ML082240088
| ML082240088 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/14/2008 |
| From: | Kalyanam N NRC/NRR/ADRO/DORL/LPLIV |
| To: | Entergy Operations |
| References | |
| TAC MD9332 | |
| Download: ML082240088 (16) | |
Text
August 14, 2008 Vice President, Operations Entergy Operations, Inc.
Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093
SUBJECT:
WATERFORD STEAM ELECTRIC STATION, UNIT 3 - AUDIT OF THE LICENSEE=S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NO.
MD9332)
Dear Sir/Madam:
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 and 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 the regulatory commitments are being effectively implemented.
An audit of Waterford Steam Electric Station, Unit 3 (Waterford 3) commitment management program was performed at the plant site on July 24 and 25, 2008. The NRC staff concludes, based on the audit, that Entergy Operations Inc. (the licensee) has implemented NRC commitments on a timely basis, and (2) the licensee has implemented an effective program for managing regulatory commitments made to NRC and their changes at Waterford 3. The details of the audit including the NRC staff observations and recommendations are set forth in the enclosed audit report.
The NRC staff appreciates the resources that were made available by your staff, both before and during the audit. If there are any questions, I can be contacted at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-382
Enclosure:
Audit Report cc w/encl: See next page
ML082240088 OFFICE LPL4/PM LPL/4/LA LPL4/BC (A) LPL4/PM NAME NKalyanam GLappert JDonohew Nkalyanam DATE 8/12/08 8/12/08 8/14/08 8/14/08 Waterford Steam Electric Station, Unit 3 (2/25/08) cc:
Senior Vice President Mr. Timothy Pflieger Entergy Nuclear Operations Environmental Scientist - Supervisor P.O. Box 31995 REP&R-CAP-SPOC Jackson, MS 39286-1995 Louisiana Department of Environmental Quality Vice President, Oversight P.O. Box 4312 Entergy Nuclear Operations Baton Rouge, LA 70821-4312 P.O. Box 31995 Jackson, MS 39286-1995 Parish President Council St. Charles Parish Senior Manager, Nuclear Safety P.O. Box 302
& Licensing Hahnville, LA 70057 Entergy Nuclear Operations P.O. Box 31995 Chairman Jackson, MS 39286-1995 Louisiana Public Services Commission P.O. Box 91154 Senior Vice President Baton Rouge, LA 70825-1697
& Chief Operating Officer Entergy Operations, Inc. Mr. Richard Penrod, Senior Environmental P.O. Box 31995 Scientist/State Liaison Officer Jackson, MS 39286-1995 Office of Environmental Services Northwestern State University Associate General Counsel Russell Hall, Room 201 Entergy Nuclear Operations Natchitoches, LA 71497 P.O. Box 31995 Jackson, MS 39286-1995 Resident Inspector Waterford NPS Manager, Licensing P.O. Box 822 Entergy Operations, Inc. Killona, LA 70057-0751 Waterford Steam Electric Station, Unit 3 17265 River Road Regional Administrator, Region IV Killona, LA 70057-3093 U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS ENTERGY OPERATIONS INC.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NOS. 50-382
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 and 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 the 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, relief requests, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.).
2.0 AUDIT PROCEDURE AND RESULTS An audit of the Waterford Steam Electric Station, Unit 3 (Waterford 3) commitment management program was performed at the plant site on July 24 and 25, 2008. The audit consisted of two parts: (1) verification of the licensee=s implementation of regulatory commitments that have been completed, and (2) verification of the licensee=s program for managing changes to regulatory commitments.
2.1 Verification of Licensees Implementation of Regulatory 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 they have been captured in an effective program for future implementation.
ENCLOSURE
2.1.1 Audit Scope The audit addressed a sample of commitments, majority of which were made during the review period of approximately the last 3 years, and some much older. The audit focused on regulatory commitments made in writing to the NRC as a result of past licensing actions (amendments, exemptions, relief requests, etc.) or licensing activities (bulletins, generic letters, etc.), licensing event reports, and inspection reports.
2.1.2 Audit Results Entergy Operations Inc. (the licensee) has implemented Procedure EN-LI-110, Commitment Management Program,@ which identifies the methods and site organization tools for managing development, review, and implementation of station commitments.
The documents furnished by the licensee during the audit included summary sheets providing the status of the commitments and appropriate backup documentation, as needed (i.e.,
commitment change evaluation form, plant procedures, examination records, and/or other plant documentation). The NRC staff reviewed the documents and summarized the selected commitments information in the attachment to this audit report.
The staff audit was intended to confirm that the licensee has documented its implementation of its regulatory commitments made to the NRC staff as part of past licensing communications, and the commitments that had not yet been implemented or incorporated in design bases documents are captured in an effective manner for future implementation.
