ML073440047
| ML073440047 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/12/2007 |
| From: | Olshan L NRC/NRR/ADRO/DORL/LPLII-1 |
| To: | Brandi Hamilton Duke Power Co |
| Olshan L N, NRR/DORL, 415-1419 | |
| References | |
| TAC MD6762, TAC MD6763, TAC MD6764 | |
| Download: ML073440047 (8) | |
Text
December 12, 2007 Mr. Bruce H. Hamilton Vice President, Oconee Site Duke Power Company LLC 7800 Rochester Highway Seneca, SC 29672
SUBJECT:
OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 - AUDIT OF DUKE POWER COMPANY LLC MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6762, MD6763, AND MD6764)
Dear Mr. Hamilton:
On May 27, 2003, the Office of Nuclear Reactor Regulation published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]. LIC-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institutes (NEIs) 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.
On December 4, 2007, the NRC staff performed an audit of the Duke Power Company LLC (Duke, the licensee) commitment management program at Oconee Nuclear Station, Units 1, 2, and 3 (Oconee). The NRC staff concludes, based on the audit, that the licensee has implemented licensee commitments to the NRC for Oconee on a timely basis and that the licensee has implemented an effective program for managing NRC commitment changes at Oconee. Details of the audit are provided in the enclosed audit report.
Sincerely,
/RA/
Leonard N. Olshan, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Audit Report cc w/encl: See next page
December 12, 2007 Mr. Bruce H. Hamilton Vice President, Oconee Site Duke Power Company LLC 7800 Rochester Highway Seneca, SC 29672
SUBJECT:
OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 - AUDIT OF DUKE POWER COMPANY LLC MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6762, MD6763, AND MD6764)
Dear Mr. Hamilton:
On May 27, 2003, the Office of Nuclear Reactor Regulation published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]. LIC-105 provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made to the NRC by licensees for commercial nuclear reactors. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institutes (NEIs) 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.
On December 4, 2007, the NRC staff performed an audit of the Duke Power Company LLC (Duke, the licensee) commitment management program at Oconee Nuclear Station, Units 1, 2, and 3 (Oconee). The NRC staff concludes, based on the audit, that the licensee has implemented licensee commitments to the NRC for Oconee on a timely basis and that the licensee has implemented an effective program for managing NRC commitment changes at Oconee. Details of the audit are provided in the enclosed audit report.
Sincerely,
/RA/
Leonard N. Olshan, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Audit Report cc w/encl: See next page Distribution:
PUBLIC RidsAcrsAcnwMailCenter LPL2-1 R/F RidsRgn2MailCenter (JMoorman)
RidsnrrDorlLpl2-1 (EMarinos) RidsNrrDorlDpr RidsNrrLAMOBrien (hard copy)
RidsNrrPMLOlshan (hard copy)
RidsOgcRp Accession Number: ML073440047 OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/LPL2-1/BC NAME LOlshan MOBrien EMarinos DATE 12/12/07 12/11 /07 12 /12/07 OFFICIAL RECORD COPY
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF REGULATORY COMMITMENTS MADE BY DUKE POWER COMPANY LLC OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287
1.0 INTRODUCTION
On May 27, 2003, the Office of Nuclear Reactor Regulation (NRR) published Office Instruction LIC-105, Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]. 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 web site (Accession No. ML022750041), 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 Institutes (NEIs) NEI 99-04, Guidance for Managing NRC Commitment Changes. The guidance in NEI 99-04 suggests that licensees use information management systems, annotations to procedures, or other methods to ensure the traceability of regulatory commitments after implementation. The NRC staff and licensees observed that such systems help ensure that subsequent changes to regulatory commitments are evaluated using the change-control guidance in NEI 99-04. The previous guidance document focused on change control and reporting of commitment changes and did not address implementation or traceability issues.
According to LIC-105, 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 Office of Nuclear Reactor Regulation 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 The NRC staff performed an on-site audit at Oconee Nuclear Station, Units 1, 2, and 3 on December 4, 2007, and reviewed commitments made in the past 3 years.
Enclosure
2.1 Verification of Commitment Implementation The primary focus of the audit was to confirm that Duke Power Company LLC (Duke, the licensee) has implemented those commitments made to the NRC as part of past licensing actions/activities. For regulatory commitments that had not yet been implemented, the NRC staff was to ascertain that the commitments had been captured in an effective program for future implementation.
2.1.1 Audit Scope Before the audit, NRC staff identified documents within the past 3 years that contained regulatory commitments meeting the criteria specified by LIC-105. Table 1 lists the licensees commitments that were audited.
The list of the selected regulatory commitments for Oconee 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 (UFSAR), 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), Part 50, 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 UFSARs. 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 these commitments had been included in the plant data base that is used to track the commitments and evaluate the status of completion of each commitment. The NRC staff found that the licensees
commitment tracking program, which is the Plant Investigation Process (PIP), had captured the regulatory commitments that were identified by the NRC staff prior to 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 the 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 the NRC staffs observations regarding the current status of the licensee commitments that were reviewed during the audit.
