ML082400045
| ML082400045 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/29/2008 |
| From: | John Hughey Plant Licensing Branch 1 |
| To: | Christian D Dominion Nuclear Connecticut |
| Hughey J, NRR/DORL, 301-415-3204 | |
| References | |
| RIS-00-017, TAC MD8477, TAC MD8478 | |
| Download: ML082400045 (9) | |
See also: RIS 2000-17
Text
August 29, 2008
Mr. David A. Christian
President and Chief Nuclear Officer
Dominion Nuclear Connecticut, Inc.
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
SUBJECT:
MILLSTONE POWER STATION, UNIT NOS. 2 AND 3 - AUDIT OF THE
LICENSEES MANAGEMENT OF REGULATORY COMMITMENTS
(TAC NOS. MD8477 AND MD8478)
Dear Mr. Christian:
The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue
Summary (RIS) 2000-17, AManaging Regulatory Commitments Made by Power Reactor
Licensees to the NRC Staff,@ dated September 21, 2000, that the Nuclear Energy Institute
document NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains
acceptable guidance for controlling regulatory commitments. RIS 2000-17 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 a periodic
audit of licensees commitment management programs to determine whether the licensees
programs are consistent with the industry guidance in NEI 99-04, and that regulatory
commitments are being effectively implemented. The previous audit of the Dominion Nuclear
Connecticut, Inc. (licensee) commitment management program was performed at the Millstone
Power Station, (MPS) Unit Nos. 2 and 3 in Waterford, Connecticut on October 7, 2004
(Agencywide Documents Access and Management Systems (ADAMS) Accession No.
The subsequent audit was performed at the site on May 20, 2008. The NRC staff concludes
that, based on the audit: (1) the licensee has an adequate program to implement and manage
regulatory commitments; and (2) the licensee has an adequate program to implement and
manage regulatory commitment changes. Details of the audit are set forth in the enclosed audit
report.
D. Christian
- 2 -
The NRC staff appreciates the resources that were made available by Millstone station staff
during the audit. If you have any questions, please contact me at (301) 415-3204.
Sincerely,
/ra/
John D. Hughey, Project Manager
Plant Licensing Branch I-2
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket Nos. 50-336 and 50-423
Enclosure:
Audit Report
cc w/encl: See next page
D. Christian
- 2 -
The NRC staff appreciates the resources that were made available by Millstone station staff
during the audit. If you have any questions, please contact me at (301) 415-3204.
Sincerely,
/ra/
John D. Hughey, Project Manager
Plant Licensing Branch I-2
Division of Operating Reactor Licensing
Office of Nuclear Reactor Regulation
Docket Nos. 50-336 and 50-423
Enclosure:
Audit Report
cc w/encl: See next page
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DATE
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08/28/08
08/29/08
OFFICIAL RECORD COPY
Millstone Power Station, Unit Nos. 2 and 3
cc:
Lillian M. Cuoco
Senior Counsel
Dominion Resources Services, Inc.
120 Tredegar Street, RS-2
Richmond, VA 23219
Edward L. Wilds, Jr., Ph.D.
Director, Division of Radiation
Department of Environmental
Protection
79 Elm Street
Hartford, CT 06106-5127
Regional Administrator, Region I
U.S. Nuclear Regulatory Commission
475 Allendale Road
King of Prussia, PA 19406
First Selectmen
Town of Waterford
15 Rope Ferry Road
Waterford, CT 06385
Charles Brinkman, Director
Washington Operations Nuclear Services
Westinghouse Electric Company
12300 Twinbrook Pkwy, Suite 330
Rockville, MD 20852
Senior Resident Inspector
Millstone Power Station
c/o U.S. Nuclear Regulatory Commission
P. O. Box 513
Niantic, CT 06357
Mr. J. W. "Bill" Sheehan
Co-Chair NEAC
19 Laurel Crest Drive
Waterford, CT 06385
Ms. Nancy Burton
147 Cross Highway
Redding Ridge, CT 00870
Mr. Evan W. Woollacott
Co-Chair
Nuclear Energy Advisory Council
128 Terrys Plain Road
Simsbury, CT 06070
Mr. Joseph Roy
Director of Operations
Massachusetts Municipal Wholesale
Electric Company
P.O. Box 426
Ludlow, MA 01056
Mr. J. Alan Price
Site Vice President
Dominion Nuclear Connecticut, Inc.
