ML080700209
| ML080700209 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 03/20/2008 |
| From: | Donohew J NRC/NRR/ADRO/DORL/LPLIV |
| To: | Entergy Operations |
| Donohew J N, NRR/DORL/LPL4, 415-1307 | |
| References | |
| TAC MD7775 | |
| Download: ML080700209 (10) | |
Text
March 20, 2008 Vice President, Operations Grand Gulf Nuclear Station Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - AUDIT OF THE LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO. MD7775)
Dear Sir or Madam:
On February 19-20, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an audit at the Grand Gulf Nuclear Station, Unit 1 (GGNS) in Port Gibson, MS. The audit examined the Entergy regulatory commitment management program. The NRC staff concludes that, based on the audit (1) GGNS had implemented NRC commitments on a timely basis; and (2) GGNS had implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
If you have any questions, please contact me at 301-415-1307.
Sincerely,
/RA/
Jack N. Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416
Enclosure:
As stated cc w/encl: See next page
ML080700209 OFFICE NRR/LPL4/GE NRR/LPL4/PM NRR/LPL4/LA NRR/LPL4/BC NAME LWilkins JDonohew JBurkhardt THiltz DATE 3/12/08 3/20/08 3/11/08 3/20/08
Grand Gulf Nuclear Station (2/25/08) cc:
Senior Vice President Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Vice President, Oversight Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety
& Licensing Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President
& Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Associate General Counsel Entergy Nuclear Operations P.O. Box 31995 Jackson, MS 39286-1995 Manager, Licensing Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 State Health Officer State Health Board P.O. Box 1700 Jackson, MS 39215 Attorney General Asst. Attorney General State of Mississippi P.O. Box 22947 Jackson, MS 39225-2947 Office of the Governor State of Mississippi Jackson, MS 39201 Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, LA 70804-9005 President Claiborne County Board of Supervisors P.O. Box 339 Port Gibson, MS 39150 Richard Penrod, Senior Environmental Scientist/State Liaison Officer Office of Environmental Services Northwestern State University Russell Hall, Room 201 Natchitoches, LA 71497 Chief, Energy and Transportation Branch Environmental Compliance and Enforcement Division Mississippi Department of Environmental Quality P.O. Box 10385 Jackson, MS 39289-0385 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 399 Port Gibson, MS 39150
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE U.S. NUCLEAR REGULATORY COMMISSION (NRC)
GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416
1.0 INTRODUCTION AND BACKGROUND
In SECY-00-045, Acceptance of NEI [Nuclear Energy Institute] 99-04, Guidelines for Managing NRC [U.S. Nuclear Regulatory Commission] 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.
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. In accordance with NEI 99-04, the NRC is informed of any regulatory commitment change that has safety or regulatory significance.
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. The NRCs Office of 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 On February 19-20, 2008, the project manager (PM) for Grand Gulf Nuclear Station, Unit 1 (GGNS) completed an audit at the GGNS Unit 1. This audit examined the GGNS regulatory commitment management program, the Commitment Management System (CMS), since completion of the prior 3-year audit in December 2005 (Agencywide Document Access and Management System (ADAMS) Accession No. ML043520027). The audit results were
discussed on February 20, 2008, with Rick Gardner, Director of Nuclear Safety Assurance, Charles Bottemiller, Licensing Manager, and Michael Larson, Plant Licensing Engineer.
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. For commitments that had not yet been implemented, the NRC staff aimed to ascertain that those commitments had been captured in an effective program for future implementation.
2.1.1 Audit Scope NRR Office Procedure LIC-105, Managing Regulatory Commitments Made By Licensees to the NRC, limits the audit of regulatory commitments to those made in writing to the NRC as a result of past licensing actions (amendments, reliefs, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Accordingly, the commitments integrated into the final safety analysis report (FSAR), quality assurance program, site security plan, emergency plan, or other documents governed by a change-control mechanism contained in regulations such as Title 10 of the Code of Federal Regulations (10 CFR), Section 50.59 or 10 CFR 50.54 are excluded from the scope of the audit.
