ML072890025
| ML072890025 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 11/28/2007 |
| From: | Wang A NRC/NRR/ADRO/DORL/LPLIV |
| To: | Ridenoure R Omaha Public Power District |
| Wilkins, L E, NRR/DORL/LPL4, 415-1377 | |
| References | |
| TAC MD6999 | |
| Download: ML072890025 (8) | |
Text
November 28, 2007 Mr. R.T. Ridenoure Vice President - Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
Post Office Box 550 Fort Calhoun, NE 68023-0550
SUBJECT:
FORT CALHOUN STATION, UNIT 1 - AUDIT OF LICENSEE REGULATORY COMMITMENT MANAGEMENT PROGRAM (TAC NO. MD6999)
Dear Mr. Ridenoure:
An audit of the Fort Calhoun Station, Unit 1 regulatory commitment management program was performed at Omaha Public Power Districts (OPPD) office in Omaha, NE, on August 27 and August 28, 2007. Based on this audit, the NRC staff concludes that Fort Calhoun Station has an adequate program to implement and manage regulatory commitments. Details of the audit are provided in the enclosed audit report.
If you have any questions, I may be reached at (301) 415-1445.
Sincerely,
/RA/
Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285
Enclosure:
As stated cc w/encl: See next page
September 2007 Ft. Calhoun Station, Unit 1 cc:
Mr. R.T. Ridenoure Vice President - Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
Post Office Box 550 Fort Calhoun, NE 68023-0550 Winston & Strawn ATTN: James R. Curtiss, Esq.
1700 K Street, N.W.
Washington, DC 20006-3817 Chairman Washington County Board of Supervisors P.O. Box 466 Blair, NE 68008 Mr. John Hanna, Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 310 Fort Calhoun, NE 68023 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Ms. Julia Schmitt, Manager Radiation Control Program Nebraska Health & Human Services R & L Public Health Assurance 301 Centennial Mall, South P.O. Box 95007 Lincoln, NE 68509-5007 Mr. David J. Bannister, Site Director Fort Calhoun Station Omaha Public Power District Fort Calhoun Station FC-1-1 Plant P.O. Box 550 Fort Calhoun, NE 68023-0550 Mr. Joe L. McManis Manager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
P.O. Box 550 Fort Calhoun, NE 68023-0550 Ms. Melanie Rasmussen Radiation Control Program Officer Bureau of Radiological Health Iowa Department of Public Health Lucas State Office Building, 5th Floor 321 East 12th Street Des Moines, IA 50319
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION (NRC)
FORT CALHOUN STATION. UNIT 1 DOCKET NO. 50-285
1.0 INTRODUCTION AND BACKGROUND
In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing NRC Commitments, dated February 22, 2000, the NRC staff informed the Commission that it had found that NEI 99-04, Guidelines for Managing NRC Commitment Changes, contains acceptable guidance for controlling regulatory commitments made by power reactor licensees to the NRC. A regulatory commitment, as defined in NEI 99-04, 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.
NEI 99-04 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by the licensees for commercial nuclear reactors to the NRC staff. According to 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. Nuclear Reactor Regulation (NRR) Project Managers 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 (e.g., amendments, reliefs, exemptions), and activities (e.g., bulletins, generic letters).
2.0 AUDIT PROCEDURE AND RESULTS The NRC staff defined the period covered by this audit to go back approximately 3 years covering 2004 through 2007. The audit was performed at Omaha Public Power Districts (OPPD) office in Fort Calhoun, Nebraska on August 27 and August 28, 2007.
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. The NRC staff also determined whether those commitments that had not yet been implemented were captured in an effective program for future implementation.
2.1.1 Audit Scope Before the audit, OPPD sent the NRC staff the licensees licensing action and licensing activity submittals dated in the last 3 years. Table 1 lists randomly picked licensee commitments from this list.
The NRC staff reviewed three licensee procedures related to the Commitment Tracking Program:
NOD-QP-23, Commitment Tracking, NOD-QP-33, Signature and Commitment Authority, and NOD-QP-34, Ongoing Commitment Program.
The NRC staff reviewed these procedures against the guidance in NEI 99-04. The NEI guidance states that any significant commitment of utility resources should follow a reasoned management decision-making process to ensure proper management control of utility resources. NOD-QP-23 is the primary procedure for the handling of regulatory commitments.
The procedure also allows for processing of internally identified action items associated with other correspondence or management request. This procedure establishes a defined methodology for the assignment, tracking, revision and closing of commitment tasks. NOD-QP-33 provides guidance for determining who defines regulatory commitments, who are authorized to make regulatory commitments and who can sign correspondence to the NRC.
NOD-QP-34 is the procedure for ongoing commitments. Ongoing commitments are those commitments which are to be performed periodically or continuously. Non-ongoing commitments are those that have a definite due date.