Millstone Power Station
Building 475, 5th Floor
Rope Ferry Road
Waterford, CT 06385
Mr. Chris L. Funderburk, Director
Nuclear Licensing &
Operations Support
Dominon Resource Services, Inc.
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060-6711
Mr. Robert T. Griffin, Director
Nuclear Safety & Licensing
Dominion Nuclear Connecticut, Inc.
Millstone Power Station
Building 475, 5th Floor
Rope Ferry Road
Waterford, CT 06385
Enclosure
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION
LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS
MILLSTONE POWER STATION, UNIT NOS. 2 AND 3
DOCKET NOS. 50-336 AND 50-423
1.0
INTRODUCTION AND BACKGROUND
The U.S. Nuclear Regulatory Commission (NRC) informed licensees in Regulatory Issue
Summary (RIS) 2000-17, AManaging Regulatory Commitments Made by Power Reactor
Licensees to the NRC Staff,@ dated September 21, 2000, that the Nuclear Energy Institute
document NEI 99-04, AGuidelines for Managing NRC Commitment Changes,@ contains
acceptable guidance for controlling regulatory commitments. RIS 2000-17 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 a
periodic audit of licensees commitment management programs to determine whether the
licensees programs are consistent with the industry guidance in NEI 99-04, and that regulatory
commitments are being effectively implemented. The previous audit of the Dominion Nuclear
Connecticut, Inc. (DNC or, the licensee) commitment management program was performed at
the Millstone Power Station, Unit Nos. 2 and 3 (MPS) in Waterford, Connecticut on
October 7, 2004 (Agencywide Documents Access and Management Systems (ADAMS)
Accession No. ML043090370).
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 perform a periodic audit of 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.).
2.0
AUDIT PROCEDURE AND RESULTS
An audit was performed at MPS on May 20, 2008. The audit reviewed commitments made
since the previous audit which was conducted October 4, 2004. The audit consisted of two
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.
- 2 -
The NRC staff concludes that, based on the audit: (1) the licensee has an adequate program to
implement and manage regulatory commitments, or to track for future implementation of
regulatory commitments; and (2) the licensee has an adequate program to implement and
manage regulatory commitment changes.
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. In general, the NRC
staff found that the licensees commitment tracking program had implemented the regulatory
commitments.
2.1.1 Audit Scope
Before the audit, the NRC staff searched ADAMS for the licensees licensing actions and
licensing activity submittals dated since the previous audit. The NRC staff requested that the
licensee provide a list of current open and closed regulatory commitments. From these lists, the
NRC staff chose a sample of items to review to ensure that the items had been captured in an
effective program for implementation. Criteria from the NRC staffs guidance documents were
used to select a sample of regulatory commitments. The commitments selected for the audit
are shown in Table 1 entitled, Audited Commitments.
2.1.2 Commitment Tracking Database Program
The licensees commitments are tracked in a computer database named the Commitment
Tracking System (CTS). CTS is defined as a repository for information associated with specific
commitments and actions taken to implement each commitment.
DNCs Administrative Procedure number LI-AA-110, Commitment Management, describes the
licensees regulatory commitment management process. The procedure defines how written
commitments to regulatory agencies are to be made only by those individuals with signature
authority for correspondence addressed to regulatory agencies.
Once commitments are identified, items are assigned a commitment type and entered into the
CTS. As described in LI-AA-110, only regulatory commitments are tracked in the system.
Following identification, the licensee enters committed due dates (i.e., those committed in formal
documentation) or establishes a due date as appropriate. These items are then assigned to the
appropriate functional area manager for implementation. The CTS maintains a record of the
required action(s), responsible party, status, due dates, and comments.
The NRC staff found that CTS: (1) adequately tracks commitments; and (2) provides an
adequate method of linking together a summary of the issue, action type, the lead department,
the responsible individual, due date, and extensions when used in accordance with the
procedure. The NRC staff also found that the CTS had captured the regulatory commitments
that were identified by the NRC staff.
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Table 1 - Audited Commitments
Commitment
Tracking
Number
Dominion
Nuclear
Inc.
Submittal
Date
Commitment
Summary/Description
Licensee
Implementation
Status
RCR-42915
RCR-42916
09/08/2004
Maintain the hydrogen
recombiners in the
Technical Requirements
Manual (TRM).
Closed
RCR-42920
RCR-42921
RCR-42922
RCR-42923
RCR-42924
RCR-42925
11/05/2004
Independent Spent Fuel
Storage Installation
(ISFSI) commitments.