Before the audit, the NRC staff searched ADAMS for the licensees licensing actions and licensing activity submittals in the last 3 years. GGNS also sent the NRC staff the licensees licensing action and licensing activity submittals dated in the last 3 years. The staff used these sources in addition to the criteria in LIC-105 to select from regulatory commitments contained in this population for the audit. These regulatory commitments are shown on Table 1 (attached).
A list of the regulatory commitments selected for the audit, along with the source documents, was provided to GGNS a few days in advance of the site visit to facilitate an effective audit.
GGNS manages their regulatory commitments through its administrative control procedure in its Nuclear Management Manual in EN-LI-110, Commitment Management Program. The procedure includes guidance on how to identify, document, track, implement, and change a commitment. The purpose of the procedure is also to provide guidance to prevent inadvertent deletion of a commitment without appropriate review.
2.1.2 Audit Results 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 captured all the regulatory commitments that were identified by the NRC staff before the audit. Although the NRC was not able to locate a reference document as listed in its Commitment Management System, GGNS staff was able to quickly identify the error, locate the item, and correct the record.
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 of 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 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 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, engineering disciplines, and licensing actions. No commitment changes were found in the sample.
The NRC staff reviewed the licensees procedure entitled, Commitment Management Program, EN-LI-110, Revision 1, against NEI 99-04. Attachments 9.3, 9.4, and 9.5 of EN-LI-110, Revision 1, provide details regarding making changes to a commitment. In general, EN-LI-110, Revision 1, is consistent with 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 which includes notifying the NRC.
The effectiveness of a procedure can be indicated by the products that are produced by the procedure. As set forth in Section 2.1 above, the NRC staff found that the licensee had properly addressed each regulatory commitment selected for this audit. As a result of review of the licensees information, as well as information from other sources, the NRC staff found no reason to differ from the licensees reported status of the audited commitments. Thus, the NRC staff surmises 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 regulatory commitments, and (2) the licensee had implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Michael Larson William Abraham Charles Bottemiller Rick Gardner
Attachment:
Table 1, Audited: Written Commitments and Related Information Principal Contributors: L. Wilkins I. Anchondo Date: March 20, 2008
TABLE 1 AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION Attachment Page 1 of 4 Item Number Grand Gulf Nuclear Station Submittal NRC TAC No.
GGNS Source Document NRC Issuance Summary of Commitment and Licensees Tracking Number Licensee Implementation Status (Documents listed are in GGNS Database) 1 3/30/2005 MC6651 GNRO-05/0 0016 Issuance of Amendment No. 169 via letter dated February 1, 2006 A statement will be added to the TS
[Technical Specifications] bases to clarify that the overlap verification is to be performed as part of the CHANNEL CHECK, SR [Surveillance Requirement]
3.3.1.1.1.
A-35486 Completed via closure document: GIN 06/00059 dated February 15, 2006 2
6/3/2005 MC1630 GNRO-05/0 0033 Safety Evaluation on proposed Emergency Action levels - letter dated July 13, 2005 Information contained in this submittal will be included in the Emergency Plan or Basis as applicable.
R-35493 Closed via closure document LDC 2003-093 3
6/3/2005 MC1630 GNRO-05/0 0033 Safety Evaluation on proposed Emergency Action levels - letter dated July 13, 2005 Approved changes will be discussed and agreed upon with State authorities as required.
R-35494 Closed via closure document LDC 2003-093 4
7/19/2005 N/A GNRI-05/00 069 Order EA-05-0007 In accordance with 10 CFR § 2.202, the Licensee must, and any other person adversely affected by this Order may, submit an answer to this Order, and may request a hearing on this Order, within 20 days of the date of this Order.
R-35536 Ongoing and being implemented via CNRO 06/00004
TABLE 1 AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION Attachment Page 2 of 4 Item Number Grand Gulf Nuclear Station Submittal NRC TAC No.
