ML082110129
| ML082110129 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/04/2008 |
| From: | Orf T NRC/NRR/ADRO/DORL/LPLII-2 |
| To: | Stall J Florida Power & Light Co |
| Orf, Tracy J.; NRR/DORL 415-2788 | |
| References | |
| TAC MD6858, TAC MD6859 | |
| Download: ML082110129 (6) | |
Text
August 4, 2008 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company Post Office Box 14000 Juno Beach, Florida 33408-0420 SUBJECT TURKEY POINT UNITS 3 AND 4 - AUDIT OF THE LICENSEE=S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6858 AND MD6859)
Dear Mr. Stall:
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U. S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains acceptable guidance for controlling regulatory commitments. It also, encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees commitment management programs once every 3 years to determine whether the licensees programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented.
An audit of Turkey Point=s commitment management program was performed at the Turkey Point Nuclear Plant in Homestead, Florida, on June 27, 2008. The NRC staff concludes, based on the audit, that (1) Turkey Point has implemented NRC commitments on a timely basis, and (2) Turkey Point has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
Tracy J. Orf, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Audit Report cc w/encl: See next page
August 4, 2008 Mr. J. A. Stall Senior Vice President, Nuclear and Chief Nuclear Officer Florida Power & Light Company Post Office Box 14000 Juno Beach, Florida 33408-0420 SUBJECT TURKEY POINT UNITS 3 AND 4 - AUDIT OF THE LICENSEE=S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD6858 AND MD6859)
Dear Mr. Stall:
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U. S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains acceptable guidance for controlling regulatory commitments. It also, encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation has instructed its staff to perform an audit of licensees commitment management programs once every 3 years to determine whether the licensees programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented.
An audit of Turkey Point=s commitment management program was performed at the Turkey Point Nuclear Plant in Homestead, Florida, on June 27, 2008. The NRC staff concludes, based on the audit, that (1) Turkey Point has implemented NRC commitments on a timely basis, and (2) Turkey Point has implemented an effective program for managing NRC commitment changes. Details of the audit are set forth in the enclosed audit report.
Sincerely,
/RA/
Tracy J. Orf, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-250 and 50-251
Enclosure:
Audit Report cc w/encl: See next page DISTRIBUTION:
PUBLIC LPL2-2 R/F RidsNrrDorlLPL2-2 RidsNrrPMTOrf RidsNrrLABClayton RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn2MailCenter RidsNrrPMBMoroney RidsNrrPMLRegner RidsNrrPMBMozafari ACCESSION No.: ML082110129 NRR-106 OFFICE LPL2-2/PM LPL2-2/ LA LPL2-2/PM LPL2-2/BC NAME TOrf BClayton BMozafari FSaba for TBoyce DATE 07 / 30 /08 07 / 30 /08 07 / 31 /08 08 / 04 /08 OFFICIAL RECORD COPY
J. A. Stall Florida Power and Light Company TURKEY POINT PLANT cc:
Mr. Mano Nazar Senior Vice President and Nuclear Chief Operating Officer Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408 M. S. Ross, Managing Attorney Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Marjan Mashhadi, Senior Attorney Florida Power & Light Company 801 Pennsylvania Avenue, NW.
Suite 220 Washington, DC 20004 William Jefferson, Jr.
Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 County Manager Miami-Dade County 111 Northwest 1 Street, 29th Floor Miami, Florida 33128 Senior Resident Inspector Turkey Point Nuclear Plant U.S. Nuclear Regulatory Commission 9762 SW. 344th Street Florida City, Florida 33035 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, Florida 32399-1741 Mr. Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, Florida 32399-2100 Attorney General Department of Legal Affairs The Capitol Tallahassee, Florida 32304 Michael Kiley Plant General Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW. 344th Street Florida City, FL 33035 Olga Hanek, Licensing Florida Power and Light Company Turkey Point Nuclear Plant 9760 SW. 344th Street Florida City, FL 33035 Don E. Grissette Vice President, Nuclear Operations, South Region Florida Power and Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Abdy Khanpour Vice President, Engineering Support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Mark E. Warner Vice President, Nuclear Plant support Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420 Peter Wells, Acting VP, Nuclear Training and Performance Improvement Florida Power & Light Company P.O. Box 14000 Juno Beach, FL 33408-0420
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS TURKEY POINT, UNIT NOS. 3 AND 4 DOCKET NOS. 50-250 AND 50-251
1.0 INTRODUCTION AND BACKGROUND
In Regulatory Issue Summary 2000-17, AManaging Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff,@ dated September 21, 2000, the U. S. Nuclear Regulatory Commission (NRC) informed licensees that the Nuclear Energy Institute (NEI) document NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains acceptable guidance for controlling regulatory commitments. It also encouraged licensees to use the NEI guidance or similar administrative controls to ensure that regulatory commitments are implemented and that changes to the regulatory commitments are evaluated and, when appropriate, reported to the NRC.