The NRC staff audit of the licensees commitment management program for Waterford 3 did not identify any regulatory commitments that were not satisfied or incorporated. The licensee has maintained the database well and the commitments selected for this audit were easily traceable in the database. In case the commitment was already incorporated, the database provided the status of the commitment providing reference to the implementation document.
Based on the results of the on-site audit, the NRC staff believes the licensee has implemented the regulatory commitments management program effectively in accordance with LIC-105, AManaging Regulatory Commitments Made by Licensees to the NRC,@ and consistent with NEI 99-04.
The attachment to this audit report contains details of the audit and a summary of the audit results.
2.2 Verification of the Licensee=s Program for Managing Regulatory Commitment Changes The focus of this part of the audit was to verify that the licensee has established administrative controls for satisfying, modifying, or deleting commitments made to the NRC.
The NRC staff found that the process sets forth the need for identifying, initiating, tracking, and reporting commitments, managing a change or deviation from a previously completed commitment.
As set forth in Section 2.1 above, the NRC staff found that the licensee had addressed each regulatory commitment selected for this audit. As a result of review of the information
provided by the licensee, 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 2.2.1 Audit Results The licensee carries out its obligations under its regulatory commitments by the processes that are outlined in the procedures. Any changes to the commitments are processed through the established processes and changes are reported to the NRC in accordance with the recommendations of LIC-105. However, no commitment changes were identified during the audit (for the commitments included in the scope of review), except for change to the implementation date.
The NRC staff audit of Entergys commitment management program did not identify any regulatory commitments that were not satisfied or incorporated. The licensee has maintained the Commitment Management Program at a satisfactory level and the commitments selected for this audit were easily traceable in Program. The Program provided an accurate status of the commitments and provided the reference to the implementation document.
Based on the results of the on-site audit, the NRC staff believes the licensee has implemented regulatory commitment changes appropriately, in accordance with LIC-105 and consistent with NEI 99-04.
3.0 OBSERVATIONS AND RECOMMENDATIONS In the Commitment List, under the columns titled, Text, Comments and Status a short description of the corrective action to be taken, general comments, and the status of the commitment are provided chronologically. While the auditors found that many of these notes contained the author(s) (with initials) and date(s), this was not done in a consistent and uniform manner. Many of the notes lacked the authors identity and the date. The auditors are of the opinion that these additions provide a valuable historical background.
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.
5.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT Robert Murillo, Ron Williams, Greg Scott Principal Contributors: N. Kalyanam G. Lappert Date: August 14, 2008
Attachment:
Summary of Audit Results
REGULATORY COMMITMENTS AND
SUMMARY
OF AUDIT RESULTS PERFORMED ON JULY 24 AND 25, 2008 WATERFORD STEAM ELECTRIC STATION, UNIT 3 Letter Number Subject Commitment Description of Implementation Status No. Commitment LER-87-018 dated Inspection of P-14296 All Safety Related WITHDRAWN and, therefore, CLOSED October 23, 1987 Containment Containment Pressure Instruments are Commitment Change Evaluation Form Operable when (CCEF) 2008-0002 (identified as Required. CCVF) Redundancy requirement being deleted from OP-903-027 since the requirement exists in MI-3-302, Containment Pressure Loop Check and the requirement in OP-903-027 is redundant. Therefore, the commitment made in P-14296 is deleted.
W3B85-0016 dated Corrective Action and P-14178 All CIWAs identified as WITHDRAWN and, therefore, CLOSED January 31, 1985 Assessments for non-conformance are Since W3 completed its operational adverse quality periodically analyzed by phase, the adverse conditions for trends. Corrective Action & Construction QA deficiencies are no Assessments for longer evident, it is not necessary to adverse quality trends. continue to track this as a commitment.
Reference:
CCEF-2006-0010.
ILN-06-0023 dated RAI GL 2004-02 A-26908 Provide a response to CLOSED February 9, 2006 Request for Additional Information (RAI) Response to the RAI was provided on Potential Impact of February 9, 2008, (i.e.,) before February Debris Blockage on 29, 2008, as required in the NRC letter Emergency to NEI.
Recirculation During Design Basis Accidents at Pressurized Water Reactors, as a result of Page 1 of 7
letter from NRC to NEI, dated November 30, 2007, supplemental licensee responses to generic letter 2004-02, Potential impact of debris blockage on emergency recirculation during design basis accidents at pressurized-water reactors CNRO-2002-0019, W3-R&R-Use of A-26369 Entergy Operations Inc. CLOSED dated March 29, Mechanical Nozzle (Entergy, the licensee) 2002 Seal Assemblies will visually inspect for Mechanical Nozzle Sealing Assemblies leakage in and around (MNSAs installed on pressurizer (PZR) the counter- during refueling outage 12 were bore/annulus region of removed. Since no MNSA are currently each installed MNSA-2 installed, the commitment is removed..
device during each Refueling Outage CNRO-2002-00010, Use of MNSAs A-26309 Use of MNSAs limited CLOSED dated March 12, to 2 cycles if installed.
