ML082820255

Audit of the Licensee'S Management of Regulatory Commitments (TAC Nos. MD9551 and MD9552)

ML082820255
Person / Time
Site:	Susquehanna
Issue date:	10/21/2008
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Mckinney B Susquehanna
vaidya B, NRR/Dorl/lpl1-1, 415-3308
References
TAC MD9551, TAC MD9552
Download: ML082820255 (9)

Text

October 21, 2008 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 - AUDIT OF THE LICENSEE'S MANAGEMENT OF REGULATORY COMMITMENTS (TAC NOS. MD9551 AND MD9552)

Dear Mr. McKinney:

On May 27, 2003, the Office of Nuclear Reactor Regulation Office Instruction LIC-105, "Managing Regulatory Commitments Made by Licensees to the NRC [Nuclear Regulatory Commission]," was published. LIC-105, which is publicly available electronically from the Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Room on the Internet at the NRC web site (Accession Number ML022750041), provides the NRC staff and its stakeholders with a common reference for handling regulatory commitments made by licensees for commercial nuclear reactors to the NRC staff. The guidance is consistent with the industry guidance prepared by the Nuclear Energy Institute (NEI), NEI 99-04, "Guidance for Managing NRC Commitment Changes." LIC-105 specifies that once every 3 years, the NRC staff will audit a licensee's commitment management program.

On September 22-24, 2008, an audit of the commitment management program for PPL Susquehanna, LLC (PPL, the licensee) was performed onsite and in the NRC office. The NRC staff concludes that, based on the audit (1) PPL had implemented NRC commitments on a timely basis; and (2) PPL's program for managing NRC commitment changes is effective.

Details of the audit are set forth in the enclosed audit report.

If you have any questions, please contact me at 301-415-3308.

Sincerely,

/RA/

Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

As stated cc w/encl: Distribution via ListServe

ML082820255 OFFICE LPLI-1/GE LPLI-1/PM LPLI-1/LA LPLI-1/BC NAME JGall BVaidya SLittle MKowal DATE 10/17/08 10/17/08 10/16/08 10/21/08 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSEE MANAGEMENT OF REGULATORY COMMITMENTS SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-387 AND 388

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 NRR Project Manager to 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 (amendments, reliefs, exemptions, etc.) and activities (bulletins, generic letters (GLs), etc.). The audit is to be performed every 3 years.

2.0 AUDIT PROCEDURE AND RESULTS An audit of the Susquehanna Steam Electric Stations, (SSES) commitment management program was performed at SSES and NRC Headquarters during the period of September 22-24, 2008. The audit reviewed commitments made since the previous audit on August 24, 2004.

The audit consisted of two major parts: (1) verification of the licensees implementation of NRC commitments that have been completed and (2) verification of the licensees program for managing changes to NRC commitments.

In support of the audit, the NRC staff reviewed several of SSES's procedures related to commitment management, NDAP-QA-0750, Revision 5 through 7, "Regulatory Open Items/Commitments." Specifically, NDAP-QA-0750, Revision 7, was compared to the guidance Enclosure

in NEI 99-04 and the NRR Office Instruction, LIC-105. In general, the licensee's procedure follows the guidance closely: it sets forth the need for identifying, tracking and reporting commitments, and it provides a mechanism for changing commitments. The NRC staff concluded that the licensee's procedures appropriately implemented NEI guidance, NEI 99-04 for commitment management. The remainder of the audit evaluated the effectiveness of the procedures by exploring the products produced by the procedures.

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 the regulatory commitments made to the NRC as part of past licensing actions/activities. For commitments that were in progress, the NRC staff aimed to ascertain that they have been captured in an effective program for future completion.

2.1.1 Audit Scope Before the audit, the NRC staff used TRIM to generate a licensing action report for each of the Susquehanna Units starting at the date of the last commitment audit, August 24, 2004. The licensing action documents were searched for commitments that fit the LIC-105 definition.

Several license amendments, a relief request, and generic letter resolution letters were selected for review, as listed in Table 1.

