evidence of leakage through reactor vessel penetrations or reactor vessel penetration nozzle cracking was found. These results were communicated by licensee submittal ET 02-0023 (Agencywide Documents Access and Management System Accession No. ML021610273).

Attachment 1

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 2 2002-025 12/4/2002 WCNOC will conduct a MRP inspection Closed This commitment was plan supplemental visual examination (No date in superseded by NRC Revised in Refueling Outage #14, currently CMS) Order EA-03-009, Issuance of scheduled for spring 2005. First Revised Order (EA-03-009) Establishing Interim Inspection Requirements For Reactor Pressure Vessel Heads at Pressurized Water Reactors.

3 2003-058 9/19/2003 A surveillance procedure for inspection Closed The required elements of the lower RPV head will be developed 12/12/2003 developed for the lower head and will include the following elements: inspection are contained in a

  • Use of VT-2 examination techniques surveillance procedure.
  • 100% circumferential examination of the annulus region between the lower RPV head and the penetration tubing
  • 100% examination of the lower head surface
  • Requirements for pictorial documentation as well as written descriptions of all relevant Indications 4 2003-059 9/19/2003 A bare-metal visual inspection of the Closed The appropriate surveillance lower RPV head will be performed. 11/27/2003 procedure was performed.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 5 2003-060 9/19/2003 WCNOC will submit to the NRC: Closed The required information was

  • a summary of the inspections (No date in provided in licensee submittal performed, CMS) WM 04-0002.
  • the extent of the Inspections,
  • the methods used,
  • a description of the as-found condition of the lower head,
  • a summary of the disposition of any findings of boric acid deposits and any corrective actions taken as a result of indications found.

6 2003-066 12/15/2003 The proposed changes to the WCGS Closed NRC issued Amendment No.

Technical Specifications (Reactor Trip (No date in 156 on 1/31/2005.

System Instrumentation and Engineered CMS) Amendment No. 156 was Safety Features Actuation System implemented on 2/16/2005.

Instrumentation) will be implemented within 90 days of NRC approval.

7 2003-067 12/15/2003 Activities that degrade the availability of Closed These restrictions have been the auxiliary feedwater system, RCS (No date in implemented in procedures.

pressure relief system (pressurizer CMS)

PORVs and safety valves), AMSAC, or turbine trip should not be scheduled when a logic train or RTB train is inoperable for maintenance.

8 2003-068 12/15/2003 One complete ECCS train that can be Closed This restriction has been actuated automatically must be (No date in implemented in procedures.

maintained when a logic train is CMS) inoperable for maintenance.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 9 2003-069 12/15/2003 Activities that cause master relays or Closed These restrictions have been slave relays in the available train to be (No date in implemented in procedures.

unavailable and activities that cause CMS) analog channels to be unavailable should not be scheduled when a logic train or RTB train is inoperable for maintenance.

10 2003-070 12/15/2003 Activities on electrical systems (e.g., AC Closed These restrictions have been and DC power) and cooling systems (No date in implemented in procedures.

(e.g., essential service water and CMS) component cooling water (CCW only for an inoperable logic train)) that support the systems or functions listed above should not be scheduled when a logic train or RTB train is inoperable for maintenance. That is, one complete train of a function that supports a complete train of a function noted above must be available.

11 2003-071 12/15/2003 The drift term used in the WCGS Closed I&C is required to collect this setpoint study was originally based on a (No date in information with each 30 day surveillance interval for COTs. CMS) surveillance. Trends are From historical experience, instrument monitored and the results are drift is expected to remain within the provided to Safety Analysis.

assumptions of the existing setpoint study with the proposed change to a COT Frequency of 184 days. However, this expectation will be validated using future surveillance results subsequent to changing the COT Frequency to a 184 day interval.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 12 2004-080 7/23/2004 The proposed changes to the WCGS Closed The licensee implemented the Technical Specifications (eliminating (No date in changes to the Technical requirement for hydrogen recombiners CMS, Specifications and Technical and hydrogen monitors) will be incorrectly Specification Bases.

implemented within 90 days of NRC listed as approval. Revision to the TS Bases will Open) be implemented pursuant to the TS Bases Control Program, TS 5.5.14, upon implementation of this license amendment.

13 2004-081 7/23/2004 WCNOC has verified that a hydrogen Closed Hydrogen monitors have been monitoring system capable of diagnosing (No date in included in the Technical beyond design-basis accidents is CMS, Requirements Manual.

installed at WCGS and is making a incorrectly regulatory commitment to maintain that listed as capability. The hydrogen monitors will Open) be included in the Technical Requirements Manual. This regulatory commitment will be implemented within 90 days of NRC approval of this amendment request.