Open
RCR-42928
12/24/2004
Replace MPS2
pressurizer.
Closed
RCR-42944
RCR-42045
12/21/2004
Provide periodic dose
information to the NRC
via an industry database.
Closed
RCR-42947
RCR-42948
RCR-42949
RCR-42950
09/01/2005
Commitments associated
with Generic Letter (GL) 2004-02, PWR
Containment Sumps.
Working
RCR-42951
09/01/2005
Submit licensee
amendment request to
change the actuation
method and start time of
the MPS3 recirculation
spray system pumps. (GL 2004-02)
Closed
RCR-42967
05/16/2006
Submit structural
evaluation report to NRC
for MPS3 core exit
thermocouple nozzles.
Closed
RCR-42983
RCR-42984
RCR-42985
RCR-42986
01/31/2007
Commitments related to
mitigation activities
associated with Alloy
600-82-182 pressurizer
butt welds.
Closed
RCR-42987
10/04/2007
Commitments related to
Relief Request RR-89-61
Closed
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2.1.3 Audit Results
The NRC staff reviewed reports generated by the tracking programs and closure documentation
to evaluate the status of commitments as reported in the CTS. The NRC staff confirmed that
the commitments selected for the sample had been appropriately implemented in station
procedures, design change programs and other station administrative processes as appropriate.
2.2
Verification of the Licensees Program for Managing NRC Commitment Changes
2.2.1 Audit Scope
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 MPS is contained in LI-AA-110,
Revision 0, Commitment Management. 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. The licensee had not reported any
commitment changes to the NRC since the previous audit conducted on October 7, 2004.
The NRC staff reviewed the licensees commitment change process to: (1) evaluate the
licensees methodology for proposed changes to regulatory commitments with particular
consideration given to the intent of the original commitment and the safety and regulatory
significance of the proposed change; and (2) evaluate the licensees method of communicating
commitment changes to the NRC when reports are warranted due to either safety or regulatory
considerations. The NRC staff also evaluated the licensees administrative controls for
maintaining commitment traceability (e.g., markings or notations within procedures) to ensure
that licensee personnel are able to recognize that future changes to the affected design features
or operating practices require evaluation of the proposed change in accordance with the
commitment change control process.
2.2.2 Audit Results
The NRC staff reviewed the licensees procedure LI-AA-110, Revision 0, Commitment
Management, against NEI 99-04. In particular, Section 5.4 of the procedure lists NEI 99-04 as
a source reference. In general, the NRC staff found that LI-AA-110, Revision 0, follows closely
the guidance of NEI 99-04, as it sets forth the need for identifying, tracking and reporting
commitments, and it provides a mechanism for changing commitments. Attachment 2 of
LI-AA-110, Revision 0, provides detailed instructions regarding making changes to a
commitment.
LI-AA-110, Revision 0, provides instructions for modification, revision or deletion of a regulatory
commitment. A Regulatory Commitment Change Evaluation form is used to perform an
applicability determination for any proposed commitment change. This evaluation process will
determine if the proposed commitment change is covered by another codified process
(e.g., 10 CFR 50.59, Changes, tests and experiments, 10 CFR 50.92, Issuance of
amendment, or 10 CFR 50.54, Conditions of licenses).
- 5 -
Once commitment changes are identified, a Regulatory Commitment Change Evaluation form is
completed and reviewed. Some differences exist with respect to the NEI 99-04 guidance
regarding reporting of changed commitments in order to conform to the MPS Corrective Action
Program. However, in general, NRC notification is provided as necessary, as determined by the
commitment change evaluation process.
For changes that do not require immediate NRC notification, notification is provided with the
licensees biannual submittal of the revision to the Updated Final Safety Analysis Report. CTS
items tracking the commitment are then updated, as appropriate, to document the regulatory
commitment change.
The NRC staff concludes that the procedure used by the licensee to manage commitments is
appropriate and effective.
3.0
CONCLUSION
The NRC staff concludes, based on the above audit, that: (1) the licensee has implemented
NRC commitments on a timely basis; and (2) the licensee has implemented an effective
program for managing NRC commitment changes.
4.0
LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT
W. Brown, Nuclear Technical Specialist III, Licensing Department
R. McIntosh, Nuclear Engineer III, Licensing Department
W. Bartron, Licensing Supervisor, Licensing Department
Principal Contributor: J. Hughey
Date: August 29, 2008