LIC-105 limits the audit of commitments to those made in writing to the NRC as a result of past licensing actions (amendments, exemptions, etc.) or licensing activities (bulletins, GLs, etc.).

Accordingly, the audit excluded the following types of commitments:

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 (RAI) by a certain date). Fulfillment of these commitments was indicated by the fact that the subject licensing action/activity was completed. Several commitments related to RAIs were reviewed to provide a larger sample and better compare the licensee's documents to their procedures.

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.

4. Commitments that have been made during the NRC Review of the License Renewal Application (TAC Nos. MD3019 and MD3020). The NRC staff review has not been completed for the licensees application for renewal of the license.

5. The steps to implement the License Conditions imposed as the result of the NRC approval of the Amendment for Extended Power Uprate for Unit 1 and Unit 2 (TAC Nos.

MD3309 and MD3310). The licensee termed these steps as Commitments.

Table 1 contains the entire population of SSES regulatory commitments for the audit time period covered, with the above exclusions.

2.1.2 Audit Results The NRC staff reviewed reports generated by the licensee's commitment tracking program, Nuclear Information Management System (NIMS), to evaluate the status of the commitments listed in Table 1. The licensees commitments are entered into NIMS either as Action Required (AR) or Management Action Request (MRA). The licensee's NIMS produces a report on each AR or MRA. Each report is identified by an AR or MRA number as the case may be.

Sometimes there is an overall package number in addition to individual task numbers for each component of the commitment. The NRC staff reviewed the reports, when available, for each of the commitments listed in Table 1 to evaluate the status of completion of various components of each commitment. In general, each commitment comprises multiple components, such as revising appropriate plant procedures, revising appropriate sections of the UFSAR, revising training manuals, and training personnel. The NRC staff reviewed the information associated with each commitment to determine the status of completion. The NRC staff found that all of the commitments had been satisfactorily addressed. While the NRC staff found that the licensee's NIMS captured most of the regulatory commitments that were identified by the NRC staff before the audit, there were some commitments as identified in Table 1, that did not have tracking numbers, but did have packages to document the completed work that satisfied the commitment. Most often the commitments with no tracking number were associated with the implementation of an amendment and did not have their own tracking number.

The NRC staff also reviewed other sources of information, in particular NRC correspondence relating to licensee submittals, to verify implementation of commitments. The review results are shown in the last column on the right of Table 1, where appropriate.

Table 1 lists the commitments audited and summarizes what the NRC staff observed as the current status of licensee commitments. The NRC staff has no basis to dispute the implementation status of these regulatory commitments.

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 licensees 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 SSES is contained in NDAP-QA-0750, Revision 7. The audit reviewed commitment changes that included changes that were or will be reported to the NRC. The audit also verifies that the licensees 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 Regarding changes to commitments, Section 6.3 of NDAP-QA-0750 "Regulatory Open Items/Commitments," Revision 7, specifically refers to the guidance of NEI-99-04. Attachments A, B, and C of NDAP-QA-0750, Revision 7, provide details of the Regulatory Commitment Change Evaluation process. Before changing a commitment, the licensee answers various

questions related to the commitment's importance to continued safety. Commitments meeting the procedure requirements can be changed with or without notifying the NRC, depending on the circumstances. The NRC staff found that commitments were changed in accordance with licensee procedures and that the only types of changes made by the licensee, for the commitments in this audit, were changes in the completion date.

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 licensee's NIMS information, as well as information from other sources, the NRC staff found no reason to differ from the licensee's reported status of the audited commitments.

3.0 CONCLUSION

Based on the above audit, the NRC staff concludes that, (1) the licensee had implemented NRC commitments on a timely basis; and (2) the licensee's program for managing NRC commitment changes is effective.