GGNS Source Document NRC Issuance Summary of Commitment and Licensees Tracking Number Licensee Implementation Status (Documents listed are in GGNS Database) 5 8/17/2005 MC8180 GNRO-05/0 0050 Issuance of Amendment No. 170 via letter dated September 29, 2006 Entergy is making the following regulatory commitments:
Completion of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> fire wrap installation on raceways that the analysis determines require it and maintenance of portions of the existing Kaowool wrap.
Revision of the combustible exclusion areas as determined by this assessment.
Revision of the combustible storage areas as determined by this assessment.
Relocation of security lockers to an area outside of combustible exclusion areas.
Upgrade to the existing fire protection program to ensure the plant is maintained in accordance with the bases for this analysis R-35524 Closed via closure document ER 2000-0916 6
11/21/2005 MC6651 GNRO-05/0 0056 Issuance of Amendment No. 169 via letter dated February 1, 2006 Plant procedures will require the DG critical trips to be tested at least once every 18 months to ensure proper functioning.
A-35541 Ongoing and being implemented via procedures:
06-OP-1P81-R-0001, 06-OP-1P75-R-0003, and 0004.
Also via SR 3.8.1.13
TABLE 1 AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION Attachment Page 3 of 4 Item Number Grand Gulf Nuclear Station Submittal NRC TAC No.
GGNS Source Document NRC Issuance Summary of Commitment and Licensees Tracking Number Licensee Implementation Status (Documents listed are in GGNS Database) 7 5/16/2006 MD1736 CNRO-06/0 0030 Request acceptance letter dated October 2, 2006 Entergy will monitor the part of the whole body within each compartment (and/or composite compartment) that receives the highest dose.
P-35624 Ongoing and being implemented via Procedure EN-RP-504 8
5/19/2006 MC8180 GNRO-06/0 0021 Issuance of Amendment 170 via letter dated September 29, 2006 The cumulative effect of the changes in the risk analyses will be tracked and included in subsequent changes,
[pursuant to the performance monitoring principles in RG [Regulatory Guidance]
1.174,] at least on a qualitative basis P-35592 Ongoing and being implemented via PRA MODEL C/REQ 2517 and GG-2517.
9 7/13/2006 MD1749 CNRO-0600 034 Request acceptance letter dated July 18, 2006 Entergy will notify the manufacturer (as well as the U.S. Nuclear Industry) of any defects experienced during the use of the Muduroa V4F1 R devices.
P-35611 Ongoing and being implemented via Procedure EN-RP-503 10 12/5/2006 MD0985 GNRI-06/00 118 Letters dated December 5 and 13, 2006, from Catherine Haney Will provide a RAI response concerning GL 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power.
A-35757 Completed via closure document : GNRO 07/00001 dated 1/31/07
TABLE 1 AUDITED: WRITTEN COMMITMENTS AND RELATED INFORMATION Attachment Page 4 of 4 Item Number Grand Gulf Nuclear Station Submittal NRC TAC No.
GGNS Source Document NRC Issuance Summary of Commitment and Licensees Tracking Number Licensee Implementation Status (Documents listed are in GGNS Database) 11 1/11/2007 MD4536 GNRO-07/0 0002 Conforming License Amendment via letter dated July 18, 2007 Entergy will fully implement the BWR mitigation strategies as described in the general description in attachment 1 in Plant Procedures or Guidance (Tables A.5-1 thru A.5-10). Note A.503 - No specific response required & A.5 Addressed by A.5-2 P-35763 Ongoing and being implemented via procedures:
MAJOR EVENT
- RESPONSE, 05-S-01-STRATEGY, 04-1-01-G33-1, 05-1-02-VI-5, 04-1-01-C11-1, 12 1/11/2007 MD4536 GNRO-07/0 0002 Conforming License Amendment via letter dated July 18, 2007 Entergy will conduct training on the mitigation strategy procedures or guidelines will be commensurate with the level of training provided for severe accident management guidelines.
P-35764 Ongoing and being implemented via LP GEXM-LOT-EPT19, LP GLP-OPS-B5B00