ML082800342
| ML082800342 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/22/2008 |
| From: | Wang A Plant Licensing Branch IV |
| To: | Conway J Pacific Gas & Electric Co |
| Wang, A B, NRR/DORL/LPLIV, 415-1445 | |
| References | |
| TAC MD9667, TAC MD9668 | |
| Download: ML082800342 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 22, 2008 Mr. John Conway Senior Vice President - Station Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 770000 San Francisco, CA 94177-0001
SUBJECT:
DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - AUDIT OF PACIFIC GAS AND ELECTRIC COMPANY'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD9667 AND MD9668)
Dear Mr. Conway:
An audit of the Pacific Gas and Electric Company (PG&E) regulatory commitment management program was performed at the Diablo Canyon Power Plant site in Avila Beach, California on September 17-18, 2008. In Regulatory Issue Summary 2000-17, "Managing 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 document NEI 99-04, "Guidelines 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 regulatory commitments are being effectively implemented.
J. Conway -2 The NRC staff concludes, based on the audit, that PG&E has implemented NRC commitments on a timely basis and has implemented an effective program for managing NRC commitment changes at Diablo Canyon Power Plant. Details of the audit are set forth in the enclosed audit report.
Sincerely, r~~ i) - l\
CU-0v~ A.I CUy1~-
Alan Wang, Project ~anager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosure:
Audit Report cc w/encl: See next page Additional Distribution via ListServ
Diablo Canyon Power Plant, Units 1 and 2 cc:
Sierra Club San Lucia Chapter City Editor c/o Henriette Groot The Tribune 1000 Montecito Road 3825 South Higuera Street Cayucos, CA 93430 P.O. Box 112 San Luis Obispo, CA 93406-0112 Ms. Nancy Culver San Luis Obispo Mr. Ed Bailey, Chief Mothers for Peace Radiologic Health Branch P.O. Box 164 State Department of Health Services Pismo Beach, CA 93448 P.O. Box 997414 (MS 7610)
Sacramento, CA 95899-7414 Mr. Truman Burns Mr. Robert Kinosian Mr. James R. Becker, Vice President California Public Utilities Commission Diablo Canyon Operations 505 Van Ness, Room 4102 and Station Director San Francisco, CA 94102 Diablo Canyon Power Plant P.O. Box 3 Diablo Canyon Independent Safety Avila Beach, CA 93424 Committee ATTN: Robert R. Wellington, Esq. Jennifer Tang Legal Counsel Field Representative 857 Cass Street, Suite D United States Senator Barbara Boxer Monterey, CA 93940 1700 lVIontgomery Street, Suite 240 San Francisco, CA 94111 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Richard F. Locke, Esq.
Pacific Gas & Electric Company P.O. Box 7442 San Francisco, CA 94120 Mr. David H. Oatley, Vice President and General Manager Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424
AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGULATORY COMMITMENTS MADE BY THE LICENSEE TO THE NUCLEAR REGULATORY COMMISSION PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AI'JD 2 DOCKET NOS. 50-275 AND 50-323
1.0 INTRODUCTION AND BACKGROUND
In Regulatory Issue Summary 2000-17, "Managing 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 99-04, "Guidelines 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 regulatory commitments are being effectively implemented.
NEI-99-04 defines a "regulatory 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 I'JRR 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 Pacific Gas and Electric Company (PG&E or licensee) program was performed at the Diablo Canyon Power Plant (DCPP) site in Avila Beach, California on September 17 -18, 2008. The NRC staff dealt mainly with the Regulatory Services Department, which has a key role in the administration of PG&E's Regulatory Commitment Program. The last audit was performed at the DCPP in February 2005. This audit covered a period of time going back approximately 3 years prior to the prior audit. This audit consists of two major parts: (1)
-2 verification of the licensee's implementation of !\IRC commitments that have been completed and (2) verification of the licensee's program for managing changes to NRC commitments.
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.). Before the audit, the NRC staff searched ADAMS for licensee's submittals during in the last 3 years and selected a representative sample for verification. PG&E's commitments are implemented through Management Directive X14, "Commitment Management," and its supporting Plant Administrative Procedures XI4.ID1, "Commitment Identification and Tracking Process," and X14.ID2, "Commitment Change Process."
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 (TSs), 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 The NRC staff reviewed reports generated by PG&E's tracking program for the commitments listed in the attached table to evaluate the status of completion. The NRC staff found that PG&E's commitment tracking program had incorporated all the regulatory commitments that were selected by the NRC staff for this audit.