However, the NRC staff noted that that the NIMS system, used by the licensee, is very complicated, even for the licensee staff, to retrieve desired information, and the procedure used by the licensee to manage commitments could be more specific. Therefore, the NRC staff would like to make the following recommendations for improvements:

a) The licensees procedure, NDAP-QA-0750, "Regulatory Open Items/Commitments,"

should clearly provide instructions for entering the commitments (preferably by the staff from Nuclear Regulatory Affairs (NRA)), in NIMS, i.e. the classification of each regulatory commitment as MRA-NRA and a group of regulatory commitments as AR-NRA.

b) Even though completion of the work related to the commitment was signed off on the work flow on the MRA data sheets by the supervisor/manager of the group, the commitment should be closed by the staff from NRA.

c) Similar to the process flow chart for changing the commitments, the process flow diagram for entering (documenting), implementing (completing), and closing the commitment should be included in the procedure, NDAP-QA-0750.

4.0 LICENSEE PERSONNEL CONTACTED FOR THIS AUDIT D. Brophy D. Filchner N Coddington B. O'Rourke Principal Contributors: B. Vaidya J. Gall Date: October 21, 2008

TABLE 1 AUDITED WRITTEN COMMITMENTS AND RELATED INFORMATION (AUGUST 2004 THROUGH AUGUST 2008)

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 1 AR 672390 PLA-5768 PPL will review changes to the plant operating parameters, MC1181 Closed 12/21/07 MRA 624024 and PRA model changes for the effects on the RI-ISI Program ML051370346 once per inspection period RAI Response on Relief Request 2 AR 672390 PLA-5768 PPL will resolve the remainder of the Peer Review Level B MC1181 In Progress MRA 673299 Facts and Observations prior to the next scheduled model ML051370346 periodic update. RAI Response on Relief Request 3 MRA 942206 PLA-6315 Verified stress tables for the final as-built dryer will be provided MD3309-10 Closed 1/9/08 to NRC demonstrating that the maximum stress intensities in ML073620458 the replacement steam dryer are lower than the maximum Amendment stress intensity reported in Reference A and thus would satisfy Supplement the licensing basis ASME Code fatigue limit of 13,600 PSI.

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 4 MRA 942207 PLA-6315 The complete verified stress report will be provided to the MD3309-10 Closed 1/25/08 NRC. ML073620458 Amendment Supplement 5 AR 9359553 PLA-6308 No maintenance or testing that affects the remaining ML673470232 In Progress MRA 935616 OPERABLE Unit 1 and Unit 2 4160 V subsystems will be MD4766 scheduled while Unit 2 TS 3.8.1 Note 3 is in effect. If any RAI Response testing or maintenance activities must be performed during this TS change time, and evaluation will be performed in accordance with 10 CFR Section 50.65(a)(4) 6 MRA 935617 PLA-6308 During the application of Unit 2 TS 3.8.2 Note 3, verify that the ML673470232 In Progress required systems, subsystems, trains, components, and MD4766 devices that depend on the remaining 4160 V busses are RAI Response OPERABLE. TS change 7 MRA 935618 PLA-6308 During the application of Unit 2 TS 3.8.2 Note 3, the Unit 2 ML673470232 In Progress safety-related HPIC and RCIC pumps will be controlled as MD4766 protected equipment and will not be taken out of service for RAI Response planned maintenance while a Unit 1 4160 V bus is out of TS change service for extended maintenance.

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 8 RA 882296 PLA-6225 Enhanced visual testing (EVT-1) of the top guide grid beams MD3309-10 Closed, new will be performed in accordance with GE SIL 554 following ML071710442 database entry sample selection and inspection frequency of BWRVIP-47 for EPU: RAI made.

CRD guide tubes. That is, inspections will be performed on Response Database is 10% of the total populations of cells within twelve years, and Supplement used to generate 5% of the population within 6 years. The sample locations scope list for selected for examination will be in areas that are exposed to inspections.

the highest fluence. This inspection plan will be implemented until and NRC approved resolution is developed in accordance with the BWRVIP and implemented at SSES Unit 1 and 2.