2.2 Verification of the Licensees Program for Managing Commitment Changes The NRC staff reviewed the licensees procedure, Nuclear System Directive:214, Commitment Management Program, Revision 6, issued June 14, 2002, (NSD 214) against NEI 99-04 guidelines. In particular, Appendix A of NSD 214 defines the process for changing a commitment. In general, NSD 214 follows closely the guidance of NEI 99-04 in that it sets forth the need for identifying, tracking, and reporting commitments, and it provides a mechanism for changing commitments.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) the licensee had implemented, or is tracking for future implementation, its regulatory commitments; and (2) the licensee has implemented an effective program for managing changes to regulatory commitments.
4.0 DUKE PERSONNEL CONTACTED FOR THIS AUDIT R. Gambrell J. Smith R. Todd
Attachment:
Table 1, Audited Written Commitments and Related Information Principal Contributor: L. Olshan Date: December 12, 2007
TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION Dukes Summary of Commitment Dukes Submittal Implementation Status 12/21/04 Perform system leakage test on Unit 2 Complete:
during fall 2005 refueling outage documented in PIP O-04-06201 and Procedure No.
MP/O/A/1720/017 11/30/06 Protect standby shutdown facility diesel Complete:
(2T) fuel vents from tornados documented in PIP O-02-06304 Revise procedures for maintaining Complete:
11/30/06 penetration termination enclosures documented in PIP (15H) O-98-05293 and Procedure No.
IP/O/A/3010/011 10/5/06 Submit a 14-day report on ultrasonic Unit 1 complete:
testing (UT) of pressurizer weld overlays documented in PIP O-06-05418 and letter to NRC dated 11/27/06 Unit 2 complete:
documented PIP O-05-05302 and letter to NRC dated 5/29/07 Unit 3 not complete:
documented in PIP O-05-05302 3/1/06 Update UFSAR to improve discussion of Complete:
accident analyses documented in PIP O-05-01997 and UFSAR Chapter 9, 12/31/06 9/27/06 Five compensatory actions to support Complete:
extension of Keowee Hydro Unit documented in PIP completion time O-06-06234 9/13/07 Submit a 14-day report on UT of DHR Not complete:
line weld overlays documented in PIP O-07-04993
TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION 11/30/06 (5T) Change in commitment to Commitment modify certain masonry walls change documented in PIP O-06-01076 and letter to NRC dated 6/28/07
Oconee Nuclear Station, Units 1, 2, and 3 cc:
Mr. Bruce H. Hamilton Mr. Leonard G. Green Vice President, Oconee Site Assistant Attorney General Duke Power Company LLC NC Department of Justice 7800 Rochester Highway P.O. Box 629 Seneca, SC 29672 Raleigh, NC 27602 Ms. Lisa F. Vaughn Mr. R. L. Gill, Jr.
Associate General Counsel and Managing Manager - Nuclear Regulatory Attorney Issues and Industry Affairs Duke Energy Carolinas, LLC Duke Power Company LLC 526 South Church Street - EC07H 526 S. Church St.
Charlotte, North Carolina 28202 Mail Stop EC05P Charlotte, NC 28202 Manager, LIS NUS Corporation Division of Radiation Protection 2650 McCormick Dr., 3rd Floor NC Dept of Environment, Health, & Natural Clearwater, FL 34619-1035 Resources 3825 Barrett Dr.
Senior Resident Inspector Raleigh, NC 27609-7721 U.S. Nuclear Regulatory Commission 7812B Rochester Highway Mr. Peter R. Harden, IV Seneca, SC 29672 VP-Customer Relations and Sales Westinghouse Electric Company Mr. Henry Porter, Director 6000 Fairview Road Division of Radioactive Waste Management 12th Floor Bureau of Land and Waste Management Charlotte, NC 28210 Dept. of Health and Env. Control 2600 Bull St. Mr. Henry Barron Columbia, SC 29201-1708 Group Vice President, Nuclear Generation and Chief Nuclear Officer Mr. Michael A. Schoppman P.O. Box 1006-EC07H Framatome ANP Charlotte, NC 28201-1006 1911 North Ft. Myer Dr.
Suite 705 Mr. Charles Brinkman Rosslyn, VA 22209 Director, Washington Operations Westinghouse Electric Company Mr. B. G. Davenport 12300 Twinbrook Parkway, Suite 330 Regulatory Compliance Manager Rockville, MD 20852 Oconee Nuclear Site Duke Energy Corporation Ms. Kathryn B. Nolan ON03RC Senior Counsel 7800 Rochester Highway Duke Energy Carolinas, LLC Seneca, SC 29672 526 South Church Street - EC07H Charlotte, NC 28202