The NRC staff also reviewed plant procedures that had been revised as a result of commitments made by PG&E to the NRC. The attached table summarizes what the NRC staff observed as the current status of licensee regulatory commitments for those selected.
-3 2.2 Verification of PG&E'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.
At DCPP, Management Directive XI4, "Commitment Management," and its supporting procedures XI4.ID1, "Commitment Identification and Tracking Process," and XI4.ID2, "Commitment Change Process," includes procedures for managing regulatory commitment changes. 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. The NRC staff reviewed these procedures and concluded that, in general, these procedures follow the guidance of NEI-99-04; set forth the need for identifying, tracking, and reporting commitments, and provide a mechanism for changing commitments.
Based on a review of the licensee's Commitment Change Summary Reports from 2005-2007 and various approved Commitment Change Requests from 2005-2008, as per procedure XI4.ID2, the NRC staff found that the commitment change process at DCPP conforms to the guidance of NEI-99-04. In addition, the NRC staff notes that from 2005 to 2007 the number of commitment changes decreased from 9 to 5 to 1, respectively, indicating that PG&E has worked diligently to meet its regulatory commitments.
The NRC staff found that PG&E had properly addressed each regulatory commitment selected for this audit and found that the commitment change process at DCPP conforms to the guidance of NEI-99-04. As a result of reviewing PG&E's information, as well as information from other sources, the NRC staff concludes that the procedure used by PG&E for managing NRC commitment changes is appropriate and effective.
2.3 PG&E's Self-Assessments of the Regulatory Commitment Management Program The NRC staff requested information from PG&E regarding any self-assessments performed on the regulatory commitment management program. The last self-assessment was performed in 2004, by the Strategic Teaming and Resource Sharing (STARS) Integrated Regulatory Assessment Group, which evaluated DCPP procedures and process for managing the NRC commitments in accordance with the guidance of NEI-99-04. The self-assessment made several meaningful recommendations which were reiterated in our February 2005 audit. The licensee opened several Action Requests (AIRs) to address these findings and they are discussed in Section 2.5.
- 4 2.4 Additional Observations and Recommendations The commitment management procedure and its supplements provide guidance for tracking several types of commitments. These procedures ensure that regulatory commitments made to the NRC in written correspondence are actively managed. The procedure ensures that regulatory commitments made to the NRC in written correspondence are actively managed.
Management includes capturing new commitments, changing existing commitments, and deleting commitments. Regulatory commitments are divided into two categories single task or recurring task commitments. Single task commitments are tracked in the AIR database which is part of the Plant Information Management System (PIMS) and Recurring Task are tracked in the Procedure Commitment Database (PCD). The databases include a description of the commitment, the origin of the commitment, responsible department or individuals and the due date. This procedure is based on the recommendations of NEI 99-04.
Plant licensing is responsible for performing an outgoing correspondence screen of all applicable outgoing plant correspondence for regulatory commitments and entering them in the appropriate databases. This pre-screen assigns a statement of commitment, reviewing organization, single or recurring task, and tracking document. Plant licensing reviews the applicable correspondence from the NRC to ensure that the re-statements of the regulatory commitments by the NRC are accurate. Once the commitments are confirmed, an entry is made either as an AIR or a PCD. AIRs are a sub-database of the PIMS database. AIRs are single task commitments and can be closed when the regulatory commitment is Implemented. If a commitment is determined to be a recurring commitment, it is entered into the PCD. For the purpose of the audit, we selected several AIRs and PCD items, checked to determine that the items captured the commitments correctly, looked at printouts of the AIRs and PCOs to see the status of the action associated with the commitment and confirmed that the AIRs and PCOs reflected the status for completion or future action. We found no deviations or missed commitments from the items reviewed. The licensee did identify one missed commitment.
The licensee noted that amendments, in general, do not generate regulatory commitments. The implementation of TS amendments, therefore, would not necessarily be tracked in the AIRs database as a regulatory commitment.
2.5 Conclusions from Previous NRC Audit The following are conclusions from the previous NRC audit and their resolution:
(a) PG&E does not identify regulatory commitments in outgoing correspondence to the NRC, and has no such procedural requirement at DCPP. This may result in the staff not having the same understanding as PG&E, regarding what commitments are being made in the submittal, and whether the commitments made are appropriate regulatory commitments. Providing a list of regulatory commitments, either in the cover letter or an attachment, will assist both the NRC and PG&E in explicit recognition and better management of regulatory commitments. Likewise, if no regulatory commitments are being made in the submittal, a statement stating such should be made in the cover letter.