14 2005-107 7/31/2005 Submit an update to information Closed The licensee submitted the contained in WCNOCs response to 5/31/2006 information requested in letter Generic Letter 2004-02 Requested WO 06-0028.

Information Item 2.

15 2006-237 9/27/2006 WCNOC will notify the NRC Project Closed The licensee notified the Manager for Wolf Creek Generating 11/06/2006 Project Manager (Jack Station (WCGS) when the ultrasonic Donohew) by email on (UT) examination of the final full 11/06/2006.

structural weld overlay is complete.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 16 2006-238 9/27/2006 WCNOC will provide the results of the Closed The results of the UT UT examinations of the full structural 11/17/2006 examinations were provided in weld overlays of the WCGS Pressurizer letter ET 06-0055.

safety, relief, spray and surge line nozzle welds to the NRC.

The results will include:

  • A listing of indications detected;
  • The type and nature of the indications Also included in the results will be a discussion of any repairs to the overlay material and/or base metal and the reason for the repair.

17 Not in CMS 4/18/2005 If cracking is found in the sample Closed The inspection was performed population of bulges or overexpansions, (No date in by Westinghouse Electric the inspection scope will be increased to CMS) Corporation on 4/22/2005, the 100% of the bulges and overexpansions results of which were reported population for the region from the top of to the NRC in letter ET the hot leg tubesheet to 17 inches below 06-0016.

the top of the tubesheet in the affected steam generator and 20% of the bulges and overexpansions population in the unaffected steam generators from the top of the hot leg tubesheet to 17 inches below the top of the tubesheet.

Item Commitment Commitment Description of Commitment Status Method of Closure No. No. Date 18 Not in CMS 4/18/2005 If cracking is reported at one or more Closed Since no cracking was tube locations not designated as either a (No date in reported, no action was top of the tubesheet expansion CMS) required to fulfill this transition, a bulge or an overexpansion, commitment.

an engineering evaluation will be performed. This evaluation will determine the cause for the signal, e.g.,

some other tube anomaly, in order to identify a critical area for the expansion of the inspection. This expanded inspection will be limited to the identified critical area within 17 inches from the top of the hot leg tubesheet.

19 Not in CMS 6/26/2006 The license amendment (to remove Closed The licensee implemented the containment atmosphere gaseous (No date in changes to the Technical radioactivity monitor from Technical CMS) Specifications and Technical Specification 3.14.15) will be Specification Bases.

implemented within 90 days of issuance.

Final TS Bases changes will be implemented pursuant to TS 5.5.14 at the time the amendment is implemented.

Table 2. Revised or Deleted Regulatory Commitments Item Commitment Commitment Description of Commitment Change to Commitment Reported Evaluation No. No. Change Date to NRC? Consistent with Procedure?

20 1997-179 5/10/2006 The Plant Manager will Work hour limitations will Yes Yes establish a performance be tracked in the cross indicator on approved work functional team panels.

hour deviations. This The Plant Manager will indicator is a tool for remain cognizant of any management monitoring of deviations through authorization frequency and review of the division justification. clock resets and related Condition Reports.

21 1997-181 5/10/2006 Procedure AP 13-001, Procedure was changed Yes Yes Revision 2, Guidelines for to state that work hour WCGS Staff Working Hours, limitations will be will be enhanced to provide included in the cross better guidance. functional team panels.

22 1986-265 12/10/2003 Compliance with Commitment remarks No Yes administrative controls [for was edited to provide combustible materials] will be clarification of the maintained by increased implementation of the inspections by the station fire commitment.

protection specialist.

23 2003-032 8/5/2004 WCNOC will revise Additional guidance is No Yes administrative controls for implemented by a monitoring and evaluating the second procedure to containment atmosphere to provide specific visual require initiation of corrective inspection parameters, action documentation when limits, and notes to sample results indicate define specific actions potential RCS leakage or needed based on the changes to RCS leakage. results.

Attachment 2

Item Commitment Commitment Description of Commitment Change to Commitment Reported Evaluation No. No. Change Date to NRC? Consistent with Procedure?

24 Not Assigned 2/6/2004 Following an unscheduled Only the Plant Safety No Yes reactor shutdown, the Review Committee will Independent Safety review the post-trip Evaluation Group (ISEG) is review, in fulfillment of responsible for performing an requirement 1.1 of independent evaluation of the Generic Letter 83-28, unscheduled reactor trip data Required Actions Based package in the same manner on Generic Implications as the Plant Safety Review of Salem ATWS Events.

Committee.

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