The NRC Office of Nuclear Reactor Regulation (NRR) has instructed its staff to perform an audit of licensees commitment management programs once every 3 years to determine whether the licensees programs are consistent with the industry guidance in NEI 99-04, and that regulatory commitments are being effectively implemented.
NEI-99-04 defines a Aregulatory commitment@ as 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.
NRR guidelines direct the NRR Project Manager to audit the licensee=s commitment management program by assessing the adequacy of the licensee=s 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 An audit of the Turkey Point commitment management program was performed at the Turkey Point Nuclear Plant in Homestead, Florida, on June 27, 2008, with supplemental information provided by the licensee through July 22, 2008. The audit was the first and reviewed commitments made generally within the previous 3 years. The audit consisted of two major parts: (1) verification of the licensee=s implementation of NRC commitments that have been completed and (2) verification of the licensee=s program for managing changes to NRC commitments.
Enclosure
2.1 Verification of Licensee=s Implementation of NRC Commitments The primary focus of this part of the audit is to confirm that the licensee has implemented commitments made to the NRC as part of past licensing actions/activities. For commitments not yet implemented, the NRC staff determines whether they have been captured in an effective program for future implementation.
2.1.1 Audit Scope The audit addressed a sample of commitments made during the review period. The audit focused on regulatory commitments (as defined above) made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, generic letters, etc.). Commitments made in Licensee Event Reports or in response to Notices of Violation may be included in the sample, but the review will be limited to verification of restoration of compliance, not the specific methods used. Before the audit, the NRC staff searched the Agencywide Documents Access and Management System (ADAMS) for the licensee=s submittals during in the last 3 years and selected a representative sample for verification.
The audit excluded the following types of commitments that are internal to licensee processes:
(1)
Commitments made on the licensee=s own initiative among internal organizational components.
(2)
Commitments that pertain to milestones of licensing actions/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/activity was completed.
(3)
Commitments made as an internal reminder to take actions to comply with existing regulatory requirements such as regulations, Technical Specifications, and Updated Final Safety Analysis Reports. Fulfillment of these commitments was indicated by the licensee having taken timely action in accordance with the subject requirements.
2.1.2 Audit Results Before the audit, the NRC staff searched ADAMS for the licensees submittals during the 3 years prior to the audit and selected a representative sample for verification. The licensee provided the documentation to support the NRC staffs audit in each of these samples. The licensees documentation included summary sheets providing the status of the commitment and appropriate backup documentation, as needed (e.g., plant procedures, examination records, and/or other plant documentation).
The NRC staff found that the licensees commitment tracking programs had captured the regulatory commitments that had been identified by the NRC staff prior to the audit.
Additionally, the NRC staff reviewed plant procedures that had been revised as a result of commitments made by the licensee to the NRC. The NRC staff found that the procedures had been revised in accordance with the commitments made to the NRC.
2.2 Verification of the Licensee=s Program for Managing NRC Commitment Changes The primary focus of this part of the audit is to verify that the licensee has established administrative controls for modifying or deleting commitments made to the NRC. The NRC staff compared the licensee=s process for controlling regulatory commitments to the guidelines in NEI-99-04, which the NRC has found to be an acceptable guide for licensees to follow for managing and changing commitments. The process used at Turkey Point is contained in procedure LDI-01, NRC Commitment Change Process. The audit reviewed a sample of commitment changes that included changes that were or will be reported to the NRC, and changes that were not or will not be reported to the NRC. The audit also verifies that the licensee=s commitment management system includes a mechanism to ensure traceability of commitments following initial implementation. This ensures that licensee personnel are able to recognize that future proposed changes to the affected design features or operating practices require evaluation in accordance with the commitment change control process.
2.2.1 Audit Results The process used at Turkey Point for managing commitments is contained in plant procedure LDI-01, NRC Commitment Change Process. It requires Turkey Point Licensing to identify and track commitments using a process similar to that of NEI 99-04. Attachment 1 to LDI-01 provides an evaluation process to aid in the decision making process regarding scope changes to a commitment. This process is identical to the guidance provided as figure A-1 in NEI 99-04.
Scope changes must be evaluated, and justified by the responsible organization at Turkey Point. According to plant procedure NPF-300, "Signature Authority," any change to the NRC commitment correspondence is required to be authorized by the Senior Vice President-Nuclear Operations.
Additionally, the NRC staff reviewed Turkey Point Licensing Departments list of updated commitments for the 3 years prior to the audit. The staff found that the basis/justification provided for the change to each commitment was acceptable; and that the changes were managed effectively, in accordance with plant procedures.
3.0 CONCLUSION
The NRC staff concludes, based on the above audit, that (1) Turkey Point has implemented commitments in a timely basis, or is tracking them for future implementation; and (2) Turkey Point has implemented an effective program to manage regulatory commitment changes.
4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Stavroula Mihalakea and Olga Hanek Principal Contributor: Tracy Orf