-5 An NR was opened to address this issue. The NR revised X11.1 01 to state that NRC submittals should explicitly list in the cover letter all regulatory commitments contained in the submittal. Based on this audit the NRC staff has concluded that PG&E has addressed this issue. Our review has found that the more recent correspondence has clearly defined regulatory commitments in its licensing correspondence including amendments and relief request.
(b) At DCPP, the PIMS is used to track regulatory commitments via its several subsystems, such as Action Request/Evaluation (AR/AE), Nonconformance Report Action (NCR ACT), and Procedure Commitment Database (PC D). DCPP Procedure XI4.ID1, "Commitment Identification and Tracking Process," requires that an AR/AE or NCR ACT be initiated to track one-time commitments and recurring commitments be tracked in the PCD. However, when the NRC staff requested from the licensee a complete listing and current status of all regulatory commitments being tracked by these subsystems, the licensee staff could not provide such a consolidated list. Rather, the licensee provided several printouts from these subsystems to demonstrate how regulatory commitments are managed at DCPP.
Therefore, it is recommended that rather than searching several subsystems to find status of commitments, PG&E establish and maintain a comprehensive listing of 'all regulatory commitments, in a spreadsheet, or a computer data base for easy tracking and resolution of these commitments.
An NR was opened to address this issue. PG&E stated that while the commitments are in several subsystems and produce different outputs, they all do reside in PIMS. PG&E is developing a unique and linked database for commitment data records. This consolidated data base concept for tracking commitments is called Systems Applications Products (SAP). PG&E will be using SAP notifications as a record for commitments. The commitments will be defined as a Diablo peD Notification (OM) type notification as a commitment. Each Commitment Data Record (CDR) will contain source information and document links, a statement of commitment, and implementing documents or links. In PIMS, these are "stale" statements. In SAP, the links can be actual "hot" links and the files can pop up when they are clicked. The implementation will be performed with a pool of clerks, who will clean-up the statements by making them declarative if possible, remove procedure reference in the statements, standardize the acronyms and abbreviations, and make the links "hot." SAP is being implemented during the month of September. Based on the above, the NRC staff has concluded that PG&E has addressed this issue with the implementation of SAP.
3.0 CONCLUSION
The NRC staff concludes that, based on the above audit findings, (1) PG&E has an adequate program to implement and manage regulatory commitments, (2) PG&E has an adequate program to implement and manage changes to regulatory commitments, (3) PG&E has an adequate program for identifying regulatory commitments in outgoing correspondence to the NRC, and (4) PG&E has a consolidated mechanism to track implementation of regulatory commitments, such as identification of which commitment is being tracked by which tracking subsystem and how that commitment is being implemented.
-6 4.0 PG&E PERSONNEL CONTACTED FOR THIS AUDIT Tom Grozan, Licensing Engineer, Regulatory Services Department Ken Schrader, Licensing Engineer, Regulatory Services Department Steve Zawalick, Senior Engineer, Regulatory Services Department Principal Contributor: A. Wang Date: October 22, 2008
TABLE -PG&E'S REGULATORY COMMITMENTS REVIEWED Source Document Licensee Description Implementation Status Tracking No.
DCL-06-139 A0732998 Implement revised EALs Missed, NR review determined due human error. Corrective action taken.
DCL-06-141 A0694315 Risk-Informed TS Initiative 5b Due 10/15/2008 DCL-04-123 A0617136 TSTF-369 removal of monthly Completed operating reports and occupational radiation exposure report DCL-05-018 A0632222 W Star Alternate Repair Completed Criteria TS DCL-08-011 A0733803 NRC Bulletin 2007-01, Completed Security Officer Attentiveness DCL-07-099 A0690550 Pressurizer Weld Overlays Completed Relief Request DCL-08-012 A0690337 Revise RWST TS level Completed A0716463 NRC GL 2008-01, Managing Due 10/15/2008 DCL-08-032 Gas Accumulation A0685022 Relief Request NDE-SBR Completed DCL-06-013 regarding testing of snubbers A0736973 90-Day Response to GL Due 11/3/08 GL 2004-02 2004-02 supplemental RAI Supplemental RAI DCL-07-019 Confirmatory action letter Complete A0688744 additional actions for pressurizer welds
October 22, 2008 J. Conway -2 The NRC staff concludes, based on the audit, that PG&E has implemented NRC commitments on a timely basis and has implemented an effective program for managing NRC commitment changes at Diablo Canyon Power Plant. Details of the audit are set forth in the enclosed audit report.
Sincerely,
./RAI Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323
Enclosure:
Audit Report cc w/encl: See next page Additional Distribution via ListServ DISTRIBUTION:
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