9 AR 718776 PLA-5901 PPL Susquehanna, LLC will establish TS Bases for LCO 3.0.8, MD0011 Closed 10/31/06 which provide guidance and details on how to implement the ML060410106 new requirements LCO 3.0.8 requires that risk be managed CLIP and assessed. The Bases will also state that while the Industry Amendment and NRC guidance on implementation of 10 CFR 50.65(a)(4), Application the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rules process to the extent possible so that the maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one ore more snubbers are not able to perform their associated support function.

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 10 No PLA-6128 Provide Supplemental Information including: (1) Summary of MD3309-10 (1) & (2)

Commitment proposed steam dryer structural modifications (2) The results ML063120119 closed No. See of the final finite element analysis at 120% original licensed EPU 12/4/06 Section 2.1.2 thermal power (OLTP base on the final dryer structural Application configuration) (3) ASME load combination tables based on the (3) & (4) 120% OLTP condition (4) A description of the steam dryer closed power ascension test plan 12/26/06 11 No PLA-5882 PPL Susquehanna, LLC has verified that a hydrogen MC8642-3 Closed, Commitment monitoring system capable of diagnosing beyond design-basis ML052850297 Implemented No. See accidents is installed at SSES Unit 1 and Unit 2 and is making CLIP along with Section 2.1.2 regulatory commitment to maintain that capability. The Application amendment hydrogen monitors will be included in the Technical Requirements Manual.

12 No PLA-5882 SSES Units 1 and 2 has an interted containment. PPL MC8642-3 Closed, Commitment Susquehanna, LLC has verified that and oxygen monitoring ML052850297 Implemented No. See system capable of verifying the status of the interted CLIP along with Section 2.1.2 containment is installed at SSES Units 1 and 2 and is making a Application amendment regulatory commitment to maintain that capability. The oxygen monitors will be included in the Technical Requirements Manual.

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 13 AR 691111 PLA-5888 Each licensee should make a regulatory commitment to MC8644 Closed, provide to the NRC using an industry database the operating ML052850299 Amendments data (monthly) that is described in GL 97-02 Revised CLIP 233 & 210 Contents of the monthly Operating Report, by the last day of Application approved the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industrys CDE program, currently being developed and maintained by the Institute of Nuclear Power Operations).

14 AR 715643 PLA-5967 PPL commits to confirm the adequacy of the channel bow MC8626 Closed 10/21/05 assumption used in the redesigned core. ML053040074 MCPR Amendment Application 15 AR 900790 PLA-5834 The Mururoa V4 MTH2 dingle use suit will be integrated into MC5634 Closed by CRA 901747 PPL Susquehannas, LLC respiratory program using the ML043630029 NDAP-QA-0624 information provided by the manufacturer. Request for Rev 5 exemption 16 AR 900790 PLA-5834 New lesson plans will be developed to train workers on MC5634 Closed by CRA 901747 Mururoas features, donning, use and removal, cautions and ML043630029 HP267-Use of use of mouth strip and tear off strips for routine emergency Request for Bubble Suit egress. exemption Rev 0

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 17 AR 900790 PLA-5834 Radiation Protection personnel will be provided additional MC5634 Closed by CRA 901747 training for selection, approval, issue, equipment set-up, ML043630029 HP-TP-750 operation and maintenance instructions for the Mururoa suit. Request for Rev 12 &

exemption HP-TP-751 Rev 17 18 AR 611545 PLA-5734 The performance of the damper motor replacement has been MD4423-4 Closed 7/29/05 MRA 611546 added to the dual-unit shutdown list. Should that opportunity ML042600070 occur prior to the planned replacement, the motors will be Proposed replaces at that time and thus the proposed change will not be amendment used.

19 AR 611545 PLA-5734 Provision will be made to restore Secondary Containment and MD4423-4 Closed 9/30/05 MRA 611555 the Standby Gas Treatment System to be functional, within ML042600070 200 minutes of an accident initiation Proposed amendment 20 AR 611545 PLA-5734 To minimize the damper motor replacement time, experienced MD4423-4 Closed 7/29/05 MRA 611556 personnel will perform the damper motor replacement. ML041950092 Proposed amendment 21 AR 611545 PLA-5734 The following mitigating measures will be taken to increase the MD4423-4 Closed 10/7/05 MRA 611557 ability to identify and take appropriate actions before a problem ML042600070 arises. -Engineering Inspections of Containment will be Proposed performed. These will include

• Testing for leak tightness of the amendment Secondary Containment Structure per TS SR 3.634.1.4 and 3.6.4.1.5.