The licensee started a Commitment Tracking System (CTS) in the 1987/1988 time frame. This system was later renamed to the Commitment Action Tracking System (CATS). In August 1998 CATS was superseded by the Resource Asset Management System (RAMS). RAMS is a software program that contains numerous modules of which one is the regulatory commitment tracking. However, the licensee noted that commitments to NRC Generic Letters, Bulletins, Information Notices, Regulatory Information Summaries, and Notice of Violations are tracked in a separate data base call the Condition Report (CR). The licensee noted that RAMS and CR have different owners.
2.1.2 Audit Results Although RAMS and CR have different process owners, the staff found that in most cases, commitments in the CR system resulted in generating a commitment item in the RAMS regulatory commitment tracking system. Some discrepancies in tracking several ongoing commitments appeared to be an artifact of the change from CATS to RAMS. RAMS appeared to be an effective tool to manage the commitment actions and the licensee was able to provide detailed printouts of the status of audited items.
The NRC staff reviewed reports generated by the tracking program for the commitments listed in Table 1 to evaluate the status of completion. The NRC staff found that the licensees commitment tracking program had adequately captured all the audited regulatory commitments.
2.2 Verification of the 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 commitments made to the NRC. The NRC staff examined the licensees commitment tracking system and the NRC commitment management procedures.
As previously stated, changing a commitment is discussed in the licensees procedures entitled, NOD-QP-23 and NOD-QP-34. NOD-QP-34 provides details for making changes to or deviating from an ongoing commitment. Attachment 1,@Ongoing Commitment Review Form,@
and Figure 1, ACommitment Management Change Process,@ provide the details for changing a commitment. NOD-QP-34 appeared to follow the guidance contained in NEI-99-04. The NRC staff noted that NOD-QP-23 did not provide the same guidance for changing a commitment as NOD-QP-34. OPPD indicated that to change a non-ongoing commitment OPPD would be required by NOD-QP-23 to appropriately notify the NRC and depending on the outcome of a 50.59 review might also need to request NRC approval. OPPD noted that this is consistent with the guidance in NOD-QP-34. The NRC staff noted that NOD-QP-23 should either reference NOD-QP-34 and/or NEI-99-04. OPPD indicated that they are considering combining NOD-QP-23 and NOD-QP-34.
3.0 CONCLUSION
The NRC staff concluded that, based on the above audit, the licensee has implemented an effective program to manage current and future regulatory commitments and regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Michael Edwards Thomas Matthews Principal Contributors: A. Wang L. Wilkins Date: August 28, 2007
TABLE 1 (Page 1 of 2)
AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION Fort Calhoun Submittal NRC Issuance Summary of Commitment, and Licensees Tracking Number Licensee Implementation Status 6/06/2007 Under review Delete the Technical Specification requirements associated with the hydrogen purge system. The change is consistent with revisions of Section 50.44 of Title 10 of the Code of Federal Regulations, Combustible gas control for nuclear power reactors.
AR 40639 Commitment to be tracked when requested amendment is issued.
06/19/2006 04/06/06 FCS Pump Relief Request E-2 for 4th 10-year Pump and Valve IST. OPPD will incorporate Relief into Program Plan and other documents as appropriate.
AR38793 Complete Pump and Valve IST, Revision 3 signed by Engineering Programs Manager, J. B. Herma 6/09/06 2/20/06 NRC Generic Letter 2006-01 1/20/06 OPPD will submit a License Amendment Request consistent with TSTF-449, Revision 4, by May 31, 2006 AR 38435 Complete OPPD letter of 5/30/06 signed by Bannister
Fort Calhoun Submittal NRC Issuance Summary of Commitment, and Licensees Tracking Number Licensee Implementation Status 1/20/06 12/06/05 OPPD will provide a response to a Demand for Information regarding key radiological mitigation strategies.
AR38181 Complete OPPD letter of 1/20/06 signed by Bannister 08/11/05 03/01/06 Change the Technical Specification to reflect NRCs issuance of Amendment - Inoperability of Snubbers.
AR 38621 Complete OPPD letter of 5/30/06 signed by Bannister 3/21/05 5/11/05 NRC Bulletin 2005-01 2/11/05 OPPD will provide 30 - day response indicating whether they will implement the requested actions as well as a 90-day response to include a detailed description of the steps to be taken to complete the complete the actions, the results of the inventory verifications, the basis for concluding that they have accurately accounted for all special nuclear material (SNM) in its possession, and the basis for concluding that programs have been established and implemented that satisfy the applicable regulatory requirements related to the control and accounting of SNM.
AR36802 Complete 3/21/2005 - LIC-05-0030 transmitted to NRC via electronic information exchange (EIE) 5/11/05 - LIC-05-0059 transmitted to NRC EIE 9/16/04 Letter, A. Wang to R.T.
Ridenoure, 8/23/04 OPPD will provide a RAI response to LAR on Prevention of Sump Clogging AR35877 Complete OPPD letter of 9/16/04 signed by Ridenoure