2001 Mechanical Nozzle Sealing Assemblies (MNSAs_ installed on pressurizer (PZR) during refueling outage 12 were removed. Since there are no MNSA currently installed, the commitment is removed.
WF-101-0025, dated Emergency Plan (EP) A-26107 Entergy will submit to CLOSED March 14, 2001 Changes NRC, within 4 years of receipt of the SER, a Letter from Entergy to NRC, dated report summarizing the January 4, 2007, Summary Report of drills and results. The Emergency Planning Drills and Drill NRC submittal will Results provides provide confirmation of a report summarizing the drills and drill the effectiveness of the results (from Page 2 of 7
EP Changes. that period) to provide confirmation of the effectiveness of the Emergency Plan changes, and thus fulfillment of the validation program.
CNRO-2003/00003, RAI Regarding A-26475 [P]rior to performing OPEN dated February 11, Proposed Alternative repairs on RPV nozzles 2003 to ASME examination above the J-weld that Since no repairs were performed during Requirements for involve using these RFOs 13 or 14 or 15, this is maintained Repairs Performed on relief requests, Entergy as an on-going, continuing compliance.
Reactor Vessel Head will notify the NRC of Unless repairs are required, no (RPV) Penetrations the need to make such notification to NRC is required.
repairs. This notification will provide information on (a) examination methods, (b) flaw location, orientation, and critical dimensions, and (c) repair plans.
CNRO-2003/00003 RAI Regarding A-26474 [W]hen repairs are OPEN dated February 11, Proposed Alternative performed using the 2003 to ASME examination subject relief requests, Since no repairs were performed on the Requirements for Entergy will perform RPV during RFOs 13 or 14 or 15, this is Repairs Performed on follow-up volumetric maintained as an on-going, continuing Reactor Vessel Head examinations using the compliance. Unless repairs are Penetrations ultrasonic examination required, no volumetric examinations method on the repaired using the ultrasonic examination method RPV nozzles during the is required next scheduled refueling outage provided the RPV head is not scheduled for replacement during that outage.
W3F1-2004-0048 Letter from Entergy to A-26690 Visual inspections of OPEN dated June 8, 2004 NRC dated June 8, the LTAs will be Page 3 of 7
2004, Supplement to performed in the On-going, continuing commitment.
Request for spent fuel pool during Exemption to the the outage, continuing During RF 14, and 15, video inspections Cladding Material compliance at the were performed. All the measurements Specified in were satisfactory and met the criteria.
end of cycles 14, 15 10 CFR 50.46 and 10 Assembly appearance was good. The CFR 50 Appendix K & 16. commitment is extended to the next to Allow Use of RFO, RFO 16.
Optimized ZIRLO Lead Test Assemblies CNRO-2003-00050, Relaxation request A-26583 Any future crack-growth OPEN dated October 2, from U.S. Nuclear analyses performed for 2003 and CNRO- Regulatory Operating Cycle 14 and Commitment has been rescheduled 2004-00020, dated Commission (NRC) future cycles for RPV outside of RFO 14 and later of RFO 15 April 15, 2004 order EA-03-009 for head penetrations will since no crack growth analyses was the vessel head be based on an required in both outages for the RPV penetration vent line acceptable crack growth head penetrations.
nozzle rate formula.
W3F1-2005-0074 License Amendment A-26881 Prior to the use of CLOSED dated October 25, Request. ZRB2, burnable 2005 To Allow the use of absorber coatings, the Commitment has been satisfied with Zirconium Diboride fuel design will be 50.59 evaluation.
and Modify TS analyzed with applicable 6.9.1.11, Core NRC staff approved Operating Limits codes and methods.
Report WF198-0202 dated P-25510 Security will notify all DELETED AND CLOSED December 14, 1998 Safeguard information authorized users In the referenced letter, this action was whenever site identified as an enhancement and not procedure W5.503, Site commitment. The Procedure W5.503 Safeguards Information has been deleted and replaced by fleet Procedure, is revised procedure EN-NS-204.
EN-NS-204 requires communication of procedure changes to effected Page 4 of 7
stakeholders to ensure they are cognizant of changes.
The CCEF states that this action is administrative in nature.