• Testing for Secondary Containment Bypass Leakage paths *7 more see actual document

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 22 AR 611545 PLA-5734 External Events monitoring: Geomagnetic activity from solar MD4423-4 Closed 8/1/05 MRA 611559 storms will be monitored via forecasts provided to the PJM. ML042600070 Proposed amendment 23 AR 611545 PLA-5734 The SSES Risk Management Process will asses the impacts MD4423-4 Closed 7/29/05 MRA 611563 of planned and emergent work prior to and during the damper ML042600070 motor replacement. Proposed amendment 24 AR 611545 PLA-5734 The following systems and components will be required to be MD4423-4 Closed 9/30/05 MRA 611564 available during damper motor replacement to reduce the plant ML042600070 risk. Elective maintenance will not be performed on these Proposed systems and components. Any failed system or component will amendment be returned to operable status as soon as possible. (The failed system/component shall be worked around the clock.) If one of these systems or components becomes unavailable or inoperable, SSES will immediately begin and promptly complete an evaluation to determine is the basis for the proposed one-time change to LCOs 3.6.4.2.1 and 3.6.4.3 remain valid, and within one hour of identification, contact the NRC Resident Inspector.

25 No PLA-5659 First response to GL 2003-01 No specifically defined ML032310442 NA Commitment commitments, but referenced by all other letters while Response to No. See describing the Control Room Habitability commitments. Generic Letter Section 2.1.2

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 26 No PLA-5711 PPL commits to providing a dose consequence submittal to ML040760752 In progress Commitment the NRC, using the methodology described in Regulatory Response to No. See Guide 1.183, Alternative Radiological Source Terms For Generic Letter Section 2.1.2 Evaluating Design Basis Accidents at Nuclear Power Reactors.

27 No PLA-5711 PPL will notify NRC if the release of an inventory of hazardous ML040760752 Completed Commitment chemicals, transported by railroad, is not imminent. [or] If the Response to No. See inventory of hazardous chemicals that are transported by the Generic Letter Section 2.1.2 railway is received by July 30th, 2004, PPL will complete the hazardous chemical control room habitability assessment.

28 No PLA-5711 PPL will commit to comply with Revision 1 or Reg Guide 1.78, ML040760752 Completed Commitment Evaluating the Habitability of a Nuclear Power Plant Control Response to No. See Room During a Postulated Hazardous Chemical Release. Generic Letter Section 2.1.2 This commitment will be incorporated into the FSAR.

29 No PLA-5711 PPL commits to perform and transmit the results of an ML040760752 Completed Commitment integrated tracer gas test using the standard test method Response to No. See described in the American Society for Testing Materials Generic Letter Section 2.1.2 (ASTM) consensus standard E741 Standard Test Method for Determining Air Change in a Single Zone by Means of Tracer Gas Dilution, and the results of the corresponding dose consequence analysis.

30 No PLA-5711 PPL will perform an assessment of the delta P Technical ML040760752 Completed Commitment Specification and determine if changes to the Technical Response to No. See Specification are required. Generic Letter Section 2.1.2

Item No. Licensee's Licensee's Summary of Commitment NRC TAC No. Licensee Commitment Submittal and NRC Implementation Tracking Document Status Number (AR is like a package number and MRA is like a subtask) 31 No PLA-5861 Provides updates on completed components and date ML050530188 NA Commitment changes to commitments from PLA-5711 Response to No. See Generic Letter Section 2.1.2 32 No PLA-5916 Provides updates on completed components and date ML051890066 NA Commitment changes to commitments from PLA-5711, PLA-5861 Final No. See Resolution of Section 2.1.2 Generic Letter 2003-01