WF194-0233 dated Violation: Failure to P-22238 The licensee failed to CLOSED January 5, 1995 implement corrective correct the deficiencies actions/identified involving erratic flow The root cause for the violation was corrective actions indications from the identified to be the failure of an engineer component cooling to initiate the effective corrective action water, containment documentation.
spray and low pressure safety injection system With the cultural and process changes flow transmitters. that are in effect now, and with the Specifically, the familiarization of the different processes Identified corrective (use of Problem Evaluation/information actions were assigned Request (PEIR), CR, and ER to a station modification processes), the odds of a similar request (MI 035) that violation occurring now are considered did not exist and was remote.
not implemented.
CNRO-2003-00050, Relaxation request A-26582 If the revised analysis OPEN dated October 2, from NRC order EA- shows that the crack 2003 and CNRO- 03-009 for the vessel growth acceptance Commitment has been rescheduled 2004-00020, dated head penetration vent criteria are not outside of RFO 14 and later of RFO 15 April 15, 2004 line nozzle exceeded during either since no revised crack growth analyses Operating Cycle 14 or was required in both outages for the the subsequent RPV head penetrations.
operating cycle, Entergy shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised.
CNRO-2003-00050, Relaxation request A-26580 If Entergy's revised OPEN dated October 2, from NRC order EA- analysis shows that the Page 5 of 7
2003 and CNRO- 03-009 for the vessel crack growth This Entergy analysis referenced in the 2004-00020, dated head penetration vent acceptance criteria are commitment is the analysis that April 15, 2004 line nozzle exceeded prior to the incorporates a crack-growth formula end of Operating Cycle different from that described in Footnote 14 (following the 1 of the Order, as provided in EPRI upcoming refueling Report MRP-55. Entergy is aware that outage), this relaxation the NRC staff has not yet completed a is rescinded and final assessment regarding the Entergy will, within 72 acceptability of the EPRI report. If the hours, submit to the NRC staff finds that the crack-growth NRC written justification formula in MRP-55 is unacceptable, for continued operation. Entergy shall revise its analysis that justifies relaxation of the Order within 30 days after the NRC informs Entergy of an NRC-approved crack-growth formula.
If Entergy's revised analysis shows that the crack growth acceptance criteria are exceeded prior to the end of Operating Cycle 14 (following the upcoming refueling outage), Entergy will, within 72 hours3 days <br />0.429 weeks <br />0.0986 months <br />, submit to the NRC written justification for continued operation.
WF104-0036 dated LAR To Modify TS A-26700 The corrosion thickness OPEN June 17, 2004 5.3.1, Fuel will be calculated using Assemblies and TS the best estimate A best-estimate corrosion calculation 6.9.1.11.1, Core models and methods performed indicated that the maximum Operating Limits described in topical oxide thickness for any Zirco clad fuel Report report CENPD-404-P. rod during cycle 15 operation was estimated to be 18.8 microns, which is less than the 100 micron limit.
Therefore, the commitment is being extended to RFO 15.
W3F1-2005-0063 Generic Letter 2004- A-26863 Request for Extension CLOSED dated September 02, "Potential Impact of Completion date for 16, 2005 of Debris Blockage Resolution of GL 2004- This commitment has been superseded on Emergency 02 by the commitment made in Entergy Recirculation During letter dated May 12, 2008, and approved Page 6 of 7
Design Basis by the NRC staff in its letter dated May Accidents at 22, 2008.
Pressurized-Water Reactors" Letter from Entergy Response to Generic A-26863 Entergy plans to CLOSED to NRC, dated Letter 2004-02, evaluate the adequacy September 16, 2005 "Potential Impact of of the strainer design This commitment has been superseded (W3F1-2005-0063) Debris Blockage on and will incorporate by the commitment made in Entergy Emergency chemical effects once letter dated May 12, 2008, and approved Recirculation During the tests results to by the NRC staff in its letter dated May Design Basis quantify chemical debris 22, 2008.
Accidents at effect on head-loss Pressurized-Water have been published.
Reactors" At the same time, an additional evaluation will be performed to determine the impact of the sump pH, spray duration, and the increased temperature profile on the head-loss due to chemical effects.
(Scheduled completion date: 12/20/2006)
Letter from Entergy Response to Generic A-26862 W-3 plant modifications CLOSED to NRC, dated Letter 2004-02, to install new pump September 16, 2005 "Potential Impact of strainers will be Sump pump strainer modules have been (W3F1-2005-0063) Debris Blockage on implemented during the installed per WO 763999 Task 08. This Emergency fall 2006 refueling commitment has been satisfied with Recirculation During outage response and implementation.
Design Basis Scheduled completion Accidents at date: 12/20/2006 Pressurized-Water Reactors" Page 7 of 7